Update in TX case. I guess it takes a month to upl
Post# of 8059
Posted On: 04/30/2014 9:22:02 PM
Update in TX case. I guess it takes a month to upload documents to their site. The following is a poorly formatted representation:
Quote:
4/1/2014 2:54:14 PM
Chris Daniel - District Clerk Harris County
Envelope No. 872869
By: GAYLE FULLER
NO. 2012-38724
GEO JS TECH GROUP, INC. § IN THE DISTRICT COURT
Plaintiff, §
§
V. § 269TH JUDICIAL DISTRICT
§
ROBERT COTTON, Et. Al. §
Defendants. § OF HARRIS COUNTY, TEXAS
EMERGENCY MOTION FOR COURT HEARING OR TELEPHONIC CONFERENCE WITH THE COURT
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COME Plaintiff, GEO JS TECH, brings this Emergency Motion for Continuance, and in support hereof show the court the following:
I.
The above-entitled and numbered cause is set for trial on April 21, 2014. Plaintiff has received information from a reliable source that Defendant, Cotton & Western, under the control and management of Mr. Brad Resnick who is the new Chief Executive
Officer has allegedly absconded with the equipment that is subject to the lawsuit. Plaintiff’s counsel has contacted defense counsel to confirm if the allegations are true, however, Plaintiff’s counsel has not heard from defense counsel to determine if the equipment has been transferred without authority. Plaintiff would like to seek emergency court intervention in the matter because of its apprehension of irreparable injury if defendant absconds, transfers or destroys the equipment that is subject and in dispute in this lawsuit.
Since time is of the essence, Plaintiff is requesting court intervention in the matter to help with this urgent issue.
WHEREFORE, PREMISES CONSIDERED, Movants request the Court to grant a time and date that is convenient for the Court to conduct a telephonic conference so that the issue can be resolved.
Respectfully submitted,
LAW OFFICE OF VY NGUYEN, PLLC
By:/s/Vy Nguyen
Vy Nguyen
State Bar No. 24060334
5177 Richmond Ave. Suite 775
Tel. 713.820.1495
Fax. 281.254.7818
Attorney for Movant/Plaintiff
CERTIFICATE OF CONFERENCE
This is to certify that the undersigned attorney attempted in good faith to resolve
the issues without court intervention, however those attempts failed. Therefore, the
matter is presented to the Court for determination.
/s/Vy Nguyen ___________
VY NGUYEN
CERTIFICATE OF SERVICE
I certify that on March 31, 2014, a true and correct copy of Plaintiff's Motion was
served via facsimile.
/s/Vy Nguyen ___________
VY NGUYEN
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