On September 27, 2021 a
Party Discovery
was filed
involving a dispute between
Mosco, Rose,
and
Miller, Sandra,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
12/13/2021 5:15 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Darling Tellez DEPUTY
CAUSE NO. DC-21-14355
ROSE MOSCO § IN THE DISTRICT COURT
§
V. § 134TH JUDICIAL DISTRICT
§
SANDRA MILLER § DALLAS COUNTY, TEXAS
DEFENDANT’S CERTIFICATE OF WRITTEN DISCOVERY
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Sandra Miller, Defendant in the above-entitled and numbered cause, and
files this Certificate of Written Discovery directed to Plaintiff pursuant to the TEXAS RULES 0F
CIVIL PROCEDURE, and states that the discovery set forth below was forwarded to the following
party on the flday of December, 2021:
TO: Plaintiff, Rose Mosco, by and through her attorney of record, Mr. Griffin
Scheumack, BEN ABBOTT & ASSOCIATES, PLLC, 1934 Pendleton Drive,
Garland, TX 75041.
Discovery Served
o Defendant’s First Set of Written Interrogatories to Plaintiff;
Defendant’s First Request for Production of Documents to Plaintiff; and
o Defendant’s First Request for Admissions to Plaintiff.
DEFENDANT’S CERTIFICATE OF WRITTEN DISCOVERY PAGE 1
10000.1 142
Respectfully submitted,
THE LECRONE LAW FIRM, PC
Wall Street Plaza
123 N01th Crockett Street, Suite 200
Sherman, TX 75090
TEL: 903.813.1900
FAX: 903.813.1944
By: /s/ Mark fl. Teague
MARK A. TEAGUE
State Bar No. 24003039
ALEXANDRIA K. CARPENTER
State Bar No. 24101596
JOHN W. BREEZE
State Bar No. 00796248
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 DEFENDANT
CERTIFICATE OF SERVICE
This is to certify that on the 13th day of December, 2021, the foregoing instrument was
forwarded to the following counsel of record:
Mr. Griffin Scheumack
BEN ABBOTT & ASSOCIATES, PLLC
1934 Pendleton Drive
Garland, TX 75041
/s/ Mark/1 ‘I’eague
MARK A. TEAGUE
DEFENDANT’S CERTIFICATE OF WRITTEN DISCOVERY PAGE 2
10000.1 142
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.
Envelope ID: 59982569
Status as of 12/14/2021 8:31 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
GRIFFIN SCHEMACK ESERVE@BENABBOTI'.COM 12/13/20215:15:10 PM ERROR
Document Filed Date
December 13, 2021
Case Filing Date
September 27, 2021
Category
MOTOR VEHICLE ACCIDENT
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FILED 12/13/2021 5:15 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Darling Tellez DEPUTY CAUSE NO. DC-21-14355 ROSE MOSCO § IN THE DISTRICT COURT § V. § 134TH JUDICIAL DISTRICT § SANDRA MILLER § DALLAS COUNTY, TEXAS DEFENDANT’S CERTIFICATE OF WRITTEN DISCOVERY TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Sandra Miller, Defendant in the above-entitled and numbered cause, and files this Certificate of Written Discovery directed to Plaintiff pursuant to the TEXAS RULES 0F CIVIL PROCEDURE, and states that the discovery set forth below was forwarded to the following party on the flday of December, 2021: TO: Plaintiff, Rose Mosco, by and through her attorney of record, Mr. Griffin Scheumack, BEN ABBOTT & ASSOCIATES, PLLC, 1934 Pendleton Drive, Garland, TX 75041. Discovery Served o Defendant’s First Set of Written Interrogatories to Plaintiff; Defendant’s First Request for Production of Documents to Plaintiff; and o Defendant’s First Request for Admissions to Plaintiff. DEFENDANT’S CERTIFICATE OF WRITTEN DISCOVERY PAGE 1 10000.1 142 Respectfully submitted, THE LECRONE LAW FIRM, PC Wall Street Plaza 123 N01th Crockett Street, Suite 200 Sherman, TX 75090 TEL: 903.813.1900 FAX: 903.813.1944 By: /s/ Mark fl. Teague MARK A. TEAGUE State Bar No. 24003039 ALEXANDRIA K. CARPENTER State Bar No. 24101596 JOHN W. BREEZE State Bar No. 00796248 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 DEFENDANT CERTIFICATE OF SERVICE This is to certify that on the 13th day of December, 2021, the foregoing instrument was forwarded to the following counsel of record: Mr. Griffin Scheumack BEN ABBOTT & ASSOCIATES, PLLC 1934 Pendleton Drive Garland, TX 75041 /s/ Mark/1 ‘I’eague MARK A. TEAGUE DEFENDANT’S CERTIFICATE OF WRITTEN DISCOVERY PAGE 2 10000.1 142 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. Envelope ID: 59982569 Status as of 12/14/2021 8:31 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status GRIFFIN SCHEMACK ESERVE@BENABBOTI'.COM 12/13/20215:15:10 PM ERROR