Preview
Electronically Electronically
Filed Submitted
6/14/2023 1:54 PM3/20/2023 2:41 PM
Hidalgo County District
HidalgoClerks
County Clerk
Accepted
Reviewed by: Carlos
By: Kimberly Diaz Guerra
CAUSE NO. CL-23-0048-G
MARIA A. QUIROZ DE LEON § IN THE COUNTY COURT AT LAW
AND §
YESIKA M. QUIROZ DE LEON §
Plaintiffs, §
§
V. § NO. 7
§
BLANCA M. RAMIREZ PEREZ §
Defendant. § HIDALGO COUNTY, TEXAS
PLAINTIFF MARIA A. QUIROZ DE LEON’S ANSWERS TO DEFENDANT’S
REQUEST FOR INTERROGATORIES
TO: Defendants, “as listed above”, by and through their attorney of record.
COMES NOW, Plaintiff, “as named above”, in the above styled and numbered cause,
and pursuant to Rules 197 of the Texas Rules of Civil Procedure hereby makes these Plaintiff’s
Responses, Answers and/or objections to Defendants Request for Interrogatories as attached
hereto.
Respectfully,
____________________________________
J.R. Ramirez
LAW OFFICEOF J.R. RAMIREZ, P.L.L.C.
1601 W. Trenton Rd., Suite I
Edinburg, Texas 78539
SBN: 24089630
Telephone:(956) 603-2352
Facsimile:(956) 603-2355
E-mail: litigation@lawofficeofjrramirez.law
ATTORNEY IN CHARGE FOR PLAINTIFFS
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Hidalgo County District
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By: Kimberly Diaz Guerra
CERTIFICATE OF SERVICE
I hereby certify on March 20, 2023, a true and correct copy of the above and foregoing
instrument has been forwarded to opposing counsel of record as noted hereunder.
____________________________
J.R. Ramirez
ATTORNEY IN CHARGE FOR PLAINTIFFS
Via E-File Service:
William R. Garza
SBN: 24012683
Palacios Garza & Thompson, P.C.
2724 W. Canton Rd.
Edinburg, TX 78539
O: (956)318-0507
F: (956) 318-0575
wgarza@pgtlawfirm.com
ATTORNEY FOR DEFENDANT
PLAINTIFF MARIA A. QUIROZ DE LEON’S RESPONSES TO DEFENDANTS’
INTERROGATORIES
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Filed Submitted
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Hidalgo County District
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Accepted
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By: Kimberly Diaz Guerra
INTERROGATORY NO. 1:
Please identify yourself fully by giving your full legal name, nicknames you have ever
been known by, current residence address, date and place of birth, driver’s license
number and state, social security number, name of current spouse, if married, names and
addresses of all spouses to whom you have been married, and the names, current
addresses and dates of birth of all natural and/or adopted children.
ANSWER: Plaintiff objects to this Interrogatory seeking Plaintiff’s current residence
address, date and place of birth, driver’s license number and state, social security
number, name and addresses of current spouse and/or all spouses and names, current
addresses and dates of birth of all natural and/or adopted children since it constitutes
an invasion of privacy and is irrelevant to any matter in this cause of action. Plaintiff
objects to this Interrogatory insofar as the information requested is overly broad,
vague, and ambiguous. Plaintiff objects to this Interrogatory as it irrelevant and not
reasonably calculated to lead to the discovery of evidence admissible at the time of
trial. Subject to the aforementioned objections:
Maria Aurelia Quiroz De Leon
c/o JR Ramirez
Law Office of JR Ramirez, PLLC
1601 W Trenton Rd. Suite I
Edinburg, Texas 78539
(956) 603-2352
INTERROGATORY NO. 2:
Please state the extent of your formal education, by stating when and where you received such
education.
ANSWER: Plaintiff objects to the extent that the discovery request seeks to invade the
Plaintiff’s right to privacy. Further, the information sought is not relevant to the subject
matter of the pending action, or if so, does not outweigh the prejudice to Plaintiff’s
constitutional right to privacy. 40 Tex. Admin. Code §19.407 (Tex. Dept. Human Svc.,
Nursing Facility). See also In re Diversicare Gen. Partner, Inc., 41 S.W.3d 788 (Tex. App. –
Corpus Christi 2001, orig. proceeding) (en banc). Additionally, the Plaintiff would object
to this request insofar as the information requested is irrelevant and inadmissible and not
reasonably calculated to lead to the discovery of evidence admissible at the time of trial.
INTERROGATORY NO. 3:
Please state the names and addresses of each of your employers (including any self-employment)
for the past ten (10) years, and for each please state:
a) The dates of such employment (including any self-employment);
b) The nature of the work or duties;
c) The place or places where such work or duties were performed;
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Hidalgo County District
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By: Kimberly Diaz Guerra
And
d) The average weekly or monthly compensation from such employment (including any
self-employment).
ANSWER: Plaintiff is not claiming lost wages.
INTERROGATORY NO. 4:
Please describe the purpose of your trip or activity on the date of this accident, including the time
and location of your departure, reasons for being at location from which you departed, and the
ultimate destination of your trip.
ANSWER: Plaintiff objects to this interrogatory as vague, ambiguous, unduly
burdensome, and overly broad in that it calls for a narrative response requiring
complete factual details and assertions and seek to narrow Plaintiff’s responses without
the benefit of specific questions during direct and/or cross-examination. Subject to and
without waiving or limiting any objection. We will supplement when depositions are
conducted.
INTERROGATORY NO. 5:
Regarding the incident in question, please state the approximate speed you were traveling and
your approximate distance from Defendant’s vehicle:
a) At the time you first saw Defendant’s vehicle; and
b) At the point of impact with Defendant’s vehicle.
ANSWER: Plaintiff objects to this interrogatory as vague, ambiguous, unduly
burdensome, and overly broad in that it calls for a narrative response requiring
complete factual details and assertions and seek to narrow Plaintiff’s responses without
the benefit of specific questions during direct and/or cross-examination. Subject to and
without waiving or limiting any objection. We will supplement when depositions are
conducted.
INTERROGATORY NO. 6:
State specifically each and every act of negligence which you contend was negligence
attributable to any other, and each other, party to this suit and state precisely what should have
been done by said party in order to not have been negligent.
ANSWER: Plaintiff refers Defendant to Plaintiff’s Original Petition.
INTERROGATORY NO. 7:
Please state the name, address and telephone number of each consulting expert who is not
expected to testify at the time of trial and whose opinions or impressions have been reviewed by
the expert or experts identified in response to Requests for Disclosure 194.2(f).
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Hidalgo County District
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Accepted
Reviewed by: Carlos
By: Kimberly Diaz Guerra
ANSWER: Plaintiff objects to this request because there are no retained experts at this time.
Plaintiff will designate experts in accordance with Court’s Docket Control Order and/or the
Rules, if needed. Additionally, Plaintiff hereby incorporates all retained and non-retained
experts designated by Defendant. In addition, Plaintiff designates any experts regardless of
who designated such experts who would be supportive of the defense of Plaintiff.
Plaintiff may use testimony and/or records and/or report(s) of any expert witness who has
been designated and/or identified as an expert witness by any part to this litigation.
Plaintiff reserves the right to call any expert witness designated by any other party to this
case as an adverse expert witness, or, alternatively, as an expert witness for and on behalf of
Plaintiff or reserves the right to call any individual as an expert witness in this matter.
Plaintiff further reserves the right to expand reasonably on the scope of the testimony of any
expert witnesses as might be necessary and/or appropriated for their defense, and as may be
developed during any deposition or trial testimony. Plaintiff further reserves the right to
elicit any expert witness testimony from other witnesses who, because of their knowledge,
are qualified to give their opinions and testimony of various issues of the issues involved
herein. Said testimony would be of benefit to the jury to determine material issues of fact
which would not be violative of any existing court order of the Texas Rules of Civil
Procedure.
Plaintiff further reserves the right to designate any additional expert witnesses and/or
provide documents at a later date, if necessary, and/or if appropriate, upon receipt of
more information and/or details as to the testimony of any expert witnesses designated
by any party. Plaintiff further reserves the right to withdraw designation of any expert
witnesses or to provide supplemental information regarding same in conformance with
the Texas Rules of Civil Procedure.
INTERROGATORY NO. 8:
For each such expert identified in Interrogatory No. 7, please state the mental impressions and
opinions held by the expert and the facts known to the expert (regardless of when the factual
information was acquired) which relate to or form the basis of the mental impressions and opinions
held by said expert.
ANSWER: Plaintiff objects to this request because there are no retained experts at this time.
Plaintiff will designate experts in accordance with Court’s Docket Control Order and/or the
Rules, if needed. Additionally, Plaintiff hereby incorporates all retained and non-retained
experts designated by Defendant. In addition, Plaintiff designates any experts regardless of
who designated such experts who would be supportive of the defense of Plaintiff.
Plaintiff may use testimony and/or records and/or report(s) of any expert witness who has
been designated and/or identified as an expert witness by any part to this litigation.
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Filed Submitted
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Hidalgo County District
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County Clerk
Accepted
Reviewed by: Carlos
By: Kimberly Diaz Guerra
Plaintiff reserves the right to call any expert witness designated by any other party to this
case as an adverse expert witness, or, alternatively, as an expert witness for and on behalf of
Plaintiff or reserves the right to call any individual as an expert witness in this matter.
Plaintiff further reserves the right to expand reasonably on the scope of the testimony of any
expert witnesses as might be necessary and/or appropriated for their defense, and as may be
developed during any deposition or trial testimony. Plaintiff further reserves the right to
elicit any expert witness testimony from other witnesses who, because of their knowledge,
are qualified to give their opinions and testimony of various issues of the issues involved
herein. Said testimony would be of benefit to the jury to determine material issues of fact
which would not be violative of any existing court order of the Texas Rules of Civil
Procedure.
Plaintiff further reserves the right to designate any additional expert witnesses and/or
provide documents at a later date, if necessary, and/or if appropriate, upon receipt of
more information and/or details as to the testimony of any expert witnesses designated
by any party. Plaintiff further reserves the right to withdraw designation of any expert
witnesses or to provide supplemental information regarding same in conformance with
the Texas Rules of Civil Procedure.
INTERROGATORY NO. 9:
Identify all photographs, videotapes or other visual records, sketches or diagrams in your
possession, custody or control, pertaining to the incident made the basis of this suit, including,
but not limited to, any photographs of the accident, your injuries, damages or condition.
ANSWER: Plaintiff refers Defendant to Exhibit A (Photographs) of Plaintiff’s
Production responses.
INTERROGATORY NO. 10:
Does there exist in any form, whether written or oral, any understanding, agreement or contract
between you or your attorney and/or any other party, or anyone who is not a party to this suit,
which provides:
a) Any compromise settlement agreement, covenant not to sue, hold harmless agreement,
indemnity agreement, Mary Carter agreement, high/low agreement, or any other
agreement or arrangement releasing or compromising any part of any cause of action or
issue asserted herein that might be the subject matter of the trial herein and arising out of
the incident made the subject of this suit; or
b) Concerning the manner in which this case will be tried including, but not limited to,
understandings, agreements or contracts regarding voir dire examinations, jury strikes,
witnesses to be called, special issues to be requested, or objections, opening statements
or arguments to be made.
If your Answer to either Interrogatory Numbers 10(a) or 10(b) is “yes,” please state the contents
of each such understanding, agreement or contract and all parties with whom same has been
made. (Alternatively, if such understanding, agreement or contract is totally contained in a
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Hidalgo County District
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Accepted
Reviewed by: Carlos
By: Kimberly Diaz Guerra
written document, you may attach a copy of such document.)
ANSWER: Plaintiff has not entered into any sort of agreement(s).
INTERROGATORY N0. 11:
Please list each and every element of damages for which you are suing this Defendant,
and after each element so listed, state the amount you claim as damages with respect to
each such element.
ANSWER: - Plaintiff refers Defendant to Request #4 of Plaintiff’s Initial Disclosures.
INTERROGATORY N0. 12:
Please state:
a) The name and complete address of any and all doctors, physicians, chiropractors
or any other health care providers where you have been seen or examined for
any reason in the last ten (10) years, stating the approximate date(s) of each visit
and the reason for such visit(s); and
b) The name and address of the doctors or health care provider providing care to
you by reason of the incident(s) made the basis of this lawsuit, the date(s) of any
such treatment or visit, the cost of such services(s), and the date(s) of such
service(s).
ANSWER:
a) Plaintiff has been seen Dr. Christopher Scoff for diabetes. Dates are unknown.
b) Plaintiff refers Defendant to Exhibit A (Medical Bills and Records) of Plaintiff’s
Initial Disclosures.
INTERROGATORY N0. 13:
Please describe each and every injury, whether physical, mental or otherwise, you sustained
for the ten (10) years prior to the accident which forms the basis of this lawsuit, requiring
health care treatment. If any, please name the health care provider(s) who treated you and
provide the telephone number(s), business address(es) of such provider(s) and the date(s) of
such treatment(s).
ANSWER: Plaintiff has not been injured physically, mentally or otherwise ten (10)
years prior to the accident.
INTERROGATORY N0. 14:
Please list each medical doctor or health care provider, including any chiropractors or physical
therapists, you have seen for injuries arising out of the incident which forms the basis of this lawsuit,
identifying each health care provider, business address, telephone number, the date(s) of treatment,
whether x-rays, CT scans and/or MRIs were taken, and any and all hospitalizations as a result of said
incident.
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Filed Submitted
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Hidalgo County District
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County Clerk
Accepted
Reviewed by: Carlos
By: Kimberly Diaz Guerra
ANSWER: Plaintiff refers Defendant to Exhibit A (Medical Bills and Records) and
Request #5 of Plaintiff’s Initial Disclosures.
INTERROGATORY N0. 15:
If you are asserting, or will assert, a claim for mental anguish resulting from the incident(s) made the
basis of this lawsuit, please state in detail the date or dates on which you claim to have first noticed
the foregoing anguish, the specific reason(s) for such mental anguish, any changes resulting from the
mental anguish (e.g. sleep habits, body weight, personal relationships, work habits, eating habits,
recreational or hobby pastimes or participation) and any diagnosis provided by any health care
provider(s) and identify all health care providers consulted regarding mental anguish and any mental
health professionals seen or consulted for ten(10) years prior to the incident which gives rise to this
lawsuit to the present date.
ANSWER: Plaintiff is not claiming mental anguish.
INTERROGATORY N0. 16:
Please state all things which you claim you can no longer perform or are physically limited from
enjoying or doing due to the incident which forms the basis of this lawsuit (including, but not limited
to, sports, household chores, sexual activities, work related activities, hobbies or any other activities)
which you were previously able to do, perform and/or enjoy, and describe in detail under what
circumstances and how often you did, performed, and/or enjoyed the same before the subject
accident and after said accident. If you have had to hire or obtain the service of someone, including,
but not limited to a relative or friend, to do these activities or assist you in doing these activities an
you allege this assistance was necessitated by the accident which forms the basis of this lawsuit,
please identify the person(s) so assisting you by providing the name(s), address(es) and telephone
number(s).
ANSWER: Plaintiff objects to this interrogatory as vague, ambiguous, unduly
burdensome, and overly broad in that it calls for a narrative response requiring
complete factual details and assertions and seek to narrow Plaintiff’s responses without
the benefit of specific questions during direct and/or cross-examination. Subject to and
without waiving or limiting any objection. We will supplement when depositions are
conducted.
INTERROGATORY N0. 17:
Please describe all mental and/or physical injuries, disability, disease, abnormality, dysfunction,
incapacity, ailments, or pains (whether full or partial, permanent or temporary) which you claim to
have suffered as a result of the alleged occurrence made the basis of your lawsuit.
ANSWER: Plaintiff objects to this interrogatory as vague, ambiguous, unduly
burdensome, and overly broad in that it calls for a narrative response requiring
complete factual details and assertions and seek to narrow Plaintiff’s responses without
the benefit of specific questions during direct and/or cross-examination. Subject to and
without waiving or limiting any objection. We will supplement when depositions are
conducted.
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Hidalgo County District
HidalgoClerks
County Clerk
Accepted
Reviewed by: Carlos
By: Kimberly Diaz Guerra
INTERROGATORY N0. 18:
If you are claiming any lost wages or income or loss of earning capacity as a result of the incident
made the basis of this suit, please state the following:
a) The names and addresses of all employers for whom you have worked dating from
ten (10) years prior to the incident made the basis of your suit to the present;
b) The inclusive dates between which you were unable to work as a result of the alleged
occurrence;
c) The total amount of earnings which you allegedly lost as a result of your absence;
d) The name, address, and telephone number of each representative from the Texas
Employment Commission with whom you have spoken to in applying and/or
receiving unemployment benefits; and
e) The name, address, and telephone number of each person or business for whom you
have either applied for employment or attempted to secure gainful employment since
the date of the incident made the basis of this suit, along with a description of the
nature of the work for which said application or attempt was made. (Indicate the
names of any such persons or businesses to whom written application forms were
prepared by using all capital letters when listing their names.)
ANSWER: Plaintiff is not claiming lost wages.
INTERROGATORY N0. 19:
Please state the name and address of all pharmacies where prescriptions were filled or medications
were purchased or obtained for MARIA A. QUIROZ DE LEON.
ANSWER: Plaintiff has not filled any prescriptions or medications.
INTERROGATORY N0. 20:
Please state whether any funds have been expended by Medicare or Medicaid or any other
government agency or program on your behalf in connection with any of the injuries alleged in this
cause of action. If so, please identify such amounts by stating the name of the medical providers, the
approximate date(s) of service, the amount of any bill(s) or statement(s) submitted for payment, and
the amount(s) paid by Medicare or Medicaid.
ANSWER: Plaintiff is not a recipient of Medicaid or Medicare.
INTERROGATORY N0. 21:
Please identify any and all claims or lawsuits made by you or on your behalf (including any claims
against any person or entity, any claims for injuries or damages, any claims filed with an insurance
company, or workers’ compensation claims); and please identify the date and nature of each such
claim or suit, the name of each expert witness testifying on your behalf, the name of each opposing
party and their attorney, the county in which suit was filed, and the disposition and/or amount
received in each claim or suit.
ANSWER: Plaintiff has not been a party to any other claim.
9
Electronically Electronically
Filed Submitted
6/14/2023 1:54 PM3/20/2023 2:41 PM
Hidalgo County District
HidalgoClerks
County Clerk
Accepted
Reviewed by: Carlos
By: Kimberly Diaz Guerra
INTERROGATORY N0. 22:
Have you ever been convicted of any felonies or crimes of moral turpitude?
If you have, please state the following:
a) the date when the crime occurred;
b) a brief summary of the crime;
c) the disposition of the case; and
d) the name of the attorney, if any, that represented you in that incident.
ANSWER: Plaintiff has never been convicted of any felonies or crimes of moral
turpitude.
INTERROGATORY N0. 23:
Please state whether there are any child support liens against you. If so, please give the exact amount
of the arrearage.
ANSWER: Plaintiff has no child support liens against them.
10
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Filed Submitted
6/14/2023 1:54 PM3/20/2023 2:41 PM
Hidalgo County District
HidalgoClerks
County Clerk
Accepted
Reviewed by: Carlos
By: Kimberly Diaz Guerra
VERIFICATION
STATE OF TEXAS §
§
COUNTY OF HIDALGO §
BEFORE ME, the undersigned authority, personally appeared Maria Aurelia uiroz
De Leon, Who stated, upon oath, that the statements made in the foregoing instrument are Within
his personal knowledge and are tme and correct.
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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
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Envelope ID: 76606103
Filing Code Description: Memorandum
Filing Description: AGREED ORDER GRANTING DEFENDANT BLANCA
M. RAMIREZ PEREZ MOTION TO CONSOLIDATE
Status as of 6/16/2023 9:28 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
William RGarza wgarza@pgtlawfirm.com 6/14/2023 1:54:37 PM SENT
Mark Guerra mguerra@mukerjilaw.com 6/14/2023 1:54:37 PM SENT
J.R. Ramirez litigation@lawofficeofjrramirez.law 6/14/2023 1:54:37 PM SENT
Sam Mukerji litigation@mukerjilaw.com 6/14/2023 1:54:37 PM SENT
Associated Case Party: Maria Quiroz De Leon
Name BarNumber Email TimestampSubmitted Status
Frank Sabo, Jr. fsabo@guerrasabo.com 6/14/2023 1:54:37 PM SENT
Associated Case Party: BlancaRamirezPerez
Name BarNumber Email TimestampSubmitted Status
CESAR CHAPA CRASHLAWFIRM@GMAIL.COM 6/14/2023 1:54:37 PM SENT
MICHAEL JAMES MAIL@JAMESCHAPALAW.COM 6/14/2023 1:54:37 PM ERROR
JAMES CHAPA MAIL@JAMESCHAPALAW.COM 6/14/2023 1:54:37 PM ERROR
Preview
Electronically Electronically Filed Submitted 6/14/2023 1:54 PM3/20/2023 2:41 PM Hidalgo County District HidalgoClerks County Clerk Accepted Reviewed by: Carlos By: Kimberly Diaz Guerra CAUSE NO. CL-23-0048-G MARIA A. QUIROZ DE LEON § IN THE COUNTY COURT AT LAW AND § YESIKA M. QUIROZ DE LEON § Plaintiffs, § § V. § NO. 7 § BLANCA M. RAMIREZ PEREZ § Defendant. § HIDALGO COUNTY, TEXAS PLAINTIFF MARIA A. QUIROZ DE LEON’S ANSWERS TO DEFENDANT’S REQUEST FOR INTERROGATORIES TO: Defendants, “as listed above”, by and through their attorney of record. COMES NOW, Plaintiff, “as named above”, in the above styled and numbered cause, and pursuant to Rules 197 of the Texas Rules of Civil Procedure hereby makes these Plaintiff’s Responses, Answers and/or objections to Defendants Request for Interrogatories as attached hereto. Respectfully, ____________________________________ J.R. Ramirez LAW OFFICEOF J.R. RAMIREZ, P.L.L.C. 1601 W. Trenton Rd., Suite I Edinburg, Texas 78539 SBN: 24089630 Telephone:(956) 603-2352 Facsimile:(956) 603-2355 E-mail: litigation@lawofficeofjrramirez.law ATTORNEY IN CHARGE FOR PLAINTIFFS 1 Electronically Electronically Filed Submitted 6/14/2023 1:54 PM3/20/2023 2:41 PM Hidalgo County District HidalgoClerks County Clerk Accepted Reviewed by: Carlos By: Kimberly Diaz Guerra CERTIFICATE OF SERVICE I hereby certify on March 20, 2023, a true and correct copy of the above and foregoing instrument has been forwarded to opposing counsel of record as noted hereunder. ____________________________ J.R. Ramirez ATTORNEY IN CHARGE FOR PLAINTIFFS Via E-File Service: William R. Garza SBN: 24012683 Palacios Garza & Thompson, P.C. 2724 W. Canton Rd. Edinburg, TX 78539 O: (956)318-0507 F: (956) 318-0575 wgarza@pgtlawfirm.com ATTORNEY FOR DEFENDANT PLAINTIFF MARIA A. QUIROZ DE LEON’S RESPONSES TO DEFENDANTS’ INTERROGATORIES 2 Electronically Electronically Filed Submitted 6/14/2023 1:54 PM3/20/2023 2:41 PM Hidalgo County District HidalgoClerks County Clerk Accepted Reviewed by: Carlos By: Kimberly Diaz Guerra INTERROGATORY NO. 1: Please identify yourself fully by giving your full legal name, nicknames you have ever been known by, current residence address, date and place of birth, driver’s license number and state, social security number, name of current spouse, if married, names and addresses of all spouses to whom you have been married, and the names, current addresses and dates of birth of all natural and/or adopted children. ANSWER: Plaintiff objects to this Interrogatory seeking Plaintiff’s current residence address, date and place of birth, driver’s license number and state, social security number, name and addresses of current spouse and/or all spouses and names, current addresses and dates of birth of all natural and/or adopted children since it constitutes an invasion of privacy and is irrelevant to any matter in this cause of action. Plaintiff objects to this Interrogatory insofar as the information requested is overly broad, vague, and ambiguous. Plaintiff objects to this Interrogatory as it irrelevant and not reasonably calculated to lead to the discovery of evidence admissible at the time of trial. Subject to the aforementioned objections: Maria Aurelia Quiroz De Leon c/o JR Ramirez Law Office of JR Ramirez, PLLC 1601 W Trenton Rd. Suite I Edinburg, Texas 78539 (956) 603-2352 INTERROGATORY NO. 2: Please state the extent of your formal education, by stating when and where you received such education. ANSWER: Plaintiff objects to the extent that the discovery request seeks to invade the Plaintiff’s right to privacy. Further, the information sought is not relevant to the subject matter of the pending action, or if so, does not outweigh the prejudice to Plaintiff’s constitutional right to privacy. 40 Tex. Admin. Code §19.407 (Tex. Dept. Human Svc., Nursing Facility). See also In re Diversicare Gen. Partner, Inc., 41 S.W.3d 788 (Tex. App. – Corpus Christi 2001, orig. proceeding) (en banc). Additionally, the Plaintiff would object to this request insofar as the information requested is irrelevant and inadmissible and not reasonably calculated to lead to the discovery of evidence admissible at the time of trial. INTERROGATORY NO. 3: Please state the names and addresses of each of your employers (including any self-employment) for the past ten (10) years, and for each please state: a) The dates of such employment (including any self-employment); b) The nature of the work or duties; c) The place or places where such work or duties were performed; 3 Electronically Electronically Filed Submitted 6/14/2023 1:54 PM3/20/2023 2:41 PM Hidalgo County District HidalgoClerks County Clerk Accepted Reviewed by: Carlos By: Kimberly Diaz Guerra And d) The average weekly or monthly compensation from such employment (including any self-employment). ANSWER: Plaintiff is not claiming lost wages. INTERROGATORY NO. 4: Please describe the purpose of your trip or activity on the date of this accident, including the time and location of your departure, reasons for being at location from which you departed, and the ultimate destination of your trip. ANSWER: Plaintiff objects to this interrogatory as vague, ambiguous, unduly burdensome, and overly broad in that it calls for a narrative response requiring complete factual details and assertions and seek to narrow Plaintiff’s responses without the benefit of specific questions during direct and/or cross-examination. Subject to and without waiving or limiting any objection. We will supplement when depositions are conducted. INTERROGATORY NO. 5: Regarding the incident in question, please state the approximate speed you were traveling and your approximate distance from Defendant’s vehicle: a) At the time you first saw Defendant’s vehicle; and b) At the point of impact with Defendant’s vehicle. ANSWER: Plaintiff objects to this interrogatory as vague, ambiguous, unduly burdensome, and overly broad in that it calls for a narrative response requiring complete factual details and assertions and seek to narrow Plaintiff’s responses without the benefit of specific questions during direct and/or cross-examination. Subject to and without waiving or limiting any objection. We will supplement when depositions are conducted. INTERROGATORY NO. 6: State specifically each and every act of negligence which you contend was negligence attributable to any other, and each other, party to this suit and state precisely what should have been done by said party in order to not have been negligent. ANSWER: Plaintiff refers Defendant to Plaintiff’s Original Petition. INTERROGATORY NO. 7: Please state the name, address and telephone number of each consulting expert who is not expected to testify at the time of trial and whose opinions or impressions have been reviewed by the expert or experts identified in response to Requests for Disclosure 194.2(f). 4 Electronically Electronically Filed Submitted 6/14/2023 1:54 PM3/20/2023 2:41 PM Hidalgo County District HidalgoClerks County Clerk Accepted Reviewed by: Carlos By: Kimberly Diaz Guerra ANSWER: Plaintiff objects to this request because there are no retained experts at this time. Plaintiff will designate experts in accordance with Court’s Docket Control Order and/or the Rules, if needed. Additionally, Plaintiff hereby incorporates all retained and non-retained experts designated by Defendant. In addition, Plaintiff designates any experts regardless of who designated such experts who would be supportive of the defense of Plaintiff. Plaintiff may use testimony and/or records and/or report(s) of any expert witness who has been designated and/or identified as an expert witness by any part to this litigation. Plaintiff reserves the right to call any expert witness designated by any other party to this case as an adverse expert witness, or, alternatively, as an expert witness for and on behalf of Plaintiff or reserves the right to call any individual as an expert witness in this matter. Plaintiff further reserves the right to expand reasonably on the scope of the testimony of any expert witnesses as might be necessary and/or appropriated for their defense, and as may be developed during any deposition or trial testimony. Plaintiff further reserves the right to elicit any expert witness testimony from other witnesses who, because of their knowledge, are qualified to give their opinions and testimony of various issues of the issues involved herein. Said testimony would be of benefit to the jury to determine material issues of fact which would not be violative of any existing court order of the Texas Rules of Civil Procedure. Plaintiff further reserves the right to designate any additional expert witnesses and/or provide documents at a later date, if necessary, and/or if appropriate, upon receipt of more information and/or details as to the testimony of any expert witnesses designated by any party. Plaintiff further reserves the right to withdraw designation of any expert witnesses or to provide supplemental information regarding same in conformance with the Texas Rules of Civil Procedure. INTERROGATORY NO. 8: For each such expert identified in Interrogatory No. 7, please state the mental impressions and opinions held by the expert and the facts known to the expert (regardless of when the factual information was acquired) which relate to or form the basis of the mental impressions and opinions held by said expert. ANSWER: Plaintiff objects to this request because there are no retained experts at this time. Plaintiff will designate experts in accordance with Court’s Docket Control Order and/or the Rules, if needed. Additionally, Plaintiff hereby incorporates all retained and non-retained experts designated by Defendant. In addition, Plaintiff designates any experts regardless of who designated such experts who would be supportive of the defense of Plaintiff. Plaintiff may use testimony and/or records and/or report(s) of any expert witness who has been designated and/or identified as an expert witness by any part to this litigation. 5 Electronically Electronically Filed Submitted 6/14/2023 1:54 PM3/20/2023 2:41 PM Hidalgo County District HidalgoClerks County Clerk Accepted Reviewed by: Carlos By: Kimberly Diaz Guerra Plaintiff reserves the right to call any expert witness designated by any other party to this case as an adverse expert witness, or, alternatively, as an expert witness for and on behalf of Plaintiff or reserves the right to call any individual as an expert witness in this matter. Plaintiff further reserves the right to expand reasonably on the scope of the testimony of any expert witnesses as might be necessary and/or appropriated for their defense, and as may be developed during any deposition or trial testimony. Plaintiff further reserves the right to elicit any expert witness testimony from other witnesses who, because of their knowledge, are qualified to give their opinions and testimony of various issues of the issues involved herein. Said testimony would be of benefit to the jury to determine material issues of fact which would not be violative of any existing court order of the Texas Rules of Civil Procedure. Plaintiff further reserves the right to designate any additional expert witnesses and/or provide documents at a later date, if necessary, and/or if appropriate, upon receipt of more information and/or details as to the testimony of any expert witnesses designated by any party. Plaintiff further reserves the right to withdraw designation of any expert witnesses or to provide supplemental information regarding same in conformance with the Texas Rules of Civil Procedure. INTERROGATORY NO. 9: Identify all photographs, videotapes or other visual records, sketches or diagrams in your possession, custody or control, pertaining to the incident made the basis of this suit, including, but not limited to, any photographs of the accident, your injuries, damages or condition. ANSWER: Plaintiff refers Defendant to Exhibit A (Photographs) of Plaintiff’s Production responses. INTERROGATORY NO. 10: Does there exist in any form, whether written or oral, any understanding, agreement or contract between you or your attorney and/or any other party, or anyone who is not a party to this suit, which provides: a) Any compromise settlement agreement, covenant not to sue, hold harmless agreement, indemnity agreement, Mary Carter agreement, high/low agreement, or any other agreement or arrangement releasing or compromising any part of any cause of action or issue asserted herein that might be the subject matter of the trial herein and arising out of the incident made the subject of this suit; or b) Concerning the manner in which this case will be tried including, but not limited to, understandings, agreements or contracts regarding voir dire examinations, jury strikes, witnesses to be called, special issues to be requested, or objections, opening statements or arguments to be made. If your Answer to either Interrogatory Numbers 10(a) or 10(b) is “yes,” please state the contents of each such understanding, agreement or contract and all parties with whom same has been made. (Alternatively, if such understanding, agreement or contract is totally contained in a 6 Electronically Electronically Filed Submitted 6/14/2023 1:54 PM3/20/2023 2:41 PM Hidalgo County District HidalgoClerks County Clerk Accepted Reviewed by: Carlos By: Kimberly Diaz Guerra written document, you may attach a copy of such document.) ANSWER: Plaintiff has not entered into any sort of agreement(s). INTERROGATORY N0. 11: Please list each and every element of damages for which you are suing this Defendant, and after each element so listed, state the amount you claim as damages with respect to each such element. ANSWER: - Plaintiff refers Defendant to Request #4 of Plaintiff’s Initial Disclosures. INTERROGATORY N0. 12: Please state: a) The name and complete address of any and all doctors, physicians, chiropractors or any other health care providers where you have been seen or examined for any reason in the last ten (10) years, stating the approximate date(s) of each visit and the reason for such visit(s); and b) The name and address of the doctors or health care provider providing care to you by reason of the incident(s) made the basis of this lawsuit, the date(s) of any such treatment or visit, the cost of such services(s), and the date(s) of such service(s). ANSWER: a) Plaintiff has been seen Dr. Christopher Scoff for diabetes. Dates are unknown. b) Plaintiff refers Defendant to Exhibit A (Medical Bills and Records) of Plaintiff’s Initial Disclosures. INTERROGATORY N0. 13: Please describe each and every injury, whether physical, mental or otherwise, you sustained for the ten (10) years prior to the accident which forms the basis of this lawsuit, requiring health care treatment. If any, please name the health care provider(s) who treated you and provide the telephone number(s), business address(es) of such provider(s) and the date(s) of such treatment(s). ANSWER: Plaintiff has not been injured physically, mentally or otherwise ten (10) years prior to the accident. INTERROGATORY N0. 14: Please list each medical doctor or health care provider, including any chiropractors or physical therapists, you have seen for injuries arising out of the incident which forms the basis of this lawsuit, identifying each health care provider, business address, telephone number, the date(s) of treatment, whether x-rays, CT scans and/or MRIs were taken, and any and all hospitalizations as a result of said incident. 7 Electronically Electronically Filed Submitted 6/14/2023 1:54 PM3/20/2023 2:41 PM Hidalgo County District HidalgoClerks County Clerk Accepted Reviewed by: Carlos By: Kimberly Diaz Guerra ANSWER: Plaintiff refers Defendant to Exhibit A (Medical Bills and Records) and Request #5 of Plaintiff’s Initial Disclosures. INTERROGATORY N0. 15: If you are asserting, or will assert, a claim for mental anguish resulting from the incident(s) made the basis of this lawsuit, please state in detail the date or dates on which you claim to have first noticed the foregoing anguish, the specific reason(s) for such mental anguish, any changes resulting from the mental anguish (e.g. sleep habits, body weight, personal relationships, work habits, eating habits, recreational or hobby pastimes or participation) and any diagnosis provided by any health care provider(s) and identify all health care providers consulted regarding mental anguish and any mental health professionals seen or consulted for ten(10) years prior to the incident which gives rise to this lawsuit to the present date. ANSWER: Plaintiff is not claiming mental anguish. INTERROGATORY N0. 16: Please state all things which you claim you can no longer perform or are physically limited from enjoying or doing due to the incident which forms the basis of this lawsuit (including, but not limited to, sports, household chores, sexual activities, work related activities, hobbies or any other activities) which you were previously able to do, perform and/or enjoy, and describe in detail under what circumstances and how often you did, performed, and/or enjoyed the same before the subject accident and after said accident. If you have had to hire or obtain the service of someone, including, but not limited to a relative or friend, to do these activities or assist you in doing these activities an you allege this assistance was necessitated by the accident which forms the basis of this lawsuit, please identify the person(s) so assisting you by providing the name(s), address(es) and telephone number(s). ANSWER: Plaintiff objects to this interrogatory as vague, ambiguous, unduly burdensome, and overly broad in that it calls for a narrative response requiring complete factual details and assertions and seek to narrow Plaintiff’s responses without the benefit of specific questions during direct and/or cross-examination. Subject to and without waiving or limiting any objection. We will supplement when depositions are conducted. INTERROGATORY N0. 17: Please describe all mental and/or physical injuries, disability, disease, abnormality, dysfunction, incapacity, ailments, or pains (whether full or partial, permanent or temporary) which you claim to have suffered as a result of the alleged occurrence made the basis of your lawsuit. ANSWER: Plaintiff objects to this interrogatory as vague, ambiguous, unduly burdensome, and overly broad in that it calls for a narrative response requiring complete factual details and assertions and seek to narrow Plaintiff’s responses without the benefit of specific questions during direct and/or cross-examination. Subject to and without waiving or limiting any objection. We will supplement when depositions are conducted. 8 Electronically Electronically Filed Submitted 6/14/2023 1:54 PM3/20/2023 2:41 PM Hidalgo County District HidalgoClerks County Clerk Accepted Reviewed by: Carlos By: Kimberly Diaz Guerra INTERROGATORY N0. 18: If you are claiming any lost wages or income or loss of earning capacity as a result of the incident made the basis of this suit, please state the following: a) The names and addresses of all employers for whom you have worked dating from ten (10) years prior to the incident made the basis of your suit to the present; b) The inclusive dates between which you were unable to work as a result of the alleged occurrence; c) The total amount of earnings which you allegedly lost as a result of your absence; d) The name, address, and telephone number of each representative from the Texas Employment Commission with whom you have spoken to in applying and/or receiving unemployment benefits; and e) The name, address, and telephone number of each person or business for whom you have either applied for employment or attempted to secure gainful employment since the date of the incident made the basis of this suit, along with a description of the nature of the work for which said application or attempt was made. (Indicate the names of any such persons or businesses to whom written application forms were prepared by using all capital letters when listing their names.) ANSWER: Plaintiff is not claiming lost wages. INTERROGATORY N0. 19: Please state the name and address of all pharmacies where prescriptions were filled or medications were purchased or obtained for MARIA A. QUIROZ DE LEON. ANSWER: Plaintiff has not filled any prescriptions or medications. INTERROGATORY N0. 20: Please state whether any funds have been expended by Medicare or Medicaid or any other government agency or program on your behalf in connection with any of the injuries alleged in this cause of action. If so, please identify such amounts by stating the name of the medical providers, the approximate date(s) of service, the amount of any bill(s) or statement(s) submitted for payment, and the amount(s) paid by Medicare or Medicaid. ANSWER: Plaintiff is not a recipient of Medicaid or Medicare. INTERROGATORY N0. 21: Please identify any and all claims or lawsuits made by you or on your behalf (including any claims against any person or entity, any claims for injuries or damages, any claims filed with an insurance company, or workers’ compensation claims); and please identify the date and nature of each such claim or suit, the name of each expert witness testifying on your behalf, the name of each opposing party and their attorney, the county in which suit was filed, and the disposition and/or amount received in each claim or suit. ANSWER: Plaintiff has not been a party to any other claim. 9 Electronically Electronically Filed Submitted 6/14/2023 1:54 PM3/20/2023 2:41 PM Hidalgo County District HidalgoClerks County Clerk Accepted Reviewed by: Carlos By: Kimberly Diaz Guerra INTERROGATORY N0. 22: Have you ever been convicted of any felonies or crimes of moral turpitude? If you have, please state the following: a) the date when the crime occurred; b) a brief summary of the crime; c) the disposition of the case; and d) the name of the attorney, if any, that represented you in that incident. ANSWER: Plaintiff has never been convicted of any felonies or crimes of moral turpitude. INTERROGATORY N0. 23: Please state whether there are any child support liens against you. If so, please give the exact amount of the arrearage. ANSWER: Plaintiff has no child support liens against them. 10 Electronically Electronically Filed Submitted 6/14/2023 1:54 PM3/20/2023 2:41 PM Hidalgo County District HidalgoClerks County Clerk Accepted Reviewed by: Carlos By: Kimberly Diaz Guerra VERIFICATION STATE OF TEXAS § § COUNTY OF HIDALGO § BEFORE ME, the undersigned authority, personally appeared Maria Aurelia uiroz De Leon, Who stated, upon oath, that the statements made in the foregoing instrument are Within his personal knowledge and are tme and correct. «k m N ~; ???VA‘ [WWW j OK 62 Maria Aurelia Quiroz De Leon SUBSCRIBED AND SWORN T0 BEFORE ME ‘Y‘M/H/flvfl Wk {Jim \€,L€{fl on mw y"; ‘ (fl; 7J, Wy § A.) ,by Notary WW Vkublic State 0f Tfias ‘(p LEA RAM‘REI Nth'ary‘D'I131349197 (QR m; @‘r vv Exmres My Commissfion "" yJanual'Y 1°» 7' 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. Envelope ID: 76606103 Filing Code Description: Memorandum Filing Description: AGREED ORDER GRANTING DEFENDANT BLANCA M. RAMIREZ PEREZ MOTION TO CONSOLIDATE Status as of 6/16/2023 9:28 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status William RGarza wgarza@pgtlawfirm.com 6/14/2023 1:54:37 PM SENT Mark Guerra mguerra@mukerjilaw.com 6/14/2023 1:54:37 PM SENT J.R. Ramirez litigation@lawofficeofjrramirez.law 6/14/2023 1:54:37 PM SENT Sam Mukerji litigation@mukerjilaw.com 6/14/2023 1:54:37 PM SENT Associated Case Party: Maria Quiroz De Leon Name BarNumber Email TimestampSubmitted Status Frank Sabo, Jr. fsabo@guerrasabo.com 6/14/2023 1:54:37 PM SENT Associated Case Party: BlancaRamirezPerez Name BarNumber Email TimestampSubmitted Status CESAR CHAPA CRASHLAWFIRM@GMAIL.COM 6/14/2023 1:54:37 PM SENT MICHAEL JAMES MAIL@JAMESCHAPALAW.COM 6/14/2023 1:54:37 PM ERROR JAMES CHAPA MAIL@JAMESCHAPALAW.COM 6/14/2023 1:54:37 PM ERROR