Agreed Motion for Continuance of Summary Judgment - Motion (No Fee) Doc ID# 40 - T.H. Trust vs Robert G Pate and Judy K Pate

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On July 25, 2017 a case was filed by T.H. Trust, represented by George M. Bishop, Iii, against Pate, Judy K, and Pate, Robert G, represented by Alicia M. Matsushima, and Russell C. Jones, in the jurisdiction of Fort Bend County. Judge James H. Shoemake presiding.

                        
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                          NO.17-DCV-243655
DAVID H. HAMILTON, AS TRUSTEE IN THE DISTRICT COURT OF
OF T.H. TRUST

PLAINTIFF FORT BEND COUNTY, TEXAS
Vv.
ROBERT G. PATE AND JUDY 434™ JUDICIAL DISTRICT

K. PATE, DEFENDANTS

AGREED MOTION FOR CONTINUANCE OF SUMMARY JUDGMENT
HEARING SET FOR DECEMBER 9, 2019

COMES NOW, David H. Hamilton, Trustee of T.H. Trust with this his
Agreed Motion for Continuance of the hearing on the Summary
Judgment from December 9, 2019 for one week to December 16,2019
and would show the Court as follows:

. I.

In September, 2019, counsel for Plaintiff purchased a ticket for a
vacation in Portugal obtaining non-refundable tickets that have
counsel leaving on November 27, 2019 and not returning until 1:45
P.M. on KLM flight 661. A true copy of his itinerary is attached as
Exhibit A.

After contacting counsel for the Defendants, Russell Jones, Mr. Jones
showed he was indeed a gentleman as he agreed to this continuance
on the condition that Plaintiff's counsel will not ask for another
continu…