Preview
Electronically Filed
10/7/2022 4:20 PM
Hidalgo County District Clerks
Reviewed By: Alan Garcia
CAUSE NO.: C-1392-21-B
WALID HAIDAR, INDIVIDUALLY, § IN THE DISTRICT COURT
AND AS REPRESENTATIVE OF 415 §
TRENTON, L.L.C. D/B/A WALK- §
ON'S SPORTS BISTREAUX, §
§
Plaintiffs/Counter-Defendants, §
§
Vs. §
§
G&G CLOSED CIRCUIT EVENTS, §
L.L.C., § 93rd JUDICIAL DISTRICT
§
Defendant/Counter-Plaintiff, §
§
Vs. §
§
MOUSSA HAIDAR, INDIVDUALLY §
AND D/B/A WALK-ON’S SPORTS §
BISTREAUX & BAR, §
§
Third-Party Counter-Defendant. § HIDALGO COUNTY, TEXAS
PLAINTIFF’S NOTICE OF INTENTION TO TAKE THE
ORAL/VIDEO/WEBCAST DEPOSITION OF NON-PARTY WITNESS GUY
LAUGHRIDGE
To: Non Party Witness, Guy Laughridge, by and through its attorney of record:
Mr. David M. Diaz
Law Offices of David Diaz, PLLC
825 Watters Creek Blvd, Build. M, Suite 250
Allen, Texas 75013
Said witness is to take notice that pursuant to the Texas and Texas Rules of
Civil Procedure, the deposition will be taken upon oral/video/webcast examination of
Non-Party Witness, Guy Laughridge, at the time and place indicated below, and
before an officer authorized to administer oaths. The deposition may be videotaped,
as well as webcast to a remote location. The deposition will be conducted via the Zoom
Plaintiff’s Notice of Intention to take the Oral/Video/Webcast Deposition of Non-Party
Witness Guy Laughridge
Page 1
Electronically Filed
10/7/2022 4:20 PM
Hidalgo County District Clerks
Reviewed By: Alan Garcia
webcast platform link at https://zoom.us/j/175373846. THE WITNESS SHOULD
HAVE A GOVERNMENT-ISSUED IDENTIFICATION TO PROVIDE TO THE
COURT REPORTER/NOTARY TO CONFIRM HIS/HER IDENTITY AT THE
COMMENCEMENT OF THE DEPOSITION AND BEFORE BEING SWORN.
PLEASE TAKE NOTICE that the ZOOM webcast deposition of Guy
Laughridge will be taken, pursuant to the Texas and Texas Rules of Civil Procedure,
on
DATE: October 31, 2022
TIME: To commence with Guy Laughridge at 3:00 P.M.
(CENTRAL TIME); and to continue thereafter from day
to day for each other named designated representative
for the matters of inquiry specified herein.
ZOOM LINK / INFORMATION FOR DEPOSITION:
https://us02web.zoom.us/j/83259996373?pwd=SXNMdVhaek04bT
lBQ1VhSnQ2R3RaZz09
Meeting ID: 832 5999 6373
Passcode: 122336
It is hereby requested that she appear at such time and place for the purpose
of giving her deposition in this cause, said deposition will be taken before a certified
court reporter from Bryant and Stingley, and may be used as evidence during the trial
of this cause, and will continue until completed.
Signed on this 7th day of October, 2022.
Respectfully submitted,
MOORE LAW FIRM
4900 North 10th Street, Suite F-3
McAllen, Texas 78504
Telephone No. (956) 631-0745
Telecopier No. (888) 266-0971
Plaintiff’s Notice of Intention to take the Oral/Video/Webcast Deposition of Non-Party
Witness Guy Laughridge
Page 2
Electronically Filed
10/7/2022 4:20 PM
Hidalgo County District Clerks
Reviewed By: Alan Garcia
Email: lit-docket@moore-firm.com
By: _______________________________
J. Michael Moore
State Bar No. 14349550
S.D. Texas Bar No.: 16942
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
A true copy of this instrument was served upon all counsel of record, in
accordance with the Texas and Texas Rules of Civil Procedure, on the 7th day of
October, 2022.
Mr. David M. Diaz
Law Offices of David Diaz, PLLC
825 Watters Creek Blvd, Build. M, Suite 250
Allen, Texas 75013
Email: david@diazlawtx.com
Attorneys for Defendant –
G&G Closed Circuit Events, L.L.C.
Mr. Pablo Garza
P. GARZA LAW FIRM, P.C.
5429 N. 23rd Street, Suite D
McAllen, Texas 78504
Telecopier: (210) 568-6115
Email: eservice@pgarzalaw.com
Attorney for Plaintiff/ Counter-Defendant,
Walid Haidar, Individually And
As Representative Of 415 Trenton, L.L.C.
D/B/A Walk-On’s Sports Bistreaux
__________________
J. Michael Moore
Plaintiff’s Notice of Intention to take the Oral/Video/Webcast Deposition of Non-Party
Witness Guy Laughridge
Page 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.
J. Michael Moore
Bar No. 14349550
lit-docket@moore-firm.com
Envelope ID: 69027881
Status as of 10/7/2022 4:31 PM CST
Associated Case Party: Walid Haidar
Name BarNumber Email TimestampSubmitted Status
Lit Docket lit-docket@moore-firm.com 10/7/2022 4:20:53 PM SENT
Kimberly Garcia kimberly@pgarzalaw.com 10/7/2022 4:20:53 PM SENT
E Service eservice@pgarzalaw.com 10/7/2022 4:20:53 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.
J. Michael Moore
Bar No. 14349550
lit-docket@moore-firm.com
Envelope ID: 69027881
Status as of 10/7/2022 4:31 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
david diaz david@diazlawtx.com 10/7/2022 4:20:53 PM SENT
PABLO GARZA PABLO@PGARZALAW.COM 10/7/2022 4:20:53 PM SENT
J. MICHAEL MOORE docket@moore-firm.com 10/7/2022 4:20:53 PM ERROR
Preview
Electronically Filed 10/7/2022 4:20 PM Hidalgo County District Clerks Reviewed By: Alan Garcia CAUSE NO.: C-1392-21-B WALID HAIDAR, INDIVIDUALLY, § IN THE DISTRICT COURT AND AS REPRESENTATIVE OF 415 § TRENTON, L.L.C. D/B/A WALK- § ON'S SPORTS BISTREAUX, § § Plaintiffs/Counter-Defendants, § § Vs. § § G&G CLOSED CIRCUIT EVENTS, § L.L.C., § 93rd JUDICIAL DISTRICT § Defendant/Counter-Plaintiff, § § Vs. § § MOUSSA HAIDAR, INDIVDUALLY § AND D/B/A WALK-ON’S SPORTS § BISTREAUX & BAR, § § Third-Party Counter-Defendant. § HIDALGO COUNTY, TEXAS PLAINTIFF’S NOTICE OF INTENTION TO TAKE THE ORAL/VIDEO/WEBCAST DEPOSITION OF NON-PARTY WITNESS GUY LAUGHRIDGE To: Non Party Witness, Guy Laughridge, by and through its attorney of record: Mr. David M. Diaz Law Offices of David Diaz, PLLC 825 Watters Creek Blvd, Build. M, Suite 250 Allen, Texas 75013 Said witness is to take notice that pursuant to the Texas and Texas Rules of Civil Procedure, the deposition will be taken upon oral/video/webcast examination of Non-Party Witness, Guy Laughridge, at the time and place indicated below, and before an officer authorized to administer oaths. The deposition may be videotaped, as well as webcast to a remote location. The deposition will be conducted via the Zoom Plaintiff’s Notice of Intention to take the Oral/Video/Webcast Deposition of Non-Party Witness Guy Laughridge Page 1 Electronically Filed 10/7/2022 4:20 PM Hidalgo County District Clerks Reviewed By: Alan Garcia webcast platform link at https://zoom.us/j/175373846. THE WITNESS SHOULD HAVE A GOVERNMENT-ISSUED IDENTIFICATION TO PROVIDE TO THE COURT REPORTER/NOTARY TO CONFIRM HIS/HER IDENTITY AT THE COMMENCEMENT OF THE DEPOSITION AND BEFORE BEING SWORN. PLEASE TAKE NOTICE that the ZOOM webcast deposition of Guy Laughridge will be taken, pursuant to the Texas and Texas Rules of Civil Procedure, on DATE: October 31, 2022 TIME: To commence with Guy Laughridge at 3:00 P.M. (CENTRAL TIME); and to continue thereafter from day to day for each other named designated representative for the matters of inquiry specified herein. ZOOM LINK / INFORMATION FOR DEPOSITION: https://us02web.zoom.us/j/83259996373?pwd=SXNMdVhaek04bT lBQ1VhSnQ2R3RaZz09 Meeting ID: 832 5999 6373 Passcode: 122336 It is hereby requested that she appear at such time and place for the purpose of giving her deposition in this cause, said deposition will be taken before a certified court reporter from Bryant and Stingley, and may be used as evidence during the trial of this cause, and will continue until completed. Signed on this 7th day of October, 2022. Respectfully submitted, MOORE LAW FIRM 4900 North 10th Street, Suite F-3 McAllen, Texas 78504 Telephone No. (956) 631-0745 Telecopier No. (888) 266-0971 Plaintiff’s Notice of Intention to take the Oral/Video/Webcast Deposition of Non-Party Witness Guy Laughridge Page 2 Electronically Filed 10/7/2022 4:20 PM Hidalgo County District Clerks Reviewed By: Alan Garcia Email: lit-docket@moore-firm.com By: _______________________________ J. Michael Moore State Bar No. 14349550 S.D. Texas Bar No.: 16942 ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE A true copy of this instrument was served upon all counsel of record, in accordance with the Texas and Texas Rules of Civil Procedure, on the 7th day of October, 2022. Mr. David M. Diaz Law Offices of David Diaz, PLLC 825 Watters Creek Blvd, Build. M, Suite 250 Allen, Texas 75013 Email: david@diazlawtx.com Attorneys for Defendant – G&G Closed Circuit Events, L.L.C. Mr. Pablo Garza P. GARZA LAW FIRM, P.C. 5429 N. 23rd Street, Suite D McAllen, Texas 78504 Telecopier: (210) 568-6115 Email: eservice@pgarzalaw.com Attorney for Plaintiff/ Counter-Defendant, Walid Haidar, Individually And As Representative Of 415 Trenton, L.L.C. D/B/A Walk-On’s Sports Bistreaux __________________ J. Michael Moore Plaintiff’s Notice of Intention to take the Oral/Video/Webcast Deposition of Non-Party Witness Guy Laughridge Page 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. J. Michael Moore Bar No. 14349550 lit-docket@moore-firm.com Envelope ID: 69027881 Status as of 10/7/2022 4:31 PM CST Associated Case Party: Walid Haidar Name BarNumber Email TimestampSubmitted Status Lit Docket lit-docket@moore-firm.com 10/7/2022 4:20:53 PM SENT Kimberly Garcia kimberly@pgarzalaw.com 10/7/2022 4:20:53 PM SENT E Service eservice@pgarzalaw.com 10/7/2022 4:20:53 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. J. Michael Moore Bar No. 14349550 lit-docket@moore-firm.com Envelope ID: 69027881 Status as of 10/7/2022 4:31 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status david diaz david@diazlawtx.com 10/7/2022 4:20:53 PM SENT PABLO GARZA PABLO@PGARZALAW.COM 10/7/2022 4:20:53 PM SENT J. MICHAEL MOORE docket@moore-firm.com 10/7/2022 4:20:53 PM ERROR