On July 31, 2023 a
Request,Application
was filed
in the District Court of Caddo County.
Preview
IN THE DISTRICT COURT OF CADDO COUNTY giate of Oklahoma
STATE OF OKLAHOMA Caddo Co.
ALBERT ADAME, Individually
FILED
and as Father and Custodial JUL 31 2023
Parent of E.A., a minor, and
AtL______O'Clock__* M.
ASHLEY ADAME, Individually and PATTI By RGER, Court Clerk
as Mother and Custodial Parent of y.
E.A., a minor,
Plaintiffs,
vs. Case No. C§-2023-F0
JIMMY SELLERS,
As AGENT of MEDLEY MATERIAL C1 - dd bd
HANDLING COMPANY, and ENTERPRISE
FM TRUST
Defendants.
PARTIES’ JOINT APPLICATION TO TRANSFER CASE
FROM “CS” TO “CJ” CIVIL DOCKET
COME NOW the parties, Plaintiffs Alberto Adame and Ashley Adame, as custodial
parents of E.A., a minor, and Defendants Jimmy Sellers, Medley Material Handling Company, and
Enterprise FM Trust, jointly seek an Order of this Court transferring the matter from the “CS”
docket to the “CJ” docket for purposes of resolving the friendly suit. In support hereof, the parties
state:
1 This friendly suit petition and answer was filed May 24, 2023. When filed, it was
accidentally filed as a “CS” matter (where the cause at issue is $10,000 or less). Because it is a
friendly suit whereby a settlement in the amount of $90,000 is at issue, it should have been filed
as a “CJ” case with the amount at issue greater than $10,000. See Exhibits 1 and 2, Petition and
Answer.
Page 1 of 4
2 Herein presented with this Joint Application is a check in the amount of $13.00
made out to the Caddo County Court Clerk, to bring the total filing fee to $242.14
3 The Parties therefore request that this Court transfer the case from a “CS” matter to
“CJ” matter, to be subsequently placed on the docket of the District Judge of Judicial District 6
the Honorable Kory Kirkland.
4 The Parties also present with this filing a proposed Order approving Transfer
Respectfully Submitted,
Adame, dually, and as Father
And Custodial Parent of the minor, E.A.
701 South Lyle Road
Weatherford OK, 73096
Telephone:
PlaintiffPro Se
WY) vt Wy kd im iually, and as Mother
And Custodial P nt of the minor, E.A.
701 South Lyle Road
Weatherford OK, 73096
Telephone:
Plaintiff Pro Se
Page 2 of 4
Eric L. Combs, OBA No. 31024
Matthew J. Becker OBA No. 35057
LYTLE SOULE & FELTY, P.C.
1200 Robinson Renaissance
119 North Robinson Avenue
Oklahoma City, OK 73102
Telephone: (405) 235-7471
Facsimile: (405) 232-3852
combs@lytlesoule.com
becker@lytlesoule.com
Attorneys for Defendant
Page 3 of 4
CERTIFICATE OF SERVICE
This is to certify that on this day of 2023, a true and correct
copy of the above and foregoing instrument was mailed, postage prepaid, to the following:
Alberto Adame
Ashley Adame
701 South Lyle Road
Weatherford OK, 73096
Plaintiffs Pro Se
Eric L. Combs
Page 4 of 4
Document Filed Date
August 01, 2023
Case Filing Date
July 31, 2023
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IN THE DISTRICT COURT OF CADDO COUNTY giate of Oklahoma STATE OF OKLAHOMA Caddo Co. ALBERT ADAME, Individually FILED and as Father and Custodial JUL 31 2023 Parent of E.A., a minor, and AtL______O'Clock__* M. ASHLEY ADAME, Individually and PATTI By RGER, Court Clerk as Mother and Custodial Parent of y. E.A., a minor, Plaintiffs, vs. Case No. C§-2023-F0 JIMMY SELLERS, As AGENT of MEDLEY MATERIAL C1 - dd bd HANDLING COMPANY, and ENTERPRISE FM TRUST Defendants. PARTIES’ JOINT APPLICATION TO TRANSFER CASE FROM “CS” TO “CJ” CIVIL DOCKET COME NOW the parties, Plaintiffs Alberto Adame and Ashley Adame, as custodial parents of E.A., a minor, and Defendants Jimmy Sellers, Medley Material Handling Company, and Enterprise FM Trust, jointly seek an Order of this Court transferring the matter from the “CS” docket to the “CJ” docket for purposes of resolving the friendly suit. In support hereof, the parties state: 1 This friendly suit petition and answer was filed May 24, 2023. When filed, it was accidentally filed as a “CS” matter (where the cause at issue is $10,000 or less). Because it is a friendly suit whereby a settlement in the amount of $90,000 is at issue, it should have been filed as a “CJ” case with the amount at issue greater than $10,000. See Exhibits 1 and 2, Petition and Answer. Page 1 of 4 2 Herein presented with this Joint Application is a check in the amount of $13.00 made out to the Caddo County Court Clerk, to bring the total filing fee to $242.14 3 The Parties therefore request that this Court transfer the case from a “CS” matter to “CJ” matter, to be subsequently placed on the docket of the District Judge of Judicial District 6 the Honorable Kory Kirkland. 4 The Parties also present with this filing a proposed Order approving Transfer Respectfully Submitted, Adame, dually, and as Father And Custodial Parent of the minor, E.A. 701 South Lyle Road Weatherford OK, 73096 Telephone: PlaintiffPro Se WY) vt Wy kd im iually, and as Mother And Custodial P nt of the minor, E.A. 701 South Lyle Road Weatherford OK, 73096 Telephone: Plaintiff Pro Se Page 2 of 4 Eric L. Combs, OBA No. 31024 Matthew J. Becker OBA No. 35057 LYTLE SOULE & FELTY, P.C. 1200 Robinson Renaissance 119 North Robinson Avenue Oklahoma City, OK 73102 Telephone: (405) 235-7471 Facsimile: (405) 232-3852 combs@lytlesoule.com becker@lytlesoule.com Attorneys for Defendant Page 3 of 4 CERTIFICATE OF SERVICE This is to certify that on this day of 2023, a true and correct copy of the above and foregoing instrument was mailed, postage prepaid, to the following: Alberto Adame Ashley Adame 701 South Lyle Road Weatherford OK, 73096 Plaintiffs Pro Se Eric L. Combs Page 4 of 4