On December 06, 2016 a
Motion,Ex Parte
was filed
involving a dispute between
Carr, Robert,
Franklin, Individually, Clifford,
and
Andrews Cleaning Service,
Johnson, Benjamin Kyle,
for Injury/Damage - Motor Vehicle
in the District Court of Smith County.
Preview
Electronically Filed
8/26/2019 10:01 AM
Penny Clarkston, Smith County District Clerk
Reviewed By: Lana Fields
CAUSE NO.: 16-2497-A
ROBERT CARR and CLIFFORD § IN THE COUNTY COURT
FRANKLIN, INDIVIDUALLY AND AS §
NEXT FRIEND OF JAMYLON RAY, §
A MINOR §
Plaintiffs, § 7th JUDICIAL DISTRICT
§
vs. §
§
BENJAMIN KYLE JOHNSON and §
ANDREWS CLEANING SERVICE §
Defendants § SMITH COUNTY, TEXAS
AGREED MOTION FOR CONTINUANCE
TO THE HONORABLE COURT:
COME NOW, Plaintiffs and Defendant, and file this Agreed Motion for Continuance and
for grounds would show unto the Court the following:
I.
This matter is currently set on the Court’s trial docket for the two-week period beginning
September 23, 2019. This is the third trial setting of this matter.
II.
New counsel has recently made an appeared on Defendants behalf which requires
additional time for the attorney to familiarize himself with the case. The parties agree that there
remains additional discovery which must be accomplished before this matter would be ready for
trial. The parties request the Court to reset the trial of this matter for 180 days from the current
trial setting of September 23, 2019.
Page 1 of 3
III.
This is the third Agreed Motion for Continuance and it is not made for delay only, but so
that justice may be done.
WHEREFORE, PREMISES CONSIDERED, the parties pray that the Court grant this third
Agreed Motion for Continuance and re-set this matter for trial, and for all other and further relief
to which the parties may be entitled.
Respectfully submitted,
PIERCE SKRABANEK, PLLC
/s/ Eduardo J. Garza
______________________________
MICHAEL E. PIERCE
State Bar No. 24039117
EDUARDO J. GARZA
State Bar No. 24099892
3701 Kirby Drive, Suite 760
Houston, Texas 77098
Telephone: (832) 690-7000
Facsimile: (832) 616-5576
E-mail: eduardo@pstriallaw.com
E-service: service@pstriallaw.com
ATTORNEYS FOR PLAINTIFF
LAW OFFICES OF DAVID C. KLOSTERBOER
____________________________________
RYAN MARTIN
State Bar No. 24086522
19450 State Highway 249, Suite 475
Houston, TX 77070
Telephone: (281)877-3300
Facsimile: (877) 369-4882
E-mail:Ryan.Martin@thehartford.com
ATTORNEYS FOR DEFENDANTS
Page 2 of 3
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing instrument has been sent to all interested counsel
by facsimile and/or electronic service on August 23, 2019.
/s/ Eduardo J. Garza
EDUARDO J. GARZA
Page 3 of 3
Document Filed Date
August 26, 2019
Case Filing Date
December 06, 2016
Category
Injury/Damage - Motor Vehicle
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Electronically Filed 8/26/2019 10:01 AM Penny Clarkston, Smith County District Clerk Reviewed By: Lana Fields CAUSE NO.: 16-2497-A ROBERT CARR and CLIFFORD § IN THE COUNTY COURT FRANKLIN, INDIVIDUALLY AND AS § NEXT FRIEND OF JAMYLON RAY, § A MINOR § Plaintiffs, § 7th JUDICIAL DISTRICT § vs. § § BENJAMIN KYLE JOHNSON and § ANDREWS CLEANING SERVICE § Defendants § SMITH COUNTY, TEXAS AGREED MOTION FOR CONTINUANCE TO THE HONORABLE COURT: COME NOW, Plaintiffs and Defendant, and file this Agreed Motion for Continuance and for grounds would show unto the Court the following: I. This matter is currently set on the Court’s trial docket for the two-week period beginning September 23, 2019. This is the third trial setting of this matter. II. New counsel has recently made an appeared on Defendants behalf which requires additional time for the attorney to familiarize himself with the case. The parties agree that there remains additional discovery which must be accomplished before this matter would be ready for trial. The parties request the Court to reset the trial of this matter for 180 days from the current trial setting of September 23, 2019. Page 1 of 3 III. This is the third Agreed Motion for Continuance and it is not made for delay only, but so that justice may be done. WHEREFORE, PREMISES CONSIDERED, the parties pray that the Court grant this third Agreed Motion for Continuance and re-set this matter for trial, and for all other and further relief to which the parties may be entitled. Respectfully submitted, PIERCE SKRABANEK, PLLC /s/ Eduardo J. Garza ______________________________ MICHAEL E. PIERCE State Bar No. 24039117 EDUARDO J. GARZA State Bar No. 24099892 3701 Kirby Drive, Suite 760 Houston, Texas 77098 Telephone: (832) 690-7000 Facsimile: (832) 616-5576 E-mail: eduardo@pstriallaw.com E-service: service@pstriallaw.com ATTORNEYS FOR PLAINTIFF LAW OFFICES OF DAVID C. KLOSTERBOER ____________________________________ RYAN MARTIN State Bar No. 24086522 19450 State Highway 249, Suite 475 Houston, TX 77070 Telephone: (281)877-3300 Facsimile: (877) 369-4882 E-mail:Ryan.Martin@thehartford.com ATTORNEYS FOR DEFENDANTS Page 2 of 3 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing instrument has been sent to all interested counsel by facsimile and/or electronic service on August 23, 2019. /s/ Eduardo J. Garza EDUARDO J. GARZA Page 3 of 3