Stipulation,Agreement: COLEMAN, KELLY vs. NASSAR, EMILE

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                                Cause Number 2017-66216

Kelly    Coleman                                                In the District Court

         Plaintiff,

versus


Emile Nassar, Robert Cummings, and
The Board of Trustees of the Pines
Condominium Association, Inc
                                                                of Harris County, Texas
         Defendants

Action Premier Hauling, ,

         Intervenor

Bob Wolfe

         Defendant                                  §           157 Judicial District

    Action Premier Hauling, Inc.’sObjection and Response to the “Agreed” Motion for
                                              Continuance

To the Honorable District Judge:

         Action Premier Hauling, LLC, Intervenor, files this Response Plaintiffs and Defendants’

Motion for Continuance (“Motion”):

                   This Court has set the matter
                                             for trial for a two week docket beginning April 30,



                   On Apmil 5, 2018, Plaintiff and Defendants filed an “Agreed” Joint Motion for

                   Continuance of Trial Setting.   Intervenor did not agree to the continuance

                   motion.

                   On Apmil 3, 2018, the undersigned informed Defendants’ counsel that Intervenor

                 ‘was opposed to the motion for continuance.    A true and correct
                                                                                copy of the

Objection and Response to Continuance - Page            1
correspondence is attached hereto as Exhibit “1.”

              The Motion does not contain a certificate of conference that reflects our written

              correspondence.    Defendants have misled and misrepresentedmaterial facts to

              this Court.

              Plaintiffs and Defendants have failed to participate in much of this lawsuit,

              have failed to respond to discovery, faile to respond to correspondence regarding

              mediation, failed to produce documents, and have filed an untimely jury demand.

              Defendants simply seek to avoid payment to Intervenor, so that Intervenor can use

              their funds to pay others to fix up the condominiunumits.    The longer
                                                                                  they can

              postpone
                  this trial, the more money they can use on other projects.

              Accordingto DefendantEmile Nassar’ s only court filings , Mr. Wolfe, Plaintiff’s

              attomey is on the board of Defendant Pines Condominium Association, Inc.            I am

              sure he is willingto settle a lawsuit with himself.

              The Condominium Association can call a meeting to discuss settlement with five

              days’ noticeArticle IV, Paragraph 3(10) of the Association's By       Laws that

             were authenticated
                          as Exhibit 1 to the Injunction hearing and attached hereto as

              Exhibit “.”   There is plenty of time before trial to accomplish this simple task

              There
                is currently a temporary injunction in place and it will expire
                                                                            on its own

              tems on April 30, 2018, as a result of the continuance motion.

                                              Prayel

       Intervenor, Action Premier Hauling, LLC, prays the Court denies “Agreed” Motion for

Continuanceand grant such other relief to which Action Premier Hauling, LLC may show itself


Objection and Response to Continuance        Page
entitled.

                                              Respectfully submitted,

                                                       /s Travis Owens
                                              Travis Owens
                                              Texas Bar Number 24065859
                                              Owens Law Group, P.L.L.C.
                                              P.O. Box 8605
                                              The Woodlands, TX 77387
                                              Tel. (936) 828
                                              Fax. (832) 327
                                              travis@owens lawgroup.com

                                              Attomey for Intervenor


                                  CERTIFICATE OF SERVICE

            I certify
                 that on April 5, 2018a true and correct copy of the foregoing was served
                                                                                      to each
  rson listed below, viae file, pursuantto Texas Rules of Civil Procedure 21 and 21a.

Robert C. E. Wolfe
7001 Corporate Drive, Suite 216
Houston, Texas 77036
texaslawhelp@yahoo.com

William S. Chesney, III
9225 Katy Fwy, Suite 250
Houston, Texas 77024
wchesney@felct.com


                                                       /s_ Travis Owens
                                              Travis Owens




Objection and Response to Continuance        Page