On September 21, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Casares, Nichole,
and
De La Cruz Gonzalez, Karla,
for Injury or Damage - Motor Vehicle (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Submitted
9/22/2023 10:21 AM
Hidalgo County Clerk
Accepted by: Carlos Guerra
CAUSE NO. CL-23-3783-G
NICHOLE CASARES, INDIVIDUALLY § IN THE COUNTY COURT
and A/N/F of J.P.A., A MINOR §
§
v. § AT LAW NO. 7
§
KARLA DE LA CRUZ GONZALEZ § HIDALGO COUNTY, TEXAS
MOTION TO APPOINT GUARDIAN AD LITEM
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Defendant, KARLA DE LA CRUZ GONZALEZ, by and through her counsel
of record, in the above-entitled and numbered cause and respectfully moves this Court to
appoint a Guardian Ad Litem for the minor Plaintiff, J.P.A., and in support thereof would
show the Court as follows:
I.
J.P.A., Minor, suing by and through his Next Friend, NICHOLE CASARES, the mother of
said minor, who has a possible adverse interest to the interests of said minor Plaintiff, and
therefore requires a Guardian Ad Litem to intervene in this suit on behalf of said minor to
protect the interests of the minor in this proceeding pursuant to and in accordance with Rule
173 of the Texas Rules of Civil Procedure.
WHEREFORE, PREMISES CONSIDERED, Defendant, KARLA DE LA CRUZ GONZALEZ,
respectfully prays that the Court grant the aforementioned Motion and appoint a Guardian
Ad Litem to protect the interests of the minor in this proceeding pursuant to and in
accordance with Rule 173 of the Texas Rules of Civil Procedure.
1
Electronically Submitted
9/22/2023 10:21 AM
Hidalgo County Clerk
Accepted by: Carlos Guerra
Respectfully submitted,
PALACIOS, GARZA, & THOMPSON, P.C.
By: ___________________________
William R. Garza
SBN: 2401283
Email: wgarza@pgtlawfirm.com
2724 W. Canton Rd.
Edinburg, Texas 78539
TEL: (956) 318-0507
FAX: (956) 318-0575
ATTORNEY FOR DEFENDANT
KARLA DE LA CRUZ GONZALEZ
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing document has
been forwarded to, all counsel of record, via e-service, on this 22nd day of September, 2023.
___________________________________
William R. Garza
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.
Mary De Leon on behalf of William Garza
Bar No. 24012683
mdeleon@pgtlawfirm.com
Envelope ID: 79837597
Filing Code Description: Answer
Filing Description: Defendant's Original Answer
Status as of 9/22/2023 10:41 AM CST
Associated Case Party: Karla De La Cruz Gonzalez
Name BarNumber Email TimestampSubmitted Status
William RGarza wgarza@pgtlawfirm.com 9/22/2023 10:21:37 AM SENT
Associated Case Party: Nichole Casares
Name BarNumber Email TimestampSubmitted Status
Leah Wise lw@leahwiselaw.com 9/22/2023 10:21:37 AM SENT
Document Filed Date
September 22, 2023
Case Filing Date
September 21, 2023
Category
Injury or Damage - Motor Vehicle (OCA)
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Electronically Submitted 9/22/2023 10:21 AM Hidalgo County Clerk Accepted by: Carlos Guerra CAUSE NO. CL-23-3783-G NICHOLE CASARES, INDIVIDUALLY § IN THE COUNTY COURT and A/N/F of J.P.A., A MINOR § § v. § AT LAW NO. 7 § KARLA DE LA CRUZ GONZALEZ § HIDALGO COUNTY, TEXAS MOTION TO APPOINT GUARDIAN AD LITEM TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Defendant, KARLA DE LA CRUZ GONZALEZ, by and through her counsel of record, in the above-entitled and numbered cause and respectfully moves this Court to appoint a Guardian Ad Litem for the minor Plaintiff, J.P.A., and in support thereof would show the Court as follows: I. J.P.A., Minor, suing by and through his Next Friend, NICHOLE CASARES, the mother of said minor, who has a possible adverse interest to the interests of said minor Plaintiff, and therefore requires a Guardian Ad Litem to intervene in this suit on behalf of said minor to protect the interests of the minor in this proceeding pursuant to and in accordance with Rule 173 of the Texas Rules of Civil Procedure. WHEREFORE, PREMISES CONSIDERED, Defendant, KARLA DE LA CRUZ GONZALEZ, respectfully prays that the Court grant the aforementioned Motion and appoint a Guardian Ad Litem to protect the interests of the minor in this proceeding pursuant to and in accordance with Rule 173 of the Texas Rules of Civil Procedure. 1 Electronically Submitted 9/22/2023 10:21 AM Hidalgo County Clerk Accepted by: Carlos Guerra Respectfully submitted, PALACIOS, GARZA, & THOMPSON, P.C. By: ___________________________ William R. Garza SBN: 2401283 Email: wgarza@pgtlawfirm.com 2724 W. Canton Rd. Edinburg, Texas 78539 TEL: (956) 318-0507 FAX: (956) 318-0575 ATTORNEY FOR DEFENDANT KARLA DE LA CRUZ GONZALEZ CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing document has been forwarded to, all counsel of record, via e-service, on this 22nd day of September, 2023. ___________________________________ William R. Garza 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. Mary De Leon on behalf of William Garza Bar No. 24012683 mdeleon@pgtlawfirm.com Envelope ID: 79837597 Filing Code Description: Answer Filing Description: Defendant's Original Answer Status as of 9/22/2023 10:41 AM CST Associated Case Party: Karla De La Cruz Gonzalez Name BarNumber Email TimestampSubmitted Status William RGarza wgarza@pgtlawfirm.com 9/22/2023 10:21:37 AM SENT Associated Case Party: Nichole Casares Name BarNumber Email TimestampSubmitted Status Leah Wise lw@leahwiselaw.com 9/22/2023 10:21:37 AM SENT