On June 03, 2021 a
Exhibit,Appendix
was filed
involving a dispute between
Ned, Tiffany,
and
Finan, Gregory,
Finan, Gregory Kim,
Green Tag Construction, Llc,
Rohr, Kelly,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
8/31/2022 10:14 AM
FELICIA PITRE
DISTRICT CLERK
'
'
H ALAK I AW
L..._.____/ www.ChalakiLaw.com
DALLAS 00., TEXAS
Rhonda Burks DEPUTY
A TEXAS lITIGAflON FIRM
E-Service: efile@chalakilaw.com Sean Chalaki, Shawn Hashemi, Yasamin Moussavi,
Phone: (972) 793-8500 Fax: (800) 991-6288 Amber Chambers
Principal Office: 3234 Commander Dr. Carrollton, Texas 75006
August 29, 2022
VIA E-SERVIQE;
Ashley G. Whatley
Mitchell Mills
Walters, Balido & Crain, L.L.P
Meadow Park Tower
10440 North Central Expressway, Suite 1500
Dallas, Texas 75231
As_hley.Whatley_@wbc1awfirm.com
Mitghell.Mills@wbclawfirm,ggm
Re: Tiffany Ned v. Kelly Rohr, Gregory Finan, and Green Tag Construction;
Cause No.: 0021-07099,- in the 160th Judicial District Court, Dallas County, Texas.
Rule 11: Amended Headings
Dear Counsel:
Please allow this letter to serve as a Rule 11 Agreement regarding the above referenced lawsuit. This
will confirm the parties‘ agreement where Defendant agrees waive and withdraw her affirmative and other
defenses set forth in paragraphs III and IV of Defendant’s First Amended Answer, and in consideration of
Defendant's waiver and withdrawal of said affirmative and other defense, Plaintiff agrees to waive, withdraw,
and non-suit any and all claims of gross negligence as well as punitive damages she had sought against
Defendant Kelly Rohr. The parties shall amend their pleadings and disclosure responses promptly to reflect this
agreement.
If the terms and conditions in this letter accurately represent the partie's agreement, then please sign
page 2 of 2 as counsel for and on behalf of Defendant.
Thank you in advance for your cooperation and attention to this matter and please do not hesitate to
contact me if you have any questions or concerns.
Page: 1 of 2 - Rule 11 Agreement regarding Parties' Allegations and Pleadings
Sincerely,
'
/5/ Shawn H
Shawn Hashemi
Attorney for Plaintiff
Agreed:
flaw/K Mdé
Ashley G. Whatley
film/2,7.
Date
Mitchell Mills
Counsel for Defendant
Cc: Client File-
Page: 2 of 2
Document Filed Date
August 31, 2022
Case Filing Date
June 03, 2021
Category
MOTOR VEHICLE ACCIDENT
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FILED 8/31/2022 10:14 AM FELICIA PITRE DISTRICT CLERK ' ' H ALAK I AW L..._.____/ www.ChalakiLaw.com DALLAS 00., TEXAS Rhonda Burks DEPUTY A TEXAS lITIGAflON FIRM E-Service: efile@chalakilaw.com Sean Chalaki, Shawn Hashemi, Yasamin Moussavi, Phone: (972) 793-8500 Fax: (800) 991-6288 Amber Chambers Principal Office: 3234 Commander Dr. Carrollton, Texas 75006 August 29, 2022 VIA E-SERVIQE; Ashley G. Whatley Mitchell Mills Walters, Balido & Crain, L.L.P Meadow Park Tower 10440 North Central Expressway, Suite 1500 Dallas, Texas 75231 As_hley.Whatley_@wbc1awfirm.com Mitghell.Mills@wbclawfirm,ggm Re: Tiffany Ned v. Kelly Rohr, Gregory Finan, and Green Tag Construction; Cause No.: 0021-07099,- in the 160th Judicial District Court, Dallas County, Texas. Rule 11: Amended Headings Dear Counsel: Please allow this letter to serve as a Rule 11 Agreement regarding the above referenced lawsuit. This will confirm the parties‘ agreement where Defendant agrees waive and withdraw her affirmative and other defenses set forth in paragraphs III and IV of Defendant’s First Amended Answer, and in consideration of Defendant's waiver and withdrawal of said affirmative and other defense, Plaintiff agrees to waive, withdraw, and non-suit any and all claims of gross negligence as well as punitive damages she had sought against Defendant Kelly Rohr. The parties shall amend their pleadings and disclosure responses promptly to reflect this agreement. If the terms and conditions in this letter accurately represent the partie's agreement, then please sign page 2 of 2 as counsel for and on behalf of Defendant. Thank you in advance for your cooperation and attention to this matter and please do not hesitate to contact me if you have any questions or concerns. Page: 1 of 2 - Rule 11 Agreement regarding Parties' Allegations and Pleadings Sincerely, ' /5/ Shawn H Shawn Hashemi Attorney for Plaintiff Agreed: flaw/K Mdé Ashley G. Whatley film/2,7. Date Mitchell Mills Counsel for Defendant Cc: Client File- Page: 2 of 2