On July 10, 2017 a
!MTN:OTHER MOTION
was filed
involving a dispute between
Tran , Cuc Kim,
and
Luong , Thuan Cam,
for DIVORCE W/CHILD (FAMILY LAW)
in the District Court of Travis County.
Preview
3/14/2018 5:01 PM
Velva L. Price
District Clerk
Travis County
NOTICE: THIS DOCUMENT D-1-FM-17-004221
Selene Cruz Lara
CONTAINS SENSITIVE DATA
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CAUSE NO. D-1-FM-17-004221
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IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §
L.
§
CUC KIM TRAN §
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AND § 98TH JUDICIAL DISTRICT
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THUAN CAM LUONG §
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§
AND IN THE INTEREST OF §
TRACY TUYET LUONG AND KEVIN § TRAVIS COUNTY, TEXAS
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DUY LUONG, CHILDREN §
er
Cl
MOTION FOR INTERIM ATTORNEY’S FEES
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This Motion for Interim Attorneys Fees is brought by Cuc Kim Tran, Petitioner, who
shows in support:
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Petitioner requests the Court, after notice and hearing, for the preservation of the property
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and protection of the parties, to make temporary orders and issue any appropriate temporary
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injunctions regarding attorney's fees as deemed necessary and equitable, including but not
limited to the following:
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Petitioner requests that Respondent be ordered to pay reasonable interim attorney’s fees
of $15,000 for fees and expenses, including but not limited to: multiple property appraisals,
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business appraisals, multiple enforcement hearings, exchange of discovery, mediation, and a
final trial. Petitioner is not in control of sufficient community assets to pay attorney’s fees and
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anticipated expenses.
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Cuc Kim Tran prays that the Court grant the Motion for Interim Attorney’s Fees.
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Respectfully submitted,
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THOMPSON SALINAS LONDERGAN LLP
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8140 N. Mopac
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Westpark 4, Suite 250
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Austin, Texas 78759
Tel: (512) 201-4083
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Fax: (512) 298-1129
Un
MOTION FOR INTERIM ATTORNEY’S FEES
IMMO TRAN AND LUONG, ITIO LUONG CHILDREN PAGE 1 OF 3
By: /s/ - Marshall A. Thompson
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Marshall A. Thompson
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State Bar No. 24059139
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marshall@centraltexaslawyers.com
Attorney for Petitioner
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NOTICE OF HEARING
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The above motion is set for hearing on March 22, 2018 at 8:30 a.m. at the Travis County
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Courthouse, 1000 Guadalupe, Austin, Texas 78701.
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MOTION FOR INTERIM ATTORNEY’S FEES
IMMO TRAN AND LUONG, ITIO LUONG CHILDREN PAGE 2 OF 3
CERTIFICATE OF SERVICE
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I certify that a true copy of the above was served on each attorney of record or party in
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accordance with the Texas Rules of Civil Procedure on March 14, 2018.
Pr
/s/ Marshall A. Thompson
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Marshall A. Thompson
Attorney for Petitioner
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Via E-Service
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Richard Olivo
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Attorney at Law
1333 Shore District Dr., Suite 1350
Austin, Texas 78741
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(512) 971-0110
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rick@olivolaw.com
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MOTION FOR INTERIM ATTORNEY’S FEES
IMMO TRAN AND LUONG, ITIO LUONG CHILDREN PAGE 3 OF 3
Document Filed Date
March 14, 2018
Case Filing Date
July 10, 2017
Category
DIVORCE W/CHILD (FAMILY LAW)
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3/14/2018 5:01 PM Velva L. Price District Clerk Travis County NOTICE: THIS DOCUMENT D-1-FM-17-004221 Selene Cruz Lara CONTAINS SENSITIVE DATA e ic CAUSE NO. D-1-FM-17-004221 Pr IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § L. § CUC KIM TRAN § a AND § 98TH JUDICIAL DISTRICT lv THUAN CAM LUONG § Ve § AND IN THE INTEREST OF § TRACY TUYET LUONG AND KEVIN § TRAVIS COUNTY, TEXAS k DUY LUONG, CHILDREN § er Cl MOTION FOR INTERIM ATTORNEY’S FEES ct This Motion for Interim Attorneys Fees is brought by Cuc Kim Tran, Petitioner, who shows in support: tri Petitioner requests the Court, after notice and hearing, for the preservation of the property is and protection of the parties, to make temporary orders and issue any appropriate temporary D injunctions regarding attorney's fees as deemed necessary and equitable, including but not limited to the following: . Co Petitioner requests that Respondent be ordered to pay reasonable interim attorney’s fees of $15,000 for fees and expenses, including but not limited to: multiple property appraisals, is business appraisals, multiple enforcement hearings, exchange of discovery, mediation, and a final trial. Petitioner is not in control of sufficient community assets to pay attorney’s fees and av anticipated expenses. Tr Cuc Kim Tran prays that the Court grant the Motion for Interim Attorney’s Fees. y op Respectfully submitted, c THOMPSON SALINAS LONDERGAN LLP l 8140 N. Mopac ia Westpark 4, Suite 250 fic Austin, Texas 78759 Tel: (512) 201-4083 of Fax: (512) 298-1129 Un MOTION FOR INTERIM ATTORNEY’S FEES IMMO TRAN AND LUONG, ITIO LUONG CHILDREN PAGE 1 OF 3 By: /s/ - Marshall A. Thompson e Marshall A. Thompson ic State Bar No. 24059139 Pr marshall@centraltexaslawyers.com Attorney for Petitioner L. NOTICE OF HEARING a The above motion is set for hearing on March 22, 2018 at 8:30 a.m. at the Travis County lv Courthouse, 1000 Guadalupe, Austin, Texas 78701. Ve k er Cl ct tri D is . Co is av Tr y op c l ia fic of Un MOTION FOR INTERIM ATTORNEY’S FEES IMMO TRAN AND LUONG, ITIO LUONG CHILDREN PAGE 2 OF 3 CERTIFICATE OF SERVICE e I certify that a true copy of the above was served on each attorney of record or party in ic accordance with the Texas Rules of Civil Procedure on March 14, 2018. Pr /s/ Marshall A. Thompson L. Marshall A. Thompson Attorney for Petitioner a Via E-Service lv Richard Olivo Ve Attorney at Law 1333 Shore District Dr., Suite 1350 Austin, Texas 78741 k (512) 971-0110 er rick@olivolaw.com Cl ct tri D is . Co is av Tr y op c l ia fic of Un MOTION FOR INTERIM ATTORNEY’S FEES IMMO TRAN AND LUONG, ITIO LUONG CHILDREN PAGE 3 OF 3