On July 13, 2021 a
Complaint,Petition
was filed
involving a dispute between
Sanchez, Carlos,
and
Glaxosmithkline Llc,
for OTHER (CIVIL)
in the District Court of Dallas County.
Preview
FILED
7/13/2021 11:53 AM
FELICIA PITRE
DISTRICT CLERK
[NOTICE THI DOCUMENT DALLAS CO., TEXAS
CONTAINS SENSITIVE DATA] Christi Undenlvood DEPUTY
0021-09029
CAUSE NO.
CARLOS SANCHEZ, AS NEXT § IN THE DISTRICT COURT OF
FRIEND OF J .S., A MINOR, §
§
§
§
§
v. § DALLAS COUNTY, TEXAS
§ 298th
§
§
GLAXOSMITHKLINE, LLC § _ JUDICIAL DISTRICT
PLAINTIFF’S ORIGINAL PETITION FOR APPROVAL OF
SETTLEMENT OF CLAIMS
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES, Carlos Sanchez, as next fn'end of J.S., a minor, and files this, his Original
Petition for Approval of Settlement of Claims, and for such would show the Court as follows:
I.
Pursuant to Texas Rule of CiVil Procedure 210, the name of the Minor has been redacted
from this Petition and all documents and pleadings filed subsequently with this Court. An
unredacted copy of every document and pleading filed in this Court has been and will be retained
in accordance with Texas Rule of CiVil Procedure 210(c).
II.
Plaintiff is the natural father of the minor and is the minor’s guardian.
Defendant GlaxoSmithKline, LLC is a corporation conducting business Within the State of
Texas. Neither issuance of a citation nor service of process is necessary
PLAINTIFF’S ORIGINAL PETITION FOR APPROVAL 0F SETTLEMENT OF CLAIMS
Page 1 of 3
[NOTICE THIS DOCUMENT
CONTAINS SENSITIVE DATA]
III.
Plaintiff made product liability claims against Defendant that resulted in damages to the
minor.
IV.
After investigation of the matter, and negotiations between the Parties, they have entered
into a proposed compromise settlement agreement under which all claims of Plaintiff against
Defendant will be fully compromised and settled. Accordingly, this petition is being filed with
the Court for the sole purpose of concluding all of Plaintiff s claims so that Defendant will be fully
and finally released from all filrther claims and liability to Plaintiff as a result of the
aforementioned claims.
Plaintiff does not desire a trial by jury.
WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that this matter be set for
hearing, and that upon hearing of this matter, that the Court enter a judgment approving the
settlement and awarding Plaintiff the full amount agreed upon by the Parties and discharging
Defendant from any and all further liability related to any claims or causes of action which Plaintiff
has asserted herein, or which could have been asserted herein.
PLAINTIFF’S ORIGINAL PETITION FOR APPROVAL 0F SETTLEMENT OF CLAIMS
Page 2 of 3
[NOTICE THIS DOCUMENT
CONTAINS SENSITIVE DATA]
Respectfully submitted,
LENNIE F. BOLLINGER
State Bar No. 24076894
Email: LB@wormin2tonlegal.com
Wormington & Bollinger
212 E. Virginia Street
McKinney, Texas 75069
Telephone: (972) 569-3930
Facsimile: (972) 547-6440
ATTORNEYS FOR PLAINTIFF
PLAINTIFF’S ORIGINAL PETITION FOR APPROVAL 0F SETTLEMENT OF CLAIMS
Page 3 of 3
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.
Cathy Thompson on behalf of Lennie Bollinger
Bar No. 24076894
Cathy@wormingtonlegal.com
Envelope ID: 55292076
Status as of 7/14/2021 9:14 AM CST
Associated Case Party: CARLOS SANCHEZ
Name BarNumber Email TimestampSubmitted Status
Lennie Bollinger lb@wormingtonlegal.com 7/13/2021 11:53:06 AM SENT
Document Filed Date
July 13, 2021
Case Filing Date
July 13, 2021
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Preview
FILED 7/13/2021 11:53 AM FELICIA PITRE DISTRICT CLERK [NOTICE THI DOCUMENT DALLAS CO., TEXAS CONTAINS SENSITIVE DATA] Christi Undenlvood DEPUTY 0021-09029 CAUSE NO. CARLOS SANCHEZ, AS NEXT § IN THE DISTRICT COURT OF FRIEND OF J .S., A MINOR, § § § § § v. § DALLAS COUNTY, TEXAS § 298th § § GLAXOSMITHKLINE, LLC § _ JUDICIAL DISTRICT PLAINTIFF’S ORIGINAL PETITION FOR APPROVAL OF SETTLEMENT OF CLAIMS TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES, Carlos Sanchez, as next fn'end of J.S., a minor, and files this, his Original Petition for Approval of Settlement of Claims, and for such would show the Court as follows: I. Pursuant to Texas Rule of CiVil Procedure 210, the name of the Minor has been redacted from this Petition and all documents and pleadings filed subsequently with this Court. An unredacted copy of every document and pleading filed in this Court has been and will be retained in accordance with Texas Rule of CiVil Procedure 210(c). II. Plaintiff is the natural father of the minor and is the minor’s guardian. Defendant GlaxoSmithKline, LLC is a corporation conducting business Within the State of Texas. Neither issuance of a citation nor service of process is necessary PLAINTIFF’S ORIGINAL PETITION FOR APPROVAL 0F SETTLEMENT OF CLAIMS Page 1 of 3 [NOTICE THIS DOCUMENT CONTAINS SENSITIVE DATA] III. Plaintiff made product liability claims against Defendant that resulted in damages to the minor. IV. After investigation of the matter, and negotiations between the Parties, they have entered into a proposed compromise settlement agreement under which all claims of Plaintiff against Defendant will be fully compromised and settled. Accordingly, this petition is being filed with the Court for the sole purpose of concluding all of Plaintiff s claims so that Defendant will be fully and finally released from all filrther claims and liability to Plaintiff as a result of the aforementioned claims. Plaintiff does not desire a trial by jury. WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that this matter be set for hearing, and that upon hearing of this matter, that the Court enter a judgment approving the settlement and awarding Plaintiff the full amount agreed upon by the Parties and discharging Defendant from any and all further liability related to any claims or causes of action which Plaintiff has asserted herein, or which could have been asserted herein. PLAINTIFF’S ORIGINAL PETITION FOR APPROVAL 0F SETTLEMENT OF CLAIMS Page 2 of 3 [NOTICE THIS DOCUMENT CONTAINS SENSITIVE DATA] Respectfully submitted, LENNIE F. BOLLINGER State Bar No. 24076894 Email: LB@wormin2tonlegal.com Wormington & Bollinger 212 E. Virginia Street McKinney, Texas 75069 Telephone: (972) 569-3930 Facsimile: (972) 547-6440 ATTORNEYS FOR PLAINTIFF PLAINTIFF’S ORIGINAL PETITION FOR APPROVAL 0F SETTLEMENT OF CLAIMS Page 3 of 3 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. Cathy Thompson on behalf of Lennie Bollinger Bar No. 24076894 Cathy@wormingtonlegal.com Envelope ID: 55292076 Status as of 7/14/2021 9:14 AM CST Associated Case Party: CARLOS SANCHEZ Name BarNumber Email TimestampSubmitted Status Lennie Bollinger lb@wormingtonlegal.com 7/13/2021 11:53:06 AM SENT