On April 30, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Dallas County Hospital District,
and
Cherokee Insurance Company,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
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FILED
8/17/2020 2:22 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Martin Reyes DEPUTY
'
l\ II
Iv-artm Reyes
CAUSE N0. DC—19—06151
DALLAS COUNTY HOSPITAL IN THE DISTRICT COURT
DISTRICT d/b/a PARKLAND HEALTH
& HOSPITAL SYSTEM,
Plaintiff,
V. DALLAS COUNTY, TEXAS
CHEROKEE INSURANCE COMPANY
and COMERICA BANK
Defendants. 193m JUDICIAL DISTRICT
MOTION FOR NONSUIT AND DISMISSAL ONLY
AS TO DEFENDANT CHEROKEE INSURANCE COMPANY
TO THE HONORABLE IUDGE OF SAID COURT:
Plaintiff Dallas County Hospital District d/b/a Parkland Health & Hospital System
(“Parkland”) files this Motion for Nonsuit and Dismissal With prejudice, as t0 Defendant
Cherokee Insurance Company, and would respectfully show the Court as follows:
Parkland would request that an Order of Nonsuit and Dismissal, with prejudice, be
entered in the above-entitled and numbered cause as t0 Defendant Cherokee Insurance for the
reason that Plaintiff is no longer interested in pursuing any action against this Defendant.
Defendant Cherokee is the only remaining defendant in this matter.
WHEREFORE, PREMESIS CONSIDERED, Plaintiff Dallas County Hospital District
d/b/a Parkland Health & Hospital System prays that an Order 0f Nonsuit and Dismissal be
entered as between any actions which Plaintiff may have against Defendant Cherokee Insurance
with prejudice of Plaintiff t0 refile in the future.
Respectfully submitted,
THE TUREK LAW FIRM, PC
By: /s/Douglas Turek
Douglas Turek
State Bar N0. 00792882
dturek@tureklawfirm.com
Emily Marr
State Bar No. 24102595
emarr@tureklawfirm.com
9595 Six Pines Drive, Suite 8210
The Woodlands, Texas 77380
Telephone: (281) 296—6920
Telecopier: (281) 296-0733
ATTORNEYS FOR PLAINTIFF DALLAS
COUNTY HOSPITAL DISTRICT D/B/A
PARKLAND HEALTH & HOSPITAL
SYSTEM
CERTIFICATE OF SERVICE
hereby certify that a true and correct copy 0f the above was served 0n each attorney of
I
record 0r party in accordance With the Texas Rules 0f Civil Procedure on this 17th day 0f August,
2020.
P. Marcus White
WHITEHURST & CAWLEY, LLP
16300 Addison Road, Suite 100
Addison, Texas 75001
Via Electronic Filing
/s/Douglas Turek
Douglas Turek
Dszm
https://tureklawfirm.sharepoint.com/Shared Documents/TLF Operations/CLIENTS/HOSPITAL LITIGATION/PARKLAND.1032.00/GAYTAN.1032.139/xMtnNonsuit7Cherokee
(Parkland).001 .docx
August 13, 2020
AutomatedCertificate 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.
Patricia McCulloch on behalf of Douglas Turek
Bar No. 792882
pmcculloch@tureklawfirm.com
Envelope ID: 45440517
Status as of 8/17/2020 3:24 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Frank GCawIey fcawley@whitehurstlaw.com 8/17/2020 2:22:08 PM SENT
Patricia McCulloch pmcculloch@tureklawfirm.com 8/17/2020 2:22:08 PM SENT
Kathleen Corcoran kcorcoran@whitehurstlaw.com 8/17/2020 2:22:08 PM SENT
P. MarcusWhite mwhite@whitehurstlaw.com 8/17/2020 2:22:08 PM SENT
DOUGLAS TUREK dturek@tureklawfirm.com 8/17/2020 2:22:08 PM SENT
Rosalinda Pleitez rpleitez@whitehurstlaw.com 8/17/2020 2:22:08 PM SENT
Diana Martinez dmartinez@whitehurstlaw.com 8/17/2020 2:22:08 PM SENT
Document Filed Date
August 17, 2020
Case Filing Date
April 30, 2019
Category
CNTR CNSMR COM DEBT
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FILED 8/17/2020 2:22 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Martin Reyes DEPUTY ' l\ II Iv-artm Reyes CAUSE N0. DC—19—06151 DALLAS COUNTY HOSPITAL IN THE DISTRICT COURT DISTRICT d/b/a PARKLAND HEALTH & HOSPITAL SYSTEM, Plaintiff, V. DALLAS COUNTY, TEXAS CHEROKEE INSURANCE COMPANY and COMERICA BANK Defendants. 193m JUDICIAL DISTRICT MOTION FOR NONSUIT AND DISMISSAL ONLY AS TO DEFENDANT CHEROKEE INSURANCE COMPANY TO THE HONORABLE IUDGE OF SAID COURT: Plaintiff Dallas County Hospital District d/b/a Parkland Health & Hospital System (“Parkland”) files this Motion for Nonsuit and Dismissal With prejudice, as t0 Defendant Cherokee Insurance Company, and would respectfully show the Court as follows: Parkland would request that an Order of Nonsuit and Dismissal, with prejudice, be entered in the above-entitled and numbered cause as t0 Defendant Cherokee Insurance for the reason that Plaintiff is no longer interested in pursuing any action against this Defendant. Defendant Cherokee is the only remaining defendant in this matter. WHEREFORE, PREMESIS CONSIDERED, Plaintiff Dallas County Hospital District d/b/a Parkland Health & Hospital System prays that an Order 0f Nonsuit and Dismissal be entered as between any actions which Plaintiff may have against Defendant Cherokee Insurance with prejudice of Plaintiff t0 refile in the future. Respectfully submitted, THE TUREK LAW FIRM, PC By: /s/Douglas Turek Douglas Turek State Bar N0. 00792882 dturek@tureklawfirm.com Emily Marr State Bar No. 24102595 emarr@tureklawfirm.com 9595 Six Pines Drive, Suite 8210 The Woodlands, Texas 77380 Telephone: (281) 296—6920 Telecopier: (281) 296-0733 ATTORNEYS FOR PLAINTIFF DALLAS COUNTY HOSPITAL DISTRICT D/B/A PARKLAND HEALTH & HOSPITAL SYSTEM CERTIFICATE OF SERVICE hereby certify that a true and correct copy 0f the above was served 0n each attorney of I record 0r party in accordance With the Texas Rules 0f Civil Procedure on this 17th day 0f August, 2020. P. Marcus White WHITEHURST & CAWLEY, LLP 16300 Addison Road, Suite 100 Addison, Texas 75001 Via Electronic Filing /s/Douglas Turek Douglas Turek Dszm https://tureklawfirm.sharepoint.com/Shared Documents/TLF Operations/CLIENTS/HOSPITAL LITIGATION/PARKLAND.1032.00/GAYTAN.1032.139/xMtnNonsuit7Cherokee (Parkland).001 .docx August 13, 2020 AutomatedCertificate 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. Patricia McCulloch on behalf of Douglas Turek Bar No. 792882 pmcculloch@tureklawfirm.com Envelope ID: 45440517 Status as of 8/17/2020 3:24 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Frank GCawIey fcawley@whitehurstlaw.com 8/17/2020 2:22:08 PM SENT Patricia McCulloch pmcculloch@tureklawfirm.com 8/17/2020 2:22:08 PM SENT Kathleen Corcoran kcorcoran@whitehurstlaw.com 8/17/2020 2:22:08 PM SENT P. MarcusWhite mwhite@whitehurstlaw.com 8/17/2020 2:22:08 PM SENT DOUGLAS TUREK dturek@tureklawfirm.com 8/17/2020 2:22:08 PM SENT Rosalinda Pleitez rpleitez@whitehurstlaw.com 8/17/2020 2:22:08 PM SENT Diana Martinez dmartinez@whitehurstlaw.com 8/17/2020 2:22:08 PM SENT