Stipulation,Agreement: BATES, RITA vs. CENTERPOINT ENERGY INC

• 
• 
• 
• 
• 
• 
• 
• 

						
                                
Preview
                                5
                                        CAUSE NO. 2007-13570

RITA BATES                                             §        IN THE DISTRICT COURT, oF)
VS.                                                    §        HARRIS COUNTY TEXAS 3G

CENTERPOINT ENERGY,             INC.                   §        334™ JUDICIAL DISTRICT                     9
                                                                                                         ZAy       \
                                                                                                                   G
                    AGREED MOTION TO DISMISS WITH PREJUDICE                                              2          eo
                                                                                                          ?
TO THE HONORABLE JUDGE OF THIS COURT:

        1        Come    now,    Plaintiff   and   Defendant,     CENTERPOINT       ENERGY,      INC.,

(“CENTERPOINT”) by and through their attorneys of record, seeking full and final dismissal of the

above-referenced cause of action, with prejudice, for the reason that Plaintiff and Centerpoint

have finally and fully settled and compromised         this suit and controversy for the valuable

consideration.

        22,      Plaintiff no longer desires to pursue her claims and causes of action against

Centerpoint and request that the court enter an order dismissing Plaintiffs claims against

Centerpoint, with prejudice to Plaintiff's right to re-file same or any part thereof.

        3        Wherefore, the Plaintiff and Centerpoint pray that the court enter and order

dismissing Plaintiffs claims, with prejudice to her right to re-file same or any part thereof.
Respectfully Submitted


                                   DONATO,             MINX & BROWN,         P.C.


                                         =   z
                                   RANDY DONAT!
                                   TBN:     05973300
                                   MARK R. PICKERING
                                   TBN: 00795591
                                   Southern District [D: 20963
                                   3200 Southwest Freeway, Ste. 2300
                                   Houston, TX 77027
                                   Telephone:     (713) 877-1112
                                   Facsimile      (713) 877-1138

                                   ATTORNEYS FOR DEFENDANT
                                   CENTERPOINT ENERGY RESOURCES CORP



                                                            &
                                               STI
                                             794178
                                   1001 west Baker Road, Suite 201
                                   Baytown, Texas 77521
                                   Telephone        281-422-2220
                                   Facsimile        281-427-1570

                                   ATTORNEY FOR PLAINTIFF


                               CERTIFICATE OF SERVICE


       I hereby certify that a true and correct copy of the foregoing Agreed Motion to Dismiss
With Prejudice and Order Dismissing All Claims with Prejudice was served on all counsel of
record by the method described below on thisfo           day of   Jud.                          > 2008.
                                                                             *
                                                                                     az   fo»    a
                                                                         ’       a

                                                                  MARK R. PICKERIN




Dismissal With Prejudice
                                          Page No. 2
DONATO, MINX & BROWN, P.C.
                                        ATTORNEYS AT LAW
                                  3200 Southwest Freeway, Suite 2300
                                         Houston, Texas 77027
                                      www.donatominxbrown.com



                                                                                                         \
Telephone: (713) 877-1112                                                    Facsimile: (713)   877-11
                                                                                                a
                                             July 14, 2008                            ~
                                                                                                oO
                                                                                                 =


Via Hand Delivery
Theresa Chang
Harris County District Clerk
201 Caroline
Houston, TX 77002

       RE:    Cause No.; 2007-13570; Rita Bates v. CenterPoint Energy inc. In 334" Judicial
              District Court of Harris County, Texas

Dear Ms. Chang:

       Enclosed please find an original and one copy of the following:

       (1)    Agreed Motion to Dismiss with Prejudice with proposed Order.

       Please file the original into the record and return a file stamped            copy to me      in the
enclosed self-addressed, postage prepaid envelope.

       Thank you for your assistance in this matter.

                                                             Sincerely,

                                                             DONATO, MINX & BROWN, PC.



                                                             Sharron White
                                                             Legal Assistant to Mark R. Pickering

MRP/sw
Enclosures




                                                    I
                               INTERNATIONAL SOCIETY OF PRIMERUS LAW FIRMS
Theresa Chang
July 14, 2008
Page 2


Cc:    Via Facsimile 281-427-1570
       Nicholas Dane Listi
       1001 West Baker Road, Suite 201
       Baytown, Texas 77521
APPROVED            AS TO FORM AND CONTENT:

DONATO, MINX & BROWN, P.C.
                         no


RANDY        DONATO
TBN: 05973300
MARK R. PICKERING
TBN: 00795591
Southern District ID: 20963
3200 Southwest Freeway, Ste. 2300
Houston, TX 77027
Telephone:      (713) 877-1112
Facsimile:      (713) 877-1138

ATTORNEYS FOR DEFENDANT
CENTERPOINT ENERGY RESOURCES CORP




  ANE LIBTI
T         94178
1001 west Baker Road, Suite 201
Baytown, Texas 77521
Telephone:           281-422-2220
Facsimile:           281-427-1570

ATTORNEY             FOR PLAINTIFF




Order of Dismissal With Prejudice
                                       Page No, 2