IN THE TARRANT COUNTY COURT AT LAW
YAMIL LUCIANO §
Plaintiff, §
§
v. § Case No.
§
PATRICK CHARLES; AND SHELDEON §
JOINER §
Defendants. §
NOTICE OF PLAINTIFF’S MOTION FOR EMERGENCY HEARING
You are notified that on the ____ day of January, 2022, at ________ (am/pm), or as soon thereafter as Plaintiff can be heard, in Courtroom ___ of the Tarrant County Court at Law, Plaintiff will bring on for hearing his Motion for Emergency Hearing for the reasons stated in the attached Motion.
Dated this ____ day of January, 2022.
Respectfully Submitted,
___________________________________
Yamil Luciano,
Plaintiff in pro per
IN THE TARRANT COUNTY COURT AT LAW
YAMIL LUCIANO §
Plaintiff, §
§
v. § Case No.
§
PATRICK CHARLES; AND SHELDEON §
JOINER §
Defendants. §
PLAINTIFF’S MOTION FOR EMERGENCY HEARING
NOW COMES Yamil Luciano, Plaintiff, and files this Motion for Emergency Hearing, and hereby avers as follows:
- Plaintiff has filed a Verified Complaint for declaratory and injunctive relief, which Complaint is incorporated herein by reference.
- The emergency hearing Plaintiff now seeks is necessary to prohibit substantial and irreparable injury to protect SPL Transport from litigation and to protect Plaintiff’s main source of livelihood by halting the actions of Defendants of winding up SPL Transport.
- Every day that passes, Defendants continue the process of winding up SPL Transport to avoid contractual obligation with My Favorite Dispatcher. Their actions will definitely expose SPL Transport’s to litigation and interfere with Plaintiff’s main source of livelihood.
- Defendants’ actions are malicious. They are aware that they can choose to resign as members of SPL Transport if they are no longer comfortable with the terms of the contract with My Favorite Dispatcher which they executed. Instead, they want to wind up the company knowing very well the impact their actions will have on SPL Transport and Plaintiff.
- The Verified Complaint has set forth substantial reasons for the protection of SPL Transport and Plaintiff, and has demonstrated there exists a reasonable likelihood of Plaintiff’s success on the merits.
- Plaintiff has no adequate remedy at law.
REASONS WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully prays for an entry of the following order:
- A Temporary Restraining Order, without bond, restraining Defendants, to immediately discontinue all actions and processes of winding up SPL Transport Logistics, LLC;
- A hearing date to be set to hear Plaintiff’s Complaint;
- For such other and further relief as this Court deems just and proper.
Dated this ____ day of January, 2022.
Respectfully Submitted,
___________________________________
Yamil Luciano,
Plaintiff in pro per
VERIFICATION
I, Yamil Luciano, being duly sworn depose and say that I am the Plaintiff in the above-entitled action, that I have read the foregoing Motion for Emergency Hearing and know the contents thereof. That the same is true of my own knowledge except as to those matters and things stated upon information and belief, and as to those things, I believe them to be true.
_________________________________
(Sign in the presence of a Notary Public)
Sworn to and subscribed before me this ___ day of ___________________, 2021.
______________________________
Notary Public
________________________________________
(Printed name of Notary Public)
My Commission Expires: ____________________
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