On July 15, 2020 a
Stipulation,Agreement
was filed
involving a dispute between
Batie, George,
and
Doe, John,
Perez, Antonia,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
7/23/2021 10:14 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Martin Reyes DEPUTY
CAUSE NO. DC-20-09607
GEORGE BATIE § IN THE DISTRICT COURT
§
Plaintlffi §
§
VS. §
§ 1931“) JUDICIAL DISTRICT
ANTONIA PEREZ A/Nm of ROSENDO §
HERNANDEZ (DECEASED) and §
AN TONIA PEREZ, INDIVIDUALLY S
§
§
Defendants. § DALLAS COUNTY, TEXAS
AGREED MOTION TO DISMISS WITH PREJUDICE
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COME Plaintiff George Batie and Defendant Antonia Perez A/N/F of Rosendo
Hernandez (Deceased) and Antonia Perez, Individually, (collectively referred to as the “Parties”),
in the above-styled and numbered cause and file this Agreed Motion to Dismiss with Prejudice
and in support thereof would show the Court as follows:
I.
The Parties request an Order of Dismissal with Prejudice from this Court dismissing the
claims of Plaintiff with prejudice in this matter because the Parties have agreed to a complete
settlement and resolution of the matters in controversy.
WHEREFORE, PREMISES CONSIDERED, the parties request that this Court dismiss
Plaintiff’s claims against Defendant with prejudice to the refiling of the same and that all costs of
court be taxed against the party incurring same.
AGREED MOTIONTO DISMISS WITH PREJUDICE - Page 1
Respectfully submitted,
FIELDING LAW, PLLC
C/v‘x/
Clayton Parry
State Bar No. 24091417
eservice@ fieldinglaweom
l 8601 LBJ Freeway
Town East Tower, Suite 3 l 5
Mesquite, Texas 75150
214-666-8625
214-279-6439 FAX
ATTORNEYS FOR PLAINTIFF
EKVALL & BYRNE, LLP
/s/ Rance M. Bryson
Richard J. Byrne
State Bar No. 03566435
rbyrne@ekvallbyrne.com
Rance M. Bryson
State Bar No. 00787158
rbryson@ekvallbyrne.com
4450 Sigma Road, Suite 100
Dallas, Texas 75244
(972) 239-0839
(972) 960-9517 Facsimile
ATTORNEYS FOR DEFENDANT
CERTIFICATE OF SERVICE
A true and correct copy of the foregoing instrument was served upon all known counsel in
accordance with the Rules of Civil Procedure, on this the day of , 2021.
Rance M. Bryson
AGREED MOTIONTO DISMISS WITH PREJUDICE — Page 2
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.
Sandi Williams on behalf of Rance M. Bryson
Bar No. 787158
swilliams@ekvallbyrne.com
Envelope ID: 55636959
Status as of 7/26/2021 8:37 AM CST
Associated Case Party: ANTONIA PEREZ
Name BarNumber Email TimestampSubmitted Status
Richard J.Byrne rbyrne@ekvallbyrne.com 7/23/2021 10:14:34 AM SENT
Sandi Williams swilliams@ekvallbyrne.com 7/23/2021 10:14:34 AM SENT
Rance MBryson rbryson@ekva||byrne.com 7/23/2021 10:14:34 AM SENT
Lillie E.Sanchez lsanchez@ekvallbyrne.com 7/23/2021 10:14:34 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
CLAYTON PARRY eservice@fieldinglaw.com 7/23/2021 10:14:34 AM SENT
Document Filed Date
July 23, 2021
Case Filing Date
July 15, 2020
Category
MOTOR VEHICLE ACCIDENT
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FILED 7/23/2021 10:14 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Martin Reyes DEPUTY CAUSE NO. DC-20-09607 GEORGE BATIE § IN THE DISTRICT COURT § Plaintlffi § § VS. § § 1931“) JUDICIAL DISTRICT ANTONIA PEREZ A/Nm of ROSENDO § HERNANDEZ (DECEASED) and § AN TONIA PEREZ, INDIVIDUALLY S § § Defendants. § DALLAS COUNTY, TEXAS AGREED MOTION TO DISMISS WITH PREJUDICE TO THE HONORABLE JUDGE OF SAID COURT: NOW COME Plaintiff George Batie and Defendant Antonia Perez A/N/F of Rosendo Hernandez (Deceased) and Antonia Perez, Individually, (collectively referred to as the “Parties”), in the above-styled and numbered cause and file this Agreed Motion to Dismiss with Prejudice and in support thereof would show the Court as follows: I. The Parties request an Order of Dismissal with Prejudice from this Court dismissing the claims of Plaintiff with prejudice in this matter because the Parties have agreed to a complete settlement and resolution of the matters in controversy. WHEREFORE, PREMISES CONSIDERED, the parties request that this Court dismiss Plaintiff’s claims against Defendant with prejudice to the refiling of the same and that all costs of court be taxed against the party incurring same. AGREED MOTIONTO DISMISS WITH PREJUDICE - Page 1 Respectfully submitted, FIELDING LAW, PLLC C/v‘x/ Clayton Parry State Bar No. 24091417 eservice@ fieldinglaweom l 8601 LBJ Freeway Town East Tower, Suite 3 l 5 Mesquite, Texas 75150 214-666-8625 214-279-6439 FAX ATTORNEYS FOR PLAINTIFF EKVALL & BYRNE, LLP /s/ Rance M. Bryson Richard J. Byrne State Bar No. 03566435 rbyrne@ekvallbyrne.com Rance M. Bryson State Bar No. 00787158 rbryson@ekvallbyrne.com 4450 Sigma Road, Suite 100 Dallas, Texas 75244 (972) 239-0839 (972) 960-9517 Facsimile ATTORNEYS FOR DEFENDANT CERTIFICATE OF SERVICE A true and correct copy of the foregoing instrument was served upon all known counsel in accordance with the Rules of Civil Procedure, on this the day of , 2021. Rance M. Bryson AGREED MOTIONTO DISMISS WITH PREJUDICE — Page 2 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. Sandi Williams on behalf of Rance M. Bryson Bar No. 787158 swilliams@ekvallbyrne.com Envelope ID: 55636959 Status as of 7/26/2021 8:37 AM CST Associated Case Party: ANTONIA PEREZ Name BarNumber Email TimestampSubmitted Status Richard J.Byrne rbyrne@ekvallbyrne.com 7/23/2021 10:14:34 AM SENT Sandi Williams swilliams@ekvallbyrne.com 7/23/2021 10:14:34 AM SENT Rance MBryson rbryson@ekva||byrne.com 7/23/2021 10:14:34 AM SENT Lillie E.Sanchez lsanchez@ekvallbyrne.com 7/23/2021 10:14:34 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status CLAYTON PARRY eservice@fieldinglaw.com 7/23/2021 10:14:34 AM SENT