LULAC Sues Linda Chavez Et Al and More Again

CAUSE NO.______________ LEAGUE OF UNITED LATIN AM ERICAN CITIZENS, INC. Plaintiff, V.
FLORINDA CHAVEZ, ALBA M ARTINEZ, JOE CARDENAS, ROBERT W . W ILSON, C & C INSURANCE SERVICES, INC., AND LUZ STELLA CUELLAR Defendants. OF BEXAR COUNTY, TEXAS IN THE COUNTY COURT
AT LAW NO. ______
PLAINTIFFS ORIGINAL PETITION TO THE HONORABLE COURT: COMES NOW , LEAGUE OF UNITED LATIN AMERICAN CITIZENS, INC., Plaintiff in the above styled and numbered cause, complaining of Defendants, FLORINDA CHAVEZ, ALBA MARTINEZ, JOE CARDENAS, ROBERT W . W ILSON, C & C INSURANCE SERVICES, INC., AND LUZ STELLA CUELLAR, (hereafter called as a group Defendants), and would respectfully show the Court the following: I. DISCOVERY PLAN 1.1. LEAGUE OF UNITED LATIN AMERICAN CITIZENS, INC. affirmatively pleads that it seeks only monetary relief aggregating $100,000.00 or less, excluding costs, prejudgment interest, and attorneys fees under Texas Rules of Civil Procedure Rule 190.2 (Level 2). II. PARTIES 2.1. LEAGUE OF UNITED LATIN AMERICAN CITIZENS, INC. (hereafter called LULAC) is an nonprofit organization doing business in Bexar County, Texas. 2.2. FLORINDA CHAVEZ (hereafter called CHAVEZ) is an individual residing at 5400 Jeffburn Cove , Austin, Texas 78745 and may be served with process at that address. 2.3. BEATRICE ALBA MARTINEZ (hereafter called MARTINEZ) is an individual residing at 7007 Arboreal, Dallas Texas 75231 and may be served with process at that address. 2.4. JOE CARDENAS (hereafter called CARDENAS) is an individual residing in Lousie, Texas 77455 and may be served with process at P.O. Box 29, Lousie, Texas 77455. 2.5. ROBERT W . W ILSON (hereafter called W ILSON) is an individual residing in Bexar County, Texas and may be served with process via certified mail returned receipt requested at 115 E. Travis, Suite 1900, San Antonio, Texas 78212. 2.6. C & C INSURANCE SERVICES, INC. (Hereafter called C & C) is a corporation doing business
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in Sugar Land, Texas and may be served with process via certified mail returned receipt requested by serving its agent LUZ STELLA CUELLAR at 4511 Collington Court, Missouri City, Texas 77459. 2.7. LUZ STELLA CUELLAR (hereafter called CUELLAR) is an individual residing at Sugar Land, Texas and an owner of C & C INSURANCE SERVICES, INC. at 4511 Collington Court, Missouri City, Texas 77459. and may be served with process at that address. III. VENUE AND JURISDICTION 3.1. Jurisdiction is proper in this Court pursuant to Section 25.000. of the Texas Government Code. The amount of damages claimed by LULAC in this case is within the jurisdictional limits of this Court. 3.2. Venue is proper in Bexar County pursuant to Section 15.002 of the Texas Civil Practice & Remedies Code because the principal offices and residence of Defendant, ROBERT W . W ILSON , are maintained in Bexar County and all or a substantial part of the events giving rise to LULACs claims occurred in Bexar County. IV. FACTUAL BACKGROUND 4.1. LULAC is a non-profit organization duly organized in accordance with the United States of America statutes and the State of Texas statutes. LULAC has a chapter based in Texas with their current principal office in San Antonio, Texas. 4.2. The Texas chapter of LULAC has a Board of Directors duly elected by the Texas LULAC states members. The Texas chapters Board of Directors is compose by the following: State Director; Deputy State Director; State Secretary; State Treasurer; Immediate Past Director; Deputies for the Elderly, W oman, Young Adults, and Youth; Twenty-one (21) District Directors; and several appointed officers. Any and all actions taken by the members of the Board of Directors are in need of approval of the Board in order for those action to be sanction and be conducted on behalf of LULAC. 4.3. Texas LULAC chapter owed an insurance policy with PHILADELPHIA, policy number PHSD683987 that would provide coverage to any member of the Board of Directors in the event that a lawsuit is filed against a member of the Board for claims directly related and as a result of the members official duties while performing the duties of his/her office. The insurance agents for Plaintiffs regarding the services for the insurance policy was Defendants C & C and CUELLAR. 4.4 LULAC sued Defendants CHAVEZ, MARTINEZ, and CARDENAS in Federal Court under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division, claiming that these Defendants committed copy rights infringement and other causes of actions after these Defendants incorporated, in Texas, an organization named TX LULAC. Defendants CHAVEZ, MARTINEZ, and CARDENAS where sued in their individual capacity. LULACs claims where not based as a result of Defendants CHAVEZ, MARTINEZ, and/or CARDENAS duties and/or responsibilities as members of or past members of Texas chapters Board of Directors. Defendants CHAVEZ, MARTINEZ, and CARDENAS were sued in their individual capacity and were represented by Defendant W ILSON. 4.5. On or about July 31, 2012, Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON with the assistance of Defendants C & C and CUELLAR filed and opened a claim against Texas chapters insurance carrier, Philadelphia Insurance Company (hereafter called PHILADELPHIA) regarding the suit filed by LULAC against Defendants CHAVEZ, MARTINEZ, and CARDENAS. Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON with the assistance of Defendants C & C and CUELLAR claimed coverage under the policy regarding the suit filed against them by Plaintiffs in the federal suit.
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4.6. The claim number generated by PHILADELPHIA was PHFF12070652315. Defendants CHAVEZ, M ARTINEZ, CARDENAS claimed coverage for their damages and Defendant W ILSON claimed coverage for his attorneys fees for the representation contracted by Defendants CHAVEZ, MARTINEZ, and CARDENAS. 4.7. Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON knew that the PHILADELPHIA policy was Plaintiffs policy. Even though they knew that the policy was Plaintiffs they filed claims against the policy without Plaintiffs knowledge. Defendants CHAVEZ, MARTINEZ, and CARDENAS claimed coverage under Plaintiffs policy for a $ 15,000.00 judgment against them and in favor of Plaintiff under the Federal Suit. Defendant W ILSON claimed coverage for attorneys fees in excess of $ 12, 000.00 for his representation of Defendants CHAVEZ, MARTINEZ, and CARDENAS under the federal suit. 4.8. Defendants C & C and CUELLAR are Plaintiffs agent and the person and entity that Plaintiff hired to provide insurance coverage for Plaintiff. Defendants C & C and CUELLAR knew that the PHILADELPHIA policy was Plaintiffs policy. Even though they knew that the policy was Plaintiffs they filed claims against the policy without Plaintiffs knowledge. Defendants C & C and CUELLAR knew the terms of the policy and knew that Defendants CHAVEZ, MARTINEZ, and CARDENAS were not entitled to coverage. Defendants C & C and CUELLAR never contacted Plaintiff to informed and/or confirm the claims made by Defendants CHAVEZ, M ARTINEZ, CARDENAS, and W ILSON. 4.9. On or about February 15, 2013, PHILADELPHIA paid a total of $ 38,255.84 to and/or on behalf of Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON and a third party law firm representing PHILADELPHIA. 4.10. On or about October 24 th, 2013, Elia Mendoza who is the current State Director for the Texas chapter, received a Notice of Cancellation from Defendants C & C and CUELLAR. PHILADELPHIA and Defendants C & C and CUELLAR informed Ms. Mendoza that the insurance policy was going to be cancelled as of December 31, 2013. This was the first time Plaintiff knew about the claimed filed by Defendants. Ms. Mendoza was informed that the reason for cancellation was the claim filed by all Defendants. Defendants C & C and CUELLAR also informed Ms. Mendoza that they would no longer be Plaintiffs agent or would be assisting to secure a new policy. Plaintiff is now without insurance coverage ass of the time this suit was filed. Plaintiff has suffered damages as a result of Defendants action for which now suit. 4.11. Defendants C & C and CUELLAR were asked by Plaintiff to provide any and all documents regarding Plaintiffs insurance policy and the claims made by Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON. Defendants C & C and CUELLAR refused to provide documents and as of the date of the filing of this suit Defendants C & C and CUELLAR has never provided any documents to Plaintiff regarding Plaintiffs policy other than the notification of cancellation issues by PHILADELPHIA. 4.12. As a result of Defendants actions Plaintiff suffered damages. V. TORTUOUS INTERFERENCE W ITH PROSPECTIVE, PRESENT, AND/OR FUTURE CONTRACTUAL RELATIONSHIP 5.1. Plaintiff incorporates by reference those paragraphs set out above as if fully set forth herein and further allege as follows: 5.2. Defendants, Defendants agents, servants and/or employees willfully and intentionally interfered with Plaintiffs prospective, present, and/or future contractual relations with PHILADELPHIA by filing fraudulent claims against Plaintiffs insurance policy causing PHILADELPHIA to cancel coverage of the insurance policy and using undue influence and/or fraud in the inducement to wrongfully and unjustly enriched themselves at the expense of Plaintiffs. As a result of Defendants interference with Plaintiffs prospective, present, and future contractual relations, Plaintiffs have sustained economic as well as other damages.
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VI. UNJUST ENRICHM ENT 6.1. Plaintiff incorporates by reference those paragraphs set out above as if fully set forth herein and further allege as follows: 6.2. Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON by way of aforementioned fraud, misrepresentations, breach of fiduciary duty and other illegal compulsion and conduct has misled Plaintiffs insurance carrier as to enter into agreements with Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON at the expense and detriment of Plaintiff. 6.3. Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON should not be permitted to unjustly enrich themselfs at the expense of Plaintiff. Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON should be required to make restitution for the property and/or monetary benefits and other benefits received, retained, and wrongly appropriated on from Plaintiff insurance carrier. 6.4. Furthermore, it is only just and equitable that Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON make restitution to Plaintiff, particularly when Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON intentionally and knowingly benefitted by receiving monetary payments from Plaintiffs insurance carrier which in justice and equity belong to Plaintiff. Plaintiff is entitled to restitution from Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON for part or all such monetary benefits wrongfully obtain. VII. FRAUD AND FRAUD IN THE INDUCEM ENT 7.1. Plaintiff incorporates by reference those paragraphs set out above as if fully set forth herein and further allege as follows: 7.2. Defendants made false and fraudulent misrepresentations to Plaintiff, including, but not limited to, representations that the payments made to Plaintiff as a result of the judgment in the federal suit was made from Defendants CHAVEZ, MARTINEZ, and CARDENAS funds and/or individual insurance coverage. 7.3. These representations and omissions were made directly by Defendants CHAVEZ, MARTINEZ, and CARDENAS, and other authorized agents of said Defendants, including Defendant W ILSON. 7.4. W hen Defendants made the foregoing misrepresentations and omissions, they knew them to be false, and said representations were made by Defendants with the intent to defraud and deceive Plaintiff, Plaintiffs agents, and providers and with the intent to induce Plaintiff not to seek remedies available to them. At all times mentioned herein, Defendant fraudulently concealed from the Plaintiff the true facts relating to their actions and intentions with regard to the above referenced transactions. 7.5. As a result of the foregoing conduct by the Defendants, Plaintiff suffered injuries and damages as alleged herein and request punitive and exemplary damages in such amounts as would punish Defendants for their conduct and act as an example that would deter them, as well as other individuals and/or companies, from engaging in similar conduct in the future. 7.6. Plaintiffs further allege that each and every one of the representations set forth in the preceding paragraphs concerned material facts in that Plaintiff would have taken the appropriate remedies to protect them and Plaintiffs businesses had Plaintiff known about the falsity of the representations and the actions taken by Defendants.
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VIII. NEGLIGENT M ISREPRESENTATION 8.1. Plaintiff incorporates by reference those paragraphs set out above as if fully set forth herein and further alleges as follows: 8.2. Defendants made negligent material, false, and fraudulent misrepresentations to Plaintiff and/or, Plaintiffs agents including, but not limited to, representations that Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON were entitled to the benefits provided by PHILADELPHIA. These representations and omissions were made directly by Defendants, and other authorized agents of said Defendants. W hen Defendants made the foregoing misrepresentations and omissions, they knew them to be false, and said representations were made by Defendants with the intent to defraud and deceive Plaintiffs and with the intent to induce Plaintiffs agents to enter into an agreement with Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON. 8.3. At all times mentioned herein Defendants fraudulently concealed from the Plaintiffs and/or Plaintiffs agents the true facts. Defendants, directly, or by and through, an authorized representative engaged in the aforesaid conduct and ratified all such activities by said agents. Defendants knew, or in the exercise of ordinary care should have known, such representations to be false yet made the representations recklessly and as a positive assertion. 8.4. As a result of the foregoing conduct by the Defendant, Plaintiffs suffered injuries and damages as alleged herein and request punitive and exemplary damages in such amounts as would punish Defendant for the conduct and act as an example that would deter Defendant, as well as others, from engaging in similar conduct in the future. IX. BREACH OF FIDUCIARY DUTY 9.1. Plaintiff incorporates by reference those paragraphs set out above as if fully set forth herein and further alleges as follows: 9.2. Defendants C & C and CUELLAR, as Plaintiffs insurance agents, had a fiduciary relationship with a fiduciary duty to Plaintiff. As a result of their fiduciary relationship, Plaintiff reposed a special confidence in Defendants C & C and CUELLAR, and Defendants C & C and CUELLAR had a duty in equity and good conscience to act in good faith and with due regard for the Plaintiffs interests. Defendants C & C and CUELLAR induced and/or aided by Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON, in violation of their duties to Plaintiff, have breached their duty to Plaintiff by: a. b. engaging in a pattern of filing claims against Plaintiffs insurance policy with PHILADELPHIA not authorized by the policy or by Plaintiff; failing to provide documents as requested by Plaintiffs regarding Plaintiffs insurance policy and the claims filed by Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON against Plaintiffs insurance policy; failing to notified Plaintiff that a claim was made by Defendants against Plaintiffs insurance policy; approving or acting on behalf of Plaintiff for the benefit of a third party and/or her individual benefit, including but not limited to the facilitation and assistance on the filing of the claim and assisting Defendants CHAVEZ, MARTINEZ, CARDENAS, and W ILSON converting such insurance policy for their individual benefit; by transferring unauthorized insurance coverage to Defendants CHAVEZ, M ARTINEZ, CARDENAS, and W ILSON; and, by the mismanagement of the Plaintiffs insurance policy with PHILADELPHIA. All of the above actions constitute fraud and/or constructive fraud.
c. d.
d. e. 9.3.
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X. CONVERSION 10.1. Plaintiff incorporates by reference those paragraphs set out above as if fully set forth herein and further alleges as follows: 10.2. Plaintiff was the owner and had the rights, possession, and/or control of the PHILADELPHIA INSURANCE POLICY, Policy Number PHSD683987. Such insurance policy was the personal property of Plaintiff. Defendants CHAVEZ, MARTINEZ, CARDENAS, and WILSON with the inducement and/or aiding of Defendants C & C and CUELLAR, wrongfully exercised dominion and control over Plaintiffs personal property in a manner inconsistent with Plaintiffs rights. 10.3. As a result Plaintiff suffered damages. XI. ACTUAL DAM AGES 11.1. Plaintiffs incorporate by reference those paragraphs set out above as if fully set forth herein and further allege as follows: 11.2. Plaintiffs have suffered actual damages for which they sue in an amount the jury deems reasonable which is in excess of the minimum jurisdictional limits of the Court. XII. EXEM PLARY DAM AGES 12.1. Plaintiffs incorporate by reference those paragraphs set out above as if fully set forth herein and further allege as follows: 12.2. The acts and conduct of the Defendants were willful, negligent and/or intentional acts, committed with actual malice towards Plaintiff, or with a wanton and reckless disregard for the rights of Plaintiff. 12.3. Plaintiffs requests that, in addition to actual economic damages and other compensatory damages prayed for herein, exemplary damages should be assessed against Defendants, jointly and/or severely, and awarded to Plaintiff in the amount of no less than $50,000.00 or found just and right by the trial of facts. XIII. M ISNOM ER AND/OR M ISIDENTIFICATION 13.1. Plaintiffs incorporate by reference those paragraphs set out above as if fully set forth herein and further allege as follows: 13.2. In the event any parties are misnamed or not included herein, it is Plaintiffs contention that such was a misnomer and/or misidentification and/or such parties are/were alter egos of parties named herein. Alternatively, Plaintiffs contends that corporate veils should be pierced to hold such parties properly included in the interest of justice. XIV. ATTORNEYS FEES AND COSTS 14.1. Plaintiffs incorporate by reference those paragraphs set out above as if fully set forth herein and further allege as follows:
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14.2. As a direct result of the actions and/or omissions of the Defendants as described above, Plaintiffs have found it necessary to retain attorneys, ORTIZ LAW OFFICES, P.C. and Miguel A. Ortiz to bring this action on their behalf. Pursuant to 38.001(7) and 38.002 of the Texas Practice & Remedies Code and 37.001 and 37.009 of the Texas Practice & Remedies Code, Plaintiffs are entitled to recover reasonable attorneys fees and costs for which they hereby sue. Plaintiffs request that Defendants cover any and all attorneys fees and expenses for services rendered in connection with this case, judgment for attorney's fees and expenses through final judgment after appeal should be granted against Defendants and in favor of Plaintiffs for the use and benefit of Plaintiffs attorneys; or, in the alternative, Plaintiffs requests that reasonable attorney's fees and expenses through final judgment after appeal be taxed as costs and be ordered paid directly to Plaintiffs attorney, who may enforce the order for fees in the attorney's own name. XV. INTEREST 15.1. Under Texas Finance Code 302.002, interest on open accounts accrues at the rate of 6 percent per annum, commencing on the 30 th day after the date on which the sum is due and payable. 15.2. LULAC is, therefore, entitled to prejudgment and post-judgment interest on the total amounts awarded. XVI. REQUEST FOR DISCLOSURE TO FLORINDA CHAVEZ 16.1. TO: FLORINDA CHAVEZ, 5400 Jeffburn Cove , Austin, Texas 78745.
16.2. Pursuant to rule 194 of the Texas Rules of Civil Procedure, you are requested to disclose, within 30 days after service of this request, the information or material described in rule 194 as set forth in the attached request. The originals or copies of documents and other tangible items requested must be produced for inspection and copying at 909 N.E. Loop 410, Suite 715, San Antonio, TX 78209 within 30 days after service of this request, together with a written response. Each written response must be preceded by the request to which it applies. No objection or assertion of work product privilege is permitted to a request under this rule. If you fail to comply with this request, the court may order sanctions against you in accordance with the Texas Rules of Civil Procedure. Your response must be signed. 16.3. RULE 194 REQUEST
16.3.1. State the correct names of the parties to the lawsuit. 16.3.2. State the names, addresses, and telephone numbers of any potential parties. 16.3.3. State the legal theories and, in general, the factual bases of your claims or defenses. 16.3.4. State the amount and any method of calculating economic damages. 16.3.5. State the names, addresses, and telephone numbers of persons having knowledge of relevant facts, and give a brief statement of each identified person's connection with the case. 16.3.6. For any testifying expert a. b. c. state the expert's name, address, and telephone number; state the subject matter on which the expert will testify; state the general substance of the expert's mental impressions and opinions and a brief summary of the basis for them or, if the expert is not retained by, employed by, or otherwise subject to your control, documents reflecting such information; if an expert is retained by, employed by, or otherwise subject to your control, produce the
d.
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originals or copies of the following: i. all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert's testimony; and, the expert's current resume and bibliography.
ii.
16.3.7. Produce the originals or copies of any indemnity and insuring agreements described in rule 192.3(f) of the Texas Rules of Civil Procedure. Rule 192.3(f) provides in part as follows: Indemnity and Insuring Agreements. Except as otherwise provided by law, a party may obtain discovery of the existence and contents of any indemnity or insurance agreement under which any person may be liable to satisfy part or all of a judgment rendered in the action or to indemnify or reimburse for payments made to satisfy the judgment. 16.3.8. Produce the originals or copies of any settlement agreements described in rule 192.3(g) of the Texas Rules of Civil Procedure. Rule 192.3(g) provides in part as follows: Settlement Agreements. A party may obtain discovery of the existence and contents of any relevant portions of a settlement agreement. 16.3.9. Produce the originals or copies of any witness statements described in rule 192.3(h) of the Texas Rules of Civil Procedure. Rule 192.3(h) provides in part as follows. Statements of Persons with Knowledge of Relevant Facts. A party may obtain discovery of the statement of any person with knowledge of relevant facts - a "witness statement" - regardless of when the statement was made. A witness statement is (1) a written statement signed or otherwise adopted or approved in writing by the person making it, or (2) a stenographic, mechanical, electrical, or other type of recording of a witness's oral statement, or any substantially verbatim transcription of such a recording. Any person may obtain, upon written request, his or her own statement concerning the lawsuit, which is in the possession, custody or control of any party. 16.3.10. State the name, address, and telephone number of any person who may be designated as a third party. XVII. REQUEST FOR PRODUCTION TO FLORINDA CHAVEZ 17.1. TO: FLORINDA CHAVEZ, 5400 Jeffburn Cove , Austin, Texas 78745.
17.2. Please take notice that request is hereby made, pursuant to Rules 192 and 196 of the Texas Rules of Civil Procedure, that FLORINDA CHAVEZ produce to the undersigned attorney for LULAC all documents responsive to the attached Requests for Production of Documents. 17.3. W ithin 30 days after service of this Request for Production of Documents, you shall file a written response stating with respect to each request that documents are being attached as requested unless the request is objected to, in which event the reason for the objection shall be stated. 17.4. DEFINITIONS AND INSTRUCTIONS
17.4.1. As used herein, the terms you and your shall refer FLORINDA CHAVEZ, the attorneys, agents, and all other natural persons or business or legal entities acting or purporting to act for or on behalf of FLORINDA CHAVEZ, whether authorized to do so or not.
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17.4.2. The term documents shall mean all writings of every kind, source, and authorship, both originals and all nonidentical copies thereof; in your possession or known by you to exits, irrespective of whether the writing is one intended for or transmitted internally by you, or intended for or transmitted to any other person or entity, including without limitation any government agency, department, administrative entity, or any private entity, or any person. 17.4.3. A document is deemed to be in your possession, custody or control if you have either actual physical possession of a document or constructive possession of the document. Constructive possession means that you have a superior right to compel the production of such document or a copy thereof from a third party having actual physical possession of the document. 17.4.4. The term shall include handwritten, typewritten, printed, photocopied, photographic, or recorded matter. It shall include communications in words, symbols, pictures, sound recordings, films, tapes, and information stored in, or accessible through, computer or other information storage or retrieval systems, together with the codes and/or programming instructions and other materials necessary to understand and use such systems. For purposes of illustration and not limitation, the term shall include: affidavits; agendas; agreements; analyses; announcements; bills, statements, and other records of obligations and expenditures; books; brochures; bulletins; calendars; canceled checks, vouchers, receipts and other records of payments; charts, drawings; check registers; checkbooks; circulars; collateral files and contents; contracts; corporate by-laws; corporate charters; correspondence; credit files and contents; deeds of trust; deposit slips; diaries, drafts; files; guaranty agreements; instructions; invoices; ledgers, journals balance sheets, profit and loss statements, and other sources of financial data; letters; logs, notes, or memoranda of telephonic or face-to-face conversations; manuals; memoranda of all kinds, to and from any persons, agencies, or entities; minutes; minute books; notes; notices; parts lists; papers; press releases; printed matter (including published books, articles, speeches, and newspaper clippings); purchase orders; records; records of administrative, technical, and financial actions taken or recommended; reports; safety deposit boxes and contents and records of entry; schedules; security agreements; specifications; statement of bank accounts; statements, interviews; stock transfer ledger; technical and engineering reports, evaluations, advice, recommendations, commentaries, conclusions, studies, test plans, manuals, procedures, data, reports, results, and conclusions; summaries, notes, and other records and recordings of any conferences, meetings, visits, statements, interviews or telephone conversations; telegrams; teletypes and other communications sent or received; transcripts of testimony; UCC instruments; work papers; and all other writings, the contents of which relate to, discuss, consider, or otherwise refer to the subject matter of the particular discovery requested. 17.4.5. Person: The term person shall include individuals, associations, partnerships, corporations, and any other type of entity or institution whether formed for business purposes or any other purposes. 17.4.6. Identify or Identification: (1) W hen used in reference to a person, identify or identification means to state his or her full name, present or last known residence address, present or last known business address and telephone number. (2) W hen used in reference to a public or private corporation, governmental entity, partnership or association, identify or identification means to state its full name, present or last known business address or operating address, the name of its chief executive officer and telephone number. (3) following: W hen used in reference to a document, identify or identification shall include statement of the
(a) the title, heading, or caption, if any, of such document; (b) the identifying number(s), letter(s), or combination thereof; if any; and the significance or meaning of such number(s), letter(s), or combination thereof; if necessary to an understanding of the document and evaluation of any claim of protection from discovery; (c) the date appearing on such document; if no date appears thereon, the answer shall so state and shall give the date or approximate date on which such document was prepared; (d) the number of pages and the general nature or description of such document (i.e., whether it
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is a letter, memorandum, minutes of a meeting, etc.), with sufficient particularity so as to enable such document to be precisely identified; (e) the name and capacity of the person who signed such document; if it was not signed, the answer shall so state and shall give the name of the person or persons who prepared it; (f) the name and capacity of the person to whom such document was addressed and the name and capacity of such person, other than such addressee, to whom such document, or a copy thereof; was sent; and (g) the physical location of the document and the name of its custodian or custodians. (4) Unless a specific date or dates is set forth in any specific question herein, you are directed that each question shall be answered for the period of time up to the present date. 17.5. REQUEST FOR PRODUCTION 17.5.1. A copy of all contracts you have entered with any Defendant or for the representation of any Defendant at any time. 17.5.2. A copy of all employment information, including without limitation, wages, salaries, bonuses, stock options, commission, earnings, income, employment contracts, pay raises, promotions, payroll deductions of any kind, credit union accounts, pension plans, pension funds, retirement plans, retirement funds, stock plan and stock fund or other benefits or deductions of any kind which are, were, previously or which may be in the future paid, available, accepted, rejected, credited, offered, withheld for any purpose by any individual, agency, department, company or otherwise, or to which you are, were or may become entitled in the future since January 1st, 2011. 17.5.3. A copy of all records indicating any and all income received by you from any and all sources since January 1st, 2011. 17.5.4. A copy of all savings accounts, credit union or other passbooks of yours, including those held by you in your name or in your name jointly with any person or any entity, or in your name as trustee for any other person, since January 1st, 2011. 17.5.5. A copy of all records pertaining to deeds or real estate in which you have acquired or may have acquired any interest at any time, including any leases, mortgages, appraisals or market analysis related thereto, together with any evidence showing all contributions in cash or otherwise made by you to effect the acquisition of such real estate. 17.5.6. A copy of all sales agreements and/or options for any real estate owned by you and those held by you in your name jointly with any person or in your name as trustee or guardian for any other person or stock evidencing ownership interest in a corporation holding real estate as its assets since January 1st, 2011. 17.5.7. A copy of all securities and investments owned or purchased by you since January 1st, 2011. 17.5.8. A copy of all financial statements, balance sheets and income statements received by you or prepared by an accountant or any other person for you or for any business you have had an interest in including without limitation, any and all proprietorships, joint ventures, partnerships, realty trust, corporations or other legal entities in which you hold a legal or equitable ownership or interest, individually or otherwise, since January 1st, 2011. 17.5.9. A copy of all partnerships, joint venture agreements, declarations of trust, and/or corporate records in which you have a legal or equitable interest, since January 1st, 2011. 17.5.10. A copy of all registrations to motor vehicles currently owned by you. 17.5.11.A copy of all records pertaining to the transfer by gift or sale of any and all property of whatsoever kind or nature for the dates requested, such records to include any and all information relative to gains or losses realized from transactions involving such transfer since the filing of this suit.
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17.5.12. Names, addresses, and telephone numbers of any and all proposed expert witnesses and all tangible reports, physical models, compilations of date and other material prepared by an expert or for an expert for this cause of action. 17.5.13. A copy of all telephone bills for any and all telephone numbers obtained in your name since January 1st, 2011. 17.5.14. A copy of all supporting documents evidencing all expenses you incurred while involved (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 17.5.15. A copy of all recorded statements of any and all witness and/or experts you intend to call at the time of trial of this cause. 17.5.16. The names, addresses, telephone numbers (home and work) and any relevant documents relating to all persons having knowledge of relevant facts who may be called at trial in this case. 17.5.17. A copy of all supporting documents evidencing all legal fees you incurred while involved (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv0296, In The United States District Court for The W estern District of Texas, El Paso Division. 17.5.18. A copy of all records indicating all interest of any kind held by you in any and all corporations (foreign or domestic) or any other entities not evidenced by certificates or other instruments since January 1st, 2011. 17.5.19. A copy of all records regarding the communications you had with PHILADELPHIAs attorneys regarding the submission of the claim number generated by PHILADELPHIA under claim number PHFF12070652315. 17.5.20. A copy of all records relative to all inter vivos trusts from which benefits have been received, are being received or will be received by you, whether such trusts are revocable or non-revocable since January 1st, 2011. 17.5.21. A copy of all declarations of trust, and minute books for all trusts to which you are a party. 17.5.22. A copy of all corporate records (articles of organization. by-laws and minute books) for every corporation in which you have a legal or equitable ownership interest at the time this suit was filed. 17.5.23. A copy of all books and records showing any fringe benefits available to you from any business entity in which you have a legal or equitable ownership interest, including without limitation, bonuses, health accident and hospital insurance. 17.5.24. A copy of all records and statements pertaining to any interest which you may have in any pension, retirement or profit-sharing plans, including copies of the plans. 17.5.25. A copy of all personal financial statements prepared by an accountant or any other person for you or for any business in which you have or had an interest since 2011. 17.5.26. A copy of all records of all bank accounts you which you are or were authorized to draw funds since January 1st, 2011. 17.5.27. A copy of any records reflecting the names and addresses of all persons who were witnesses to or have knowledge or information of any relevant facts relating to this action or who possess proof of any incident(s) or who were eyewitnesses; all written memoranda and reports and photographs submitted to you or your attorney by any such person, and all tape recordings or other evidence prepared from tape recordings made in connection with any wiretapping or other electronic surveillance conducted by you or others on your behalf.
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17.5.28. A copy of all photographs in your possession or under your control, which you intend to or may offer at the time of trial. 17.5.29. A copy of all tape recordings, sound reproductions, video tapes or movies of you and/or Plaintiff, Plaintiff agent, representatives, or member of the Board of Directors and/or others in your possession or subject to your control that you expect to present as evidence at any hearings under this cause action. 17.5.30. A copy of all personal calendars, diaries, memoranda, letters, recordings (whether video, telephone, cassette, etc.), photographs, newspaper articles, hand written notes, and any other tangible item in your possession or being held for your behalf, whether containing information regarding you, Plaintiff, Plaintiffs agent, representatives, or members of the Board of Directors and/or others, or any party of the suit that are in your possession or subject to your control that you expect to present as evidence at any hearings under this cause action. 17.5.31. All records, receipts, lists, acknowledgments, canceled checks, of any and all payments made to you either by cash or any other form of payment while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division, paid by any individual or entity. 17.5.32. A copy of all police reports and/or evidence intended to be used that you expect to present as evidence at any hearings under this cause action. 17.5.33. A copy of all policies of insurance whether life, health, fire, liability, disability, home owners, personal article or otherwise in which the parties took out or claim any insurable interest while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 17.5.34. A copy of any notes, bills, statements, invoices, evidence in any account receivable or indebtedness owed or paid to you by any Defendant while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 17.5.35. A copy of all records that reflect your criminal record to include but not limited to any arrests, warrants, etc. 17.5.36. A copy of all documents that you expect to present as evidence at any hearings under this cause action. 17.5.37. A copy of all pictures that you expect to present as evidence at any hearings under this cause action. 17.5.38. A copy of all videos that you expect to present as evidence at any hearings under this cause action. 17.5.39. A copy of your entire records including but not limited to whether they are electronic records, papers documents, emails, letters, audio recordings, video recordings, billing, itemized statements, expense records, faxes, telephone calls, and any other records relating to the submission of the claim number generated by PHILADELPHIA under claim number PHFF12070652315. 17.5.40. A copy of the entire package you provided PHILADELPHIA for payment under the claim number PHFF12070652315. 17.5.41. A copy of any deposits of any monetary compensation received by you from any Defendant or by a third party on behalf and for the benefit of any Defendant from January 1st, 2011, to present. 17.5.42. A copy of the contract you have entered with any person representing you and/or assisting you in any form in this cause of action.
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17.5.43. A copy of the payments you have made to any person representing you and/or assisting you in any form in this cause of action. 17.5.44. A copy of any payments you have made to any person or made by a third party on your behalf and for your benefit for the legal representation under this case. 17.5.45. A copy of any evidence that supports your contention that you were entitled and/or had the right to filed a claim against Plaintiffs insurance policy with PHILADELPHIA. 17.5.46. A copy of any evidence that supports your contention that you had the appropriate authorization to filed a claim against Plaintiffs insurance policy with PHILADELPHIA. XVIII. REQUEST FOR INTERROGATORIES TO FLORINDA CHAVEZ 18.1. TO: FLORINDA CHAVEZ, 5400 Jeffburn Cove , Austin, Texas 78745.
18.2. Under rules 190 and 197 of the Texas Rules of Civil Procedure, you are required to answer in complete detail and in writing each of the attached interrogatories, sign your answers to the interrogatories, swear to the truth of your answers before a notary public or other judicial officer as required by rules 191.3(a) and 197.2(d) of the Texas Rules of Civil Procedure, and deliver a complete, signed, and notarized copy of your answers to the undersigned attorney within 30 days following service of this request. If you fail to comply with the requirements above, the Court may order sanctions against you in accordance with the Texas Rules of Civil Procedure. 18.3. Definitions
18.3.1 "Identity and location" means the person's name and present or last known address and telephone number. If any of the above information is not available, state any other means of identifying the individual. 18.3.2 "Person" includes and is intended to mean any natural person or the representative of any company, limited liability company, firm, nonpublicly traded corporation, association, trust, business trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity. 18.3.3. "Entity" or "entities" includes and is intended to mean any company, limited liability company, firm, nonpublicly traded corporation, association, trust, business trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity. 18.4. Instructions
18.4.1 All information that is not privileged that is in the possession of FLORINDA CHAVEZ , her attorney, investigators, agents, and consulting experts, as defined in the Texas Rules of Civil Procedure, employees, or other representatives of FLORINDA CHAVEZ is to be divulged. Possession, custody, or control of an item means that the person either has physical possession of the item or has a right to possession of the item that is equal or superior to that of the person who has physical possession of the item. 18.4.2. If an interrogatory calls for an answer that involves more than one part, each part of the answer must be clearly set out so that it is understandable. You must precede your answer to each separate interrogatory with the question constituting the separate interrogatory. 18.5 Option to Produce Records
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18.5.1. If the answer to an interrogatory may be derived or ascertained from public records, from your business records, or from a compilation, abstract, or summary of your business records, and the burden of deriving or ascertaining the answer is substantially the same for LULAC as for you, you may answer the interrogatory by specifying and, if applicable, producing the records or compilation, abstract, or summary of the records. The records from which the answer may be derived or ascertained must be specified in sufficient detail to permit LULAC to locate and identify them as readily as you can. If you have specified business records, you must state a reasonable time and place for examination of the documents. You must produce the documents at the time and place stated, unless otherwise agreed by the parties or ordered by the court, and must provide LULAC a reasonable opportunity to inspect them. 18.6. INTERROGATORIES
18.6.1. State the name, address, and telephone number of any person who is expected to be called to testify at the trial of this lawsuit. 18.6.2. State which of your answers to these interrogatories are based on information obtained from other persons and state the name, address, and telephone number of each person from whom you obtained the information and the date the information was obtained. 18.6.3. If you, at any time, had possession or control of a document requested in a request for production, and if the document has been lost, has been destroyed, or is not presently in your possession, custody, or control, describe the document, the date of its loss, destruction, purge, or separation from your possession, custody, or control, and the circumstances surrounding its loss, destruction, purge, or separation from your possession, custody, or control. 18.6.4. If any person or entity with which you are associated provides you with any fringe benefits (fringe benefits include but are not limited to payment of personal expenses; payment of housing expenses; payment of medical, hospitalization, or dental insurance, life insurance, annuities, and disability insurance policies; payment of automobile expenses including note payment, gasoline, repairs, maintenance, insurance, and mileage compensation; payment of travel allowances; deferred compensation plans, 401(k) contributions, stock options, or retirement or pension benefits; country club or other memberships; bonuses or dividends of any kind; use of company airplanes, homes, boats, or cars; payment of business professional dues; interest-free or low-interest loans; payment of legal fees; accounting or bookkeeping services; and payment for items used by you personally), state for each fringe benefit-cost. a. b. c. a description of the fringe benefit; the amount paid monthly by the person or entity for the fringe benefit; and, the specific person or entity providing each fringe benefit.
18.6.5. If you claim any property (tangible or intangible) is protected by law from execution under a Court Judgment or under the homestead protections afforded by the State of Texas, for each item of property statea. b. c. a description of the property; all facts supporting your claims; and your opinion of the value of the property.
18.6.6. If you have had any interest in any trust, for each trust statea. b. the identify and location of the trust and trustee(s); and the identity and location of the entity or institution in which the trust is or was held.
18.6.7. If you have made any gifts or transfers of funds, money, property, or property rights in excess of a value of $500.00 in the aggregate to any person unrelated or related to you by blood or marriage since the day this suit was filed, for each such gift or transfer statea. b. the identity and location of each person; the date and nature of the gift or transfer; and
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c. 18.6.8. state:a. b.
the value of the gift or item transferred. Please describe any and all criminal convictions and arrests that you have, if any. For each please
the date; and the circumstances of each.
18.6.9. Please state the name, address, and telephone number of the person or persons who first contacted Defendants C & C and/or CUELLAR regarding the filing of the claim with PHILADELPHIA, claim number PHFF12070652315. 18.6.10. Please state the name, address, and telephone number of the person or persons that authorized you to file a claim against Plaintiffs insurance policy with PHILADELPHIA, claim number PHFF12070652315. 18.6.11. Please briefly state the legal theories and factual allegations that supports your contention that you were entitled to file a claim against Plaintiffs insurance policy, PHILADELPHIA, claim number PHFF12070652315. 18.6.12. Please state the name, address and telephone number of every person you had contact before, during, and after your filing regarding the claim with PHILADELPHIA, claim number PHFF12070652315. 18.6.13. Please state the date that you received approval from Plaintiff that authorized you to file a claim against Plaintiffs insurance policy with PHILADELPHIA, claim number PHFF12070652315. 18.6.14. Please state the steps you took to ensure you obtained the proper approval from Plaintiff in order for you to be able to filed the claim against Plaintiffs insurance carrier, PHILADELPHIA, claim number PHFF12070652315. 18.6.15. Please state the name, address, and telephone number of the person or persons you kept informed withing Plaintiffs Board of Directors (excluding you if you are a member of the board or any other Defendant) regarding the claim filed against Plaintiffs insurance policy issued by PHILADELPHIA, claim number PHFF12070652315. 18.6.16. If you claim that you have the approval from Plaintiff to filed a claim against Plaintiffs insurance policy with PHILADELPHIA as a result of your involvement in the suit filed under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division , please state what steps you took to ensure that yo have the proper approval from Plaintiff to filed such claim. 18.6.17. If you contend that you were entitled to file a claim against Plaintiffs insurance policy with PHILADELPHIA as a result of your involvement in the suit filed under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division , please state your legal theories and factual allegations that support your contention that you were entitle to filed such claim. 18.6.18. Please state the name, address, and telephone number of the person or persons who first contacted PHILADELPHIA regarding the filing of claim number PHFF12070652315. XIX. REQUEST FOR DISCLOSURE TO DEFENDANT BEATRICE ALBA M ARTINEZ 19.1. TO: BEATRICE ALBA MARTINEZ, 7007 Arboreal, Dallas Texas 75231.
19.2. Pursuant to rule 194 of the Texas Rules of Civil Procedure, you are requested to disclose, within 30 days after service of this request, the information or material described in rule 194 as set forth in the attached request. The originals or copies of documents and other tangible items requested must be produced for inspection and copying
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at 909 N.E. Loop 410, Suite 715, San Antonio, TX 78209 within 30 days after service of this request, together with a written response. Each written response must be preceded by the request to which it applies. No objection or assertion of work product privilege is permitted to a request under this rule. If you fail to comply with this request, the court may order sanctions against you in accordance with the Texas Rules of Civil Procedure. Your response must be signed. 19.3. RULE 194 REQUEST
19.3.1. State the correct names of the parties to the lawsuit. 19.3.2. State the names, addresses, and telephone numbers of any potential parties. 19.3.3. State the legal theories and, in general, the factual bases of the claims or defenses of BEATRICE ALBA MARTINEZ. 19.3.4. State the amount and any method of calculating economic damages. 19.3.5. State the names, addresses, and telephone numbers of persons having knowledge of relevant facts, and give a brief statement of each identified person's connection with the case. 19.3.6. For any testifying expert a. b. c. state the expert's name, address, and telephone number; state the subject matter on which the expert will testify; state the general substance of the expert's mental impressions and opinions and a brief summary of the basis for them or, if the expert is not retained by, employed by, or otherwise subject to the control of BEATRICE ALBA MARTINEZ , documents reflecting such information; if an expert is retained by, employed by, or otherwise subject to the control of BEATRICE ALBA MARTINEZ, produce the originals or copies of the following: i. all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert's testimony; and, ii. the expert's current resume and bibliography.
d.
19.3.7. Produce the originals or copies of any indemnity and insuring agreements described in rule 192.3(f) of the Texas Rules of Civil Procedure. Rule 192.3(f) provides in part as follows: Indemnity and Insuring Agreements. Except as otherwise provided by law, a party may obtain discovery of the existence and contents of any indemnity or insurance agreement under which any person may be liable to satisfy part or all of a judgment rendered in the action or to indemnify or reimburse for payments made to satisfy the judgment. 19.3.8. Produce the originals or copies of any settlement agreements described in rule 192.3(g) of the Texas Rules of Civil Procedure. Rule 192.3(g) provides in part as follows: Settlement Agreements. A party may obtain discovery of the existence and contents of any relevant portions of a settlement agreement. 19.3.9. Produce the originals or copies of any witness statements described in rule 192.3(h) of the Texas Rules of Civil Procedure. Rule 192.3(h) provides in part as follows. Statements of Persons with Knowledge of Relevant Facts. A party may obtain discovery of the statement of any person with knowledge of relevant facts - a "witness statement" - regardless of when the statement was made. A witness statement is (1) a written statement signed or otherwise adopted or approved in writing by the person making it, or (2) a stenographic, mechanical, electrical, or other type of recording of a witness's oral
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statement, or any substantially verbatim transcription of such a recording. Any person may obtain, upon written request, his or her own statement concerning the lawsuit, which is in the possession, custody or control of any party. 19.3.10. State the name, address, and telephone number of any person who may be designated as a third party. XX. REQUEST FOR PRODUCTION TO BEATRICE ALBA M ARTINEZ 20.1. TO: BEATRICE ALBA MARTINEZ , 7007 Arboreal, Dallas Texas 75231.
20.2. Please take notice that request is hereby made, pursuant to Rules 192 and 196 of the Texas Rules of Civil Procedure, that BEATRICE ALBA MARTINEZ , produce to the undersigned attorney for LULAC any and all documents responsive to the attached Requests for Production of Documents. W ithin 30 days after service of this Request for Production of Documents, BEATRICE ALBA MARTINEZ, shall file a written response stating with respect to each request that documents are being attached as requested unless the request is objected to, in which event the reason for the objection shall be stated. 20.4. DEFINITIONS AND INSTRUCTIONS
20.4.1. As used herein, the terms you and your shall refer to BEATRICE ALBA MARTINEZ, the attorneys, agents, and all other natural persons or business or legal entities acting or purporting to act for or on behalf of BEATRICE ALBA MARTINEZ, whether authorized to do so or not. 20.4.2. The term documents shall mean all writings of every kind, source, and authorship, both originals and all nonidentical copies thereof; in your possession or known by you to exits, irrespective of whether the writing is one intended for or transmitted internally by you, or intended for or transmitted to any other person or entity, including without limitation any government agency, department, administrative entity, or any private entity, or any person. 20.4.3. A document is deemed to be in your possession, custody or control if you have either actual physical possession of a document or constructive possession of the document. Constructive possession means that you have a superior right to compel the production of such document or a copy thereof from a third party having actual physical possession of the document. 20.4.4. The term shall include handwritten, typewritten, printed, photocopied, photographic, or recorded matter. It shall include communications in words, symbols, pictures, sound recordings, films, tapes, and information stored in, or accessible through, computer or other information storage or retrieval systems, together with the codes and/or programming instructions and other materials necessary to understand and use such systems. For purposes of illustration and not limitation, the term shall include: affidavits; agendas; agreements; analyses; announcements; bills, statements, and other records of obligations and expenditures; books; brochures; bulletins; calendars; canceled checks, vouchers, receipts and other records of payments; charts, drawings; check registers; checkbooks; circulars; collateral files and contents; contracts; corporate by-laws; corporate charters; correspondence; credit files and contents; deeds of trust; deposit slips; diaries, drafts; files; guaranty agreements; instructions; invoices; ledgers, journals balance sheets, profit and loss statements, and other sources of financial data; letters; logs, notes, or memoranda of telephonic or face-to-face conversations; manuals; memoranda of all kinds, to and from any persons, agencies, or entities; minutes; minute books; notes; notices; parts lists; papers; press releases; printed matter (including published books, articles, speeches, and newspaper clippings); purchase orders; records; records of administrative, technical, and financial actions taken or recommended; reports; safety deposit boxes and contents and records of entry; schedules; security agreements; specifications; statement of bank accounts; statements, interviews; stock transfer ledger; technical and engineering reports, evaluations, advice, recommendations, commentaries, conclusions, studies, test plans, manuals, procedures, data, reports, results, and conclusions; summaries, notes, and other records and recordings of any conferences, meetings, visits, statements, interviews or telephone conversations; telegrams; teletypes and other communications sent or received;
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transcripts of testimony; UCC instruments; work papers; and all other writings, the contents of which relate to, discuss, consider, or otherwise refer to the subject matter of the particular discovery requested. 20.4.5. Person: The term person shall include individuals, associations, partnerships, corporations, and any other type of entity or institution whether formed for business purposes or any other purposes. 20.4.6. Identify or Identification: (1) W hen used in reference to a person, identify or identification means to state his or her full name, present or last known residence address, present or last known business address and telephone number. (2) W hen used in reference to a public or private corporation, governmental entity, partnership or association, identify or identification means to state its full name, present or last known business address or operating address, the name of its chief executive officer and telephone number. (3) following: W hen used in reference to a document, identify or identification shall include statement of the
(a) the title, heading, or caption, if any, of such document; (b) the identifying number(s), letter(s), or combination thereof; if any; and the significance or meaning of such number(s), letter(s), or combination thereof; if necessary to an understanding of the document and evaluation of any claim of protection from discovery; (c) the date appearing on such document; if no date appears thereon, the answer shall so state and shall give the date or approximate date on which such document was prepared; (d) the number of pages and the general nature or description of such document (i.e., whether it is a letter, memorandum, minutes of a meeting, etc.), with sufficient particularity so as to enable such document to be precisely identified; (e) the name and capacity of the person who signed such document; if it was not signed, the answer shall so state and shall give the name of the person or persons who prepared it; (f) the name and capacity of the person to whom such document was addressed and the name and capacity of such person, other than such addressee, to whom such document, or a copy thereof; was sent; and (g) the physical location of the document and the name of its custodian or custodians. (4) Unless a specific date or dates is set forth in any specific question herein, you are directed that each question shall be answered for the period of time up to the present date. 20.5. REQUEST FOR PRODUCTION 20.5.1. A copy of all contracts you have entered with any Defendant or for the representation of any Defendant at any time. 20.5.2. A copy of all employment information, including without limitation, wages, salaries, bonuses, stock options, commission, earnings, income, employment contracts, pay raises, promotions, payroll deductions of any kind, credit union accounts, pension plans, pension funds, retirement plans, retirement funds, stock plan and stock fund or other benefits or deductions of any kind which are, were, previously or which may be in the future paid, available, accepted, rejected, credited, offered, withheld for any purpose by any individual, agency, department, company or otherwise, or to which you are, were or may become entitled in the future since January 1st, 2011. 20.5.3. A copy of all records indicating any and all income received by you from any and all sources since January 1st, 2011. 20.5.4. A copy of all savings accounts, credit union or other passbooks of yours, including those held by you in your name or in your name jointly with any person or any entity, or in your name as trustee for any other person, since January 1st, 2011.
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20.5.5. A copy of all records pertaining to deeds or real estate in which you have acquired or may have acquired any interest at any time, including any leases, mortgages, appraisals or market analysis related thereto, together with any evidence showing all contributions in cash or otherwise made by you to effect the acquisition of such real estate. 20.5.6. A copy of all sales agreements and/or options for any real estate owned by you and those held by you in your name jointly with any person or in your name as trustee or guardian for any other person or stock evidencing ownership interest in a corporation holding real estate as its assets since January 1st, 2011. 20.5.7. A copy of all securities and investments owned or purchased by you since January 1st, 2011. 20.5.8. A copy of all financial statements, balance sheets and income statements received by you or prepared by an accountant or any other person for you or for any business you have had an interest in including without limitation, any and all proprietorships, joint ventures, partnerships, realty trust, corporations or other legal entities in which you hold a legal or equitable ownership or interest, individually or otherwise, since January 1st, 2011. 20.5.9. A copy of all partnerships, joint venture agreements, declarations of trust, and/or corporate records in which you have a legal or equitable interest, since January 1st, 2011. 20.5.10. A copy of all registrations to motor vehicles currently owned by you. 20.5.11.A copy of all records pertaining to the transfer by gift or sale of any and all property of whatsoever kind or nature for the dates requested, such records to include any and all information relative to gains or losses realized from transactions involving such transfer since the filing of this suit. 20.5.12. Names, addresses, and telephone numbers of any and all proposed expert witnesses and all tangible reports, physical models, compilations of date and other material prepared by an expert or for an expert for this cause of action. 20.5.13. A copy of all telephone bills for any and all telephone numbers obtained in your name since January 1st, 2011. 20.5.14. A copy of all supporting documents evidencing all expenses you incurred while involved (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 20.5.15. A copy of all recorded statements of any and all witness and/or experts you intend to call at the time of trial of this cause. 20.5.16. The names, addresses, telephone numbers (home and work) and any relevant documents relating to all persons having knowledge of relevant facts who may be called at trial in this case. 20.5.17. A copy of all supporting documents evidencing all legal fees you incurred while involved (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv0296, In The United States District Court for The W estern District of Texas, El Paso Division. 20.5.18. A copy of all records indicating all interest of any kind held by you in any and all corporations (foreign or domestic) or any other entities not evidenced by certificates or other instruments since January 1st, 2011. 20.5.19. A copy of all records regarding the communications you had with PHILADELPHIAs attorneys regarding the submission of the claim number generated by PHILADELPHIA under claim number PHFF12070652315. 20.5.20. A copy of all records relative to all inter vivos trusts from which benefits have been received, are being received or will be received by you, whether such trusts are revocable or non-revocable since January 1st, 2011.
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20.5.21. A copy of all declarations of trust, and minute books for all trusts to which you are a party. 20.5.22. A copy of all corporate records (articles of organization. by-laws and minute books) for every corporation in which you have a legal or equitable ownership interest at the time this suit was filed. 20.5.23. A copy of all books and records showing any fringe benefits available to you from any business entity in which you have a legal or equitable ownership interest, including without limitation, bonuses, health accident and hospital insurance. 20.5.24. A copy of all records and statements pertaining to any interest which you may have in any pension, retirement or profit-sharing plans, including copies of the plans. 20.5.25. A copy of all personal financial statements prepared by an accountant or any other person for you or for any business in which you have or had an interest since 2011. 20.5.26. A copy of all records of all bank accounts you which you are or were authorized to draw funds since January 1st, 2011. 20.5.27. A copy of any records reflecting the names and addresses of all persons who were witnesses to or have knowledge or information of any relevant facts relating to this action or who possess proof of any incident(s) or who were eyewitnesses; all written memoranda and reports and photographs submitted to you or your attorney by any such person, and all tape recordings or other evidence prepared from tape recordings made in connection with any wiretapping or other electronic surveillance conducted by you or others on your behalf. 20.5.28. A copy of all photographs in your possession or under your control, which you intend to or may offer at the time of trial. 20.5.29. A copy of all tape recordings, sound reproductions, video tapes or movies of you and/or Plaintiff, Plaintiff agent, representatives, or member of the Board of Directors and/or others in your possession or subject to your control that you expect to present as evidence at any hearings under this cause action. 20.5.30. A copy of all personal calendars, diaries, memoranda, letters, recordings (whether video, telephone, cassette, etc.), photographs, newspaper articles, hand written notes, and any other tangible item in your possession or being held for your behalf, whether containing information regarding you, Plaintiff, Plaintiffs agent, representatives, or members of the Board of Directors and/or others, or any party of the suit that are in your possession or subject to your control that you expect to present as evidence at any hearings under this cause action. 20.5.31. All records, receipts, lists, acknowledgments, canceled checks, of any and all payments made to you either by cash or any other form of payment while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division, paid by any individual or entity. 20.5.32. A copy of all police reports and/or evidence intended to be used that you expect to present as evidence at any hearings under this cause action. 20.5.33. A copy of all policies of insurance whether life, health, fire, liability, disability, home owners, personal article or otherwise in which the parties took out or claim any insurable interest while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 20.5.34. A copy of any notes, bills, statements, invoices, evidence in any account receivable or indebtedness owed or paid to you by any Defendant while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division.
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20.5.35. A copy of all records that reflect your criminal record to include but not limited to any arrests, warrants, etc. 20.5.36. A copy of all documents that you expect to present as evidence at any hearings under this cause action. 20.5.37. A copy of all pictures that you expect to present as evidence at any hearings under this cause action. 20.5.38. A copy of all videos that you expect to present as evidence at any hearings under this cause action. 20.5.39. A copy of your entire records including but not limited to whether they are electronic records, papers documents, emails, letters, audio recordings, video recordings, billing, itemized statements, expense records, faxes, telephone calls, and any other records relating to the submission of the claim number generated by PHILADELPHIA under claim number PHFF12070652315. 20.5.40. A copy of the entire package you provided PHILADELPHIA for payment under the claim number PHFF12070652315. 20.5.41. A copy of any deposits of any monetary compensation received by you from any Defendant or by a third party on behalf and for the benefit of any Defendant from January 1st, 2011, to present. 20.5.42. A copy of the contract you have entered with any person representing you and/or assisting you in any form in this cause of action. 20.5.43. A copy of the payments you have made to any person representing you and/or assisting you in any form in this cause of action. 20.5.44. A copy of any payments you have made to any person or made by a third party on your behalf and for your benefit for the legal representation under this case. 20.5.45. A copy of any evidence that supports your contention that you were entitled and/or had the right to filed a claim against Plaintiffs insurance policy with PHILADELPHIA. 20.5.46. A copy of any evidence that supports your contention that you had the appropriate authorization to filed a claim against Plaintiffs insurance policy with PHILADELPHIA. XXI. REQUEST FOR INTERROGATORIES TO BEATRICE ALBA M ARTINEZ 21.1. TO: BEATRICE ALBA MARTINEZ, 7007 Arboreal, Dallas Texas 75231.
21.3.1 "Identity and location" means the person's name and present or last known address and telephone number. If any of the above information is not available, state any other means of identifying the individual. 21.3.2 "Person" includes and is intended to mean any natural person or the representative of any company,
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limited liability company, firm, nonpublicly traded corporation, association, trust, business trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity. 21.3.3. "Entity" or "entities" includes and is intended to mean any company, limited liability company, firm, nonpublicly traded corporation, association, trust, business trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity. 21.4. Instructions
21.4.1 All information that is not privileged that is in the possession of BEATRICE ALBA MARTINEZ , her attorney, investigators, agents, and consulting experts, as defined in the Texas Rules of Civil Procedure, employees, or other representatives of BEATRICE ALBA MARTINEZ is to be divulged. Possession, custody, or control of an item means that the person either has physical possession of the item or has a right to possession of the item that is equal or superior to that of the person who has physical possession of the item. 21.4.2. If an interrogatory calls for an answer that involves more than one part, each part of the answer must be clearly set out so that it is understandable. You must precede your answer to each separate interrogatory with the question constituting the separate interrogatory. 21.5 Option to Produce Records
21.6.1. State the name, address, and telephone number of any person who is expected to be called to testify at the trial of this lawsuit. 21.6.2. State which of your answers to these interrogatories are based on information obtained from other persons and state the name, address, and telephone number of each person from whom you obtained the information and the date the information was obtained. 21.6.3. If you, at any time, had possession or control of a document requested in a request for production, and if the document has been lost, has been destroyed, or is not presently in your possession, custody, or control, describe the document, the date of its loss, destruction, purge, or separation from your possession, custody, or control, and the circumstances surrounding its loss, destruction, purge, or separation from your possession, custody, or control. 21.6.4. If any person or entity with which you are associated provides you with any fringe benefits (fringe benefits include but are not limited to payment of personal expenses; payment of housing expenses; payment of medical, hospitalization, or dental insurance, life insurance, annuities, and disability insurance policies; payment of automobile expenses including note payment, gasoline, repairs, maintenance, insurance, and mileage compensation; payment of travel allowances; deferred compensation plans, 401(k) contributions, stock options, or retirement or pension benefits; country club or other memberships; bonuses or dividends of any kind; use of company airplanes, homes, boats, or cars; payment of business professional dues; interest-free or low-interest loans; payment of legal fees; accounting or bookkeeping services; and payment for items used by you personally), state for each fringe benefit-cost.
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a. b. c.
a description of the fringe benefit; the amount paid monthly by the person or entity for the fringe benefit; and, the specific person or entity providing each fringe benefit.
21.6.7. If you have made any gifts or transfers of funds, money, property, or property rights in excess of a value of $500.00 in the aggregate to any person unrelated or related to you by blood or marriage since the day this suit was filed, for each such gift or transfer statea. b. c. the identity and location of each person; the date and nature of the gift or transfer; and the value of the gift or item transferred.
21.6.8. Please describe any and all criminal convictions and arrests that you have, if any. For each please state:a. b. the date; and the circumstances of each.
21.6.9. Please state the name, address, and telephone number of the person or persons who first contacted Defendants C & C and/or CUELLAR regarding the filing of the claim with PHILADELPHIA, claim number PHFF12070652315. 21.6.10. Please state the name, address, and telephone number of the person or persons that authorized you to file a claim against Plaintiffs insurance policy with PHILADELPHIA, claim number PHFF12070652315. 21.6.11. Please briefly state the legal theories and factual allegations that supports your contention that you were entitled to file a claim against Plaintiffs insurance policy, PHILADELPHIA, claim number PHFF12070652315. 21.6.12. Please state the name, address and telephone number of every person you had contact before, during, and after your filing regarding the claim with PHILADELPHIA, claim number PHFF12070652315. 21.6.13. Please state the date that you received approval from Plaintiff that authorized you to file a claim against Plaintiffs insurance policy with PHILADELPHIA, claim number PHFF12070652315. 21.6.14. Please state the steps you took to ensure you obtained the proper approval from Plaintiff in order for you to be able to filed the claim against Plaintiffs insurance carrier, PHILADELPHIA, claim number PHFF12070652315. 21.6.15. Please state the name, address, and telephone number of the person or persons you kept informed withing Plaintiffs Board of Directors (excluding you if you are a member of the board or any other Defendant) regarding the claim filed against Plaintiffs insurance policy issued by PHILADELPHIA, claim number PHFF12070652315. 21.6.16. If you claim that you have the approval from Plaintiff to filed a claim against Plaintiffs insurance
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policy with PHILADELPHIA as a result of your involvement in the suit filed under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division , please state what steps you took to ensure that yo have the proper approval from Plaintiff to filed such claim. 21.6.17. If you contend that you were entitled to file a claim against Plaintiffs insurance policy with PHILADELPHIA as a result of your involvement in the suit filed under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division , please state your legal theories and factual allegations that support your contention that you were entitle to filed such claim. 21.6.18. Please state the name, address, and telephone number of the person or persons who first contacted PHILADELPHIA regarding the filing of claim number PHFF12070652315. XXII. REQUEST FOR DISCLOSURE TO DEFENDANT JOE CARDENAS 22.1. JOE CARDENAS, P.O. Box 29, Lousie, Texas 77455.
22.3.1. State the correct names of the parties to the lawsuit. 22.3.2. State the names, addresses, and telephone numbers of any potential parties. 22.3.3. State the legal theories and, in general, the factual bases of the claims or defenses of CARDENAS. 22.3.4. State the amount and any method of calculating economic damages. 22.3.5. State the names, addresses, and telephone numbers of persons having knowledge of relevant facts, and give a brief statement of each identified person's connection with the case. 22.3.6. For any testifying expert a. b. c. state the expert's name, address, and telephone number; state the subject matter on which the expert will testify; state the general substance of the expert's mental impressions and opinions and a brief summary of the basis for them or, if the expert is not retained by, employed by, or otherwise subject to the control of JOE CARDENAS , documents reflecting such information; if an expert is retained by, employed by, or otherwise subject to the control of JOE CARDENAS, produce the originals or copies of the following: i. all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert's testimony; and, J O E
d.
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ii.
the expert's current resume and bibliography.
22.3.7. Produce the originals or copies of any indemnity and insuring agreements described in rule 192.3(f) of the Texas Rules of Civil Procedure. Rule 192.3(f) provides in part as follows: Indemnity and Insuring Agreements. Except as otherwise provided by law, a party may obtain discovery of the existence and contents of any indemnity or insurance agreement under which any person may be liable to satisfy part or all of a judgment rendered in the action or to indemnify or reimburse for payments made to satisfy the judgment. 22.3.8. Produce the originals or copies of any settlement agreements described in rule 192.3(g) of the Texas Rules of Civil Procedure. Rule 192.3(g) provides in part as follows: Settlement Agreements. A party may obtain discovery of the existence and contents of any relevant portions of a settlement agreement. 22.3.9. Produce the originals or copies of any witness statements described in rule 192.3(h) of the Texas Rules of Civil Procedure. Rule 192.3(h) provides in part as follows. Statements of Persons with Knowledge of Relevant Facts. A party may obtain discovery of the statement of any person with knowledge of relevant facts - a "witness statement" - regardless of when the statement was made. A witness statement is (1) a written statement signed or otherwise adopted or approved in writing by the person making it, or (2) a stenographic, mechanical, electrical, or other type of recording of a witness's oral statement, or any substantially verbatim transcription of such a recording. Any person may obtain, upon written request, his or her own statement concerning the lawsuit, which is in the possession, custody or control of any party. 22.3.10. State the name, address, and telephone number of any person who may be designated as a third party. XXIII. REQUEST FOR PRODUCTION TO JOE CARDENAS 23.1. TO: JOE CARDENAS, P.O. Box 29, Lousie, Texas 77455.
23.2. Please take notice that request is hereby made, pursuant to Rules 192 and 196 of the Texas Rules of Civil Procedure, that JOE CARDENAS , produce to the undersigned attorney for LULAC any and all documents responsive to the attached Requests for Production of Documents. 23.3. W ithin 30 days after service of this Request for Production of Documents, JOE CARDENAS, shall file a written response stating with respect to each request that documents are being attached as requested unless the request is objected to, in which event the reason for the objection shall be stated. 23.4. DEFINITIONS AND INSTRUCTIONS
23.4.1. As used herein, the terms you and your shall refer to JOE CARDENAS , the attorneys, agents, and all other natural persons or business or legal entities acting or purporting to act for or on behalf of JOE CARDENAS, whether authorized to do so or not. 23.4.2. The term documents shall mean all writings of every kind, source, and authorship, both originals and all nonidentical copies thereof; in your possession or known by you to exits, irrespective of whether the writing is one intended for or transmitted internally by you, or intended for or transmitted to any other person or entity, including without limitation any government agency, department, administrative entity, or any private entity, or any person. 23.4.3. A document is deemed to be in your possession, custody or control if you have either actual physical possession of a document or constructive possession of the document. Constructive possession means that you have a
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superior right to compel the production of such document or a copy thereof from a third party having actual physical possession of the document. 23.4.4. The term shall include handwritten, typewritten, printed, photocopied, photographic, or recorded matter. It shall include communications in words, symbols, pictures, sound recordings, films, tapes, and information stored in, or accessible through, computer or other information storage or retrieval systems, together with the codes and/or programming instructions and other materials necessary to understand and use such systems. For purposes of illustration and not limitation, the term shall include: affidavits; agendas; agreements; analyses; announcements; bills, statements, and other records of obligations and expenditures; books; brochures; bulletins; calendars; canceled checks, vouchers, receipts and other records of payments; charts, drawings; check registers; checkbooks; circulars; collateral files and contents; contracts; corporate by-laws; corporate charters; correspondence; credit files and contents; deeds of trust; deposit slips; diaries, drafts; files; guaranty agreements; instructions; invoices; ledgers, journals balance sheets, profit and loss statements, and other sources of financial data; letters; logs, notes, or memoranda of telephonic or face-to-face conversations; manuals; memoranda of all kinds, to and from any persons, agencies, or entities; minutes; minute books; notes; notices; parts lists; papers; press releases; printed matter (including published books, articles, speeches, and newspaper clippings); purchase orders; records; records of administrative, technical, and financial actions taken or recommended; reports; safety deposit boxes and contents and records of entry; schedules; security agreements; specifications; statement of bank accounts; statements, interviews; stock transfer ledger; technical and engineering reports, evaluations, advice, recommendations, commentaries, conclusions, studies, test plans, manuals, procedures, data, reports, results, and conclusions; summaries, notes, and other records and recordings of any conferences, meetings, visits, statements, interviews or telephone conversations; telegrams; teletypes and other communications sent or received; transcripts of testimony; UCC instruments; work papers; and all other writings, the contents of which relate to, discuss, consider, or otherwise refer to the subject matter of the particular discovery requested. 23.4.5. Person: The term person shall include individuals, associations, partnerships, corporations, and any other type of entity or institution whether formed for business purposes or any other purposes. 23.4.6. Identify or Identification: (1) W hen used in reference to a person, identify or identification means to state his or her full name, present or last known residence address, present or last known business address and telephone number. (2) W hen used in reference to a public or private corporation, governmental entity, partnership or association, identify or identification means to state its full name, present or last known business address or operating address, the name of its chief executive officer and telephone number. (3) following: W hen used in reference to a document, identify or identification shall include statement of the
(a) the title, heading, or caption, if any, of such document; (b) the identifying number(s), letter(s), or combination thereof; if any; and the significance or meaning of such number(s), letter(s), or combination thereof; if necessary to an understanding of the document and evaluation of any claim of protection from discovery; (c) the date appearing on such document; if no date appears thereon, the answer shall so state and shall give the date or approximate date on which such document was prepared; (d) the number of pages and the general nature or description of such document (i.e., whether it is a letter, memorandum, minutes of a meeting, etc.), with sufficient particularity so as to enable such document to be precisely identified; (e) the name and capacity of the person who signed such document; if it was not signed, the answer shall so state and shall give the name of the person or persons who prepared it; (f) the name and capacity of the person to whom such document was addressed and the name and capacity of such person, other than such addressee, to whom such document, or a copy thereof; was sent; and (g) the physical location of the document and the name of its custodian or custodians. (4) Unless a specific date or dates is set forth in any specific question herein, you are directed that each
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question shall be answered for the period of time up to the present date. 23.5. REQUEST FOR PRODUCTION 23.5.1. A copy of all contracts you have entered with any Defendant or for the representation of any Defendant at any time. 23.5.2. A copy of all employment information, including without limitation, wages, salaries, bonuses, stock options, commission, earnings, income, employment contracts, pay raises, promotions, payroll deductions of any kind, credit union accounts, pension plans, pension funds, retirement plans, retirement funds, stock plan and stock fund or other benefits or deductions of any kind which are, were, previously or which may be in the future paid, available, accepted, rejected, credited, offered, withheld for any purpose by any individual, agency, department, company or otherwise, or to which you are, were or may become entitled in the future since January 1st, 2011. 23.5.3. A copy of all records indicating any and all income received by you from any and all sources since January 1st, 2011. 23.5.4. A copy of all savings accounts, credit union or other passbooks of yours, including those held by you in your name or in your name jointly with any person or any entity, or in your name as trustee for any other person, since January 1st, 2011. 23.5.5. A copy of all records pertaining to deeds or real estate in which you have acquired or may have acquired any interest at any time, including any leases, mortgages, appraisals or market analysis related thereto, together with any evidence showing all contributions in cash or otherwise made by you to effect the acquisition of such real estate. 23.5.6. A copy of all sales agreements and/or options for any real estate owned by you and those held by you in your name jointly with any person or in your name as trustee or guardian for any other person or stock evidencing ownership interest in a corporation holding real estate as its assets since January 1st, 2011. 23.5.7. A copy of all securities and investments owned or purchased by you since January 1st, 2011. 23.5.8. A copy of all financial statements, balance sheets and income statements received by you or prepared by an accountant or any other person for you or for any business you have had an interest in including without limitation, any and all proprietorships, joint ventures, partnerships, realty trust, corporations or other legal entities in which you hold a legal or equitable ownership or interest, individually or otherwise, since January 1st, 2011. 23.5.9. A copy of all partnerships, joint venture agreements, declarations of trust, and/or corporate records in which you have a legal or equitable interest, since January 1st, 2011. 23.5.10. A copy of all registrations to motor vehicles currently owned by you. 23.5.11.A copy of all records pertaining to the transfer by gift or sale of any and all property of whatsoever kind or nature for the dates requested, such records to include any and all information relative to gains or losses realized from transactions involving such transfer since the filing of this suit. 23.5.12. Names, addresses, and telephone numbers of any and all proposed expert witnesses and all tangible reports, physical models, compilations of date and other material prepared by an expert or for an expert for this cause of action. 23.5.13. A copy of all telephone bills for any and all telephone numbers obtained in your name since January 1st, 2011. 23.5.14. A copy of all supporting documents evidencing all expenses you incurred while involved (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division.
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23.5.15. A copy of all recorded statements of any and all witness and/or experts you intend to call at the time of trial of this cause. 23.5.16. The names, addresses, telephone numbers (home and work) and any relevant documents relating to all persons having knowledge of relevant facts who may be called at trial in this case. 23.5.17. A copy of all supporting documents evidencing all legal fees you incurred while involved (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv0296, In The United States District Court for The W estern District of Texas, El Paso Division. 23.5.18. A copy of all records indicating all interest of any kind held by you in any and all corporations (foreign or domestic) or any other entities not evidenced by certificates or other instruments since January 1st, 2011. 23.5.19. A copy of all records regarding the communications you had with PHILADELPHIAs attorneys regarding the submission of the claim number generated by PHILADELPHIA under claim number PHFF12070652315. 23.5.20. A copy of all records relative to all inter vivos trusts from which benefits have been received, are being received or will be received by you, whether such trusts are revocable or non-revocable since January 1st, 2011. 23.5.21. A copy of all declarations of trust, and minute books for all trusts to which you are a party. 23.5.22. A copy of all corporate records (articles of organization. by-laws and minute books) for every corporation in which you have a legal or equitable ownership interest at the time this suit was filed. 23.5.23. A copy of all books and records showing any fringe benefits available to you from any business entity in which you have a legal or equitable ownership interest, including without limitation, bonuses, health accident and hospital insurance. 23.5.24. A copy of all records and statements pertaining to any interest which you may have in any pension, retirement or profit-sharing plans, including copies of the plans. 23.5.25. A copy of all personal financial statements prepared by an accountant or any other person for you or for any business in which you have or had an interest since 2011.
23.5.26. A copy of all records of all bank accounts you which you are or were authorized to draw funds since January 1st, 2011. 23.5.27. A copy of any records reflecting the names and addresses of all persons who were witnesses to or have knowledge or information of any relevant facts relating to this action or who possess proof of any incident(s) or who were eyewitnesses; all written memoranda and reports and photographs submitted to you or your attorney by any such person, and all tape recordings or other evidence prepared from tape recordings made in connection with any wiretapping or other electronic surveillance conducted by you or others on your behalf. 23.5.28. A copy of all photographs in your possession or under your control, which you intend to or may offer at the time of trial. 23.5.29. A copy of all tape recordings, sound reproductions, video tapes or movies of you and/or Plaintiff, Plaintiff agent, representatives, or member of the Board of Directors and/or others in your possession or subject to your control that you expect to present as evidence at any hearings under this cause action. 23.5.30. A copy of all personal calendars, diaries, memoranda, letters, recordings (whether video, telephone, cassette, etc.), photographs, newspaper articles, hand written notes, and any other tangible item in your possession or being held for your behalf, whether containing information regarding you, Plaintiff, Plaintiffs agent, representatives, or members of the Board of Directors and/or others, or any party of the suit that are in your possession or subject to your
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control that you expect to present as evidence at any hearings under this cause action. 23.5.31. All records, receipts, lists, acknowledgments, canceled checks, of any and all payments made to you either by cash or any other form of payment while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division, paid by any individual or entity. 23.5.32. A copy of all police reports and/or evidence intended to be used that you expect to present as evidence at any hearings under this cause action. 23.5.33. A copy of all policies of insurance whether life, health, fire, liability, disability, home owners, personal article or otherwise in which the parties took out or claim any insurable interest while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 23.5.34. A copy of any notes, bills, statements, invoices, evidence in any account receivable or indebtedness owed or paid to you by any Defendant while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 23.5.35. A copy of all records that reflect your criminal record to include but not limited to any arrests, warrants, etc. 23.5.36. A copy of all documents that you expect to present as evidence at any hearings under this cause action. 23.5.37. A copy of all pictures that you expect to present as evidence at any hearings under this cause action. 23.5.38. A copy of all videos that you expect to present as evidence at any hearings under this cause action. 23.5.39. A copy of your entire records including but not limited to whether they are electronic records, papers documents, emails, letters, audio recordings, video recordings, billing, itemized statements, expense records, faxes, telephone calls, and any other records relating to the submission of the claim number generated by PHILADELPHIA under claim number PHFF12070652315. 23.5.40. A copy of the entire package you provided PHILADELPHIA for payment under the claim number PHFF12070652315. 23.5.41. A copy of any deposits of any monetary compensation received by you from any Defendant or by a third party on behalf and for the benefit of any Defendant from January 1st, 2011, to present. 23.5.42. A copy of the contract you have entered with any person representing you and/or assisting you in any form in this cause of action. 23.5.43. A copy of the payments you have made to any person representing you and/or assisting you in any form in this cause of action. 23.5.44. A copy of any payments you have made to any person or made by a third party on your behalf and for your benefit for the legal representation under this case. 23.5.45. A copy of any evidence that supports your contention that you were entitled and/or had the right to filed a claim against Plaintiffs insurance policy with PHILADELPHIA. 23.5.46. A copy of any evidence that supports your contention that you had the appropriate authorization to filed a claim against Plaintiffs insurance policy with PHILADELPHIA.
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XXIV. REQUEST FOR INTERROGATORIES TO JOE CARDENAS 24.1. TO: JOE CARDENAS, P.O. Box 29, Lousie, Texas 77455.
24.4.1 All information that is not privileged that is in the possession of BEATRICE ALBA MARTINEZ , her attorney, investigators, agents, and consulting experts, as defined in the Texas Rules of Civil Procedure, employees, or other representatives of BEATRICE ALBA MARTINEZ is to be divulged. Possession, custody, or control of an item means that the person either has physical possession of the item or has a right to possession of the item that is equal or superior to that of the person who has physical possession of the item. 24.4.2. If an interrogatory calls for an answer that involves more than one part, each part of the answer must be clearly set out so that it is understandable. You must precede your answer to each separate interrogatory with the question constituting the separate interrogatory. 24.5. Option to Produce Records
24.6.1. State the name, address, and telephone number of any person who is expected to be called to testify at the trial of this lawsuit.
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24.6.2. State which of your answers to these interrogatories are based on information obtained from other persons and state the name, address, and telephone number of each person from whom you obtained the information and the date the information was obtained. 24.6.3. If you, at any time, had possession or control of a document requested in a request for production, and if the document has been lost, has been destroyed, or is not presently in your possession, custody, or control, describe the document, the date of its loss, destruction, purge, or separation from your possession, custody, or control, and the circumstances surrounding its loss, destruction, purge, or separation from your possession, custody, or control. 24.6.4. If any person or entity with which you are associated provides you with any fringe benefits (fringe benefits include but are not limited to payment of personal expenses; payment of housing expenses; payment of medical, hospitalization, or dental insurance, life insurance, annuities, and disability insurance policies; payment of automobile expenses including note payment, gasoline, repairs, maintenance, insurance, and mileage compensation; payment of travel allowances; deferred compensation plans, 401(k) contributions, stock options, or retirement or pension benefits; country club or other memberships; bonuses or dividends of any kind; use of company airplanes, homes, boats, or cars; payment of business professional dues; interest-free or low-interest loans; payment of legal fees; accounting or bookkeeping services; and payment for items used by you personally), state for each fringe benefit-cost. a. b. c. a description of the fringe benefit; the amount paid monthly by the person or entity for the fringe benefit; and, the specific person or entity providing each fringe benefit.
24.6.9. Please state the name, address, and telephone number of the person or persons who first contacted Defendants C & C and/or CUELLAR regarding the filing of the claim with PHILADELPHIA, claim number PHFF12070652315. 24.6.10. Please state the name, address, and telephone number of the person or persons that authorized you to file a claim against Plaintiffs insurance policy with PHILADELPHIA, claim number PHFF12070652315.
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24.6.11. Please briefly state the legal theories and factual allegations that supports your contention that you were entitled to file a claim against Plaintiffs insurance policy, PHILADELPHIA, claim number PHFF12070652315. 24.6.12. Please state the name, address and telephone number of every person you had contact before, during, and after your filing regarding the claim with PHILADELPHIA, claim number PHFF12070652315. 24.6.13. Please state the date that you received approval from Plaintiff that authorized you to file a claim against Plaintiffs insurance policy with PHILADELPHIA, claim number PHFF12070652315. 24.6.14. Please state the steps you took to ensure you obtained the proper approval from Plaintiff in order for you to be able to filed the claim against Plaintiffs insurance carrier, PHILADELPHIA, claim number PHFF12070652315. 24.6.15. Please state the name, address, and telephone number of the person or persons you kept informed withing Plaintiffs Board of Directors (excluding you if you are a member of the board or any other Defendant) regarding the claim filed against Plaintiffs insurance policy issued by PHILADELPHIA, claim number PHFF12070652315. 24.6.16. If you claim that you have the approval from Plaintiff to filed a claim against Plaintiffs insurance policy with PHILADELPHIA as a result of your involvement in the suit filed under Civil Number EP:12-cv-0296, In The United States District Court for The Western District of Texas, El Paso Division , please state what steps you took to ensure that yo have the proper approval from Plaintiff to filed such claim. 24.6.17. If you contend that you were entitled to file a claim against Plaintiffs insurance policy with PHILADELPHIA as a result of your involvement in the suit filed under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division , please state your legal theories and factual allegations that support your contention that you were entitle to filed such claim.
24.6.18. Please state the name, address, and telephone number of the person or persons who first contacted PHILADELPHIA regarding the filing of claim number PHFF12070652315. XXV. REQUEST FOR DISCLOSURE TO DEFENDANT ROBERT W . WILSON 25.1. TO: ROBERT W . W ILSON, 115 E. Travis, Suite 1900, San Antonio, Texas 78212.
25.3.1. State the correct names of the parties to the lawsuit. 25.3.2. State the names, addresses, and telephone numbers of any potential parties. 25.3.3. State the legal theories and, in general, the factual bases of the claims or defenses of W . W ILSON . 25.3.4. State the amount and any method of calculating economic damages. ROBERT
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25.3.5. State the names, addresses, and telephone numbers of persons having knowledge of relevant facts, and give a brief statement of each identified person's connection with the case. 25.3.6. For any testifying expert a. b. c. state the expert's name, address, and telephone number; state the subject matter on which the expert will testify; state the general substance of the expert's mental impressions and opinions and a brief summary of the basis for them or, if the expert is not retained by, employed by, or otherwise subject to the control of ROBERT W . W ILSON, documents reflecting such information; if an expert is retained by, employed by, or otherwise subject to the control of ROBERT W. W ILSON, produce the originals or copies of the following: i. all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert's testimony; and, the expert's current resume and bibliography.
d.
ii.
25.3.7. Produce the originals or copies of any indemnity and insuring agreements described in rule 192.3(f) of the Texas Rules of Civil Procedure. Rule 192.3(f) provides in part as follows: Indemnity and Insuring Agreements. Except as otherwise provided by law, a party may obtain discovery of the existence and contents of any indemnity or insurance agreement under which any person may be liable to satisfy part or all of a judgment rendered in the action or to indemnify or reimburse for payments made to satisfy the judgment. 25.3.8. Produce the originals or copies of any settlement agreements described in rule 192.3(g) of the Texas Rules of Civil Procedure. Rule 192.3(g) provides in part as follows: Settlement Agreements. A party may obtain discovery of the existence and contents of any relevant portions of a settlement agreement. 25.3.9. Produce the originals or copies of any witness statements described in rule 192.3(h) of the Texas Rules of Civil Procedure. Rule 192.3(h) provides in part as follows. Statements of Persons with Knowledge of Relevant Facts. A party may obtain discovery of the statement of any person with knowledge of relevant facts - a "witness statement" - regardless of when the statement was made. A witness statement is (1) a written statement signed or otherwise adopted or approved in writing by the person making it, or (2) a stenographic, mechanical, electrical, or other type of recording of a witness's oral statement, or any substantially verbatim transcription of such a recording. Any person may obtain, upon written request, his or her own statement concerning the lawsuit, which is in the possession, custody or control of any party. 25.3.10. State the name, address, and telephone number of any person who may be designated as a third party. XXVI. REQUEST FOR PRODUCTION TO ROBERT W . W ILSON 26.1. TO: ROBERT W . W ILSON, 115 E. Travis, Suite 1900, San Antonio, Texas 78212.
26.2. Please take notice that request is hereby made, pursuant to Rules 192 and 196 of the Texas Rules of Civil Procedure, that ROBERT W . W ILSON, produce to the undersigned attorney for LULAC any and all documents responsive to the attached Requests for Production of Documents.
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26.3. W ithin 30 days after service of this Request for Production of Documents, JOE CARDENAS, shall file a written response stating with respect to each request that documents are being attached as requested unless the request is objected to, in which event the reason for the objection shall be stated. 26.4. DEFINITIONS AND INSTRUCTIONS
26.4.1. As used herein, the terms you and your shall refer to ROBERT W . W ILSON, the attorneys, agents, and all other natural persons or business or legal entities acting or purporting to act for or on behalf of ROBERT W . W ILSON, whether authorized to do so or not. 26.4.2. The term documents shall mean all writings of every kind, source, and authorship, both originals and all nonidentical copies thereof; in your possession or known by you to exits, irrespective of whether the writing is one intended for or transmitted internally by you, or intended for or transmitted to any other person or entity, including without limitation any government agency, department, administrative entity, or any private entity, or any person. 26.4.3. A document is deemed to be in your possession, custody or control if you have either actual physical possession of a document or constructive possession of the document. Constructive possession means that you have a superior right to compel the production of such document or a copy thereof from a third party having actual physical possession of the document. 26.4.4. The term shall include handwritten, typewritten, printed, photocopied, photographic, or recorded matter. It shall include communications in words, symbols, pictures, sound recordings, films, tapes, and information stored in, or accessible through, computer or other information storage or retrieval systems, together with the codes and/or programming instructions and other materials necessary to understand and use such systems. For purposes of illustration and not limitation, the term shall include: affidavits; agendas; agreements; analyses; announcements; bills, statements, and other records of obligations and expenditures; books; brochures; bulletins; calendars; canceled checks, vouchers, receipts and other records of payments; charts, drawings; check registers; checkbooks; circulars; collateral files and contents; contracts; corporate by-laws; corporate charters; correspondence; credit files and contents; deeds of trust; deposit slips; diaries, drafts; files; guaranty agreements; instructions; invoices; ledgers, journals balance sheets, profit and loss statements, and other sources of financial data; letters; logs, notes, or memoranda of telephonic or face-to-face conversations; manuals; memoranda of all kinds, to and from any persons, agencies, or entities; minutes; minute books; notes; notices; parts lists; papers; press releases; printed matter (including published books, articles, speeches, and newspaper clippings); purchase orders; records; records of administrative, technical, and financial actions taken or recommended; reports; safety deposit boxes and contents and records of entry; schedules; security agreements; specifications; statement of bank accounts; statements, interviews; stock transfer ledger; technical and engineering reports, evaluations, advice, recommendations, commentaries, conclusions, studies, test plans, manuals, procedures, data, reports, results, and conclusions; summaries, notes, and other records and recordings of any conferences, meetings, visits, statements, interviews or telephone conversations; telegrams; teletypes and other communications sent or received; transcripts of testimony; UCC instruments; work papers; and all other writings, the contents of which relate to, discuss, consider, or otherwise refer to the subject matter of the particular discovery requested. 26.4.5. Person: The term person shall include individuals, associations, partnerships, corporations, and any other type of entity or institution whether formed for business purposes or any other purposes. 26.4.6. Identify or Identification: (1) W hen used in reference to a person, identify or identification means to state his or her full name, present or last known residence address, present or last known business address and telephone number. (2) W hen used in reference to a public or private corporation, governmental entity, partnership or association, identify or identification means to state its full name, present or last known business address or operating address, the name of its chief executive officer and telephone number. (3) following: W hen used in reference to a document, identify or identification shall include statement of the
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(a) the title, heading, or caption, if any, of such document; (b) the identifying number(s), letter(s), or combination thereof; if any; and the significance or meaning of such number(s), letter(s), or combination thereof; if necessary to an understanding of the document and evaluation of any claim of protection from discovery; (c) the date appearing on such document; if no date appears thereon, the answer shall so state and shall give the date or approximate date on which such document was prepared; (d) the number of pages and the general nature or description of such document (i.e., whether it is a letter, memorandum, minutes of a meeting, etc.), with sufficient particularity so as to enable such document to be precisely identified; (e) the name and capacity of the person who signed such document; if it was not signed, the answer shall so state and shall give the name of the person or persons who prepared it; (f) the name and capacity of the person to whom such document was addressed and the name and capacity of such person, other than such addressee, to whom such document, or a copy thereof; was sent; and, (g) the physical location of the document and the name of its custodian or custodians. (4) Unless a specific date or dates is set forth in any specific question herein, you are directed that each question shall be answered for the period of time up to the present date. 26.5. REQUEST FOR PRODUCTION 26.5.1. A copy of all contracts you have entered with any Defendant or for the representation of any Defendant at any time. 26.5.2. A copy of all employment information, including without limitation, wages, salaries, bonuses, stock options, commission, earnings, income, employment contracts, pay raises, promotions, payroll deductions of any kind, credit union accounts, pension plans, pension funds, retirement plans, retirement funds, stock plan and stock fund or other benefits or deductions of any kind which are, were, previously or which may be in the future paid, available, accepted, rejected, credited, offered, withheld for any purpose by any individual, agency, department, company or otherwise, or to which you are, were or may become entitled in the future since January 1st, 2011. 26.5.3. A copy of all records indicating any and all income received by you from any and all sources since January 1st, 2011. 26.5.4. A copy of all savings accounts, credit union or other passbooks of yours, including those held by you in your name or in your name jointly with any person or any entity, or in your name as trustee for any other person, since January 1st, 2011. 26.5.5. A copy of all records pertaining to deeds or real estate in which you have acquired or may have acquired any interest at any time, including any leases, mortgages, appraisals or market analysis related thereto, together with any evidence showing all contributions in cash or otherwise made by you to effect the acquisition of such real estate. 26.5.6. A copy of all sales agreements and/or options for any real estate owned by you and those held by you in your name jointly with any person or in your name as trustee or guardian for any other person or stock evidencing ownership interest in a corporation holding real estate as its assets since January 1st, 2011. 26.5.7. A copy of all securities and investments owned or purchased by you since January 1st, 2011. 26.5.8. A copy of all financial statements, balance sheets and income statements received by you or prepared by an accountant or any other person for you or for any business you have had an interest in including without limitation, any and all proprietorships, joint ventures, partnerships, realty trust, corporations or other legal entities in which you hold a legal or equitable ownership or interest, individually or otherwise, since January 1st, 2011. 26.5.9. A copy of all partnerships, joint venture agreements, declarations of trust, and/or corporate records in which you have a legal or equitable interest, since January 1st, 2011.
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26.5.10. A copy of all registrations to motor vehicles currently owned by you. 26.5.11.A copy of all records pertaining to the transfer by gift or sale of any and all property of whatsoever kind or nature for the dates requested, such records to include any and all information relative to gains or losses realized from transactions involving such transfer since the filing of this suit. 26.5.12. Names, addresses, and telephone numbers of any and all proposed expert witnesses and all tangible reports, physical models, compilations of date and other material prepared by an expert or for an expert for this cause of action. 26.5.13. A copy of all telephone bills for any and all telephone numbers obtained in your name since January 1st, 2011. 26.5.14. A copy of all supporting documents evidencing all expenses you incurred while involved (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 26.5.15. A copy of all recorded statements of any and all witness and/or experts you intend to call at the time of trial of this cause. 26.5.16. The names, addresses, telephone numbers (home and work) and any relevant documents relating to all persons having knowledge of relevant facts who may be called at trial in this case. 26.5.17. A copy of all supporting documents evidencing all legal fees you incurred while involved (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv0296, In The United States District Court for The W estern District of Texas, El Paso Division. 26.5.18. A copy of all records indicating all interest of any kind held by you in any and all corporations (foreign or domestic) or any other entities not evidenced by certificates or other instruments since January 1st, 2011. 26.5.19. A copy of all records regarding the communications you had with PHILADELPHIAs attorneys regarding the submission of the claim number generated by PHILADELPHIA under claim number PHFF12070652315. 26.5.20. A copy of all records relative to all inter vivos trusts from which benefits have been received, are being received or will be received by you, whether such trusts are revocable or non-revocable since January 1st, 2011. 26.5.21. A copy of all declarations of trust, and minute books for all trusts to which you are a party. 26.5.22. A copy of all corporate records (articles of organization. by-laws and minute books) for every corporation in which you have a legal or equitable ownership interest at the time this suit was filed. 26.5.23. A copy of all books and records showing any fringe benefits available to you from any business entity in which you have a legal or equitable ownership interest, including without limitation, bonuses, health accident and hospital insurance. 26.5.24. A copy of all records and statements pertaining to any interest which you may have in any pension, retirement or profit-sharing plans, including copies of the plans. 26.5.25. A copy of all personal financial statements prepared by an accountant or any other person for you or for any business in which you have or had an interest since 2011. 26.5.26. A copy of all records of all bank accounts you which you are or were authorized to draw funds since January 1st, 2011. 26.5.27. A copy of any records reflecting the names and addresses of all persons who were witnesses to or have
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knowledge or information of any relevant facts relating to this action or who possess proof of any incident(s) or who were eyewitnesses; all written memoranda and reports and photographs submitted to you or your attorney by any such person, and all tape recordings or other evidence prepared from tape recordings made in connection with any wiretapping or other electronic surveillance conducted by you or others on your behalf. 26.5.28. A copy of all photographs in your possession or under your control, which you intend to or may offer at the time of trial. 26.5.29. A copy of all tape recordings, sound reproductions, video tapes or movies of you and/or Plaintiff, Plaintiff agent, representatives, or member of the Board of Directors and/or others in your possession or subject to your control that you expect to present as evidence at any hearings under this cause action. 26.5.30. A copy of all personal calendars, diaries, memoranda, letters, recordings (whether video, telephone, cassette, etc.), photographs, newspaper articles, hand written notes, and any other tangible item in your possession or being held for your behalf, whether containing information regarding you, Plaintiff, Plaintiffs agent, representatives, or members of the Board of Directors and/or others, or any party of the suit that are in your possession or subject to your control that you expect to present as evidence at any hearings under this cause action. 26.5.31. All records, receipts, lists, acknowledgments, canceled checks, of any and all payments made to you either by cash or any other form of payment while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division, paid by any individual or entity. 26.5.32. A copy of all police reports and/or evidence intended to be used that you expect to present as evidence at any hearings under this cause action. 26.5.33. A copy of all policies of insurance whether life, health, fire, liability, disability, home owners, personal article or otherwise in which the parties took out or claim any insurable interest while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 26.5.34. A copy of any notes, bills, statements, invoices, evidence in any account receivable or indebtedness owed or paid to you by any Defendant while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 26.5.35. A copy of all records that reflect your criminal record to include but not limited to any arrests, warrants, etc. 26.5.36. A copy of all documents that you expect to present as evidence at any hearings under this cause action. 26.5.37. A copy of all pictures that you expect to present as evidence at any hearings under this cause action. 26.5.38. A copy of all videos that you expect to present as evidence at any hearings under this cause action. 26.5.39. A copy of your entire records including but not limited to whether they are electronic records, papers documents, emails, letters, audio recordings, video recordings, billing, itemized statements, expense records, faxes, telephone calls, and any other records relating to the submission of the claim number generated by PHILADELPHIA under claim number PHFF12070652315. 26.5.40. A copy of the entire package you provided PHILADELPHIA for payment under the claim number PHFF12070652315. 26.5.41. A copy of any deposits of any monetary compensation received by you from any Defendant or by a third party on behalf and for the benefit of any Defendant from January 1st, 2011, to present.
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26.5.42. A copy of the contract you have entered with any person representing you and/or assisting you in any form in this cause of action. 26.5.43. A copy of the payments you have made to any person representing you and/or assisting you in any form in this cause of action. 26.5.44. A copy of any payments you have made to any person or made by a third party on your behalf and for your benefit for the legal representation under this case. 26.5.45. A copy of any evidence that supports your contention that you were entitled and/or had the right to filed a claim against Plaintiffs insurance policy with PHILADELPHIA. 26.5.46. A copy of any evidence that supports your contention that you had the appropriate authorization to filed a claim against Plaintiffs insurance policy with PHILADELPHIA. XXVII. REQUEST FOR INTERROGATORIES TO ROBERT W . WILSON 27.1. TO: ROBERT W . W ILSON, 115 E. Travis, Suite 1900, San Antonio, Texas 78212.
27.4.1 All information that is not privileged that is in the possession of ROBERT W . W ILSON , his attorney, investigators, agents, and consulting experts, as defined in the Texas Rules of Civil Procedure, employees, or other representatives of ROBERT W . W ILSON is to be divulged. Possession, custody, or control of an item means that the person either has physical possession of the item or has a right to possession of the item that is equal or superior to that of the person who has physical possession of the item. 27.4.2. If an interrogatory calls for an answer that involves more than one part, each part of the answer must be clearly set out so that it is understandable. You must precede your answer to each separate interrogatory with the question constituting the separate interrogatory. 27.5. Option to Produce Records
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27.6.9. Please state the name, address, and telephone number of the person or persons who first contacted Defendants C & C and/or CUELLAR regarding the filing of the claim with PHILADELPHIA, claim number PHFF12070652315. 27.6.10. Please state the name, address, and telephone number of the person or persons that authorized you to file a claim against Plaintiffs insurance policy with PHILADELPHIA, claim number PHFF12070652315. 27.6.11. Please briefly state the legal theories and factual allegations that supports your contention that you were entitled to file a claim against Plaintiffs insurance policy, PHILADELPHIA, claim number PHFF12070652315. 27.6.12. Please state the name, address and telephone number of every person you had contact before, during, and after your filing regarding the claim with PHILADELPHIA, claim number PHFF12070652315. 27.6.13. Please state the date that you received approval from Plaintiff that authorized you to file a claim against Plaintiffs insurance policy with PHILADELPHIA, claim number PHFF12070652315. 27.6.14. Please state the steps you took to ensure you obtained the proper approval from Plaintiff in order for you to be able to filed the claim against Plaintiffs insurance carrier, PHILADELPHIA, claim number PHFF12070652315. 27.6.15. Please state the name, address, and telephone number of the person or persons you kept informed withing Plaintiffs Board of Directors (excluding you if you are a member of the board or any other Defendant) regarding the claim filed against Plaintiffs insurance policy issued by PHILADELPHIA, claim number PHFF12070652315. 27.6.16. If you claim that you have the approval from Plaintiff to filed a claim against Plaintiffs insurance policy with PHILADELPHIA as a result of your involvement in the suit filed under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division , please state what steps you took to ensure that yo have the proper approval from Plaintiff to filed such claim. 27.6.17. If you contend that you were entitled to file a claim against Plaintiffs insurance policy with PHILADELPHIA as a result of your involvement in the suit filed under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division , please state your legal theories and factual allegations that support your contention that you were entitle to filed such claim. 27.6.18. Please state the name, address, and telephone number of the person or persons who first contacted PHILADELPHIA regarding the filing of claim number PHFF12070652315. XXVIII. REQUEST FOR DISCLOSURE TO DEFENDANT C & C INSURANCE SERVICES INC. 28.1. TO: C & C INSURANCE SERVICES, INC., by serving its agent LUZ STELLA CUELLAR at 4511 Collington Court, Missouri City, Texas 77459. 28.2. Pursuant to rule 194 of the Texas Rules of Civil Procedure, you are requested to disclose, within 30 days after service of this request, the information or material described in rule 194 as set forth in the attached request. The originals or copies of documents and other tangible items requested must be produced for inspection and copying at 909 N.E. Loop 410, Suite 715, San Antonio, TX 78209 within 30 days after service of this request, together with a written response. Each written response must be preceded by the request to which it applies. No objection or assertion of work product privilege is permitted to a request under this rule. If you fail to comply with this request, the court may
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order sanctions against you in accordance with the Texas Rules of Civil Procedure. Your response must be signed. 28.3. RULE 194 REQUEST
28.3.1. State the correct names of the parties to the lawsuit. 28.3.2. State the names, addresses, and telephone numbers of any potential parties. 28.3.3. State the legal theories and, in general, the factual bases of the claims or defenses of INSURANCE SERVICES, INC.. 28.3.4. State the amount and any method of calculating economic damages. 28.3.5. State the names, addresses, and telephone numbers of persons having knowledge of relevant facts, and give a brief statement of each identified person's connection with the case. 28.3.6. For any testifying expert a. b. c. state the expert's name, address, and telephone number; state the subject matter on which the expert will testify; state the general substance of the expert's mental impressions and opinions and a brief summary of the basis for them or, if the expert is not retained by, employed by, or otherwise subject to the control of C & C INSURANCE SERVICES, INC., documents reflecting such information; if an expert is retained by, employed by, or otherwise subject to the control of C & C INSURANCE SERVICES, INC., produce the originals or copies of the following: i. all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert's testimony; and, the expert's current resume and bibliography. C & C
d.
ii.
28.3.7. Produce the originals or copies of any indemnity and insuring agreements described in rule 192.3(f) of the Texas Rules of Civil Procedure. Rule 192.3(f) provides in part as follows: Indemnity and Insuring Agreements. Except as otherwise provided by law, a party may obtain discovery of the existence and contents of any indemnity or insurance agreement under which any person may be liable to satisfy part or all of a judgment rendered in the action or to indemnify or reimburse for payments made to satisfy the judgment. 28.3.8. Produce the originals or copies of any settlement agreements described in rule 192.3(g) of the Texas Rules of Civil Procedure. Rule 192.3(g) provides in part as follows: Settlement Agreements. A party may obtain discovery of the existence and contents of any relevant portions of a settlement agreement. 28.3.9. Produce the originals or copies of any witness statements described in rule 192.3(h) of the Texas Rules of Civil Procedure. Rule 192.3(h) provides in part as follows. Statements of Persons with Knowledge of Relevant Facts. A party may obtain discovery of the statement of any person with knowledge of relevant facts - a "witness statement" - regardless of when the statement was made. A witness statement is (1) a written statement signed or otherwise adopted or approved in writing by the person making it, or (2) a stenographic, mechanical, electrical, or other type of recording of a witness's oral statement, or any substantially verbatim transcription of such a recording. Any person may obtain, upon written request, his or her own statement concerning the lawsuit, which is in the possession, custody or control of any
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party. 28.3.10. State the name, address, and telephone number of any person who may be designated as a third party. XXIX. REQUEST FOR PRODUCTION TO C & C INSURANCE SERVICES INC. 29.1. TO: C & C INSURANCE SERVICES, INC., by serving its agent LUZ STELLA CUELLAR at 4511 Collington Court, Missouri City, Texas 77459. 29.2. Please take notice that request is hereby made, pursuant to Rules 192 and 196 of the Texas Rules of Civil Procedure, that C & C INSURANCE SERVICES, INC., produce to the undersigned attorney for LULAC any and all documents responsive to the attached Requests for Production of Documents. 29.3. W ithin 30 days after service of this Request for Production of Documents, JOE CARDENAS, shall file a written response stating with respect to each request that documents are being attached as requested unless the request is objected to, in which event the reason for the objection shall be stated. 29.4. DEFINITIONS AND INSTRUCTIONS
29.4.1. As used herein, the terms you and your shall refer to BEATRICE ALBA M ARTINEZ, the attorneys, agents, and all other natural persons or business or legal entities acting or purporting to act for or on behalf of BEATRICE ALBA MARTINEZ, whether authorized to do so or not. 29.4.2. The term documents shall mean all writings of every kind, source, and authorship, both originals and all nonidentical copies thereof; in your possession or known by you to exits, irrespective of whether the writing is one intended for or transmitted internally by you, or intended for or transmitted to any other person or entity, including without limitation any government agency, department, administrative entity, or any private entity, or any person. 29.4.3. A document is deemed to be in your possession, custody or control if you have either actual physical possession of a document or constructive possession of the document. Constructive possession means that you have a superior right to compel the production of such document or a copy thereof from a third party having actual physical possession of the document. 29.4.4. The term shall include handwritten, typewritten, printed, photocopied, photographic, or recorded matter. It shall include communications in words, symbols, pictures, sound recordings, films, tapes, and information stored in, or accessible through, computer or other information storage or retrieval systems, together with the codes and/or programming instructions and other materials necessary to understand and use such systems. For purposes of illustration and not limitation, the term shall include: affidavits; agendas; agreements; analyses; announcements; bills, statements, and other records of obligations and expenditures; books; brochures; bulletins; calendars; canceled checks, vouchers, receipts and other records of payments; charts, drawings; check registers; checkbooks; circulars; collateral files and contents; contracts; corporate by-laws; corporate charters; correspondence; credit files and contents; deeds of trust; deposit slips; diaries, drafts; files; guaranty agreements; instructions; invoices; ledgers, journals balance sheets, profit and loss statements, and other sources of financial data; letters; logs, notes, or memoranda of telephonic or face-to-face conversations; manuals; memoranda of all kinds, to and from any persons, agencies, or entities; minutes; minute books; notes; notices; parts lists; papers; press releases; printed matter (including published books, articles, speeches, and newspaper clippings); purchase orders; records; records of administrative, technical, and financial actions taken or recommended; reports; safety deposit boxes and contents and records of entry; schedules; security agreements; specifications; statement of bank accounts; statements, interviews; stock transfer ledger; technical and engineering reports, evaluations, advice, recommendations, commentaries, conclusions, studies, test plans, manuals, procedures, data, reports, results, and conclusions; summaries, notes, and other records and recordings of any conferences, meetings, visits, statements, interviews or telephone conversations; telegrams; teletypes and other communications sent or received; transcripts of testimony; UCC instruments; work papers; and all other writings, the contents of which relate to, discuss, consider, or otherwise refer to the subject matter of the particular discovery requested.
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29.4.5. Person: The term person shall include individuals, associations, partnerships, corporations, and any other type of entity or institution whether formed for business purposes or any other purposes. 29.4.6. Identify or Identification: (1) W hen used in reference to a person, identify or identification means to state his or her full name, present or last known residence address, present or last known business address and telephone number. (2) W hen used in reference to a public or private corporation, governmental entity, partnership or association, identify or identification means to state its full name, present or last known business address or operating address, the name of its chief executive officer and telephone number. (3) following: W hen used in reference to a document, identify or identification shall include statement of the
(a) the title, heading, or caption, if any, of such document; (b) the identifying number(s), letter(s), or combination thereof; if any; and the significance or meaning of such number(s), letter(s), or combination thereof; if necessary to an understanding of the document and evaluation of any claim of protection from discovery; (c) the date appearing on such document; if no date appears thereon, the answer shall so state and shall give the date or approximate date on which such document was prepared; (d) the number of pages and the general nature or description of such document (i.e., whether it is a letter, memorandum, minutes of a meeting, etc.), with sufficient particularity so as to enable such document to be precisely identified; (e) the name and capacity of the person who signed such document; if it was not signed, the answer shall so state and shall give the name of the person or persons who prepared it; (f) the name and capacity of the person to whom such document was addressed and the name and capacity of such person, other than such addressee, to whom such document, or a copy thereof; was sent; and (g) the physical location of the document and the name of its custodian or custodians. (4) Unless a specific date or dates is set forth in any specific question herein, you are directed that each question shall be answered for the period of time up to the present date. 29.5. REQUEST FOR PRODUCTION 29.5.1. A copy of all contracts you have entered with any Defendant or for the representation of any Defendant at any time. 29.5.2. A copy of all employment information, including without limitation, wages, salaries, bonuses, stock options, commission, earnings, income, employment contracts, pay raises, promotions, payroll deductions of any kind, credit union accounts, pension plans, pension funds, retirement plans, retirement funds, stock plan and stock fund or other benefits or deductions of any kind which are, were, previously or which may be in the future paid, available, accepted, rejected, credited, offered, withheld for any purpose by any individual, agency, department, company or otherwise, or to which you are, were or may become entitled in the future since January 1st, 2011. 29.5.3. A copy of all records indicating any and all income received by you from any and all sources since January 1st, 2011. 29.5.4. A copy of all savings accounts, credit union or other passbooks of yours, including those held by you in your name or in your name jointly with any person or any entity, or in your name as trustee for any other person, since January 1st, 2011. 29.5.5. A copy of all records pertaining to deeds or real estate in which you have acquired or may have acquired any interest at any time, including any leases, mortgages, appraisals or market analysis related thereto, together with any evidence showing all contributions in cash or otherwise made by you to effect the acquisition of such real estate.
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29.5.6. A copy of all sales agreements and/or options for any real estate owned by you and those held by you in your name jointly with any person or in your name as trustee or guardian for any other person or stock evidencing ownership interest in a corporation holding real estate as its assets since January 1st, 2011. 29.5.7. A copy of all securities and investments owned or purchased by you since January 1st, 2011. 29.5.8. A copy of all financial statements, balance sheets and income statements received by you or prepared by an accountant or any other person for you or for any business you have had an interest in including without limitation, any and all proprietorships, joint ventures, partnerships, realty trust, corporations or other legal entities in which you hold a legal or equitable ownership or interest, individually or otherwise, since January 1st, 2011. 29.5.9. A copy of all partnerships, joint venture agreements, declarations of trust, and/or corporate records in which you have a legal or equitable interest, since January 1st, 2011. 29.5.10. A copy of all registrations to motor vehicles currently owned by you. 29.5.11.A copy of all records pertaining to the transfer by gift or sale of any and all property of whatsoever kind or nature for the dates requested, such records to include any and all information relative to gains or losses realized from transactions involving such transfer since the filing of this suit. 29.5.12. Names, addresses, and telephone numbers of any and all proposed expert witnesses and all tangible reports, physical models, compilations of date and other material prepared by an expert or for an expert for this cause of action. 29.5.13. A copy of all telephone bills for any and all telephone numbers obtained in your name since January 1st, 2011. 29.5.14. A copy of all supporting documents evidencing all expenses you incurred while involved (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 29.5.15. A copy of all recorded statements of any and all witness and/or experts you intend to call at the time of trial of this cause. 29.5.16. The names, addresses, telephone numbers (home and work) and any relevant documents relating to all persons having knowledge of relevant facts who may be called at trial in this case. 29.5.17. A copy of all supporting documents evidencing all legal fees you incurred while involved (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv0296, In The United States District Court for The W estern District of Texas, El Paso Division. 29.5.18. A copy of all records indicating all interest of any kind held by you in any and all corporations (foreign or domestic) or any other entities not evidenced by certificates or other instruments since January 1st, 2011. 29.5.19. A copy of all records regarding the communications you had with PHILADELPHIAs attorneys regarding the submission of the claim number generated by PHILADELPHIA under claim number PHFF12070652315. 29.5.20. A copy of all records relative to all inter vivos trusts from which benefits have been received, are being received or will be received by you, whether such trusts are revocable or non-revocable since January 1st, 2011. 29.5.21. A copy of all declarations of trust, and minute books for all trusts to which you are a party. 29.5.22. A copy of all corporate records (articles of organization. by-laws and minute books) for every corporation in which you have a legal or equitable ownership interest at the time this suit was filed.
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29.5.23. A copy of all books and records showing any fringe benefits available to you from any business entity in which you have a legal or equitable ownership interest, including without limitation, bonuses, health accident and hospital insurance. 29.5.24. A copy of all records and statements pertaining to any interest which you may have in any pension, retirement or profit-sharing plans, including copies of the plans. 29 29.5.25. A copy of all personal financial statements prepared by an accountant or any other person for you or for any business in which you have or had an interest since 2011. 29.5.26. A copy of all records of all bank accounts you which you are or were authorized to draw funds since January 1st, 2011. 29.5.27. A copy of any records reflecting the names and addresses of all persons who were witnesses to or have knowledge or information of any relevant facts relating to this action or who possess proof of any incident(s) or who were eyewitnesses; all written memoranda and reports and photographs submitted to you or your attorney by any such person, and all tape recordings or other evidence prepared from tape recordings made in connection with any wiretapping or other electronic surveillance conducted by you or others on your behalf. 29.5.28. A copy of all photographs in your possession or under your control, which you intend to or may offer at the time of trial. 29.5.29. A copy of all tape recordings, sound reproductions, video tapes or movies of you and/or Plaintiff, Plaintiff agent, representatives, or member of the Board of Directors and/or others in your possession or subject to your control that you expect to present as evidence at any hearings under this cause action. 29.5.30. A copy of all personal calendars, diaries, memoranda, letters, recordings (whether video, telephone, cassette, etc.), photographs, newspaper articles, hand written notes, and any other tangible item in your possession or being held for your behalf, whether containing information regarding you, Plaintiff, Plaintiffs agent, representatives, or members of the Board of Directors and/or others, or any party of the suit that are in your possession or subject to your control that you expect to present as evidence at any hearings under this cause action. 29.5.31. All records, receipts, lists, acknowledgments, canceled checks, of any and all payments made to you either by cash or any other form of payment while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division, paid by any individual or entity. 29.5.32. A copy of all police reports and/or evidence intended to be used that you expect to present as evidence at any hearings under this cause action. 29.5.33. A copy of all policies of insurance whether life, health, fire, liability, disability, home owners, personal article or otherwise in which the parties took out or claim any insurable interest while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 29.5.34. A copy of any notes, bills, statements, invoices, evidence in any account receivable or indebtedness owed or paid to you by any Defendant while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 29.5.35. A copy of all records that reflect your criminal record to include but not limited to any arrests, warrants, etc. 29.5.36. A copy of all documents that you expect to present as evidence at any hearings under this cause action. 29.5.37. A copy of all pictures that you expect to present as evidence at any hearings under this cause action.
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29.5.38. A copy of all videos that you expect to present as evidence at any hearings under this cause action. 29.5.39. A copy of your entire records including but not limited to whether they are electronic records, papers documents, emails, letters, audio recordings, video recordings, billing, itemized statements, expense records, faxes, telephone calls, and any other records relating to the submission of the claim number generated by PHILADELPHIA under claim number PHFF12070652315. 29.5.40. A copy of the entire package you provided PHILADELPHIA for payment under the claim number PHFF12070652315. 29.5.41. A copy of any deposits of any monetary compensation received by you from any Defendant or by a third party on behalf and for the benefit of any Defendant from January 1st, 2011, to present. 29.5.42. A copy of the contract you have entered with any person representing you and/or assisting you in any form in this cause of action. 29.5.43. A copy of the payments you have made to any person representing you and/or assisting you in any form in this cause of action. 29.5.44. A copy of any payments you have made to any person or made by a third party on your behalf and for your benefit for the legal representation under this case. 29.5.45. A copy of any evidence that supports your contention that you were entitled and/or had the right to filed a claim against Plaintiffs insurance policy with PHILADELPHIA. 29.5.46. A copy of any evidence that supports your contention that you had the appropriate authorization to filed a claim against Plaintiffs insurance policy with PHILADELPHIA. 29.5.47. A copy of your entire file regarding your insurance agent relationship with Plaintiff. XXX. REQUEST FOR INTERROGATORIES TO C & C INSURANCE SERVICES INC. 30.1. TO: C & C INSURANCE SERVICES, INC., by serving its agent LUZ STELLA CUELLAR at 4511 Collington Court, Missouri City, Texas 77459. 30.2. Under rules 190 and 197 of the Texas Rules of Civil Procedure, you are required to answer in complete detail and in writing each of the attached interrogatories, sign your answers to the interrogatories, swear to the truth of your answers before a notary public or other judicial officer as required by rules 191.3(a) and 197.2(d) of the Texas Rules of Civil Procedure, and deliver a complete, signed, and notarized copy of your answers to the undersigned attorney within 30 days following service of this request. If you fail to comply with the requirements above, the Court may order sanctions against you in accordance with the Texas Rules of Civil Procedure. 30.3. Definitions
30.3.1 "Identity and location" means the person's name and present or last known address and telephone number. If any of the above information is not available, state any other means of identifying the individual. 30.3.2 "Person" includes and is intended to mean any natural person or the representative of any company, limited liability company, firm, nonpublicly traded corporation, association, trust, business trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity. 30.3.3. "Entity" or "entities" includes and is intended to mean any company, limited liability company, firm, nonpublicly traded corporation, association, trust, business trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity.
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30.4.
Instructions
30.4.1 All information that is not privileged that is in the possession of C & C INSURANCE SERVICES, INC. , his attorney, investigators, agents, and consulting experts, as defined in the Texas Rules of Civil Procedure, employees, or other representatives of C & C INSURANCE SERVICES, INC. is to be divulged. Possession, custody, or control of an item means that the person either has physical possession of the item or has a right to possession of the item that is equal or superior to that of the person who has physical possession of the item. 30.4.2. If an interrogatory calls for an answer that involves more than one part, each part of the answer must be clearly set out so that it is understandable. You must precede your answer to each separate interrogatory with the question constituting the separate interrogatory. 30.5. Option to Produce Records
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30.6.9. Please state the name, address, and telephone number of the person or persons who first contacted you regarding the filing of the claim with PHILADELPHIA, claim number PHFF12070652315. 30.6.10. Please state the name, address, and telephone number of the person or persons that authorized you to file a claim against Plaintiffs insurance policy with PHILADELPHIA, claim number PHFF12070652315. 30.6.11. Please briefly state the legal theories and factual allegations that supports your contention that you were entitled to file a claim against Plaintiffs insurance policy, PHILADELPHIA, claim number PHFF12070652315. 30.6.12. Please state the name, address and telephone number of every person you had contact before, during, and after your filing regarding the claim with PHILADELPHIA, claim number PHFF12070652315. 30.6.13. Please state the date that you received approval from Plaintiff that authorized you to file a claim against Plaintiffs insurance policy with PHILADELPHIA, claim number PHFF12070652315. 30.6.14. Please state the steps you took to ensure you obtained the proper approval from Plaintiff in order for you to be able to filed the claim against Plaintiffs insurance carrier, PHILADELPHIA, claim number PHFF12070652315. 30.6.15. Please state the name, address, and telephone number of the person or persons you kept informed withing Plaintiffs Board of Directors (excluding you if you are a member of the board or any other Defendant) regarding the claim filed against Plaintiffs insurance policy issued by PHILADELPHIA, claim number PHFF12070652315. 30.6.16. If you claim that you have the approval from Plaintiff to filed a claim against Plaintiffs insurance policy with PHILADELPHIA as a result of your involvement in the suit filed under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division , please state what steps you took to ensure that yo have the proper approval from Plaintiff to filed such claim. 30.6.17. If you contend that you were entitled to file a claim against Plaintiffs insurance policy with PHILADELPHIA as a result of your involvement in the suit filed under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division , please state your legal theories and factual allegations that support your contention that you were entitle to filed such claim. 30.6.18. Please state the name, address, and telephone number of the person or persons who first contacted PHILADELPHIA regarding the filing of claim number PHFF12070652315. 30.6.19. Please state the name, address, and telephone number of the person or persons who you contacted at PHILADELPHIA regarding the filing of the claim with PHILADELPHIA, claim number PHFF12070652315.
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XXXI. REQUEST FOR DISCLOSURE TO DEFENDANT LUZ STELLA CUELLAR 31.1. TO: LUZ STELLA CUELLAR, 4511 Collington Court, Missouri City, Texas 77459.
31.3.1. State the correct names of the parties to the lawsuit. 31.3.2. State the names, addresses, and telephone numbers of any potential parties. 31.3.3. State the legal theories and, in general, the factual bases of the claims or defenses of LUZ STELLA CUELLAR. 31.3.4. State the amount and any method of calculating economic damages. 31.3.5. State the names, addresses, and telephone numbers of persons having knowledge of relevant facts, and give a brief statement of each identified person's connection with the case. 31.3.6. For any testifying expert a. b. c. state the expert's name, address, and telephone number; state the subject matter on which the expert will testify; state the general substance of the expert's mental impressions and opinions and a brief summary of the basis for them or, if the expert is not retained by, employed by, or otherwise subject to the control of LUZ STELLA CUELLAR, documents reflecting such information; if an expert is retained by, employed by, or otherwise subject to the control of LUZ STELLA CUELLAR, produce the originals or copies of the following: i. all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert's testimony; and, the expert's current resume and bibliography.
d.
ii.
31.3.7. Produce the originals or copies of any indemnity and insuring agreements described in rule 192.3(f) of the Texas Rules of Civil Procedure. Rule 192.3(f) provides in part as follows: Indemnity and Insuring Agreements. Except as otherwise provided by law, a party may obtain discovery of the existence and contents of any indemnity or insurance agreement under which any person may be liable to satisfy part or all of a judgment rendered in the action or to indemnify or reimburse for payments made to satisfy the judgment. 31.3.8. Produce the originals or copies of any settlement agreements described in rule 192.3(g) of the Texas Rules of Civil Procedure. Rule 192.3(g) provides in part as follows: Settlement Agreements. A party may obtain discovery of the existence and contents of any relevant portions of a settlement agreement.
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31.3.9. Produce the originals or copies of any witness statements described in rule 192.3(h) of the Texas Rules of Civil Procedure. Rule 192.3(h) provides in part as follows. Statements of Persons with Knowledge of Relevant Facts. A party may obtain discovery of the statement of any person with knowledge of relevant facts - a "witness statement" - regardless of when the statement was made. A witness statement is (1) a written statement signed or otherwise adopted or approved in writing by the person making it, or (2) a stenographic, mechanical, electrical, or other type of recording of a witness's oral statement, or any substantially verbatim transcription of such a recording. Any person may obtain, upon written request, his or her own statement concerning the lawsuit, which is in the possession, custody or control of any party. 31.3.10. State the name, address, and telephone number of any person who may be designated as a third party. XXXII. REQUEST FOR PRODUCTION TO LUZ STELLA CUELLAR 32.1. TO: LUZ STELLA CUELLAR, 4511 Collington Court, Missouri City, Texas 77459.
32.2. Please take notice that request is hereby made, pursuant to Rules 192 and 196 of the Texas Rules of Civil Procedure, that LUZ STELLA CUELLAR, produce to the undersigned attorney for LULAC any and all documents responsive to the attached Requests for Production of Documents. 32.3. W ithin 30 days after service of this Request for Production of Documents, LUZ STELLA CUELLAR, shall file a written response stating with respect to each request that documents are being attached as requested unless the request is objected to, in which event the reason for the objection shall be stated. 32.4. DEFINITIONS AND INSTRUCTIONS
32.4.1. As used herein, the terms you and your shall refer to LUZ STELLA CUELLAR, the attorneys, agents, and all other natural persons or business or legal entities acting or purporting to act for or on behalf of LUZ STELLA CUELLAR, whether authorized to do so or not. 32.4.2. The term documents shall mean all writings of every kind, source, and authorship, both originals and all nonidentical copies thereof; in your possession or known by you to exits, irrespective of whether the writing is one intended for or transmitted internally by you, or intended for or transmitted to any other person or entity, including without limitation any government agency, department, administrative entity, or any private entity, or any person. 32.4.3. A document is deemed to be in your possession, custody or control if you have either actual physical possession of a document or constructive possession of the document. Constructive possession means that you have a superior right to compel the production of such document or a copy thereof from a third party having actual physical possession of the document. 32.4.4. The term shall include handwritten, typewritten, printed, photocopied, photographic, or recorded matter. It shall include communications in words, symbols, pictures, sound recordings, films, tapes, and information stored in, or accessible through, computer or other information storage or retrieval systems, together with the codes and/or programming instructions and other materials necessary to understand and use such systems. For purposes of illustration and not limitation, the term shall include: affidavits; agendas; agreements; analyses; announcements; bills, statements, and other records of obligations and expenditures; books; brochures; bulletins; calendars; canceled checks, vouchers, receipts and other records of payments; charts, drawings; check registers; checkbooks; circulars; collateral files and contents; contracts; corporate by-laws; corporate charters; correspondence; credit files and contents; deeds of trust; deposit slips; diaries, drafts; files; guaranty agreements; instructions; invoices; ledgers, journals balance sheets, profit and loss statements, and other sources of financial data; letters; logs, notes, or memoranda of telephonic or face-to-face conversations; manuals; memoranda of all kinds, to and from any persons, agencies, or entities; minutes; minute books; notes; notices; parts lists; papers; press releases; printed matter (including published books, articles, speeches, and newspaper clippings); purchase orders; records; records of administrative, technical, and financial actions taken or recommended; reports; safety deposit boxes and contents and records of entry; schedules; security agreements;
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specifications; statement of bank accounts; statements, interviews; stock transfer ledger; technical and engineering reports, evaluations, advice, recommendations, commentaries, conclusions, studies, test plans, manuals, procedures, data, reports, results, and conclusions; summaries, notes, and other records and recordings of any conferences, meetings, visits, statements, interviews or telephone conversations; telegrams; teletypes and other communications sent or received; transcripts of testimony; UCC instruments; work papers; and all other writings, the contents of which relate to, discuss, consider, or otherwise refer to the subject matter of the particular discovery requested. 32.4.5. Person: The term person shall include individuals, associations, partnerships, corporations, and any other type of entity or institution whether formed for business purposes or any other purposes. 32.4.6. Identify or Identification: (1) W hen used in reference to a person, identify or identification means to state his or her full name, present or last known residence address, present or last known business address and telephone number. (2) W hen used in reference to a public or private corporation, governmental entity, partnership or association, identify or identification means to state its full name, present or last known business address or operating address, the name of its chief executive officer and telephone number. (3) following: W hen used in reference to a document, identify or identification shall include statement of the
(a) the title, heading, or caption, if any, of such document; (b) the identifying number(s), letter(s), or combination thereof; if any; and the significance or meaning of such number(s), letter(s), or combination thereof; if necessary to an understanding of the document and evaluation of any claim of protection from discovery; (c) the date appearing on such document; if no date appears thereon, the answer shall so state and shall give the date or approximate date on which such document was prepared; (d) the number of pages and the general nature or description of such document (i.e., whether it is a letter, memorandum, minutes of a meeting, etc.), with sufficient particularity so as to enable such document to be precisely identified; (e) the name and capacity of the person who signed such document; if it was not signed, the answer shall so state and shall give the name of the person or persons who prepared it; (f) the name and capacity of the person to whom such document was addressed and the name and capacity of such person, other than such addressee, to whom such document, or a copy thereof; was sent; and (g) the physical location of the document and the name of its custodian or custodians. (4) Unless a specific date or dates is set forth in any specific question herein, you are directed that each question shall be answered for the period of time up to the present date. 32.5. REQUEST FOR PRODUCTION 32.5.1. A copy of all contracts you have entered with any Defendant or for the representation of any Defendant at any time. 32.5.2. A copy of all employment information, including without limitation, wages, salaries, bonuses, stock options, commission, earnings, income, employment contracts, pay raises, promotions, payroll deductions of any kind, credit union accounts, pension plans, pension funds, retirement plans, retirement funds, stock plan and stock fund or other benefits or deductions of any kind which are, were, previously or which may be in the future paid, available, accepted, rejected, credited, offered, withheld for any purpose by any individual, agency, department, company or otherwise, or to which you are, were or may become entitled in the future since January 1st, 2011. 32.5.3. A copy of all records indicating any and all income received by you from any and all sources since January 1st, 2011.
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32.5.4. A copy of all savings accounts, credit union or other passbooks of yours, including those held by you in your name or in your name jointly with any person or any entity, or in your name as trustee for any other person, since January 1st, 2011. 32.5.5. A copy of all records pertaining to deeds or real estate in which you have acquired or may have acquired any interest at any time, including any leases, mortgages, appraisals or market analysis related thereto, together with any evidence showing all contributions in cash or otherwise made by you to effect the acquisition of such real estate. 32.5.6. A copy of all sales agreements and/or options for any real estate owned by you and those held by you in your name jointly with any person or in your name as trustee or guardian for any other person or stock evidencing ownership interest in a corporation holding real estate as its assets since January 1st, 2011. 32.5.7. A copy of all securities and investments owned or purchased by you since January 1st, 2011. 32.5.8. A copy of all financial statements, balance sheets and income statements received by you or prepared by an accountant or any other person for you or for any business you have had an interest in including without limitation, any and all proprietorships, joint ventures, partnerships, realty trust, corporations or other legal entities in which you hold a legal or equitable ownership or interest, individually or otherwise, since January 1st, 2011. 32.5.9. A copy of all partnerships, joint venture agreements, declarations of trust, and/or corporate records in which you have a legal or equitable interest, since January 1st, 2011. 32.5.10. A copy of all registrations to motor vehicles currently owned by you. 32.5.11.A copy of all records pertaining to the transfer by gift or sale of any and all property of whatsoever kind or nature for the dates requested, such records to include any and all information relative to gains or losses realized from transactions involving such transfer since the filing of this suit. 32.5.12. Names, addresses, and telephone numbers of any and all proposed expert witnesses and all tangible reports, physical models, compilations of date and other material prepared by an expert or for an expert for this cause of action. 32.5.13. A copy of all telephone bills for any and all telephone numbers obtained in your name since January 1st, 2011. 32.5.14. A copy of all supporting documents evidencing all expenses you incurred while involved (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 32.5.15. A copy of all recorded statements of any and all witness and/or experts you intend to call at the time of trial of this cause. 32.5.16. The names, addresses, telephone numbers (home and work) and any relevant documents relating to all persons having knowledge of relevant facts who may be called at trial in this case. 32.5.17. A copy of all supporting documents evidencing all legal fees you incurred while involved (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv0296, In The United States District Court for The W estern District of Texas, El Paso Division. 32.5.18. A copy of all records indicating all interest of any kind held by you in any and all corporations (foreign or domestic) or any other entities not evidenced by certificates or other instruments since January 1st, 2011. 32.5.19. A copy of all records regarding the communications you had with PHILADELPHIAs attorneys regarding the submission of the claim number generated by PHILADELPHIA under claim number PHFF12070652315. 32.5.20. A copy of all records relative to all inter vivos trusts from which benefits have been received, are being received or will be received by you, whether such trusts are revocable or non-revocable since January 1st, 2011.
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32.5.21. A copy of all declarations of trust, and minute books for all trusts to which you are a party. 32.5.22. A copy of all corporate records (articles of organization. by-laws and minute books) for every corporation in which you have a legal or equitable ownership interest at the time this suit was filed. 32.5.23. A copy of all books and records showing any fringe benefits available to you from any business entity in which you have a legal or equitable ownership interest, including without limitation, bonuses, health accident and hospital insurance. 32.5.24. A copy of all records and statements pertaining to any interest which you may have in any pension, retirement or profit-sharing plans, including copies of the plans. 32.5.25. A copy of all personal financial statements prepared by an accountant or any other person for you or for any business in which you have or had an interest since 2011. 32.5.26. A copy of all records of all bank accounts you which you are or were authorized to draw funds since January 1st, 2011. 32.5.27. A copy of any records reflecting the names and addresses of all persons who were witnesses to or have knowledge or information of any relevant facts relating to this action or who possess proof of any incident(s) or who were eyewitnesses; all written memoranda and reports and photographs submitted to you or your attorney by any such person, and all tape recordings or other evidence prepared from tape recordings made in connection with any wiretapping or other electronic surveillance conducted by you or others on your behalf. 32.5.28. A copy of all photographs in your possession or under your control, which you intend to or may offer at the time of trial. 32.5.29. A copy of all tape recordings, sound reproductions, video tapes or movies of you and/or Plaintiff, Plaintiff agent, representatives, or member of the Board of Directors and/or others in your possession or subject to your control that you expect to present as evidence at any hearings under this cause action. 32.5.30. A copy of all personal calendars, diaries, memoranda, letters, recordings (whether video, telephone, cassette, etc.), photographs, newspaper articles, hand written notes, and any other tangible item in your possession or being held for your behalf, whether containing information regarding you, Plaintiff, Plaintiffs agent, representatives, or members of the Board of Directors and/or others, or any party of the suit that are in your possession or subject to your control that you expect to present as evidence at any hearings under this cause action. 32.5.31. All records, receipts, lists, acknowledgments, canceled checks, of any and all payments made to you either by cash or any other form of payment while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division, paid by any individual or entity. 32.5.32. A copy of all police reports and/or evidence intended to be used that you expect to present as evidence at any hearings under this cause action. 32.5.33. A copy of all policies of insurance whether life, health, fire, liability, disability, home owners, personal article or otherwise in which the parties took out or claim any insurable interest while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 32.5.34. A copy of any notes, bills, statements, invoices, evidence in any account receivable or indebtedness owed or paid to you by any Defendant while and/or as result of your involvement (either as a Defendant or as an attorney representing any Defendant) in the Federal Courts case under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division. 32.5.35. A copy of all records that reflect your criminal record to include but not limited to any arrests, warrants, etc.
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32.5.36. A copy of all documents that you expect to present as evidence at any hearings under this cause action. 32.5.37. A copy of all pictures that you expect to present as evidence at any hearings under this cause action. 32.5.38. A copy of all videos that you expect to present as evidence at any hearings under this cause action. 32.5.39. A copy of your entire records including but not limited to whether they are electronic records, papers documents, emails, letters, audio recordings, video recordings, billing, itemized statements, expense records, faxes, telephone calls, and any other records relating to the submission of the claim number generated by PHILADELPHIA under claim number PHFF12070652315. 32.5.40. A copy of the entire package you provided PHILADELPHIA for payment under the claim number PHFF12070652315. 32.5.41. A copy of any deposits of any monetary compensation received by you from any Defendant or by a third party on behalf and for the benefit of any Defendant from January 1st, 2011, to present. 32.5.42. A copy of the contract you have entered with any person representing you and/or assisting you in any form in this cause of action. 32.5.43. A copy of the payments you have made to any person representing you and/or assisting you in any form in this cause of action. 32.5.44. A copy of any payments you have made to any person or made by a third party on your behalf and for your benefit for the legal representation under this case. 32.5.45. A copy of any evidence that supports your contention that you were entitled and/or had the right to filed a claim against Plaintiffs insurance policy with PHILADELPHIA. 32.5.46. A copy of any evidence that supports your contention that you had the appropriate authorization to filed a claim against Plaintiffs insurance policy with PHILADELPHIA. XXXIII. REQUEST FOR INTERROGATORIES TO LUZ STELLA CUELLAR 33.1. TO: LUZ STELLA CUELLAR, 4511 Collington Court, Missouri City, Texas 77459.
33.3.1 "Identity and location" means the person's name and present or last known address and telephone number. If any of the above information is not available, state any other means of identifying the individual. 33.3.2 "Person" includes and is intended to mean any natural person or the representative of any company, limited liability company, firm, nonpublicly traded corporation, association, trust, business trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity.
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33.3.3. "Entity" or "entities" includes and is intended to mean any company, limited liability company, firm, nonpublicly traded corporation, association, trust, business trust, partnership, limited partnership, family limited partnership, limited liability partnership, joint venture, proprietorship, or any other form of business entity. 33.4. Instructions
33.4.1 All information that is not privileged that is in the possession of LUZ STELLA CUELLAR , his attorney, investigators, agents, and consulting experts, as defined in the Texas Rules of Civil Procedure, employees, or other representatives of LUZ STELLA CUELLAR is to be divulged. Possession, custody, or control of an item means that the person either has physical possession of the item or has a right to possession of the item that is equal or superior to that of the person who has physical possession of the item. 33.4.2. If an interrogatory calls for an answer that involves more than one part, each part of the answer must be clearly set out so that it is understandable. You must precede your answer to each separate interrogatory with the question constituting the separate interrogatory. 33.5. Option to Produce Records
33.6.1. State the name, address, and telephone number of any person who is expected to be called to testify at the trial of this lawsuit.
33.6.2. State which of your answers to these interrogatories are based on information obtained from other persons and state the name, address, and telephone number of each person from whom you obtained the information and the date the information was obtained. 33.6.3. If you, at any time, had possession or control of a document requested in a request for production, and if the document has been lost, has been destroyed, or is not presently in your possession, custody, or control, describe the document, the date of its loss, destruction, purge, or separation from your possession, custody, or control, and the circumstances surrounding its loss, destruction, purge, or separation from your possession, custody, or control. 33.6.4. If any person or entity with which you are associated provides you with any fringe benefits (fringe benefits include but are not limited to payment of personal expenses; payment of housing expenses; payment of medical, hospitalization, or dental insurance, life insurance, annuities, and disability insurance policies; payment of automobile expenses including note payment, gasoline, repairs, maintenance, insurance, and mileage compensation; payment of travel allowances; deferred compensation plans, 401(k) contributions, stock options, or retirement or pension benefits; country club or other memberships; bonuses or dividends of any kind; use of company airplanes, homes, boats, or cars; payment of business professional dues; interest-free or low-interest loans; payment of legal fees; accounting or bookkeeping services; and payment for items used by you personally), state for each fringe benefit-cost. a. b. c. a description of the fringe benefit; the amount paid monthly by the person or entity for the fringe benefit; and, the specific person or entity providing each fringe benefit.
33.6.5. If you claim any property (tangible or intangible) is protected by law from execution under a Court Judgment or under the homestead protections afforded by the State of Texas, for each item of property state-
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a. b. c.
a description of the property; all facts supporting your claims; and your opinion of the value of the property.
33.6.9. Please state the name, address, and telephone number of the person or persons who first contacted you regarding the filing of the claim with PHILADELPHIA, claim number PHFF12070652315. 33.6.10. Please state the name, address, and telephone number of the person or persons that authorized you to file a claim against Plaintiffs insurance policy with PHILADELPHIA, claim number PHFF12070652315. 33.6.11. Please briefly state the legal theories and factual allegations that supports your contention that you were entitled to file a claim against Plaintiffs insurance policy, PHILADELPHIA, claim number PHFF12070652315. 33.6.12. Please state the name, address and telephone number of every person you had contact before, during, and after your filing regarding the claim with PHILADELPHIA, claim number PHFF12070652315. 33.6.13. Please state the date that you received approval from Plaintiff that authorized you to file a claim against Plaintiffs insurance policy with PHILADELPHIA, claim number PHFF12070652315. 33.6.14. Please state the steps you took to ensure you obtained the proper approval from Plaintiff in order for you to be able to filed the claim against Plaintiffs insurance carrier, PHILADELPHIA, claim number PHFF12070652315. 33.6.15. Please state the name, address, and telephone number of the person or persons you kept informed withing Plaintiffs Board of Directors (excluding you if you are a member of the board or any other Defendant) regarding the claim filed against Plaintiffs insurance policy issued by PHILADELPHIA, claim number PHFF12070652315. 33.6.16. If you claim that you have the approval from Plaintiff to filed a claim against Plaintiffs insurance policy with PHILADELPHIA as a result of your involvement in the suit filed under Civil Number EP:12-cv-0296, In The United States District Court for The Western District of Texas, El Paso Division , please state what steps you took to ensure that yo have the proper approval from Plaintiff to filed such claim. 33.6.17. If you contend that you were entitled to file a claim against Plaintiffs insurance policy with PHILADELPHIA as a result of your involvement in the suit filed under Civil Number EP:12-cv-0296, In The United States District Court for The W estern District of Texas, El Paso Division, please state your legal theories and factual allegations that support your contention that you were entitle to filed such claim. 33.6.18. Please state the name, address, and telephone number of the person or persons who first contacted PHILADELPHIA regarding the filing of claim number PHFF12070652315.
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33.6.19. Please state the name, address, and telephone number of the person or persons who you contacted at PHILADELPHIA regarding the filing of the claim with PHILADELPHIA, claim number PHFF12070652315. XXXIV. PRAYER 34. W HEREFORE, PREMISES CONSIDERED, LEAGUE OF UNITED LATIN AMERICAN CITIZENS, INC. respectfully requests that Defendants be cited to appear and answer herein, and that upon final trial or hearing, LEAGUE OF UNITED LATIN AMERICAN CITIZENS, INC. have and recover judgement against Defendants: 34.1. For all actual, punitive and consequential damages arising from the actions described herein; 34.2. For pre- and post-judgment interest; 34.3. For reasonable and necessary attorneys fees; 34.4. For costs of court; and 34.5. For all such other and further relief, both general and special, at law and in equity, to which LEAGUE OF UNITED LATIN AMERICAN CITIZENS, INC. may show itself justly entitled. Respectfully submitted, ORTIZ LAW OFFICES, P.C. 909 NE Loop 410, Suite 715 San Antonio, Texas 78209 (210) 822-4200 (210) 822-4208 fax
By: Miguel A. Ortiz State Bar No. 24029757 ATTORNEY FOR PLAINTIFF LEAGUE OF UNITED LATIN AMERICAN CITIZENS, INC.
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LULAC Sues Linda Chavez Et Al and More Again

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LULAC Sues Linda Chavez Et Al and More Again

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CAUSE NO.______________ LEAGUE OF UNITED LATIN AM ERICAN CITIZENS, INC. Plaintiff, V.

AT LAW NO. ______

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the date; and the circumstances of each.

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the expert's current resume and bibliography.

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