On January 03, 2020 a
Motion - PLAINTIFF'S MOTION TO AMEND ADMISSIONS
was filed
involving a dispute between
Fernandez, Julio Cesar,
and
Massachusetts Bay Ins Co,
New Millennium L. Investments, Inc.,
Santa Fe Phc,
for Injury or Damage - Other (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Filed
7/19/2022 9:42 AM
Hidalgo County District Clerks
Reviewed By: Faith Martinez
CAUSE NO. C-0031-20-E
JULIO CESAR FERNANDEZ § IN THE DISTRICT COURT OF
Plaintiff, §
§
§
v. § 275th JUDICIAL DISTRICT
§
NEW MILLENNIUM L. §
INVESTMENTS, INC., SANTA FE PHC §
and MASSACHUSETTS BAY INS CO §
Defendants. § HIDALGO COUNTY, TEXAS
PLAINTIFF’S MOTION TO AMEND ADMISSIONS
TO THE HONORABLE JUDGE OF THIS COURT:
Comes Now, JULIO CESAR FERNANDEZ, (Hereinafter referred to as “Plaintiff”),
Plaintiff, in the above-styled and numbered cause, and files this Motion to Amend his
responses to Admissions, and would show the Court as follows:
I.
Plaintiff was served with Request for Admissions on or about July 14, 2021 via E-
Service.
On or about the 18th day of August 2021 Plaintiff responded to said Requests for
Admissions which were served on Defendant via E-Service
II.
Plaintiff responded to the admissions but made a clerical error on one of the responses.
Pursuant to Rule 198.3, a party may amend or withdraw an admission so long as the party relying
Plaintiff’s Motion to Amend Admissions
Julio Cesar Fernandez Espinoza v. New Millennium L. Investments, Inc.
Page 1 of 3
Electronically Filed
7/19/2022 9:42 AM
Hidalgo County District Clerks
Reviewed By: Faith Martinez
on said responses or admissions will not be unduly prejudiced and that the presentation of the
merits of the action will be subserved by permitting the party to amend or withdraw the admission.
In this case, Plaintiff made an error on answering an admission. And therefore by
amending said admission would not prejudice the defendant nor change the merits of this case.
Therefore, Plaintiff hereby requests this honorable court to allow them to amend their responses
to admissions.
For these reasons above Plaintiff prays the court grant this motion and that they be allowed
to Amend their admissions.
Respectfully submitted,
VALDEZ, MONARREZ & SAN
MIGUEL, PLLC
207 North 15th Street
McAllen, Texas 78501
Telephone: 956-627-2855
Fax: 956-627-2758
BY: /s/ Carlos N. Monarrez
Carlos N. Monarrez
State Bar No. 24067776
carlos@valdezmonarrez.com
ATTORNEY FOR PLAINTIFF
Plaintiff’s Motion to Amend Admissions
Julio Cesar Fernandez v. New Millennium L. Investments, Inc.
Page 2 of 3
Electronically Filed
7/19/2022 9:42 AM
Hidalgo County District Clerks
Reviewed By: Faith Martinez
CERTIFICATE OF SERVICE
I certify that a true copy of this document was served in accordance with Rule 21a of the Texas
Rules of Civil Procedure on this the 19th day of July, 2022.
Jose Caso Via E-Service
Caso Law Firm PLLC
112 E. Cano St. ‘
Edinburg, TX 78539
/s/ Carlos N. Monarrez
Carlos N. Monarrez
Plaintiff’s Motion to Amend Admissions
Julio Cesar Fernandez v. New Millennium L. Investments, Inc.
Page 3 of 3
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.
Jesus Valdez on behalf of Carlos Monarrez
Bar No. 24067776
cm1@valdezmonarrez.com
Envelope ID: 66443350
Status as of 7/19/2022 9:52 AM CST
Associated Case Party: New Millennium L. Investments, Inc.
Name BarNumber Email TimestampSubmitted Status
Jose LuisCaso jcaso@casolawfirm.com 7/19/2022 9:42:58 AM 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.
Jesus Valdez on behalf of Carlos Monarrez
Bar No. 24067776
cm1@valdezmonarrez.com
Envelope ID: 66443350
Status as of 7/19/2022 9:52 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Carlos N.Monarrez carlos@valdezmonarrez.com 7/19/2022 9:42:58 AM SENT
Joe Paredes cm1@valdezmonarrez.com 7/19/2022 9:42:58 AM SENT
Jesus RaymundoValdez raymundo@valdezmonarrez.com 7/19/2022 9:42:58 AM SENT
Adell Alaniz cm3@valdezmonarrez.com 7/19/2022 9:42:58 AM SENT
Document Filed Date
July 19, 2022
Case Filing Date
January 03, 2020
Category
Injury or Damage - Other (OCA)
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Electronically Filed 7/19/2022 9:42 AM Hidalgo County District Clerks Reviewed By: Faith Martinez CAUSE NO. C-0031-20-E JULIO CESAR FERNANDEZ § IN THE DISTRICT COURT OF Plaintiff, § § § v. § 275th JUDICIAL DISTRICT § NEW MILLENNIUM L. § INVESTMENTS, INC., SANTA FE PHC § and MASSACHUSETTS BAY INS CO § Defendants. § HIDALGO COUNTY, TEXAS PLAINTIFF’S MOTION TO AMEND ADMISSIONS TO THE HONORABLE JUDGE OF THIS COURT: Comes Now, JULIO CESAR FERNANDEZ, (Hereinafter referred to as “Plaintiff”), Plaintiff, in the above-styled and numbered cause, and files this Motion to Amend his responses to Admissions, and would show the Court as follows: I. Plaintiff was served with Request for Admissions on or about July 14, 2021 via E- Service. On or about the 18th day of August 2021 Plaintiff responded to said Requests for Admissions which were served on Defendant via E-Service II. Plaintiff responded to the admissions but made a clerical error on one of the responses. Pursuant to Rule 198.3, a party may amend or withdraw an admission so long as the party relying Plaintiff’s Motion to Amend Admissions Julio Cesar Fernandez Espinoza v. New Millennium L. Investments, Inc. Page 1 of 3 Electronically Filed 7/19/2022 9:42 AM Hidalgo County District Clerks Reviewed By: Faith Martinez on said responses or admissions will not be unduly prejudiced and that the presentation of the merits of the action will be subserved by permitting the party to amend or withdraw the admission. In this case, Plaintiff made an error on answering an admission. And therefore by amending said admission would not prejudice the defendant nor change the merits of this case. Therefore, Plaintiff hereby requests this honorable court to allow them to amend their responses to admissions. For these reasons above Plaintiff prays the court grant this motion and that they be allowed to Amend their admissions. Respectfully submitted, VALDEZ, MONARREZ & SAN MIGUEL, PLLC 207 North 15th Street McAllen, Texas 78501 Telephone: 956-627-2855 Fax: 956-627-2758 BY: /s/ Carlos N. Monarrez Carlos N. Monarrez State Bar No. 24067776 carlos@valdezmonarrez.com ATTORNEY FOR PLAINTIFF Plaintiff’s Motion to Amend Admissions Julio Cesar Fernandez v. New Millennium L. Investments, Inc. Page 2 of 3 Electronically Filed 7/19/2022 9:42 AM Hidalgo County District Clerks Reviewed By: Faith Martinez CERTIFICATE OF SERVICE I certify that a true copy of this document was served in accordance with Rule 21a of the Texas Rules of Civil Procedure on this the 19th day of July, 2022. Jose Caso Via E-Service Caso Law Firm PLLC 112 E. Cano St. ‘ Edinburg, TX 78539 /s/ Carlos N. Monarrez Carlos N. Monarrez Plaintiff’s Motion to Amend Admissions Julio Cesar Fernandez v. New Millennium L. Investments, Inc. Page 3 of 3 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. Jesus Valdez on behalf of Carlos Monarrez Bar No. 24067776 cm1@valdezmonarrez.com Envelope ID: 66443350 Status as of 7/19/2022 9:52 AM CST Associated Case Party: New Millennium L. Investments, Inc. Name BarNumber Email TimestampSubmitted Status Jose LuisCaso jcaso@casolawfirm.com 7/19/2022 9:42:58 AM 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. Jesus Valdez on behalf of Carlos Monarrez Bar No. 24067776 cm1@valdezmonarrez.com Envelope ID: 66443350 Status as of 7/19/2022 9:52 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Carlos N.Monarrez carlos@valdezmonarrez.com 7/19/2022 9:42:58 AM SENT Joe Paredes cm1@valdezmonarrez.com 7/19/2022 9:42:58 AM SENT Jesus RaymundoValdez raymundo@valdezmonarrez.com 7/19/2022 9:42:58 AM SENT Adell Alaniz cm3@valdezmonarrez.com 7/19/2022 9:42:58 AM SENT