Party Discovery: GARCIA'S QUALITY FRUIT & PRODUCE, LLC VS. CHRIS DAMON, INDIVIDUALLY AND D/B/A PRODUCE CONNECTION, INC., JOHN MEENA, INDIVIDUALLY AND D/B/A PRODUCE CONNECTION, INC., JOSE GARCIA, INDIVIDUALLY AND D/B/A PRODUCE CONNECTION, INC.

• 
• 
• 
• 
• 
• 
• 
• 

						
                                
Preview
                                Electronically Filed
                                                                          10/3/2022 12:00 AM
                                                                          Hidalgo County District Clerks
                                                                          Reviewed By: Valerie Garza


                              CAUSE NO. C-2351-19-D

GARCIA'S QUALITY FRUIT & PRODUCE, LLC                §           IN THE DISTRICT COURT
Plaintiff,                                           §
                                                     §
V.                                                   §      206TH JUDICIAL DISTRICT
                                                     §
CHRIS DAMON, JOHN MEENA, AND                         §
JOSE GARCIA, EACH INDIVIDUALLY                       §
AND D/B/A PRODUCE CONNECTION, INC.                   §
Defendants.                                          §      HIDALGO COUNTY, TEXAS



               PLAINTIFF'S CERTIFICATE OF WRITTEN DISCOVERY
                          DIRECTED TO DEFENDANTS


      Plaintiff, GARCIA'S QUALITY FRUIT & PRODUCE, LLC, files this Certificate of

Written Discovery Directed to the Defendant, THE AVOCADO CONNECTION, INC.,

pursuant to the applicable local rule and states that the discovery set forth below was

served upon the following party on October 02, 2022:


      THE AVOCADO CONNECTION, INC., Defendant, by and through Defendant's
      attorneys of record, Nicondra Chargois-Allen, Jessie Lopez, and Bart M. Botta.


                                  Discovery Served

             1.     Request for Admissions
             2.     Request for Production


                                        Respectfully submitted,

                                        By: /s/Rolando Cantu
                                        ROLANDO CANTU
                                        Texas Bar No. 00789201
                                        1111 W. Nolana Avenue
                                        McAllen, Texas 78504-3747
                                        Tel: (956) 687-5777
                                        Fax: (956) 435-7238
                                        Email: rcantu@cantulawfirm.com

                                        Attorney for Plaintiff
                                                                               Electronically Filed
                                                                               10/3/2022 12:00 AM
                                                                               Hidalgo County District Clerks
                                                                               Reviewed By: Valerie Garza



                               CERTIFICATE OF SERVICE


       I certify that on October 02, 2022 a true and correct copy of Plaintiff's Certificate of
Written Discovery was electronically served on the following attorneys of record via the
eFile.TXCourts.gov Electronic Filing Service.


NICONDRA CHARGOIS-ALLEN
JESSIE LOPEZ
Davidson Troilo Ream & Garza, P.C.
601 N.W. Loop 410, Suite 100
San Antonio, Texas 78216
Tel: (210) 349-6484
Email: nallen@dtrglaw.com
Email: jlopez@dtrglaw.com


BART M. BOTTA
Rynn & Janowsky, LLP
4100 Newport Place Drive, Suite 700
Newport Beach, California 92660
Tel: (949) 752-2911
Email: bart@rjlaw.com

Attorneys for Defendants

                                           /s/ Rolando Cantu
                                           ROLANDO CANTU
                         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.

Rolando Cantu
Bar No. 789201
rcantu@cantulawfirm.com
Envelope ID: 68810867
Status as of 10/3/2022 9:42 AM CST
Associated Case Party: CHRIS DAMON, INDIVIDUALLY AND D/B/A PRODUCE CONNECTION, INC.
Name               BarNumber     Email               TimestampSubmitted       Status
TERESA G.CRUZ                    tcruz@dtrglaw.com   10/2/2022 12:46:08 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.

Rolando Cantu
Bar No. 789201
rcantu@cantulawfirm.com
Envelope ID: 68810867
Status as of 10/3/2022 9:42 AM CST
Case Contacts
Name                      BarNumber   Email                TimestampSubmitted      Status
NICONDRA CHARGOISALLEN                nallen@dtrglaw.com   10/2/2022 12:46:08 PM   SENT
BART BOTTA                            BART@RJLAW.COM       10/2/2022 12:46:08 PM   SENT
Jessie Lopez                          jlopez@dtrglaw.com   10/2/2022 12:46:08 PM   SENT
Bart M.Botta                          bart@rjlaw.com       10/2/2022 12:46:08 PM   SENT