On January 28, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Carrasco, Victor,
and
Stockham, Brian,
for Inj/Damage-Motor Vehicle >$200,000
in the District Court of Montgomery County.
Preview
Received and E-Filed for Record
9/9/2021 7:50 AM
Melisa Miller, District Clerk
Montgomery County, Texas
Deputy Clerk, Catherine Gant
Cause No. 21-01-01333
VICTOR CARRASCO § IN THE DISTRICT COURT
§
VS. § 284TH JUDICIAL DISTRICT
§
BRIAN STOCKHAM § MONTGOMERY COUNTY, TEXAS
Agreed Motion for Continuance
All parties move for a continuance of the trial, which is set for October 18, 2021. This is
the first trial setting.
1.
The parties have been unable to complete discovery, despite diligently attempting to do so.
The parties need additional time to conduct additional discovery and prepare for trial. Further, the
parties have not been able to schedule mediation prior to the trial setting and need additional time
to mediate the case.
2.
This request is not sought for delay, but so that justice may be done for all parties.
All parties respectfully request that the Court remove this case from its current trial setting
and reset this case for trial at a later date and grant other relief, both general and special, to which
the parties are entitled.
Respectfully submitted,
___________________________*w/permission
Nathan Surprise
TBN: 24097163
440 Louisiana St, Suite 1400
Houston, TX 77002
Telephone: (713) 588-0383
Facsimile: (713) 587-9086
Email: e-service@daspitlaw.com
Attorney for Plaintiff Victor Carrasco
Linda M. Villarreal & Associates
Kristi C. Skillern
Texas Bar Number: 00786328
1221 Lamar, Suite 900
Houston, Texas 77010
Telephone: (713) 437-8200
Facsimile: (855) 460-3974
Email: stex.law-villarreal@statefarm.com
Attorneys for Defendant
Neal R. Stockham
Certificate of Conference
All counsel and/or pro se parties have conferred and agreed to this motion.
Kristi C. Skillern
Certificate of Service
I certify that a copy of this document was served pursuant to the Texas Rules of Civil
Procedure on all parties and/or their respective attorneys of record on September 9, 2021.
Kristi C. Skillern
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Deonna Langford on behalf of Kristi Skillern
Bar No. 786328
deonna.langford.j2jd@statefarm.com
Envelope ID: 57073691
Status as of 9/9/2021 11:20 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Alma Lira Alira@proactivelegal.com 9/9/2021 7:50:55 AM SENT
Daspit Proactive Legal daspit@proactivelegal.com 9/9/2021 7:50:55 AM SENT
Jaime Holder jholder@proactivelegal.com 9/9/2021 7:50:55 AM SENT
Nathan Surprise Nathan@daspitlaw.com 9/9/2021 7:50:55 AM SENT
Alexandria Pacioni alexandria@daspitlaw.com 9/9/2021 7:50:55 AM SENT
John Daspit e-service@daspitlaw.com 9/9/2021 7:50:55 AM SENT
Document Filed Date
September 09, 2021
Case Filing Date
January 28, 2021
Category
Inj/Damage-Motor Vehicle >$200,000
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Received and E-Filed for Record 9/9/2021 7:50 AM Melisa Miller, District Clerk Montgomery County, Texas Deputy Clerk, Catherine Gant Cause No. 21-01-01333 VICTOR CARRASCO § IN THE DISTRICT COURT § VS. § 284TH JUDICIAL DISTRICT § BRIAN STOCKHAM § MONTGOMERY COUNTY, TEXAS Agreed Motion for Continuance All parties move for a continuance of the trial, which is set for October 18, 2021. This is the first trial setting. 1. The parties have been unable to complete discovery, despite diligently attempting to do so. The parties need additional time to conduct additional discovery and prepare for trial. Further, the parties have not been able to schedule mediation prior to the trial setting and need additional time to mediate the case. 2. This request is not sought for delay, but so that justice may be done for all parties. All parties respectfully request that the Court remove this case from its current trial setting and reset this case for trial at a later date and grant other relief, both general and special, to which the parties are entitled. Respectfully submitted, ___________________________*w/permission Nathan Surprise TBN: 24097163 440 Louisiana St, Suite 1400 Houston, TX 77002 Telephone: (713) 588-0383 Facsimile: (713) 587-9086 Email: e-service@daspitlaw.com Attorney for Plaintiff Victor Carrasco Linda M. Villarreal & Associates Kristi C. Skillern Texas Bar Number: 00786328 1221 Lamar, Suite 900 Houston, Texas 77010 Telephone: (713) 437-8200 Facsimile: (855) 460-3974 Email: stex.law-villarreal@statefarm.com Attorneys for Defendant Neal R. Stockham Certificate of Conference All counsel and/or pro se parties have conferred and agreed to this motion. Kristi C. Skillern Certificate of Service I certify that a copy of this document was served pursuant to the Texas Rules of Civil Procedure on all parties and/or their respective attorneys of record on September 9, 2021. Kristi C. Skillern Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Deonna Langford on behalf of Kristi Skillern Bar No. 786328 deonna.langford.j2jd@statefarm.com Envelope ID: 57073691 Status as of 9/9/2021 11:20 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Alma Lira Alira@proactivelegal.com 9/9/2021 7:50:55 AM SENT Daspit Proactive Legal daspit@proactivelegal.com 9/9/2021 7:50:55 AM SENT Jaime Holder jholder@proactivelegal.com 9/9/2021 7:50:55 AM SENT Nathan Surprise Nathan@daspitlaw.com 9/9/2021 7:50:55 AM SENT Alexandria Pacioni alexandria@daspitlaw.com 9/9/2021 7:50:55 AM SENT John Daspit e-service@daspitlaw.com 9/9/2021 7:50:55 AM SENT