On May 28, 2020 a
PLTF'NOT OF REQ FOR PROD PER SUBP(STEPHANIE GARDNE
was filed
involving a dispute between
and
for CONTRACT, OTHER DEBT/CONTRACT
in the District Court of Tarrant County.
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236-317103-20 FILED
TARRANT COUNTY
10/22/2020 9:05 AM
THOMAS A. WILDER
NO. 236-317103-20 DISTRICT CLERK
MAHMOUD I. ELKASSIH AND § IN THE DISTRICT COURT OF
MAY B. ELKASSIH, §
§
Plaintiffs, §
§
v. § TARRANT COUNTY, TEXAS
§
§
FEDERAL NATIONAL MORTGAGE §
ASSOCIATION AND NATIONSTAR §
MORTGAGE, LLC D/B/A MR. § 236th JUDICIAL DISTRICT
COOPER
Defendant,
PLAINTIFFS’ NOTICE OF REQUEST FOR PRODUCTION PER SUBPOENA WITH
DUCES TECUM PURSUANT TO TEX. R. CIV. P. 205.2
TO THE HONORABLE JUDGE OF SAID COURT:
PLEASE TAKE NOTICE THAT, Plaintiffs Mahmoud I. Elkassih and May B. Elkassih
intend to subpoena records of Stephanie Gardner responsive to the categories set forth below.
Responsive documents are to be produced by Stephanie Gardner to The Lane Law Firm, on or
before November 16, 2020 at 5:00 p.m. This notice of request for production of documents per
Subpoena Duces Tecum is being made in compliance with Tex. R. Civ. P. 205.2 Categories of
documents sought pursuant to the Subpoena Duces Tecum will include the following:
1. Produce all documents including but not limited to notary log entries, receipts,
invoices, closing documents, emails, texts, and correspondence, from any party
including but not limited to BNT of Texas, LLC, Mahmoud I. Elkassih, or May B.
Elkassih, which in anyway relate to the loan closing by Mahmoud I. Elkassih and May
B. Elkassih on May 27, 2016 regarding the Property at: 3502 Summer Trail Ct,
Arlington, TX 76016.
1
Respectfully submitted this 22nd day of October 2020.
Respectfully submitted,
THE LANE LAW FIRM, P.L.L.C.
By: /s/ Robert “Chip” Lane
Robert “Chip” Lane
State Bar No. 2404626
notifications@lanelaw.com
Joshua D. Gordon
State Bar No. 24091592
joshua.gordon@lanelaw.com
S. Alex Lick
State Bar no. 24107844
alex.lick@lanelaw.com
6200 Savoy Drive, Suite 1150
Houston, Texas 77036-3300
(713) 595-8200 Telephone
(713) 595-8201 Facsimile
ATTORNEYS FOR PLAINTIFFS
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing was served
upon the Defendants via electronic service.
/s/ Robert “Chip” Lane
Robert “Chip” Lane
2
Document Filed Date
October 22, 2020
Case Filing Date
May 28, 2020
Category
CONTRACT, OTHER DEBT/CONTRACT
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236-317103-20 FILED TARRANT COUNTY 10/22/2020 9:05 AM THOMAS A. WILDER NO. 236-317103-20 DISTRICT CLERK MAHMOUD I. ELKASSIH AND § IN THE DISTRICT COURT OF MAY B. ELKASSIH, § § Plaintiffs, § § v. § TARRANT COUNTY, TEXAS § § FEDERAL NATIONAL MORTGAGE § ASSOCIATION AND NATIONSTAR § MORTGAGE, LLC D/B/A MR. § 236th JUDICIAL DISTRICT COOPER Defendant, PLAINTIFFS’ NOTICE OF REQUEST FOR PRODUCTION PER SUBPOENA WITH DUCES TECUM PURSUANT TO TEX. R. CIV. P. 205.2 TO THE HONORABLE JUDGE OF SAID COURT: PLEASE TAKE NOTICE THAT, Plaintiffs Mahmoud I. Elkassih and May B. Elkassih intend to subpoena records of Stephanie Gardner responsive to the categories set forth below. Responsive documents are to be produced by Stephanie Gardner to The Lane Law Firm, on or before November 16, 2020 at 5:00 p.m. This notice of request for production of documents per Subpoena Duces Tecum is being made in compliance with Tex. R. Civ. P. 205.2 Categories of documents sought pursuant to the Subpoena Duces Tecum will include the following: 1. Produce all documents including but not limited to notary log entries, receipts, invoices, closing documents, emails, texts, and correspondence, from any party including but not limited to BNT of Texas, LLC, Mahmoud I. Elkassih, or May B. Elkassih, which in anyway relate to the loan closing by Mahmoud I. Elkassih and May B. Elkassih on May 27, 2016 regarding the Property at: 3502 Summer Trail Ct, Arlington, TX 76016. 1 Respectfully submitted this 22nd day of October 2020. Respectfully submitted, THE LANE LAW FIRM, P.L.L.C. By: /s/ Robert “Chip” Lane Robert “Chip” Lane State Bar No. 2404626 notifications@lanelaw.com Joshua D. Gordon State Bar No. 24091592 joshua.gordon@lanelaw.com S. Alex Lick State Bar no. 24107844 alex.lick@lanelaw.com 6200 Savoy Drive, Suite 1150 Houston, Texas 77036-3300 (713) 595-8200 Telephone (713) 595-8201 Facsimile ATTORNEYS FOR PLAINTIFFS CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing was served upon the Defendants via electronic service. /s/ Robert “Chip” Lane Robert “Chip” Lane 2