On September 25, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Teresa R Dehnel,
and
The Boxer Property Management Corporation,
for Civil - Employment
in the District Court of Tarrant County.
Preview
342-320239-20 FILED
TARRANT COUNTY
2/10/2022 3:21 PM
THOMAS A. WILDER
Cause No. 342-320239-20 DISTRICT CLERK
TERESA R. DEHNEL, § IN THE DISTRICT COURT
§
Plaintiff, §
§
v. § OF TARRANT COUNTY, TEXAS
§
BOXER PROPERTY MANAGEMENT §
CORPORATION, §
§
Defendant. § 342nd JUDICIAL DISTRICT
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR CONTINUANCE
Because Defendant has not shown good cause for a continuance, Plaintiff opposes the
motion.
Plaintiff has been trying for many months to obtain information concerning (a) the sales
procured by salespersons, and (b) the revenue realized from such sales. Plaintiff requested the
actual contracts only after Defendant claimed it was unable to state the amount of revenue
booked up front (i.e. the amount contracted for), or the actual revenue received.
Defendant’s response to this request for production of the contracts was due on October
15, 2021. The fact that Defendant did not do adequate investigation to produce these documents
when they were due almost four months ago is not grounds for a continuance of the present trial
setting.
Regarding the information Plaintiff is now getting from the current owner of the Holiday
Inn, Defendant is not and cannot be surprised by anything they are providing. As Defendant
stated in a brief to this Court: “All sales information in the PMS should also be contained in
Central Sales,” a computer system that Boxer created and still has. See Defendant’s Response to
Plaintiff’s Second Motion to Compel at ¶ 23 (filed 1/4/22).
1
The new owner is providing information from the PMS that it took over from Defendant,
and Defendant has all such information already. The fact that Plaintiff may now be finally
acquiring access to the information as well is not grounds for continuance of the trial setting.
Wherefore, Plaintiff respectfully requests that the motion be denied.
Respectfully submitted,
/s/ Donald E. Uloth
Donald E. Uloth
Law Office of Donald E. Uloth
Texas Bar No. 20374200
18208 Preston Rd. Suite D-9 # 261
Dallas, Texas 75252
Phone: (214) 989-4396
Email: don.uloth@uloth.pro
Counsel for Plaintiff
CERTIFICATE OF SERVICE
I certify that on February 10, 2022, I served the foregoing document to David Castaneda
by email at David.Castaneda@BoxerProperty.com and to Mark C. Roberts II by email at
Mark.Roberts@BoxerProperty.com.
/s/ Donald E. Uloth
Donald E. Uloth
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.
Donald Uloth on behalf of Donald Uloth
Bar No. 20374200
don.uloth@uloth.pro
Envelope ID: 61639942
Status as of 2/10/2022 3:24 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
David Castaneda david.castaneda@boxerproperty.com 2/10/2022 3:21:32 PM SENT
Mark Roberts Mark.Roberts@BoxerProperty.com 2/10/2022 3:21:32 PM SENT
Donald Uloth don.uloth@uloth.pro 2/10/2022 3:21:32 PM SENT
Riki Henry rikih@boxerproperty.com 2/10/2022 3:21:32 PM SENT
Document Filed Date
February 10, 2022
Case Filing Date
September 25, 2020
Category
Civil - Employment
Status
FINAL JUDGMENT BY JURY VERDICT
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342-320239-20 FILED TARRANT COUNTY 2/10/2022 3:21 PM THOMAS A. WILDER Cause No. 342-320239-20 DISTRICT CLERK TERESA R. DEHNEL, § IN THE DISTRICT COURT § Plaintiff, § § v. § OF TARRANT COUNTY, TEXAS § BOXER PROPERTY MANAGEMENT § CORPORATION, § § Defendant. § 342nd JUDICIAL DISTRICT PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR CONTINUANCE Because Defendant has not shown good cause for a continuance, Plaintiff opposes the motion. Plaintiff has been trying for many months to obtain information concerning (a) the sales procured by salespersons, and (b) the revenue realized from such sales. Plaintiff requested the actual contracts only after Defendant claimed it was unable to state the amount of revenue booked up front (i.e. the amount contracted for), or the actual revenue received. Defendant’s response to this request for production of the contracts was due on October 15, 2021. The fact that Defendant did not do adequate investigation to produce these documents when they were due almost four months ago is not grounds for a continuance of the present trial setting. Regarding the information Plaintiff is now getting from the current owner of the Holiday Inn, Defendant is not and cannot be surprised by anything they are providing. As Defendant stated in a brief to this Court: “All sales information in the PMS should also be contained in Central Sales,” a computer system that Boxer created and still has. See Defendant’s Response to Plaintiff’s Second Motion to Compel at ¶ 23 (filed 1/4/22). 1 The new owner is providing information from the PMS that it took over from Defendant, and Defendant has all such information already. The fact that Plaintiff may now be finally acquiring access to the information as well is not grounds for continuance of the trial setting. Wherefore, Plaintiff respectfully requests that the motion be denied. Respectfully submitted, /s/ Donald E. Uloth Donald E. Uloth Law Office of Donald E. Uloth Texas Bar No. 20374200 18208 Preston Rd. Suite D-9 # 261 Dallas, Texas 75252 Phone: (214) 989-4396 Email: don.uloth@uloth.pro Counsel for Plaintiff CERTIFICATE OF SERVICE I certify that on February 10, 2022, I served the foregoing document to David Castaneda by email at David.Castaneda@BoxerProperty.com and to Mark C. Roberts II by email at Mark.Roberts@BoxerProperty.com. /s/ Donald E. Uloth Donald E. Uloth 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. Donald Uloth on behalf of Donald Uloth Bar No. 20374200 don.uloth@uloth.pro Envelope ID: 61639942 Status as of 2/10/2022 3:24 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status David Castaneda david.castaneda@boxerproperty.com 2/10/2022 3:21:32 PM SENT Mark Roberts Mark.Roberts@BoxerProperty.com 2/10/2022 3:21:32 PM SENT Donald Uloth don.uloth@uloth.pro 2/10/2022 3:21:32 PM SENT Riki Henry rikih@boxerproperty.com 2/10/2022 3:21:32 PM SENT