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Electronically Filed
7/12/2021 2:18 PM
Hidalgo County District Clerks
Reviewed By: Alexis Bonilla
C-2715-21-A
CAUSE NO.
ERIKA DEL CARMEN SEBA, as Next § IN THE DISTRICT COURT OF
Friend of KARLA FERNANDA GOMEZ, §
BRAYAN DE JESUS GOMEZ AND §
ALEYDA GOMEZ; Minor Children §
§ HIDALGO COUNTY, TEXAS
VS. §
§
CARLOS ROLDAN and RCA §
TRANSPORT § JUDICIAL DISTRICT
JOINT AGREED MOTION FOR APPOINTMENT OF GUARDIARN AD LITEM & T0
SET FRIENDLY SUIT HEARING
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Plaintiff, ERIKA DEL CARMEN SEBA, as Next Friend of KARLA
FERNANDA GOMEZ, BRAYAN DE JESUS GOMEZ AND ALEYDA GOMEZ Minor
Children (“Plaintiff”), and Defendants, CARLOS ROLDAN and RCA TRANSPORT
(“Defendants”), and pursuant to Texas Rule of Civil Procedure 173, file this, their Joint Agreed
Motion for Appointment of a Guardian Ad Litem and to set a friendly suit hearing. In support
thereof, the parties would respectfully show the following:
This isa personal injury suit arising out ofautomobile accident. Plaintiff Erika Del Carmen
Seba, as Next Friend of KARLA FERNANDA GOMEZ, BRAYAN DE JESUS GOMEZ AND
ALEYDA GOMEZ., minor children, alleges the minor children sustained injuries and damages as
a result of the accident.
Plaintiff has reached a settlement with the Defendants in this case. In an effort to avoid any
potential conflicts of interests, Plaintiffand Defendants, pursuant to Texas Rule ofCivil Procedure
173, ask this Court to appoint a Guardian Ad Litem to represent the best interests of the minor
Electronically Filed
7/12/2021 2:18 PM
Hidalgo County District Clerks
Reviewed By: Alexis Bonilla
C-2715-21-A
children involved in this case, to review the settlement, make appropriate recommendations to the
Court, and to set this matter for a friendly suit hearing.
WHEREFORE, PREMISES CONSIDERED, Plaintiff ERIKA DEL CARMEN, as next
Friend of KARLA FERNANDA GOMEZ, BRAYAN DE JESUS GOMEZ AND ALEYDA
GOMEZ, Minor Children, and Defendants, CARLOS ROLDAN and RCA TRANSPORT,
respectfully pray that this Honorable Court enter their Proposed Order granting their Joint Motion
to Appoint Guardian Ad Litem, appoint a suitable Guardian Ad Litem to look out for and protect
the interest of the minor children involved in this case, and to set a hearing to consider the
settlement.
Respectfully submitted,
LAW OFFICE 0F EFRAIN CARRERA, P.C.
/s/ aim. carrcra
Efrain Carrera
State Bar No. 24025284
cl'rainczn‘rcruIKulvzlhooxom
61 7 South 12‘“ Street
Edinburg, Texas 78539
Tel: (956) 387-0909
Fax: (956) 387-0914
ATTORNEY FOR ERIKA DEL
CARMEN SEBA, as Next Friend of K.G.,
B.G. and A.G., Minor Children.
ROYSTON, RAYZOR, VICKERY &
WILLIAMS, L.L.P.
/s/ James H. Huwter, Jr.
James H. Hunter, Jr.
State Bar No. 00784311
55 Cove Circle
P. O. Box 3509
Brownsville, Texas 78523-3509
Tel: (956) 542-4377
Fax: (956) 542-4370
Electronically Filed
7/12/2021 2:18 PM
Hidalgo County District Clerks
Reviewed By: Alexis Bonilla
C-2715-21-A
Attorney for Defendants
CARLOS ROLDAN and RCA
TRANSPORT
CERTIFICATE OF SERVICE
Ihereby certify that a true and correct copy of the above and foregoing Joint Motion for
Appointment of Guardian Ad Litem was emailed to all known counsel ofrecord on this 12‘“ day
ofJuly 2021 as follows:
James H. Hunter, Jr.
M. David Alexander
ROYSTON, RAYZOR, VICKERY & WILLIAMS, LLP
Jim.hunlcru1rm'stonlauzcom
55 Cove Circle
Brownsville, Texas 78523 3509
/s/ miw ca rrcra
OF: LAW OFFICE OF EFRAlN CARRERA, P.C
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Electronically Filed 7/12/2021 2:18 PM Hidalgo County District Clerks Reviewed By: Alexis Bonilla C-2715-21-A CAUSE NO. ERIKA DEL CARMEN SEBA, as Next § IN THE DISTRICT COURT OF Friend of KARLA FERNANDA GOMEZ, § BRAYAN DE JESUS GOMEZ AND § ALEYDA GOMEZ; Minor Children § § HIDALGO COUNTY, TEXAS VS. § § CARLOS ROLDAN and RCA § TRANSPORT § JUDICIAL DISTRICT JOINT AGREED MOTION FOR APPOINTMENT OF GUARDIARN AD LITEM & T0 SET FRIENDLY SUIT HEARING TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Plaintiff, ERIKA DEL CARMEN SEBA, as Next Friend of KARLA FERNANDA GOMEZ, BRAYAN DE JESUS GOMEZ AND ALEYDA GOMEZ Minor Children (“Plaintiff”), and Defendants, CARLOS ROLDAN and RCA TRANSPORT (“Defendants”), and pursuant to Texas Rule of Civil Procedure 173, file this, their Joint Agreed Motion for Appointment of a Guardian Ad Litem and to set a friendly suit hearing. In support thereof, the parties would respectfully show the following: This isa personal injury suit arising out ofautomobile accident. Plaintiff Erika Del Carmen Seba, as Next Friend of KARLA FERNANDA GOMEZ, BRAYAN DE JESUS GOMEZ AND ALEYDA GOMEZ., minor children, alleges the minor children sustained injuries and damages as a result of the accident. Plaintiff has reached a settlement with the Defendants in this case. In an effort to avoid any potential conflicts of interests, Plaintiffand Defendants, pursuant to Texas Rule ofCivil Procedure 173, ask this Court to appoint a Guardian Ad Litem to represent the best interests of the minor Electronically Filed 7/12/2021 2:18 PM Hidalgo County District Clerks Reviewed By: Alexis Bonilla C-2715-21-A children involved in this case, to review the settlement, make appropriate recommendations to the Court, and to set this matter for a friendly suit hearing. WHEREFORE, PREMISES CONSIDERED, Plaintiff ERIKA DEL CARMEN, as next Friend of KARLA FERNANDA GOMEZ, BRAYAN DE JESUS GOMEZ AND ALEYDA GOMEZ, Minor Children, and Defendants, CARLOS ROLDAN and RCA TRANSPORT, respectfully pray that this Honorable Court enter their Proposed Order granting their Joint Motion to Appoint Guardian Ad Litem, appoint a suitable Guardian Ad Litem to look out for and protect the interest of the minor children involved in this case, and to set a hearing to consider the settlement. Respectfully submitted, LAW OFFICE 0F EFRAIN CARRERA, P.C. /s/ aim. carrcra Efrain Carrera State Bar No. 24025284 cl'rainczn‘rcruIKulvzlhooxom 61 7 South 12‘“ Street Edinburg, Texas 78539 Tel: (956) 387-0909 Fax: (956) 387-0914 ATTORNEY FOR ERIKA DEL CARMEN SEBA, as Next Friend of K.G., B.G. and A.G., Minor Children. ROYSTON, RAYZOR, VICKERY & WILLIAMS, L.L.P. /s/ James H. Huwter, Jr. James H. Hunter, Jr. State Bar No. 00784311 55 Cove Circle P. O. Box 3509 Brownsville, Texas 78523-3509 Tel: (956) 542-4377 Fax: (956) 542-4370 Electronically Filed 7/12/2021 2:18 PM Hidalgo County District Clerks Reviewed By: Alexis Bonilla C-2715-21-A Attorney for Defendants CARLOS ROLDAN and RCA TRANSPORT CERTIFICATE OF SERVICE Ihereby certify that a true and correct copy of the above and foregoing Joint Motion for Appointment of Guardian Ad Litem was emailed to all known counsel ofrecord on this 12‘“ day ofJuly 2021 as follows: James H. Hunter, Jr. M. David Alexander ROYSTON, RAYZOR, VICKERY & WILLIAMS, LLP Jim.hunlcru1rm'stonlauzcom 55 Cove Circle Brownsville, Texas 78523 3509 /s/ miw ca rrcra OF: LAW OFFICE OF EFRAlN CARRERA, P.C