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CAUSE NO. 2005-43572
4
LARRY WAYNE FRANCOIS IN THE DISTRICT COURT OF
Plaintiff,
Vv. HARRIS ousry,
ASior
x
JOSEPH RAY BLANCO, et al. CHAR ict
Spiatrict
Defendants. 61" TIC P
FRAN
Foxes
PLAINT! 'S UNOPPOSED MOTION TO
AND TRANSFER VE erat
BY
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, LARRY WAYNE FRANCOIS, Plaintiff herein, and moves the Court to
retain the above-entitled and numbered cause on its docket to be disposed of by trial on the merits
without dismissal for want of prosecution and to transfer venue to a District Court in Lordsburg,
Hidalgo County, New Mexico. In support of this motion, Plaintiff would respectfully show the
Court as follows:
1 Plaintiff’s claims are meritorious, and there is good cause for this case to be retained
and transferred to a District Court in Lordsburg, Hidalgo County, New Mexico. All Defendants have
been served and have answered subject to special appearance herein. Plaintiff conducted discovery
on Defendant, Joseph Ray Blanco to determine whether jurisdiction and venue are proper in this
Court. Based on Defendant’s verified responses it would appear that Defendant lacks the minimum
contacts necessary for personal jurisdiction.
2. Plaintiff, therefore, seeks to pursue its claims against Defendant in the county in New
Mexico where the accident occurred and where venue is proper.
3 The affidavit of counsel for Plaintiff is attached hereto and incorporated herein.
Nee.
WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that this motion be granted and
this cause be retained and transferred to a District Court in Lordsburg, Hidalgo County, New
Mexico.
Respectfully submitted,
STEVEN E. THOMPSON & ASSOCIATES, P.C.
Steven E. Thompson
State Bar No.: 00785102
1920 N. Memorial Way, Suite 205
Houston, Texas 77007
(713) 463-8085 Telephone
(713) 463-6674 Facsimile
ATTORNEY FOR PLAINTIFF
CERTIFICATE OF CONFERENCE
I certify that I have conferred with opposing counsel about the merits of this motion and he is
unopposed to this motion.
s 0 ON
CERTIFICATE OF SERVICE
I do hereby certify that a true and correct copy of the foregoing instrument has been served
upon counsel of record pursuant to the Texas Rules of Civil Procedure, via hand delivery, certified
mail, return receipt requested and/or facsimile on this 26" day of May, 2006.
VIA E-MAIL immo: cbylaw.com
Richard Simmons
COKINOS, BOSIEN & YOUNG
2919 Allen Parkway, Suite 1500
Houston, Texas 77019
STE E. THOMPSON
a
Nn
+
THE STATE OF TEXAS §
§
COUNTY OF HARRIS §
BEFORE ME, the undersigned authority, on this day personally appeared Steven E.
Thompson, who being by me duly sworn on his oath deposed and stated that he is counsel for
Plaintiff herein and is duly qualified and authorized in all respects to make this Affidavit; that he has
read the above and foregoing Motion to Retain; and that every statement contained therein is true and
correct.
Steven E. Thompson
SUBSCRIBED AND SWORN TO BEFORE ME 01 this” i“ day of May, 2006, to certify
which witness my hand and seal of office.
@
STELLA L. MON!
NOTARY PUBLIC Notary Public, State of Texas
STATE OF TI
im. Exp. JULY 21, 2009
ww \ed
STEVEN E. THOMPSON & ASSOCIATES, P.C.
A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
1920 N. MEMORIAL WAY, SUITE 205, ‘TELEPHONE (713) 463-8085.
STEVEN E. THOMPSON HOUSTON, TEXAS 77007 FACSIMILE (713) 463-6674
F i tr ED
CHARLES BACARISSE
May 26, 2006 Dist! rict Clerk
VIA HAND DELIVERY MAY 2 6 2h
Clerk, 61" District Court
201 Caroline Street, 9" Floor Time ris County, Texas
Houston, Texas 77002
By. ‘Deputy
Re: Cause No. 2005-43572; Larry Wayne Francois v. Joseph Ray Blanco, et al; in the
61* Judicial District Court; Harris County, Texas
Dear Sir:
Enclosed for filing in the above-referenced matter are an original and one copy of:
1 Plaintiff's Unopposed Motion and Order to Retain and Transfer Venue.
Please file the originals in your usual manner and return the file-stamped copies in the
envelope. Thank you in advance for your attention to this matter.
Very truly yours,
Mitr
BR. Monel
Stella L. Monreal
Paralegal to Steven E. Thompson
/sim
Enclosures
cc: VIA E-MAIL rsimmons@cbylaw.com
Richard Simmons
COKINOS, BOSIEN & YOUNG
2919 Allen Parkway, Suite 1500
Houston, Texas 77019
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CAUSE NO. 2005-43572 4 LARRY WAYNE FRANCOIS IN THE DISTRICT COURT OF Plaintiff, Vv. HARRIS ousry, ASior x JOSEPH RAY BLANCO, et al. CHAR ict Spiatrict Defendants. 61" TIC P FRAN Foxes PLAINT! 'S UNOPPOSED MOTION TO AND TRANSFER VE erat BY TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, LARRY WAYNE FRANCOIS, Plaintiff herein, and moves the Court to retain the above-entitled and numbered cause on its docket to be disposed of by trial on the merits without dismissal for want of prosecution and to transfer venue to a District Court in Lordsburg, Hidalgo County, New Mexico. In support of this motion, Plaintiff would respectfully show the Court as follows: 1 Plaintiff’s claims are meritorious, and there is good cause for this case to be retained and transferred to a District Court in Lordsburg, Hidalgo County, New Mexico. All Defendants have been served and have answered subject to special appearance herein. Plaintiff conducted discovery on Defendant, Joseph Ray Blanco to determine whether jurisdiction and venue are proper in this Court. Based on Defendant’s verified responses it would appear that Defendant lacks the minimum contacts necessary for personal jurisdiction. 2. Plaintiff, therefore, seeks to pursue its claims against Defendant in the county in New Mexico where the accident occurred and where venue is proper. 3 The affidavit of counsel for Plaintiff is attached hereto and incorporated herein. Nee. WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that this motion be granted and this cause be retained and transferred to a District Court in Lordsburg, Hidalgo County, New Mexico. Respectfully submitted, STEVEN E. THOMPSON & ASSOCIATES, P.C. Steven E. Thompson State Bar No.: 00785102 1920 N. Memorial Way, Suite 205 Houston, Texas 77007 (713) 463-8085 Telephone (713) 463-6674 Facsimile ATTORNEY FOR PLAINTIFF CERTIFICATE OF CONFERENCE I certify that I have conferred with opposing counsel about the merits of this motion and he is unopposed to this motion. s 0 ON CERTIFICATE OF SERVICE I do hereby certify that a true and correct copy of the foregoing instrument has been served upon counsel of record pursuant to the Texas Rules of Civil Procedure, via hand delivery, certified mail, return receipt requested and/or facsimile on this 26" day of May, 2006. VIA E-MAIL immo: cbylaw.com Richard Simmons COKINOS, BOSIEN & YOUNG 2919 Allen Parkway, Suite 1500 Houston, Texas 77019 STE E. THOMPSON a Nn + THE STATE OF TEXAS § § COUNTY OF HARRIS § BEFORE ME, the undersigned authority, on this day personally appeared Steven E. Thompson, who being by me duly sworn on his oath deposed and stated that he is counsel for Plaintiff herein and is duly qualified and authorized in all respects to make this Affidavit; that he has read the above and foregoing Motion to Retain; and that every statement contained therein is true and correct. Steven E. Thompson SUBSCRIBED AND SWORN TO BEFORE ME 01 this” i“ day of May, 2006, to certify which witness my hand and seal of office. @ STELLA L. MON! NOTARY PUBLIC Notary Public, State of Texas STATE OF TI im. Exp. JULY 21, 2009 ww \ed STEVEN E. THOMPSON & ASSOCIATES, P.C. A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 1920 N. MEMORIAL WAY, SUITE 205, ‘TELEPHONE (713) 463-8085. STEVEN E. THOMPSON HOUSTON, TEXAS 77007 FACSIMILE (713) 463-6674 F i tr ED CHARLES BACARISSE May 26, 2006 Dist! rict Clerk VIA HAND DELIVERY MAY 2 6 2h Clerk, 61" District Court 201 Caroline Street, 9" Floor Time ris County, Texas Houston, Texas 77002 By. ‘Deputy Re: Cause No. 2005-43572; Larry Wayne Francois v. Joseph Ray Blanco, et al; in the 61* Judicial District Court; Harris County, Texas Dear Sir: Enclosed for filing in the above-referenced matter are an original and one copy of: 1 Plaintiff's Unopposed Motion and Order to Retain and Transfer Venue. Please file the originals in your usual manner and return the file-stamped copies in the envelope. Thank you in advance for your attention to this matter. Very truly yours, Mitr BR. Monel Stella L. Monreal Paralegal to Steven E. Thompson /sim Enclosures cc: VIA E-MAIL rsimmons@cbylaw.com Richard Simmons COKINOS, BOSIEN & YOUNG 2919 Allen Parkway, Suite 1500 Houston, Texas 77019