Motion,Ex Parte: NEW STREAM REAL ESTATE LLC (FORMERLY KNOWN AS CHARTER OAK REAL ESTATE vs. MORGAN, FRED

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                                CAUSE NO. 20     -81721

NEW STREAM REAL ESTATE,                         IN THE DISTRICT COURT OF
LLC, f/k/a CHARTER OAK REAL
ESTATE FUND, LLC,
  Plaintiff,

                                                HARRIS COUNTY, TEXAS

FRED MORGAN,
DAVID HENDRICKS, and
JAMES CHARNQUIST,                               190TH JUDICIAL DISTRICT
Defendants.


             DEFENDANT JAMES CHARNQUIST’S
      UNOPPOSED MOTION TO DISMISS WITH PREJUDICE


      Pursuant the Settlement Agreement            between the parties before this

ppellant    James       Charnquist                    to   dismiss   this   action   with

prejudice and would show the Court:

      ()       On  December 28, 2009, judgment plaintiff New Stream Real
               ate   , LLC filed its Notice of Filing Foreign Judgment against
               Fred Morgan, David Hendricks, and James Charnqu          in this
               Court.

      (2)      On November 28, 2019,                    entered an order severing
               the clais against judgment         defenda      Fred Morgan into
               No. 2009       81721 -A.

      3)       On   June    11, 2019, David Hendricks filed a Notice           of Filing
                             Liens as to David Hendric in this Court.

      (4)                 10, 2020, James Charnquist filed a Notice of Filing
               Release of Liens as to James Charnquist.
Because New Stream has either released the underlying judgment

severed all judgment   defendants, James     Charnquist moves to dismiss this

acith prejudiceThis motion is unopposed.

          these reasons,   appellant James    Charnquist   moves this Court to

            action with prejudice

                                     Respectfully submitted,

                                      URFORD       ERRY

                                    /s/ Brent C. Perry

                                    Brent C. Perry
                                    Bar No.: 15799650
                                    Matt E. Parks
                                    State Bar No. 24083622
                                    909 FanninSt., Suite 2630
                                              Texas 7701
                                    Telephone: (713) 4   9790
                                    Facsimile: (713) 9937739
                                    bperry@burfordperry.com
                                    mparks@burfordperry.com
                                    Attorneys for James Charnquist
CERTIFICATE      OF CONFERNCE

       Chris DiFerrante, counsel for appell               ee New Stream
Real Estate, LLC about the merits of this motion,   and New Stream Real
Estate, LLC does not oppose this motion.

                                        /s/ Brent C. Perry

                                        Brent C. Perry




                     TIFICATE        OF SERVICE

          April 10, 2020 I served the foregoing document in accordance
with Tex. R. Civ. P. 21 and 21a on all counsel of record via the court’s
ing system and/or email.

         Ferrante
402 Ea       Str
Houston, Texas 77008
chris@cdflaw.com
Attorney for Plaintiff




                                        /s/ Brent

                                        Brent C. Perry