On December 18, 2018 a
Stipulation,Agreement
was filed
involving a dispute between
Del Bosque, Eduardo,
and
Barbosa, Juan,
for OTHER (CIVIL)
in the District Court of Dallas County.
Preview
FILED
11/29/2021 9:57 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Dorothy Strogen DEPUTY
CAUSE NO. DC-18-18847
EDUARDO DEL BOSQUE § IN THE DISTRICT COURT OF
§
§
Plainttffi §
§ DALLAS COUNTY, TEXAS
v. §
§
JUAN BARBOSA, §
§
Defendant. § 192ND JUDICIAL DISTRICT
AGREED MOTION FOR CONTINUANCE
The Parties in this matter jointly submit this Agreed Motion for Continuance of the trial
setting of December 6, 2021 because the Parties have made concrete commitments based on the
Court’s prior order setting the trial for January 3, 2022.
1. The Court entered an Order Granting the parties’ Joint Motion to Reinstate and
ordered the parties to submit a joint scheduling order with a “trial date no later than January 3.”
Accordingly, the parties submitted an Agreed Scheduling Order as directed on September 13,
2021, which requested a trial date for December 6, 2021.
2. On September 13, 2021, the Court entered an order setting trialin this matter for
January 3, 2021.
3. Subsequently, counsel for the Parties made other commitments. Counsel for
Plaintiff is now committed to two hearings on December 6, 2021, including: an adversary
proceeding in In Re EFO Holdings, LP Case No. 12-37936-hdh7 in the United States Bankruptcy
Court for the Northern District of Texas; and a hearing on a significant matter in Synergy v.
Hinduja Global Solutions, Inc. Cause No. DC-19-20539 pending in the 19lst Judicial District in
Dallas County.
AGREED MOTION FOR CONTINUAN CE PAGE 1
4. Counsel for Defendant also made personal commitments for December 6, 2021
after the Court had entered its order setting trial for January 3, 2022.
5. The Parties have continued to work together in good faith and have exchanged trial
exhibits lists and discussed stipulations. The Parties respectfully request that the Court reset trial
in this matter for January 3, 2022 as previously set so counsel for the Parties may keep their other
commitments.
AGREED:
Gregog A. Brasstzeld David 0 ’Dens
Gregory A. Brassfield David O’Dens
Bar No. 24079900 Bar No. 15198100
gbrassfield@lynnllp.com odens@settlepou.com
Lynn Pinker Hurst & Schwegmann LLP SettlePou
2100 Ross Avenue 3333 Lee Parkway
Suite 2700 Eighth Floor
Dallas, Texas 75201 Dallas, Texas 75219
214-981-3800 214-520.3300
AGREED MOTION FOR CONTINUAN CE PAGE 2
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.
Envelope ID: 59498593
Status as of 11/29/2021 11:27 AM CST
Associated Case Party: EDUARDO DEL BOSQUE
Name BarNumber Email TimestampSubmitted Status
Christopher W.Patton cpatton@lynnllp.com 11/29/2021 9:57:19 AM SENT
Gregory Brassfield gbrassfield@lynnllp.com 11/29/2021 9:57:19 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
David M.O'Dens odens@settlepou.com 11/29/2021 9:57:19 AM SENT
April Sandefur asandefur@lynnllp.com 11/29/2021 9:57:19 AM SENT
Jordan Whiddon jwhiddon@tailimsong.com 11/29/2021 9:57:19 AM SENT
Yuliana Ramirez yuliana@tailimsong.com 11/29/2021 9:57:19 AM SENT
Daniel Polese 24102364 dpolese@lynnllp.com 11/29/2021 9:57:19 AM SENT
Tailim Song tsong@tailimsong.com 11/29/2021 9:57:19 AM SENT
Pam Oakley poakley@lynnllp.com 11/29/2021 9:57:19 AM SENT
Document Filed Date
November 29, 2021
Case Filing Date
December 18, 2018
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED 11/29/2021 9:57 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Dorothy Strogen DEPUTY CAUSE NO. DC-18-18847 EDUARDO DEL BOSQUE § IN THE DISTRICT COURT OF § § Plainttffi § § DALLAS COUNTY, TEXAS v. § § JUAN BARBOSA, § § Defendant. § 192ND JUDICIAL DISTRICT AGREED MOTION FOR CONTINUANCE The Parties in this matter jointly submit this Agreed Motion for Continuance of the trial setting of December 6, 2021 because the Parties have made concrete commitments based on the Court’s prior order setting the trial for January 3, 2022. 1. The Court entered an Order Granting the parties’ Joint Motion to Reinstate and ordered the parties to submit a joint scheduling order with a “trial date no later than January 3.” Accordingly, the parties submitted an Agreed Scheduling Order as directed on September 13, 2021, which requested a trial date for December 6, 2021. 2. On September 13, 2021, the Court entered an order setting trialin this matter for January 3, 2021. 3. Subsequently, counsel for the Parties made other commitments. Counsel for Plaintiff is now committed to two hearings on December 6, 2021, including: an adversary proceeding in In Re EFO Holdings, LP Case No. 12-37936-hdh7 in the United States Bankruptcy Court for the Northern District of Texas; and a hearing on a significant matter in Synergy v. Hinduja Global Solutions, Inc. Cause No. DC-19-20539 pending in the 19lst Judicial District in Dallas County. AGREED MOTION FOR CONTINUAN CE PAGE 1 4. Counsel for Defendant also made personal commitments for December 6, 2021 after the Court had entered its order setting trial for January 3, 2022. 5. The Parties have continued to work together in good faith and have exchanged trial exhibits lists and discussed stipulations. The Parties respectfully request that the Court reset trial in this matter for January 3, 2022 as previously set so counsel for the Parties may keep their other commitments. AGREED: Gregog A. Brasstzeld David 0 ’Dens Gregory A. Brassfield David O’Dens Bar No. 24079900 Bar No. 15198100 gbrassfield@lynnllp.com odens@settlepou.com Lynn Pinker Hurst & Schwegmann LLP SettlePou 2100 Ross Avenue 3333 Lee Parkway Suite 2700 Eighth Floor Dallas, Texas 75201 Dallas, Texas 75219 214-981-3800 214-520.3300 AGREED MOTION FOR CONTINUAN CE PAGE 2 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. Envelope ID: 59498593 Status as of 11/29/2021 11:27 AM CST Associated Case Party: EDUARDO DEL BOSQUE Name BarNumber Email TimestampSubmitted Status Christopher W.Patton cpatton@lynnllp.com 11/29/2021 9:57:19 AM SENT Gregory Brassfield gbrassfield@lynnllp.com 11/29/2021 9:57:19 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status David M.O'Dens odens@settlepou.com 11/29/2021 9:57:19 AM SENT April Sandefur asandefur@lynnllp.com 11/29/2021 9:57:19 AM SENT Jordan Whiddon jwhiddon@tailimsong.com 11/29/2021 9:57:19 AM SENT Yuliana Ramirez yuliana@tailimsong.com 11/29/2021 9:57:19 AM SENT Daniel Polese 24102364 dpolese@lynnllp.com 11/29/2021 9:57:19 AM SENT Tailim Song tsong@tailimsong.com 11/29/2021 9:57:19 AM SENT Pam Oakley poakley@lynnllp.com 11/29/2021 9:57:19 AM SENT