On June 21, 2021 a
Party Discovery
was filed
involving a dispute between
Vikor Scientific, Llc,
and
Arroyo, Nicolas,
Eckerbrecht, Gary,
Frasch, Julie,
Genetic Technological Innovations. Llc S,
Glimcher S, Nicholas,
Lamb, Phillip,
Matlick, Susan,
Mcbride, Gina,
Nissel, Paul,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
Preview
FILED
7/13/2021 6:57 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
CAROLYN SELLERS DEPUTY
CAUSE NO. DC-21-07835
VIKOR SCIENTIFIC, LLC § IN THE DISTRICT COURT
§
Plaintiff, §
§
v. § 116th JUDICIAL DISTRICT
§
JULIE FRASCH; GINA McBRIDE; §
PAUL NISSEL; SUSAN MATLICK §
§
Defendants. § DALLAS COUNTY, TEXAS
PLAINTIFF VIKOR SCIENTIFIC, LLC NOTICE OF INTENT TO TAKE ORAL AND
VIDEO TAPE DEPOSITION OF JAY NETTLES
TO: JAY NETTLES
COMES NOW Vikor Scientific, LLC ("Plaintiff"), Plaintiff in the above-styled and
numbered cause, and hereby serves Plaintiff Vikor Scientific, LLC Notice of Intent to Take Oral
and Videotaped Deposition of Jay Nettles (the "Notice"). Pursuant to Texas law and the Texas
Rules of Civil Procedure, notice is hereby given of Plaintiff’s intent to take the oral and Videotaped
deposition of Jay Nettles. Nettles’ deposition is scheduled to commence on August 28, 2021 at
10:00 a.m. via Zoom and will be recorded stenographically.
The deposition shall be conducted before a certified court reporter, stenographically and/or
by video recording, and will continue from day-to-day until completed unless the parties agree on
other dates and times. All parties are invited to attend and propound such questions to the witness
as may by appropriate pursuant to and in accordance with the Texas Rules of Civil Procedure.
Respectfully submitted,
JAMES S. BELL, P.C.
ISI COIHMH N3SI1
Connor Nash
State Bar No. 24116809
Email: connor@iamesbellpc.com
James S. Bell
State Bar No. 24049314
Email: iames@iamesbellpc.com
2808 Cole Avenue
Dallas, Texas 75204
Telephone: (214) 668-9000
CERTIFICATE OF SERVICE
I certify that a true and correct copy was served on all counsels of record electronically
pursuant to the Texas Rules of Civil Procedure.
/s/ Connor Nash
Connor Nash
THE STATE OF TEXAS
SUBPOENA IN A CIVIL CASE
CAUSE NO. DC-21-07835
VIKOR SCIENTIFIC, LLC IN THE DISTRICT COURT
Plaintiff,
V- 116th JUDICIAL DISTRICT
JULIE FRASCH; GINA MCBRIDE; PAUL
NISSEL; SUSAN MATTLICK
Defendants, DALLAS COUNTY, TEXAS
TO ANY SHERIFF OR CONSTABLE OF THE STATE OF TEXAS OR OTHER PERSON
AUTHORIZED TO SERVE AND EXECUTE — GREETINGS: YOU ARE HEREBY
COMMANDED TO SUMMON:
Jay Nettles
DYOU ARE COMMANDED to appear at the place, date, and time specified below to testify in the above case.
PLACE OF TESTIMONY COURTROOM
DATE AND TIME
IYOU ARE COMMANDED to appear at the place, date and time specified below to testify at the taking of a video deposition in the
above case.
PLACE OF TESTIMONY DATE AND TIME
Zoom August 28, 2021 at 10:00 a.m.
DYOU ARE COMMANDED to produce and permit inspection and copying of the following documents or tangible things at the
place, date, and time specified below (list of documents or tangible things):
PLACE DATE AND TIME
U YOU ARE COMMANDED to permit inspection of the following premises at the date and time specified below.
PREMISES DATE AND TIME
Failure by any person without adequate excuse to obey a subpoena served upon that person may be deemed
a contempt of the court from which the subpoena is issued or a district court in the county in which the
subpoena is served, and may be punished by fine or confinement, or both. Texas Rules of Civil Procedure
176.8(a).
ISSUING OFFICER SIGNATURE AND TITLE (INDICATE IF ATTORNEY FOR PLAINTIFF OR DATE
DEFENDANT)
/s/ Connor Nash July 13,2021
ISSUING OFFICER’S NAME, ADDRESS, AND PHONE NUMBER
Connor Nash
connor@jamesbellpc.com
2808 Cole Ave.
Dallas, Texas 75204
214.668.9000
PROOF OF SERVICE
DATE PLACE
SERVED
SERVED 0N (PRINT NAME) MANNER 0F SERVICE
SERVED BY (PRINT NAME) TITLE
DECLARATION OF SERVER
I declare under penalty of perjury under the laws of the State of Texas that the foregoing
information contained in the Proof of Service is true and correct.
Executed on
SIGNATURE OF SERVER
ADDRESS OF SERVER:
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.
Connor Nash
Bar No. 24116809
connor@jamesbellpc.com
Envelope ID: 55319186
Status as of 7/15/2021 5:38 PM CST
Associated Case Party: VIKOR SCIENTIFIC, LLC
Name BarNumber Email TimestampSubmitted Status
James SamueIBeII James@jamesbellpc.com 7/13/2021 6:57:53 PM SENT
Connor Nash connor@jamesbellpc.com 7/13/2021 6:57:53 PM SENT
Mallory Rice mallory@jamesbel|pc.com 7/13/2021 6:57:53 PM SENT
Associated Case Party: GARY ECKERBRECHT
Name BarNumber Email TimestampSubmitted Status
Dave Wishnew dwishnew@cw|.|aw 7/13/2021 6:57:53 PM SENT
Cameron Jean cjean@cwl.law 7/13/2021 6:57:53 PM SENT
Associated Case Party: GINA MCBRIDE
Name BarNumber Email TimestampSubmitted Status
James Erdle jerdle@gpm-law.com 7/13/2021 6:57:53 PM SENT
Aaron Martinez amartinez@gpm-law.com 7/13/2021 6:57:53 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Nicole Vazquez nvazquez@cwl.law 7/13/2021 6:57:53 PM SENT
Janie Gonzales jgonzales@cwl.law 7/13/2021 6:57:53 PM SENT
Victoria Patterson vpatterson@cw|.law 7/13/2021 6:57:53 PM SENT
Associated Case Party: PAUL NISSEL
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.
Connor Nash
Bar No. 24116809
connor@jamesbellpc.com
Envelope ID: 55319186
Status as of 7/15/2021 5:38 PM CST
Associated Case Party: PAUL NISSEL
Name BarNumber Email TimestampSubmitted Status
James Erdle jerdle@gpm-law.com 7/13/2021 6:57:53 PM SENT
Aaron Martinez amartinez@gpm-law.com 7/13/2021 6:57:53 PM SENT
Document Filed Date
July 13, 2021
Case Filing Date
June 21, 2021
Category
CNTR CNSMR COM DEBT
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FILED 7/13/2021 6:57 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS CAROLYN SELLERS DEPUTY CAUSE NO. DC-21-07835 VIKOR SCIENTIFIC, LLC § IN THE DISTRICT COURT § Plaintiff, § § v. § 116th JUDICIAL DISTRICT § JULIE FRASCH; GINA McBRIDE; § PAUL NISSEL; SUSAN MATLICK § § Defendants. § DALLAS COUNTY, TEXAS PLAINTIFF VIKOR SCIENTIFIC, LLC NOTICE OF INTENT TO TAKE ORAL AND VIDEO TAPE DEPOSITION OF JAY NETTLES TO: JAY NETTLES COMES NOW Vikor Scientific, LLC ("Plaintiff"), Plaintiff in the above-styled and numbered cause, and hereby serves Plaintiff Vikor Scientific, LLC Notice of Intent to Take Oral and Videotaped Deposition of Jay Nettles (the "Notice"). Pursuant to Texas law and the Texas Rules of Civil Procedure, notice is hereby given of Plaintiff’s intent to take the oral and Videotaped deposition of Jay Nettles. Nettles’ deposition is scheduled to commence on August 28, 2021 at 10:00 a.m. via Zoom and will be recorded stenographically. The deposition shall be conducted before a certified court reporter, stenographically and/or by video recording, and will continue from day-to-day until completed unless the parties agree on other dates and times. All parties are invited to attend and propound such questions to the witness as may by appropriate pursuant to and in accordance with the Texas Rules of Civil Procedure. Respectfully submitted, JAMES S. BELL, P.C. ISI COIHMH N3SI1 Connor Nash State Bar No. 24116809 Email: connor@iamesbellpc.com James S. Bell State Bar No. 24049314 Email: iames@iamesbellpc.com 2808 Cole Avenue Dallas, Texas 75204 Telephone: (214) 668-9000 CERTIFICATE OF SERVICE I certify that a true and correct copy was served on all counsels of record electronically pursuant to the Texas Rules of Civil Procedure. /s/ Connor Nash Connor Nash THE STATE OF TEXAS SUBPOENA IN A CIVIL CASE CAUSE NO. DC-21-07835 VIKOR SCIENTIFIC, LLC IN THE DISTRICT COURT Plaintiff, V- 116th JUDICIAL DISTRICT JULIE FRASCH; GINA MCBRIDE; PAUL NISSEL; SUSAN MATTLICK Defendants, DALLAS COUNTY, TEXAS TO ANY SHERIFF OR CONSTABLE OF THE STATE OF TEXAS OR OTHER PERSON AUTHORIZED TO SERVE AND EXECUTE — GREETINGS: YOU ARE HEREBY COMMANDED TO SUMMON: Jay Nettles DYOU ARE COMMANDED to appear at the place, date, and time specified below to testify in the above case. PLACE OF TESTIMONY COURTROOM DATE AND TIME IYOU ARE COMMANDED to appear at the place, date and time specified below to testify at the taking of a video deposition in the above case. PLACE OF TESTIMONY DATE AND TIME Zoom August 28, 2021 at 10:00 a.m. DYOU ARE COMMANDED to produce and permit inspection and copying of the following documents or tangible things at the place, date, and time specified below (list of documents or tangible things): PLACE DATE AND TIME U YOU ARE COMMANDED to permit inspection of the following premises at the date and time specified below. PREMISES DATE AND TIME Failure by any person without adequate excuse to obey a subpoena served upon that person may be deemed a contempt of the court from which the subpoena is issued or a district court in the county in which the subpoena is served, and may be punished by fine or confinement, or both. Texas Rules of Civil Procedure 176.8(a). ISSUING OFFICER SIGNATURE AND TITLE (INDICATE IF ATTORNEY FOR PLAINTIFF OR DATE DEFENDANT) /s/ Connor Nash July 13,2021 ISSUING OFFICER’S NAME, ADDRESS, AND PHONE NUMBER Connor Nash connor@jamesbellpc.com 2808 Cole Ave. Dallas, Texas 75204 214.668.9000 PROOF OF SERVICE DATE PLACE SERVED SERVED 0N (PRINT NAME) MANNER 0F SERVICE SERVED BY (PRINT NAME) TITLE DECLARATION OF SERVER I declare under penalty of perjury under the laws of the State of Texas that the foregoing information contained in the Proof of Service is true and correct. Executed on SIGNATURE OF SERVER ADDRESS OF SERVER: 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. Connor Nash Bar No. 24116809 connor@jamesbellpc.com Envelope ID: 55319186 Status as of 7/15/2021 5:38 PM CST Associated Case Party: VIKOR SCIENTIFIC, LLC Name BarNumber Email TimestampSubmitted Status James SamueIBeII James@jamesbellpc.com 7/13/2021 6:57:53 PM SENT Connor Nash connor@jamesbellpc.com 7/13/2021 6:57:53 PM SENT Mallory Rice mallory@jamesbel|pc.com 7/13/2021 6:57:53 PM SENT Associated Case Party: GARY ECKERBRECHT Name BarNumber Email TimestampSubmitted Status Dave Wishnew dwishnew@cw|.|aw 7/13/2021 6:57:53 PM SENT Cameron Jean cjean@cwl.law 7/13/2021 6:57:53 PM SENT Associated Case Party: GINA MCBRIDE Name BarNumber Email TimestampSubmitted Status James Erdle jerdle@gpm-law.com 7/13/2021 6:57:53 PM SENT Aaron Martinez amartinez@gpm-law.com 7/13/2021 6:57:53 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Nicole Vazquez nvazquez@cwl.law 7/13/2021 6:57:53 PM SENT Janie Gonzales jgonzales@cwl.law 7/13/2021 6:57:53 PM SENT Victoria Patterson vpatterson@cw|.law 7/13/2021 6:57:53 PM SENT Associated Case Party: PAUL NISSEL 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. Connor Nash Bar No. 24116809 connor@jamesbellpc.com Envelope ID: 55319186 Status as of 7/15/2021 5:38 PM CST Associated Case Party: PAUL NISSEL Name BarNumber Email TimestampSubmitted Status James Erdle jerdle@gpm-law.com 7/13/2021 6:57:53 PM SENT Aaron Martinez amartinez@gpm-law.com 7/13/2021 6:57:53 PM SENT