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    Motion To Show Cause

    Uploaded by

    jeweljonesy
    Example Motion to Show Cause

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    Motion To Show Cause

    Uploaded by

    jeweljonesy
    50 views2 pages
    Example Motion to Show Cause

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    Motion to Show Cause

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    © © All Rights Reserved

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    Example Motion to Show Cause

    Copyright:

    © All Rights Reserved
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    Download as pdf or txt
    50 views2 pages

    Motion To Show Cause

    Uploaded by

    jeweljonesy
    Example Motion to Show Cause

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
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    NO.

    424-024FD

    JARED DONOVAN IN THE JUSTICE COURT

    vs. PRECINCT____, PLACE____

    EDGAR B GREENLAND LIVING TRUST ___________COUNTY, TEXAS

    Motion to Show Cause- Landlord’s Delay

    Honorable Judge,

    I, JARED DONOVAN the Plaintiff/Tenant in the above-captioned matter, through undersigned


    counsel, respectfully move this Honorable Court for an order to show cause as to why the
    Defendant/Landlord, should not be held in contempt or face other appropriate consequences for
    their delay in communication and remedy regarding payments and invoicing, repairs, casualty
    and hazards.

    Reasons for Show Cause Request

    Background: Deming Real Estate has established a habitual negligence to respond to


    communication attempts to deliver invoices and complete payments, as well as notices
    regarding necessary structural repairs, ooding damage, and conditions materially effecting
    physical health and safety.

    Court Order or Agreement: Please reference the annexed Letter of Conditional Acceptance as
    record of default on the Lease contract and violation of TX PROPERTY CODE.

    Impact of Delay: Delay has resulted in Tenant’s obstruction to operational occupancy, risk of
    health and safety hazards, out-of-pocket costs, escalating municipal complaints and nes, and
    loss of income while seeking remedy.

    Notice to Landlord: Since May many attempts to communicate for payment and remedy via
    phone, text, and email to Property Manager William R. Gold have been consistently ignored.

    Efforts to Resolve: Property Manager William R. Gold is in receipt of a Letter of Conditional


    Acceptance offer for redress and performance.

    Relief Sought: Landlord to comply with obligations of communication and performance


    appropriate to remedy the delay

    Certi cate of Service: I hereby certify that a true and correct copy of the foregoing Show
    Cause Request was served via court clerk on

    EDGAR B GREENLAND LIVING TRUST


    1406 W Koenig Ln,
    Austin, TX 78756
    fi
    .

    fl


    :

    fi
    NO.424-024FD

    Therefore, Plaintiff/Tenant respectfully requests this Honorable Court to issue an order to show
    cause and set a hearing date convenient for all parties

    Respectfully submitted

    By:
    ___________________________, Agent
    Jared-Scott: Family of Donovan
    ,

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