Preview
Electronically Filed
5/15/2018 2:15 PM
Lois Rogers, Smith County District Clerk
Reviewed By: J oyce Lawrence
CAUSE NO. 16-2498-C
DOUG JENSEN and CINDY JENSEN, § IN THE DISTRICT COURT
Plaintiffs
VS. § 241st JUDICIAL DISTRICT
TRENT WILLIAMS CONSTRUCTION §
MANAGEMENT, LLC. §
Defendant § SMITH COUNTY, TEXAS
UONOPPOSED MOTION TO WITHDRAW AS COUNSEL FOR PLAINTIFFS
TO THE HONORABLE JUDGE OF SAID COURT:
Movant, ADAM B. ALLEN, Attormey for Plaintiffs, Doug and Cindy Jensen, (hereinafter
called Plaintiffs), and brings this Unopposed Motion for Withdrawal of Counsel on behalf of Plaintiffs
and in support thereof, shows the Court the following:
I
Movant would show the Court that he is unable to effectively represent the Plaintiffs. In
addition, Plaintiffs have requested the undersigned to withdraw as counsel. Therefore, good cause exists
for withdrawal of counsel. Movant would request that he be allowed to withdraw so that Plaintiffs may
proceed pro se or retain new counsel pursuant to Plaintiffs’ request.
i.
This withdrawal is not sought only for delay, but that Plaintiffs might be represented by
counsel of their choice or pro se.
mm.
The settings and deadlines in this case are as follows:
Trial — July 19, 2018
A confirmed copy of the Agreed Docket Control Order is attached hereto as Exhibit “A”.
Iv.
This Motion is not sought for the purposes of delay.
Vv.
A copy of this motion bearing the enclosed notice has been delivered to the last known address of
Plaintiffs at:
Doug and Cindy Jensen
1227 Rainmaker
Tyler, TX 75703
VI.
Plaintiffs are hereby notified in writing of the right to object to this motion.
NOTICE
You are hereby notified that this Motion for Withdrawal of Counsel is being filed with
the Court. You do not have to agree to this motion. If you wish to contest the withdrawal of
Adam B. Allen as your attorney, you should request that this matter be set for a hearing.
WHEREFORE, PREMISES CONSIDERED, Movant pmys that the Court enter an order discharging
Movant as attomey of record for Plaintiffs, Doug and Cindy Jensen, and for such other and further relief that
may be awarded at law or in equity.
Respectfully submitted,
WHITE ,SHAVER
205 W, Lotust
Tyler, Texas 75702
Telephone: 903/533-9447
Telefax: 903/595-3766
By:
ADAM B. ALLEN
Bar No. 24038738
aallen@whiteshaverlaw.com
ATTORNEY FOR PLAINTIFFS
CERTIFICATE OF CONFERENCE
Thereby certify that I have conferred with counsel for Defendant, G. Blake Thompson, on
this 15" day of May, 2018 and he is unopposed to the filing of this Motion.
Cee —
Adam. B. Allen
CERTIFICATE OF SERVICE
T hereby certify that a true and correct copy of the above and foregoing instrument has
been forwarded to all counsel of record and Plaintiffs pro se, Doug and Cindy Jensen, in
accordance with the Texas Rules of Civil Procedure on this the is® day of May, 2018.
CEE
Adam. B. Allen
ee -
CAUSE NO. 16-2498-C
DOUG JENSEN and CINDY JENSEN, iN THE pidericEtouk?
Plaintiffs,
HAR 2:7 268
24' st
DIC}
fete eat
TRENT WILLIAMS CONSTRUCTION
MANAGEMENT, LLC wn
Defendant. SMITH COUNTY, TEXAS
TRIAL SETTING AND PRE-TRIAL ORDER
ORDERING CASE TO MEDIATION
AND SCHEDULING ORDER
The Court ORDERS this case be set for docket call and trial on the following date:
BENCH TRIAL: WEEK BEGINNING suit) 2018 @
AT 8:30 A.M.
Scheduling of Case
Based on the information available to the court, the following scheduling order shall
apply to this case unless modified by the court. If no date is given below, the item is governed
by the Texas Rules of Civil Procedure. The Court ORDERs that the following deadlines be met
and actions taken by the parties, as follows:
wae JOINDER. All parties must be added and served, whether by
amendment or third party practice, by this date: THE PARTY
CAUSING THE JOINDER SHALL PROVIDE A COPY OF
THIS SCHEDULING ORDER AT THE TIME OF SERVICE.
2 nia EXPERT WITNESS DESIGNATION.
3. June 1, 2018 ALTERNATIVE DISPUTE RESOLUTION. By this
date the parties must in writing filed with the court
designate an agreed mediator. If no designation is filed
the court will designate a mediator.
Agreed Scheduling Order Page Sola
EXHIBIT
¥
4. DISCOVERY DEADLINE. All discovery requests and deposition
notices must be filed by this date. Counsel may initiate discovery
beyond this deadline by agreement, however incomplete discovery will
NOT DELAY the trial date.
5. n/a FACT WITNESSES LISTS. A list including the name,
address, phone number, and topic of testimony of each
fact witness who may be called at trial must be filed by
this date. Fact witnesses not listed in compliance with
this paragraph will not be permitted to testify absent a
showing of good cause. This list is not a substitute for |
any required interrogatory supplementation,
6. wa
na PLEADINGS. All amendments must be filed by this
date. This order does not preclude prompt filing of
pleadings directly responsive to any timely filed
pleadings.
7. wa JOINT PRE-TRIAL ORDER, JOINT PROPOSED SPECIAL
ISSUES, MOTIONS IN LIMINE.
One Day ESTIMATED DAYS OF TRIAL,
9. —wa PRETRIAL CONFERENCE, 8:30 A.M.
10. July , 018 TRIAL SETTING DATE. EXHIBITS & EXHIBIT
LISTS
The parties may by written agreement alter these deadlines,
4s/ G. Blake Thompson (by permission)
Plaintiffs’ Counsel Signature Defense Counsel Signature
{attach signature page) (attach signature page)
Mpsor
Plaintiff's Counsel Printed Name Defense Counsel Printed Name
Agreed Scheduling Order Page Solo
"4
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scaxen ano ren vin ae fl yo ! la ) » 2018,
HO
Chef Lhe LEN
3LE JACK SKEEN, Judge
Lp
24 strictCo, Smit County, Te
Agreed Scheduling Order Page Solo
Preview
Electronically Filed 5/15/2018 2:15 PM Lois Rogers, Smith County District Clerk Reviewed By: J oyce Lawrence CAUSE NO. 16-2498-C DOUG JENSEN and CINDY JENSEN, § IN THE DISTRICT COURT Plaintiffs VS. § 241st JUDICIAL DISTRICT TRENT WILLIAMS CONSTRUCTION § MANAGEMENT, LLC. § Defendant § SMITH COUNTY, TEXAS UONOPPOSED MOTION TO WITHDRAW AS COUNSEL FOR PLAINTIFFS TO THE HONORABLE JUDGE OF SAID COURT: Movant, ADAM B. ALLEN, Attormey for Plaintiffs, Doug and Cindy Jensen, (hereinafter called Plaintiffs), and brings this Unopposed Motion for Withdrawal of Counsel on behalf of Plaintiffs and in support thereof, shows the Court the following: I Movant would show the Court that he is unable to effectively represent the Plaintiffs. In addition, Plaintiffs have requested the undersigned to withdraw as counsel. Therefore, good cause exists for withdrawal of counsel. Movant would request that he be allowed to withdraw so that Plaintiffs may proceed pro se or retain new counsel pursuant to Plaintiffs’ request. i. This withdrawal is not sought only for delay, but that Plaintiffs might be represented by counsel of their choice or pro se. mm. The settings and deadlines in this case are as follows: Trial — July 19, 2018 A confirmed copy of the Agreed Docket Control Order is attached hereto as Exhibit “A”. Iv. This Motion is not sought for the purposes of delay. Vv. A copy of this motion bearing the enclosed notice has been delivered to the last known address of Plaintiffs at: Doug and Cindy Jensen 1227 Rainmaker Tyler, TX 75703 VI. Plaintiffs are hereby notified in writing of the right to object to this motion. NOTICE You are hereby notified that this Motion for Withdrawal of Counsel is being filed with the Court. You do not have to agree to this motion. If you wish to contest the withdrawal of Adam B. Allen as your attorney, you should request that this matter be set for a hearing. WHEREFORE, PREMISES CONSIDERED, Movant pmys that the Court enter an order discharging Movant as attomey of record for Plaintiffs, Doug and Cindy Jensen, and for such other and further relief that may be awarded at law or in equity. Respectfully submitted, WHITE ,SHAVER 205 W, Lotust Tyler, Texas 75702 Telephone: 903/533-9447 Telefax: 903/595-3766 By: ADAM B. ALLEN Bar No. 24038738 aallen@whiteshaverlaw.com ATTORNEY FOR PLAINTIFFS CERTIFICATE OF CONFERENCE Thereby certify that I have conferred with counsel for Defendant, G. Blake Thompson, on this 15" day of May, 2018 and he is unopposed to the filing of this Motion. Cee — Adam. B. Allen CERTIFICATE OF SERVICE T hereby certify that a true and correct copy of the above and foregoing instrument has been forwarded to all counsel of record and Plaintiffs pro se, Doug and Cindy Jensen, in accordance with the Texas Rules of Civil Procedure on this the is® day of May, 2018. CEE Adam. B. Allen ee - CAUSE NO. 16-2498-C DOUG JENSEN and CINDY JENSEN, iN THE pidericEtouk? Plaintiffs, HAR 2:7 268 24' st DIC} fete eat TRENT WILLIAMS CONSTRUCTION MANAGEMENT, LLC wn Defendant. SMITH COUNTY, TEXAS TRIAL SETTING AND PRE-TRIAL ORDER ORDERING CASE TO MEDIATION AND SCHEDULING ORDER The Court ORDERS this case be set for docket call and trial on the following date: BENCH TRIAL: WEEK BEGINNING suit) 2018 @ AT 8:30 A.M. Scheduling of Case Based on the information available to the court, the following scheduling order shall apply to this case unless modified by the court. If no date is given below, the item is governed by the Texas Rules of Civil Procedure. The Court ORDERs that the following deadlines be met and actions taken by the parties, as follows: wae JOINDER. All parties must be added and served, whether by amendment or third party practice, by this date: THE PARTY CAUSING THE JOINDER SHALL PROVIDE A COPY OF THIS SCHEDULING ORDER AT THE TIME OF SERVICE. 2 nia EXPERT WITNESS DESIGNATION. 3. June 1, 2018 ALTERNATIVE DISPUTE RESOLUTION. By this date the parties must in writing filed with the court designate an agreed mediator. If no designation is filed the court will designate a mediator. Agreed Scheduling Order Page Sola EXHIBIT ¥ 4. DISCOVERY DEADLINE. All discovery requests and deposition notices must be filed by this date. Counsel may initiate discovery beyond this deadline by agreement, however incomplete discovery will NOT DELAY the trial date. 5. n/a FACT WITNESSES LISTS. A list including the name, address, phone number, and topic of testimony of each fact witness who may be called at trial must be filed by this date. Fact witnesses not listed in compliance with this paragraph will not be permitted to testify absent a showing of good cause. This list is not a substitute for | any required interrogatory supplementation, 6. wa na PLEADINGS. All amendments must be filed by this date. This order does not preclude prompt filing of pleadings directly responsive to any timely filed pleadings. 7. wa JOINT PRE-TRIAL ORDER, JOINT PROPOSED SPECIAL ISSUES, MOTIONS IN LIMINE. One Day ESTIMATED DAYS OF TRIAL, 9. —wa PRETRIAL CONFERENCE, 8:30 A.M. 10. July , 018 TRIAL SETTING DATE. EXHIBITS & EXHIBIT LISTS The parties may by written agreement alter these deadlines, 4s/ G. Blake Thompson (by permission) Plaintiffs’ Counsel Signature Defense Counsel Signature {attach signature page) (attach signature page) Mpsor Plaintiff's Counsel Printed Name Defense Counsel Printed Name Agreed Scheduling Order Page Solo "4 ° * scaxen ano ren vin ae fl yo ! la ) » 2018, HO Chef Lhe LEN 3LE JACK SKEEN, Judge Lp 24 strictCo, Smit County, Te Agreed Scheduling Order Page Solo