On March 26, 2021 a
Stipulation,Agreement
was filed
involving a dispute between
Kim, Chong,
Kim, Jai,
Kim, Thai S.,
and
Berrett Pest Control,
Berrett Pest Control Corporate,
Berrett Pest Control Services, Inc,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
12/28/2022 10:30 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Margaret Thomas DEPUTY
CAUSE NO. DC-21-04007
Chong Kim and Iai Kim §
§ In the District Court of
v. §
§ Dallas County, Texas
Berrett Pest Control Corporate, Inc. §
Berrett Pest Control Services, Inc. § 162ml Judicial District Court
Agreed Motion to Dismiss with Prejudice
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW, Plaintiffs Chong Kim and Iai Kim, and Defendants Berrett Pest
Control Corporate, Inc. and Berrett Pest Control Services, Inc., and file this their Agreed
Motion to Dismiss with Prejudice, and would show the Court that all matters in
controversy and dispute between Plaintiffs and Defendants have been compromised and
settled, and that Plaintiffs’ action against these Defendants should be dismissed with
prejudice to the refiling of same.
WHEREFORE, PREMESIS CONSIDERED, Plaintiffs and Defendants pray that this
Agreed Motion to Dismiss with Prejudice be granted, that Court costs be taxed against
the Party incurring same, that Plaintiffs’ claims against Defendants in this cause be
dismissed with prejudice to the refiling of same, and for such and further relief to which
they may show themselves to be justly entitled.
AGREED MOTION T0 DISMISS WITH PREJUDICE PAGE 1
Respectfully submitted,
Touchstone, Bernays, Johnston,
Beall, Smith 8: Stollenwerck, LLP
By: /s/ Andrew T. Fifield
Andrew T. Fifield — SBN: 06982500
1717 Main Street, Suite 3400
Dallas, Texas 75201
214-741-1166
214-741-7548 (fax)
andrew.fifield@tbibs.com
Attorneys for Defendant Berrett Pest Control
Corporate, Inc. and Berrett Pest Control
Services, Inc.
/s/ Leon R. Kassab (w/permission)
Leon R. Kassab — 24095164
The Benton Law Firm
1825 Market Center Blvd., Ste. 350
Dallas, Texas 75207
Leon@jeffbenton.com
Telephone: (214) 777-7777
Facsimile: (214) 615-2950
Attorney for Plaintiffs Chong Kim
and Jai Kim
CERTIFICATE OF SERVICE
This is to certify that on the 28th day of December, 2022, a true and correct copy of the
foregoing document has been served to all counsel of record pursuant to Rule 21a of the
Texas Rules of Civil Procedure:
/s/ Andrew T. Fifleld
Andrew T. Fifield
AGREED MOTION T0 DISMIss WITH PREJUDICE PAGE 2
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.
Ashleigh Murphy on behalf of Andrew Fifield
Bar No. 6982500
ashleigh.greer@tbjbs.com
Envelope ID: 71318481
Status as of 12/28/2022 11:50 AM CST
Associated Case Party: BERRE'I'I' PEST CONTROL CORPORATE
Name BarNumber Email Timestam pSubmitted Status
Andrew T.Fifie|d andrew.fifield@tbjbs.com 12/28/2022 10:30:39 AM SENT
Tanner Wilson tanner.wilson@tbjbs.com 12/28/2022 10:30:39 AM SENT
Associated Case Party: CHONG KIM
Name BarNumber Email TimestampSubmitted Status
Jeff Benton service@thebentonlawfirm.com 12/28/2022 10:30:39 AM SENT
Leon Kassab leon@jeffbenton.com 12/28/2022 10:30:39 AM SENT
Gina Marino gina@jeffbenton.com 12/28/2022 10:30:39 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Thai Kim tkim@kimlawllc.com 12/28/2022 10:30:39 AM SENT
Ashleigh Greer ashleigh.greer@tbjbs.com 12/28/2022 10:30:39 AM SENT
Clarissa Anderson Clarissa.anderson@tbjbs.com 12/28/2022 10:30:39 AM SENT
Document Filed Date
December 28, 2022
Case Filing Date
March 26, 2021
Category
MOTOR VEHICLE ACCIDENT
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FILED 12/28/2022 10:30 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Margaret Thomas DEPUTY CAUSE NO. DC-21-04007 Chong Kim and Iai Kim § § In the District Court of v. § § Dallas County, Texas Berrett Pest Control Corporate, Inc. § Berrett Pest Control Services, Inc. § 162ml Judicial District Court Agreed Motion to Dismiss with Prejudice TO THE HONORABLE JUDGE OF SAID COURT: COME NOW, Plaintiffs Chong Kim and Iai Kim, and Defendants Berrett Pest Control Corporate, Inc. and Berrett Pest Control Services, Inc., and file this their Agreed Motion to Dismiss with Prejudice, and would show the Court that all matters in controversy and dispute between Plaintiffs and Defendants have been compromised and settled, and that Plaintiffs’ action against these Defendants should be dismissed with prejudice to the refiling of same. WHEREFORE, PREMESIS CONSIDERED, Plaintiffs and Defendants pray that this Agreed Motion to Dismiss with Prejudice be granted, that Court costs be taxed against the Party incurring same, that Plaintiffs’ claims against Defendants in this cause be dismissed with prejudice to the refiling of same, and for such and further relief to which they may show themselves to be justly entitled. AGREED MOTION T0 DISMISS WITH PREJUDICE PAGE 1 Respectfully submitted, Touchstone, Bernays, Johnston, Beall, Smith 8: Stollenwerck, LLP By: /s/ Andrew T. Fifield Andrew T. Fifield — SBN: 06982500 1717 Main Street, Suite 3400 Dallas, Texas 75201 214-741-1166 214-741-7548 (fax) andrew.fifield@tbibs.com Attorneys for Defendant Berrett Pest Control Corporate, Inc. and Berrett Pest Control Services, Inc. /s/ Leon R. Kassab (w/permission) Leon R. Kassab — 24095164 The Benton Law Firm 1825 Market Center Blvd., Ste. 350 Dallas, Texas 75207 Leon@jeffbenton.com Telephone: (214) 777-7777 Facsimile: (214) 615-2950 Attorney for Plaintiffs Chong Kim and Jai Kim CERTIFICATE OF SERVICE This is to certify that on the 28th day of December, 2022, a true and correct copy of the foregoing document has been served to all counsel of record pursuant to Rule 21a of the Texas Rules of Civil Procedure: /s/ Andrew T. Fifleld Andrew T. Fifield AGREED MOTION T0 DISMIss WITH PREJUDICE PAGE 2 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. Ashleigh Murphy on behalf of Andrew Fifield Bar No. 6982500 ashleigh.greer@tbjbs.com Envelope ID: 71318481 Status as of 12/28/2022 11:50 AM CST Associated Case Party: BERRE'I'I' PEST CONTROL CORPORATE Name BarNumber Email Timestam pSubmitted Status Andrew T.Fifie|d andrew.fifield@tbjbs.com 12/28/2022 10:30:39 AM SENT Tanner Wilson tanner.wilson@tbjbs.com 12/28/2022 10:30:39 AM SENT Associated Case Party: CHONG KIM Name BarNumber Email TimestampSubmitted Status Jeff Benton service@thebentonlawfirm.com 12/28/2022 10:30:39 AM SENT Leon Kassab leon@jeffbenton.com 12/28/2022 10:30:39 AM SENT Gina Marino gina@jeffbenton.com 12/28/2022 10:30:39 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Thai Kim tkim@kimlawllc.com 12/28/2022 10:30:39 AM SENT Ashleigh Greer ashleigh.greer@tbjbs.com 12/28/2022 10:30:39 AM SENT Clarissa Anderson Clarissa.anderson@tbjbs.com 12/28/2022 10:30:39 AM SENT