On September 20, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Rapalo, Delmy,
and
Escobar, Ana Daysi,
Escobar, Noe,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
Preview
FILED
8/9/2022 2:35 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Cassandra Walker DEPUTY
CAUSE NO. DC-21-14009
DELMY RAPALO, INDIVIDUALLY AND § 1N THE DISTRICT COURT
AS NEXT FRIEND 0F A.A.R., A MINOR §
§
§
V. § 134T“ JUDICIAL DISTRICT
§
ANA DAYSI ESCOBAR AND NOE §
ESCOBAR § DALLAS COUNTY, TEXAS
CERTIFICATE OF CONFERENCE REGARDING PLAINTIFFS’ MOTION TO
QUASH DEFENDAN TS’ NOTICE OF INTENTION TO TAKE THE ORAL
DEPOSITION OF PLAINTIFF A.A.R., A MINOR
CERTIFICATE OF CONFERENCE
I hereby certify that on July 18, 2022 counsel for the Defendants’, Alexandria Carpenter,
and Plaintiffs’, Elizabeth Moran, conferred regarding Plaintiffs’ Motion to Quash Defendants’
Notice of Intention to Take the Oral Deposition of A.A.R., Minor Plaintiff and Ms. Carpenter was
opposed.
/s/fll'axanJria K Carpenter
ALEXANDRIA K. CARPENTER
CERTIFICATE OF CONFERENCE REGARDING PLAINTIFFS’ MOTION TO QUASH
DEFENDANTS’ NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION OF
PLAINTIFF A.A.R., A MINOR PAGE 1
10000.1 135/ LEX-blp
Respectfully submitted,
THE LECRONE LAW FIRM, PC
Wall Street Plaza
123 NOIth Crockett Street, Suite 200
Sherman, TX 75090
TEL: 903.813.1900
FAX: 903.813.1944
By: /s/fl[axand'n'a K. Carpenter
JOHN W. BREEZE
State Bar No. 00796248
MARK A. TEAGUE
State Bar No. 24003039
ALEXANDRIA K. CARPENTER
State Bar No. 24101596
HILLARY LUCKETT CLARK
State Bar No. 24077714
RHONDA D. HOLCOMB
State Bar No. 24099024
BLAISE S. WILCOTT
State Bar No. 24086481
SELENE DOMINGUEZ PENA
State Bar No. 24106929
MOLLY J. KAELIN
State Bar NO. 24122949
ESERVICE@LECRONELAW.COM
ATTORNEYS FOR DEFENDANTS’
CERTIFICATE OF SERVICE
This is to certify that on the 9th day of August, 2022, the foregoing instrument was
forwarded to the following counsel of record:
Mr. Eric D. Nielsen
THE NIELSEN LAW FIRM, PC
9800 Northwest Frwy., Ste. 314
Houston, TX 77092
TEL: 713.524.4800
FAX: 888.587.9443
eric@nielsentriallaw.com
/s/fl[exanJn’a K, Carpenter
ALEXANDRIA K. CARPENTER
CERTIFICATE 0F CONFERENCE REGARDING PLAINTIFFS’ MOTION TO QUASH
DEFENDANTS’ NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION OF
PLAINTIFF A.A.R., A MINOR PAGE 2
10000.1 135/ LEX-blp
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Bethany Phelps on behalf of Alexandria Carpenter
Bar No. 24101596
bethany@lecronelaw.com
Envelope ID: 67107818
Status as of 8/9/2022 3:06 PM CST
Associated Case Party: DELMY RAPALO
Name BarNumber Email TimestampSubmitted Status
Eric Nielsen eric@nielsentriallaw.com 8/9/2022 2:35:41 PM SENT
Service TNLF service@nielsentriallaw.com 8/9/2022 2:35:41 PM SENT
Daniela Rodriguez daniela@nielsentriallaw.com 8/9/2022 2:35:41 PM SENT
Elizabeth Moran liz@nielsentriallaw.com 8/9/2022 2:35:41 PM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Bethany Phelps on behalf of Alexandria Carpenter
Bar No. 24101596
bethany@lecronelaw.com
Envelope ID: 67107818
Status as of 8/9/2022 3:06 PM CST
Associated Case Party: ANADAYSIESCOBAR
Name BarNumber Email TimestampSubmitted Status
Mark A.Teague eservice@lecronelaw.com 8/9/2022 2:35:41 PM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Bethany Phelps on behalf of Alexandria Carpenter
Bar No. 24101596
bethany@lecronelaw.com
Envelope ID: 67107818
Status as of 8/9/2022 3:06 PM CST
Associated Case Party: NOE ESCOBAR
Name BarNumber Email TimestampSubmitted Status
Mark A.Teague eservice@lecronelaw.com 8/9/2022 2:35:41 PM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Bethany Phelps on behalf of Alexandria Carpenter
Bar No. 24101596
bethany@lecronelaw.com
Envelope ID: 67107818
Status as of 8/9/2022 3:06 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Francine Ly fly@dallascourts.org 8/9/2022 2:35:41 PM SENT
Document Filed Date
August 09, 2022
Case Filing Date
September 20, 2021
Category
OTHER PERSONAL INJURY
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FILED 8/9/2022 2:35 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Cassandra Walker DEPUTY CAUSE NO. DC-21-14009 DELMY RAPALO, INDIVIDUALLY AND § 1N THE DISTRICT COURT AS NEXT FRIEND 0F A.A.R., A MINOR § § § V. § 134T“ JUDICIAL DISTRICT § ANA DAYSI ESCOBAR AND NOE § ESCOBAR § DALLAS COUNTY, TEXAS CERTIFICATE OF CONFERENCE REGARDING PLAINTIFFS’ MOTION TO QUASH DEFENDAN TS’ NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION OF PLAINTIFF A.A.R., A MINOR CERTIFICATE OF CONFERENCE I hereby certify that on July 18, 2022 counsel for the Defendants’, Alexandria Carpenter, and Plaintiffs’, Elizabeth Moran, conferred regarding Plaintiffs’ Motion to Quash Defendants’ Notice of Intention to Take the Oral Deposition of A.A.R., Minor Plaintiff and Ms. Carpenter was opposed. /s/fll'axanJria K Carpenter ALEXANDRIA K. CARPENTER CERTIFICATE OF CONFERENCE REGARDING PLAINTIFFS’ MOTION TO QUASH DEFENDANTS’ NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION OF PLAINTIFF A.A.R., A MINOR PAGE 1 10000.1 135/ LEX-blp Respectfully submitted, THE LECRONE LAW FIRM, PC Wall Street Plaza 123 NOIth Crockett Street, Suite 200 Sherman, TX 75090 TEL: 903.813.1900 FAX: 903.813.1944 By: /s/fl[axand'n'a K. Carpenter JOHN W. BREEZE State Bar No. 00796248 MARK A. TEAGUE State Bar No. 24003039 ALEXANDRIA K. CARPENTER State Bar No. 24101596 HILLARY LUCKETT CLARK State Bar No. 24077714 RHONDA D. HOLCOMB State Bar No. 24099024 BLAISE S. WILCOTT State Bar No. 24086481 SELENE DOMINGUEZ PENA State Bar No. 24106929 MOLLY J. KAELIN State Bar NO. 24122949 ESERVICE@LECRONELAW.COM ATTORNEYS FOR DEFENDANTS’ CERTIFICATE OF SERVICE This is to certify that on the 9th day of August, 2022, the foregoing instrument was forwarded to the following counsel of record: Mr. Eric D. Nielsen THE NIELSEN LAW FIRM, PC 9800 Northwest Frwy., Ste. 314 Houston, TX 77092 TEL: 713.524.4800 FAX: 888.587.9443 eric@nielsentriallaw.com /s/fl[exanJn’a K, Carpenter ALEXANDRIA K. CARPENTER CERTIFICATE 0F CONFERENCE REGARDING PLAINTIFFS’ MOTION TO QUASH DEFENDANTS’ NOTICE OF INTENTION TO TAKE THE ORAL DEPOSITION OF PLAINTIFF A.A.R., A MINOR PAGE 2 10000.1 135/ LEX-blp Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Bethany Phelps on behalf of Alexandria Carpenter Bar No. 24101596 bethany@lecronelaw.com Envelope ID: 67107818 Status as of 8/9/2022 3:06 PM CST Associated Case Party: DELMY RAPALO Name BarNumber Email TimestampSubmitted Status Eric Nielsen eric@nielsentriallaw.com 8/9/2022 2:35:41 PM SENT Service TNLF service@nielsentriallaw.com 8/9/2022 2:35:41 PM SENT Daniela Rodriguez daniela@nielsentriallaw.com 8/9/2022 2:35:41 PM SENT Elizabeth Moran liz@nielsentriallaw.com 8/9/2022 2:35:41 PM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Bethany Phelps on behalf of Alexandria Carpenter Bar No. 24101596 bethany@lecronelaw.com Envelope ID: 67107818 Status as of 8/9/2022 3:06 PM CST Associated Case Party: ANADAYSIESCOBAR Name BarNumber Email TimestampSubmitted Status Mark A.Teague eservice@lecronelaw.com 8/9/2022 2:35:41 PM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Bethany Phelps on behalf of Alexandria Carpenter Bar No. 24101596 bethany@lecronelaw.com Envelope ID: 67107818 Status as of 8/9/2022 3:06 PM CST Associated Case Party: NOE ESCOBAR Name BarNumber Email TimestampSubmitted Status Mark A.Teague eservice@lecronelaw.com 8/9/2022 2:35:41 PM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Bethany Phelps on behalf of Alexandria Carpenter Bar No. 24101596 bethany@lecronelaw.com Envelope ID: 67107818 Status as of 8/9/2022 3:06 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Francine Ly fly@dallascourts.org 8/9/2022 2:35:41 PM SENT