`
`
`NO. C-4241-17-J
`
`Electronically Filed
`6/29/2023 2:54 PM
`Hidalgo County District Clerks
`Reviewed By: Lorena Gonzalez
`
`DAVID ROJAS INDIVIDUALLY and
`D/B/A AUTOMATION STATION, LLC
`Plaintiff,
`
`V.
`
`PANASONIC
`and
`RUBIO
`ERIC
`CORPORATION OF NORTH AMERICA
`D/B/A
`PANASONIC AUTOMOTIVE
`SYSTEMS COMPANY OF AMERICA
`Defendants,
`
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`IN THE DISTRICT COURT
`
`
`
`430th JUDICIAL DISTRICT
`
`
`
`OF HIDALGO COUNTY, TEXAS
`
`MOTION FOR ENTRY OF AGREED DOCKET CONTROL ORDER
`
`This Motion for Entry of Agreed Docket Control Order is brought by Plaintiff, DAVID
`ROJAS INDIVIDUALLY and D/B/A AUTOMATION STATION, LLC. Plaintiff hereby requests
`that this Court enter the Agreed Docket Control Order for the following reasons:
`
`1.
`
`
`
`
`
`
`
`On April 28th, 2023, a Docket Control Conference was held in the above-referenced
`and number cause. All parties were in attendance and Plaintiff’s counsel was
`requested to submit the Agreed Docket Control Order for the court’s approval.
`
`Plaintiff’s counsel circulated a proposed Agreed Docket Control Order to all parties
`on May 1, 2023 and a revised Agreed Docket Control Order on May 2, 2023.
`Defense counsel for Defendant, Panasonic Corporation of North America D/B/A
`Panasonic Automotive Systems Company of America, returned the signed order on
`May 4, 2023.
`
`Plaintiff’s counsel sent a follow up email to defense counsel Hernandez for
`Defendant, Eric Rubio, followed with the signature page that held defense counsel
`Cardenas’ signature. No response was received by defense counsel Hernandez. A
`second follow up email was sent to defense counsel Hernandez on June 6, 2023,
`and again no response was received. Plaintiff’s counsel attempted to call defense
`counsel Hernandez’s office on two separate occasions and left messages, yet no
`response was received.
`
`Plaintiff’s counsel has made every effort necessary to contact defense counsel
`Hernandez for Defendant, Eric Rubio, to review and sign the Agreed Docket
`Control Order.
`
`2.
`
`3.
`
`4.
`
`5.
`
` The Agreed Docket Control Order should therefore be signed.
`
`
`
`_____________________________________________________________________________________________
`Rojas vs Rubio & Panasonic; Cause No. C-4241-17-J
`Motion for Entry of Agreed Docket Control Order
`
`
`
`Page 1 of 2
`
`
`
`Electronically Filed
`6/29/2023 2:54 PM
`Hidalgo County District Clerks
`Reviewed By: Lorena Gonzalez
`
`6.
`
`Plaintiff, DAVID ROJAS INDIVIDUALLY and D/B/A AUTOMATION
`STATION, LLC hereby requests that this Court sign and enter the Agreed Docket
`Control Order attached to this motion as Proposed Order.
`
`Respectfully submitted,
`
`THE LAW OFFICE OF DAMIAN C. OROZCO, P.C.
`1138 E. Expressway 83, Suite C.
`Pharr, Texas 78577
`Tel: (956) 782-5447
`Fax: (956) 782-5448
`
`By: /s/ Damian C. Orozco
`Damian C. Orozco
`State Bar No. 24008756
`Email: dorozco@orozco-law.com
`Attorney for Plaintiff
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I certify that a true copy of this document was served in accordance with rule 21a of the
`
`Texas Rules of Civil Procedure on the following on June 29, 2023:
`
`Via E-Service:
`Luis Cardenas, Attorney
`Joe Escobedo, Attorney
`ESCOBEDO & CARDENAS, LLP
`3700 N. 10th Street, Suite 210
`McAllen, Texas 78501
`Telephone: (956) 630-2222
`Fax: (956) 630-2223
`Email: luis@escobedocardenas.com
`Email: joe@escobedocardenas.com
`Attorneys for Defendant, Panasonic Corporation of
`North America D/B/A Panasonic Automotive
`System Company of America
`
`Via E-Service:
`Alex R. Hernandez, Attorney
`ALEX R. HERNANDEZ, JR. TRIAL LAWYERS
`921 N. Chaparral Suite 100
`Corpus Christi, Texas 78401
`Telephone: (361) 792-3811
`Fax: (361) 232-4975
`Email: alexhernandez@alexhernandeztriallaw.com
`Attorney for Defendant, Eric Rubio
`
` By: /s/ Damian C. Orozco
` Damian C. Orozco
` Attorney for Plaintiff
`
`_____________________________________________________________________________________________
`Rojas vs Rubio & Panasonic; Cause No. C-4241-17-J
`Motion for Entry of Agreed Docket Control Order
`
`Page 2 of 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.
`Cristal Gonzalez on behalf of Damian Orozco
`Bar No. 24008756
`cgonzalez@orozco-law.com
`Envelope ID: 77101698
`Filing Code Description: Motion (No Fee)
`Filing Description: Motion for Entry of DCO
`Status as of 6/30/2023 10:23 AM CST
`
`Associated Case Party: DAVID ROJAS INDIVIDUALLY AND D/B/A AUTOMATION
`STATION L.L.C.
`
`Name
`DAMIAN OROZCO
`The Law Office of Damian COrozco
`The Law Office of Damian COrozco
`Law Office of Damian C.Orozco
`
`BarNumber Email
`dorozco@orozco-law.com
`jgarcia@orozco-law.com
`cgonzalez@orozco-law.com
`orozcolawoffice@orozco-law.com
`
`TimestampSubmitted
`6/29/2023 2:54:51 PM
`6/29/2023 2:54:51 PM
`6/29/2023 2:54:51 PM
`6/29/2023 2:54:51 PM
`
`Status
`SENT
`SENT
`SENT
`SENT
`
`Associated Case Party: PANASONIC CORPORATION OF NORTH AMERICA D/B/A
`PANASONIC AUTOMOTIVE SYSTEMS COMPAN
`
`Name
`LUIS CARDENAS
`Cathy AGonzalez
`Joe Escobedo
`
`BarNumber Email
`luis@escobedocardenas.com
`cathy@escobedocardenas.com
`joe@escobedocardenas.com
`
`TimestampSubmitted
`6/29/2023 2:54:51 PM
`6/29/2023 2:54:51 PM
`6/29/2023 2:54:51 PM
`
`Status
`SENT
`SENT
`SENT
`
`Associated Case Party: ERIC RUBIO
`
`Name
`Alex R.Hernandez
`Joe Navarro
`
`BarNumber Email
`alexhernandez@alexhernandeztriallaw.com
`joenavarro@alexhernandeztriallaw.com
`
`TimestampSubmitted
`6/29/2023 2:54:51 PM
`6/29/2023 2:54:51 PM
`
`Status
`SENT
`SENT
`
`