On September 11, 2017 a
Rule 11 agreement
was filed
involving a dispute between
Derama Services Llc,
and
Alshakhshir, Oday,
Enovya International Inc (Individually And Doing Business As Texas,
Texas Auto Spot,
for PERSONAL INJ (NON-AUTO)
in the District Court of Harris County.
Preview
NO. 2017-59258 & 2017-59258-A
DERAMA SERVICES LLC * IN THE DISTRICT COURT OF
VS.
* HARRIS COUNTY, TEXAS
ENOVYA INTERNATIONAL INC.,
INDIVIDUALLY AND DOING
BUSINESS AS TEXAS AUTO SPOT,
AND ODAY ALSHAKHSHIR . 281ST JUDICIAL DISTRICT
RULE 11 AGREEMENT
This binding agreement pursuant to Rule 11, Texas Rules of Civil Procedure, is
between the Plaintiff, DERAMA SERVICES LLC (hereinafter referred to as
DERAMA), and Defendanis, ENOVYA INTERNATIONAL INC., INDIVIDUALLY AND
DOING BUSINESS AS TEXAS AUTO SPOT (hereinafier referred to as ENOVYA) and
ODAY ALSHAKHSHIR {hereinafter referred to as ODAY) and is intended to settle
the above-referenced causes of action. In connection with this agreement,
ODAY represents that he is the sole owner of ENOVYA.
The parties agree to settle the above-referenced lawsuit as follows:
Is
ODAY agrees to pay DERAMA $65,000, as follows: $10,000 on or before
June 1, 2019; and thereafter 55 insiallmenis of $1,000 per month on or
before thelst of each month, with the first installment of $1,000 being due
on or before July 1, 2019;
ODAY and ENOVYA will consent to the entry of judgment against them
and in favor of DERAMA in ihe amount of $75,000 such that ODAY and
ENOVYA are jointly and severally liable to DERAMA with respect to said
judgment, as security for the payment of the setilement amount of
$65,000. In the event ODAY defaults on a payment, he will be given two
notices of default with the opportunity to cure within 10 days, buf such a
default will not be permitied more than twice per year. ODAY and
ENOVYA agree noi to appeal said conseni judgment and not bring any
motion atiacking said judgment, including motion for new trial. DERAMA
agrees not fo execute or abstract on said consent judgment provided
ODAY and ENOVYA timely make the payments to DERAMA as set forth
herein. DERAMA agrees to release the $75,000 consent judgment fully
and finally paid once the entire balance is paid in full;
ap by~3. The paymenis set forth herein shall be made to DEREMA SERVICES LLC
by direct deposit to a bank of DERAMA's choosing.
SIGNED on the _[© __ day of March 2019.
/ THOMAS. SWANSO
( ie Bar No. 19555900
‘s--" 1302 Waugh Drive, PMB 383
Houston, Texas 77019
Telephone: (713) 529-2778
Facsimile: (855) 422-4466
E-Mail: velvaS3@hotmail.com
ATTORNEY FOR PLAINTIFF,
DERAMA SERVICES. INC.
DERAMA SERVICES LLC
Dench Yousef ¢
(- fy DYJ. Nathan Overstreet & Assoc., P.C.
James Nathan Overstreet, 3 784706
8714 Hwy 6 North, Suite 230
Housion, Texas 77095
(281) 655-1000; Fax (281) 855-4580
oversirsetlawfirm @ amail .com
Attorney for Defendants, Enovya
International Inc. d/b/a Texas Auto Spot
and Oday Alshakhshir
ENOVYA INTERNATIONAL INC.,
INDIVIDUALLY AND DOING BUSINEESS AS
TEXAS AUTO SPOT
<—ODAY ALSHAKASHIR
a
-GOAY AISHAKBSHIR IndividuallyCERTIFICATE OF SERVICE
| hereby certify that a true and correct copy of the foregoing was sent by
FAX to 281-855-4580 and certified mail, return receipt requested on March 14,
2019, to counsel of record for Defendants, as follows:
James Nathan Overstreet
8711 Highway 6, North, Suite #230
Houston, Texas 77095
Document Filed Date
March 14, 2019
Case Filing Date
September 11, 2017
Category
PERSONAL INJ (NON-AUTO)
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NO. 2017-59258 & 2017-59258-A DERAMA SERVICES LLC * IN THE DISTRICT COURT OF VS. * HARRIS COUNTY, TEXAS ENOVYA INTERNATIONAL INC., INDIVIDUALLY AND DOING BUSINESS AS TEXAS AUTO SPOT, AND ODAY ALSHAKHSHIR . 281ST JUDICIAL DISTRICT RULE 11 AGREEMENT This binding agreement pursuant to Rule 11, Texas Rules of Civil Procedure, is between the Plaintiff, DERAMA SERVICES LLC (hereinafter referred to as DERAMA), and Defendanis, ENOVYA INTERNATIONAL INC., INDIVIDUALLY AND DOING BUSINESS AS TEXAS AUTO SPOT (hereinafier referred to as ENOVYA) and ODAY ALSHAKHSHIR {hereinafter referred to as ODAY) and is intended to settle the above-referenced causes of action. In connection with this agreement, ODAY represents that he is the sole owner of ENOVYA. The parties agree to settle the above-referenced lawsuit as follows: Is ODAY agrees to pay DERAMA $65,000, as follows: $10,000 on or before June 1, 2019; and thereafter 55 insiallmenis of $1,000 per month on or before thelst of each month, with the first installment of $1,000 being due on or before July 1, 2019; ODAY and ENOVYA will consent to the entry of judgment against them and in favor of DERAMA in ihe amount of $75,000 such that ODAY and ENOVYA are jointly and severally liable to DERAMA with respect to said judgment, as security for the payment of the setilement amount of $65,000. In the event ODAY defaults on a payment, he will be given two notices of default with the opportunity to cure within 10 days, buf such a default will not be permitied more than twice per year. ODAY and ENOVYA agree noi to appeal said conseni judgment and not bring any motion atiacking said judgment, including motion for new trial. DERAMA agrees not fo execute or abstract on said consent judgment provided ODAY and ENOVYA timely make the payments to DERAMA as set forth herein. DERAMA agrees to release the $75,000 consent judgment fully and finally paid once the entire balance is paid in full; ap by~3. The paymenis set forth herein shall be made to DEREMA SERVICES LLC by direct deposit to a bank of DERAMA's choosing. SIGNED on the _[© __ day of March 2019. / THOMAS. SWANSO ( ie Bar No. 19555900 ‘s--" 1302 Waugh Drive, PMB 383 Houston, Texas 77019 Telephone: (713) 529-2778 Facsimile: (855) 422-4466 E-Mail: velvaS3@hotmail.com ATTORNEY FOR PLAINTIFF, DERAMA SERVICES. INC. DERAMA SERVICES LLC Dench Yousef ¢ (- fy DYJ. Nathan Overstreet & Assoc., P.C. James Nathan Overstreet, 3 784706 8714 Hwy 6 North, Suite 230 Housion, Texas 77095 (281) 655-1000; Fax (281) 855-4580 oversirsetlawfirm @ amail .com Attorney for Defendants, Enovya International Inc. d/b/a Texas Auto Spot and Oday Alshakhshir ENOVYA INTERNATIONAL INC., INDIVIDUALLY AND DOING BUSINEESS AS TEXAS AUTO SPOT <—ODAY ALSHAKASHIR a -GOAY AISHAKBSHIR IndividuallyCERTIFICATE OF SERVICE | hereby certify that a true and correct copy of the foregoing was sent by FAX to 281-855-4580 and certified mail, return receipt requested on March 14, 2019, to counsel of record for Defendants, as follows: James Nathan Overstreet 8711 Highway 6, North, Suite #230 Houston, Texas 77095