Electronically Filed
`1/5/2024 1:08 PM
`Hidalgo County District Clerks
`Reviewed By: Arlene Villarreal
`
`CAUSE NO. C-4241-17-J
`DAVID ROJAS INDIVIDUALLY and
`IN THE DISTRICT COURT
`D/B/A AUTOMATION STATION, LLC,
`PZaim‘zff,
`
`§
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`§
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`§
`§
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`§
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`430” JUDICIAL DISTRICT
`
`HIDALGO COUNTY, TEXAS
`
`§ §
`
`
`
`V.
`ERIC RUBIO and PANASONIC
`CORPORATION OF NORTH
`AMERICA D/B/A PANASONIC
`AUTOMOTIVE SYSTEMS COMPANY
`OF AMERICA,
`Defendants.
`
`AGREED MOTION TO DISMISS WITH PREJUDICE
`TO THE HONORABLE JUDGE OF SAID COURT:
`NOW COME Plaintiffs DAVID ROJAS INDIVIDUALLY and D/B/A AUTOMATION
`STATION, LLC, and Defendants PANASONIC CORPORATION OF NORTH AMERICA
`D/B/A PANASONIC AUTOMOTIVE SYSTEMS COMPANY OF AMERICA and file this
`Agreed Motion to Dismiss with Prejudice and would show the Court as follows:
`Plaintiffs DAVID ROJAS INDIVIDUALLY and D/B/A AUTOMATION STATION,
`LLC hereby moves this Court to dismiss their claims against Defendants PANASONIC
`CORPORATION OF NORTH" AMERICA D/B/A PANASONIC AUTOMOTIVE SYSTEMS
`COMPANY OF AMERICA with prejudice as to the refiling of same.
`WHEREFORE PREMISES CONSIDERED, Plaintiffs DAVID ROJAS
`INDIVIDUALLY and D/B/A AUTOMATION STATION, LLC and Defendants PANASONIC
`CORPORATION OF NORTH AMERICA D/B/A PANASONIC AUTOMOTIVE SYSTEMS
`COMPANY OF AMERICA pray that this Court grant their Agreed Motion to Dismiss, that this
`Court dismiss Plaintiffs David Rojas Individually and D/B/A Automation Station, LLC’s claims
`
`against Defendants with prejudice and for any further relief to which they may be entitled. The
`
`Page I of3
`
`
`1/5/2024 1:08 PM
`Hidalgo County District Clerks
`Reviewed By: Arlene Villarreal
`
`CAUSE NO. C-4241-17-J
`DAVID ROJAS INDIVIDUALLY and
`IN THE DISTRICT COURT
`D/B/A AUTOMATION STATION, LLC,
`PZaim‘zff,
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`430” JUDICIAL DISTRICT
`
`HIDALGO COUNTY, TEXAS
`
`§ §
`
`
`
`V.
`ERIC RUBIO and PANASONIC
`CORPORATION OF NORTH
`AMERICA D/B/A PANASONIC
`AUTOMOTIVE SYSTEMS COMPANY
`OF AMERICA,
`Defendants.
`
`AGREED MOTION TO DISMISS WITH PREJUDICE
`TO THE HONORABLE JUDGE OF SAID COURT:
`NOW COME Plaintiffs DAVID ROJAS INDIVIDUALLY and D/B/A AUTOMATION
`STATION, LLC, and Defendants PANASONIC CORPORATION OF NORTH AMERICA
`D/B/A PANASONIC AUTOMOTIVE SYSTEMS COMPANY OF AMERICA and file this
`Agreed Motion to Dismiss with Prejudice and would show the Court as follows:
`Plaintiffs DAVID ROJAS INDIVIDUALLY and D/B/A AUTOMATION STATION,
`LLC hereby moves this Court to dismiss their claims against Defendants PANASONIC
`CORPORATION OF NORTH" AMERICA D/B/A PANASONIC AUTOMOTIVE SYSTEMS
`COMPANY OF AMERICA with prejudice as to the refiling of same.
`WHEREFORE PREMISES CONSIDERED, Plaintiffs DAVID ROJAS
`INDIVIDUALLY and D/B/A AUTOMATION STATION, LLC and Defendants PANASONIC
`CORPORATION OF NORTH AMERICA D/B/A PANASONIC AUTOMOTIVE SYSTEMS
`COMPANY OF AMERICA pray that this Court grant their Agreed Motion to Dismiss, that this
`Court dismiss Plaintiffs David Rojas Individually and D/B/A Automation Station, LLC’s claims
`
`against Defendants with prejudice and for any further relief to which they may be entitled. The
`
`Page I of3
`
`
`
`Electronically Filed
`1/5/2024 1:08 PM
`Hidalgo County District Clerks
`Reviewed By: Arlene Villarreal
`
`Parties further request that all taxable court costs and fees be assessed against the party incurring
`
`same.
`
`Respectfully submitted,
`ESCOBEDO & CARDENAS, LLP
`l602 Dulcinea
`Edinburg, Texas
`Telephone: (956) 630-2222
`Telecopier: (956) 630-2223
`
`By: M Jan gggg
`Joe Escobedo
`State Bar No. 06665850
`joe(d)escobedocardenas.com
`Luis Cardenas
`State Bar No. 24001837
`luis((Descobcdocardenascom
`ATTORNEY FOR DEFENDANT,
`PANASONIC CORPORATION OF NORTH
`AMERICA DBA PANASONIC AUTOMOTIVE
`SYSTEMS COMPANY OF AMERICA
`
`AGREED AS TO SUBSTANCE AND FORM:
`
`LAW OFFICES OF DAMAIN C. VOROZCO, EC.
`1138 E. Expressway 83, Suite C
`Pharr, exas 78577
`~
`Tclephon : (956) 782-5447
`
`~ ~~
`
`~ dO1'OZCO aJorozco—1aw.corn
`
`ATTORNEY FOR PLAINTIFF
`
`Page 2 of3
`
`
`
`Electronically Filed
`1/5/2024 1:08 PM
`Hidalgo County District Clerks
`Reviewed By: Arlene Villarreal
`
`CERTIFICATE OF SERVICE
`I hereby certify that a true and correct copy of the foregoing served on the following
`counsel of record on the 5“‘ day of January, 2024:
`
`Via E-Service
`Damian C. Orozco
`LAW OFFICES OF DAMIAN C. OROZCO, PC
`1138 E. Expressway 83, Suite C
`Pharr, Texas 78577
`
`/¢/ .4m
`Luis Cardenas
`
`Page 3 of3
`
`
`
`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.
`Cathy Gonzalez on behalf of Luis Cardenas
`Bar No. 24001837
`cathy@escobedocardenas.com
`Envelope ID: 83127393
`Filing Code Description: Motion (No Fee)
`Filing Description: Agreed Motion to Dismiss with Prejudice
`Status as of 1/5/2024 1:33 PM CST
`
`Case Contacts
`
`Name
`Jose Escobedo
`
`BarNumber
`6665850
`
`esther@escobedocardenas.com
`
`TimestampSubmitted
`1/5/2024 1:08:06 PM
`
`Status
`SENT
`
`Associated Case Party: DAVID ROJAS INDIVIDUALLY AND D/B/A AUTOMATION
`STATION L.L.C.
`
`Name
`DAMIAN OROZCO
`JOSE ESCOBEDO
`Cristal Gonzalez
`Alex Hernandez
`The Law Office of Damian COrozco
`Law Office of Damian C.Orozco
`
`BarNumber Email
`dorozco@orozco-law.com
`joe@escobedocardenas.com
`cgonzalez@orozco-law.com
`alexhernandez@alexhernandeztriallaw.com
`cgonzalez@orozco-law.com
`orozcolawoffice@orozco-law.com
`
`TimestampSubmitted
`1/5/2024 1:08:06 PM
`1/5/2024 1:08:06 PM
`1/5/2024 1:08:06 PM
`1/5/2024 1:08:06 PM
`1/5/2024 1:08:06 PM
`1/5/2024 1:08:06 PM
`
`Status
`SENT
`SENT
`SENT
`SENT
`SENT
`SENT
`
`Associated Case Party: PANASONIC CORPORATION OF NORTH AMERICA D/B/A
`PANASONIC AUTOMOTIVE SYSTEMS COMPAN
`
`Name
`LUIS CARDENAS
`Cathy AGonzalez
`Joe Escobedo
`
`BarNumber Email
`luis@escobedocardenas.com
`cathy@escobedocardenas.com
`joe@escobedocardenas.com
`
`TimestampSubmitted
`1/5/2024 1:08:06 PM
`1/5/2024 1:08:06 PM
`1/5/2024 1:08:06 PM
`
`Status
`SENT
`SENT
`SENT
`
`Associated Case Party: ERIC RUBIO
`
`Name
`Alex R.Hernandez
`
`BarNumber Email
`alexhernandez@alexhernandeztriallaw.com
`
`TimestampSubmitted
`1/5/2024 1:08:06 PM
`
`Status
`SENT
`
`
`
`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.
`Cathy Gonzalez on behalf of Luis Cardenas
`Bar No. 24001837
`cathy@escobedocardenas.com
`Envelope ID: 83127393
`Filing Code Description: Motion (No Fee)
`Filing Description: Agreed Motion to Dismiss with Prejudice
`Status as of 1/5/2024 1:33 PM CST
`
`Associated Case Party: ERIC RUBIO
`
`Alex R.Hernandez
`Joe Navarro
`
`alexhernandez@alexhernandeztriallaw.com
`joenavarro@alexhernandeztriallaw.com
`
`1/5/2024 1:08:06 PM
`1/5/2024 1:08:06 PM
`
`SENT
`SENT
`
`
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