On November 30, 2023 a
Stipulation,Agreement
was filed
involving a dispute between
Zavala, Ricardo Duran,
and
Machado, Ramon,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
12/4/2023 9:06 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Debra Clark DEPUTY
THIS DOCUMENT CONTAINS SENSITIVE DATA
MIC. 27751
CAUSE NO. DC-23-19959
RICARDO DURAN ZAVALA, § IN THE DISTRICT COURT
INDIVIDUALLY AND AS NEXT §
FRIEND OF B.D., A MINOR §
§ OF DALLAS COUNTY, TEXAS
V. §
§
RAMON MACHADO § 134th JUDICIAL DISTRICT
AGREED MOTION TO APPOINT GUARDIAN AD LITEM
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COME RICARDO DURAN ZAVALA, INDIVIDUALLY AND AS NEXT
FRIEND OF B.D., A MINOR (“Plaintiffs”), and RAMON MACHADO (“Defendant”), and files
this their Agreed Motion to Appoint Guardian Ad Litem. In support of this Motion, the Parties
will show unto this Court as follows:
Plaintiff B.D. is a minor in this lawsuit. The Parties would represent to the Court that this
is a minor friendly lawsuit and that the minor Plaintiff B.D. was a minor at the time of the
accident made the basis of this suit. Plaintiffs and Defendant have reached a settlement of this
matter and the Parties request that a Guardian Ad Litem be appointed to represent the interests of
B.D. in this matter.
WHEREFORE, PREMISES CONSIDERED, the Parties move this Court to appoint a
Guardian Ad Litem for B.D., a Minor, pursuant to Rule 173 of the TEXAS RULES OF CIVIL
PROCEDURE.
AGREED MOTION TO APPOINT GUARDIAN AD LITEM - Page 1
Respectfully submitted,
FLETCHER, FARLEY,
SHIPMAN, & SALINAS, L.L.P.
/s/ William F. Sharp
MICHAEL J. SHIPMAN
State Bar No. 18268500
mike.shipman@fletcherfarley.com
WILLIAM F. SHARP
State Bar No. 24121827
william.sharp@fletcherfarley.com
9201 North Central Expressway, 6th Floor
Dallas, Texas 75231
214-987-9600
214-987-9866 (Fax)
ATTORNEYS FOR DEFENDANT
RAMON MACHADO
AGREED:
/s/ Clyde R. Parks
CLYDE R. PARKS
State Bar No. 15518500
clydeparkslaw@aol.com
Law Offices of Clyde R. Parks
ATTORNEY FOR PLAINTIFFS RICARDO
DURAN ZAVALA, INDIVIDUALLY AND AS
NEXT FRIEND OF B.D., A MINOR.
AGREED MOTION TO APPOINT GUARDIAN AD LITEM - Page 2
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.
Brenda Papania on behalf of William Sharp
Bar No. 24121827
brenda.papania@fletcherfarley.com
Envelope ID: 82181194
Filing Code Description: Original Answer - General Denial
Filing Description:
Status as of 12/4/2023 9:19 AM CST
Associated Case Party: RICARDODURANZAVALA
Name BarNumber Email TimestampSubmitted Status
Clyde R. Parks 15518500 Clydeparkslaw@aol.com 12/4/2023 9:06:46 AM SENT
Associated Case Party: RAMON MACHADO
Name BarNumber Email TimestampSubmitted Status
William FSharp william.sharp@fletcherfarley.com 12/4/2023 9:06:46 AM SENT
Laura Collins laura.collins@fletcherfarley.com 12/4/2023 9:06:46 AM SENT
Michael J. Shipman mike.shipman@fletcherfarley.com 12/4/2023 9:06:46 AM SENT
Document Filed Date
December 04, 2023
Case Filing Date
November 30, 2023
Category
MOTOR VEHICLE ACCIDENT
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FILED 12/4/2023 9:06 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Debra Clark DEPUTY THIS DOCUMENT CONTAINS SENSITIVE DATA MIC. 27751 CAUSE NO. DC-23-19959 RICARDO DURAN ZAVALA, § IN THE DISTRICT COURT INDIVIDUALLY AND AS NEXT § FRIEND OF B.D., A MINOR § § OF DALLAS COUNTY, TEXAS V. § § RAMON MACHADO § 134th JUDICIAL DISTRICT AGREED MOTION TO APPOINT GUARDIAN AD LITEM TO THE HONORABLE JUDGE OF SAID COURT: NOW COME RICARDO DURAN ZAVALA, INDIVIDUALLY AND AS NEXT FRIEND OF B.D., A MINOR (“Plaintiffs”), and RAMON MACHADO (“Defendant”), and files this their Agreed Motion to Appoint Guardian Ad Litem. In support of this Motion, the Parties will show unto this Court as follows: Plaintiff B.D. is a minor in this lawsuit. The Parties would represent to the Court that this is a minor friendly lawsuit and that the minor Plaintiff B.D. was a minor at the time of the accident made the basis of this suit. Plaintiffs and Defendant have reached a settlement of this matter and the Parties request that a Guardian Ad Litem be appointed to represent the interests of B.D. in this matter. WHEREFORE, PREMISES CONSIDERED, the Parties move this Court to appoint a Guardian Ad Litem for B.D., a Minor, pursuant to Rule 173 of the TEXAS RULES OF CIVIL PROCEDURE. AGREED MOTION TO APPOINT GUARDIAN AD LITEM - Page 1 Respectfully submitted, FLETCHER, FARLEY, SHIPMAN, & SALINAS, L.L.P. /s/ William F. Sharp MICHAEL J. SHIPMAN State Bar No. 18268500 mike.shipman@fletcherfarley.com WILLIAM F. SHARP State Bar No. 24121827 william.sharp@fletcherfarley.com 9201 North Central Expressway, 6th Floor Dallas, Texas 75231 214-987-9600 214-987-9866 (Fax) ATTORNEYS FOR DEFENDANT RAMON MACHADO AGREED: /s/ Clyde R. Parks CLYDE R. PARKS State Bar No. 15518500 clydeparkslaw@aol.com Law Offices of Clyde R. Parks ATTORNEY FOR PLAINTIFFS RICARDO DURAN ZAVALA, INDIVIDUALLY AND AS NEXT FRIEND OF B.D., A MINOR. AGREED MOTION TO APPOINT GUARDIAN AD LITEM - Page 2 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. Brenda Papania on behalf of William Sharp Bar No. 24121827 brenda.papania@fletcherfarley.com Envelope ID: 82181194 Filing Code Description: Original Answer - General Denial Filing Description: Status as of 12/4/2023 9:19 AM CST Associated Case Party: RICARDODURANZAVALA Name BarNumber Email TimestampSubmitted Status Clyde R. Parks 15518500 Clydeparkslaw@aol.com 12/4/2023 9:06:46 AM SENT Associated Case Party: RAMON MACHADO Name BarNumber Email TimestampSubmitted Status William FSharp william.sharp@fletcherfarley.com 12/4/2023 9:06:46 AM SENT Laura Collins laura.collins@fletcherfarley.com 12/4/2023 9:06:46 AM SENT Michael J. Shipman mike.shipman@fletcherfarley.com 12/4/2023 9:06:46 AM SENT