On May 27, 2016 a
Party Discovery
was filed
involving a dispute between
Attorney General Of Texas,
Gupta, Atul Kumar,
Jain, Vibha,
and
Gupta, Atul Kumar,
Jain, Vibha,
for Divorce - With Children
in the District Court of Fort Bend County.
Preview
DocuSign Envelope ID: 72E13CC0-4A01-4F86-87DE-6BEFDC26E19F Filed
12/15/2022 3:14 PM
Beverley McGrew Walker
District Clerk
Fort Bend County, Texas
Kiara Fears
CAUSE NO. 16-DCV-232757
IN THE INTERESTS OF IN THE DISTRICT COURT
a
A CHILD 328'" JUDICIAL DISTRICT
FORT BEND COUNTY, TEXAS
PARTIAL MEDIATED SETTLEMENT AGREEMENT
The undersigned parties herewith agree to compromise and settle the claims and controversies
between them to include only the issues as specifically set forth in this agreement. All other issues shall be
reserved for future disposition. The parties wish to avoid potentially protracted and costly litigation and
agree and stipulate that they have carefully considered the needs of the child, their respective ability and
contribution other than in cash, for support, and the best interest of the child.
THE PARTIES ALSO AGREE THAT THIS MEDIATION AGREEMENT IS BINDING ON BOTH
OF THEM AND IS NOT SUBJECT TO REVOCATION BY EITHER OF THEM. EACH PARTY
IS ENTITLED TO JUDGMENT ON THIS AGREEMENT.
ANY DISPUTES ARISING FROM (a) THE DRAFTING OF THE ORDER OR ANCILLARY
DOCUMENTS WHICH CANNOT BE RESOLVED BY MEDIATION, SHALL BE DECIDED
BY BINDING ARBITRATION WITH JAMES A. COOPER SERVING AS BINDING
ARBITRATOR. NOTHING IN THIS PROVISION GIVES THE MEDIATOR ANY POWER TO
ACT OTHER THAN AN ARBITRATOR AS DESCRIBED HEREIN. SPECIFICALLY, THE
ARBITRATION LANGUAGE SHALL NOT EXTEND TO (a) PERFORMANCE UNDER THE
AGREEMENT OR ANY OF ITS PROVISIONS, (b) ENFORCEMENT UNDER THE
AGREEMENT, OR (c) ANY POST JUDGMENT ISSUES. THE PARTIES ACKNOWLEDGE
THAT THE MEDIATOR MAY HAVE RECEIVED CONFIDENTIAL INFORMATION
DURING THE COURSE OF THE MEDIATION AND HEREBY WAIVE ANY CONFLICT IN
THE MEDIATOR ACTING AS ARBITRATOR. EACH PARTY ADDITIONALLY WAIVES
ANY OBJECTION OR CONFLICT TO JAMES A. COOPER ACTING AS ARBITRATOR DUE
TO HIS BEING MEDIATOR IN THIS CASE.
AGREEMENTS
1 Atul Gupta, hereinafter father and Vibha Jain, herein after mother appeared with counsel
and agreed as follows;
2. The parties agree that Amy Galpin will act as the child's therapist during the pendency of
DocuSign Envelope ID: 72E13CC0-4A01-4F 86-87DE-6BEFDC26E19F
this litigation. It is agreed that the child will attend at least three sessions and additional
sessions as recommended by the therapist. The mother shall be responsible for 100% of
the costs of the therapy until further order of the court. The parent in possession of the
child at the time of the scheduled appointment shall exercise diligence in scheduling and
getting the child to and from the appointments for therapy.
Mother and father agree to follow any and all recommendations of the therapist pending
further order of the court including but not limited to scheduling and treatment plans.
The father agrees to turn over the child's passport to the mother on or before Friday
December 16th 2022 at 6:00 PM.
The mother agrees not to turn the child's cell phone off during her periods of possession.
The parents shall follow the current Court order as it relates to electronic communication.
However, except in case of emergency, the father will not call the child more than once at
3:00 PM each day.
Signed this the 12‘ day of December 2022
(A
DocuSigned by: Docusigned by:
Viblua Sain.
-238ADB180B4743A.
“ATUL GUPTA HA JAIN
DocuSigned by: Docusigned by:
Koval
(. Muller Chuistive Thrash
9120744307384D0. F61FD1DOA39C4E;
INALD C. MULLER CHRISTINE R. THRASH
(s
DocuSigned by: DocuSigned by:
James Coopur
DeeTIDACcAN1479,
STACY MCCARTTY - AMICUS [ES A. COOPER - MEDIATOR
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.
James Cooper on behalf of James Cooper
Bar No. 793548
jcooper@jcoopermediation.com
Envelope ID: 71060322
Status as of 12/15/2022 4:14 PM CST
Associated Case Party: AtulKumarGupta
Name BarNumber | Email TimestampSubmitted Status
Atul KumarGupta atoolkg@gmail.com 12/15/2022 3:14:04 PM SENT
Ronald C.Muller muller@rsmlegalteam.com 12/15/2022 3:14:04 PM SENT
Jessica Brown jbrown@rsmlegalteam.com 12/15/2022 3:14:04 PM SENT
Associated Case Party: Vibha Jain
Name BarNumber Email TimestampSubmitted | Status
Christine R.Thrash christinethrash@sbcglobal.net 12/15/2022 3:14:04 PM | SENT
Christine Thrash paralegal@thrashlawtexas.com 12/15/2022 3:14:04 PM | SENT
Associated Case Party: Vihan Gupta
Name BarNumber Email TimestampSubmitted | Status
Stacy SchnitzerMcCarty stacymccarty@ymail.com 12/15/2022 3:14:04 PM | SENT
Associated Case Party: Attorney General of Texas
Name BarNumber Email TimestampSubmitted | Status
Stephanie Truong | 24070451 CSD-legal-1003@oag.texas.gov | 12/15/2022 3:14:04 PM | SENT
Case Contacts
Name BarNumber Email TimestampSubmitted | Status
Ronald C. Muller 14649100 muller@rsmlegalteam.com 12/15/2022 3:14:04 PM | SENT
Leena Khaterpal Bhasin | 24029155 leenabhasinlawoffice@gmail.com 12/15/2022 3:14:04 PM | ERROR
Document Filed Date
December 15, 2022
Case Filing Date
May 27, 2016
Category
Divorce - With Children
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DocuSign Envelope ID: 72E13CC0-4A01-4F86-87DE-6BEFDC26E19F Filed 12/15/2022 3:14 PM Beverley McGrew Walker District Clerk Fort Bend County, Texas Kiara Fears CAUSE NO. 16-DCV-232757 IN THE INTERESTS OF IN THE DISTRICT COURT a A CHILD 328'" JUDICIAL DISTRICT FORT BEND COUNTY, TEXAS PARTIAL MEDIATED SETTLEMENT AGREEMENT The undersigned parties herewith agree to compromise and settle the claims and controversies between them to include only the issues as specifically set forth in this agreement. All other issues shall be reserved for future disposition. The parties wish to avoid potentially protracted and costly litigation and agree and stipulate that they have carefully considered the needs of the child, their respective ability and contribution other than in cash, for support, and the best interest of the child. THE PARTIES ALSO AGREE THAT THIS MEDIATION AGREEMENT IS BINDING ON BOTH OF THEM AND IS NOT SUBJECT TO REVOCATION BY EITHER OF THEM. EACH PARTY IS ENTITLED TO JUDGMENT ON THIS AGREEMENT. ANY DISPUTES ARISING FROM (a) THE DRAFTING OF THE ORDER OR ANCILLARY DOCUMENTS WHICH CANNOT BE RESOLVED BY MEDIATION, SHALL BE DECIDED BY BINDING ARBITRATION WITH JAMES A. COOPER SERVING AS BINDING ARBITRATOR. NOTHING IN THIS PROVISION GIVES THE MEDIATOR ANY POWER TO ACT OTHER THAN AN ARBITRATOR AS DESCRIBED HEREIN. SPECIFICALLY, THE ARBITRATION LANGUAGE SHALL NOT EXTEND TO (a) PERFORMANCE UNDER THE AGREEMENT OR ANY OF ITS PROVISIONS, (b) ENFORCEMENT UNDER THE AGREEMENT, OR (c) ANY POST JUDGMENT ISSUES. THE PARTIES ACKNOWLEDGE THAT THE MEDIATOR MAY HAVE RECEIVED CONFIDENTIAL INFORMATION DURING THE COURSE OF THE MEDIATION AND HEREBY WAIVE ANY CONFLICT IN THE MEDIATOR ACTING AS ARBITRATOR. EACH PARTY ADDITIONALLY WAIVES ANY OBJECTION OR CONFLICT TO JAMES A. COOPER ACTING AS ARBITRATOR DUE TO HIS BEING MEDIATOR IN THIS CASE. AGREEMENTS 1 Atul Gupta, hereinafter father and Vibha Jain, herein after mother appeared with counsel and agreed as follows; 2. The parties agree that Amy Galpin will act as the child's therapist during the pendency of DocuSign Envelope ID: 72E13CC0-4A01-4F 86-87DE-6BEFDC26E19F this litigation. It is agreed that the child will attend at least three sessions and additional sessions as recommended by the therapist. The mother shall be responsible for 100% of the costs of the therapy until further order of the court. The parent in possession of the child at the time of the scheduled appointment shall exercise diligence in scheduling and getting the child to and from the appointments for therapy. Mother and father agree to follow any and all recommendations of the therapist pending further order of the court including but not limited to scheduling and treatment plans. The father agrees to turn over the child's passport to the mother on or before Friday December 16th 2022 at 6:00 PM. The mother agrees not to turn the child's cell phone off during her periods of possession. The parents shall follow the current Court order as it relates to electronic communication. However, except in case of emergency, the father will not call the child more than once at 3:00 PM each day. Signed this the 12‘ day of December 2022 (A DocuSigned by: Docusigned by: Viblua Sain. -238ADB180B4743A. “ATUL GUPTA HA JAIN DocuSigned by: Docusigned by: Koval (. Muller Chuistive Thrash 9120744307384D0. F61FD1DOA39C4E; INALD C. MULLER CHRISTINE R. THRASH (s DocuSigned by: DocuSigned by: James Coopur DeeTIDACcAN1479, STACY MCCARTTY - AMICUS [ES A. COOPER - MEDIATOR 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. James Cooper on behalf of James Cooper Bar No. 793548 jcooper@jcoopermediation.com Envelope ID: 71060322 Status as of 12/15/2022 4:14 PM CST Associated Case Party: AtulKumarGupta Name BarNumber | Email TimestampSubmitted Status Atul KumarGupta atoolkg@gmail.com 12/15/2022 3:14:04 PM SENT Ronald C.Muller muller@rsmlegalteam.com 12/15/2022 3:14:04 PM SENT Jessica Brown jbrown@rsmlegalteam.com 12/15/2022 3:14:04 PM SENT Associated Case Party: Vibha Jain Name BarNumber Email TimestampSubmitted | Status Christine R.Thrash christinethrash@sbcglobal.net 12/15/2022 3:14:04 PM | SENT Christine Thrash paralegal@thrashlawtexas.com 12/15/2022 3:14:04 PM | SENT Associated Case Party: Vihan Gupta Name BarNumber Email TimestampSubmitted | Status Stacy SchnitzerMcCarty stacymccarty@ymail.com 12/15/2022 3:14:04 PM | SENT Associated Case Party: Attorney General of Texas Name BarNumber Email TimestampSubmitted | Status Stephanie Truong | 24070451 CSD-legal-1003@oag.texas.gov | 12/15/2022 3:14:04 PM | SENT Case Contacts Name BarNumber Email TimestampSubmitted | Status Ronald C. Muller 14649100 muller@rsmlegalteam.com 12/15/2022 3:14:04 PM | SENT Leena Khaterpal Bhasin | 24029155 leenabhasinlawoffice@gmail.com 12/15/2022 3:14:04 PM | ERROR