Sample Motion For Insurance Coverage

                             STATE OF TEXAS
                             COUNTY OF HARRIS

JENNY A. JONES                          CASE NO:95-45554-DM

VS                                      JUDGE: NORMAN MAILER

JOHN B. JONES                           MOTION TO CONTINUE
                                        INSURANCE COVERAGE
John Wrangler
2467 E Hill Rd
Houston, TX  77001
TX: 713-695-6950
Attorney For Plaintiff
Jenny R. Joplin
8221 Longstreet
Flint, Mi. 77002
TX: 713-234-1212
Attorney For Defendant

Now comes the Plaintiff, Jenny Jones, by and through her attorney, James Whalen, who represents to this Honorable Court the following:

1. That the parties, both of them, are covered by health insurance through the benefit plan of General Motors Corporation, Buick Division, by virtue of Defendant’s employment with that company.

2. That on August 18th, 2018, (the day after Defendant returned the children, having had them for a visitation period, and started a violent argument with Plaintiff [Defendant was hauled off to jail after assaulting Plaintiff and her brother]) the Defendant notified General Motors Benefits Office that his marital status was “single”, and that he would no longer be elected to have the optional payment for spousal health insurance withdrawn from his paycheck.

3. The optional coverage costs eleven dollars per month.

4. Your Plaintiff has received a letter (copy attached as Exhibit One) indicating that the health insurance coverage will be canceled effective October 1st.

5. That, absent an order from this court, directing the Defendant to reinstate the health insurance coverage of your Plaintiff, your Plaintiff will be uninsured.

WHEREFORE Your Plaintiff prays that this honorable court will enter an order, directing the Defendant to reinstate the health insurance coverage of the Plaintiff and to maintain and pay for same, until the trial in this cause.

Further, Plaintiff prays not.

[signature]Jenny A. Jones.