On May 27, 2020 a
Party Notice
was filed
involving a dispute between
Rhea, Clendon,
and
Allstate Fire And Casualty Insurance Company,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
10/5/2022 3:06 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Martin Reyes DEPUTY
LAUREN S. SHAW AND ASSOCIATES
Not a Partnership or Professional Corporation
Attorneys and Staff are Employees of United Automobile Insurance Services
DALLAS HOUSTON
901 Main St, Suite 5330 3120 Southwest Freeway, Suite 215
Dallas, Texas 75202 Houston, Texas 77098
Phone: 972-764-0035 Phone: 281-661-3321
Fax: 214-560-6871 Fax: 713-527-7888
Michael Spears
972-764-0035 X77240
mspear@uaig.net
September 26, 2022
Via Facsimile: 972-682-7586
Andrew Vrankovic
Ben Abbott & Associates, PLLC
1934 Pendleton Dr.
Garland, Texas 75041
Re: Cause No. DC-21-06260; Diana Ramirez v. Samuel Munoz-Santillan; Pending
Dallas County 193rd Judicial District Court
Our claim no: 0800192977
Dear Andrew Vrankovic:
Please allow this to serve as a Rule 11 Agreement concerning the settlement of the
above-referenced matter. This will confirm that Plaintiff Diana Ramirez has agreed to accept
the settlement of $30,000 (Thirty thousand and zero/100 dollars) to settle any and all claims
arising out of the automobile collision that is the subject of the above-styled lawsuit against
Defendant Samuel Munoz-Santillan.
This settlement will include Plaintiff providing a full and final release of any and all
claims, including claims for any and all medical expenses and property damages against
Defendant. Plaintiff further agrees to execute a formal Release, Settlement and Indemnity
Agreement and Agreed Order of Dismissal upon receipt of the settlement funding.
Please note that, in light of the Texas Hospital Lien Statute, any treating hospital will be
named as a payee on the settlement draft unless Plaintiff provides a hospital billing invoice
showing a zero balance for the dates of treatment at issue in this lawsuit or drafting instructions
for the direct payment to the hospital by Defendant’s insurance carrier. Further, the parties
agree that any subrogation interests, including but not limited to claims for reimbursement by a
health insurance plan or first party insurance carrier, will be named as payees on the settlement
check absent an agreement to the contrary.
Finally, Plaintiff agrees to provide his/her full name, D/O/B, Social Security Number
and HICN Number. Please note that providing this information is not a condition to this
settlement, but merely compliance with Federal Law. Pursuant to the Medicare Secondary
Payer Statute, 42 U.S.C. 1395y and 42 C.F.R. 411.25(a) we have an affirmative obligation to
determine if a claimant is entitled to Medicare, Medicaid or SCHIP. If so, we are required, by
Federal Law, to notify Medicare of this settlement. I have attached a CMS form to this letter for
your convenience.
If this accurately depicts our agreement, please sign below and return to my attention so
that we may file the agreement with the Court.
Thank you for your attention to this matter. If you have any questions, please do not
hesitate to call me.
With kind regards,
//%¢w
Mi ael Spears
Attorney for Defendant
AGREED:
(AM
Andrew Vrankovic
Attorney 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.
Alex Maldonado on behalf of Young Christian Jenkins
Bar No. 24034505
Alex.Maldonado@allstate.com
Envelope ID: 68934611
Status as of 10/5/2022 3:16 PM CST
Associated Case Party: CLENDON RHEA
Name BarNumber Email TimestampSubmitted Status
Constance Mutong eservice@benabbott.com 10/5/2022 3:06:29 PM 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.
Alex Maldonado on behalf of Young Christian Jenkins
Bar No. 24034505
Alex.Maldonado@allstate.com
Envelope ID: 68934611
Status as of 10/5/2022 3:16 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
CAMILO VALENCIA eService@benabbott.com 10/5/2022 3:06:29 PM SENT
Young Jenkins dallaslegal@allstate.com 10/5/2022 3:06:29 PM SENT
Document Filed Date
October 05, 2022
Case Filing Date
May 27, 2020
Category
MOTOR VEHICLE ACCIDENT
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Preview
FILED 10/5/2022 3:06 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Martin Reyes DEPUTY LAUREN S. SHAW AND ASSOCIATES Not a Partnership or Professional Corporation Attorneys and Staff are Employees of United Automobile Insurance Services DALLAS HOUSTON 901 Main St, Suite 5330 3120 Southwest Freeway, Suite 215 Dallas, Texas 75202 Houston, Texas 77098 Phone: 972-764-0035 Phone: 281-661-3321 Fax: 214-560-6871 Fax: 713-527-7888 Michael Spears 972-764-0035 X77240 mspear@uaig.net September 26, 2022 Via Facsimile: 972-682-7586 Andrew Vrankovic Ben Abbott & Associates, PLLC 1934 Pendleton Dr. Garland, Texas 75041 Re: Cause No. DC-21-06260; Diana Ramirez v. Samuel Munoz-Santillan; Pending Dallas County 193rd Judicial District Court Our claim no: 0800192977 Dear Andrew Vrankovic: Please allow this to serve as a Rule 11 Agreement concerning the settlement of the above-referenced matter. This will confirm that Plaintiff Diana Ramirez has agreed to accept the settlement of $30,000 (Thirty thousand and zero/100 dollars) to settle any and all claims arising out of the automobile collision that is the subject of the above-styled lawsuit against Defendant Samuel Munoz-Santillan. This settlement will include Plaintiff providing a full and final release of any and all claims, including claims for any and all medical expenses and property damages against Defendant. Plaintiff further agrees to execute a formal Release, Settlement and Indemnity Agreement and Agreed Order of Dismissal upon receipt of the settlement funding. Please note that, in light of the Texas Hospital Lien Statute, any treating hospital will be named as a payee on the settlement draft unless Plaintiff provides a hospital billing invoice showing a zero balance for the dates of treatment at issue in this lawsuit or drafting instructions for the direct payment to the hospital by Defendant’s insurance carrier. Further, the parties agree that any subrogation interests, including but not limited to claims for reimbursement by a health insurance plan or first party insurance carrier, will be named as payees on the settlement check absent an agreement to the contrary. Finally, Plaintiff agrees to provide his/her full name, D/O/B, Social Security Number and HICN Number. Please note that providing this information is not a condition to this settlement, but merely compliance with Federal Law. Pursuant to the Medicare Secondary Payer Statute, 42 U.S.C. 1395y and 42 C.F.R. 411.25(a) we have an affirmative obligation to determine if a claimant is entitled to Medicare, Medicaid or SCHIP. If so, we are required, by Federal Law, to notify Medicare of this settlement. I have attached a CMS form to this letter for your convenience. If this accurately depicts our agreement, please sign below and return to my attention so that we may file the agreement with the Court. Thank you for your attention to this matter. If you have any questions, please do not hesitate to call me. With kind regards, //%¢w Mi ael Spears Attorney for Defendant AGREED: (AM Andrew Vrankovic Attorney 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. Alex Maldonado on behalf of Young Christian Jenkins Bar No. 24034505 Alex.Maldonado@allstate.com Envelope ID: 68934611 Status as of 10/5/2022 3:16 PM CST Associated Case Party: CLENDON RHEA Name BarNumber Email TimestampSubmitted Status Constance Mutong eservice@benabbott.com 10/5/2022 3:06:29 PM 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. Alex Maldonado on behalf of Young Christian Jenkins Bar No. 24034505 Alex.Maldonado@allstate.com Envelope ID: 68934611 Status as of 10/5/2022 3:16 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status CAMILO VALENCIA eService@benabbott.com 10/5/2022 3:06:29 PM SENT Young Jenkins dallaslegal@allstate.com 10/5/2022 3:06:29 PM SENT