I'm a bit confused by your question. If you're the one moving for a no-evidence summary judgment, then all you need to do with respect to "facts" is identify (as specifically as possible) what element or elements of the opposing party's claim(s) or defense(s) are lacking in respect to any admissible evidence. For example, if you were moving for no-evidence summary judgment on a negligence claim and believed there was no evidence to support the "duty" element of a negligence cause of action,...
I would call Texas a "pro" non-compete state. Since 2006, it has become pretty easy for employers to enforce non-competes.
That said, generally speaking, 24 months is a reasonable duration--heck, I've enforced 36 months before.
With respect to your particular situation, realize that Texas is a "blue pencil" state--so even if a judge thought 24 months was unreasonable, he/she could "pencil" in a shorter timeframe.
The Texas Rules of Civil Procedure apply in the same manner. Typically, discovery responses are due within 30 days of receipt (unless they are sent with a petition and citation) not counting the "mailbox rule" of 3 days. Rule 11 Agreements can alter deadlines, much like in family law practice.
Take the time out to visit a reputable immigration attorney in Dallas. There are several good ones. They will take a few minutes to explain your situation to you and, ideally, help you with any necessary paperwork you need to file with the U.S. government.
The reality is you may need to apply for an I-601 hardship waiver, and that does involve going back to Mexico. There may be other options, though, so sitting down with an immigration attorney for an hour is well worth your time (and money).
While you'll rarely find an attorney advising someone to forego legal counsel, the truth is you do not need an attorney to settle your workers' compensation claim in Texas. However, as it's been said, an experienced workers' compensation attorney may be able to negotiate better on your behalf. If you feel comfortable without one, that's certainly your prerogative-- but you might want to consult with an attorney first to double-check.
Sure, you can, but it may not be worth your while to pursue her in court, even if you choose to proceed without counsel. You will probably need an expert witness to provide the opinion that your dog is not a purebred Boston Terrier. Experts cost money. You may need an expert (a different one, if that one cannot provide an opinion) as to the cost difference between a purebred dog and yours.
I'd call the breeder and ask for a reasonable refund and avoid litigation completely.
Should you consult a lawyer? Absolutely. There are many excellent personal injury attorneys in the Abilene area that would be able to give you a good idea of what your options are.
Generally, though, what you're describing is known as a "premises liability" case. You have to prove that the store was negligent in allowing a dangerous condition to exist on premises. One of the biggest hurdles you may have to prove is what's called "notice." Notice means that a store employee knew or...