On September 24, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
The Department Of Family And Protective Services,
and
Anderson, Jenny Rebecca,
Simpson, Jason Ryan,
for Child Protective Services
in the District Court of Smith County.
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Electronically Filed
7/22/2020 9:23 AM
Penny Clarkston, Smith County District Clerk
Reviewed By: Daisy Duran
NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA
CAUSE NO. 19-2377-D
IN THE INTEREST OF § IN THE DISTRICT COURT OF
§
J. s. § SMITH COUNTY, TEXAS
§
A CHILD § 321ST JUDICIAL DISTRICT
AND
NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA
CAUSE NO. 18-5215-E
IN THE INTEREST OF IN COUNTY COURT
JAYDON SIMPSON AT LAW#321
A CHILD SMITH COUNTY, TEXAS
MOTION TO CONSOLIDATE
This Motion to Consolidate the above lawsuits is filed by the Department of Family and
Protective Services ("the Department") seeking to consolidate the above-styled cases.
1. These lawsuits involve common questions of law or of fact, relating to the best interests
of the children involved in both suits.
2. Texas law provides that only one court should acquire and retain continuing exclusive
jurisdiction of a suit affecting the parent-child relationship. It would serve the
convenience of the Court, litigants, and counsel and would avoid multiplicity of suits,
duplication of testimony, and unnecessary expense and delay, as well as prevent the
potential entry of conflicting final orders, to have these lawsuits consolidated for trial.
3. The Department prays that the Court grant the Motion to Consolidate and consolidate
these lawsuits under cause number 19-2377-D in the 321st Judicial District Court of
SMITH County.
Respectfully Submitted,
Motion to Consolidate 19-2377-D 1321ST
Page 1 ASAP04
Attorney for Petitioner,
Department of Family and Protective Services
200 E Ferguson Suite 515
Tyler, Texas 75702
email: jwortham@smith-county.com
phone: (903)590-4633
fax : (903) 590-4630
State Bar # 24081488
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing has been sent by the
following methods to the following parties:
KAREN BRETZKE, 520 SOUTH BONNER A VE, TYLER, TX 75702
Via Email: cps@bretzkelawfirm.com
CASA, BY SUPERVISOR LACI MURRAY, 3728 S PARK DR, TYLER, TX
Via Email: amy@casaforkidsofet.org
JENNIFER DEEN, 109 W FERGUSON, TYLER, TX 75702
Via Email: jgdeen@att.net
AMY DAUGHTREY, PO Box 4252, Tyler, TX 75702
Via Email: adaughtrey@suddenlink.net
in accordance with the Texas Rules of Civil Procedure on July 22, 2020.
Motion to Consolidate 19-2377-0 1321ST
Page 2 ASAP 04
Document Filed Date
July 22, 2020
Case Filing Date
September 24, 2019
Category
Child Protective Services
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Electronically Filed 7/22/2020 9:23 AM Penny Clarkston, Smith County District Clerk Reviewed By: Daisy Duran NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA CAUSE NO. 19-2377-D IN THE INTEREST OF § IN THE DISTRICT COURT OF § J. s. § SMITH COUNTY, TEXAS § A CHILD § 321ST JUDICIAL DISTRICT AND NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA CAUSE NO. 18-5215-E IN THE INTEREST OF IN COUNTY COURT JAYDON SIMPSON AT LAW#321 A CHILD SMITH COUNTY, TEXAS MOTION TO CONSOLIDATE This Motion to Consolidate the above lawsuits is filed by the Department of Family and Protective Services ("the Department") seeking to consolidate the above-styled cases. 1. These lawsuits involve common questions of law or of fact, relating to the best interests of the children involved in both suits. 2. Texas law provides that only one court should acquire and retain continuing exclusive jurisdiction of a suit affecting the parent-child relationship. It would serve the convenience of the Court, litigants, and counsel and would avoid multiplicity of suits, duplication of testimony, and unnecessary expense and delay, as well as prevent the potential entry of conflicting final orders, to have these lawsuits consolidated for trial. 3. The Department prays that the Court grant the Motion to Consolidate and consolidate these lawsuits under cause number 19-2377-D in the 321st Judicial District Court of SMITH County. Respectfully Submitted, Motion to Consolidate 19-2377-D 1321ST Page 1 ASAP04 Attorney for Petitioner, Department of Family and Protective Services 200 E Ferguson Suite 515 Tyler, Texas 75702 email: jwortham@smith-county.com phone: (903)590-4633 fax : (903) 590-4630 State Bar # 24081488 CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing has been sent by the following methods to the following parties: KAREN BRETZKE, 520 SOUTH BONNER A VE, TYLER, TX 75702 Via Email: cps@bretzkelawfirm.com CASA, BY SUPERVISOR LACI MURRAY, 3728 S PARK DR, TYLER, TX Via Email: amy@casaforkidsofet.org JENNIFER DEEN, 109 W FERGUSON, TYLER, TX 75702 Via Email: jgdeen@att.net AMY DAUGHTREY, PO Box 4252, Tyler, TX 75702 Via Email: adaughtrey@suddenlink.net in accordance with the Texas Rules of Civil Procedure on July 22, 2020. Motion to Consolidate 19-2377-0 1321ST Page 2 ASAP 04