On March 02, 2020 a
Party Statement
was filed
involving a dispute between
Reyes, Diana,
and
Allstate County Mutual Insurance Company,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
8/24/2020 3:20PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO.,TEXAS
Jeremy Jones DEPUTY
CAUSE NO. DC—20-03505
DIANA REYES, INDIVIDUALLY AND IN THE DISTRICT COURT
AS
NEXT FRIEND OF E.G. (MINOR),
Plaintiff,
192ND JUDICIAL DISTRICT
V.
ALLSTATE COUNTY MUTUAL
INSURANCE COMPANY, DALLAS COUNTY, TEXAS
Defendant.
DEFENDANT’S NOTICE OF FILING AFFIDAVIT OF RICHARD W. HARE, D.C.
TO: DIANA REYES, INDIVIDUALLY AND AS NEXT FRIEND OF E.G. (MINOR), by
and through Plaintiff(s)’ attorney 0f record, Landon Knotts, Ben Abbott & Associates,
PLLC, 1934 Pendleton Dr., Garland, TX 75041
ALLSTATE COUNTY MUTUAL INSURANCE COMPANY, hereinafter referred t0 as
Defendant whether one 0r more, pursuant t0 Rules 803(6) and 803(7) and 902(10) of the Texas
Rules 0f Civil Evidence and pursuant to the applicable sections of the Texas. CiV. Prac. &
Remedies Code, Sec. 18.001, files the attached Affidavit 0f RICHARD W. HARE, D.C. along
With the attached 19 pages ofrecords. RICHARD W. HARE, D.C. is employed by MES Solutions,
12300 Ford Rd #390, Dallas, TX 75234. A true and correct copy of these records are attached
hereto.
a1 vs. Allstate
Reyes, et PAGE 1
DEFENDANT’S NOTICE OF FILING AFFIDAVIT OF «AFFIANT»
0539944362.1
Respectfully submitted,
SUSAN L. FLORENCE & ASSOCIATES
thgwébx
KATE GARDNER
TBN: 24101788
1201 Elm Street, Suite 5050
Dallas, TX 75270
DallasLegal@allstate.com
(214) 659-43 15
(877) 678-4763 (fax)
ATTORNEY FOR DEFENDANT(S)
ALLSTATE COUNTY MUTUAL
INSURANCE COMPANY
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been served in compliance
with Rules 21 and 21a of the Texas Rules of Civil Procedure on the 24th day 0f August, 2020, to:
Landon Knotts
241 16630
Ben Abbott & Associates, PLLC
1934 Pendleton Drive
Garland, TX 75041
(972) 263-5555
(817) 263—5555
(972) 682-7586 Facsimile
eService@benabbott.com
ATTORNEYS FOR PLAINTIFF
3%ng
KATE GARDNER
et a1 vs. Allstate
Reyes, PAGE 2
DEFENDANT’S NOTICE OF FILING AFFIDAVIT OF «AFFIANT»
0539944362J
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.
Jessica Muniz on behalf of Kate Gardner
Bar No. 24101788
jmunm@allstate.com
Envelope ID: 45645595
Status as of 8/25/2020 1:57 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
LANDON KNOTTS ESERVICE@BENABBOTT.COM 8/24/2020 3:20:26 PM SENT
Document Filed Date
August 24, 2020
Case Filing Date
March 02, 2020
Category
MOTOR VEHICLE ACCIDENT
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FILED 8/24/2020 3:20PM FELICIA PITRE DISTRICT CLERK DALLAS CO.,TEXAS Jeremy Jones DEPUTY CAUSE NO. DC—20-03505 DIANA REYES, INDIVIDUALLY AND IN THE DISTRICT COURT AS NEXT FRIEND OF E.G. (MINOR), Plaintiff, 192ND JUDICIAL DISTRICT V. ALLSTATE COUNTY MUTUAL INSURANCE COMPANY, DALLAS COUNTY, TEXAS Defendant. DEFENDANT’S NOTICE OF FILING AFFIDAVIT OF RICHARD W. HARE, D.C. TO: DIANA REYES, INDIVIDUALLY AND AS NEXT FRIEND OF E.G. (MINOR), by and through Plaintiff(s)’ attorney 0f record, Landon Knotts, Ben Abbott & Associates, PLLC, 1934 Pendleton Dr., Garland, TX 75041 ALLSTATE COUNTY MUTUAL INSURANCE COMPANY, hereinafter referred t0 as Defendant whether one 0r more, pursuant t0 Rules 803(6) and 803(7) and 902(10) of the Texas Rules 0f Civil Evidence and pursuant to the applicable sections of the Texas. CiV. Prac. & Remedies Code, Sec. 18.001, files the attached Affidavit 0f RICHARD W. HARE, D.C. along With the attached 19 pages ofrecords. RICHARD W. HARE, D.C. is employed by MES Solutions, 12300 Ford Rd #390, Dallas, TX 75234. A true and correct copy of these records are attached hereto. a1 vs. Allstate Reyes, et PAGE 1 DEFENDANT’S NOTICE OF FILING AFFIDAVIT OF «AFFIANT» 0539944362.1 Respectfully submitted, SUSAN L. FLORENCE & ASSOCIATES thgwébx KATE GARDNER TBN: 24101788 1201 Elm Street, Suite 5050 Dallas, TX 75270 DallasLegal@allstate.com (214) 659-43 15 (877) 678-4763 (fax) ATTORNEY FOR DEFENDANT(S) ALLSTATE COUNTY MUTUAL INSURANCE COMPANY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been served in compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on the 24th day 0f August, 2020, to: Landon Knotts 241 16630 Ben Abbott & Associates, PLLC 1934 Pendleton Drive Garland, TX 75041 (972) 263-5555 (817) 263—5555 (972) 682-7586 Facsimile eService@benabbott.com ATTORNEYS FOR PLAINTIFF 3%ng KATE GARDNER et a1 vs. Allstate Reyes, PAGE 2 DEFENDANT’S NOTICE OF FILING AFFIDAVIT OF «AFFIANT» 0539944362J 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. Jessica Muniz on behalf of Kate Gardner Bar No. 24101788 jmunm@allstate.com Envelope ID: 45645595 Status as of 8/25/2020 1:57 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status LANDON KNOTTS ESERVICE@BENABBOTT.COM 8/24/2020 3:20:26 PM SENT