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Contract No. (o09 loO
CAUSE NO. 352-347354-23
ST ATE FARM MUTUAL
AUTOMOBILE INSURANCE
COMPANY AS SUBROGEE OF
JOE THRASHER
Plaintiff
v.
CITY OF FORT WORTH
Defendant
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IN THE DISTRICT COURT
352ND DISTRICT COURT
TARRANT COUNTY, TEXAS
PROPERTY DAMAGE RELEASE
WHEREAS, STATE FARM MUTUAL INSURANCE COMPANY A/S/O JOE
LAYTON THRASHER, hereinafter sometimes referred to as Plaintiff, alleges that its
policyholder's vehicle, a 2018 HYUNDAI SANTA FE VIN 5XYZT3LB2JG559087,
was damaged as a result of an accident that occurred on or about SEPTEMBER 29, 2022,
at or near FORT WORTH, TEXAS.
WHEREAS, Plaintiff has asserted a claim against the City of F01t Worth,
hereinafter sometimes referred to as the City, for monetary damages alleging that the
damage to its policyholder's vehicle was proximately caused by the negligence or other
fault of the City of Fort W 01th or one of its officers, agents, or employees; and,
WHEREAS, while the City of Fort Worth denies that the alleged damage to
Plaintiffs policyholder's vehicle was caused by any negligence or other fault of the City
or its officers, agents or employees, it has agreed to pay, and Plaintiff has agreed to accept,
the total sum of $19,364.78 in full and final settlement of any and all property damage
claims of Plaintiff against the City of Fort W01th, its officers, agents and employees and
all other persons and entities in privity with, or connected with, the City of Fort Wmth,
hereinafter sometimes referred to as the Released Parties, as a result of the accident
mentioned above.
NOW, THEREFORE:
STATE FARM MUTUAL INSURANCE COMPANY A/S/O JOE LAYTON
THRASHER, in consideration of the payment of $19,364.78 paid to it by the City ofF01t
Wmth, the receipt and sufficiency of which are hereby acknowledged, does hereby fully
and finally release the City of Fmt W01th and its officers, agents and employees and all
OfflCiAL RECORD
C SEC RETARY
fT. WO RTH, TX
other persons and entities in privity with, or connected with, the City of Fort Worth of and
from any property damage claim, whatsoever, it has against the City on the date of the
signing of this Release or that may hereafter accrue as a result of the damage to its
policyholder's vehicle mentioned above including, but not limited to, cost of repair, loss of
use, diminution in value and all property damage claims , that were asserted or could have
been asserted by claimant.
STATE FARM MUTUAL INSURANCE COMPANY A/S/O JOE LAYTON
THRASHER, represents that it is the sole owner of the claims being released. This release
is not intended to preclude or release any claims asserted by Joe Layton Thrasher
individually for the above referenced loss.
Plaintiff agrees to dismiss the cause of action in the above-entitled and numbered
matter, with prejudice, and hereby authorizes and directs its attorney, Matthew D. Warner,
to prepare and file the appropriate Motion and Order of Dismissal, with prejudice, with
respect to State Farm Mutual Insurance Company A/S/0 Joe Layton Thrasher's claims and
causes of action in the above entitled and numbered case against the City. And, in this
connection, Plaintiff State Farm Mutual Insurance Company A/S/0 Joe Layton Thrasher
and its attorney agree to expeditiously provide any information the Court may require,
and/or to attend any hearings the Court may require, in connection with the dismissal of
said lawsuit.
It is understood and agreed that all taxable court costs will be paid by the party
incurring same.
I, THE AUTHORIZED REPRESENTATIVE OF STATE FARM MUTUAL
INSURANCE COMP ANY A/S/O JOE LAYTON THRASHER, whose signature is
affixed below acknowledge that I have read this Release in its entirety and have had an
opportunity to consult with an attorney before signing it. I agree that this Release shall be
construed as a whole according to its fair meaning and shall not be construed strictly for or
against either party. I further represent that I am, in all things , authorized to agree to this
Property Damage Release on behalf of STATE FARM MUTUAL INSURANCE
COMP ANY A/S/O JOE LAYTON THRASHER.
Release of Property Damage Claim
Cause No. 352-347354-23; State Farm v. City of Fort Worth Page 2 of 4
STATE OF TEXAS §
COUNTY OF J:ARRANTCcf/, n §
~--i_
AUTHORIZED REPRESENTATIVE
OF STATE FARM MUTUAL INS. CO.
A/S/O JOE LAYTON THRASHER,
Plaintiff
Date:_)_· -_}cf_,,.._) {}J......____L/ _
1 A BEFORE ME, the undersigned authority, on this day personally appeared
;v,t ~J.J.he<,J I) h/c.rtv'-J AUTHORIZED REPRESENTATIVE
OF STATE FARM MUTUAL INS. CO. A/S/O JOE LAYTON THRASHER known
to me to be the person whose name is subscribed to the foregoing instrument, and
acknowledged to me that she executed the same as her free act and deed for purposes and
consideration therein expressed.
GIVEN UNDER MY HAND AND SEAL OF OFFICE this L2 fl1t ay of fe ~(\,(/
2024.
Release of Property Damage Claim
Cause No . 352-347354-23; State Farm v. City of Fort Worth
NICOLETTE C. ECKHART
My Nolary ID# 10336335
Expires October 23, 2027
Page 3 of 4
APPROVED:
(\~
Attorney for Plaintiff
Matthew D. Warner
Carpenter & Schumacher, P.C.
CITY OF FORT WORTH:
APPROVED:
Assistant City Mana r
CITY OF FORT W
APPROVED:
Attorney for Defendant, City of Fort Worth
Harvey L. Frye Jr.
Sr . Assistant City Attorney
ATTEST:
Date:
Date: 2 //'f'g__o L'/
I
Date:
Release of Property Damage Claim~!l. X~~❖-<>-¢
Cause No . 352-347354-23; State Farm v. City of}~~J_ _ _ ----i
i OFFICIAL RECORD
CJN SECRETARY
fT. WORTH, TX
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