IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

In re: 

CHRISTOPHER BRANDON JUDGE and 

RAQUELLE ANN JUDGE 

 Debtor(s) 

_____________________________ 

KRISTIN NEWMAN 

Plaintiff 

vs. 

CHRISTOPHER BRANDON JUDGE ET 

AL. 

Defendants 

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CASE NO.: 23-41465-ELM7 

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ADVERSARY NO.: 23-04066-ELM 

UNOPPOSED MOTION FOR CONTINUANCE AND 

REQUEST FOR A NEW SCHEDULING ORDER 

Pursuant to the Federal Rules of Civil Procedure and the Local Rules, Plaintiff Kristin 

Newman (“Plaintiff”) files this Unopposed Motion for Continuance and Request for a New 

Scheduling Order and state: 

1. On November 22, 2022, Plaintiff filed a lawsuit in the 249th District Court for 

Johnson County, Texas, Cause No. DC-C202200572. On May 23, 2023, Defendants filed a 

petition for relief under Chapter 7 of the United States Bankruptcy Code (Title 11) in Case No. 23-

41465-7. Accordingly, Plaintiff’s lawsuit in the 249th District Court was stayed. On August 15, 

2023, Plaintiff filed this Adversary Proceeding in this Court. On September 15, 2023, Defendants 

filed their answer to the Adversary Proceeding in this Court. 

2. On August 16, 2023, the Court issued a scheduling order setting the case for trial 

on February 5, 2024. 

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3. Plaintiff and Defendant have exercised diligence in conducting discovery of the 

facts that could be developed. The Parties have conducted written discovery. Due to the holidays 

and party availability, the Parties have not been able to complete depositions. 

4. Furthermore, additional fact and expert discovery is needed for trial. Despite their 

best efforts, both parties need additional time to conduct fact and expert discovery prior to the trial 

of this case. 

5. The United States anticipates that a ninety (90) day continuance of the docket call 

date and an extension of all deadlines will allow Education time to consider the Attestation and 

what position to take in this lawsuit. The motion is made in good faith, to conserve judicial 

resources, and not to prejudice any party or to undue delay proceedings. The United States 

respectfully requests the Court enter an order continuing the docket call date for at least ninety 

(90) days, extending the deadlines set forth in the Alternate Scheduling Order in accordance with 

paragraph 7 of the order, and for such other relief it may show itself entitled. 

6. Plaintiff anticipates that a six (6) month continuance of the docket call date and an 

extension of all deadlines will allow the Parties to gather and consider information through 

discovery. Plaintiff believes a continuance of the case, are in the best interest of the clients and the 

orderly administration of this case. This motion is made in good faith, to conserve judicial 

resources, and not to prejudice any party or to unduly delay proceeding. Plaintiff respectfully 

requests the Court enter an order continuing the docket call date six (6) months, extending 

deadlines set forth in the Scheduling Order, and for such other relief it may show herself entitled. 

THEREFORE, Plaintiff respectfully requests that the Court grant this Motion for 

Continuance, issue an amended scheduling order with new dates for disclosure of experts and 

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discovery from fact and expert depositions, and resetting the trial date by six months. Plaintiff 

requests that the Court grant all other relief to which they may be justly entitled. 

Respectfully submitted, 

/s/ Michael S. Newman

Michael S. Newman 

Bar No 14963900 

8813 N. Tarrant Pkwy., Ste. 252 

North Richland Hills, TX 76182 

Phone: 817-656-8100 

Email: mike@newmanlawtx.com 

Kristin Newman 

Bar No 24102279 

1409 Kaitlyn Lane 

Keller, TX 76248 

T: 817-480-5877 

E-Mail: kristinnewman@me.com 

CERTIFICATE OF CONFERENCE 

On January 8, 2024, Michael Newman conferred with Clayton Everett and Mr. Everett 

agreed to this unopposed motion for continuance. 

By: /s/ Michael Newman 

CERTIFICATE OF SERVICE 

I certify that on January 12, 2024, a true and correct copy of the foregoing has been 

served on all parties using the Court’s Electronic Filing System. 

By: /s/ Michael Newman 

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