On December 22, 2014 a
Motion,Ex Parte
was filed
involving a dispute between
Velasquez, Carmen,
and
Fiesta Mart, Inc.,
for PROPERTY
in the District Court of Dallas County.
Preview
FILED
DALLAS COUNTY
5/9/2016 5:16:11 PM
FELICIA PITRE
DISTRICT CLERK
CAUSE NO. DC-14-14829
CARMEN VELASQUEZ, § IN THE DISTRICT COURT
Plaintiff, §
§
vs. § 160th JUDICIAL DISTRICT
§
FIESTA MART, INC. §
Defendant. § DALLAS COUNTY, TEXAS
JOINT MOTION TO EXTEND MEDIATION DEADLINE
Plaintiff, Carmen Velasquez, and Defendant Fiesta Mart, Inc. file this Joint Motion to
Extend Mediation Deadline, asking the Court to extend the current mediation deadline set for
May 13, 2016, to June 10, 2016.
I.
This case is set for trial on June 27, 2016. Per the October 22, 2016 Amended Agreed
Scheduling Order, the parties are to mediate this matter with Lexa Auld by May 13, 2016.
However, the parties require additional time to conduct discovery, including the depositions of
two additional fact witnesses. The parties are in the process of coordinating these depositions
and intend to conduct mediation in late May or early June. The current trial setting will not be
affected by a continuance of the mediation deadline to June 10, 2016.
II.
The Parties therefore pray that the May 13, 2106 mediation deadline be continued to
June 10, 2016, in order for everyone to be fully prepared for mediation. The Parties request
such other and further relief to which they may be entitled.
JOINT MOTION TO EXTEND MEDIATION DEADLINE 1
submitted,
A dj:e"w B. Sommerman
State Bar No. 18842150
andrew@textrial.com
Sommerman & Quesada, L.L.P.
3811 Turtle Creek Blvd., Suite 1400
Dallas, Texas 75219
(214) 720-0720 Telephone
(214) 720-0184 Facsimile
ATTORNEY FOR PLAINTIFF
Respectfully submitted,
/s/ B. Kyle Briscoe
B. Kyle Briscoe
State Bar No. 24069421
kbriscoe@peavlergroup.com
Laura Salinas
State Bar No. 24085573
lsalinas@peavlergroup.com
THE PEAVLER GROUP
2215 Westgate Plaza
Grape~ne,Texas76051
(214) 999-0550
(214) 999-0551 (fax)
ATTORNEYS FOR DEFENDANT
JOINT MOTION TO EXTEND MEDIATION DEADLINE 2
CERTIFICATE OF SERVICE
hereby certify that a true and correct copy of the foregoing document has been
forwarded to all counsel of record pursuant to and in accordance with the Texas Rules of Civil
Procedure on this_ 9th day of May 2016.
/s/ B. Kyle Briscoe
B. Kyle Briscoe
JOINT MOTION TO EXTEND MEDIATION DEADLINE 3
Document Filed Date
May 09, 2016
Case Filing Date
December 22, 2014
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FILED DALLAS COUNTY 5/9/2016 5:16:11 PM FELICIA PITRE DISTRICT CLERK CAUSE NO. DC-14-14829 CARMEN VELASQUEZ, § IN THE DISTRICT COURT Plaintiff, § § vs. § 160th JUDICIAL DISTRICT § FIESTA MART, INC. § Defendant. § DALLAS COUNTY, TEXAS JOINT MOTION TO EXTEND MEDIATION DEADLINE Plaintiff, Carmen Velasquez, and Defendant Fiesta Mart, Inc. file this Joint Motion to Extend Mediation Deadline, asking the Court to extend the current mediation deadline set for May 13, 2016, to June 10, 2016. I. This case is set for trial on June 27, 2016. Per the October 22, 2016 Amended Agreed Scheduling Order, the parties are to mediate this matter with Lexa Auld by May 13, 2016. However, the parties require additional time to conduct discovery, including the depositions of two additional fact witnesses. The parties are in the process of coordinating these depositions and intend to conduct mediation in late May or early June. The current trial setting will not be affected by a continuance of the mediation deadline to June 10, 2016. II. The Parties therefore pray that the May 13, 2106 mediation deadline be continued to June 10, 2016, in order for everyone to be fully prepared for mediation. The Parties request such other and further relief to which they may be entitled. JOINT MOTION TO EXTEND MEDIATION DEADLINE 1 submitted, A dj:e"w B. Sommerman State Bar No. 18842150 andrew@textrial.com Sommerman & Quesada, L.L.P. 3811 Turtle Creek Blvd., Suite 1400 Dallas, Texas 75219 (214) 720-0720 Telephone (214) 720-0184 Facsimile ATTORNEY FOR PLAINTIFF Respectfully submitted, /s/ B. Kyle Briscoe B. Kyle Briscoe State Bar No. 24069421 kbriscoe@peavlergroup.com Laura Salinas State Bar No. 24085573 lsalinas@peavlergroup.com THE PEAVLER GROUP 2215 Westgate Plaza Grape~ne,Texas76051 (214) 999-0550 (214) 999-0551 (fax) ATTORNEYS FOR DEFENDANT JOINT MOTION TO EXTEND MEDIATION DEADLINE 2 CERTIFICATE OF SERVICE hereby certify that a true and correct copy of the foregoing document has been forwarded to all counsel of record pursuant to and in accordance with the Texas Rules of Civil Procedure on this_ 9th day of May 2016. /s/ B. Kyle Briscoe B. Kyle Briscoe JOINT MOTION TO EXTEND MEDIATION DEADLINE 3