Motion for Summary Judgment in GEICO COUNTY MUTUAL INSURANCE COMPANY VS. SANDRA YADIRA VELA AGUIRRE, SUSAN GALVAN OLVERA| Trellis.Law

On July 22, 2019 a Motion,Ex Parte was filed involving a dispute between Geico County Mutual Insurance Company, and Aguirre, Sandra Yadira Vela, Olvera, Susan Galvan, for Injury or Damage - Motor Vehicle (OCA) in the District Court of Hidalgo County.

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Electronically Submitted
6/24/2020 10:13 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

3061903.001 / EV1

CAUSE NUMBER: CL-19-3838-H

GEICO County Mutual Insurance Company )
ae )
Plainciff, ) HIDALGO COUNTY COURT AT LAW #8
)
¥ ) Hidalgo County, Texas
Sandra Yadira Vela Aguirre, et al. }
Defendants )

PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT AS TO DEFENDANT
SANDRA YADIRA VELA AGUIRRE

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW, GEICO COUNTY MUTUAL INSURANCE COMPANY and (hereinafter
referred to as "Plaintiff") file this Motion for Summary Judgment in the above-styled and numbered
cause and would show the Court the following:

A. INTRODUCTION

1. Plaintiff sued Defendant SANDRA YADIRA VELA AGUIRRE (hereinafter referred to as
Defendant) for damages resulting from an automobile accident.

2. Defendant has filed an answer.
3. Plaintiff files this motion for summary judgment based on Defendant’s failure to respond to
Plaintiffs Requests for Admissions propounded and served on defendant via first class and

certified mail return receipt requested.

4, Plaintiff filed and served this motion on Defendant at least twenty-one (21) days before the
hearing on the motion.
B. ARGUMENT & AUTHORITIES
5. When a plaintiff moves for summary judgment on his cause of action, he is entitled to

summary judgment if he proves all essential elements of his claim as a matter of law. MMP,
Lid. v. Jones, 710 SW.2d 59, 60 (Tex. 1986). Plaintiff must show there are no genuine issues

TX MS] on Business R.Doc-20200127Electronically Submitted
6/24/2020 10:13 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

of material fact. TEX. R. CIV. P. 166a(a); Lear Siegler, Inc. v. Perez, 819 S.W.2d 470, 471 (Tex.
1991).

6. Plaintiff is entitled to summary judgment because Plaintiff's summary judgment evidence
proves he is entitled to judgment as a matter of law. Further, there are no fact issues in this
case. The court may decide this case on the summary judgment evidence included in the
appendix to this motion.

7. Defendant has not pled any counterclaim that precludes a final summary judgment.

8. Pursuant to Texas Insurance Code §542.302, Plaintiff, an insurer which has brought this suit
against Defendant, who is uninsured, is entitled to recover, in addition to the amounts plead
herein, reasonable attorney's fees, which, in this case, amount to $750.00.

9. Pursuant to Tex. Civ. Prac. & Rem. Code § 16.003(@), suit was timely filed within the
recognized two-year statute of limitations. Evidence thereof can be seen in the original
Petition attached in the appendix to this motion.

10. Plaintiff includes the summary judgment evidence in an appendix attached to and filed with
this motion and incorporates the evidence by reference.

11. This motion for summaty judgment depends upon the following proof:

a. Requests for admissions. Attached as Exhibit "A" is a copy of the Requests for
Admissions served on Defendant which establish the following facts:

1. On or about October 26, 2018, a vehicle owned by Plaintiffs insured Janie Landa,
was damaged in the collision with a vehicle operated by Defendant Sandra Yadira

Vela Aguirre.

2. Defendant Sandra Yadira Vela Aguirre was negligent in the above described
operation of the vehicle in failing to maintain a proper lookout, a safe distance from
the vehicle in front and a safe speed of travel.

3. Defendant Sandra Yadira Vela Aguirre's negligence was the sole direct and
proximate cause of the above described collision and the damages which resulted.

4. On the date of the collision, Defendant Susan Galvan Olvera was the owner of the
vehicle driven by Defendant Sandra Yadita Vela Aguirre.

TX MS] on Business R.Doc-20200127Electronically Submitted
6/24/2020 10:13 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

5. On the date of the collision, Defendant Susan Galvan Olvera lent the vehicle to
Defendant Sandra Yadira Vela Aguirre for Purposes of operating it on the public
streets and highways of Texas.

6. At the time of the above-described collision Defendant Sandra Yadita Vela Aguirre
operated it with the knowledge, consent and permission of Defendant Susan Galvan
Olvera.

b. Affidavit. The affidavit attached hereto as Exhibit “B” is incorporated by reference as
if set out in full establishes the amount of damages sustained by Plaintiff in this case,
both to the insured’s vehicle and for medical treatment of the insured.

1. The collision caused a loss in fair market value of PlaintifPs insured Janie Landa’s
vehicle in Hidalgo County. the county where the collision occurred, of $6,509.91.

2. The reasonable and necessary cost to tepair the damage to Plaintiffs insured’s
vehicle in Hidalgo County, the county whete the collision occurred, was $6,509.91.

3. At the time of the collision, Plaintiff insured’s vehicle and Janie Landa were covered
under a policy of auto insurance issued by Plaintiff.

4. After the collision and pursuant to its policy of auto insurance, Plaintiff paid to or on
behalf of its insured $34,899.91 in damages sustained in said collision.

c. Police Report. The Police Report attached hereto as Exhibit “C” is incorporated by
reference as if set out in full establishes the Defendant’s negligence in failing to control
his speed, which was the proximate cause of the damages sustained by Plaintiff.

C. CONCLUSION

13. Plaintiff is entitled to summary judgment on all its claims asserted in its petition because as a
matter of law all clements of Plaintiff's cause of action are deemed admitted.

D. PRAYER
11. For these reasons, Plaintiff asks the court to grant this motion and enter a final summary
judgment.
Respectfully submitted,

TX MS] on Business R.Doc-20200127TX MS] on Business R.Doe-20200127

RATHBONE GROUP, LLC

Loom to

Jessica R. Lobes / SBN 24083405
John M. Lamerson / SBN: 24076495
Jated B. Hall / SBN: 24055615
5930 Royal Lane, Ste E #515
Dallas, TX 75230-3896
800-870-5521

216-298-4495 [fax
JLobes@Rathbonegroup.com
JLamerson@Rathbonegroup.com
JHall@Rathbonegroup.com
Attorneys for Plaintiff

RG File 3061903.001 / EV1

Electronically Submitted
6/24/2020 10:13 AM

Hidalgo County Clerk
Accepted by: Alma NavarroElectronically Submitted
6/24/2020 10:13 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

CERTIFICATE OF SERVICE

The undersigned certifies compliance with Rule 21 and Rule 21(a), Texas Rules of Civil Procedure

Jeonp—

ols/208
Attorney for Plaintiff

TX MSJ on Business R.Doc-20200127Electronically Submitted
6/24/2020 10:13 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

3061903.001 / EV1

CAUSE NUMBER: CL-19-3838-H

GEICO County Mutual Insurance Company)
Plaintiff, HIDALGO COUNTY COURT AT LAW #8
“ } Hidalgo County, Texas

Sandra Yadira Vela Aguirre, ef al ;
Defendants }

AFFIDAVIT

Before me, the undersigned authority, personally appeared John Nace being by me duly
sworn, deposed as follows:

"My name is Io 9M Lgmeo*), I am over the age of 21, have personal knowledge of the facts

contained herein, and I am of sound mind and capable of making this affidavit. I am the attorney in
charge of this file for Plaintiff. I have Pptepared and read the attached Motion of Summary Judgment
and all facts are true and correct. Specifically, the following facts are known:

1, Plaintiff GEICO COUNTY MUTUAL INSURANCE COMPANY sued Defendant
SANDRA YADIRA VELA AGUIRRE for damages and injuries as a result of an
automobile accident;

2. Plaintiff served Defendant with Plaintiffs Original Petition on October 24, 2019.

Defendant Sandra Yadira Vela Aguirre filed an answer.

4, Plaintiff files this motion for summary judgment based on Defendant’s failure to respond to
Plaintiffs Requests for Admissions propounded and served on defendant via first class and
certified mail return receipt requested. The requests for admissions were served on
Defendant in accordance with Texas Rule of Civil Procedure 21a on April 28, 2020. Proof
of service of the discovery is attached hereto."

TX MS] on Business R.Doc-20200127Electronically Submitted
6/24/2020 10:13 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

Further, Affiant saith not. bn mM b_

SUBSCRIBED AND SWORN TO this day

"A. JACQUELINE E.R. LAMERSON
“MY COMMISSION EXPIRES
a 06-25-2021
“29 NOTARY ID: 131185769

TX MS] on Business R.Doc-20200127Electronically Submitted
6/24/2020 10:13 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

3061903.001 / EV1i

CAUSE NUMBER: CL-19-3838-H

GEICO County Mutual Insurance Company)
. )
Plaintiff, ) HIDALGO COUNTY COURT AT LAW #8
)
.. ) Hidalgo County, Texas
Sandra Yadira Vela Aguirre, ef a/ }
)

Defendants )

AFFIDAVIT IN SUPPORT OF ATTORNEY FEES

Before me, the undersigned authority, personally appeated John M. Lamerson a person
whose identity is known to me, who being by me duly sworn, deposed as follows:

My name is John M. Lamerson. I am capable of making this affidavit. I am over the age of
21 and I am of sound mind. I am the attorney in charge of this case for the Plaintiff. I have
Prepared and submitted the attached default judgment. The facts stated within this affidavit filed in
support of the default judgment are within my personal knowledge and are true and correct. The
following facts are known to me:

a. Plaintiff, GEICO County Mutual Insurance Company, sued Defendant Sandra
Yadira Vela Aguirre for damages arising from an automobile accident;

b. Defendant was served on October 24, 2019 with Plaintiff's Petition.

c. I, and other attorneys employed by Plaintiff's counsel's firm, have spent in excess of
3.0 hours in preparing and filing the petition and summons, following for serivce of
Process, preparing discovery, and preparing this motion.

d. Iam of the opinion that a fee award of $250.00 pet hour, for a total award of at least
$750.00 is entirely reasonable in light of the novelty and difficulty of the questions of
law involved, the skill requisite to properly perform the legal services called for
herein, the fee customarily charged in this locality for similar services, the amounts
involved, and the experience, reputation, and ability of me and the other attorneys at
my firm who have performed the services referenced above.

Further Affiant sayeth not. Qn

Jofin M. Lamerson

SUBSCRIBED AND SWORN TO.#
My commission expires:

JACQUELINE E. R. LAMERSON
MY COMMISSION EXPIRES
Ag 06-25-2021

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Electronically Submitted
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8:33 AM

Q-County Clerk
ma Navarro

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Restoal oy 2] 0, | 1Electronically Submitted
2d.

‘Enforcament and TxDOT Use ONLY. 9:53 AM
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FT Cena “Comh Tene ccep y: Alma Navarro

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PAQSNY SAN SUAN POLICE DEPARTMENT

Name: Last First, MiddleElectronically Submitted
6&2/2202010:33 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

Payment Records

MTN.TX.01.05112017Claim Number
Pay To The Order Of

Financials
Gross Amount
Net Amount

Backup Withholding

Payment Identification
Issued Date

Mail To Name

Mail To Address

0508433250101144

CHRISTOPHER CRUZ and JANIE ROSIE
LANDA,

$4,830.61
$4,830.61
$0.00

10/29/2018
MARK OF XCELLENCE COLLISION SERVICES
612 W FERGUSON ST, PHARR, TX, 78577-2412

Electronically Submitted
6@2/22002010:33 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

Memo COLLISION COVERAGE
INITIAL ESTIMATE
Payment Type Manual Check
‘Check Number 621346395,
Related Documents
Document Name
Reserve Line Allocation
Exposure Reserve Line Cost Type ‘Amount
Janie Rosie Landa - UM PD (2016 L) Uninsured Motorist - PD Loss $4,830.61
Janie Rosie Landa - Colision (2016 L) Collision Loss $4,830.61
Janie Rosie Landa - Colision (2016 L} Collision Loss $4,830.61Claim Number
Pay To The Order Of

Financials
Gross Amount

Net Amount
Backup Withholding

Payment Identification
Issued Date

M
Mail To Address
Memo

fo Name

Paymont Type
(Check Number

Related Documents

Document Name

Reserve Line Allocation
Exposure

Janie Rosie Landa - UM PD (2016 L)

0508433250101144
CHRISTOPHER CRUZ

$623.30
$623.30
$0.00

vaner2o18
CHRISTOPHER CRUZ
ae

UNINSURED MOTORIST COVERAGE

‘System Check
201246960

Reserve Line Cost Type

Uninsured Motorist - PD Loss

‘Amount
$623.30

Electronically Submitted
6@2/22002010:33 AM

Hidalgo County Clerk
Accepted by: Alma NavarroClaim Number
Pay To The Order Of

Financials
Gross Amount

Net Amount
Backup Withholding

Payment Identification
Issued Date

Mail To Name

Mail To Address

Memo

Payment Type
Check Number

Related Documents

Document Name

Reserve Line Allocation
Exposure
Janie Rosie Landa - Rental (2016 L)

0508433250101144
HERTZ LOCAL EDITION

$805.00
$805.00
$0.00

11/26/2018
HERTZ LOCAL EDITION

Hie Insurance Dept. 1139, P.o. Box 121138,
Dallas, TX, 75312-1139

RENTAL REIMBURSEMENT COVG.
INVOICE - 648838510

‘System Check
201443412

Reserve Line Cost Type
Rental Reimbursement Loss

‘Amount
$805.00

Electronically Submitted
6@2/22002010:33 AM

Hidalgo County Clerk
Accepted by: Alma NavarroClaim Number 0508433250101144

Pay To The Order Of Janie Rosie Landa and The J Gonzalez
Law Firm

Financials

Gross Amount $8,000.00

Net Amount $8,000.00

Backup Withholding $0.00

Payment Identification

Issued Date 03/20/2019

Mail To Name ‘The J Gonzalez Law Firm

Mail To Address 2120 Oakland Ave, Mcallen, TX, 78601-7283
Memo Uninsured Motorist Coverage

Full & Final settlement of
any & all claims including
liens known & unknown

Payment Type ‘System Check
(Check Number 204274164

Related Documents

Document Name

Electronically Submitted
6@2/22002010:33 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

Reserve Line Allocation

Exposure Reserve Line Cost Type

Janie Rosie Landa - UM BI Uninsured Motorist - BI Loss

‘Amount

$8,000.00Claim Number 0508433250101144

Pay To The Order Of Jesus Alanis and The J Gonzalez Law
Firm

Financials

Gross Amount $8,100.00

Net Amount $8,100.00

Backup Withholding $0.00

Payment Identification

Issued Date 03/20/2019

Mail To Name ‘The J Gonzalez Law Firm

Mail To Address 2120 Oakland Ave, Mcallen, TX, 78601-7283
Memo Uninsured Motorist Coverage

Full & Final settlement of
any & all claims including
liens known & unknown

Payment Type ‘System Check
(Check Number 204273209

Related Documents

Document Name

Electronically Submitted
6@2/22002010:33 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

Reserve Line Allocation

Exposure Reserve Line Cost Type

Jesus Alanis - UM 81 Uninsured Motorist - BI Loss

‘Amount

$8,100.00Claim Number 0508433250101144

Pay To The Order Of Clemencia Tapia and The J Gonzalez
Law Firm

Financials

Gross Amount $8,200.00

Net Amount $8,200.00

Backup Withholding $0.00

Payment Identification

Issued Date 03/20/2019

Mail To Name The J Gonzalez Law Firm

Mail To Address 2120 Oakland Ave, Mcallen, TX, 78601-7283
Memo Uninsured Motorist Coverage

Full & Final settlement of
any & all claims including
liens known & unknown

Payment Type ‘System Check
(Check Number 204274183

Related Documents

Document Name

Electronically Submitted
6@2/22002010:33 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

Reserve Line Allocation

Exposure Reserve Line Cost Type

Clemencia Tapia - UM BI Uninsured Motorist - BI Loss

‘Amount

$8,200.00Claim Number
Pay To The Order Of

Financials
Gross Amount

Net Amount
Backup Withholding

Payment Identification
Issued Date

Mail To Name

Mail To Address

Memo

Payment Type
(Check Number

Related Documents

Document Name

Reserve Line Allocation

Exposure

‘Angel Alanis - UM BI

0508433250101144

Clemencia Tapia as parent/guardian
of Angel Alanis, a minor and The J
Gonzalez

Law Firm

$1,100.00
$1,100.00
$0.00

03/20/2019
‘The J Gonzalez Law Fem
2120 Oakland Ave, Mcallen, TX, 78501-7283

Uninsured Motorist Coverage
Full & Final settiement of
any & all claims including
liens known & unknown

‘System Check

204273045
Reserve Line Cost Type
Uninsured Motorist - BI Loss

‘Amount

$1,100.00

Electronically Submitted
6@2/22002010:33 AM

Hidalgo County Clerk
Accepted by: Alma NavarroClaim Number
Pay To The Order Of

Financials
Gross Amount

Net Amount
Backup Withholding

Payment Identification
Issued Date

Mail To Name

Mail To Address

Memo

Payment Type
(Check Number

Related Documents

Document Name

Reserve Line Allocation

Exposure

Maxine Torres - UM BI

0508433250101144

Janie Rosie Landa, as parent
guardian of Maxine Torres and The J
Gonzalez

Law Firm, as attorney

$1,100.00
$1,100.00
$0.00

03/20/2019
‘The J Gonzalez Law Fem
2120 Oakland Ave, Mcallen, TX, 78501-7283

Uninsured Motorist Coverage
Full & Final settiement of
any & all claims including
liens known & unknown

‘System Check

204273059
Reserve Line Cost Type
Uninsured Motorist - BI Loss

‘Amount

$1,100.00,

Electronically Submitted
62/2000010:33 AM

Hidalgo County Clerk
Accepted by: Alma NavarraClaim Number
Pay To The Order Of

Financials
Gross Amount

Net Amount
Backup Withholding

Payment Identification
Issued Date

Mail To Name

Mail To Address

Memo

Payment Type
(Check Number

Related Documents

Document Name

Reserve Line Allocation

Exposure

Carlos Torres - UM BI

0508433250101144

Janie Rosie Landa as parent/guardian
of Carlos Torres, a minor and The J
Gonzalez

Law Firm

$1,640.00
$1,640.00,
$0.00

03/20/2019
‘The J Gonzalez Law Fem
2120 Oakland Ave, Mcallen, TX, 78501-7283

Uninsured Motorist Coverage
Full & Final settiement of
any & all claims including
liens known & unknown

‘System Check

204272025
Reserve Line Cost Type
Uninsured Motorist - BI Loss

‘Amount

$1,640.00

Electronically Submitted
6@2/22002010:33 AM

Hidalgo County Clerk
Accepted by: Alma NavarroElectronically Submitted
6&2/2202010:33 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

Property Damage

MTN.TX.01.05112017GEICO
05

Request a supplement at partners.geico.com

Geico

2280 N Greenville Ave
Richardson, TX 75082

Supplement of Record 1 Summary

Electronically Submitted
6&2/2202010:33 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

Claim #:
Workfile ID:

0508433250101144-01
e1f08002

Insured: Janie Landa
Type of Loss: Collision
Point of Impact: 06 Rear
Owner (Insured):

Janie Landa

|
fo
ER Evening

Owner Policy #:
Date of Loss:
Deductible:

Inspection Location:
Hacienda Collision Ctr-XD
Hacienda Collision Ctr-XD
1325 E Pecan Blvd
Mcallen, TX 78501
Drive-in

(956) 213-1000 Day

|
10/26/2018 04:00 PM
501.00

Appraiser Information:

coortega@geico.com
(956) 408-9311

Claim #:
Days to Repair: 4

Written By: CONRAD ORTEGA, License Number: 1678731, 11/16/2018 1:17:20 PM
Adjuster: AKC6

0508433250101144-01

Repair Facility:

MARK OF XCELLENCE

612 W Furguson St

Pharr, TX 78577

(956) 884-7020 Business
455077574 Federal ID
455077574 License Number

VEHICLE

2016 RANG Discovery Sport HSE AWD 4D UTV 4-2.0L Turbocharged Gasoline Gasoline Direct Injection CORRIS GREY

VIN: ; Production Date: 08/2015 Interior Color: BLACK LEATHER

License: 7 Odometer: 76671 Exterior Color: CORRIS GREY

State: ™ Condition:

TRANSMISSION HOME LINK ELECTRIC GLASS ROOF SIGNAL INTEGRATED MIRRORS

AUTOMATIC TRANSMISSION INSTRUMENT PANEL SKYVIEW ROOF PRIVACY GLASS

4 WHEEL DRIVE TRACTION CONTROL SAFETY SEATS

DRIVER CONVENIENCE STABILITY CONTROL DRIVERS SIDE AIR BAG LEATHER SEATS

KEYLESS ENTRY LANE DEPARTURE WARNING PASSENGER AIR BAG POWER PASSENGER SEAT

MESSAGE CENTER ALARM FRONT SIDE IMPACT AIR BAGS VENTILATED SEATS

MEMORY PACKAGE AIR CONDITIONING HEAD/CURTAIN AIR BAGS HEATED SEATS

POWER DRIVER SEAT CLIMATE CONTROL PAINT REAR HEATED SEATS

POWER WINDOWS REAR DEFOGGER CLEARCOAT PAINT 3RD ROW SEAT

POWER LOCKS HANDS FREE DEVICE METALLIC PAINT REAR END

POWER MIRRORS COMMUNICATION SYSTEM FRONT END BACKUP CAMERA W/ PARKING
SENSORS.

HEATED MIRRORS NAVIGATION SYSTEM FOG LAMPS REAR WINDOW WIPER

POWER TRUNK/GATE RELEASE RADIO HEADLAMP WASHERS REAR SPOILER

CRUISE CONTROL AM RADIO XENON HEADLAMPS, WHEELS

INTERMITTENT WIPERS FM RADIO POWER STEERING 4-WHEEL DISC BRAKES.

TILT WHEEL STEREO POWER BRAKES ALUMINUM/ALLOY WHEELS

TELESCOPIC WHEEL ‘SEARCH/SEEK ANTI-LOCK BRAKES (4) LOCKING WHEELS

11/16/2018 1:17:21 PM

139958 | 1.7.04.08030

Page 1Electronically Submitted

Claim #: enna ema clon
Workfile ID: Accepted BR Aa Navarro

Supplement of Record 1 Summary

2016 RANG Discovery Sport HSE AWD 4D UTV 4-2.0L Turbocharged Gasoline Gasoline Direct Injection CORRIS GREY

STEERING WHEEL TOUCH AUXILIARY AUDIO CONNECTION GLASS & MIRRORS
CONTROLS
CONSOLE/STORAGE ROOF

DUAL MIRRORS

11/16/2018 1:17:21 PM 139958 | 1.7.04.08030 Page 2Supplement of Record 1 Summary

Electronically Submitted

Claim #: enna ema clon
Workfile ID: Accepted BR Aa Navarro

2016 RANG Discovery Sport HSE AWD 4D UTV 4-2.0L Turbocharged Gasoline Gasoline Direct Injection CORRIS GREY

Line

Oper

Description

Qty

Extended

Labor Paint

Price $

3 LIFT GATE

12
13
14
15
16
17
18
19
20 sot

11/16/2018 1:17:21 PM

Ral
Repl

Repl
Repl
Repl
Repl

R&I
R&d
R&I
R&I
R&I
R&I
Repl

Check sensors for damage
Ph stated that vehicle shakes in the back when she drives

NOTE: NO IMPACT TO TIRE ARE NO ALIGNMENT ADDED TO ESTIMATE.

Wiper arm
Lift gate

1
1

0.2

1,999.37 5.8 3.8

NOTE: LABOR: Time includes tail lamps on lift gate, finish panel and spoiler.

LKQ
NO LIFT GATE AVAIL.

FINISH PANEL N/A

NONE AVAIL FOR TAIL LAMP
RECON REAR BUMPER 686
TAIL LAMP IN LIFT GATE NONE
QUOTE# 1784320

REY'S

LIFT GATE - COMPLETE - 2300
LAMPS NOT AVAIL

BUMPER NOT AVAIL

R&R

NOT AVAIL ON ANY

Add for Clear Coat

Add for trnsfr glass

Emblem

Nameplate "DISCO" light atlas

Nameplate "VERY" light atlas

Finish panel w/rear camera, w/o premium sound atlas

NOTE: LKQ
NOT AVAIL
QUOTE# 1784320

REY'S

NOT AVAIL

R&R

NOT AVAIL ON ANY

Overlap Minor Panel

Add for Clear Coat

R&d spoiler

Upper trim cirrus

RT Side cover cirrus

LT Side cover cirrus

Lower trim panel w/o power lift gate ebony/lunar
Handle ebony/lunar

Rear camera w/o premium audio

139958 | 1.7.04.08030

15
0.8
38.44 0.1
104.25 0.2
93.51 0.2

500.03 Incl. 0.7

0.2
01
05
Incl,
01
0.1
Incl.
Ind.
334,86 OL

Page 3Supplement of Record 1 Summary

Claim #:
Workfile ID:

Electronically Submitted
1019:33 AM

enna ‘ounty Clerk
Accepted BR Rf Navarro

2016 RANG Discovery Sport HSE AWD 4D UTV 4-2.0L Turbocharged Gasoline Gasoline Direct Injection CORRIS GREY

21 REAR LAMPS
22 Repl

23 R&d
24 Repl

25 R&I
26 R&I
27 R&I
28 S01 Repl
29 REAR BUMPER

31 OF Repl

32
33. OTHER CHARGES
340 #

NOTE: NOT WORKING PROPERLY.

PARTS: Order by application. LABOR: Time is after finish panel is removed.

RT Tail lamp w/o adaptive headlamps
NOTE: LKQ

TAIL LAMP IN LIFT GATE NONE
QUOTE# 1784320

REY'S
LAMPS NOT AVAIL

R&R
NOT AVAIL ON ANY

LT Tail lamp w/o adaptive headlamps
RT Tail lamp w/o adaptive headlamps

NOTE: LKQ
TAIL LAMP IN LIFT GATE NONE
QUOTE# 1784320

REY'S

LAMPS NOT AVAIL

R&R

NOT AVAIL ON ANY

RT License lamp

LT License lamp

High mount lamp

LT Tail lamp w/o adaptive headlamps

O/H rear bumper

Bumper cover w/3rd row seat w/park aid

272.58

244.54

240.93

826.25

Incl.

Incl.
Incl.

0.2
Incl.

21
Incl. 0.0

NOTE: LABOR: Time is after tail lamp assemblies and wheel opening are removed. Time includes R&I/R&R lower

cover and rear fog lamps.

LKQ

RECON REAR BUMPER 686
QUOTE# 1784320

REY'S

BUMPER NOT AVAIL

R&R

NOT AVAIL ON ANY

OE MORE COST EFFECTIVE
Add for park sensor

E.P.C.

2.50

0.4

4,657.26

10.8 5.9

11/16/2018 1:17:21 PM

139958 | 1.7.04.08030

Page 42016 RANG Discovery Sport HSE AWD 4D UTV 4-2.0L Turbocharged Gasoline Gasoline Direct Injection CORRIS GREY

Prior Damage Notes:

P/S DOOR HAS CHIPPED PAINT,

SCRATCH ON D/S REAR DOOR,
GRILLE HAS PAINT DMG,

11/16/2018 1:17:21 PM

Supplement of Record 1 Summary

NOTES

Claim #:
Workfile ID:

Electronically Submitted
1019:33 AM

enna ‘ounty Clerk
Accepted BR Rf Navarro

ESTIMATE TOTALS
Category Basis Rate Cost $
Parts 4,654.76
Body Labor 10.8hrs @ $ 44.00 /hr 475.20
Paint Labor 5.9hrs @ $ 44.00 /hr 259.60
Paint Supplies 5.9hrs @ $ 28.00 /hr 165.20
Other Charges 2.50
Subtotal 5,557.26
Sales Tax $4,819.96 @ 8.2500 % 397.65
Total Cost of Repairs 5,954.91
Deductible 501.00
Total Adjustments 501.00
Net Cost of Repairs 5,453.91
139958 | 1.7.04.08030 Page 5Claim #:
Workfile ID:

Supplement of Record 1 Summary

Electronically Submitted

1019:33 AM

ee ‘ounty Clerk
Accepted BOR Rf Navarro

2016 RANG Discovery Sport HSE AWD 4D UTV 4-2.0L Turbocharged Gasoline Gasoline Direct Injection CORRIS GREY

SUPPLEMENT SUMMARY
Line Oper Description Qty Extended Labor Paint
Price $
Deleted Items
20 R&I Rear camera w/o premium audio -0.1
24 R&I LT Tail lamp w/o adaptive headlamps Incl.
Added Items
20 S01 Repl Rear camera w/o premium audio 1 334.86, 0.1
NOTE: NOT WORKING PROPERLY.
PARTS: Order by application. LABOR: Time is after finish panel is removed.
28 S01 Repl LT Tail lamp w/o adaptive headlamps 1 240.93 Incl.
SUBTOTALS 575.79 0.0 0.0
NOTES
Prior Damage Notes:
P/S DOOR HAS CHIPPED PAINT,
SCRATCH ON D/S REAR DOOR,
GRILLE HAS PAINT DMG,
TOTALS SUMMARY
Category Basis Rate Cost $
Parts 575.79
Body Labor 0.00
Subtotal 575.79
Sales Tax $575.79 @ 8.2500 % 47.50
Additional Supplement Taxes 0.01
Total Supplement Amount 623.30
NET COST OF SUPPLEMENT 623.30
CUMULATIVE EFFECTS OF SUPPLEMENT(S)
Estimate 5,331.61 MARIO MORA
Supplement S01 623.30 CONRAD ORTEGA
Workfile Total: $ 5,954.91
TOTAL ADJUSTMENTS: $ 501.00
NET COST OF REPAIRS: $ 5,453.91

11/16/2018 1:17:21 PM

139958 | 1.7.04.08030

Page 6Electronically Submitted

Claim #: enna ema clon
Workfile ID: Accepted BR Aa Navarro

Supplement of Record 1 Summary

2016 RANG Discovery Sport HSE AWD 4D UTV 4-2.0L Turbocharged Gasoline Gasoline Direct Injection CORRIS GREY

This is not an authorization to repair.
All GEICO customers have the right to have their vehicle repaired in the shop of their choice.
No Supplement will be honored unless authorized by GEICO.

NOTICE: Vehicles constructed of special metals may require the use of specialized welding and bonding equipment.
Proper measuring and structural repair systems are required on today's vehicle to accurately accomplish vehicle
repairs. Make sure your shop has the proper equipment to repair your vehicle.

ALTERNATE PARTS DISCLAIMER:

IF A QUALITY REPLACEMENT PART (A/M, LKQ, RECOND OR OPT OEM) APPEARS ON THIS ESTIMATE, IT INDICATES
THAT THIS ESTIMATE HAS BEEN PREPARED BASED ON THE USE OF ONE OR MORE CRASH PARTS SUPPLIED BY A
SOURCE OTHER THAN THE MANUFACTURER OF YOUR MOTOR VEHICLE. GUARANTEES, IF ANY, APPLICABLE TO
THESE REPLACEMENT CRASH PARTS ARE PROVIDED BY THE PART MANUFACTURER OR DISTRIBUTOR RATHER
THAN BY THE MANUFACTURER OF YOUR VEHICLE.

***IN ADDITION TO ANY SUCH GUARANTEES, GEICO PROVIDES THE FOLLOWING:

OWNER LIMITED GUARANTEE**** WE GUARANTEE THAT ALL QUALITY REPLACEMENT BODY PARTS (PARTS
NOT MANUFACTURED BY THE MANUFACTURER) IDENTIFIED ON YOUR ESTIMATE, ARE FREE OF DEFECTS IN
MATERIAL AND WORKMANSHIP AND MEET GENERALLY ACCEPTED INDUSTRY STANDARDS. THIS PARTS AND
LABOR GUARANTEE WILL BE IN EFFECT FOR AS LONG AS YOU OWN THE VEHICLE DESCRIBED IN THE ESTIMATE.
THIS GUARANTEE COVERS THE COST OF THE PART, LABOR TO INSTALL, AND INCIDENTALS SUCH AS PAINT AND
MATERIALS AND IS SPECIFICALLY LIMITED TO THOSE ITEMS. THIS GUARANTEE DOES NOT COVER LOSS OR
DAMAGE THAT IS UNRELATED TO DEFECTS IN THE QUALITY REPLACEMENT PARTS. THIS IS NOT TRANSFERABLE.
IF ANY QUALITY REPLACEMENT PARTS ARE DEFECTIVE IN EITHER MATERIAL OR WORKMANSHIP, CONTACT YOUR
LOCAL GEICO REPRESENTATIVE.

11/16/2018 1:17:21 PM 139958 | 1.7.04.08030 Page 7Electronically Submitted

Claim #: enna ema clon
Workfile ID: Accepted BR Aa Navarro

Supplement of Record 1 Summary

2016 RANG Discovery Sport HSE AWD 4D UTV 4-2.0L Turbocharged Gasoline Gasoline Direct Injection CORRIS GREY

Estimate based on MOTOR CRASH ESTIMATING GUIDE and potentially other third party sources of data. Unless
otherwise noted, (a) all items are derived from the Guide ERW7130, CCC Data Date 11/8/2018, and potentially other
third party sources of data; and (b) the parts presented are OEM-parts manufactured by the vehicles Original
Equipment Manufacturer. OEM parts are available at OE/Vehicle dealerships. OPT OEM (Optional OEM) or ALT OEM
(Alternative OEM) parts are OEM parts that may be provided by or through alternate sources other than the OEM
vehicle dealerships. OPT OEM or ALT OEM parts may reflect some specific, special, or unique pricing or discount.
OPT OEM or ALT OEM parts may include "Blemished" parts provided by OEM's through OEM vehicle dealerships.
Asterisk (*) or Double Asterisk (**) indicates that the parts and/or labor data provided by third party sources of data
may have been modified or may have come from an alternate data source. Tilde sign (~) items indicate MOTOR
Not-Included Labor operations. The symbol (<>) indicates the refinish operation WILL NOT be performed as a
separate procedure from the other panels in the estimate. Non-Original Equipment Manufacturer aftermarket parts
are described as Non OEM, A/M or NAGS. Used parts are described as LKQ, RCY, or USED. Reconditioned parts are
described as Recond. Recored parts are described as Recore. NAGS Part Numbers and Benchmark Prices are
provided by National Auto Glass Specifications. Labor operation times listed on the line with the NAGS information
are MOTOR suggested labor operation times. NAGS labor operation times are not included. Pound sign (#) items
indicate manual entries.

Some 2019 vehicles contain minor changes from the previous year. For those vehicles, prior to receiving updated
data from the vehicle manufacturer, labor and parts data from the previous year may be used. The CCC ONE
estimator has a list of applicable vehicles. Parts numbers and prices should be confirmed with the local dealership.

The following is a list of additional abbreviations or symbols that may be used to describe work to be done or parts to
be repaired or replaced:

SYMBOLS FOLLOWING PART PRICE:
m=MOTOR Mechanical component. s=MOTOR Structural component. T=Miscellaneous Taxed charge category.
X=Miscellaneous Non-Taxed charge category.

SYMBOLS FOLLOWING LABOR:
D=Diagnostic labor category. E=Electrical labor category. F=Frame labor category. G=Glass labor category.
M=Mechanical labor category. S=Structural labor category. (numbers) 1 through 4=User Defined Labor Categories.

OTHER SYMBOLS AND ABBREVIATIONS:

Adj.=Adjacent. Algn.=Align. ALU=Aluminum. A/M=Aftermarket part. Blnd=Blend. BOR=Boron steel.
CAPA=Certified Automotive Parts Association. D&R=Disconnect and Reconnect. HSS=High Strength Steel.
HYD=Hydroformed Steel. Incl.=Included. LKQ=Like Kind and Quality. LT=Left. MAG=Magnesium. Non-Adj.=Non
Adjacent. NSF=NSF International Certified Part. O/H=Overhaul. Qty=Quantity. Refn=Refinish. Repl=Replace.
R&I=Remove and Install. R&R=Remove and Replace. Rpr=Repair. RT=Right. SAS=Sandwiched Steel.
Sect=Section. Subl=Sublet. UHS=Ultra High Strength Steel. N=Note(s) associated with the estimate line.

CCC ONE Estimating - A product of CCC Information Services Inc.

The following is a list of abbreviations that may be used in CCC ONE Estimating that are not part of the MOTOR
CRASH ESTIMATING GUIDE:

BAR=Bureau of Automotive Repair. EPA=Environmental Protection Agency. NHTSA= National Highway
Transportation and Safety Administration. PDR=Paintless Dent Repair. VIN=Vehicle Identification Number.

11/16/2018 1:17:21 PM 139958 | 1.7.04.08030 Page 8Claim #:
Workfile ID:

Supplement of Record 1 Summary

2016 RANG Discovery Sport HSE AWD 4D UTV 4-2.0L Turbocharged Gasoline Gasoline Direct Injection CORRIS GREY

ALTERNATE PARTS USAGE

2016 RANG Discovery Sport HSE AWD 4D UTV 4-2.0L Turbocharged Gasoline Gasoline Direct Injection CORRIS GREY

VIN: fF Production Date: 08/2015 Interior Color:

Electronically Submitted
1019:33 AM

anna ‘ounty Clerk
Accepted BR Rf Navarro

BLACK LEATHER
License: 7 Odometer: 76671 Exterior Color: CORRIS GREY
State: ™ Condition:

Alternate Part Type # Of Available Parts # Of Parts Selected
Aftermarket 0 0
Optional OEM 0 0
Reconditioned 0 0
Recycled 3 0
11/16/2018 1:17:21 PM 139958 | 1.7.04.08030 Page 9Claim #:
Workfile ID:

Electronically Submitted
1019:33 AM

anna ‘ounty Clerk
Accepted BR Rf Navarro

Supplement of Record 1 Summary

2016 RANG Discovery Sport HSE AWD 4D UTV 4-2.0L Turbocharged Gasoline Gasoline Direct Injection CORRIS GREY
RECALL INFO

2016 RANG Discovery Sport HSE AWD 4D UTV 4-2.0L Turbocharged Gasoline Gasoline Direct Injection CORRIS GREY

VIN: fF Production Date: 08/2015 Interior Color: BLACK LEATHER
License: 7 Odometer: 76671 Exterior Color: CORRIS GREY
State: ™ Condition:

The National Highway Transportation and Safety Administration (NHTSA) has issued 2 safety-related recall notice(s) that may apply to the selected
vehicle.

NHTSAID: 16V889000 Issued: Dec 12, 16 Number of Vehicles: 00000220

SUSPENSION:FRONT:CONTROL ARM:LOWER ARM Jaguar Land Rover North America, LLC (Land Rover) is recalling certain model year 2016-2017
Land Rover Discovery Sport vehicles manufactured May 30, 2016, to August 24, 2016, and 2016-2017 Range Rover Evoque vehicles manufactured
June 7, 2016, to August 26, 2016. The affected vehicles have front lower control arm fasteners that may fail due to an assembly error, possibly
resulting in separation of the steering knuckle. If the fasteners were to fail causing the knuckle to separate, vehicle handling may be affected,
increasing the risk of a crash. Land Rover will notify owners, and dealers will replace the hardware that connects the front lower control arm to the
knuckle, free of charge. The recall began on January 27, 2017. Owners may contact Land Rover customer service at 1-800-637-6837. Land
Rover's number for this recall is Q650/Q651.

NHTSAID: 16V274000 Issued: May 5, 16 Number of Vehicles: 00014731

EXTERIOR LIGHTING Jaguar Land Rover North America, LLC (Land Rover) is recalling certain model year 2015-2016 Land Rover Discovery Sport
vehicles manufactured September 17, 2014, to March 5, 2016. In the affected vehicles, the license plate illumination lamp may fall out. As such,
these vehicles fail to comply with the requirements of Federal Motor Vehicle Safety Standard (FMVSS) number 108, "Lamps, Reflective Devices,
and Associated Equipment.” Without license plate illumination, the vehicle may be difficult to identify at night. Land Rover will notify owners, and
dealers will replace both rear license plate lamp housings, free of charge. The recall began on June 21, 2016. Owners may contact Land Rover
customer service at 1-800-637-6837. Land Rover's number for this recall is P077.

11/16/2018 1:17:21 PM 139958 | 1.7.04.08030 Page 10Electronically Submitted
6mal

20000:53 AM
HERTZ LOCAL EDITION Rental A N tielge G ounty Clerk
fenta. jreement No: A: A
Phone: 4-888-777-3700 Invoice Date: *FSSSRIRG by: Alma Navarro
Fax: Document : 609089242413
Eval |: CUSTOMEREILLINGRMERTZ.COM ®@
LOCAL EDITION Renter: JANIE LANDA
Direct All Inquiries To: ORIGINAL INVOICE Account No. : feeeee447544 HCC
HERTZ LOCAL EDITION CDP No.: 1692030
HLE INSURANCE DEPT 1139 CDP Name: HLE GEICO DALLAS HIRS
PO BOX 121139
DALLAS, TX 75312-1139
TAX Id: 13-1938568
MORA MARIO
GEICO-DALLAS
PO BOX 509105
TRISH GOOD-RENTAL SERV UNIT
SAN DIEGO, CA 92150
RENTAL REFERENCE
Rental Agreement No: A48838510 Rate Plan: IN: HIDA OUT
Reservation ID OKRCU28041 Rented On: ingore a0: MU Lace 76980
Returned On 11/20/2018 17:00 LOC# 769802
MISSION, TX
Car Description: SIR MAXIMA KSH7884
VIN & ‘IN4AAG APXJC379725,
CAR CLASS Charged: MILEAGE In: 17,274
Rented: Gut: 14/960
Reserved: F Oriven: 2,314
BILLING INFORMATION BILLING DETAILS
Claim No: 0508433250107144 DAYS 38 08.75 807.25
Policy No: ‘SUBTOTAL 661.25
Date of Loss: 2018-10-25
Type of Loss: o VEHICLE LICENSE FEE 38.75
Repair Facility: MARK OF XCELLENCE 15.008 105.00
Author ized Rate: 35.00 TOTAL CHARGES 805.00 USD
Authorized Days: 23
Adjuster: MORA MARIO
Insured: 0
AMOUNT DUE 805.00 USD
‘TR-X MILES DRIVEN 115
TOTAL RENTAL DAYS: 23
BILLED 10 CUSTOMER 29.85
TOTAL RENTAL CHARGES: 834.85

PAYMENT DUE UPON RECEIPT

THANK YOU FOR RENTING FROM HERTZ

PLEASE INCLUDE RENTAL AGREEMENT NO. ON YOUR CHECK.

REMIT TO:

HERTZ LOCAL EDITION
HLE_ INSURANCE DEPT 1139
PO BOX 121139

DALLAS, TX 75312-1139
UNITED STATES

AMOUNT OU
Phone 1-888-777-3700
E-mail: CUSTOMERBILL ING@HERTZ COM

IE:

805.00 USDElectronically Submitted
6&2/2202010:33 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

Medical Damage

MTN.TX.01.05112017Electronically Submitted
8 5f#700001 0:55 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

From:J Gonzalez Law Firm 966463046777 03/20/2019 15:61 #552

RELEASE AND TRUST AGREEMENT
KNOW ALL MEN BY THESE PRESENTS Claim Number 0508433250101144 /J633

That 1, Jesus Alanis, Of the City of McAllen State of Texas, being of Majority Age, for and in consideration of eight
thousand one hundred dollars and 00/100($8,100.00) the receipt whereof is hereby acknowledged, do release and forever
discharge GEICO County Mutual Insurance Company, hereinafter referred to as the Company, from any and all liability
under the Uninsured Motorists Coverage of policy number| issued in the name of Janie Rosie Landa, by the
Company resulting from an accident which occurred on or about the 26th day of October, 2018, at or near San Juan, TX. It
is understood and agreed that this is a full and final settlement of all claims for death, injuries, loss damage, known and
unknown, Jesus Alanis may have under the Uninsured Motorist Coverage of policy ee in the name of
Janie Rosie Landa by the Company.

I HEREBY REPRESENT AND COVENANT THAT:

(A) No settlement or agreement has been made or will be made by me or in my behalf with any person or
organization other than the Company affecting Liability to me for loss or damage resulting from the
above described accident, and no release, receipt, covenant or agreement of any kind has been made or
given by me or in my bebalf or will in the future be made or given by me or in my behalf, without the
written consent of the Company.

No determination, award, verdict or judgment has been made relating to my damages or injuries
resulting from the above described accident by any arbitrators, referee, Commission or Court.

No Workmen’s Compensation benefits of | ‘any kind, either financial or medical care or treatment, have
been received by me or in my behalf, nor has any claim been made or petition filed by me or in my behalf
under any Workmen’s Compensation Act, as a result of the above described accident, and that, to the
best of my information and belief, said accident did not arise out of and in the course of my employment
with my employer.

IT IS UNDERSTOOD AND AGREED that the Company has relied upon the foregoing covenants and representations as
material to its contractual obligations to me as evidenced by the payment referred to herein, and that in the event any such
covenant or representation is not true, I will return and repay said amount to the Company within thirty (30) days after the
Company has given written notice to me of the falsity of such representation or covenant and demand for such repayment,
and that the within instrument and the aforesaid written notice and demand by the Company shall be sufficient as evidence to
establish my obligation to the Company in any legal proceedings relating thereto.

It is expressly warranted and agreed that no promise or agreement not herein expressed has been made to me, and in

executing this release | am not relying upon any statement or representation made by anyone who has acted for the ‘Company
or on its behalf, but T am relying solely upon my own judgment.

In witness whereof, Ihave hereunto set my hand and seal this XOW day of Wor cla 20 19.
(SIGNATURE) Jes < 4 gel Alon: 6
a
SEALED AND DELIVERED IN THE PRESENCE OF
Witness! Bj :
Address JS N99 Gol Gn allen TY
“eX; .

Stateof__
County Ne a

‘On this 90) day of VMONC _.in the year two thousand and _ OVA, before me
personally cume and appeared S ‘Ss _____the person described in and who
executed the foregoing instrument, and he (or she) acknowledged to me that pg (orghe) executed the same, k\

NSO
Official Title

MEMBER NATIONAL IN! ICE

y, JATZIRY LETICIA TREVINO
Notary Public, State of Texas}
25 Comm. Expires 12-29-2020

Notary 1D 12506252-7Electronically Submitted
°-°B Rafe 0010:55 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

From:J Gonzalez Law Firm 9564+630+6777 03/20/2019 15:51 #552

KNOW ALL MEN BY THESE PRESENTS Claim Number 0508433250101144 / 1633

That 1, Janie Landa, Of the City of San Juan State of Texas, being of Majority Age, for and in consideration of eight
thousand dollars and 00/100($8,000.00) the receipt whereof is hereby acknowledged, do release and forever discharge
GEICO County Mutual Insurance Company, hereinafter referred to as the Company, from any and all liability under the
Uninsured Motorists Coverage of policy number| issued in the name of Janie Rosie Landa, by the Company
resulting from an accident which occurred on or about the 26th day of October, 2018, at or near San Juan, TX. It is
understood and agreed that this is a full and final settlement of all claims for death, injuries, loss or damage, known and
unknown, Janie Landa may have under the Uninsured Motorist Coverage of > aa issued in the name of
Janie Rosie Landa by the Company.

HEREBY REPRESENT AND COVENANT THAT:

(1) No settlement or agreement has been made or will be made by me or in my behalf with any person or
organization other than the Company affecting Liability to me for loss or damage resulting from the
above described accident, and no release, receipt, covenant or agreement of any kind has been made or
given by me or in my behalf or will in the future be made or given by me or in my behalf, without the
written consent of the Company.

No determination, award, verdict or judgment has been made relating to my damages or injuries
resulting from the above described accident by any arbitrators, referee, Commission or Court.

No Workmen’s Compensation benefits of any kind, either financial or medical care or treatment, have
been received by me or in my behalf, nor has any claim been made or petition filed by me or in my behalf
under any Workmen’s Compensation Act, as a result of the above described accident, and that, to the
best of my information and belief, suid accident did not arise out of and in the course of my employment
with my employer.

It is expressly warranted and agreed that no promise or agreement not herein expressed has been made to me, and in
executing this release I am not relying upon any statement or representation made by anyone who has acted for the Company
or on its behalf, but am relying solely upon my own judgment.

In witness whereof, I have hereunto set my hand and seal this

(SIGNATURE),

(SIGNATURE) oe
SEALED DBLIVIRED IN THE PRESENCE OF
Wiens Sh Tee ids _
Address, Aled Oaica Aue ECA Tx
State of. OOS a
County.

On this day of” TAGYCV\ _inthe year two thousand and _QO\O)_ defore me
Xe

personally came and appeared “Wak OWA, _the person described in and who

executed the foregoing instrument, and he (or she) acknowledged to me that he (or ghe) executed the same. wh
Ss a A K ea RAK) | 1 Ve
ial Title

MEMBER NATIONAL INSIA ra RATA TREVINO
Notary Public, State of Texas|
‘Comm. Expites 12-29-2020

Notary 1D 12506252-7

WeltFrom:J Gonzalez Law Firm

Electronically Submitted
PB granyna01 0:55 AM

Hidalgo County Clerk
Accepted by: Alma Navarro

956463046777 03/20/2019 16:52 #552

KNOW ALL MEN BY THESE PRESENTS:

RELEASE AND TRUST AGREEMENT
Claim Number 0508433250101144 / 3633

That I, Clemencia Tapia, Of the City of Edinburg State of Texas, being of Majority Age, for and in consideration of eight
thousand two hundred dollars and 00/100($8,200.00) the receipt whereof is hereby acknowledged, do release and forever
discharge GEICO County Mutual Insurance Company, hereinafter referred to as the Company, from any and all liability
under the Uninsured Motorists Coverage of policy number issued in the name of Janie Rosie Landa, by the
Company resulting from an accident which occurred on or about the 26th day of October, 2018, at or near San Juan, TX. It
is understood and agreed that this is a full and final settlement of all claims for death, injuries, loss or damage, known and
unknown, Clemencia Tapia may have under the Uninsured Motorist Coverage of policy issued in the name of
Janie Rosie Landa by the Company.

THEREBY REPRESENT AND COVENANT THAT

No determination, award, verdict or judgment has been made relating to my damages or inju

Case Info

Judge

O'Cana-Olivarez, Patricia Track Judge’s New Case

Case No.

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Document Filed Date

June 24, 2020

Case Filing Date

July 22, 2019

County

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Motion,Ex Parte: GEICO COUNTY MUTUAL INSURANCE COMPANY VS. SANDRA YADIRA VELA AGUIRRE, SUSAN GALVAN OLVERA

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