Plaintiff's Motion to Compel

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Angela Claiborne                                               IN THE DISTRICT COURT OF

       Plaintiff

Vv.                                                            HARRIS COUNTY,       TEXAS

APTVC, LLC
       Defendant                                               190   JUDICIAL DISTRICT

                                     Plaintiff’s Motion to Compel

       The Court should compel Defendants APTVC, LLC and Gatesco, Inc. (collectively

“Defendants”) to produce their policy for insurance coverage that may be liable to satisfy

Plaintiff's claims. The Rules mandate that Defendants produce such policies, and they have

refused to do so.




                          APTVC LLC’s Responses to Plaintiff’s Request for Disclosure.

                          GATESCO, INC’s Responses to Plaintiff's Request for Disclosure

                          Email chain between co




                                                Background

       Ms. Claiborne sustained severe injuries on J…