Preview
FILED
10/10/2022 4:10 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
CAROLYN SELLERS DEPUTY
CAUSE NO. DC-l 8—18021
ANTHONY LOUIS MARTIN, IN THE DISTRICT COURT
§§§§§§§§§§§§§§§§§
Plaintiffi
V.
CORDIS CORPORATION, a Flon'da
Corporation; JOHNSON
& JOHNSON, a New Jersey Corporation; DALLAS COUNTY, TEXAS
CONFLUENT MEDICAL
TECHNOLOGIES, INC., a Delaware
Corporation; TIMOTHY C. PRINGLE,
M.D.; AND TIMOTHY C. PRINGLE,
M.D. P.A. d/b/a CORE VASCULAR
SERVICES
Defendants. 1 16TH JUDICIAL DISTRICT
AGREED MOTON TO DISMISS WITH PREJUDICE DEFENDANTS,
CARDINAL HEALTH, INC., CORDIS CORPORATION AND
CONFLUENT MEDICAL TECHNOLOGIES, INC.
Plaintiff, Anthony Louis Martin and Defendants, Cardinal Health, Inc., Cordis Corporation
and Confluent Medical Technologies Inc. (together “Defendants”), jointly move this Court to
dismiss Defendants with prejudice. In support of this Agreed Motion, the parties stated herein
respectfully shows the Court as follows:
Plaintiff and Defendants, Cardinal Health, Inc., Cordis Corporation and Confluent Medical
Technologies Inc., to this action have reached an agreement to settle all claims and causes of
action. Accordingly, Plaintiff and these Defendants hereby request that the Court enter an Agreed
Order of Dismissal dismissing all claims and causes of action of Plaintiff against Defendants,
Cardinal Health, Inc., Cordis Corporation and Confluent Medical Technologies Inc. with
prejudice.
WHEREFORE, PREMISES CONSIDERED, Plaintiff, Anthony Louis Martin and
AGREED MOTON TO DISMISS WITH PREJUDICE DEFENDANTS, CARDINAL HEALTH, INC.,
CORDIS CORPORATION AND CONFLUENT MEDICAL TECHNOLOGIES INC. Page 1 of 3
Defendants, Cardinal Health, Inc., Cordis Corporation and Confluent Medical Technologies Inc.,
requests this Court to sign an order dismissing all claims and causes of action with prejudice made
by Plaintiff, Anthony Louis Martin, and Defendants, Cardinal Health, Inc., Cordis Corporation
and Confluent Medical Technologies Inc., with each party to bear their own costs.
Respectfully submitted,
MARTIN BAUGHMAN
L, JZfléL/f
BEN C. MARTIN
State Bar No. 13052400
bmartin@bencmartin.com
THOMAS WM. ARBON
State Bar No. 01284275
tarbon@bencmartin.com
LAURA BAUGHMAN
State Bar No. 00791846
lbaughman@martinbaughman.com
3141 Hood Street Level 6
Dallas, Texas 76219
Tel: (214) 761-6614
Fax: (214) 744-7590
ATTORNEYS FOR PLAINTIFF
ANTHONY LOUIS MARTIN
and
THE KAROS LAW FIRM, PLLC
By
MARIA KATINA KAROS
The Karos Law Firm, PLLC
DEFENDANTS CARDINAL HEALTH, INC.’S, CORDIS CORPORATION’S, AND CONFLUENT
MEDICAL TECHNOLOGIES, INC.’S UNOPPOSED MOTION FOR
WITHDRAWAL OF APPEARANCE Page 2 of 3
5057 Keller Springs Rd.,
Ste. 400
Addison, Texas 75001
Tel.: 972-201-0494
Fax: 972-201-0098
maria@karostrial.com
and
CROWELL MORING
ANDREW D. KAPLAN
CLIFFORD J. ZATZ
Crowell Moring
1001 Pennsylvania Avenue NW
Washington, D.C. 20004-2595
Tel.: 202-624-2500
Fax: 202-628-51 16
akaplan@crowell.com
czatz@crowell.com
ATTORNEYS FOR DEFENDANTS
CORDIS CORPORATION,
CONFLUENT MEDICAL
TECHNOLOGIES, INC., and
CARDINAL HEALTH, INC.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing has been served on
all known counsel of record as authorized by the Texas Rules of Civil Procedure on the 10th day
of October, 2022.
in.
Thomas Wm. Arbon
DEFENDANTS CARDINAL HEALTH, INC.’S, CORDIS CORPORATION’S, AND CONFLUENT
MEDICAL TECHNOLOGIES, INC.’S UNOPPOSED MOTION FOR
WITHDRAWAL OF APPEARANCE Page 3 of 3
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.
Diana Martinez on behalf of Thomas Wm. Arbon
Bar No. 1284275
dmartinez@martinbaughman.com
Envelope ID: 69071764
Status as of 10/11/2022 9:27 AM CST
Associated Case Party: ANTHONYLOUISMARTIN
Name BarNumber Email TimestampSubmitted Status
Ben C.Martin bmartin@martinbaughman.com 10/10/2022 4:10:12 PM SENT
Thomas Wm.Arbon tarbon@martinbaughman.com 10/10/2022 4: 1 0:12 PM SENT
Matt Munson mmunson@martinbaughman.com 10/10/2022 4:10:12 PM SENT
Diana Martinez dmartinez@martinbaughman.com 10/10/2022 4:10:12 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.
Diana Martinez on behalf of Thomas Wrn. Arbon
Bar No. 1284275
dmartinez@martinbaughman.com
Envelope ID: 69071764
Status as of 10/11/2022 9:27 AM CST
Associated Case Party: CORDIS CORPORATION
Name BarNumber Email TimestampSubmitted Status
Laura Aradi |aradi@crowel|.com 10/10/2022 4:10:12 PM SENT
Maria KatinaKaros maria@karostrial.com 10/10/2022 4: 1 0:12 PM SENT
Clifford J.Zatz czatz@crowell.com 10/10/2022 4: 1 0:12 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.
Diana Martinez on behalf of Thomas Wrn. Arbon
Bar No. 1284275
dmartinez@martinbaughman.com
Envelope ID: 69071764
Status as of 10/11/2022 9:27 AM CST
Associated Case Party: TIMOTHYC.PRINGLE
Name BarNumber Email TimestampSubmitted Status
Charles B.Mitchell, Jr. service@thewillislawgroup.com 10/10/2022 4:10:12 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.
Diana Martinez on behalf of Thomas Wm. Arbon
Bar No. 1284275
dmartinez@martinbaughman.com
Envelope ID: 69071764
Status as of 10/11/2022 9:27 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Maria KatinaKaros maria@karostrial.com 10/10/2022 4:10:12 PM SENT
Ken Patterson kpatterson@hhdulaw.com 10/10/2022 4: 1 0:12 PM ERROR
Heather Kanny hkanny@hhdulaw.com 10/10/2022 4:10:12 PM ERROR
Linda Maloney service@thewillislawgroup.com 10/10/2022 4:10:12 PM SENT