On July 15, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
American Express National Bank,
and
Black Gold Industries Llc,
Roberts, Van,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
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FILED
9/10/2021 11:27 AM
FELICIA PITRE
DISTRICT CLERK
NO. DC-21-O9224 DALLAS 00., TEXAS
Eduardo Suarez DEPUTY
AMERICAN EXPRESS NATIONAL § IN THE DISTRICT COURT
BANK, §
Plaintiff § 193RD JUDICIAL DISTRICT
§
V. § DALLAS COUNTY, TEXAS
§
VAN ROBERTS AND BLACK GOLD §
INDUSTRIES LLC,
Defendant(s)
PLAIN TIFF’S MOTION TO RETAIN CASE ON DOCKET
TO THE HONORABLE JUDGE OF SAID COURT:
AMERICAN EXPRESS NATIONAL BANK, Plaintiff, moves the Court to retain this case
on the Court’s docket and would respectfully show the Court the following:
1. This suit was filed on or about July 15, 2021.
2. Defendant has not yet been served in this cause.
Plaintiff forwarded the citation to a local constable for service and diligently
attempted to locate the Defendant for the purpose of service of process and to
expedite the prosecution of this case.
Plaintiff’ s Motion for Substitute Service was filed on September O9, 2021
(Plaintiff s Motion).
The Order on Plaintiff’ s Motion was signed by the Court on September O9, 2021
(Court’s Order).
Plaintiff has forwarded the Court’s Order to a local constable for service, and
Plaintiff believes that the Defendant will be served in the coming days.
WHEREFORE, premises considered, Plaintiff respectfully requests that the Court retain
this cause on its docket so the Plaintiff may proceed with the Litigation, and the Court grant
Plaintiff such other and further relief to which it may be justly entitled.
Respectfully submitted,
ZWICKER & ASSOCIATES, P.C.
A Law Firm Engaged in Debt Collection
Attorneys for Plaintiff
PO BOX 797488
DALLAS, TX 75379
ZATDLIT@ZWICKERPC.COM
833-510-2100
972-591-0468 (fax)
BY: [8/ y 7W
El DAVID L. WINSTON
STATE BAR NUMBER 21787100
El OLAWALE ADEOGUN
STATE BAR NUMBER 24109562
El ANTONY J. CHERIAN
STATE BAR NUMBER 24087291
IZIOLUWATOYOSI J. THOMAS
STATE BAR NUMBER 24118554
Document Filed Date
September 10, 2021
Case Filing Date
July 15, 2021
Category
CNTR CNSMR COM DEBT
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FILED 9/10/2021 11:27 AM FELICIA PITRE DISTRICT CLERK NO. DC-21-O9224 DALLAS 00., TEXAS Eduardo Suarez DEPUTY AMERICAN EXPRESS NATIONAL § IN THE DISTRICT COURT BANK, § Plaintiff § 193RD JUDICIAL DISTRICT § V. § DALLAS COUNTY, TEXAS § VAN ROBERTS AND BLACK GOLD § INDUSTRIES LLC, Defendant(s) PLAIN TIFF’S MOTION TO RETAIN CASE ON DOCKET TO THE HONORABLE JUDGE OF SAID COURT: AMERICAN EXPRESS NATIONAL BANK, Plaintiff, moves the Court to retain this case on the Court’s docket and would respectfully show the Court the following: 1. This suit was filed on or about July 15, 2021. 2. Defendant has not yet been served in this cause. Plaintiff forwarded the citation to a local constable for service and diligently attempted to locate the Defendant for the purpose of service of process and to expedite the prosecution of this case. Plaintiff’ s Motion for Substitute Service was filed on September O9, 2021 (Plaintiff s Motion). The Order on Plaintiff’ s Motion was signed by the Court on September O9, 2021 (Court’s Order). Plaintiff has forwarded the Court’s Order to a local constable for service, and Plaintiff believes that the Defendant will be served in the coming days. WHEREFORE, premises considered, Plaintiff respectfully requests that the Court retain this cause on its docket so the Plaintiff may proceed with the Litigation, and the Court grant Plaintiff such other and further relief to which it may be justly entitled. Respectfully submitted, ZWICKER & ASSOCIATES, P.C. A Law Firm Engaged in Debt Collection Attorneys for Plaintiff PO BOX 797488 DALLAS, TX 75379 ZATDLIT@ZWICKERPC.COM 833-510-2100 972-591-0468 (fax) BY: [8/ y 7W El DAVID L. WINSTON STATE BAR NUMBER 21787100 El OLAWALE ADEOGUN STATE BAR NUMBER 24109562 El ANTONY J. CHERIAN STATE BAR NUMBER 24087291 IZIOLUWATOYOSI J. THOMAS STATE BAR NUMBER 24118554