On July 25, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
T.H. Trust,
and
Pate, Judy K,
Pate, Robert G,
for Other Civil
in the District Court of Fort Bend County.
Preview
NO. 17-DCV-243655
DAVID H. HAMILTON, AS TRUSTEES§ IN THE DISTRICT COURT
OF T. H. TRUST §
Plaintiff and Counter-Defendant, §
§
Vv. §
ROBERT G. PATE AND JUDY K. PATE§ 434TH JUDICIAL DISTRICT
Defendants and Counter-Plaintiffs §
§
Vv §
GEORGE M. BISHOP, K. M. BISHOP§
AND i.
DAVID HAMILTON,§
INDIVIDUALLY ,
Cross-Defendants § OF FORT BEND COUNTY, TEXAS
DEFENDANTS' MOTION FOR CONTINUANCE
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COME Defendants, Judy K. Pate, Movants herein, and bring this Motion for
Continuance, and in support hereof, show the Court the following:
I
Movants request this Court, pursuant to Texas Rules of Civil Procedure, Rule 166a(g), to
reset the hearings on Plaintiff's Summary Judgment Motion and on Plaintiffs Motion for No
Evidence Summary Judgment on the grounds that Movants are unable to respond to Plaintiffs
motion.
Il.
Movants served their Demand for Abstract on David H. Hamilton, as Trustee of T. H.
Trust on or about August 16, 2017. A true and correct copy of said Demand for Abstract is
attached to Movant’s previous Motion to Compel Abstract and incorporated by reference.
a
m
My a.
ne =
a. hk 4.
Ee.
5. a
=
me th
= me
i
&
B.
B. ¢.
ae
e
3.
g.
g. a
BR.
5 a.
.
a.
me a
a.
BE. g.
=
E. kh
gZ.
=
Kn.
=.
kh
a.
a.
a.
5
> TAN
a3 age
a
wie
AB8
m™ a9
ar
&
S
a
x
B -
mow a. g
gw
oN z
ga ©S
veo
QB a8
a.
Bn BOQ
ae FH
os
BE.
aso s.
au
Bo E. a.
eB.
Go
E
~
eB
=
E.
eB. me a. a
a
za Sn
s. a sy co
o-=
eg
ZS
oF a>
os
gE.
mz
E 2.
=.
a. .
B
a muon ion LR LP SN LN SH LN ©
gc &.
EE
=z.
=.
a:
ce
Bg,
o
a
gies
& th EB. Eg. g.
ae
i;‘fo
ga
oe th
B.
4. a
re ue 4
be
a.
d. a
2
a
go. a
5 mee
a.
=
e. EB. hh
N 2g.
2.
=.
E
BE.
th g
Bg.
Filed
7/10/2019 4:29 PM
Beverley McGrew Walker
District Clerk
Fort Bend County, Texas
Erica Rodriguez
NO. 17-DCV-243655
DAVID H. HAMILTON, AS TRUSTEE § IN THE DISTRICT COURT
OF T. H. TRUST §
Plaintiff, §
Vv. § 434TH JUDICIAL DISTRICT
ROBERT G. PATE AND JUDY K. PATE §
Defendants. § OF FORT BEND COUNTY, TEXAS
MOTION TO COMPEL RESPONSE TO DEMAND FOR ABSTRACT
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COME Defendants, Robert G. Pate and Judy K. Pate, Movants herein, and bring
this Motion to Compel against David H. Hamilton, as Trustee of T. H. Trust, Respondent, to
compel a response to Defendants’ prior Demand for Abstract, served almost two years ago. In
support thereof, Movants would show the Court the following:
I
Movants served their Demand for Abstract on David H. Hamilton, as Trustee of T. H. Trust
on or about August 16, 2017. A true and correct copy of said Demand for Abstract is attached
hereto and incorporated by reference as Exhibit "A."
IL.
As of the date of filing this motion, David H. Hamilton, as Trustee of T. H. Trust has not
provided any responses to the Demand for Abstract.
TL.
The documents requested are relevant to the subject matter in this pending cause and are
reasonably calculated to lead to discovery of admissible evidence. The above-entitled and
numbered cause is a case for trespass to try title. The documents requested are required by the
applicable rules.
Exhibit "A"
gE; o
kh
th =.
BE.
RB
2. m
=
Z. eB.
a. g.
a
a
a
Me a,
a.
ms a.
a.
=.
=
me
kk =
a. mE
a in.
me =. a. me
BE.
g
Z.
2, a
gz.
Ss
Ma
&
s. a
me
E. &. £.
Me
a
E:
2g, hh
E
s.
&.
a.
ao
o.
aX<
Se
©
Ba
=
is
Apain
os 2s 2 3
DdF AEa
2a ot
od
mow vpSs
gw
ON
Qa ey
©.
S
BE. ve
as Sk
m
a
=
Z
mn op wor wor
zeSo a2
AD
2 map
2.
E
a3
os
3
os
eB
‘Bumberg i, 208
>;
£.
5.
Document Filed Date
March 12, 2020
Case Filing Date
July 25, 2017
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
NO. 17-DCV-243655 DAVID H. HAMILTON, AS TRUSTEES§ IN THE DISTRICT COURT OF T. H. TRUST § Plaintiff and Counter-Defendant, § § Vv. § ROBERT G. PATE AND JUDY K. PATE§ 434TH JUDICIAL DISTRICT Defendants and Counter-Plaintiffs § § Vv § GEORGE M. BISHOP, K. M. BISHOP§ AND i. DAVID HAMILTON,§ INDIVIDUALLY , Cross-Defendants § OF FORT BEND COUNTY, TEXAS DEFENDANTS' MOTION FOR CONTINUANCE TO THE HONORABLE JUDGE OF SAID COURT: NOW COME Defendants, Judy K. Pate, Movants herein, and bring this Motion for Continuance, and in support hereof, show the Court the following: I Movants request this Court, pursuant to Texas Rules of Civil Procedure, Rule 166a(g), to reset the hearings on Plaintiff's Summary Judgment Motion and on Plaintiffs Motion for No Evidence Summary Judgment on the grounds that Movants are unable to respond to Plaintiffs motion. Il. Movants served their Demand for Abstract on David H. Hamilton, as Trustee of T. H. Trust on or about August 16, 2017. A true and correct copy of said Demand for Abstract is attached to Movant’s previous Motion to Compel Abstract and incorporated by reference. a m My a. ne = a. hk 4. Ee. 5. a = me th = me i & B. B. ¢. ae e 3. g. g. a BR. 5 a. . a. me a a. BE. g. = E. kh gZ. = Kn. =. kh a. a. a. 5 > TAN a3 age a wie AB8 m™ a9 ar & S a x B - mow a. g gw oN z ga ©S veo QB a8 a. Bn BOQ ae FH os BE. aso s. au Bo E. a. eB. Go E ~ eB = E. eB. me a. a a za Sn s. a sy co o-= eg ZS oF a> os gE. mz E 2. =. a. . B a muon ion LR LP SN LN SH LN © gc &. EE =z. =. a: ce Bg, o a gies & th EB. Eg. g. ae i;‘fo ga oe th B. 4. a re ue 4 be a. d. a 2 a go. a 5 mee a. = e. EB. hh N 2g. 2. =. E BE. th g Bg. Filed 7/10/2019 4:29 PM Beverley McGrew Walker District Clerk Fort Bend County, Texas Erica Rodriguez NO. 17-DCV-243655 DAVID H. HAMILTON, AS TRUSTEE § IN THE DISTRICT COURT OF T. H. TRUST § Plaintiff, § Vv. § 434TH JUDICIAL DISTRICT ROBERT G. PATE AND JUDY K. PATE § Defendants. § OF FORT BEND COUNTY, TEXAS MOTION TO COMPEL RESPONSE TO DEMAND FOR ABSTRACT TO THE HONORABLE JUDGE OF SAID COURT: NOW COME Defendants, Robert G. Pate and Judy K. Pate, Movants herein, and bring this Motion to Compel against David H. Hamilton, as Trustee of T. H. Trust, Respondent, to compel a response to Defendants’ prior Demand for Abstract, served almost two years ago. In support thereof, Movants would show the Court the following: I Movants served their Demand for Abstract on David H. Hamilton, as Trustee of T. H. Trust on or about August 16, 2017. A true and correct copy of said Demand for Abstract is attached hereto and incorporated by reference as Exhibit "A." IL. As of the date of filing this motion, David H. Hamilton, as Trustee of T. H. Trust has not provided any responses to the Demand for Abstract. TL. The documents requested are relevant to the subject matter in this pending cause and are reasonably calculated to lead to discovery of admissible evidence. The above-entitled and numbered cause is a case for trespass to try title. The documents requested are required by the applicable rules. Exhibit "A" gE; o kh th =. BE. RB 2. m = Z. eB. a. g. a a a Me a, a. ms a. a. =. = me kk = a. mE a in. me =. a. me BE. g Z. 2, a gz. Ss Ma & s. a me E. &. £. Me a E: 2g, hh E s. &. a. ao o. aX< Se © Ba = is Apain os 2s 2 3 DdF AEa 2a ot od mow vpSs gw ON Qa ey ©. S BE. ve as Sk m a = Z mn op wor wor zeSo a2 AD 2 map 2. E a3 os 3 os eB ‘Bumberg i, 208 >; £. 5.