On May 11, 2021 a
Stipulation,Agreement
was filed
involving a dispute between
Sunbelt Rentals, Inc.,
and
Airborne Excavation And Utility, L.L.C.,
Tagert, Jeff,
for Contract - Other
in the District Court of Smith County.
Preview
Electronically Filed
8/25/2021 11:12 AM
Penny Clarkston, Smith County District Clerk
Reviewed By: Gina McClung
EDWARD SALDANA, PLLC
A Professional limited llablllly Company law Firm edward@edsflrm.com
flrewheel Town Genier. 675 Town Square Blvd .. Sulle 200. Garland, TX 75040 I Office 214-299-7606 I Fax 214-299-7601
August 24, 2021
VIA EMAIL
Monica Schulz Orlando
Orlando & Orlando, LLP
1021 Main Street, Suite 1150
Houston, TX 77002
Re: Sunbelt Rentals, Inc. v.Airborne Excavation and Utility LLC and JejJTagert;
Cause No. 21-1074-B; in the 1141h District Court of Smith County, Texas
Dear Monica:
This will confirm our agreement pursuant to Texas Rule of Civil Procedure 11 regarding
the deadline for my clients, Airborne Excavation and Utility LLC ("Airborne") and Jeff Tagert
("Tagert") (collectively "Defendants"), to respond to the discovery requests listed below
propounded by your client, Sunbelt Rentals, Inc. ("Sunbelt" or "Plaintiff'):
1. Plaintiff's First Set of Interrogatories, Request for Admissions, and Request for
Production lo Defendant Airborne Excavation and Utility, LLC and
2. Plaintiff's First Set of Inlel'l'ogalories, Request for Admissions, and Request for
Production to Defendant Je.ffTagert.
The discove1y requests listed above are hereinafter referred to as "Plaintiffs Discovery
Requests." We have agreed that - due to current settlement efforts - the deadline for Airborne
and Tagert to serve their objections and responses to Plaintiffs Discovery Requests listed above
shall be and is hereby extended to and including September 3, 2021. If this accurately reflects
our agreement, please sign below where indicated and return to me by e-mail for filing.
Sincerely,
Edward D. Saldana, Attorney for Defendants
AGRI,ED Pl RSUANT TO RULE 11 TRCP:
M , elm z Orlando, Attorney for Plaintiff Date I 1
I
/
cf /Court (via e-file) & Airborne Excavation and Utility LLC (via e-mail)
Document Filed Date
August 25, 2021
Case Filing Date
May 11, 2021
Category
Contract - Other
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Electronically Filed 8/25/2021 11:12 AM Penny Clarkston, Smith County District Clerk Reviewed By: Gina McClung EDWARD SALDANA, PLLC A Professional limited llablllly Company law Firm edward@edsflrm.com flrewheel Town Genier. 675 Town Square Blvd .. Sulle 200. Garland, TX 75040 I Office 214-299-7606 I Fax 214-299-7601 August 24, 2021 VIA EMAIL Monica Schulz Orlando Orlando & Orlando, LLP 1021 Main Street, Suite 1150 Houston, TX 77002 Re: Sunbelt Rentals, Inc. v.Airborne Excavation and Utility LLC and JejJTagert; Cause No. 21-1074-B; in the 1141h District Court of Smith County, Texas Dear Monica: This will confirm our agreement pursuant to Texas Rule of Civil Procedure 11 regarding the deadline for my clients, Airborne Excavation and Utility LLC ("Airborne") and Jeff Tagert ("Tagert") (collectively "Defendants"), to respond to the discovery requests listed below propounded by your client, Sunbelt Rentals, Inc. ("Sunbelt" or "Plaintiff'): 1. Plaintiff's First Set of Interrogatories, Request for Admissions, and Request for Production lo Defendant Airborne Excavation and Utility, LLC and 2. Plaintiff's First Set of Inlel'l'ogalories, Request for Admissions, and Request for Production to Defendant Je.ffTagert. The discove1y requests listed above are hereinafter referred to as "Plaintiffs Discovery Requests." We have agreed that - due to current settlement efforts - the deadline for Airborne and Tagert to serve their objections and responses to Plaintiffs Discovery Requests listed above shall be and is hereby extended to and including September 3, 2021. If this accurately reflects our agreement, please sign below where indicated and return to me by e-mail for filing. Sincerely, Edward D. Saldana, Attorney for Defendants AGRI,ED Pl RSUANT TO RULE 11 TRCP: M , elm z Orlando, Attorney for Plaintiff Date I 1 I / cf /Court (via e-file) & Airborne Excavation and Utility LLC (via e-mail)