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FILED
2/17/2020 2:13PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Margaret Thomas DEPUTY
CAUSE NO. DC-18-00241
BEHROOZ KHADEMAZAD d/b/a, § IN THE DISTRICT COURT
GRAND PRAIRIE FAMILY §
DENTAL
§
Plaintiff, §
§
V. § 101“ JUDICIAL DISTRICT
§
SEAN GHARAVI, §
§
Defendant. § DALLAS COUNTY, TEXAS
BEHROOZ KHADEMAZAD’S REMITTITUR OF JUDGMENT
Plaintiff, Behrooz Khademazad, d/b/a Grand Prairie Family Dental, files this
remittitur in the above cause, and respectfully shows:
1. On October 23, 2019, this court entered judgment under the terms of Which
Behrooz Khademazad recovered from Sean Gharavi, the defendant in the
above cause, the amount of $1,293,190.00, Which included pre—judgment
interest 0f $143,018.83 (calculated at 6%, rather that 5.25% land calculated
on exemplary damages), With post-judgment interest at 5.25%2 per year from
October 23, 2019, and all costs 0f suit.
2. Pursuant to Rule 315 0f the Texas Rules of Civil Procedure, Behrooz
Khademazad desires to make a voluntary remittitur 0f $53,589.04, which is
that portion 0f the judgment attributable t0 pre-judgment interest 0n the
1
Per Texas Office of Consumer Credit Commissioner
2
Per Texas Office 0f Consumer Credit Commissioner
BEHROOZ KHADEMAZAD’S REMITTITUR OF JUDGMENT — Page 1 15847351
exemplary damages 0f $500,000, and a voluntary remittitur of $8,709.06,
Which is the amount 0f reduction 0f the pre-judgment interest 0n the remaining
3
$650,171.21 t0 5.25%, from 6.0%.
3. With that correction, the base amount 0f the judgment is $1,150,171 .21, with
pre-judgment interest of $60,975.04 (calculated at 5.25% simple interest,
excluding exemplary damages) Therefore, Behrooz Khademazad releases
$53,589.04 0f the judgment attributable t0 pre—judgment interest on the
exemplary damages 0f $500,000 and $8,709.06, Which is difference between
the pre-judgment interest 0n the remaining $650.171 .21 at 5.25%, rather than
6.0%, t0 Sean Gharavi, and requests that execution be issued only for the
balance 0fthe judgment, Which is now the amount 0f $1,211,146.20 plus post-
judgment interest at 5.25% per annum from October 23, 2019 until paid.
WILLIAM L.
Texas
COWLES
W
Respectfully
Bar No.
&
submitted,
SIEGEL
18342480
bsiegel@cowlesthompson.com
THOMPSON, P.C.
901 Main Street, Suite 3900
Dallas, TX 75202
(214) 672-2126 (Tel)
(214) 672-2326 (Fax)
3
Per Texas Office of Consumer Credit Commissioner
BEHROOZ KHADEMAZAD’S REMITTITUR OF JUDGMENT — Page 2 15847351
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy 0f Behrooz
Khademazad’s Remittitur 0f Judgment has been forwarded t0 counsel 0f record
through the court’ s electronic filing system 0n February 17, 2020.
Jason P. Bloom
State Bar N0. 2404551 1
Jason.B100m@havnesboone.com
Ryan Paulsen
State Bar N0. 24060397
Ryan.Paulsen@havnesboone.com
Christopher R. Knight
State Bar No. 24097945
Chris.Knight@havnesboone.com
HAYNES AND BOONE, LLP
2323 Victory Avenue, Suite 700
Dallas, Texas 75219
Timothy E. Baker
tbaker@timbaker.com
Texas Bar N0. 24050247
1205 S. Greenville Avenue
Allen Texas 75002
ATTORNEYS
SEAN GHARAVI
FOR DEFENDANT
W
WILLlAaM L. SIEGEL
BEHROOZ KHADEMAZAD’S REMITTITUR OF JUDGMENT — Page 3 15847351
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FILED 2/17/2020 2:13PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Margaret Thomas DEPUTY CAUSE NO. DC-18-00241 BEHROOZ KHADEMAZAD d/b/a, § IN THE DISTRICT COURT GRAND PRAIRIE FAMILY § DENTAL § Plaintiff, § § V. § 101“ JUDICIAL DISTRICT § SEAN GHARAVI, § § Defendant. § DALLAS COUNTY, TEXAS BEHROOZ KHADEMAZAD’S REMITTITUR OF JUDGMENT Plaintiff, Behrooz Khademazad, d/b/a Grand Prairie Family Dental, files this remittitur in the above cause, and respectfully shows: 1. On October 23, 2019, this court entered judgment under the terms of Which Behrooz Khademazad recovered from Sean Gharavi, the defendant in the above cause, the amount of $1,293,190.00, Which included pre—judgment interest 0f $143,018.83 (calculated at 6%, rather that 5.25% land calculated on exemplary damages), With post-judgment interest at 5.25%2 per year from October 23, 2019, and all costs 0f suit. 2. Pursuant to Rule 315 0f the Texas Rules of Civil Procedure, Behrooz Khademazad desires to make a voluntary remittitur 0f $53,589.04, which is that portion 0f the judgment attributable t0 pre-judgment interest 0n the 1 Per Texas Office of Consumer Credit Commissioner 2 Per Texas Office 0f Consumer Credit Commissioner BEHROOZ KHADEMAZAD’S REMITTITUR OF JUDGMENT — Page 1 15847351 exemplary damages 0f $500,000, and a voluntary remittitur of $8,709.06, Which is the amount 0f reduction 0f the pre-judgment interest 0n the remaining 3 $650,171.21 t0 5.25%, from 6.0%. 3. With that correction, the base amount 0f the judgment is $1,150,171 .21, with pre-judgment interest of $60,975.04 (calculated at 5.25% simple interest, excluding exemplary damages) Therefore, Behrooz Khademazad releases $53,589.04 0f the judgment attributable t0 pre—judgment interest on the exemplary damages 0f $500,000 and $8,709.06, Which is difference between the pre-judgment interest 0n the remaining $650.171 .21 at 5.25%, rather than 6.0%, t0 Sean Gharavi, and requests that execution be issued only for the balance 0fthe judgment, Which is now the amount 0f $1,211,146.20 plus post- judgment interest at 5.25% per annum from October 23, 2019 until paid. WILLIAM L. Texas COWLES W Respectfully Bar No. & submitted, SIEGEL 18342480 bsiegel@cowlesthompson.com THOMPSON, P.C. 901 Main Street, Suite 3900 Dallas, TX 75202 (214) 672-2126 (Tel) (214) 672-2326 (Fax) 3 Per Texas Office of Consumer Credit Commissioner BEHROOZ KHADEMAZAD’S REMITTITUR OF JUDGMENT — Page 2 15847351 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy 0f Behrooz Khademazad’s Remittitur 0f Judgment has been forwarded t0 counsel 0f record through the court’ s electronic filing system 0n February 17, 2020. Jason P. Bloom State Bar N0. 2404551 1 Jason.B100m@havnesboone.com Ryan Paulsen State Bar N0. 24060397 Ryan.Paulsen@havnesboone.com Christopher R. Knight State Bar No. 24097945 Chris.Knight@havnesboone.com HAYNES AND BOONE, LLP 2323 Victory Avenue, Suite 700 Dallas, Texas 75219 Timothy E. Baker tbaker@timbaker.com Texas Bar N0. 24050247 1205 S. Greenville Avenue Allen Texas 75002 ATTORNEYS SEAN GHARAVI FOR DEFENDANT W WILLlAaM L. SIEGEL BEHROOZ KHADEMAZAD’S REMITTITUR OF JUDGMENT — Page 3 15847351