On March 21, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
and
for DIVORCE
in the District Court of Tarrant County.
Preview
,
325-658610-19 FILED
TARRANT COUNTY
8/16/2019 9:14 AM
THOMAS A. WILDER
CAUSE NO. 325-658610-19 DISTRICT CLERK
IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF
GAIL HALLUM § 325TH JUDICIAL DISTRICT
AND
DAVID HALLUM TARRANT COUNTY, TEXAS
Respondent’s Motion for Additional Temporary Orders
and Request for Expedited Hearing
This Motion for Additional Temporary Orders is brought by David Hallum, Respondent,
who shows in support the following:
Background
On April 24, 2019 following a contested hearing, the Associate Judge of this Court
announced her rulings for temporary orders and memorialized those rulings in an Associate
Judge’s Report.
As part of the Court’s ruling, GAIL HALLUM was awarded temporary exclusive use and
possession of the residence located at 6908 Tumbling Trail, Ft. Worth, Texas. Additionally, this
property was to be listed for sale and the net proceeds from that sale were to be deposited into
the trust account of Gail Hallum’s attorney. The bulk of the contents of this residence were to
remain in place in order to help stage the home for sale.
The parties have entered into a contract for the sale of the above house and must vacate
the property by August 30, 2019. (The closing date is August 22, 2019 with a lease-back through
August 30, 2019).
The parties have been unable to agree on the disposition of the contents of the Tumbling
Trail house. Further, the parties have been unable to agree upon a time for David Hallum to have
Motion for Additional Temporary Orders
CAUSE NO. 325-658610-19; ITMOTMO HALLUM Page 1 of3
P
access to the house to conduct a video inventory, pack items, or arrange for any disposition of
the property located at this residence.
If the parties are unable to agree upon the temporary or final disposition of the personal
property located at the Tumbling Trail House, there is a high probability that the pending sale
will fall through, thus causing serious financial harm to the parties.
Movant would respectfully request that the Court enter an Order that permits David
Hallum to enter the Tumbling Trail property on August 28 — 30, 2019 between the hours of 8:00
am and 8:00 pm each day in order to conduct a video inventory and to pack and move items of
personal property temporarily awarded to him by the court or by the agreement of the parties.
Further, the Court should order that each party be responsible for arranging the removal and
storage of property temporarily awarded to them prior to August 30, 2019. Additionally, each
party should be responsible for their own moving arrangements as well as the cost of moving and
storing the property temporarily awarded to them.
Sale of Stockton House
David Hallum respectfully requests that the property located at 6416 Stockton Dr., Ft.
Worth, Texas be listed for sale under the same terms and conditions as those for the Tumbling
Trail property. The proceeds from the sale of this property should be deposited into the trust
account of an attorney for the parties as may be designated by the Court.
DAVID HALLUM prays that the Court grant this motion.
Respectfully submitted,
The Law Office of William D Pruett, P.L.L.C.
909 W. Magnolia Ave., Suite 6
Fort Worth, TX 76104
Tel: (817) 489-9877
Fax: (817) 386-2552
bill.thecowtownlawyer@gmail.com
Motion for Additional Temporary Orders
CAUSE NO. 325-658610-19; JTMOTMO HALLUM Page 2 of3
bi R—
By:
William D. Pruett
State Bar No. 90001580
Attorney for Counterpetitioner
Certificate of Conference
I certify that a reasonable effort has been made to resolve the discovery dispute without
the necessity of court intervention and has failed. “a J
Wo
William D. Pruett
Attorney for DAVID HALLUM
Certificate of Service
in accordance
I certify that a true copy of this Motion to Compel Discovery was served
of record on
with rule 21a of the Texas Rules of Civil Procedure on the parties or attorney
Vy R—
August 16, 2019:
by electronic filing manager.
William D. Pruett
Attorney for DAVID HALLUM
Motion for Additional Temporary Orders Page 3 of3
CAUSE NO. 325-658610-19; /TMOTMO HALLUM
Document Filed Date
August 16, 2019
Case Filing Date
March 21, 2019
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, 325-658610-19 FILED TARRANT COUNTY 8/16/2019 9:14 AM THOMAS A. WILDER CAUSE NO. 325-658610-19 DISTRICT CLERK IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF GAIL HALLUM § 325TH JUDICIAL DISTRICT AND DAVID HALLUM TARRANT COUNTY, TEXAS Respondent’s Motion for Additional Temporary Orders and Request for Expedited Hearing This Motion for Additional Temporary Orders is brought by David Hallum, Respondent, who shows in support the following: Background On April 24, 2019 following a contested hearing, the Associate Judge of this Court announced her rulings for temporary orders and memorialized those rulings in an Associate Judge’s Report. As part of the Court’s ruling, GAIL HALLUM was awarded temporary exclusive use and possession of the residence located at 6908 Tumbling Trail, Ft. Worth, Texas. Additionally, this property was to be listed for sale and the net proceeds from that sale were to be deposited into the trust account of Gail Hallum’s attorney. The bulk of the contents of this residence were to remain in place in order to help stage the home for sale. The parties have entered into a contract for the sale of the above house and must vacate the property by August 30, 2019. (The closing date is August 22, 2019 with a lease-back through August 30, 2019). The parties have been unable to agree on the disposition of the contents of the Tumbling Trail house. Further, the parties have been unable to agree upon a time for David Hallum to have Motion for Additional Temporary Orders CAUSE NO. 325-658610-19; ITMOTMO HALLUM Page 1 of3 P access to the house to conduct a video inventory, pack items, or arrange for any disposition of the property located at this residence. If the parties are unable to agree upon the temporary or final disposition of the personal property located at the Tumbling Trail House, there is a high probability that the pending sale will fall through, thus causing serious financial harm to the parties. Movant would respectfully request that the Court enter an Order that permits David Hallum to enter the Tumbling Trail property on August 28 — 30, 2019 between the hours of 8:00 am and 8:00 pm each day in order to conduct a video inventory and to pack and move items of personal property temporarily awarded to him by the court or by the agreement of the parties. Further, the Court should order that each party be responsible for arranging the removal and storage of property temporarily awarded to them prior to August 30, 2019. Additionally, each party should be responsible for their own moving arrangements as well as the cost of moving and storing the property temporarily awarded to them. Sale of Stockton House David Hallum respectfully requests that the property located at 6416 Stockton Dr., Ft. Worth, Texas be listed for sale under the same terms and conditions as those for the Tumbling Trail property. The proceeds from the sale of this property should be deposited into the trust account of an attorney for the parties as may be designated by the Court. DAVID HALLUM prays that the Court grant this motion. Respectfully submitted, The Law Office of William D Pruett, P.L.L.C. 909 W. Magnolia Ave., Suite 6 Fort Worth, TX 76104 Tel: (817) 489-9877 Fax: (817) 386-2552 bill.thecowtownlawyer@gmail.com Motion for Additional Temporary Orders CAUSE NO. 325-658610-19; JTMOTMO HALLUM Page 2 of3 bi R— By: William D. Pruett State Bar No. 90001580 Attorney for Counterpetitioner Certificate of Conference I certify that a reasonable effort has been made to resolve the discovery dispute without the necessity of court intervention and has failed. “a J Wo William D. Pruett Attorney for DAVID HALLUM Certificate of Service in accordance I certify that a true copy of this Motion to Compel Discovery was served of record on with rule 21a of the Texas Rules of Civil Procedure on the parties or attorney Vy R— August 16, 2019: by electronic filing manager. William D. Pruett Attorney for DAVID HALLUM Motion for Additional Temporary Orders Page 3 of3 CAUSE NO. 325-658610-19; /TMOTMO HALLUM