IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

SAN ANTONIO DiVISION

JONATHAN VILLARREAL,

Plaintiff,

vs.

JOHN SAENZ; MIGUEL VILLARREAL,

JR; and GUNN, LEE & CAVE, P.C.,

Defendants.

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No. 5:20-CV-00571-OLG

PLAINTIFF’S MOTION FOR AN EXTENSION OF TIME TO OBTAIN NEW

REPRESENTATION

TO THE HONORABLE JUDGE RICHARD B. FARRER:

Plaintiff’s Motion to Extend Time to Obtain New Representation Page 1 of 4

Case 5:20-cv-00571-OLG Document 66 Filed 07/26/21 Page 1 of 5
COMES NOW, Plaintiff, Jonathan Villarreal, pro se, respectfully requesting an order

granting an additional 45 days in which to obtain new representation. Plaintiff would respectfully

show the court as follows:

1. VIOLATION OF PLAINTIFF'S 14TH AMENDMENT CIVIL RIGHTS AND

PROCEDURAL DUE PROCESS

Pursuant to Texas Disciplinary Rule 3.03(a)(1), a lawyer may not knowingly make a

false statement of material fact or law to a tribunal; pursuant to Texas Disciplinary Rule

3.03(a)(2), a lawyer may not knowingly fail to disclose a fact to a tribunal when disclosure is

necessary to avoid assisting a criminal or fraudulent act; pursuant to Texas Disciplinary Rule

3.03(a)(5), a lawyer may not knowingly offer or use evidence that the lawyer knows to be

false.

Former legal representation for plaintiff, The Vethan Lawfirm has intentionally perjury

to the extent that their actions unconstitutionally and critically impacted the report and

recommendation of the court. see Dkt No. 58 at 7-8 “The Extensive Delay,”

Plaintiff's First Amended Application for Seizure, Temporary Restraining Order,

Preliminary Injunction, and Permanent Injunctive Relief, was DENIED. Dkt. Nos. 34 (sealed

copy) & 37 (redacted copy for the public record).

Plaintiff’s Motion to Extend Time to Obtain New Representation Page 2 of 4

Case 5:20-cv-00571-OLG Document 66 Filed 07/26/21 Page 2 of 5
2. COVID-19 WAS NEVER A REASON FOR LATE FILING OF THE LAWSUIT,

NEGLIGENCE OF PLAINTIFF’S FORMER LEGAL REPRESENTATION IS SHOWN

IN EXHIBIT “A.”

SUPPORT

1. Plaintiff engaged the Vethan Law Firm October 29th, 2021

2. The last email plaintiff sent to defendant Mike Villarreal (who was representing

defendant John Saenz and plaintiff at the same time, while internal disputes were

happening) was October, 11th, 2019.

3. Plaintiff tried to exit the legal relationship with defendant Mike Villarreal four (4)

times in written emails, and Mike Villarreal continued to pressure plaintiff into

working things out with Defendant John Saenz.

4. The period of time that lapsed between seeking counsel to file a lawsuit against

John Saenz was 12 business days.

5. Exhibit A is dated Feb, 2nd 2020 and shows the following:

● Initial engagement date - October, 29th 2019

● Total hours worked on the matter - 1.3 hours

● Last date worked December, 17th 2019

6. After months of requesting status updates, and finally threatening to report The

Vethan Lawfirm to the Texas Bar Association, plaintiff is sent a new engagement

letter from The Vethan Law Firm on March 4th, 2020, now asking for more

money to start the lawsuit.

Plaintiff’s Motion to Extend Time to Obtain New Representation Page 3 of 4

Case 5:20-cv-00571-OLG Document 66 Filed 07/26/21 Page 3 of 5
3. PLAINTIFF INFORMED DEFENSE OF THE PERJURY, YET NO ACTION WAS

TAKEN, THERE WAS NO MOTION TO REHEAR FILED, THERE WERE NO

ETHICAL OBJECTIONS, NOR WERE THERE ANY INQUIRIES INTO THE

MATTER BY THE DEFENSE.

Because of these actions and the aforementioned, plaintiff is respectfully requesting that

the court grant a 45 day extension to find legal representation that can fully understand the case,

dedicate the proper amount of time to the matter, and not put plaintiff into another dire situation

due to unclean hands.

PRAYER FOR RELIEF

4. For the reasons set forth above, Plaintiff requests that this court grant Plaintiff’s Motion for an

Extension of Time to Obtain New Counsel, and to extend the deadline to obtain new counsel up

to September 9th, 2021.

Respectfully, Submitted,

Jonathan Villarreal, Plaintiff, pro se

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28251 Boerne Stage Rd

Boerne, TX 78006

830-499-3071

Plaintiff’s Motion to Extend Time to Obtain New Representation Page 4 of 4

Case 5:20-cv-00571-OLG Document 66 Filed 07/26/21 Page 4 of 5
CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing was electronically filed with the Court on the

26th day of July 2021, and electronically served on the date reflected in the ECF system upon all

parties registered to receive notice pursuant to the Court’s CM/ECF system.

______________________

Jonathan Villarreal, pro se

Plaintiff’s Motion to Extend Time to Obtain New Representation Page 5 of 4

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