Case 3:24-cv-00013-B-BK Document 13 Filed 07/07/24 Page 1 of 2 PageID 38 UNITED STATES DISTRICT COURT FOR NORTHERN DISTRICT OF TEXAS SOUTHWEST MARINE & GENERAL INSURANCE COMPANY, as assignee and No. 3:24-cv-00013-B subrogee of My Community Credit Union, Plaintiff, v. TAMMION VALENTINE and VALENTINE TRAVEL EXPRESS LLC, Defendants. PLAINTIFF’S REQUEST TO DISMISS DEFENDANT, VALENTINE TRAVEL EXPRESS LLC WITHOUT PREJUDICE AND FOR DEFAULT JUDGMENT TO BE ENTERED AGAINST DEFENDANT, TAMMION VALENTINE Plaintiff, Southwest Marine & General Insurance Company, by and through its attorneys, McElroy, Deutsch, Mulvaney & Carpenter, LLP, requests that this Honorable Court (1) dismiss the claims against Defendant, Valentine Travel Express LLC, without prejudice; and (2) enter default judgment in its favor and against Defendant, Tammion Valentine, as set forth in Plaintiff’s Motion for Default Judgment (Docket No. 11) which remains pending. McELROY, DEUTSCH, MULVANEY & CARPENTER, LLP Dated: July 3, 2024 By: /s/ Matthew A. Lipman Matthew A. Lipman, Esq. 1617 JFK Boulevard, Suite 1500 Philadelphia, Pennsylvania 19103-1815 Telephone: (215) 557-2900 Facsimile: (215) 557-2990 mlipman@mdmc-law.com Attorneys for Plaintiff, Southwest Marine & General Insurance Company Case 3:24-cv-00013-B-BK Document 13 Filed 07/07/24 Page 2 of 2 PageID 39 UNITED STATES DISTRICT COURT FOR NORTHERN DISTRICT OF TEXAS SOUTHWEST MARINE & GENERAL INSURANCE COMPANY, as assignee and No. 3:24-cv-00013-B subrogee of My Community Credit Union, Plaintiff, v. TAMMION VALENTINE and VALENTINE TRAVEL EXPRESS LLC, Defendants. CERTIFICATE OF SERVICE I hereby state that on July 3, 2024, I served a true and correct copy of the foregoing documents on the following via first class mail: Ms. Tammion Valentine 12701 Purdue Drive Balch Springs, TX 75180 Valentine Travel Express LLC c/o Tammion Valentine 12701 Purdue Drive Balch Springs, TX 75180 By: /s/ Matthew A. Lipman Matthew A. Lipman, Esquire