On November 27, 2019 a
Judgment
was filed
involving a dispute between
City Of Galveston,
Insurors Indemnity Company,
Quality Works Construction, Inc.,
Davis, Sharon,
and
City Of Galveston,
Insurors Indemnity Company,
Quality Works Construction, Inc.,
for Injury/Damage - Other
in the District Court of Galveston County.
Preview
Filed: 10/12/2021 1:49 PM
J OHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 58103714
CAUSE NO. 19-CV-2191 By: Shailja Dixit
10/12/2021 3:05 PM
SHARON DAVIS, INDIVIDUALLY and as §
ASSIGNEE OF THE CITY OF GALVESTON § IN THE DISTRICT COURT
Plaintiff, §
v. GALVESTON COUNTY, TEXAS
QUALITY WORKS CONSTRUCTION, INC.,
and
INSURORS INDEMNITY COMPANY
Defendants. 56 JUDICIAL DISTRICT
AGREED MOTION TO DISMISS
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES, PLAINTIFF SHARON DAVIS, INDIVIDUALLY and as ASSIGNEE OF
THE CITY OF GALVESTON, and moves the Court to dismiss this cause with prejudice to refiling
as to Defendant Insurors Indemnity Company for the reason that all matters of fact and things in
controversy have been resolved by and between these parties.
WHEREFORE, PREMISES CONSIDERED, Plaintiff Sharon Davis, Individually and as
Assignee of The City of Galveston, requests that the Court enter an order dismissing the said causes
with prejudice to the right of Plaintiff to refile the same or any part thereof as to Defendant Insurors
Indemnity Company and that ali costs of court be taxed against the party incurring same.
Respectfully submitted,
CALDWELL A
FLE PC
By: atl
Caldwell Fletcher
State Bar No. 07141710
3401 Allen Parkway, Suite 100
Houston, Texas 77019
(713) 284-1624 — Telephone
(713) 583-9883 — Fax
caldwell@caldwellfltecherpe.com
ATTORNEYS FOR PLAINTIFF
BEARD KULTGEN BROPHY
BOSTWICK & DICKSON, PLLC
dock rfacbene
Dan N. MacLemore
State Bar No, 24037013
220 South 4th Street
Waco, Texas 76701
Tel (254) 776-5500
Fax (254) 776-3591
maclemore@thetexasfirm.com
ATTORNEYS FOR DEFENDANT
INSURORS INDEMNITY COMPANY
CERTIFICATE OF SERVICE
This will certify that a true and correct copy of the foregoing instrument has been mailed,
telecopied, hand delivered, and/or electronically filed and served to all attorneys of record in this
cause of action on the oe
_/ y of October, 2021,
a Che Caldwell Fletcher
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.
Caldwell Fletcher
Bar No. 7141710
cfletcher@ ellingtonlaw.com
Envelope ID: 58103714
Status as of 10/12/2021 3:05 PM CST
Associated Case Party: Sharon Davis
Name BarNumber | Email TimestampSubmitted | Status
Caldwell Fletcher | 7141710 caldwell@ caldwellfletcherpc.com 10/12/2021 1:49:38 PM | SENT
Caldwell Fletcher Caldwell@ caldwellfletcherpc.com | 10/12/2021 1:49:38 PM | SENT
Associated Case Party: QUALITY WORKS CONSTRUCTION, INC.
Name BarNumber | Email TimestampSubmitted | Status
Byron KBarclay BKBarclay@ Lawyer.com | 10/12/2021 1:49:38PM | SENT
Associated Case Party: INSURORS INDEMNITY COMPANY
Name BarNumber | Email TimestampSubmitted | Status
Callye Berry berry@ thetexasfirm.com 10/12/2021 1:49:38 PM | SENT
Dan MacLemore maclemore@ thetexasfirm.com | 10/12/2021 1:49:38 PM | SENT
Associated Case Party: City of Galveston
Name BarNumber | Email TimestampSubmitted Status
Donald Glywasky Glywaskydon@ cityofgalveston.org | 10/12/2021 1:49:38 PM SENT
Beverly DianeWest bwest@ galvestontx.gov 10/12/2021 1:49:38 PM SENT
Barry C.Willey bwilley@ galvestontx.gov 10/12/2021 1:49:38 PM SENT
Associated Case Party: J ohnP .Cahill
Name
Lanza Law Firm Eservice
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.
Caldwell Fletcher
Bar No. 7141710
cfletcher@ ellingtonlaw.com
Envelope ID: 58103714
Status as of 10/12/2021 3:05 PM CST
Associated Case Party: J ohnP .Cahill
J ohn PCahill jcahill@ lanzalawfirm.com 10/12/2021 1:49:38 PM | SENT
Document Filed Date
October 12, 2021
Case Filing Date
November 27, 2019
Category
Injury/Damage - Other
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Preview
Filed: 10/12/2021 1:49 PM J OHN D. KINARD - District Clerk Galveston County, Texas Envelope No. 58103714 CAUSE NO. 19-CV-2191 By: Shailja Dixit 10/12/2021 3:05 PM SHARON DAVIS, INDIVIDUALLY and as § ASSIGNEE OF THE CITY OF GALVESTON § IN THE DISTRICT COURT Plaintiff, § v. GALVESTON COUNTY, TEXAS QUALITY WORKS CONSTRUCTION, INC., and INSURORS INDEMNITY COMPANY Defendants. 56 JUDICIAL DISTRICT AGREED MOTION TO DISMISS TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES, PLAINTIFF SHARON DAVIS, INDIVIDUALLY and as ASSIGNEE OF THE CITY OF GALVESTON, and moves the Court to dismiss this cause with prejudice to refiling as to Defendant Insurors Indemnity Company for the reason that all matters of fact and things in controversy have been resolved by and between these parties. WHEREFORE, PREMISES CONSIDERED, Plaintiff Sharon Davis, Individually and as Assignee of The City of Galveston, requests that the Court enter an order dismissing the said causes with prejudice to the right of Plaintiff to refile the same or any part thereof as to Defendant Insurors Indemnity Company and that ali costs of court be taxed against the party incurring same. Respectfully submitted, CALDWELL A FLE PC By: atl Caldwell Fletcher State Bar No. 07141710 3401 Allen Parkway, Suite 100 Houston, Texas 77019 (713) 284-1624 — Telephone (713) 583-9883 — Fax caldwell@caldwellfltecherpe.com ATTORNEYS FOR PLAINTIFF BEARD KULTGEN BROPHY BOSTWICK & DICKSON, PLLC dock rfacbene Dan N. MacLemore State Bar No, 24037013 220 South 4th Street Waco, Texas 76701 Tel (254) 776-5500 Fax (254) 776-3591 maclemore@thetexasfirm.com ATTORNEYS FOR DEFENDANT INSURORS INDEMNITY COMPANY CERTIFICATE OF SERVICE This will certify that a true and correct copy of the foregoing instrument has been mailed, telecopied, hand delivered, and/or electronically filed and served to all attorneys of record in this cause of action on the oe _/ y of October, 2021, a Che Caldwell Fletcher 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. Caldwell Fletcher Bar No. 7141710 cfletcher@ ellingtonlaw.com Envelope ID: 58103714 Status as of 10/12/2021 3:05 PM CST Associated Case Party: Sharon Davis Name BarNumber | Email TimestampSubmitted | Status Caldwell Fletcher | 7141710 caldwell@ caldwellfletcherpc.com 10/12/2021 1:49:38 PM | SENT Caldwell Fletcher Caldwell@ caldwellfletcherpc.com | 10/12/2021 1:49:38 PM | SENT Associated Case Party: QUALITY WORKS CONSTRUCTION, INC. Name BarNumber | Email TimestampSubmitted | Status Byron KBarclay BKBarclay@ Lawyer.com | 10/12/2021 1:49:38PM | SENT Associated Case Party: INSURORS INDEMNITY COMPANY Name BarNumber | Email TimestampSubmitted | Status Callye Berry berry@ thetexasfirm.com 10/12/2021 1:49:38 PM | SENT Dan MacLemore maclemore@ thetexasfirm.com | 10/12/2021 1:49:38 PM | SENT Associated Case Party: City of Galveston Name BarNumber | Email TimestampSubmitted Status Donald Glywasky Glywaskydon@ cityofgalveston.org | 10/12/2021 1:49:38 PM SENT Beverly DianeWest bwest@ galvestontx.gov 10/12/2021 1:49:38 PM SENT Barry C.Willey bwilley@ galvestontx.gov 10/12/2021 1:49:38 PM SENT Associated Case Party: J ohnP .Cahill Name Lanza Law Firm Eservice 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. Caldwell Fletcher Bar No. 7141710 cfletcher@ ellingtonlaw.com Envelope ID: 58103714 Status as of 10/12/2021 3:05 PM CST Associated Case Party: J ohnP .Cahill J ohn PCahill jcahill@ lanzalawfirm.com 10/12/2021 1:49:38 PM | SENT