On December 29, 2009 a
Motion,Ex Parte
was filed
involving a dispute between
Daniels, James Edward,
and
Dart Area Rapid Transit,
Edgar, Jr., Jerry Lane,
Fox, Jason,
Loncar, Brian,
Nationwide Insurance Company,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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Fax sunt by : 2143825641 e@ LOMCAR & ARBOCIATES Qe O5:S4p Fg: 2/5
FILED
CAUSE NO. 09-17355-B LOMAR -3 AHIO: 00
JAMES EDWARD DANIELS §
§
vs. 5
3
DART AREA RAPID TRANSIT, 1
JERRY LANE EDGAR, JR., §
NATIONWIDE INSURANCE. CO, §
BRIAN LONCAR, ATTORNEY, 4
JASON FOX OF LONCAR AND 3
ASSOC, IN THEIR OFFICIAL $
CAPACITY AND INDIVIDUALLY $ 44™ JUDICIAL DISTRICT
WITH PREJUDICE
TO THE HONORABLE JUDGE:
COMES NOW, JAMES EDWARD DANIELS, Plaintiff herein, and BRIAN LONCAR,
ATTORNEY, JASON FOX OF LONCAR AND ASSOC., IN THEIR OFFICIAL CAPACITY AND
INDIVIDUALLY and moves this Honorable Court to dismiss the above entitled and mumbered
cause as to Defendants, BRIAN LONCAR, ATTORNEY, JASON FOX OF LONCAR AND
ASSOC. IN THEIR OFFICIAL CAPACITY AND INDIVIDUALLY and would respectfully show
the Court the following:
L
Plaintiff no longer deaires to prosecute his causes of action as alleged in Plaintiff's Original
Petition, and any amendments thereto, because all matters of fact and things in controversy have
been fully and finally compromised and settled by and between Plaintiff JAMBS EDWARD
DANIELS and Defendants BRIAN LONCAR, ATTORNEY, JASON FOX OF LONCAR AND
ASSOC. IN THEIR OFFICIAL CAPACITY AND INDIVIDUALLY
WHEREFORE, PREMISES CONSIDERED, the partles request the Court enter its Order
AGREED MOTION POR DISMABBAL WITH PREJUDICE « Page 1
S$ /€ “dowd Wd 10°80 OT02'2O'2zeWFax ment by: 2143825841 @ LONCAR & ASSOCIATES @er-u @5:SSp Py: VS
dismissing said cause, with prejudice, to the right of Plaintiff to refile same or any part thereof
against Defendants BRIAN LONCAR, ATTORNEY, JASON FOX OF LONCAR AND
ASSOCIATES, IN THEIR OFFICIAL CAPACITY AND INDIVIDUALLY and court costa be
taxed against the party incurring same.
Bridge
State Bar No. 50511654
John C. Wren
State Bar No. 22019100
Jason HL Fox
State Bar No. 24029557
Loncar & Associates
424 S. Central
Dallas, Texas 75201
(214) 747-0422
(214) 382-5841 (Facsimile)
ATTORNEYS FOR DEFENDANTS
BRIAN LONCAR, ATTORNEY AND
JASON FOX OF LONCAR AND ASSOC,
IN THEIR OFFICIAL CAPACITY
AND INDIVIDUALLY
AGREED MOTION FOR OIEMISGAL WITH PRIBJUOICE - Page 2
/b "dowd Wd 20:80 OT0Z°Z0°TeWPex sont by : 2143975841 e LOMCAR & ABSOCIATES ere BS:SSp Pg: 45
’
CERTIFICATE OF SERVICE
1, Juson Fox, do hereby certify that this document, was served on the plaintiff vis facsimile
972-423-2401, and by United States Certified Mail - RRR, #7009 2820 0003 7874 8993 and hand
delivered to ad} other parties of record on thisthe_ @ day of owe » 2010.
JASONFOX
AGREEO MOTION FOR DIGMSBAL, WITH PREAIDICE - Page 3
S$ /S ‘Fovd Wd 20:80 QT0Z2°ZO‘°2eW
Document Filed Date
March 03, 2010
Case Filing Date
December 29, 2009
Category
MOTOR VEHICLE ACCIDENT
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Fax sunt by : 2143825641 e@ LOMCAR & ARBOCIATES Qe O5:S4p Fg: 2/5 FILED CAUSE NO. 09-17355-B LOMAR -3 AHIO: 00 JAMES EDWARD DANIELS § § vs. 5 3 DART AREA RAPID TRANSIT, 1 JERRY LANE EDGAR, JR., § NATIONWIDE INSURANCE. CO, § BRIAN LONCAR, ATTORNEY, 4 JASON FOX OF LONCAR AND 3 ASSOC, IN THEIR OFFICIAL $ CAPACITY AND INDIVIDUALLY $ 44™ JUDICIAL DISTRICT WITH PREJUDICE TO THE HONORABLE JUDGE: COMES NOW, JAMES EDWARD DANIELS, Plaintiff herein, and BRIAN LONCAR, ATTORNEY, JASON FOX OF LONCAR AND ASSOC., IN THEIR OFFICIAL CAPACITY AND INDIVIDUALLY and moves this Honorable Court to dismiss the above entitled and mumbered cause as to Defendants, BRIAN LONCAR, ATTORNEY, JASON FOX OF LONCAR AND ASSOC. IN THEIR OFFICIAL CAPACITY AND INDIVIDUALLY and would respectfully show the Court the following: L Plaintiff no longer deaires to prosecute his causes of action as alleged in Plaintiff's Original Petition, and any amendments thereto, because all matters of fact and things in controversy have been fully and finally compromised and settled by and between Plaintiff JAMBS EDWARD DANIELS and Defendants BRIAN LONCAR, ATTORNEY, JASON FOX OF LONCAR AND ASSOC. IN THEIR OFFICIAL CAPACITY AND INDIVIDUALLY WHEREFORE, PREMISES CONSIDERED, the partles request the Court enter its Order AGREED MOTION POR DISMABBAL WITH PREJUDICE « Page 1 S$ /€ “dowd Wd 10°80 OT02'2O'2zeWFax ment by: 2143825841 @ LONCAR & ASSOCIATES @er-u @5:SSp Py: VS dismissing said cause, with prejudice, to the right of Plaintiff to refile same or any part thereof against Defendants BRIAN LONCAR, ATTORNEY, JASON FOX OF LONCAR AND ASSOCIATES, IN THEIR OFFICIAL CAPACITY AND INDIVIDUALLY and court costa be taxed against the party incurring same. Bridge State Bar No. 50511654 John C. Wren State Bar No. 22019100 Jason HL Fox State Bar No. 24029557 Loncar & Associates 424 S. Central Dallas, Texas 75201 (214) 747-0422 (214) 382-5841 (Facsimile) ATTORNEYS FOR DEFENDANTS BRIAN LONCAR, ATTORNEY AND JASON FOX OF LONCAR AND ASSOC, IN THEIR OFFICIAL CAPACITY AND INDIVIDUALLY AGREED MOTION FOR OIEMISGAL WITH PRIBJUOICE - Page 2 /b "dowd Wd 20:80 OT0Z°Z0°TeWPex sont by : 2143975841 e LOMCAR & ABSOCIATES ere BS:SSp Pg: 45 ’ CERTIFICATE OF SERVICE 1, Juson Fox, do hereby certify that this document, was served on the plaintiff vis facsimile 972-423-2401, and by United States Certified Mail - RRR, #7009 2820 0003 7874 8993 and hand delivered to ad} other parties of record on thisthe_ @ day of owe » 2010. JASONFOX AGREEO MOTION FOR DIGMSBAL, WITH PREAIDICE - Page 3 S$ /S ‘Fovd Wd 20:80 QT0Z2°ZO‘°2eW