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Paez v. Childrens Health System of Texas — Entry #24: Joint MOTION to Dismiss with Prejudice filed by Alexander Paez

Case: Paez v. Childrens Health System of Texas txnd · 3:23-cv-02243

filed October 10, 2023

What this document is

Docket entry #24 · filed September 30, 2024

Joint MOTION to Dismiss with Prejudice filed by Alexander Paez (Attachments: (1) Proposed Order) (Gasper, Travis)

Who is involved

Why we have it

We follow this case because it names a company we track, although that company is not a party:

A free copy from the RECAP archive of federal court filings (mirrored at the Internet Archive), retrieved October 23, 2026. Federal court filings are public records.

URL
https://archive.org/download/gov.uscourts.txnd.382062/gov.uscourts.txnd.382062.24.0.pdf
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RECAP
Published
2024-09-30 00:00:00-04:00
Retrieved
2026-10-23 06:52:16.586781-04:00
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Document text

2 page(s), 3,283 characters, converted from the PDF's text layer · plain text.

Full text
Case 3:23-cv-02243-E Document 24 Filed 09/30/24              Page 1 of 2 PageID 128


                      IN THE UNITED STATES DISTRICT COURT
                      FOR THE NORTHERN DISTRICT OF TEXAS
                                DALLAS DIVISION
ALEXANDER PAEZ,                               §
                                              §
               Plaintiff,                     §
                                              §
v.                                            §         Civil Action No. 3:23-cv-2243-BW
                                              §
CHILDREN’S HEALTH SYSTEM OF                   §
TEXAS,                                        §
                                              §
               Defendant.                     §

                    JOINT MOTION TO DISMISS WITH PREJUDICE

        Pursuant to the Federal Rules of Civil Procedure, Plaintiff Alexander Paez and Defendant

Children’s Health System of Texas (jointly, the “Parties”) file this Joint Motion to Dismiss with

Prejudice. The Parties respectfully request that the Court enter an order providing that (1) all

claims in this case are dismissed with prejudice to the refiling of same in any form, and (2) all

costs and attorneys’ fees are to be paid by the party incurring same, as provided in the

accompanying Agreed Order of Dismissal.

Respectfully submitted,

GASPER LAW PLLC                                   OGLETREE, DEAKINS, NASH, SMOAK &
                                                  STEWART, P.C.
/s/ Travis Gasper
Travis Gasper                                     By: /s/ Jamie Ashton (with permission)
Texas Bar No. 24096881                                Jamie Ashton
[email protected]                               Texas State Bar No. 24087211
1408 N. Riverfront Blvd., Suite 323                   [email protected]
Dallas, Texas 75207                                   Molly Ann Lawrence
Telephone: (469) 663-7736                             Texas State Bar No. 24083365
Facsimile: (833) 957-2957                             [email protected]
                                                      8117 Preston Road, Suite 500
ATTORNEY FOR PLAINTIFF                                Dallas, Texas 75225
                                                      Telephone: (214) 987-3800
                                                      Facsimile: (214) 987-3927

                                                  ATTORNEYS FOR DEFENDANT

JOINT MOTION TO DISMISS WITH PREJUDICE                                                     PAGE 1


   Case 3:23-cv-02243-E Document 24 Filed 09/30/24                Page 2 of 2 PageID 129


                                CERTIFICATE OF SERVICE

        I hereby certify that on September 30, 2024, I electronically filed the foregoing with the
Clerk of Court using the CM/ECF system, which will transmit a Notice of Electronic Filing to all
parties of record.

                                             /s/ Travis Gasper
                                             Travis Gasper


JOINT MOTION TO DISMISS WITH PREJUDICE                                                     PAGE 2
                                                                              64437733.v1-OGLETREE