On August 11, 2020 a
Party Discovery
was filed
involving a dispute between
Turner, Charla,
Turner, Thomas,
and
Allstate Insurance Company,
Esquivel, Juan,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
1/13/2021 1:39 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Veronica Vaughn DEPUTY
NO. DC-20-1 1037
THOMAS TURNER AND § IN THE DISTRICT COURT
CHARLA TURNER, §
PLAINTIFFS, §
§
VS. § DALLAS COUNTY, TEXAS
§
JUAN ESQUIVEL AND ALLSTATE §
INSURANCE COMPANY, §
DEFENDANTS. § 191“ JUDICIAL DISTRICT
DEFENDANT JUAN ESQUIVEL’S CERTIFICATE OF WRITTEN DISCOVERY
The undersigned certies that on this 13th day of January, 202 1, Defendant Juan Esquivel’s
Second Supplemental Response to Plaintiffs’ Request for Disclosure and Designation of Experts
was served on all counsel of record. The undersigned further certies that an exact copy of the
materials listed herein will be retained by the undersigned counsel While the case is pending and
for one year thereafter.
Respectfully submitted,
%)///%_
Chad Kimble, State Bar No. 24007483
Kyle Smith, State Bar No. 241025 12
D. Brent Beasley, State Bar NO. 24082669
LAW OFFICE OF CHAD KIMBLE, P.C.
1204 S. White Chapel Blvd.
Southlake, Texas 76092
eservice@chadkimblelaw.com
817.766.7488
817.423.7492 fax
ATTORNEY FOR DEFENDANT
JUAN ESQUIVEL
CERTIFICATE OF SERVICE
The undersigned certies that on the 13th day of January, 2021 , a true copy ofthe foregoing
has been served on all parties in accordance with Rule 21a, Texas Rules of Civil Procedure.
%/%_
Kyle Smith
CERTIFICATE 0F WRITTEN DISCOVERY Page 1 0f l
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.
Chad Kimble
Bar No. 24007483
eservice@chadkimblelaw.com
Envelope ID: 49669688
Status as of 1/14/2021 2:38 PM CST
Associated Case Party: ALLSTATE INSURANCE COMPANY
Name BarNumber Email TimestampSubmitted Status
JUNE WILLIAMSON jbwlegal23@gmail.com 1/13/2021 1:39:41 PM SENT
Brad Westmoreland brad@westmorelandlawfirm.com 1/1 3/2021 1:39:41 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Patricia Morgan morgan@kelleyfirm.com 1/13/2021 1:39:41 PM SENT
Kyle Smith eservice@chadkimblelaw.com 1/13/2021 1:39:41 PM SENT
Kevin Lee lee@kelleyfirm.com 1/13/2021 1:39:41 PM SENT
ISRAEL GARICAPEREZ Perez@kelleyfirm.com 1/13/2021 1:39:41 PM SENT
Ayanna Whitebear whitebear@kelleyfirm.com 1/13/2021 1:39:41 PM SENT
Dagmawi Getachew getachew@kelleyfirm.com 1/13/2021 1:39:41 PM SENT
Siboney Rivera rivera@kelleyfirm.com 1/1 3/2021 1:39:41 PM SENT
Document Filed Date
January 13, 2021
Case Filing Date
August 11, 2020
Category
MOTOR VEHICLE ACCIDENT
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FILED 1/13/2021 1:39 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Veronica Vaughn DEPUTY NO. DC-20-1 1037 THOMAS TURNER AND § IN THE DISTRICT COURT CHARLA TURNER, § PLAINTIFFS, § § VS. § DALLAS COUNTY, TEXAS § JUAN ESQUIVEL AND ALLSTATE § INSURANCE COMPANY, § DEFENDANTS. § 191“ JUDICIAL DISTRICT DEFENDANT JUAN ESQUIVEL’S CERTIFICATE OF WRITTEN DISCOVERY The undersigned certies that on this 13th day of January, 202 1, Defendant Juan Esquivel’s Second Supplemental Response to Plaintiffs’ Request for Disclosure and Designation of Experts was served on all counsel of record. The undersigned further certies that an exact copy of the materials listed herein will be retained by the undersigned counsel While the case is pending and for one year thereafter. Respectfully submitted, %)///%_ Chad Kimble, State Bar No. 24007483 Kyle Smith, State Bar No. 241025 12 D. Brent Beasley, State Bar NO. 24082669 LAW OFFICE OF CHAD KIMBLE, P.C. 1204 S. White Chapel Blvd. Southlake, Texas 76092 eservice@chadkimblelaw.com 817.766.7488 817.423.7492 fax ATTORNEY FOR DEFENDANT JUAN ESQUIVEL CERTIFICATE OF SERVICE The undersigned certies that on the 13th day of January, 2021 , a true copy ofthe foregoing has been served on all parties in accordance with Rule 21a, Texas Rules of Civil Procedure. %/%_ Kyle Smith CERTIFICATE 0F WRITTEN DISCOVERY Page 1 0f l 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. Chad Kimble Bar No. 24007483 eservice@chadkimblelaw.com Envelope ID: 49669688 Status as of 1/14/2021 2:38 PM CST Associated Case Party: ALLSTATE INSURANCE COMPANY Name BarNumber Email TimestampSubmitted Status JUNE WILLIAMSON jbwlegal23@gmail.com 1/13/2021 1:39:41 PM SENT Brad Westmoreland brad@westmorelandlawfirm.com 1/1 3/2021 1:39:41 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Patricia Morgan morgan@kelleyfirm.com 1/13/2021 1:39:41 PM SENT Kyle Smith eservice@chadkimblelaw.com 1/13/2021 1:39:41 PM SENT Kevin Lee lee@kelleyfirm.com 1/13/2021 1:39:41 PM SENT ISRAEL GARICAPEREZ Perez@kelleyfirm.com 1/13/2021 1:39:41 PM SENT Ayanna Whitebear whitebear@kelleyfirm.com 1/13/2021 1:39:41 PM SENT Dagmawi Getachew getachew@kelleyfirm.com 1/13/2021 1:39:41 PM SENT Siboney Rivera rivera@kelleyfirm.com 1/1 3/2021 1:39:41 PM SENT