On January 21, 2022 a
Party Discovery
was filed
involving a dispute between
Diversitas Holdings Llc,
and
Champ Logistics, Llc,
Saenz, Jorge A.,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
Preview
FILE
3/11/2022 3:11 Pl
FELICIA PITR\
DISTRICT CLERI
DALLAS co., TEXA:
Kellie Juricek DEPUT‘
CAUSE NO. DC—22—00951
IN THE DISTRICT COURT
OF
DIVERSITAS HOLDINGS LLC
§§§§§§§
Plaintiff
DALLAS COUNTY, TEXAS
VS.
CHAMP LOGISTICS, LLC and EN Z 95‘“ JUDICIAL COURT
JORGE A. SA EN Z aka JO RG E SA
PLEA OF PRIVILEGE
OF SAID COURT:
TO THE HONORABLE JUDGE
and Defendant CHAMP
Now comes Defendant, JORGE A. SAENZ,
to appear herein, and
n her eto fore served with citation
LOGISTICS LLC, having bee
to the Court as grounds the
refor the following:
files this, their plea of privilege, showing
I.
the institution of such suit,
Def end ant s bot h cla im such privilege, were not at
The
, nor is at the time
of the filing of such
nor at the tim e of the ser vice of pro cess the rein
in which such suit is instituted.
res ide nts of Dal las cou nty , Texas, the county
plea,
11.
rein, the
titu tion of suc h sui t and at the time of service of process the
At the ins
this is, Hidalgo County,
and at the time of filing plea’it
residence of Defendants was,
h tim es the post office address
of their attorney L. Aron Pena, was
Texas, and suc h at suc
Texas 78539.
and is,600 South Closner, Edinburg,
III. ,
in the county of oneis residence, provided by
No exception to exclusive venue
at this time.
law, exists in said cause
tain this plea of
con side red , Defendants prays the court to sus
Wherefore, premises
Texas.
cause be transferred to Hidalgo County,
privilege, and that said
i
t
l
2
ity, on this I I ida y of March, 202 personally
Before me, the undersigned author
ted that he is the main
Defendant in the above-
on oat h sta
appeared Jorge
A. Saenz, who,
and denial
and eve ry stateme , allegation,
the foregoing ple a
mentioned cause and that
thereof are true.
Jorge A. Sae
the
TO BEFORE as notary public on this
E,
UBSCRIBED AND SWORN l.
nlM of rch, 2022, to certify which witness my hand and offic' sea
Ma
flfiaé
|
Wm
I l :iay
I
NORA EUA PEClNA
M, Notary Public
-
2”w%
52°32 tog
3")?“
e" mg
STATE OF TEXAS
Notary ID# 286
My Comm. Exp.
755-2
08-31-2025
Notary Public
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.
Lionel Pena
Bar No. 15739000
jericiii@aol.com
Envelope ID: 62544267
Status as of 3/14/2022 9:35 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
JARED ROUGEAU txcases@replevinlawfirm.com 3/11/2022 3:11 :42 PM SENT
Document Filed Date
March 11, 2022
Case Filing Date
January 21, 2022
Category
CNTR CNSMR COM DEBT
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FILE 3/11/2022 3:11 Pl FELICIA PITR\ DISTRICT CLERI DALLAS co., TEXA: Kellie Juricek DEPUT‘ CAUSE NO. DC—22—00951 IN THE DISTRICT COURT OF DIVERSITAS HOLDINGS LLC §§§§§§§ Plaintiff DALLAS COUNTY, TEXAS VS. CHAMP LOGISTICS, LLC and EN Z 95‘“ JUDICIAL COURT JORGE A. SA EN Z aka JO RG E SA PLEA OF PRIVILEGE OF SAID COURT: TO THE HONORABLE JUDGE and Defendant CHAMP Now comes Defendant, JORGE A. SAENZ, to appear herein, and n her eto fore served with citation LOGISTICS LLC, having bee to the Court as grounds the refor the following: files this, their plea of privilege, showing I. the institution of such suit, Def end ant s bot h cla im such privilege, were not at The , nor is at the time of the filing of such nor at the tim e of the ser vice of pro cess the rein in which such suit is instituted. res ide nts of Dal las cou nty , Texas, the county plea, 11. rein, the titu tion of suc h sui t and at the time of service of process the At the ins this is, Hidalgo County, and at the time of filing plea’it residence of Defendants was, h tim es the post office address of their attorney L. Aron Pena, was Texas, and suc h at suc Texas 78539. and is,600 South Closner, Edinburg, III. , in the county of oneis residence, provided by No exception to exclusive venue at this time. law, exists in said cause tain this plea of con side red , Defendants prays the court to sus Wherefore, premises Texas. cause be transferred to Hidalgo County, privilege, and that said i t l 2 ity, on this I I ida y of March, 202 personally Before me, the undersigned author ted that he is the main Defendant in the above- on oat h sta appeared Jorge A. Saenz, who, and denial and eve ry stateme , allegation, the foregoing ple a mentioned cause and that thereof are true. Jorge A. Sae the TO BEFORE as notary public on this E, UBSCRIBED AND SWORN l. nlM of rch, 2022, to certify which witness my hand and offic' sea Ma flfiaé | Wm I l :iay I NORA EUA PEClNA M, Notary Public - 2”w% 52°32 tog 3")?“ e" mg STATE OF TEXAS Notary ID# 286 My Comm. Exp. 755-2 08-31-2025 Notary Public 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. Lionel Pena Bar No. 15739000 jericiii@aol.com Envelope ID: 62544267 Status as of 3/14/2022 9:35 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status JARED ROUGEAU txcases@replevinlawfirm.com 3/11/2022 3:11 :42 PM SENT