Motion to Stay, Filed - ON BOTH JUNE 24TH HEARING AND THIS CAUSE-C-1007-24-F June 17, 2024 (2024)

On February 29, 2024 aHearingwas filedinvolving a dispute betweenRodriguez, Henry,andPhillips, Gilda,Rodriguez, Roberto,for Real Property - Other Real Property (OCA)in the District Court of Hidalgo County.

 
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 LED O CLOCK M JUN Y .7 202‘! CAUSE NO. C—1007-24-F LAU ‘ ‘ HENRYR ODRIGUEZ § IN '1 l H z DIS l ' RI(B&D(is(t)rliclt z 099M35 Plaintiff. § § § VS. § 332M) JUDICIAL DISTRICT § ROBERTO RODRIGUEZ JR. § Defendant. § IHDALGU COUNTY. TEXAS PLAINTIFF’S MOTION FOR A STAY 0N BOTH JUNE 24"“ HEARING AND THIS CAUSE — (.'-1007-24-F Plaintiff. Henry Rodriguez. as Pro—Sc files this ‘Motion‘ t0 request from this Court for astay/hold on both the June 24. 2024 Hearing and this Cause C-1007-24—F until a new counsel canbe hired. This 24‘“ date hearing was requested by Defendant 0n his 'Motion T0 Dismiss. . Plaintiff‘s counsel. Attomey Joseph Preston. has voluntarily removed himself: as so shownon his ‘Motion for Leave T0 Withdraw From Counsel.‘ Please sec Plaintiff‘s own version 0foccurrences 0n “Plaintiff‘s Notice ot‘Attorncy’s Removal From This Cause And Thisdocument was necessitated I0 set the record straight. And so that the Plaintiff be given a fairchance for justice without a dark cloud handing over his hcad for the mere fact that his counselhas decided to quit after his many failures. The 'Plaintift‘s Notice ofAttorney's RemovalFrom.....‘ will demonstrate that because ofAttorncy Preston‘s failures. the Plaintiffhas beenevicted from his own home when the Defendant knows he had n0 right t0 evict being that hedoes not have 100% ownership ofproperty. And when thc 0an case. P37.920. is being probatedfor the other half ofownership I0 property. Plaintiff fears that Atlomey Preston might have failed t0 file any documents 0n time thatcould dismiss or hinder this case. Just like a mcrc $350 fee 0r the $1.800 bond was not paid byhim. when the Plaintiff‘s two sisters ran 10 wire the money. the attorney requested. His failureshave caused an unlawful, immoral. uncaring. unjustifiable. costly. horrific. but most 0f all. ahumiliating EVICTION l0 the terminally ill Plaintiff— brother. that has only shown them love. Plaintiffasks this Court for a fair chance t0 prove his case without a dark cloud over his headbecause of the failures 0f his counsel. He is asking for a chance t0 be able t0 demonstrate. withevidence, his case; after trying so hard t0 negotiate with the Defendant to avoid this lawsuit. PLAINTIFF’S SUPPORTING EVIDENCE Attorney Preston was sent by thc Plaintiff. as our evidence. the same 3 exhibits that theDefendant is using. lfAttomey Preston would have listened to the Plaintiff. t0 file these 3 deedsas Plaintiff‘s exhibits. the Defendant would have zero exhibits t0 present t0 this Court.Nevertheless. the Plaintiffwill use Defendant's own Exhibits l. 2. and 3. copies of 3 deeds. tohelp prove his case and lists below his supporting evidence as follows: EXHIBIT A MOTHER‘S COPY OF WILL — NOT PROBATED EXHIBIT B EXAMPLE OF ANOTHER DEED BY SAME LAW FIRM EXHIBIT D ESEQUIEL‘S SIGNED WAIVER ON EXPIRED NOTARY STAMP ON CASE P37.920 (DECEASED SIBIJNG) EXHIBIT E JUANITA RODRIGUEZ AFFIDAVIT ()N NO NOTARY PRESENT (SISTER-lN-LAW) EXHIBIT F ANNA LARA‘S AFFIDAVIT (SIBLING) EXHIBIT G ELISA BALLI‘S AFFIDAVI'I‘ (SIBLING) EXHIBIT H HENRY RODRIGUEZ AFFIDAVIT (PLAINTIFF) EXHIBIT l ROLANDO BALL! AFFIDAVIT (NEPHEW) EXHIBIT L RUBEN RODRIQUEZ FACTUAL SIGNATURE ON HIS MILITARY RECORDS (DECEASED SIBLING) PRAYER WHEREAS, Plaintiff prays that a temporary stay bc granted andjuslicc be done by this courtin his favor. and for such other and furthcr rclicl‘us this mun dccmsjusl zmd proper. Respectfully submitted. /s/ Henfl Rodriguez Henry Rodriguez P.(). Box I78 La Tx 78562 Villa. Phone: (713) 826-6375 Email: rodriguezhenryl 102@gmal.com CERTIFICATE OF SERVICE On the 14th day of June 2024. a copy ot‘this pleading was served on counsel ofrecord by email. /s/ Henm Rodriguez Henry Rodriguez P.().Box I78 La Villa. Tx 78562 Phone: (713) 826—6375 Email: rodriguezhenryl 102@gmal.com ATTORNEY OF RECORD: Attorney Jordan King King Law Firm Texas Bar No.24090522 Email: Jordan kingf(ilrkingrgvlawxom W/cc: corozco’u kinurgvlanzcmn 3409 North 10‘“ Street McAllen. Texas78501 Phone #z (956) 687-6294