Motion,Ex Parte: Julio Mondragon, Maria Del Carmen De La Cruz v. Rongos Inc

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                                Filed: 4/20/2023 6:13 PM
                                                                                                                Clerk
                                                                                               Allen County, Indiana
                                                                                                                  ED



STATE OF INDIANA             )                      IN THE ALLEN SUPERIOR COURT
                             )§:
COUNTY OF ALLEN              )                      CAUSE NO.: 02D03-2301-CT-000059

JULIO MONDRAGON and                          )
MARIA DEL CARMEN DE LA CRUS                  )
GONZALEZ As Co-Personal                      )
Representatives of the ESTATE OF             )
REBECA GARCIA SALAZAR,                       )
       Plaintiffs,                           )
                                             )
       vs.                                   )
                                             )
RONGOS, INC.,                                )
    Defendant.                               )


         PLAINTIFFS’ VERIFIED MOTION TO VACATE, CONTINUE AND RESET
           THE APRIL 27, 2023 2:30 P.M. CASE MANAGEMENT CONFERENCE


       COME NOW, the Plaintiffs, Julio Mondragon and Maria Del Carmen De La Crus

Gonzalez, as Co-Personal Representatives, by counsel, Samuel L. Bolinger, and file their verified

motion to vacate, continue and reset the case management conference of April 27, 2023 at 2:30

p.m. and states:

1.     The parties are doing discovery.

2.     Defendant’s counsel has been contacted and has no objection.

3.     Samuel L. Bolinger is in trial on April 27 and 28, 2023 in State v. Gerald Scott Black,

       Huntington Superior Court, Cause No. 35D01-2208-F6-000245. It is first setting and

       ready to be tried.

4.     The parties have commenced settlement discussions.

5.     Said continuance is not to bias, prejudice or harm the Defendant.

6.     No trial dates have been scheduled nor mediator selected.
       WHEREFORE, Plaintiffs move the Court to vacate, continue and reset the April 27, 2023

2:30 p.m. case management conference, and for all other just and proper relief.

       I, the undersigned, swear and affirm under the pains and penalties of perjury that the

above-foregoing is true and accurate.

                                        Respectfully submitted,

                                        /s/ Samuel L. Bolinger
                                        Samuel L. Bolinger, #10786-98
                                        803 S. Calhoun St., Ste. 300
                                        Fort Wayne, IN 46802
                                        Tel: 260.407.0040
                                        Fax: 260.407.0039
                                        Email: mark@slbolingerlaw.com
                                        Counsel for Plaintiffs

                      PROOF OF NOTICE UNDER TRIAL RULE 72(D):

        A copy of this entry was served either by mail to the address of record, deposited in the
Court’s attorney’s distribution box, distributed personally upon the person (s), via the Indiana E-
Filing System, and/or filed as listed below:


James J. Shea
jshea@hsk-law.com

Scott L. Bunnell
sbunnell@hsk-law.com

Date of Notice:        April 20, 2023


                                                      /s/ Samuel L. Bolinger
                                                      Samuel L. Bolinger