Motion,Ex Parte: SALDANA & SALDANA ENTERPRISES, LLC D/B/A S & S ENTERPRISES, LLC, AS AGENT FOR FREIGHT ALL KINDS, INC VS. MARISOL TREVINO AKA MARI ALMEIDA

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                                Electronically Submitted
                                                                                        3/22/2024 3:30 PM
                                                                                      Hidalgo County Clerk
                                                                              Accepted by: Alexis Medina


                                CAUSE NO. CL-19-6011-J

SALDANA & SALDANA ENTERPRISES, LLC                    §        IN THE COUNTY COURT
D/B/A S & S ENTERPRISES, LLC                          §
AS AGENT FOR FREIGHT ALL KINDS, INC.                  §
Plaintiff,                                            §
                                                      §
V.                                                    §                 AT LAW NO. 10
                                                      §
MARISOL TREVINO A/K/A MARI ALMEIDA                    §
Defendant.                                            §     HIDALGO COUNTY, TEXAS


                      PLAINTIFF'S MOTION FOR CONTINUANCE


TO THE HONORABLE JUDGE OF SAID COURT:

         NOW COMES Plaintiff SALDANA & SALDANA ENTERPRISES, LLC D/B/A S &

S ENTERPRISES, LLC AS AGENT FOR FREIGHT ALL KINDS, INC., Movant herein,

and brings this Motion for Continuance of the trial on March 25, 2024, and in support

hereof, shows the Court the following:

                                             I.

         This continuance is sought so that justice may be done, and not for purposes of

delay.

                                            II.

         A.    Trial is scheduled for March 25, 2024, at 8:30 a.m.

         B.    Plaintiff requests the trial on March 25, 2024 to be continued because

Plaintiff's attorney, ROLANDO CANTU, has a schedule conflict on that date. Plaintiff's

attorney is scheduled to appear in the United States District Court for the Southern

District of Texas for Case No. 7:24-cr-00145 on the same date and at the same time.
                                                                                       Electronically Submitted
                                                                                            3/22/2024 3:30 PM
                                                                                          Hidalgo County Clerk
                                                                                Accepted by: Alexis Medina


      WHEREFORE, PREMISES CONSIDERED, Plaintiff SALDANA & SALDANA

ENTERPRISES, LLC D/B/A S & S ENTERPRISES, LLC AS AGENT FOR FREIGHT

ALL KINDS, INC., Movant herein, requests this Court to grant this Motion for

Continuance of the trial on March 25, 2024 and to continue this case for at least 30

days, and for such other and further relief that may be awarded at law or in equity.

                                         Respectfully submitted,


                                         By: /s/Rolando Cantu
                                         ROLANDO CANTU
                                         Texas Bar No. 00789201
                                         1111 W. Nolana Avenue
                                         McAllen, Texas 78504
                                         Tel: (956) 687-5777
                                         Fax: (956) 435-7238
                                         Email: rcantu@cantulawfirm.com

                                         Attorney for Plaintiff




                              CERTIFICATE OF SERVICE

       I hereby certify that on March 22, 2024, a true and correct copy of Plaintiff's
Motion for Continuance was electronically served on all parties and counsel of record
via the eFile.TXCourts.gov electronic filing system.



                                         /s/Rolando Cantu
                                         ROLANDO CANTU
                         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.

Rolando Cantu
Bar No. 789201
rcantu@cantulawfirm.com
Envelope ID: 85871739
Filing Code Description: Motion (No Fee)
Filing Description: PLAINTIFF'S MOTION FOR CONTINUANCE
Status as of 3/22/2024 3:36 PM CST

Associated Case Party: MARISOL TREVINO

Name              BarNumber Email                      TimestampSubmitted Status

MARISOL TREVINO             marisoltrevino87@gmail.com 3/22/2024 3:30:41 PM   SENT