On June 26, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Stricklen, Haskell Glen,
and
Brown, Krista Lynne,
for Divorce without Children
in the District Court of Denton County.
Preview
IN THE MATTER OF
THE MARRIAGE OF
HASKELL GLEN STRICKLEN
AND
KRISTA BROWN STRICKLEN
KENNETH C. KRAMER, JENNIFER C.
BROWN, AND CHARLES A. BROWN,
AND CHARLES A. BROWN LIVING
NO. 18-5535-362
IN THE DISTRICT COURT
362ND JUDICIAL DISTRICT
AAMAMAMNMM
TRUST, MOVANTS AND INTERVENORS § DENTON COUNTY, TEXAS
MOTION FOR CONTINUANCE
This Motion for Continuance is brought by Haskell Glen Stricklen, Petitioner, who
shows in support:
as
Respondent's Motion for Appointment of Receiver is presently set for
hearing on January 3, 2019 at 2:30 p.m. This hearing was set by counsel
for Respondent on December 13, 2018.
On December 12, 2018, counsel for Petitioner had informed counsel for
Respondent that we were unable to agree to a date this soon because it
would not allow for discovery to be conducted prior to the hearing. Counsel
for Petitioner requested for additional dates more than 30 days out to allow
for discovery.
Respondent is the sole financial earner of the marriage and has been since
early 2016. Respondent has sole access to the parties’ financial accounts,
including the account for the mortgage on the parties’ residence and for
financial accounts used to pay the mortgage.
Petitioner does not have access to any of the parties’ financial accounts or
accounts regarding the home that Respondent is seeking the appointment
of a receiver to sell. Petitioner needs further time for investigation prior to
a hearing being held for the appointment of a receiver.
Counsel for Petitioner sent discovery requests to counsel for Respondent
on December 20, 2018. Responses are currently due on January 21, 2019.
The parties’ residence is not presently subject to foreclosure proceedings
and resetting this hearing until after Respondent's discovery responses are
due would not cause irreparable loss to the community estate.
Petitioner has not previously requested a continuance in this suit.
MOTION FOR CONTINUANCE - Stricklen — Page 1 of 3Bs This continuance is not sought for delay, but that justice may be done.
9. Given the necessity of filing this motion, Haskell Glen Stricklen respectfully
requests that the Court order Krista Brown Stricklen to pay reasonable
attorney's fees and costs as provided by law, for the filing and prosecution
of this motion.
WHEREFORE, PREMISES CONSIDERED, Haskell Glen Stricklen prays that the
Court grant this Motion for Continuance, order reasonable attorney's fees and costs, and
for all further relief authorized by law.
Respectfully submitted,
BEAL LAW FIRM, PLLC
2920 W. Southlake Blvd., Ste. 140
Southlake, Texas 76092
Tel: (817) 261-4333
Fax: (817) 281-0086
www.DFWDIVORCE.com
E-Service: texfile@dfwdivorce.com
By:_/s/ Timothy J. Alexander _
Eric D. Beal
State Bar No. 01949950
Constance A. Mims
State Bar No. 24060284
Timothy J. Alexander
State Bar No. 24093856
Attorneys for Haskell Glen Stricklen
MOTION FOR CONTINUANCE - Stricklen — Page 2 of 3Verification
The undersigned states under oath: "| am the attorney for the movant in the
foregoing Motion for Continuance. | have read the motion. The statements contained in
the motion are within my personal knowledge and are true and correct."
Timothy J. Alexander
Attorney for Haskell Glen Stricklen
SIGNED under oath before me on Ir1o | | ¢ .
CASSIDY L. PEARSON CA Me™ '
jotary Public, State of Texas Notary Public, State of Texas
tomm. Expires 01-23-2021
Notary ID 130974267
Certificate of Service
| certify that a true copy of the above was served on each attorney of record or
party in accordance with the Texas Rules of Civil Procedure on December 21, 2018, to
wit:
Roger M. Yale Via e-Service: roger@yalelawgroup.com
John M. Rogers Via e-Service: john.rogers@rogersilp.com
/s/ Timothy J. Alexander
Timothy J. Alexander
Attorney for Haskell Glen Stricklen
MOTION FOR CONTINUANCE — Stricklen — Page 3 of 3
Preview
IN THE MATTER OF THE MARRIAGE OF HASKELL GLEN STRICKLEN AND KRISTA BROWN STRICKLEN KENNETH C. KRAMER, JENNIFER C. BROWN, AND CHARLES A. BROWN, AND CHARLES A. BROWN LIVING NO. 18-5535-362 IN THE DISTRICT COURT 362ND JUDICIAL DISTRICT AAMAMAMNMM TRUST, MOVANTS AND INTERVENORS § DENTON COUNTY, TEXAS MOTION FOR CONTINUANCE This Motion for Continuance is brought by Haskell Glen Stricklen, Petitioner, who shows in support: as Respondent's Motion for Appointment of Receiver is presently set for hearing on January 3, 2019 at 2:30 p.m. This hearing was set by counsel for Respondent on December 13, 2018. On December 12, 2018, counsel for Petitioner had informed counsel for Respondent that we were unable to agree to a date this soon because it would not allow for discovery to be conducted prior to the hearing. Counsel for Petitioner requested for additional dates more than 30 days out to allow for discovery. Respondent is the sole financial earner of the marriage and has been since early 2016. Respondent has sole access to the parties’ financial accounts, including the account for the mortgage on the parties’ residence and for financial accounts used to pay the mortgage. Petitioner does not have access to any of the parties’ financial accounts or accounts regarding the home that Respondent is seeking the appointment of a receiver to sell. Petitioner needs further time for investigation prior to a hearing being held for the appointment of a receiver. Counsel for Petitioner sent discovery requests to counsel for Respondent on December 20, 2018. Responses are currently due on January 21, 2019. The parties’ residence is not presently subject to foreclosure proceedings and resetting this hearing until after Respondent's discovery responses are due would not cause irreparable loss to the community estate. Petitioner has not previously requested a continuance in this suit. MOTION FOR CONTINUANCE - Stricklen — Page 1 of 3Bs This continuance is not sought for delay, but that justice may be done. 9. Given the necessity of filing this motion, Haskell Glen Stricklen respectfully requests that the Court order Krista Brown Stricklen to pay reasonable attorney's fees and costs as provided by law, for the filing and prosecution of this motion. WHEREFORE, PREMISES CONSIDERED, Haskell Glen Stricklen prays that the Court grant this Motion for Continuance, order reasonable attorney's fees and costs, and for all further relief authorized by law. Respectfully submitted, BEAL LAW FIRM, PLLC 2920 W. Southlake Blvd., Ste. 140 Southlake, Texas 76092 Tel: (817) 261-4333 Fax: (817) 281-0086 www.DFWDIVORCE.com E-Service: texfile@dfwdivorce.com By:_/s/ Timothy J. Alexander _ Eric D. Beal State Bar No. 01949950 Constance A. Mims State Bar No. 24060284 Timothy J. Alexander State Bar No. 24093856 Attorneys for Haskell Glen Stricklen MOTION FOR CONTINUANCE - Stricklen — Page 2 of 3Verification The undersigned states under oath: "| am the attorney for the movant in the foregoing Motion for Continuance. | have read the motion. The statements contained in the motion are within my personal knowledge and are true and correct." Timothy J. Alexander Attorney for Haskell Glen Stricklen SIGNED under oath before me on Ir1o | | ¢ . CASSIDY L. PEARSON CA Me™ ' jotary Public, State of Texas Notary Public, State of Texas tomm. Expires 01-23-2021 Notary ID 130974267 Certificate of Service | certify that a true copy of the above was served on each attorney of record or party in accordance with the Texas Rules of Civil Procedure on December 21, 2018, to wit: Roger M. Yale Via e-Service: roger@yalelawgroup.com John M. Rogers Via e-Service: john.rogers@rogersilp.com /s/ Timothy J. Alexander Timothy J. Alexander Attorney for Haskell Glen Stricklen MOTION FOR CONTINUANCE — Stricklen — Page 3 of 3