Stipulation,Agreement: CLARA DIAZ vs. JOHNANTHAN OCHOA

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                                FILED
                                                                                                   2/5/2024 3:13 PM
                                                                                                     FELICIA PITRE
                                                                                                  DISTRICT CLERK
                                                                                               DALLAS CO., TEXAS
                                                                                       Elizabeth Ferguson DEPUTY

                                   CAUSE NO. DC-24-01765

CLARA DIAZ, INDIVIDUALLY AND AS                       §            IN THE DISTRICT COURT
NEXT FRIEND OF J. G. D., A MINOR                      §
                        Plaintiffs,                   §
                                                      §
vs.                                                   §              95th JUDICIAL DISTRICT
                                                      §
JOHNATHAN OCHOA                                       §
                              Defendant               §           DALLAS COUNTY, TEXAS

              DEFENDANT’S MOTION TO APPOINT GUARDIAN AD LITEM

TO THE HONORABLE JUDGE OF SAID COURT:

       Defendant in the above styled and numbered cause files this Motion for Appointment of

Guardian Ad Litem, pursuant to Rule 173, TEX. R. CIV. P., and respectfully shows the following:

                                               I.

                             CERTIFICATE OF CONFERENCE

       The undersigned’s office corresponded with Plaintiffs regarding this Motion and they are

in agreement with the filing of this motion.

                                                     /s/ Kimberly Munson
                                                     ______________________________


                                               II.

                                      BASIS OF MOTION

       2.01    Clara Diaz, Indivdually and as Next Friend of J. G. D., a minor seeks damages.

       2.02    A proposed settlement agreement has been arrived at between Plaintiffs and

Defendant.

       2.03    Defendant believes that the interests of Clara Diaz could be adverse to J. G. D.

Defendant desires to have a Guardian Ad Litem review and recommend the settlement before

presentment to the Court for approval.

      1   DEFENDANT’S MOTION TO APPOINT GUARDIAN AD LITEM
       2.04    As a result of the foregoing, Defendant requests that this Court appoint a

Guardian Ad Litem to represent the interests of J. G. D. in the above referenced matter.

       2.05    The reasonable costs of the ad-litem should be taxed as court costs in the above

referenced matter.

       WHEREFORE, PREMISES CONSIDERED, Defendant prays this Motion for

Appointment of Guardian Ad Litem be in all things granted. Defendant requests all other and

further relief to which he may show himself to be justly entitled.

                                              Respectfully submitted,

                                               /s/ Kimberly J. Munson
                                              ______________________________
                                              Kimberly J. Munson
                                              State Bar No.: 00789613
                                              THE LAW OFFICES OF KIMBERLY J. MUNSON, PLLC
                                              401 Century Parkway No. 54
                                              Allen, Texas 75013
                                              214.383.3150 Phone
                                              214.383.3250 Fax
                                              service@kjmunson.com
                                              ATTORNEY FOR DEFENDANT

                                CERTIFICATE OF SERVICE

        This is to certify that a true and correct copy of the foregoing document,
DEFENDANT’S MOTION TO APPOINT GUARDIAN AD LITEM, was served on this the
5th day of February, 2024, pursuant to Texas Rules of Civil Procedure 21 and 21a to:

 Clara Diaz                                         FACSIMILE                     
 1602 Dean Forest Rd., Lot E18                      CERTIFIED MAIL                
 Savannah, GA 31408                                 EMAIL                         
 PRO SE PLAINTIFF                                   ELECTRONIC FILE               


                                                      /s/ Kimberly J. Munson
                                                     ______________________________
                                                     Kimberly J. Munson




      2   DEFENDANT’S MOTION TO APPOINT GUARDIAN AD LITEM