IN THE TARRANT COUNTY COURT AT LAW

 

PERSONA     §

Plaintiff,     §

  1.     § Case No.

PERSONA     §

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,

___________________________________

PERSONA

Plaintiff in pro per

IN THE TARRANT COUNTY COURT AT LAW

 

PERSONA     §

Plaintiff,     §

  1.     § Case No.

PERSONA   §

JOINER     §

Defendants.     §

 

PLAINTIFF’S MOTION FOR EMERGENCY HEARING

NOW COMES , Plaintiff, and files this Motion for Emergency Hearing, and hereby avers as follows:

  1. Plaintiff has filed a Verified Complaint for declaratory and injunctive relief, which Complaint is incorporated herein by reference.
  2. The emergency hearing Plaintiff now seeks is necessary to prohibit substantial and irreparable injury to protect  Transport from litigation and to protect Plaintiff’s main source of livelihood by halting the actions of Defendants of winding up  Transport.
  3. Every day that passes, Defendants continue the process of winding up  Transport to avoid contractual obligation with My Favorite Dispatcher. Their actions will definitely expose Transport’s to litigation and interfere with Plaintiff’s main source of livelihood. 
  4. Defendants’ actions are malicious. They are aware that they can choose to resign as members of  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  Transport and Plaintiff.
  5. 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.
  6. Plaintiff has no adequate remedy at law.

REASONS WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully prays for an entry of the following order:

  1. A Temporary Restraining Order, without bond, restraining Defendants, to immediately discontinue all actions and processes of winding up Transport Logistics, LLC;
  2. A hearing date to be set to hear Plaintiff’s Complaint;
  3. For such other and further relief as this Court deems just and proper.

 

Dated this ____ day of January, 2022.

 

Respectfully Submitted,

___________________________________

PERSONA,

Plaintiff in pro per

VERIFICATION

I,Persona, 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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