On June 28, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Kamal, Suhayb,
and
Jp Morgan Chase Bank,
V Room Automotive, Llc,
for OTHER (CIVIL)
in the District Court of Dallas County.
Preview
FILED
4/21/2023 11:38 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Debra Clark DEPUTY
CAUSE NO. DC-22-07187
SUHAYB KAMAL IN THE DISTRICT COURT
§§§§§§§§§§
Plaintiffi
V. 134m JUDICIAL DISTRICT
VROOM AUTOMOTIVE, LLC &
JPMORGAN CHASE BANK, N.A.
Defendants. DALLAS COUNTY, TEXAS
AGREED JOINT MOTION TO LIFT STAY AND TO DISMISS
Plaintiff and Defendants jointly move the Court to lift the stay, imposed by the Court on
April 5, 2023, in connection with compelling the case to arbitration, and to dismiss this lawsuit
with prejudice. The parties have reached an agreement to settle all matters in controversy
between them. The parties shall each bear their own costs incurred in connection with this suit.
Wherefore, the parties pray that this Court grant this Motion to lift the stay and to dismiss
this lawsuit and the claims in it with prejudice.
JAFFER & ASSOCIATES PLLC
Shawn Jaffer
State Bar No.: 24107817
Allen Robertson
State Bar No.: 24076655
Robert Leach
State Bar No.2 24103582
5757 Alpha Rd. Ste. 430
Dallas, Texas 75240
Phone: (214) 494-1871
Fax: (888) 530-3910
Email: attorneys@jaffer.law
ATTORNEYS FOR PLAINTIFF
AND
THOMPSON, COE, COUSINS & IRONS, L.L.P.
/s/ John W. Chambless II (with permission)
John W. Chambless II
State Bar No. 00796334
2801 Via Fortuna, Suite 300
Austin, Texas 78746
(512) 703-5073
(512) 708-8777 (fax)
@ambless@thompsoncoe.com
ATTORNEY FOR DEFENDANTS
CERTIFICATE OF SERVICE
I hereby certify that on this 21“ day April 2023, a copy of the foregoing was sent to all
parties of record through the electronic filing system.
/s/ Shawn Jaffer
Shawn Jaffer
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.
Shawn Jaffer
Bar No. 24107817
attorneys@jaffer.law
Envelope ID: 74892577
Filing Code Description: Motion - Miscellanous
Filing Description: AGREED JOINT MTN TO LIFT STAY AND TO
DISMISS
Status as of 4/21/2023 2:08 PM CST
Associated Case Party: SUHAYB KAMAL
Name BarNumber Email TimestampSubmitted Status
SHAWN JAFFER attorneys@jaffer.law 4/21/2023 11:38:14 AM SENT
Associated Case Party: V ROOM AUTOMOTIVE, LLC
Name BarNumber Email TimestampSubmitted Status
John Chambless jchambless@thompsoncoe.com 4/21/2023 11:38:14 AM SENT
Trudy Rush trush@thompsoncoe.com 4/21/2023 11:38:14 AM SENT
Kimberly Koletar kkoletar@thompsoncoe.com 4/21/2023 11:38:14 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Francine Ly fly@da||ascourts.org 4/21/2023 11:38:14 AM SENT
Document Filed Date
April 21, 2023
Case Filing Date
June 28, 2022
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FILED 4/21/2023 11:38 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Debra Clark DEPUTY CAUSE NO. DC-22-07187 SUHAYB KAMAL IN THE DISTRICT COURT §§§§§§§§§§ Plaintiffi V. 134m JUDICIAL DISTRICT VROOM AUTOMOTIVE, LLC & JPMORGAN CHASE BANK, N.A. Defendants. DALLAS COUNTY, TEXAS AGREED JOINT MOTION TO LIFT STAY AND TO DISMISS Plaintiff and Defendants jointly move the Court to lift the stay, imposed by the Court on April 5, 2023, in connection with compelling the case to arbitration, and to dismiss this lawsuit with prejudice. The parties have reached an agreement to settle all matters in controversy between them. The parties shall each bear their own costs incurred in connection with this suit. Wherefore, the parties pray that this Court grant this Motion to lift the stay and to dismiss this lawsuit and the claims in it with prejudice. JAFFER & ASSOCIATES PLLC Shawn Jaffer State Bar No.: 24107817 Allen Robertson State Bar No.: 24076655 Robert Leach State Bar No.2 24103582 5757 Alpha Rd. Ste. 430 Dallas, Texas 75240 Phone: (214) 494-1871 Fax: (888) 530-3910 Email: attorneys@jaffer.law ATTORNEYS FOR PLAINTIFF AND THOMPSON, COE, COUSINS & IRONS, L.L.P. /s/ John W. Chambless II (with permission) John W. Chambless II State Bar No. 00796334 2801 Via Fortuna, Suite 300 Austin, Texas 78746 (512) 703-5073 (512) 708-8777 (fax) @ambless@thompsoncoe.com ATTORNEY FOR DEFENDANTS CERTIFICATE OF SERVICE I hereby certify that on this 21“ day April 2023, a copy of the foregoing was sent to all parties of record through the electronic filing system. /s/ Shawn Jaffer Shawn Jaffer 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. Shawn Jaffer Bar No. 24107817 attorneys@jaffer.law Envelope ID: 74892577 Filing Code Description: Motion - Miscellanous Filing Description: AGREED JOINT MTN TO LIFT STAY AND TO DISMISS Status as of 4/21/2023 2:08 PM CST Associated Case Party: SUHAYB KAMAL Name BarNumber Email TimestampSubmitted Status SHAWN JAFFER attorneys@jaffer.law 4/21/2023 11:38:14 AM SENT Associated Case Party: V ROOM AUTOMOTIVE, LLC Name BarNumber Email TimestampSubmitted Status John Chambless jchambless@thompsoncoe.com 4/21/2023 11:38:14 AM SENT Trudy Rush trush@thompsoncoe.com 4/21/2023 11:38:14 AM SENT Kimberly Koletar kkoletar@thompsoncoe.com 4/21/2023 11:38:14 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Francine Ly fly@da||ascourts.org 4/21/2023 11:38:14 AM SENT