On April 11, 2014 a
Motion - TO DISSOLVE TEMPORARY INJUNCTION
was filed
involving a dispute between
Gonzalez, Alejandro Adame,
and
Gonzalez, Jr., Francisco,
Ruiz, Miguel,
for Real Property - Other Real Property (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Filed
7/13/2022 3:52 PM
Hidalgo County District Clerks
Reviewed By: Valerie Garza
CAUSE NO._C-3750-14-I
ALEJANDRO ADAME GONZALEZ, § IN THE DISTRICT COURT
PLAINTIFF §
§
§
VS. § 398TH JUDICIAL DISTRICT
§
MIGUEL RUIZ, §
DEFENDANT § HIDALGO COUNTY, TEXAS
MOTION TO DISSOLVED TEMPORARY INJUNCTION
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Miguel Ruiz, Defendant herein, and files this his Motion to
Dissolved Temporary Injunction Signed on May 19th 2014 in the above styled
and numbered cause and for grounds would show the Court the following:
I. INTRODUCTION
On May 19th, 2014 this honorable entered a Temporary Injunction
restraining and prohibiting Defendant from directly or indirectly selling or
transferring the following described property:
A Five 5.00 acre tract of land being the South 5.00 acres of Lot Three
(3), Block Fifteen (15), Santa Cruz Gardens Unit No. 2 Subdivision, as
recorded in Volume 8, Page 28, Map Records, Hidalgo County, Texas.
II. LACK OF DILIGENT EFFORT TO PROSECUTE
This case has been pending for over 7 years and Plaintiff has made no
diligent effort to include but not limited to any type of discovery to prosecute this
case. Defendant is asking this Honorable Court to not only dissolve the
Temporary Injunction signed on May 19th, 2014 but also dismiss the case for
want of prosecution.
III. LACK OF BOND
According to Plaintiff, Alejandro Adame Gonzalez, Plaintiff states that “On
Mrch 5, 2014, the Defendant Miguel Ruiz appeared before the Defendant
Francisco Gonzalez, a registered and licensed notary public, and acting as if he
(Defendant Ruiz) were the Plaintiff, proceeded to forge the Plaintiff signature
and delivered the deed, purporting to convey the property described in
Electronically Filed
7/13/2022 3:52 PM
Hidalgo County District Clerks
Reviewed By: Valerie Garza
Paragraph III to himself. The Plaintiff never appeared in person before the
notary public, never signed the deed in question, and never had any intention
to deliver or convey his property to the said Defendant Ruiz.
Defendant position is that Plaintiff Alejandro Adame Gonzalez is being
coached by other to make false statement and would ask this court to allow
Defendant to introduce about fifteen minutes of evidence in front of this
honorable court. Is so doing, Defendant will be able to show that Plaintiff
Alejandro Adame Gonzalez is not being truthful.
II. ARGUMENT AND AUTHORITIES
This case has been lingering for over eight years. Defendant believes that
if this Honorable Court a few minutes to present evidence, this case could come
to a finale.
III. RELIEF REQUESTED
Plaintiff hereby requests that the court dissolved the temporary injunction
signed on May 19th, 2014.
WHEREFORE PREMISES CONSIDERED, Defendant Miguel Ruiz. prays
that the court grant an evidentiary hearing, if necessary, and that the temporary
injunction signed on May 19th, 2014, be dissolved by the court Defendant prays
for general relief.
Respectfully submitted,
LAW OFFICE OF
JUAN ANGEL GUERRA
1409 N. Stuart Place Road, Ste A
Harlingen, Texas 78552
956-428-1600
956-428-1601
juanangelguerra1983@gmail.com
SBN: 08581320
Electronically Filed
7/13/2022 3:52 PM
Hidalgo County District Clerks
Reviewed By: Valerie Garza
CERTIFICATE OF SERVICE
This is to certify that on the 13th day of July 2022, a true and correct copy of
the foregoing has been forwarded to all counsel of record as follows:
LAW OFFICE OF ALFREDO MORALES, JR.
P.O. Box 52942
McAllen, Texas 78505
956-536-8800
956-381-4269
Amjr700@gmail.com
______/s/_Juan Angel Guerra____________
Juan Angel Guerra
Document Filed Date
July 13, 2022
Case Filing Date
April 11, 2014
Category
Real Property - Other Real Property (OCA)
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Electronically Filed 7/13/2022 3:52 PM Hidalgo County District Clerks Reviewed By: Valerie Garza CAUSE NO._C-3750-14-I ALEJANDRO ADAME GONZALEZ, § IN THE DISTRICT COURT PLAINTIFF § § § VS. § 398TH JUDICIAL DISTRICT § MIGUEL RUIZ, § DEFENDANT § HIDALGO COUNTY, TEXAS MOTION TO DISSOLVED TEMPORARY INJUNCTION TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Miguel Ruiz, Defendant herein, and files this his Motion to Dissolved Temporary Injunction Signed on May 19th 2014 in the above styled and numbered cause and for grounds would show the Court the following: I. INTRODUCTION On May 19th, 2014 this honorable entered a Temporary Injunction restraining and prohibiting Defendant from directly or indirectly selling or transferring the following described property: A Five 5.00 acre tract of land being the South 5.00 acres of Lot Three (3), Block Fifteen (15), Santa Cruz Gardens Unit No. 2 Subdivision, as recorded in Volume 8, Page 28, Map Records, Hidalgo County, Texas. II. LACK OF DILIGENT EFFORT TO PROSECUTE This case has been pending for over 7 years and Plaintiff has made no diligent effort to include but not limited to any type of discovery to prosecute this case. Defendant is asking this Honorable Court to not only dissolve the Temporary Injunction signed on May 19th, 2014 but also dismiss the case for want of prosecution. III. LACK OF BOND According to Plaintiff, Alejandro Adame Gonzalez, Plaintiff states that “On Mrch 5, 2014, the Defendant Miguel Ruiz appeared before the Defendant Francisco Gonzalez, a registered and licensed notary public, and acting as if he (Defendant Ruiz) were the Plaintiff, proceeded to forge the Plaintiff signature and delivered the deed, purporting to convey the property described in Electronically Filed 7/13/2022 3:52 PM Hidalgo County District Clerks Reviewed By: Valerie Garza Paragraph III to himself. The Plaintiff never appeared in person before the notary public, never signed the deed in question, and never had any intention to deliver or convey his property to the said Defendant Ruiz. Defendant position is that Plaintiff Alejandro Adame Gonzalez is being coached by other to make false statement and would ask this court to allow Defendant to introduce about fifteen minutes of evidence in front of this honorable court. Is so doing, Defendant will be able to show that Plaintiff Alejandro Adame Gonzalez is not being truthful. II. ARGUMENT AND AUTHORITIES This case has been lingering for over eight years. Defendant believes that if this Honorable Court a few minutes to present evidence, this case could come to a finale. III. RELIEF REQUESTED Plaintiff hereby requests that the court dissolved the temporary injunction signed on May 19th, 2014. WHEREFORE PREMISES CONSIDERED, Defendant Miguel Ruiz. prays that the court grant an evidentiary hearing, if necessary, and that the temporary injunction signed on May 19th, 2014, be dissolved by the court Defendant prays for general relief. Respectfully submitted, LAW OFFICE OF JUAN ANGEL GUERRA 1409 N. Stuart Place Road, Ste A Harlingen, Texas 78552 956-428-1600 956-428-1601 juanangelguerra1983@gmail.com SBN: 08581320 Electronically Filed 7/13/2022 3:52 PM Hidalgo County District Clerks Reviewed By: Valerie Garza CERTIFICATE OF SERVICE This is to certify that on the 13th day of July 2022, a true and correct copy of the foregoing has been forwarded to all counsel of record as follows: LAW OFFICE OF ALFREDO MORALES, JR. P.O. Box 52942 McAllen, Texas 78505 956-536-8800 956-381-4269 Amjr700@gmail.com ______/s/_Juan Angel Guerra____________ Juan Angel Guerra