On September 08, 2022 a
Rule 11 Agreement, Filed
was filed
involving a dispute between
Batista, Leslye,
Martinez, Martita,
and
City Of Progreso,
Gonzalez, Daena Nicole,
for Injury or Damage - Motor Vehicle (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Filed
12/12/2022 3:35 PM
Hidalgo County District Clerks
Reviewed By: Vincente Facundo
AGUILAR1~ZABARTE, LLC
J. Arnold Aguilar 990 Marine D riYc
B01,rd CtJ'Jified - Personid Injm:v 1H,rl Lu11 Brownsville, TX 78520
Tex,is Board ofLegal Spcd,rlh:,ttion Office: (956) 504-1100
Fax: (956) 504-1408
Email: arnold@aguilarz.1bartclk.com
December 12, 2022
Noe A. Gonzalez
Associate Attorney
HINOJOSA LAW, PLLC
3110 E. Bus Hwy. 83, Suite B,
Weslaco TX 78596
ngonzalez@hinojosalaw.com
Re: Cause No. C-3502-22-I
Maiiita Martinez and Leslye Batista
v. Daena Nicole Gonzalez and City of Progreso
Our File No. 820-22
RULE 11 AGREEMENT
Dear Mr. Gonzalez:
As we discussed, this is to confirm that you have agreed to amend Plaintiffs' Original
Petition to identify facts to establish Chief Solis was negligent, including how he was
negligent in failing to obey traffic regulations, facts to establish Chief Solis violated Texas
Transportation Code§§ 545.062, 545.103, 545.104, and 545.151, and facts to establish the
City of Progreso may be liable for negligent training, hiring, permitting, supervising,
monitoring, securing, failing to provide adequate safety procedures and policies, and creating
a hazard and/or endangeling the lives of others, if you are able to develop such facts, and that
you will identify the maximum amount of damages you are seeking from the City of Progreso,
by F1iday, December 30, 2022, in the above referenced action.
If this is your understanding of our agreement, I would ask that you please sign in the
space provided below, scan, and return this agreement to me via email as soon as possible so
that I can submit it to the Court and contact the clerk to pass the hearing cunently scheduled
for tomorrow, Tuesday, December 13, 2022 at 8:00 a.m.
Electronically Filed
12/12/2022 3:35 PM
Hidalgo County District Clerks
Reviewed By: Vincente Facundo
Mr. Noe A. Gonzalez
December 12, 2022
Page 2
Thank you for your consideration in this matter.
Ve1y truly yours,
AGUILAR AZABARTE, LLC
Q~~~
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.
Gabriela Garcia on behalf of J. Arnold Aguilar
Bar No. 00936270
gabriela@aguilarzabarte.onmicrosoft.com
Envelope ID: 70931216
Status as of 12/12/2022 4:20 PM CST
Associated Case Party: Martita Martinez
Name BarNumber Email TimestampSubmitted Status
Roxanne Hinojosa roxannehinojosa@hinojosalaw.com 12/12/2022 3:35:46 PM SENT
Jason Casell jcasell@hinojosalaw.com 12/12/2022 3:35:46 PM SENT
Hinojosa Law e-service@hinojosalaw.com 12/12/2022 3:35:46 PM SENT
Richard Hinojosa richardhinojosa@hinojosalaw.com 12/12/2022 3:35:46 PM SENT
Noe A.Gonzalez ngonzalez@hinojosalaw.com 12/12/2022 3:35:46 PM SENT
Carolina Yagas cyagas@hinojosalaw.com 12/12/2022 3:35:46 PM SENT
Ricka Tijerina rtijerina@hinojosalaw.com 12/12/2022 3:35:46 PM SENT
Alexandra Thomas athomas@hinojosalaw.com 12/12/2022 3:35:46 PM SENT
Justin DavidBurrow jburrow@hinojosalaw.com 12/12/2022 3:35:46 PM SENT
Associated Case Party: City of Progreso
Name BarNumber Email TimestampSubmitted Status
J. Arnold Aguilar arnold@aguilarzabartellc.com 12/12/2022 3:35:46 PM SENT
Gabriela Garcia gabriela@aguilarzabarte.onmicrosoft.com 12/12/2022 3:35:46 PM SENT
Associated Case Party: Leslye Batista
Name BarNumber Email TimestampSubmitted Status
Carolina Yagas cyagas@hinojosalaw.com 12/12/2022 3:35:46 PM SENT
Document Filed Date
December 12, 2022
Case Filing Date
September 08, 2022
Category
Injury or Damage - Motor Vehicle (OCA)
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Preview
Electronically Filed 12/12/2022 3:35 PM Hidalgo County District Clerks Reviewed By: Vincente Facundo AGUILAR1~ZABARTE, LLC J. Arnold Aguilar 990 Marine D riYc B01,rd CtJ'Jified - Personid Injm:v 1H,rl Lu11 Brownsville, TX 78520 Tex,is Board ofLegal Spcd,rlh:,ttion Office: (956) 504-1100 Fax: (956) 504-1408 Email: arnold@aguilarz.1bartclk.com December 12, 2022 Noe A. Gonzalez Associate Attorney HINOJOSA LAW, PLLC 3110 E. Bus Hwy. 83, Suite B, Weslaco TX 78596 ngonzalez@hinojosalaw.com Re: Cause No. C-3502-22-I Maiiita Martinez and Leslye Batista v. Daena Nicole Gonzalez and City of Progreso Our File No. 820-22 RULE 11 AGREEMENT Dear Mr. Gonzalez: As we discussed, this is to confirm that you have agreed to amend Plaintiffs' Original Petition to identify facts to establish Chief Solis was negligent, including how he was negligent in failing to obey traffic regulations, facts to establish Chief Solis violated Texas Transportation Code§§ 545.062, 545.103, 545.104, and 545.151, and facts to establish the City of Progreso may be liable for negligent training, hiring, permitting, supervising, monitoring, securing, failing to provide adequate safety procedures and policies, and creating a hazard and/or endangeling the lives of others, if you are able to develop such facts, and that you will identify the maximum amount of damages you are seeking from the City of Progreso, by F1iday, December 30, 2022, in the above referenced action. If this is your understanding of our agreement, I would ask that you please sign in the space provided below, scan, and return this agreement to me via email as soon as possible so that I can submit it to the Court and contact the clerk to pass the hearing cunently scheduled for tomorrow, Tuesday, December 13, 2022 at 8:00 a.m. Electronically Filed 12/12/2022 3:35 PM Hidalgo County District Clerks Reviewed By: Vincente Facundo Mr. Noe A. Gonzalez December 12, 2022 Page 2 Thank you for your consideration in this matter. Ve1y truly yours, AGUILAR AZABARTE, LLC Q~~~ 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. Gabriela Garcia on behalf of J. Arnold Aguilar Bar No. 00936270 gabriela@aguilarzabarte.onmicrosoft.com Envelope ID: 70931216 Status as of 12/12/2022 4:20 PM CST Associated Case Party: Martita Martinez Name BarNumber Email TimestampSubmitted Status Roxanne Hinojosa roxannehinojosa@hinojosalaw.com 12/12/2022 3:35:46 PM SENT Jason Casell jcasell@hinojosalaw.com 12/12/2022 3:35:46 PM SENT Hinojosa Law e-service@hinojosalaw.com 12/12/2022 3:35:46 PM SENT Richard Hinojosa richardhinojosa@hinojosalaw.com 12/12/2022 3:35:46 PM SENT Noe A.Gonzalez ngonzalez@hinojosalaw.com 12/12/2022 3:35:46 PM SENT Carolina Yagas cyagas@hinojosalaw.com 12/12/2022 3:35:46 PM SENT Ricka Tijerina rtijerina@hinojosalaw.com 12/12/2022 3:35:46 PM SENT Alexandra Thomas athomas@hinojosalaw.com 12/12/2022 3:35:46 PM SENT Justin DavidBurrow jburrow@hinojosalaw.com 12/12/2022 3:35:46 PM SENT Associated Case Party: City of Progreso Name BarNumber Email TimestampSubmitted Status J. Arnold Aguilar arnold@aguilarzabartellc.com 12/12/2022 3:35:46 PM SENT Gabriela Garcia gabriela@aguilarzabarte.onmicrosoft.com 12/12/2022 3:35:46 PM SENT Associated Case Party: Leslye Batista Name BarNumber Email TimestampSubmitted Status Carolina Yagas cyagas@hinojosalaw.com 12/12/2022 3:35:46 PM SENT