On January 07, 2022 a
Stipulation,Agreement
was filed
involving a dispute between
Cruz Romero, Ana,
Romero, Nuvia,
and
Lauber, Joshua Hayes,
State Farm Mutual Automobile Insurance Company,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
4/17/2024 8:54 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Kryshawna Charleston DEPUTY
CAUSE NO. DC-22-00255
NUVIA ROMERO § IN THE DISTRICT COURT OF
§
§
Plaintiff, §
§
v. § DALLAS COUNTY, TEXAS
§
JOSHUA HAYES LAUBER AND STATE §
FARM MUTUAL AUTOMOBILE §
INSURANCE COMPANY §
§
§
§
§
Defendants. § 116TH JUDICIAL DISTRICT
PARTIES THIRD AGREED MOTION FOR CONTINUAN CE
AND REQUEST FOR NEW DOCKET CONTROL ORDER
Plaintiff, Nuvia Romero, and Defendant,]oshua Hayes Lauber file this Third Agreed Motion
for Continuance and Request for Entry of New Docket Control Order and respectfully Show unto
the Court as follows:
I.
This case is set for trial on April 22nd, 2024 in Dallas County, Texas. This is the third trial
setting and the third request for continuance by any party in this case.
II.
The Parties request a continuance Of at least 150 days as further discovery is necessary in this
matter. The Parties have been diligent in prosecuting this matter to this point. However, attorney
Connor Colemere will be departing Alford 8c Clark, PLLC. See Exhibit A, Declaration of Connor
Colemere. With Mr. Colemere’s departure from Plaintiff’ s counsel, Plaintiff will be unable to
prepare for and attend trial. It is expected all trial preparations for this case Will be completed Within
the time frame
requested for a continuance.
III.
All Parties have agreed t0 this request for continuance and issuance of a new docket control
order. This continuance is not sought for delay, but so that justice may be done.
Prayer
All Parties respectfully request that the Court GRANT this Agreed Motion for Continuance
and Request for New Docket Control Order, reset this case for at least 150 days, and for such other
and fiarther relief, in law and in equity, to which they may be justly entitled.
Respectfully submitted,
ALFORD & CLARK PLLC
[:1 lamb Alford
Jacob R. Alford
SBN: 24088856
4538 Walzem Road
San Antonio, Texas 78218
Telephone: (210) 951-9467
Facsimile: (800) 347-1865
servicealford@injuredtexan.com
ATTORNEYS FOR PLAINTIFF
-and—
/J'/ Blaise Wilton? :igned wit/9 ,Demz'm'on
Blaise Wilcott
SBN: 24086481
THE LECRONE LAW FIRM, PC
123 North Crockett Street, Suite 200
Sherman, Texas 75090
Telephone: (903) 813-1900
Facsimile: (903) 813-1944
eservice@lecronelaw.com
ATTORNEY FOR DEFENDANT
CERTIFICATE OF CONFERENCE
The Parties have conferred and each party is in agreement with the matters raised in the
foregoing motion.
[:1 lamb Alford
Jacob Alford
PLAINTIFF’S APPROVAL
The Plaintist has conferred With her attorney and approves and is in agreement With the
matters raised in the foregoing motion.
50
“ uvia Cruz (Apr 17, 2024 13:55 CDT]
/.r/
Nuvia Romero, Plaintiff
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing was served in accordance with the Texas Rules of
Civil Procedure upon all attorney of record.
/:/ lamb Alford
Jacob Alford
EXHIBIT A
CAUSE NO. DC-22-00255
NU V IA ROMERO IN THE DISTRICT COURT OF
§§§§§§§§§
Plaintzffi
V.
DALLAS COUNTY, TEXAS
JOSHUA HAYES LAUBER AND STATE
FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY,
Defendant. 116th JUDICIAL DISTRICT
DECLARATION OF CONNOR COLEMERE
1. My name is Connor Colemere. I am over 18 years of age. I am of sound mind and
competent to make this declaration. I have personal knowledge of the facts stated herein, and I
can attest that all the facts stated herein are true and correct.
2. I am an attorney licensed in the State of Texas, and I am employed by the law firm
Alford & Clark, PLLC.
3. I am departing the firm for personal reasons. Furthermore, Counsel is set for
another trial in Williamson County, Texas at the same time as this case. Such case has been called
to trial beginning on Monday. As it stands, this case would benefit from further discovery and
mediation.
4. This continuance is not being sought merely for delay, but so that justice may be
done.
My name is Connor R. Colemere, my date of birth is January 24, 1990, and my address is
4538 Walzem Rd., San Antonio, Texas 78218. I declare under penalty of perjury that the foregoing
is true and correct.
Executed in Bexar County, State of Texas, on the 17th day of April, 2024
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.
Jacob Alford on behalf of Jacob Alford
Bar No. 24088856
servicealford@injuredtexan.com
Envelope ID: 86788830
Filing Code Description: Motion - Continuance
Filing Description: 3RD AGREED W/ REQUEST FOR NEW DOCKET
CONTROL ORDER
Status as of 4/18/2024 8:56 AM CST
Associated Case Party: JOSHUAHAYESLAUBER
Name BarNumber Email TimestampSubmitted Status
John W.Breeze eservice@lecronelaw.com 4/17/2024 8:54:01 PM SENT
Associated Case Party: ANA CRUZ ROMERO
Name BarNumber Email Timestam pSubmitted Status
JACOB RALFORD service@injuredtexan.com 4/17/2024 8:54:01 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Carlos A.Balido BalidoEDocsNotifications@wbclawfirm.com 4/17/2024 8:54:01 PM SENT
Jacob Alford servicealford@injuredtexan.com 4/17/2024 8:54:01 PM SENT
Document Filed Date
April 17, 2024
Case Filing Date
January 07, 2022
Category
MOTOR VEHICLE ACCIDENT
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FILED 4/17/2024 8:54 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Kryshawna Charleston DEPUTY CAUSE NO. DC-22-00255 NUVIA ROMERO § IN THE DISTRICT COURT OF § § Plaintiff, § § v. § DALLAS COUNTY, TEXAS § JOSHUA HAYES LAUBER AND STATE § FARM MUTUAL AUTOMOBILE § INSURANCE COMPANY § § § § § Defendants. § 116TH JUDICIAL DISTRICT PARTIES THIRD AGREED MOTION FOR CONTINUAN CE AND REQUEST FOR NEW DOCKET CONTROL ORDER Plaintiff, Nuvia Romero, and Defendant,]oshua Hayes Lauber file this Third Agreed Motion for Continuance and Request for Entry of New Docket Control Order and respectfully Show unto the Court as follows: I. This case is set for trial on April 22nd, 2024 in Dallas County, Texas. This is the third trial setting and the third request for continuance by any party in this case. II. The Parties request a continuance Of at least 150 days as further discovery is necessary in this matter. The Parties have been diligent in prosecuting this matter to this point. However, attorney Connor Colemere will be departing Alford 8c Clark, PLLC. See Exhibit A, Declaration of Connor Colemere. With Mr. Colemere’s departure from Plaintiff’ s counsel, Plaintiff will be unable to prepare for and attend trial. It is expected all trial preparations for this case Will be completed Within the time frame requested for a continuance. III. All Parties have agreed t0 this request for continuance and issuance of a new docket control order. This continuance is not sought for delay, but so that justice may be done. Prayer All Parties respectfully request that the Court GRANT this Agreed Motion for Continuance and Request for New Docket Control Order, reset this case for at least 150 days, and for such other and fiarther relief, in law and in equity, to which they may be justly entitled. Respectfully submitted, ALFORD & CLARK PLLC [:1 lamb Alford Jacob R. Alford SBN: 24088856 4538 Walzem Road San Antonio, Texas 78218 Telephone: (210) 951-9467 Facsimile: (800) 347-1865 servicealford@injuredtexan.com ATTORNEYS FOR PLAINTIFF -and— /J'/ Blaise Wilton? :igned wit/9 ,Demz'm'on Blaise Wilcott SBN: 24086481 THE LECRONE LAW FIRM, PC 123 North Crockett Street, Suite 200 Sherman, Texas 75090 Telephone: (903) 813-1900 Facsimile: (903) 813-1944 eservice@lecronelaw.com ATTORNEY FOR DEFENDANT CERTIFICATE OF CONFERENCE The Parties have conferred and each party is in agreement with the matters raised in the foregoing motion. [:1 lamb Alford Jacob Alford PLAINTIFF’S APPROVAL The Plaintist has conferred With her attorney and approves and is in agreement With the matters raised in the foregoing motion. 50 “ uvia Cruz (Apr 17, 2024 13:55 CDT] /.r/ Nuvia Romero, Plaintiff CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was served in accordance with the Texas Rules of Civil Procedure upon all attorney of record. /:/ lamb Alford Jacob Alford EXHIBIT A CAUSE NO. DC-22-00255 NU V IA ROMERO IN THE DISTRICT COURT OF §§§§§§§§§ Plaintzffi V. DALLAS COUNTY, TEXAS JOSHUA HAYES LAUBER AND STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant. 116th JUDICIAL DISTRICT DECLARATION OF CONNOR COLEMERE 1. My name is Connor Colemere. I am over 18 years of age. I am of sound mind and competent to make this declaration. I have personal knowledge of the facts stated herein, and I can attest that all the facts stated herein are true and correct. 2. I am an attorney licensed in the State of Texas, and I am employed by the law firm Alford & Clark, PLLC. 3. I am departing the firm for personal reasons. Furthermore, Counsel is set for another trial in Williamson County, Texas at the same time as this case. Such case has been called to trial beginning on Monday. As it stands, this case would benefit from further discovery and mediation. 4. This continuance is not being sought merely for delay, but so that justice may be done. My name is Connor R. Colemere, my date of birth is January 24, 1990, and my address is 4538 Walzem Rd., San Antonio, Texas 78218. I declare under penalty of perjury that the foregoing is true and correct. Executed in Bexar County, State of Texas, on the 17th day of April, 2024 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. Jacob Alford on behalf of Jacob Alford Bar No. 24088856 servicealford@injuredtexan.com Envelope ID: 86788830 Filing Code Description: Motion - Continuance Filing Description: 3RD AGREED W/ REQUEST FOR NEW DOCKET CONTROL ORDER Status as of 4/18/2024 8:56 AM CST Associated Case Party: JOSHUAHAYESLAUBER Name BarNumber Email TimestampSubmitted Status John W.Breeze eservice@lecronelaw.com 4/17/2024 8:54:01 PM SENT Associated Case Party: ANA CRUZ ROMERO Name BarNumber Email Timestam pSubmitted Status JACOB RALFORD service@injuredtexan.com 4/17/2024 8:54:01 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Carlos A.Balido BalidoEDocsNotifications@wbclawfirm.com 4/17/2024 8:54:01 PM SENT Jacob Alford servicealford@injuredtexan.com 4/17/2024 8:54:01 PM SENT