If you entered this page from a search engine or another link, Click Here, to enter our site.
©1998-2000 Page Designed by: Don Thompson
IN THE COUNTY COURT AT LAW NUMBER TWO
EL PASO COUNTY, TEXAS
DONALD L. THOMPSON,
Plaintiff, Pro-Se
vs. Cause No. 94-12,817
ALLSTATE INSURANCE COMPANY
and ROBERT WILSON,
DefendantsMOTION FOR CONTINUANCE AND SPECIAL SETTING
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW the Defendant, ALLSTATE INSURANCE COMPANY, by and through its attorney, and moves the Court to enter an order for a continuance of the current trial setting of June 1,1998; and to reschedule as a special setting, and, as grounds therefore, would show to the Court as follows:
I. REQUEST FOR CONTINUANCE
Again, this matter is currently set for trial on June 1,1998. Counsel for Plaintiff is currently scheduled to be out of the country during the entire week of June 1,1998. This matter was set for trial without any pretrial conference or other scheduling conference. Further, Plaintiff has not filed any certificate of readiness in this case. This Defendant needs a continuance in order to properly prepare for trial of this matter. This motion is not made for the purposes of delay, but only so that adequate discovery and trial preparation can be accomplished and this matter can proceed to trial.
II. REQUEST FOR SPECIAL SETTING
All of the factual matter in this lawsuit occurred outside of El Paso County and it will be necessary to bring all fact witnesses as well as all expert witnesses from other parts of Texas. Under the circumstances, Defendant requests that the Court schedule this matter as a special setting, giving the parties adequate time to notify all witnesses and arrange for their appearance at trial.
WHEREFORE, Defendant requests that the Court cancel the current trial setting of June 1, 1998, and considering rescheduling this matter as a special setting.
Respectfully submitted,
THE LAW OFFICE OF VICTOR F. POULOS, P.C. Attorneys for Defendant
If you will notice above attorney for Defendant said counsel for the Plaintiff would be out of town. That's me, and I had no intention of being out of town so I objected for this reason. Judge just laughed and asked, what kind of an attorney would make that kind of mistake. Also as you can see above, his other reason was that I hadn't filed readiness certificate. I pointed out to the Judge that it had been filed since 09-23-97. Judge still granted the continuance. As of this date, I have not been able to get another trial setting.
If you entered this page from a search engine or another link, Click Here, to enter our site.
©1998-2000 Page Designed by: Don Thompson