On March 02, 2020 a
Stipulation,Agreement
was filed
involving a dispute between
Reyes, Diana,
and
Allstate County Mutual Insurance Company,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
9/13/2022 8:11 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Dorothy Strogen DEPUTY
Lisa Chastain4= LISA CHASTAIN & ASSOCIATES
Senior Managing Counsel Russell Jones, III
STAFF COUNSEL L ea d C0mm l
All Staff Members are Employees of
Sapna Perera Allstate Insurance Company
Lead Counsel Joe L_ C a"e on
This Office is not a Partnership or a Corporation Anthony Decuerre?”
Adam Adler
Tabor J .G. Dorsey
Kathryn T. Heflin
Lauren DeGirolamoi: MAILING ADDRESS" Jacqueline M. ‘Jackie’ Houlette
Natasha E. Egharevba P.0. 30x 655441 Marsheldondria ‘Dondria’
Caitlin M. Hodge
Young C. Jenkins Dallas, TX 75265 JOhnson
Amber Jones
Lauren Lawrence Kursten King
,
Paula Loftis
Physwal Address: Michelanie Rayford
Emery Martinez 86 75 Freeport Parkway — MS #3 7 Sable Taddesse
Gabrielle Mathis Nicholas ‘Nick’ Vincent
Christina McGlothlin Irving, Texas 75063
Robert J. Yadao
Faith Miller
Kirstein “Lexa” Ritchie :l:Also Admitted in California
Ashley Reichner Fax: (8 77) 6 78-4 763 Admitted in District of Columbia
Tesch Ussery . :Also
Also Admitted in Illinois
E-Servtce Email: DallasLegal@llstate.com * A150 Admitted in New
Jersey
#Also Admitted in New York
oAlso Admitted in Virginia
Attorney Administrative Assistant Paralegal
(214) 213-8862 (214) 659-4389 (214) 659-4394
September 12, 2022
VIA EMAIL: ESERVICE@BENABBOTT.COM
Amanda Green French, Esq.
Ben Abbott & Associates, PLLC
1934 Pendleton Drive
Garland, TX 75041
Re: Reyes, et a1 VS. Allstate
Cause Number: DC-20-03505
Date of Loss: March l9, 2019
Our File Number: 05399443621
Dear Ms. Green French:
DMNA REYES, INDIVIDUALLY AND AS NEXT FRIEND OF E.G. (MINOR) and ALLSTATE
COUNTY MUTUAL INSURANCE COMPANY agree to settle this case for $10,000.00 for the adult
and $1200.00 for the minor inclusive of any and all liens and/or subrogated interests. In exchange for
the payment of the sum of $10,000.00 for the adult and $1200.00 for the minor, upon receipt of the
settlement check(s), DIANA REYES, INDIVIDUALLY AND AS NEXT FRIEND OF E.G. (MINOR)
shall dismiss the case with prejudice to any refiling and provide ALLSTATE COUNTY MUTUAL
INSURANCE COMPANY with a full and final release. In addition, Plaintiff’s Counsel will provide
Defense Counsel with drafting instructions for proper and direct payment to the lienholder or holder of a
subrogated interest. Counsel for Plaintiff agrees to hold the settlement check(s) in trust and that
payment is contingent upon the receipt of the properly executed closing documents.
Amanda Green French, Esq.
Reyes, et a1 vs. Allstate
September 12, 2022
Page 2 of 2
If these are the terms of our agreement, please sign below in the space provided, and return it to me Via
fax. Pursuant to Rule 11, Texas Rules of Civil Procedure, a copy of this letter will be filed among the
papers of this cause to evidence our agreement in this matter.
Your consideration in this matter is deeply appreciated.
Sincerely, Agreed:
LISA CHASTAIN & ASSOCIATES BEN ABBOTT & ASSOCIATES, PLLC
ls/ Amanda French w/permission
NATASHA E. EGHAREVBA AMANDA GREEN FRENCH
For General Communication: Email:
Natasha.Egharevba@allstate. com
For E-Service Only:
DallasLegal@allstate.com
Attorney for ALLSTATE COUNTY Attorney for DIANA REYES,
MUTUAL INSURANCE COMPANY INDIVIDUALLY AND AS NEXT FRIEND
OF E.G. (MINOR)
cc: Amanda Green French
State Bar No. 24106026
Ben Abbott & Associates, PLLC
1934 Pendleton Drive
Garland, TX 75041
(972) 263-5555
(817) 263-5555
(972) 682-7586 Facsimile
eService@benabbott.com
ATTORNEYS FOR PLAINTIFF
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Natasha Egharevba on behalf of Natasha Egharevba
Bar No. 24093483
natasha.egharevba@allstate.com
Envelope ID: 68184111
Status as of 9/13/2022 10:55 AM CST
Associated Case Party: DIANA REYES
Name BarNumber Email TimestampSubmitted Status
Amanda Green-French eservice@benabbott.com 9/13/2022 8:11:12 AM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Natasha Egharevba on behalf of Natasha Egharevba
Bar No. 24093483
natasha.egharevba@allstate.com
Envelope ID: 68184111
Status as of 9/13/2022 10:55 AM CST
Associated Case Party: ALLSTATE COUNTY MUTUAL INSURANCE COMPANY
Name BarNumber Email TimestampSubmitted Status
Sapna Perera DallasLegaI@allstate.com 9/13/2022 8:11 :12 AM SENT
Dallas Legal DallasLegal@allstate.com 9/13/2022 8:11:12 AM SENT
Natasha E.Egharevba DallasLegal@allstate.com 9/13/2022 8:11:12 AM SENT
Natasha E.Egharevba natasha.egharevba@allstate.com 9/13/2022 8:11:12 AM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Natasha Egharevba on behalf of Natasha Egharevba
Bar No. 24093483
natasha.egharevba@allstate.com
Envelope ID: 68184111
Status as of 9/13/2022 10:55 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
LANDON KNOTTS ESERVICE@BENABBOTT.COM 9/13/2022 8:11:12 AM SENT
Document Filed Date
September 13, 2022
Case Filing Date
March 02, 2020
Category
MOTOR VEHICLE ACCIDENT
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Preview
FILED 9/13/2022 8:11 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Dorothy Strogen DEPUTY Lisa Chastain4= LISA CHASTAIN & ASSOCIATES Senior Managing Counsel Russell Jones, III STAFF COUNSEL L ea d C0mm l All Staff Members are Employees of Sapna Perera Allstate Insurance Company Lead Counsel Joe L_ C a"e on This Office is not a Partnership or a Corporation Anthony Decuerre?” Adam Adler Tabor J .G. Dorsey Kathryn T. Heflin Lauren DeGirolamoi: MAILING ADDRESS" Jacqueline M. ‘Jackie’ Houlette Natasha E. Egharevba P.0. 30x 655441 Marsheldondria ‘Dondria’ Caitlin M. Hodge Young C. Jenkins Dallas, TX 75265 JOhnson Amber Jones Lauren Lawrence Kursten King , Paula Loftis Physwal Address: Michelanie Rayford Emery Martinez 86 75 Freeport Parkway — MS #3 7 Sable Taddesse Gabrielle Mathis Nicholas ‘Nick’ Vincent Christina McGlothlin Irving, Texas 75063 Robert J. Yadao Faith Miller Kirstein “Lexa” Ritchie :l:Also Admitted in California Ashley Reichner Fax: (8 77) 6 78-4 763 Admitted in District of Columbia Tesch Ussery . :Also Also Admitted in Illinois E-Servtce Email: DallasLegal@llstate.com * A150 Admitted in New Jersey #Also Admitted in New York oAlso Admitted in Virginia Attorney Administrative Assistant Paralegal (214) 213-8862 (214) 659-4389 (214) 659-4394 September 12, 2022 VIA EMAIL: ESERVICE@BENABBOTT.COM Amanda Green French, Esq. Ben Abbott & Associates, PLLC 1934 Pendleton Drive Garland, TX 75041 Re: Reyes, et a1 VS. Allstate Cause Number: DC-20-03505 Date of Loss: March l9, 2019 Our File Number: 05399443621 Dear Ms. Green French: DMNA REYES, INDIVIDUALLY AND AS NEXT FRIEND OF E.G. (MINOR) and ALLSTATE COUNTY MUTUAL INSURANCE COMPANY agree to settle this case for $10,000.00 for the adult and $1200.00 for the minor inclusive of any and all liens and/or subrogated interests. In exchange for the payment of the sum of $10,000.00 for the adult and $1200.00 for the minor, upon receipt of the settlement check(s), DIANA REYES, INDIVIDUALLY AND AS NEXT FRIEND OF E.G. (MINOR) shall dismiss the case with prejudice to any refiling and provide ALLSTATE COUNTY MUTUAL INSURANCE COMPANY with a full and final release. In addition, Plaintiff’s Counsel will provide Defense Counsel with drafting instructions for proper and direct payment to the lienholder or holder of a subrogated interest. Counsel for Plaintiff agrees to hold the settlement check(s) in trust and that payment is contingent upon the receipt of the properly executed closing documents. Amanda Green French, Esq. Reyes, et a1 vs. Allstate September 12, 2022 Page 2 of 2 If these are the terms of our agreement, please sign below in the space provided, and return it to me Via fax. Pursuant to Rule 11, Texas Rules of Civil Procedure, a copy of this letter will be filed among the papers of this cause to evidence our agreement in this matter. Your consideration in this matter is deeply appreciated. Sincerely, Agreed: LISA CHASTAIN & ASSOCIATES BEN ABBOTT & ASSOCIATES, PLLC ls/ Amanda French w/permission NATASHA E. EGHAREVBA AMANDA GREEN FRENCH For General Communication: Email: Natasha.Egharevba@allstate. com For E-Service Only: DallasLegal@allstate.com Attorney for ALLSTATE COUNTY Attorney for DIANA REYES, MUTUAL INSURANCE COMPANY INDIVIDUALLY AND AS NEXT FRIEND OF E.G. (MINOR) cc: Amanda Green French State Bar No. 24106026 Ben Abbott & Associates, PLLC 1934 Pendleton Drive Garland, TX 75041 (972) 263-5555 (817) 263-5555 (972) 682-7586 Facsimile eService@benabbott.com ATTORNEYS FOR PLAINTIFF Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Natasha Egharevba on behalf of Natasha Egharevba Bar No. 24093483 natasha.egharevba@allstate.com Envelope ID: 68184111 Status as of 9/13/2022 10:55 AM CST Associated Case Party: DIANA REYES Name BarNumber Email TimestampSubmitted Status Amanda Green-French eservice@benabbott.com 9/13/2022 8:11:12 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Natasha Egharevba on behalf of Natasha Egharevba Bar No. 24093483 natasha.egharevba@allstate.com Envelope ID: 68184111 Status as of 9/13/2022 10:55 AM CST Associated Case Party: ALLSTATE COUNTY MUTUAL INSURANCE COMPANY Name BarNumber Email TimestampSubmitted Status Sapna Perera DallasLegaI@allstate.com 9/13/2022 8:11 :12 AM SENT Dallas Legal DallasLegal@allstate.com 9/13/2022 8:11:12 AM SENT Natasha E.Egharevba DallasLegal@allstate.com 9/13/2022 8:11:12 AM SENT Natasha E.Egharevba natasha.egharevba@allstate.com 9/13/2022 8:11:12 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Natasha Egharevba on behalf of Natasha Egharevba Bar No. 24093483 natasha.egharevba@allstate.com Envelope ID: 68184111 Status as of 9/13/2022 10:55 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status LANDON KNOTTS ESERVICE@BENABBOTT.COM 9/13/2022 8:11:12 AM SENT