On November 08, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Kim, Dae Joon,
and
Krouse, John H,
The University Of Texas-Rio Grande Valley,
for All Other Civil Cases (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Filed
6/22/2023 8:03 PM
Hidalgo County District Clerks
Reviewed By: Faith Martinez
CAUSE NO. C-4343-22-D
DAE JOON KIM § IN THE DISTRICT COURT
Plaintiff, §
§
v. §
§ HIDALGO COUNTY, TEXAS
THE UNIVERSITY OF TEXAS RIO §
GRANDE VALLEY §
Defendant. § 206th JUDICIAL DISTRICT
COUNSEL FOR DEFENDANT THE UNIVERSITY OF TEXAS RIO GRANDE
VALLEY’S MOTION TO APPEAR REMOTELY BASED ON MEDICAL CONDITION
TO THE HONORABLE JUDGE OF SAID COURT:
The undersigned counsel of record for Defendant The University of Texas Rio Grande
Valley (“UTRGV”) files this Motion to Appear Remotely at any hearing scheduled before July 14,
2023, including the hearing on UTRGV’s Motion to Stay Discovery, based on counsel’s medical
condition. As indicated by counsel’s vacation letter filed on June 21, 2023, counsel will be taking
a period of parental leave on or before July 14, 2023, continuing for twelve weeks. Before that
date, counsel is available to appear remotely for a hearing, but is unable to travel to appear in
person. Counsel respectfully requests that she be allowed to appear at any hearing scheduled before
July 14, 2023 remotely, if the Court is able to so accommodate.
Respectfully submitted,
John Scott
Provisional Attorney General
BRENT WEBSTER
First Assistant Attorney General
GRANT DORFMAN
Deputy First Assistant Attorney General
SHAWN COWLES
Deputy Attorney General for Civil Litigation
Electronically Filed
6/22/2023 8:03 PM
Hidalgo County District Clerks
Reviewed By: Faith Martinez
KIMBERLY GDULA
Deputy Chief, General Litigation Division
RYAN KERCHER
Deputy Chief, General Litigation Division
/s/ Mary Quimby
MARY QUIMBY
Texas Bar No. 24132506
Assistant Attorney General
General Litigation Division
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
(512) 463-4651 / Fax (512) 320-0667
mary.quimby@oag.texas.gov
COUNSEL FOR DEFENDANT
THE UNIVERSITY OF TEXAS RIO GRANDE
VALLEY
CERTIFICATE OF CONFERENCE
I hereby certify that on June 21-22, 2023, I attempted to confer with Plaintiff’s counsel,
William Mount, regarding the relief requested in this motion. I did not hear back regarding whether
Mr. Mount was opposed to this motion.
CERTIFICATE OF SERVICE
I hereby certify that on June 22, 2023, a true and correct copy of the foregoing instrument
has been served in accordance with Tex. R. Civ. P. 21a via the Court’s electronic filing manager
and via email to:
William Mount, Jr.
1100 E. Jasmine Ave., Ste. 202
McAllen, TX 78501
office@daleklein.com
COUNSEL FOR PLAINTIFF
/s/ Mary Quimby
MARY QUIMBY
Assistant Attorney General
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Laura Hendrix on behalf of Mary Quimby
Bar No. 24132506
Laura.Hendrix@oag.texas.gov
Envelope ID: 76891152
Filing Code Description: Motion (No Fee)
Filing Description: TO APPEAR REMOTELY BASED ON MEDICAL
CONDITION
Status as of 6/23/2023 8:02 AM CST
Associated Case Party: The University of Texas-Rio Grande Valley
Name BarNumber Email TimestampSubmitted Status
Laura Hendrix laura.hendrix@oag.texas.gov 6/22/2023 8:03:56 PM SENT
Mary Quimby mary.quimby@oag.texas.gov 6/22/2023 8:03:56 PM SENT
Associated Case Party: DaeJoonKim
Name BarNumber Email TimestampSubmitted Status
William D.Mount, Jr. office@daleklein.com 6/22/2023 8:03:56 PM SENT
KATIE KLEIN office@dklawllp.com 6/22/2023 8:03:56 PM SENT
Document Filed Date
June 22, 2023
Case Filing Date
November 08, 2022
Category
All Other Civil Cases (OCA)
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Electronically Filed 6/22/2023 8:03 PM Hidalgo County District Clerks Reviewed By: Faith Martinez CAUSE NO. C-4343-22-D DAE JOON KIM § IN THE DISTRICT COURT Plaintiff, § § v. § § HIDALGO COUNTY, TEXAS THE UNIVERSITY OF TEXAS RIO § GRANDE VALLEY § Defendant. § 206th JUDICIAL DISTRICT COUNSEL FOR DEFENDANT THE UNIVERSITY OF TEXAS RIO GRANDE VALLEY’S MOTION TO APPEAR REMOTELY BASED ON MEDICAL CONDITION TO THE HONORABLE JUDGE OF SAID COURT: The undersigned counsel of record for Defendant The University of Texas Rio Grande Valley (“UTRGV”) files this Motion to Appear Remotely at any hearing scheduled before July 14, 2023, including the hearing on UTRGV’s Motion to Stay Discovery, based on counsel’s medical condition. As indicated by counsel’s vacation letter filed on June 21, 2023, counsel will be taking a period of parental leave on or before July 14, 2023, continuing for twelve weeks. Before that date, counsel is available to appear remotely for a hearing, but is unable to travel to appear in person. Counsel respectfully requests that she be allowed to appear at any hearing scheduled before July 14, 2023 remotely, if the Court is able to so accommodate. Respectfully submitted, John Scott Provisional Attorney General BRENT WEBSTER First Assistant Attorney General GRANT DORFMAN Deputy First Assistant Attorney General SHAWN COWLES Deputy Attorney General for Civil Litigation Electronically Filed 6/22/2023 8:03 PM Hidalgo County District Clerks Reviewed By: Faith Martinez KIMBERLY GDULA Deputy Chief, General Litigation Division RYAN KERCHER Deputy Chief, General Litigation Division /s/ Mary Quimby MARY QUIMBY Texas Bar No. 24132506 Assistant Attorney General General Litigation Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 (512) 463-4651 / Fax (512) 320-0667 mary.quimby@oag.texas.gov COUNSEL FOR DEFENDANT THE UNIVERSITY OF TEXAS RIO GRANDE VALLEY CERTIFICATE OF CONFERENCE I hereby certify that on June 21-22, 2023, I attempted to confer with Plaintiff’s counsel, William Mount, regarding the relief requested in this motion. I did not hear back regarding whether Mr. Mount was opposed to this motion. CERTIFICATE OF SERVICE I hereby certify that on June 22, 2023, a true and correct copy of the foregoing instrument has been served in accordance with Tex. R. Civ. P. 21a via the Court’s electronic filing manager and via email to: William Mount, Jr. 1100 E. Jasmine Ave., Ste. 202 McAllen, TX 78501 office@daleklein.com COUNSEL FOR PLAINTIFF /s/ Mary Quimby MARY QUIMBY Assistant Attorney General Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Laura Hendrix on behalf of Mary Quimby Bar No. 24132506 Laura.Hendrix@oag.texas.gov Envelope ID: 76891152 Filing Code Description: Motion (No Fee) Filing Description: TO APPEAR REMOTELY BASED ON MEDICAL CONDITION Status as of 6/23/2023 8:02 AM CST Associated Case Party: The University of Texas-Rio Grande Valley Name BarNumber Email TimestampSubmitted Status Laura Hendrix laura.hendrix@oag.texas.gov 6/22/2023 8:03:56 PM SENT Mary Quimby mary.quimby@oag.texas.gov 6/22/2023 8:03:56 PM SENT Associated Case Party: DaeJoonKim Name BarNumber Email TimestampSubmitted Status William D.Mount, Jr. office@daleklein.com 6/22/2023 8:03:56 PM SENT KATIE KLEIN office@dklawllp.com 6/22/2023 8:03:56 PM SENT