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Plaintiff's motion to dismiss pursuant to settlement
IN THE UNITED STATES DISTRICT
FOR THE __________ DISTRICT OF TEXAS
__________ DIVISION
________, §
§
Plaintiff, § §
§ Civil Action No. ____________
v. §
§
________ §
§
Defendant. §
PLAINTIFF’S MOTION TO DISMISS
PURSUANT TO SETTLEMENT
TO THE HONORABLE U.S. DISTRICT JUDGE:
COMES NOW, __________, Plaintiff, and files her Motion to Dismiss her claims against Defendant __________, pursuant to the settlement reached between the parties, which disposes of all claims and causes of action between the parties.
Plaintiff __________ requests that the Court enter its Order of Dismissal with prejudice to the refilling of same submitted contemporaneously with this Motion.
Respectfully submitted,
___________________________________
ATTORNEY FOR PLAINTIFF
CERTIFICATE OF CONFERENCE
This is to certify that prior to the filing of the foregoing Motion to Dismiss, a conference was held with Defendant’s counsel of record regarding the foregoing Motion, who is not opposed to the relief requested.
_________________________
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I hereby certify that a...
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- Substantive
- Notice of intent to use discovery products
- Plaintiff's original petition
- Petition to compel arbitration (State Court)
- General complete release in favor of defendant (with mutuality option)
- Defendant's standard brief in support of motion to compel arbitration, dismiss and stay proceedings (State Court)
- Motion to compel arbitration, dismiss, and stay (State Court)
- Defendant's standard brief in support of motion to stay pending arbitration (Federal Court)
- Settlement agreement and release (includes owbpa language)
- Affidavit - Discovery Authentication
- Motion to stay pending arbitration, alternatively motion to dismiss (Federal Court)
- Special exception & answer (State Court)
- Defendant's motion for summary judgment: mitigation of damages
- Separation and release agreement (for unrepresented employee)
- Consolidation Motion (Fed.)
- Unopposed Mtn Expedite 5th Cir. Appeal
- Brief supporting MTN to expedite appeal
- Brief for emer. MTN for temp stay pend appeal to fifth circuit
- Emergency MTN for temp stay pending appeal to 5th CIR
- AFFIDAVIT-Business Records
- Opposition to MTN. To vacate arbitration award; MTN and brief to confirm arbitration award
- Order granting objections to summary judgment evidence
- AFFIDAVIT - Authentication of deposition excerpts
- Defendant's motion for summary judgment: after-acquired evidence, wrongful discharge, constructive discharge, IIED, retaliation, whistleblowing
- Response to EEOC Charge of Discrimination
- Joinder in/ consent to removal
- Plaintiff’s Original Petition-Sabine Pilot/Refusal to Perform Illegal Act
- Plaintiff's original petition-FMLA, ADEA
- Plaintiff's brief in support of motion for summary judgment-adea-federal court
- Plaintiff's petition - employment agreement - FRAUD
- Plaintiff's petition - workers' compensation retaliation
- Plaintiff's letter brief-gender discrimination-cat's paw doctrine
- Plaintiff's response to defendant employer's motion for summary judgment - workers' compensation retaliation case
- Defendant's plea to jurisdiction
- Defendant's motion to dismiss for lack of subject matter jurisdiction and supporting brief - title VII - Federal Court
- Order of dismissal
- Amended complaint - TCHRA - age discrimination
- Motion for summary judgment (by employer) for false imprisonment and breach of contract
- Plaintiff's motion to dismiss pursuant to settlement
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