Preview
Exhibit E
CAUSE 2021-45494
Plaintiffs,
HARRIS
WARD-BROWN PARTNERS, d/b/a
WARD BUILDERS
Defendant.
PLAINTIFFS SECOND PRODUCTION
Defendant, Ward-Brown Partners, d/b/a Builders, its
record, Andrew Schreck Whiteley, Stanford,
Southwest Freeway, Sugar Texas Powers, Burford
Perry LLP, Texas 77010.
Pursuant Texas Plaintiffs Trapp Elena
(collectively, Trapps Plaintiffs serve following Second Production
Defendant Ward-Brown Partners, d/b/a Builders Defendant
Respectfully submitted,
ilpatrick ownsend
/s/Nicholas Nieto_____________
Texas 24045928
icholas
Louisiana Street,
Telephone:
Telecopier:
Email bgaudet(5)kiIpatricktownsend.com
Email: nnieto@kilpatricktownsend.com
ATTORNEYS PLAINTIFFS
CERTIFICATE SERVICE
certify correct document forwarded
record accordance Texas Rules Procedure
Email: aschreck@downsstanford.com
Email: awhitelev@downsstanford.com
Schreck
Whiteley
tanford
14090 Southwest Freeway,
Attorney
Email: kDOwers@,burfordDerrv.com
M. Powers
Burford Perry
Fannin
Houston, Texas
Attorney
Nieto
Nicholas
INSTRUCTIONS
Each following categories construed responded independently
referenced herein limitation.
pursuant request tendered precise
business organized labeled
correspond categories follow this request.
Except forth documents existing electronic magnetic
either (digital versatile disc) (compact
thumb external
Please produce e-mail form forms readily support import standard
e-mail programs, form produetion adhere conventions
internet e-mail standard.
With respeet communieation contend protected
discovery grounds information contained therein from document
communication derived privileged confidential, provide written
speeifically forth, appropriate, following information:
document communication transmitted,
received;
name title each addressee, reeipient
communication;
furnished privy
communication, possession document
communication manifestation doeument
communication, access contents
communication;
number pages document communication equivalent measure
length, appropriate, ESI);
matter information contend protected
discovery;
speeific basis asserting document communication are privileged
confidential;
precise factual basis privilege asserted
claimed;
discovery request requests which information question
responsive.
documents referred herein custody
control actual state following
whether missing lost, destroyed, transferred voluntarily
involuntarily others disposed
location
cannot location
left possession, custody control parties;
reasons document
control party;
having matters are
subject inquiry immediately preceding
herein destroyed, requested describe
circumstances destruction all
documents which relate circumstances destruction.
requesting intention permissible discovery,
particularly privileged matters. herein withheld
privilege whatever requested state
specifically privilege reason withhold production
identify document date, subject matter, disclosing
sufficient allow described ruling privilege
asserted. are further
document which privilege
exercising otherwise protecf which privilege asserted,
technique result disclosing contents privilege
asserted.
request production nature. addif documents
brought attention discovery preparations trial,
supplementaf required.
DEFINITIONS
The following document requests listed below. herein,
following following meanings:
''Person'" natural corporation, partnership, unincorporated
form business, governmental, public charitable entity. Where
employee performs task inquiry requests
include employing
employed person.
"Document" "Documents" original non-identical
written, electronic, matter, produced, whether
received, neither, including drafts sides thereof, custody,
control specifically includes Metadata.
identical handwritten notations, identification marks
modifications, non-identical separate within
definition. include, limited handwritten, typewritten,
printed, drawn, filed, recorded matter,
which custody control, including, limited account,
record, brochure, catalog, periodical, publication, advertisement,
schedule, list, manual, letter, correspondence, telegram, telephone record, memorandum,
contract, lease, invoice, manifest, purchase order, ticket, computer record, bulletin,
report, sales letter, chart, sheet, intra company
communication, report, plan, worksheet, statement, journal,
travel record, calendar, minutes, transcripts, accounting record, financial record,
record, photograph, record, recording, recording, films,
drawings, maps, picture films, parts components
equipment, models, information stored accessible computer
information storage retrieval systems, “documents tangible
physical object possession subject control within
responding requests production, their counsel,
investigators. definition includes copies, reproductions facsimiles documents
whatever documents privilege claimed. definition
also computer files recoverable from computer-based
media, included are erased recoverable maintained personal
computer, notebook computer, server, minicomputer, mainframe computer,
storage device limited hard drive drives,
archival (whether stored site), drives, mobile
communications Blackberries iPhones,
electronically stored information includes, limited
information electronically, magnetically optically stored digital communications
email, messaging); processed documents Microsoft
WordPerfect documents drafts); tables
Excel worksheets); accounting application
Money, Peachtree files); image facsimile files
images); recordings files); video animation
files); (e.g. Project Wise, Oracle,
SAP); electronic mail, contact relationship management data
Maximizer, ACT!), including emails resident servers
files); calendar application Outlook tools);
access (e.g., temporary internet files, history, cookies); presentations
PowerPoint, Corel Presentations); network access activity
project application computer design/drawing files
files (*.txt); archival files
'"Metadata'" application metadata. System metadata
information describing history characteristics ESI. information
associated with tracking managing electronic file includes
reflecting folder, file size, location, creation last
modification, comments, updates, access relevant meta Application
information automatically included electronic files
may including deleted content, draft language, commentary,
collaboration distribution creation printing. electronic mail,
includes header routing attachment addition
From, Subject, Received Time fields,
relevant data.
document communication which "relates subject constituting,
comprising, identilying, referring dealing with subject matter.
"Including" "includes" without limitation.
"Communication" transfer, attempted transfer requests transfer
information includes method communication whether
written, oral, mechanical, magnetic, electronic, optical, digital, photographic,
pectoral means. also includes, limited includes letters,
emails, messages, message, online chats, social media social
"Identity" "identities," reference persons, information
concerning address, office address,
street office telephone telephone
number, person information which locate
Identify'" following meanings:
reference natural state person full
business affiliation, title current telephone residence
address business address.
reference natural
form organization, service process, address its principal
office present business telephone numbers.
reference document, state:
(letter, memorandum, telegram, ehart, email, etc.); (ii) address,
affiliation title signer thereof; (iii) its
affiliation addressees recipients; present
location; present business affiliation title
person having thereof
reference communication means: (i) state
communication occurred telephone conversation,
meeting, etc.); communication document, identify each
person received document state
document received; (iii) communication telephone
conversation, identify person during all
communication, describe detail information communicated
natural the communication meeting, state
meeting, identify natural meeting,
describe detail information communicated natural person;
described natural person
provided information communicated, state which
communication received describe detail information
eommunicated.
""and/or."
include plural, plural singular, effect
doing increase information responses.
terms ""relating ""reflecting," ""referring ""regarding" subject,
when specify document, communication, statement, document,
communication, statement constitutes, contains, reflects, identifies,
states, with, whatsoever pertinent subject.
The terms and/or, inclusively, exclusively.
refer Ward-Brown Partners,
Builders, its parents, subsidiaries, affiliates, predecessors,
owners, partners, members, managers, directors, officers, agents.
representatives, employees thereof, acting its behalf, including
limited Brown David Ward.
'"Plaintiffs'' collectively refer Trapp Trapp.
"Property" real property Street, Houston, Texas
"Project" associated with Property.
"Original executed Ward
original the Property, Jeroen
"City Houston" Houston, departments (including
limited Department Engineering
Development Department), representatives, employees.
"Lawsuit" "Dispute" refer following action:
Elena Ward-Brown Partners, d/b/a
Builders, District Harris Texas.
Engineering refer Engineering its parents,
subsidiaries, affiliates, predecessors, owners, members, managers,
directors, officers, agents, representatives, employees acting
its behalf, limited Qashshu Jack Spivey.
Engineering, shall parents, subsidiaries,
affiliates, predecessors, successors, owners, partners, members, managers, directors,
officers, representatives, employees thereof, acting
"Geoscience Engineering Testing, refer GEOSCIENCE ENGfNEERfNG
TESTING, parents, subsidiaries, affiliates, predecessors, owners,
partners, members, officers, representatives,
thereof, acting behalf
BISON BUILDING MATERIALS its parents,
subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers,
directors, officers, representatives, employees thereof,
behalf, limited Jamie Cortez.
refer Corporation Building Materials
Construction Services, respective parents, subsidiaries, affiliates, predecessors,
successors, owners, partners, members, directors, officers,
representatives, employees thereof, persons acting behalf
"Frontier Title Company" Frontier Title its parents,
subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers,
directors, officers, agents, representatives, employees thereof,
behalf
refer ROOFING, its parents,
subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers,
directors, officers, representatives, employees acting
behalf, limited
Systems LLC" refer Systems parents, subsidiaries,
affiliates, predecessors, owners, partners, members, managers, directors,
officers, representatives, employees persons acting behalf,
including limited
Arnulfo Rodriguez Roofing RODRIGUEZ
ROOFfNG its parents, subsidiaries, affiliates, predecessors, successors,
owners, members, managers, directors, officers, agents, representatives,
employees thereof, acting behalf, limited
Arnulfo Rodrigues
''Grogan Builders Company"' refer BUILDERS SUPPLY
COMPANY, its parents, subsidiaries, affiliates, predecessors, successors, owners, partners,
members, managers, directors, officers, representatives, employees thereof,
acting its behalf, limited Shawn Schwiesow.
Industries" Industries Acquisitions, its parents,
subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers,
directors, officers, representatives, employees thereof, acting
its behalf, limited Walter III.
"Blue FinanciaF Tarp Financial, BlueTarp Financial,
respective parents, subsidiaries, affiliates, predecessors, owners, partners,
members, managers, directors, officers, agents, representatives, employees thereof,
acting its behalf
Homes, refer its parents, subsidiaries,
affiliates, predecessors, owners, partners, members, managers, directors,
officers, representatives, employees persons acting
"Gomez Gutters Services, refer Gomez Gutters Services, parents,
subsidiaries, affiliates, owners, partners, members, managers,
directors, officers, agents, representatives, employees thereof,
its behalf
"A.R.H. Construction Inc."" refer Construction its parents,
subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers,
directors, officers, agents, representatives, employees thereof, acting
its behalf
"Urban Access Properties Inc."" refer URBAN PROPERTIES its
parents, subsidiaries, affiliates, predecessors, owners, partners, members.
managers, directors, officers, agents, representatives, employees thereof,
acting its behalf, limited Miranda Sharlene
Abghary.
^Beth Associates, refer ASSOCIATES, its
parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members,
managers, directors, officers, representatives, employees thereof,
acting its behalf, limited
'^International Architectural Services'" refer International Architectural Services,
its parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members,
managers, officers, agents, representatives, employees thereof,
acting its
Tension, refer HOUSTON TENSION,
parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members,
managers, directors, officers, agents, representatives, employees thereof,
acting its behalf, limited David Cooney.
Construction CONSTRUCTION its
parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members,
managers, directors, officers, representatives, employees thereof,
acting its behalf
"Statewide Inspections" refer Statewide Property Inspections, parents,
subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers,
directors, officers, representatives, employees acting
its behalf
"Home Inspections" Inspections, parents,
subsidiaries, affiliates, successors, owners, partners, members, managers,
directors, officers, representatives, employees acting
its behalf
"HBIS" refer Builders Services, its parents, subsidiaries,
affiliates, predecessors, owners, partners, members, managers, directors,
officers, agents, representatives, employees persons acting its
"Anne's Permit, refer Permit, its parents, subsidiaries, affiliates,
predecessors, successors, owners, partners, members, managers, directors, officers,
representatives, employees thereof, acting its behalf
3\."Retzer Construction" refer Retzer Construction, its parents, subsidiaries,
affiliates, predecessors, owners, partners, members, managers, directors,
officers, representatives, employees thereof, acting its behalf
Metal Roofing'" refer Sheet Metal its
parents, subsidiaries, affiliates, predecessors, owners, partners, members,
managers, directors, officers, representatives, employees thereof,
persons aeting its behalf
Texas refer Spirit its parents, subsidiaries,
affiliates, predecessors, owners, partners, members, managers, directors,
officers, agents, representatives, employees thereof, aeting behalf
Kelly refer its parents,
subsidiaries, affiliates, owners, partners, members, managers,
directors, officers, agents, representatives, employees thereof, acting
its behalf
LLC" refer its parents, subsidiaries,
affiliates, predecessors, owners, partners, members, directors,
officers, representatives, employees thereof persons acting
PLAINTIFFS SECOND PRODUCTION DEFENDANT
REQUEST PRODUCTION construction warranties provided
connection Original Sales Contract native format.
REQUEST PRODUCTION entitled “Ward
Builders Limited Warranty Coverage
format.
insurance coverage applicable,
part, Project Property.
REQUEST indemnity insuring agreements related
applicable, Project Property.
REQUEST certificates insurance received
provided Brown Project.
REQUEST PRODUCTION settlement agreements executed
Project Property.
REQUEST PRODUCTION applications, invoices, requests
payment submitted Brown, acting its behalf,
connection with Project.
REQUEST PRODUCTION payment invoices, requests
payment Project.
payments Brown,
including persons acting its behalf, materials
connection with Project.
connection
Project.
REQUEST documents communication relating
Project Property.
REQUEST documents communication relating
Project Property exchanged between persons acting
its behalf) following persons:
Previous owner(s)
Jeroen Kirschbaum;
Architect(s);
Designer(s);
Engineer(s);
General contractor(s);
Subcontractor(s);
Engineering EEC;
Ammar
Engineering,
Geoscience Engineering Testing,
Frontier Title Company;
Roofing,
Systems
Arnulfo Rodriguez
Builders
RAM Industries;
Tarp Financial;
Paragon
Gutters Services,
Javier Eara;
Wilkes;
Construction
Access Properties
аа) Wolff Associates,
International Architectural Services;
Tension,
Construction
ee) Statewide Inspections;
ff) Home Inspections;
Malacara;
Permit,
Retzer Construction;
Sheet Metal
Spirit
mm) O'Kelly
Julio Quintero;
Amador Trim,
Jasun Juergens;
Cecelia Gerber;
rr) Broadfoot;
Houston.
documents communication relating
construction repair performed Brown
persons identified Production
REQUEST PRODUCTION documents communication referring
referencing construction warranties provided
Original Contract. includes, limited communications
original owner(s) Property, Frontier Title fmaneial institutions
construction Property, internal communications
Brown. electronic communication format.
documents communication referring
relating referencing requests applications: issuance
amendment permit(s) Projeet authorization
modify drawings, plans, specifications were
with permit(s) Project.
Preview
Exhibit E CAUSE 2021-45494 Plaintiffs, HARRIS WARD-BROWN PARTNERS, d/b/a WARD BUILDERS Defendant. PLAINTIFFS SECOND PRODUCTION Defendant, Ward-Brown Partners, d/b/a Builders, its record, Andrew Schreck Whiteley, Stanford, Southwest Freeway, Sugar Texas Powers, Burford Perry LLP, Texas 77010. Pursuant Texas Plaintiffs Trapp Elena (collectively, Trapps Plaintiffs serve following Second Production Defendant Ward-Brown Partners, d/b/a Builders Defendant Respectfully submitted, ilpatrick ownsend /s/Nicholas Nieto_____________ Texas 24045928 icholas Louisiana Street, Telephone: Telecopier: Email bgaudet(5)kiIpatricktownsend.com Email: nnieto@kilpatricktownsend.com ATTORNEYS PLAINTIFFS CERTIFICATE SERVICE certify correct document forwarded record accordance Texas Rules Procedure Email: aschreck@downsstanford.com Email: awhitelev@downsstanford.com Schreck Whiteley tanford 14090 Southwest Freeway, Attorney Email: kDOwers@,burfordDerrv.com M. Powers Burford Perry Fannin Houston, Texas Attorney Nieto Nicholas INSTRUCTIONS Each following categories construed responded independently referenced herein limitation. pursuant request tendered precise business organized labeled correspond categories follow this request. Except forth documents existing electronic magnetic either (digital versatile disc) (compact thumb external Please produce e-mail form forms readily support import standard e-mail programs, form produetion adhere conventions internet e-mail standard. With respeet communieation contend protected discovery grounds information contained therein from document communication derived privileged confidential, provide written speeifically forth, appropriate, following information: document communication transmitted, received; name title each addressee, reeipient communication; furnished privy communication, possession document communication manifestation doeument communication, access contents communication; number pages document communication equivalent measure length, appropriate, ESI); matter information contend protected discovery; speeific basis asserting document communication are privileged confidential; precise factual basis privilege asserted claimed; discovery request requests which information question responsive. documents referred herein custody control actual state following whether missing lost, destroyed, transferred voluntarily involuntarily others disposed location cannot location left possession, custody control parties; reasons document control party; having matters are subject inquiry immediately preceding herein destroyed, requested describe circumstances destruction all documents which relate circumstances destruction. requesting intention permissible discovery, particularly privileged matters. herein withheld privilege whatever requested state specifically privilege reason withhold production identify document date, subject matter, disclosing sufficient allow described ruling privilege asserted. are further document which privilege exercising otherwise protecf which privilege asserted, technique result disclosing contents privilege asserted. request production nature. addif documents brought attention discovery preparations trial, supplementaf required. DEFINITIONS The following document requests listed below. herein, following following meanings: ''Person'" natural corporation, partnership, unincorporated form business, governmental, public charitable entity. Where employee performs task inquiry requests include employing employed person. "Document" "Documents" original non-identical written, electronic, matter, produced, whether received, neither, including drafts sides thereof, custody, control specifically includes Metadata. identical handwritten notations, identification marks modifications, non-identical separate within definition. include, limited handwritten, typewritten, printed, drawn, filed, recorded matter, which custody control, including, limited account, record, brochure, catalog, periodical, publication, advertisement, schedule, list, manual, letter, correspondence, telegram, telephone record, memorandum, contract, lease, invoice, manifest, purchase order, ticket, computer record, bulletin, report, sales letter, chart, sheet, intra company communication, report, plan, worksheet, statement, journal, travel record, calendar, minutes, transcripts, accounting record, financial record, record, photograph, record, recording, recording, films, drawings, maps, picture films, parts components equipment, models, information stored accessible computer information storage retrieval systems, “documents tangible physical object possession subject control within responding requests production, their counsel, investigators. definition includes copies, reproductions facsimiles documents whatever documents privilege claimed. definition also computer files recoverable from computer-based media, included are erased recoverable maintained personal computer, notebook computer, server, minicomputer, mainframe computer, storage device limited hard drive drives, archival (whether stored site), drives, mobile communications Blackberries iPhones, electronically stored information includes, limited information electronically, magnetically optically stored digital communications email, messaging); processed documents Microsoft WordPerfect documents drafts); tables Excel worksheets); accounting application Money, Peachtree files); image facsimile files images); recordings files); video animation files); (e.g. Project Wise, Oracle, SAP); electronic mail, contact relationship management data Maximizer, ACT!), including emails resident servers files); calendar application Outlook tools); access (e.g., temporary internet files, history, cookies); presentations PowerPoint, Corel Presentations); network access activity project application computer design/drawing files files (*.txt); archival files '"Metadata'" application metadata. System metadata information describing history characteristics ESI. information associated with tracking managing electronic file includes reflecting folder, file size, location, creation last modification, comments, updates, access relevant meta Application information automatically included electronic files may including deleted content, draft language, commentary, collaboration distribution creation printing. electronic mail, includes header routing attachment addition From, Subject, Received Time fields, relevant data. document communication which "relates subject constituting, comprising, identilying, referring dealing with subject matter. "Including" "includes" without limitation. "Communication" transfer, attempted transfer requests transfer information includes method communication whether written, oral, mechanical, magnetic, electronic, optical, digital, photographic, pectoral means. also includes, limited includes letters, emails, messages, message, online chats, social media social "Identity" "identities," reference persons, information concerning address, office address, street office telephone telephone number, person information which locate Identify'" following meanings: reference natural state person full business affiliation, title current telephone residence address business address. reference natural form organization, service process, address its principal office present business telephone numbers. reference document, state: (letter, memorandum, telegram, ehart, email, etc.); (ii) address, affiliation title signer thereof; (iii) its affiliation addressees recipients; present location; present business affiliation title person having thereof reference communication means: (i) state communication occurred telephone conversation, meeting, etc.); communication document, identify each person received document state document received; (iii) communication telephone conversation, identify person during all communication, describe detail information communicated natural the communication meeting, state meeting, identify natural meeting, describe detail information communicated natural person; described natural person provided information communicated, state which communication received describe detail information eommunicated. ""and/or." include plural, plural singular, effect doing increase information responses. terms ""relating ""reflecting," ""referring ""regarding" subject, when specify document, communication, statement, document, communication, statement constitutes, contains, reflects, identifies, states, with, whatsoever pertinent subject. The terms and/or, inclusively, exclusively. refer Ward-Brown Partners, Builders, its parents, subsidiaries, affiliates, predecessors, owners, partners, members, managers, directors, officers, agents. representatives, employees thereof, acting its behalf, including limited Brown David Ward. '"Plaintiffs'' collectively refer Trapp Trapp. "Property" real property Street, Houston, Texas "Project" associated with Property. "Original executed Ward original the Property, Jeroen "City Houston" Houston, departments (including limited Department Engineering Development Department), representatives, employees. "Lawsuit" "Dispute" refer following action: Elena Ward-Brown Partners, d/b/a Builders, District Harris Texas. Engineering refer Engineering its parents, subsidiaries, affiliates, predecessors, owners, members, managers, directors, officers, agents, representatives, employees acting its behalf, limited Qashshu Jack Spivey. Engineering, shall parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers, directors, officers, representatives, employees thereof, acting "Geoscience Engineering Testing, refer GEOSCIENCE ENGfNEERfNG TESTING, parents, subsidiaries, affiliates, predecessors, owners, partners, members, officers, representatives, thereof, acting behalf BISON BUILDING MATERIALS its parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers, directors, officers, representatives, employees thereof, behalf, limited Jamie Cortez. refer Corporation Building Materials Construction Services, respective parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members, directors, officers, representatives, employees thereof, persons acting behalf "Frontier Title Company" Frontier Title its parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers, directors, officers, agents, representatives, employees thereof, behalf refer ROOFING, its parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers, directors, officers, representatives, employees acting behalf, limited Systems LLC" refer Systems parents, subsidiaries, affiliates, predecessors, owners, partners, members, managers, directors, officers, representatives, employees persons acting behalf, including limited Arnulfo Rodriguez Roofing RODRIGUEZ ROOFfNG its parents, subsidiaries, affiliates, predecessors, successors, owners, members, managers, directors, officers, agents, representatives, employees thereof, acting behalf, limited Arnulfo Rodrigues ''Grogan Builders Company"' refer BUILDERS SUPPLY COMPANY, its parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers, directors, officers, representatives, employees thereof, acting its behalf, limited Shawn Schwiesow. Industries" Industries Acquisitions, its parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers, directors, officers, representatives, employees thereof, acting its behalf, limited Walter III. "Blue FinanciaF Tarp Financial, BlueTarp Financial, respective parents, subsidiaries, affiliates, predecessors, owners, partners, members, managers, directors, officers, agents, representatives, employees thereof, acting its behalf Homes, refer its parents, subsidiaries, affiliates, predecessors, owners, partners, members, managers, directors, officers, representatives, employees persons acting "Gomez Gutters Services, refer Gomez Gutters Services, parents, subsidiaries, affiliates, owners, partners, members, managers, directors, officers, agents, representatives, employees thereof, its behalf "A.R.H. Construction Inc."" refer Construction its parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers, directors, officers, agents, representatives, employees thereof, acting its behalf "Urban Access Properties Inc."" refer URBAN PROPERTIES its parents, subsidiaries, affiliates, predecessors, owners, partners, members. managers, directors, officers, agents, representatives, employees thereof, acting its behalf, limited Miranda Sharlene Abghary. ^Beth Associates, refer ASSOCIATES, its parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers, directors, officers, representatives, employees thereof, acting its behalf, limited '^International Architectural Services'" refer International Architectural Services, its parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers, officers, agents, representatives, employees thereof, acting its Tension, refer HOUSTON TENSION, parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers, directors, officers, agents, representatives, employees thereof, acting its behalf, limited David Cooney. Construction CONSTRUCTION its parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers, directors, officers, representatives, employees thereof, acting its behalf "Statewide Inspections" refer Statewide Property Inspections, parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers, directors, officers, representatives, employees acting its behalf "Home Inspections" Inspections, parents, subsidiaries, affiliates, successors, owners, partners, members, managers, directors, officers, representatives, employees acting its behalf "HBIS" refer Builders Services, its parents, subsidiaries, affiliates, predecessors, owners, partners, members, managers, directors, officers, agents, representatives, employees persons acting its "Anne's Permit, refer Permit, its parents, subsidiaries, affiliates, predecessors, successors, owners, partners, members, managers, directors, officers, representatives, employees thereof, acting its behalf 3\."Retzer Construction" refer Retzer Construction, its parents, subsidiaries, affiliates, predecessors, owners, partners, members, managers, directors, officers, representatives, employees thereof, acting its behalf Metal Roofing'" refer Sheet Metal its parents, subsidiaries, affiliates, predecessors, owners, partners, members, managers, directors, officers, representatives, employees thereof, persons aeting its behalf Texas refer Spirit its parents, subsidiaries, affiliates, predecessors, owners, partners, members, managers, directors, officers, agents, representatives, employees thereof, aeting behalf Kelly refer its parents, subsidiaries, affiliates, owners, partners, members, managers, directors, officers, agents, representatives, employees thereof, acting its behalf LLC" refer its parents, subsidiaries, affiliates, predecessors, owners, partners, members, directors, officers, representatives, employees thereof persons acting PLAINTIFFS SECOND PRODUCTION DEFENDANT REQUEST PRODUCTION construction warranties provided connection Original Sales Contract native format. REQUEST PRODUCTION entitled “Ward Builders Limited Warranty Coverage format. insurance coverage applicable, part, Project Property. REQUEST indemnity insuring agreements related applicable, Project Property. REQUEST certificates insurance received provided Brown Project. REQUEST PRODUCTION settlement agreements executed Project Property. REQUEST PRODUCTION applications, invoices, requests payment submitted Brown, acting its behalf, connection with Project. REQUEST PRODUCTION payment invoices, requests payment Project. payments Brown, including persons acting its behalf, materials connection with Project. connection Project. REQUEST documents communication relating Project Property. REQUEST documents communication relating Project Property exchanged between persons acting its behalf) following persons: Previous owner(s) Jeroen Kirschbaum; Architect(s); Designer(s); Engineer(s); General contractor(s); Subcontractor(s); Engineering EEC; Ammar Engineering, Geoscience Engineering Testing, Frontier Title Company; Roofing, Systems Arnulfo Rodriguez Builders RAM Industries; Tarp Financial; Paragon Gutters Services, Javier Eara; Wilkes; Construction Access Properties аа) Wolff Associates, International Architectural Services; Tension, Construction ee) Statewide Inspections; ff) Home Inspections; Malacara; Permit, Retzer Construction; Sheet Metal Spirit mm) O'Kelly Julio Quintero; Amador Trim, Jasun Juergens; Cecelia Gerber; rr) Broadfoot; Houston. documents communication relating construction repair performed Brown persons identified Production REQUEST PRODUCTION documents communication referring referencing construction warranties provided Original Contract. includes, limited communications original owner(s) Property, Frontier Title fmaneial institutions construction Property, internal communications Brown. electronic communication format. documents communication referring relating referencing requests applications: issuance amendment permit(s) Projeet authorization modify drawings, plans, specifications were with permit(s) Project.