On October 31, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Gomez, Deny,
and
Ugwu, Innocent,
for Injury or Damage Involving Motor Vehicle
in the District Court of Fort Bend County.
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Filed
11/1/2023 10:52 AM
Beverley McGrew Walker
THIS DOCUMENT CONTAINS SENSITIVE DATA District Clerk
Fort Bend County, Texas
Norma Sosa
CAUSE NO. 23-DCV-310147
DENY GOMEZ, as Next Friend IN THE DISTRICT COURT OF
of A.G. and Y.G., Minors,
Plaintiff,
FORT BEND COUNTY, TEXAS
vs.
INNOCENT UGWU,
434th JUDICIAL DISTRICT
Defendant.
JOINT MOTION TO APPOINT GUARDIAN AD LITEM
Deny Gomez, as next friend of andi Vinors (“Minor
Plaintiffs”), and Innocent Ugwu (“Defendant”), request that the Court appoint a guardian ad litem
to represent Minor Plaintiffs, pursuant to Texas Rule of Civil Procedure 173 and would show the
following:
The parties have agreed to a compromise and settlement of all the claims made by
Minor Plaintiffs. A potential exists for a conflict of interest between Minor Plaintiffs and Plaintiff
Deny Gomez, who represents the minors as next friend.
The parties pray that the Court appoint a guardian ad litem to represent the Minor
Plaintiffs.
Respectfully submitted,
THE HUGHES LAW FIRM
By: /s/ Laura L. Hughes (KW w/permission)
Laura L. Hughes
State Bar No. 24032439
8876 Gulf Freeway, Suite 370
Houston, Texas 77017
Telephone: 281.833.8003
lhughes@thehughesattorneys.com
ATTORNEY FOR PLAINTIFFS
JORDAN, LYNCH & CANCIENNE PLLC
By: /s/ Kelly Wilson
Michael Cancienne
State Bar No. 24116942
Kelly Wilson
State Bar No. 24089579
1980 Post Oak Blvd., Suite 2300
Houston, Texas 77056
Telephone: 713.955.4025
Facsimile: 713.955.9644
Email: meancienne@jlcfirm.com
Email: kwilson@jlcfirm.com
ATTORNEYS FOR DEFENDANT
CERTIFICATE OF SERVICE
This certifies that a copy of the above and foregoing was sent to all known counsel
of record by means of the Court’s electronic filing system on November I, 2023.
/s/ Kelly Wilson
Kelly Wilson
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.
Linda Thomas on behalf of Michael Cancienne
Bar No. 24055256
Ithomas@jlcfirm.com
Envelope ID: 81185290
Filing Code Description: Motion (No Fee)
Filing Description: Joint Motion to Appoint Guardian ad Litem
Status as of 11/1/2023 10:58 AM CST
Associated Case Party: Innocent Ugwu
Name BarNumber | Email TimestampSubmitted | Status
Michael Cancienne meancienne@jlcfirm.com | 11/1/2023 10:52:11 AM | SENT
Kelly HillWilson kwilson@jlcfirm.com 11/1/2023 10:52:11 AM | ERROR
Associated Case Party: Deny Gomez as Next Friend of Atalya Gomez
Name BarNumber | Email TimestampSubmitted | Status
Laura Hughes Ihughes@thehughesattorneys.com | 11/1/2023 10:52:11 AM | SENT
Document Filed Date
November 01, 2023
Case Filing Date
October 31, 2023
Category
Injury or Damage Involving Motor Vehicle
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Filed 11/1/2023 10:52 AM Beverley McGrew Walker THIS DOCUMENT CONTAINS SENSITIVE DATA District Clerk Fort Bend County, Texas Norma Sosa CAUSE NO. 23-DCV-310147 DENY GOMEZ, as Next Friend IN THE DISTRICT COURT OF of A.G. and Y.G., Minors, Plaintiff, FORT BEND COUNTY, TEXAS vs. INNOCENT UGWU, 434th JUDICIAL DISTRICT Defendant. JOINT MOTION TO APPOINT GUARDIAN AD LITEM Deny Gomez, as next friend of andi Vinors (“Minor Plaintiffs”), and Innocent Ugwu (“Defendant”), request that the Court appoint a guardian ad litem to represent Minor Plaintiffs, pursuant to Texas Rule of Civil Procedure 173 and would show the following: The parties have agreed to a compromise and settlement of all the claims made by Minor Plaintiffs. A potential exists for a conflict of interest between Minor Plaintiffs and Plaintiff Deny Gomez, who represents the minors as next friend. The parties pray that the Court appoint a guardian ad litem to represent the Minor Plaintiffs. Respectfully submitted, THE HUGHES LAW FIRM By: /s/ Laura L. Hughes (KW w/permission) Laura L. Hughes State Bar No. 24032439 8876 Gulf Freeway, Suite 370 Houston, Texas 77017 Telephone: 281.833.8003 lhughes@thehughesattorneys.com ATTORNEY FOR PLAINTIFFS JORDAN, LYNCH & CANCIENNE PLLC By: /s/ Kelly Wilson Michael Cancienne State Bar No. 24116942 Kelly Wilson State Bar No. 24089579 1980 Post Oak Blvd., Suite 2300 Houston, Texas 77056 Telephone: 713.955.4025 Facsimile: 713.955.9644 Email: meancienne@jlcfirm.com Email: kwilson@jlcfirm.com ATTORNEYS FOR DEFENDANT CERTIFICATE OF SERVICE This certifies that a copy of the above and foregoing was sent to all known counsel of record by means of the Court’s electronic filing system on November I, 2023. /s/ Kelly Wilson Kelly Wilson 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. Linda Thomas on behalf of Michael Cancienne Bar No. 24055256 Ithomas@jlcfirm.com Envelope ID: 81185290 Filing Code Description: Motion (No Fee) Filing Description: Joint Motion to Appoint Guardian ad Litem Status as of 11/1/2023 10:58 AM CST Associated Case Party: Innocent Ugwu Name BarNumber | Email TimestampSubmitted | Status Michael Cancienne meancienne@jlcfirm.com | 11/1/2023 10:52:11 AM | SENT Kelly HillWilson kwilson@jlcfirm.com 11/1/2023 10:52:11 AM | ERROR Associated Case Party: Deny Gomez as Next Friend of Atalya Gomez Name BarNumber | Email TimestampSubmitted | Status Laura Hughes Ihughes@thehughesattorneys.com | 11/1/2023 10:52:11 AM | SENT