On October 05, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Action Premier Hauling Inc,
Coleman, Kelly,
and
Board Of Trustees Of The Pines Condominium Association Inc,
Cummings, Robert,
Nassar, Emile,
Coleman, Kelly,
Creative Management Company,
Omega Contractors,
Santino, Laska,
Unknown Foundation Repair Company,
Wolfe, Bob,
Wolfe, Robert,
for OTHER CIVIL
in the District Court of Harris County.
Preview
CAUSE NO. 2017-66216
KELLY COLEMAN § IN THE DISTRICT COURT
§
vs § OF HARRIS COUNTY, TEXAS
§
EMILE NASSAR, ROBERT CUMMINGS §
AND THE BOARD OF TRUSTEES OF §
THE PINES CONDOMINIUM §
ASSOCIATION, § 157TH JUDICIAL DISTRICT
MOTION FOR CONTINUANCE
Plaintiff's attorney, ROBERT WOLFE, Movant herein, files this Motion for Continuance
and respectfully shows the Court as follows:
1. This case is set for trial on September 17, 2018. Movant requests a continuance of
this case for 90 days for the reasons stated below:
2. Attorney Robert Wolfe has recently been diagnosed with atrial fibrillation by Dr.
Reynolds Delgado, Cardiologist. Treatment of this condition with medication has been
unsuccessful at this time, blood pressure continues to be at stroke levels. Dr. Delgado is warning
to stay away from stressful situations and will be performing procedure to look for blood clots
and if no blood clots are found then Dr. Delgado will do a cardiac reset procedure n order to
attempt to correct the heart rhythm.
3. This continuance is not sought for delay only, but that justice may be done.
4, Movant has attached an affidavit to this Motion which is incorporated herein for all
purposes.
PRAYER: Movant prays that the Court set this matter for hearing and, at the conclusion
thereof, the Court continue this case as requested above.Respectfully submitted,
Law Office of Robert C. E. Wolfe
7001 Corporate Dr, Suite 216
Houston, TX 77036
EK WLI—
Robert Wolfe
Attorney for: Plaintiff
Phone: 713-225-5244
Fax: 1-855-329-7239
Email: texaslawhelp@yahoo.com
CERTIFICATE OF CONFERENCE
I certify that I was not able to confer with Travis Owens, counsel for the Intervenor, I
email Mr. Owens on August 27, 2018 and I have had no response. Mr. William Chesney attorney
for The Pines Condominiums has agreed to the reset.
Date: August 29, 2018
EER WRF —
Robert Wolfe
AGREED TO CONTINUANCE
WIA ( [bara
William s- Chesney, If1
Texas Bar No. 2475657
Attorney for: EMILE NASSAR, ROBERT CUMMINGS and THE BOARD OF TRUSTEES
OF THE PINES CONDOMINIUM ASSOCIATION,
Email: wehesney@felct.com
Telephone: 713.224.9400
Fax: 713.224.0609
9225 Katy Fwy., Suite 250
Houston, TX 77024CERTIFICATE OF SERVICE
As required by Rule 21a, Texas Rules of Civil Procedure, I certify that on August 29,
2018, a true and correct copy of this document was served on the following attorneys in the
manner indicated:
William s. Chesney, III was served electronically through the electronic filing manager.
Travis Owens was served electronically through the electronic filing manager.
IRENE
Robert WolfeCAUSE NO. 2017-66216
KELLY COLEMAN § IN THE DISTRICT COURT
§
vs § OF HARRIS COUNTY, TEXAS
§
EMILE NASSAR, ROBERT CUMMINGS § 157TH JUDICIAL DISTRICT
AND THE BOARD OF TRUSTEES OF §
THE PINES CONDOMINIUM §
ASSOCIATION,
AFFIDAVIT IN SUPPORT OF MOTION FOR CONTINUANCE
STATE OF TEXAS
COUNTY OF HARRIS
BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared
the person known by me to be Law Office of Robert C. E. Wolfe, P.C. who, after being by me
duly sworn, testified as follows:
“My name is Law Office of Robert C. E. Wolfe, P.C., I am over 18 years of age, I am
competent to make this affidavit and I have personal knowledge of the matters stated herein.
“T have read the attached Motion for Continuance and all matters stated therein are true
and correct.
“T have recently been diagnosed with atrial fibrillation by Dr. Reynolds Delgado,
Cardiologist. Treatment of this condition with medication has been unsuccessful at this time,
blood pressure continues to be at stroke levels. Dr. Delgado is warning to stay away from
stressful situations and he will be performing a procedure to look for blood clots, if no blood
clots are found then Dr. Delgado will do a cardiac reset procedure in order to attempt to correct
the heart rhythm.”
“T am requesting a 90 day reset to recover from this medical procedure.”“ee A
Robert C. E. Wolfe
SUBSCRIBED AND SWORN TO before me on August 29, 2018.
ns, wolfe
Notary Public
MEL HUANG WOLFE
Notary Public, State of Texas
‘comm. Expires 10-27-2019
Notary 1D 130420579
Preview
CAUSE NO. 2017-66216 KELLY COLEMAN § IN THE DISTRICT COURT § vs § OF HARRIS COUNTY, TEXAS § EMILE NASSAR, ROBERT CUMMINGS § AND THE BOARD OF TRUSTEES OF § THE PINES CONDOMINIUM § ASSOCIATION, § 157TH JUDICIAL DISTRICT MOTION FOR CONTINUANCE Plaintiff's attorney, ROBERT WOLFE, Movant herein, files this Motion for Continuance and respectfully shows the Court as follows: 1. This case is set for trial on September 17, 2018. Movant requests a continuance of this case for 90 days for the reasons stated below: 2. Attorney Robert Wolfe has recently been diagnosed with atrial fibrillation by Dr. Reynolds Delgado, Cardiologist. Treatment of this condition with medication has been unsuccessful at this time, blood pressure continues to be at stroke levels. Dr. Delgado is warning to stay away from stressful situations and will be performing procedure to look for blood clots and if no blood clots are found then Dr. Delgado will do a cardiac reset procedure n order to attempt to correct the heart rhythm. 3. This continuance is not sought for delay only, but that justice may be done. 4, Movant has attached an affidavit to this Motion which is incorporated herein for all purposes. PRAYER: Movant prays that the Court set this matter for hearing and, at the conclusion thereof, the Court continue this case as requested above.Respectfully submitted, Law Office of Robert C. E. Wolfe 7001 Corporate Dr, Suite 216 Houston, TX 77036 EK WLI— Robert Wolfe Attorney for: Plaintiff Phone: 713-225-5244 Fax: 1-855-329-7239 Email: texaslawhelp@yahoo.com CERTIFICATE OF CONFERENCE I certify that I was not able to confer with Travis Owens, counsel for the Intervenor, I email Mr. Owens on August 27, 2018 and I have had no response. Mr. William Chesney attorney for The Pines Condominiums has agreed to the reset. Date: August 29, 2018 EER WRF — Robert Wolfe AGREED TO CONTINUANCE WIA ( [bara William s- Chesney, If1 Texas Bar No. 2475657 Attorney for: EMILE NASSAR, ROBERT CUMMINGS and THE BOARD OF TRUSTEES OF THE PINES CONDOMINIUM ASSOCIATION, Email: wehesney@felct.com Telephone: 713.224.9400 Fax: 713.224.0609 9225 Katy Fwy., Suite 250 Houston, TX 77024CERTIFICATE OF SERVICE As required by Rule 21a, Texas Rules of Civil Procedure, I certify that on August 29, 2018, a true and correct copy of this document was served on the following attorneys in the manner indicated: William s. Chesney, III was served electronically through the electronic filing manager. Travis Owens was served electronically through the electronic filing manager. IRENE Robert WolfeCAUSE NO. 2017-66216 KELLY COLEMAN § IN THE DISTRICT COURT § vs § OF HARRIS COUNTY, TEXAS § EMILE NASSAR, ROBERT CUMMINGS § 157TH JUDICIAL DISTRICT AND THE BOARD OF TRUSTEES OF § THE PINES CONDOMINIUM § ASSOCIATION, AFFIDAVIT IN SUPPORT OF MOTION FOR CONTINUANCE STATE OF TEXAS COUNTY OF HARRIS BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared the person known by me to be Law Office of Robert C. E. Wolfe, P.C. who, after being by me duly sworn, testified as follows: “My name is Law Office of Robert C. E. Wolfe, P.C., I am over 18 years of age, I am competent to make this affidavit and I have personal knowledge of the matters stated herein. “T have read the attached Motion for Continuance and all matters stated therein are true and correct. “T have recently been diagnosed with atrial fibrillation by Dr. Reynolds Delgado, Cardiologist. Treatment of this condition with medication has been unsuccessful at this time, blood pressure continues to be at stroke levels. Dr. Delgado is warning to stay away from stressful situations and he will be performing a procedure to look for blood clots, if no blood clots are found then Dr. Delgado will do a cardiac reset procedure in order to attempt to correct the heart rhythm.” “T am requesting a 90 day reset to recover from this medical procedure.”“ee A Robert C. E. Wolfe SUBSCRIBED AND SWORN TO before me on August 29, 2018. ns, wolfe Notary Public MEL HUANG WOLFE Notary Public, State of Texas ‘comm. Expires 10-27-2019 Notary 1D 130420579