On February 03, 2005 a
Motion,Ex Parte
was filed
involving a dispute between
State Farm Lloyds,
and
Curry, Deonicia,
Curry, Lafeder,
for DAMAGES (OTH)
in the District Court of Harris County.
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CAUSE NO. 2005-08063 2
STATE FARM LLOYDS as Subrogee of § IN THE DISTRICT COURT
y Py
Qs %
CYNTHIA DRESDEN § 2 SyOe, GZ
Vs. § OF HARRIS COUNTY, TEXAS % %
§
DEONICIA CURRY and LAFEDER CURRY § 234" JUDICIAL DISTRICT
MOTION TO RETAIN
‘TO TI HONORABLE JUDGE OF SAID COURT:
COMES NOW, STATE FARM LLOYDS as Subrogee of CYNTHIA DRESDEN
(hereinaficr “Plaintiff’) and presents this Motion to Retain, and for grounds would show as follows:
I
Defendant DRONICIA CURRY was served with Plaintiff's Original Petition on February
18. 2005.
Detendant LAFEDER CURRY was served with Plaintiff's Original Petition on February 18,
2005,
Th.
‘To date. neither Defendant has filed an answer nor attempted to resolve this matter.
However, there have been discussions with Defendant Lafeder Curry’s liability carrier concerning
settlements.
i.
This is Plaintiff's first Motion to Retain and is not sought for delay, but that justice may be
done, Further, Plainti[T has prepared and will be filing a Motion for Default Judgment, in the vent
a settlement is not reached.
Fo Taundaers 401 2¢P endings & Discovery-Motion wo Retain. wpa Page 1
on
WHERETORE, PREMISES CONSIDERED, Plaintiff STATE FARM LLOYDS as Subrogee
of CYNTHIA DRESDEN prays that this Court enter on order retaining this cause on the docket of
the Coun, and granting Plaintiff such other and further relief to which it may show itself justly
entitled.
Respectfully submitted.
HARGIS, HIARPOLD, L.L,P.
GRA P.HARPOELD
State Bar No. 09034300
2 Riverway, Suite 1020
Houston, ‘lexas 77056
(713) 751-0800 Telephone
(713) 751-0105 Facsimile
ATTORNEYS FOR PLAINTIFF
STATE FARM LLOYDS as Subrogee of
CYNTHIA DRESDEN
He-Lata Docs 20 L090 Pleadinys& Discover’ Metion tw Retain.wpl Page 2
“a,
VERIFICATION
STALE OF TEXAS §
8
COUNTY OF HARRIS 8
BEFORE ME, the undersigned authority, this day personally appeared GRANT P.
MARPOLD of the law firm of Hargis & Harpold, L.L.P., attorneys for STATE FARM LLOYDS as
Subrogee of CYNTHIA DRESDEN, and, afier being duly sworn, slated upon oath that he has read
the foregoing Motion to Retain and that all of the statements contained therein ure within his
personal knowledge and are true and correct.
TI v
GRANT P. HARPOLD
SUBSCRIBED and SWORN TO BEFORE: ME by the said GRANT P. HARPOLD on this,
the /9yCday of May. 2005,
wnat
OTARY’ Sn lee
PUBLIC in and for the
STATE OF TEXAS
C.J. SWEET
MY COMMISSION EXPIRES:
February
24, 2007
Le Doty Lacs: IM EP endings & Discuvery’ Mution to Retain. wpi Page 3
wo
-~
Harois & HaRPoup, LLP. &
A RUOISTERED LIMITED LIABILITY PARTNERSHIP én 3
ATTORNEYS AT LAW
2 RIVERWAY, SUITE 1020 hy ‘oy
HOUSTON, TEXAS 77036 £9
TELEPHONE: (713) 751-0800
“o> 4
es %
% %
FACSIMILEX? 13) 751-0105 &%
May 19. 2005
Mr. Charles Bacarisse Via First Class Mail
Distrie! ‘ork
Harris ‘unty
C Civil Courts Bldg.
301 Fannin
Houston, Texas 77002
Re: Cause No. 2005-08063: State Farm Llovdy as Subrogee of Cynthia Dresden vs.
Deonicia Curry and Lafeder Curry; in the 234" Judicial District Court of Harris
County. ‘Texas.
Dear Mr. Bacarjsse:
Enclosed please find Plaintiff's Motion to Retain, Verification, and Order Retaining Case
on Docket. Please acknowledge receipt and filing of this document by returning « file-stamped copy
in the envelope provided.
‘Thank you for your assistance in this matter. [anything further is required. please do not
hesitate to contact this office.
ry
GPH/ejs . Harpold
Enclosures
CCl Ms. Nancy Baird
State Farm Lloyds
Claim No. 53-Q717-066
Kia First Class Mail
E°-Datatdaes
13 ROO orrespondence\Court 1 tr U5 1805. wed
Document Filed Date
May 20, 2005
Case Filing Date
February 03, 2005
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es 7s - so @) 2 CAUSE NO. 2005-08063 2 STATE FARM LLOYDS as Subrogee of § IN THE DISTRICT COURT y Py Qs % CYNTHIA DRESDEN § 2 SyOe, GZ Vs. § OF HARRIS COUNTY, TEXAS % % § DEONICIA CURRY and LAFEDER CURRY § 234" JUDICIAL DISTRICT MOTION TO RETAIN ‘TO TI HONORABLE JUDGE OF SAID COURT: COMES NOW, STATE FARM LLOYDS as Subrogee of CYNTHIA DRESDEN (hereinaficr “Plaintiff’) and presents this Motion to Retain, and for grounds would show as follows: I Defendant DRONICIA CURRY was served with Plaintiff's Original Petition on February 18. 2005. Detendant LAFEDER CURRY was served with Plaintiff's Original Petition on February 18, 2005, Th. ‘To date. neither Defendant has filed an answer nor attempted to resolve this matter. However, there have been discussions with Defendant Lafeder Curry’s liability carrier concerning settlements. i. This is Plaintiff's first Motion to Retain and is not sought for delay, but that justice may be done, Further, Plainti[T has prepared and will be filing a Motion for Default Judgment, in the vent a settlement is not reached. Fo Taundaers 401 2¢P endings & Discovery-Motion wo Retain. wpa Page 1 on WHERETORE, PREMISES CONSIDERED, Plaintiff STATE FARM LLOYDS as Subrogee of CYNTHIA DRESDEN prays that this Court enter on order retaining this cause on the docket of the Coun, and granting Plaintiff such other and further relief to which it may show itself justly entitled. Respectfully submitted. HARGIS, HIARPOLD, L.L,P. GRA P.HARPOELD State Bar No. 09034300 2 Riverway, Suite 1020 Houston, ‘lexas 77056 (713) 751-0800 Telephone (713) 751-0105 Facsimile ATTORNEYS FOR PLAINTIFF STATE FARM LLOYDS as Subrogee of CYNTHIA DRESDEN He-Lata Docs 20 L090 Pleadinys& Discover’ Metion tw Retain.wpl Page 2 “a, VERIFICATION STALE OF TEXAS § 8 COUNTY OF HARRIS 8 BEFORE ME, the undersigned authority, this day personally appeared GRANT P. MARPOLD of the law firm of Hargis & Harpold, L.L.P., attorneys for STATE FARM LLOYDS as Subrogee of CYNTHIA DRESDEN, and, afier being duly sworn, slated upon oath that he has read the foregoing Motion to Retain and that all of the statements contained therein ure within his personal knowledge and are true and correct. TI v GRANT P. HARPOLD SUBSCRIBED and SWORN TO BEFORE: ME by the said GRANT P. HARPOLD on this, the /9yCday of May. 2005, wnat OTARY’ Sn lee PUBLIC in and for the STATE OF TEXAS C.J. SWEET MY COMMISSION EXPIRES: February 24, 2007 Le Doty Lacs: IM EP endings & Discuvery’ Mution to Retain. wpi Page 3 wo -~ Harois & HaRPoup, LLP. & A RUOISTERED LIMITED LIABILITY PARTNERSHIP én 3 ATTORNEYS AT LAW 2 RIVERWAY, SUITE 1020 hy ‘oy HOUSTON, TEXAS 77036 £9 TELEPHONE: (713) 751-0800 “o> 4 es % % % FACSIMILEX? 13) 751-0105 &% May 19. 2005 Mr. Charles Bacarisse Via First Class Mail Distrie! ‘ork Harris ‘unty C Civil Courts Bldg. 301 Fannin Houston, Texas 77002 Re: Cause No. 2005-08063: State Farm Llovdy as Subrogee of Cynthia Dresden vs. Deonicia Curry and Lafeder Curry; in the 234" Judicial District Court of Harris County. ‘Texas. Dear Mr. Bacarjsse: Enclosed please find Plaintiff's Motion to Retain, Verification, and Order Retaining Case on Docket. Please acknowledge receipt and filing of this document by returning « file-stamped copy in the envelope provided. ‘Thank you for your assistance in this matter. [anything further is required. please do not hesitate to contact this office. ry GPH/ejs . Harpold Enclosures CCl Ms. Nancy Baird State Farm Lloyds Claim No. 53-Q717-066 Kia First Class Mail E°-Datatdaes 13 ROO orrespondence\Court 1 tr U5 1805. wed