Motion to Be Relieved or Withdraw as Counsel in WELDON CONTRACTORS, LLC D/B/A WELDON CONTRACTORS vs. CZOT / MGS LLCet al| Trellis.Law

On July 26, 2021 a Party Discovery was filed involving a dispute between Weldon Contractors, Llc D B A Weldon Contractors, and Czot Mgs Llc, Hartford Fire Insurance Company, for OTHER CONTRACT in the District Court of Dallas County.

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FILED
10/20/2022 4:19 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS 00., TEXAS
Harper Ream DEPUTY

CAUSE NUMBER: DC-21-09687
WELDON CONTRACTORS, LLC DIBIA § IN THE DISTRICT COURT
WELDON CONTRACTORS, '
§
Plaintiff, § 9ST" JUDICIAL DISTRICT
§
VS. § DALLAS COUNTY, TEXAS

CZOTIMGS LLC AND HARTFORD FIRE
INSURANCE COMPANY,
Defendants.

- AFFIDAVIT OF SERVICE

Came to my hand on October l4, 2022 at 5:55 PM,
Delivered at: EMA Engineering, 328 S. Broadway Ave, Tyler, Texas 75702
within the county of Smith at 10:58 AM, on Monday, October 17, 2022
by hand delivery to the within named
EMA Engineering
By delivery to Jimie Taylor, Its CFO and Custodian ol' Records

a true SERVICE OF SUBPOENA REQUIRING APPEARANCE AT DEPOSITION
copy of the NOTICE OF
AND PRODUCTION 0F DOCUMENTS TO THE CUSTODIAN 0F RECORDS FOR EMA ENGINEERING;
SUBPOENA REQUIRING APPEARANCE AT DEPOSITION AND PRODUCTION 0F DOCUMENTS T0
THE CUSTODIAN OF RECORDS FOR EMA ENGINEERING; and EXHIBITS A and B, with the date of the
delivery endorsed themn.
I tendered the witness $11.00

BEFORE ME, the undersigned authority, on this day personally appeared Marcus .l Collins, who aﬂer being duly sworn on oath states:
"My name is Marcus J Collins. I am a person over eighteen (18) years of age and I am competent to make this afﬁdavit. I am a
resident of the State of Texas. I have personal knowledge of the facts and statements contained in this afﬁdavit and aver that each is
true and correct. I arn not a party to this suit nor related or afﬁliated with any herein, and have no interest in the outcome of the suit. I
have n'ever been convicted of a felony or of a misdemeanor involving moral turpitude. I am familiar with the Texas Rules of Civil
Procedure, and the Texas Practice and Remedies Codes as they apply to service of process. l am approved by the Judicial Branch
Certiﬁcation Commission (JBCC) of Texas under Rule 103 and 50l.2 of the TRCP to deliver citations and other notices from any
District, County and Justice Courts in and for the State of Texas."

Reference 2870456

Marcus 3 Collins
0f: Smith Co nty, Texas

By:
Process Server P -2l47, Expires 07/31/2024
Subscribed and Sworn to by Marcus .l Collins, Before Me, the undersigned authority, on this LES day of
October. 2022.
Michael .I Collins
sf’ﬁﬁ MyComrmuonE res
04/22/2024
IDNO 6508879 otary Public In at! tate o
Cause No. DC-21-09687

WELDON CONTRACTORS, LLC D/B/A § IN THE DISTRICT COURT OF
WELDON CONTRACTORS §
§
Plaintiff, §
v. §
§ 9ST" JUDICIAL DISTRICT
CZOT/MGS LLC AND HARTFORD FIRE §
INSURANCE COMPANY §
§
Defendants. § DALLAS COUNTY

NOTICE OF SERVICE OF SUBPOENA REQUIRING APPEARANCE AT
DEPOSITION AND PRODUCTION 0F DOCUMENTS TO THE CUSTODIAN OF
RECORDS FOR EMA ENGINEERING

TO: Custodian of Records for
EMA Engineering
328 S. Broadway Ave.
Tyler, Texas 75702

PLEASE TAKE NOTICE that pursuant to the TEXAS RULES 0F CIVIL PROCEDURE 176

and 205, counsel for Weldon Contractors, LLC d/b/a Weldon Contractors ("Weldon”)

intends to serve the enclosed subpoena commanding the custodian of records for the non-

party EMA Engineering (”EMA”) in the above-styled action to attend a deposition on

written questions in Exhibit "A" and produce and permit for inspection and copying of

designated documents or tangible things in EMA's possession, custody, or control

described in Exhibit “B" attached to the Subpoena.

The deposition on written questions and production of documents will take place

on the 16“ day of November 2022 at 10:00 A.M. at the offices of EMA Engineering. You

Nance or SERVICE or SuaPoENA REQUIRING APPEARANCE AT Derosmou AND PRODUCTION or DOCUMENTS Pace 1
To THE CUSTODIAN or RECORDS FOR EMA ENGINEERING
may also contact Todd Nectoux at tnectouxrwtl’andw.com for instructions on how to

produce the documents electronically. A courtesy copy of the proposed Subpoena has

been attached to this notice for your review. Pursuant to Rules 200.] and 205.2 of the

TEXAS RULES OF CIVIL PROCEDURE, this Notice is being served on the custodian of records

for EMA at least twenty days before service of the subpoena compelling deposition on

written question and production of documents.

The deposition by written question attached may be used in evidence upon the

trial of the above-styled and numbered cause pending in the above-named court. Notice

is further given that request is hereby made as authorized through this case and tribunal,

to the officer authorized to issue a Subpoena and cause it to be served on the witness to

produce the documents requested in the document attached as Exhibit B to the Subpoena

for EMA.

Respectfully submitted,

THOMAS, FELDMAN & WILSHUSEN, LLJ’.

By: Isl Todd R. Nectoux
TODD R. NECTOUX
State Bar No. 24032899
—
Email: tnectoux@tfandw.com
MICHAEL T. PIPKIN
State Bar No. 24122988
—
Email: myipkin®ttandmcom
Merit Tower
12222 Merit Drive, Suite 1450
Dallas, Texas 75251 -3297
Telephone: (214) 369-3008
Fax: (214)369-8393
None: or SERVICE or Suaroem REQUIRING APPEARANCE AT DEPOSITION AND Paooumox or Docuuems Pace 2
To me QJS‘I'ODIAN or RECORDS so: EMA ENGINEERING
COUNSEL FOR PLAINTIFF WELDON
CONTRACTORS, LLC D/B/A WELDON
CONTRACTORS

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above and foregoing document
has been forwarded to the following parties of record on the 14th day of October 2022 in
accordance with Rule 21a of the TEXAS RULES OF CIVIL PROCEDURE.

Ig/ Todd R. Nectoux
Todd R. Nectoux

Via E-Mail: Attorney For Defendants
camwarmzleakelamum: CZOT/MGS LLC AND HARTFORD FIRE
Ionathan C. Conway INSURANCE COMPANY
State Bar No. 24092281

WT SKIP LEAKE PC
350 Westpark Way, Suite 205
Euless, Texas 76040
(817) 460-7711

None: or SERVICE or SUBI’OENA REQUIRING APPEARANCE AT DEPOSITION AND Pkonucnox or DOCUMENTS PAGE 3
TOTHE CUSTODIAN or RECORDS FOR EMA Eucmteamc
Cause No. DC-21-09687

WELDON CONTRACTORS, LLC D/B/A § IN THE DISTRICT COURT OF
WELDON CONTRACTORS §
§
Plaintiff, §
V- §
§ 951'" JUDICIAL DISTRICT
CZOT/MGS LLC AND HARTFORD FIRE §
INSURANCE COMPANY §
§
Defendants. § DALLAS COUNTY

THE STATE OF TEXAS

SUBPOENA REQUIRING APPEARANCE AT DEPOSITION AND PRODUCTION
OF DOCUMENTS TO THE CU STODIAN OF RECORD
FOR EMA ENGINEERING

Greetings to the sheriff, constable, or any other person authorized to serve and
execute subpoenas as provided in TEXAS RULE OF CIVIL PROCEDURE 176.5. You are
commanded to subpoena and summon the following witness:

Custodian of Records for
EMA Engineering
328 S. Broadway Ave.
Tyler, Texas 75702

YOU ARE COMMANDED to appear before a Notary Public or an officer of the
State of Texas and give testimony at a deposition in the above-styled case, on the 16'“ day
of November 2022 at 10 AM. at the ofﬁces of EMA Engineering, or at such other time or
place that may be mutually agreed upon.

YOU ARE FURTHER COMMANDED, pursuant to Rule 199.2(b)(l), TEX. R. CIV.
P., to testify on behalf of Engineering, answer under oath the questions set forth in Exhibit
and produce and permit for inspection and copying of designated documents or
tangible things in your possession, custody, or control identiﬁed in the Subpoena
attached hereto as Exhibit ”B."

SUBPOENA REQUIRING APPEARANCE AT DeposmON AND PRouucrION 0F Documsms PAGE 4
To THE CUSTODIAN or RECORDS or EMA ENGINEERING
Your attention is directed to the penalties set forth in TEXAS RULE OF CIVIL
PROCEDURE 215 for failure to comply with the discovery requested.

Alternatively, please contact Todd Nectoux at tnectoux@tfandw.com for
instructions on how to electronically produce all documents along with completed
Exhibits ”A" and "B” or in hard copy to Thomas, Feldman 8c Wilshusen, L.L.P., Merit
Tower, 12222 Merit Drive, Suite 1450, Dallas, Texas, 75251.

You are advised that under TEXAS RULE 0F CIVIL PROCEDURE 176, a person served
with a discovery subpoena has certain rights and obligations. Rule 176.6 provides:

(a) Compliance required. Except as provided in this subdivision, a person
served with a subpoena must comply with the command stated therein unless discharged
by the court or by the party summoning such witness. A person commanded to appear
and give testimony must remain at the place of deposition, hearing, or trial from day to
day until discharged by the court or by the party summoning the witness.

(b) Organizations. If a subpoena commanding testimony is directed to a
corporation, partnership, association, governmental agency, or other organization, and
the matters on which examination is requested are described with reasonable
particularity, the organization must designate one or more persons to testify on its behalf
as to matters known or reasonably available to the organization.

(c) Production of documents or tangible things. A person commanded to
produce documents or tangible things need not appear in person at the time and place of
production unless the person is also commanded to attend and give testimony, either in
the same subpoena or a separate one. A person must produce documents as they are kept
in the usual course of business or must organize and label them to corresp0nd with the
categories in the demand. A person may withhold material or information claimed to be
privileged but must comply with Rule 193.3. A nonparty‘s production of a document
authenticates the document for use against the n0nparty to the same extent as a party’s
production of a document is authenticated for use against the party under Rule 193.7.

(d) ObjectiOns. A person commanded to produce and permit inspection and
copying of designated documents and things may serve on the party requesting issuance
of the subpoena—before the time specified for compliance—written objections to
producing any or all of the designated materials. A person need not comply with the part
of a subpoena to which objection is made as provided in this paragraph unless ordered

Sunposmx REQUIRING APPEARANCE AT DerosmoN AND Pkooucnon or DOCUMENTS PAGE 5
To THE CusrooIAN or Reconosor EMA ENGINEERING
to do 50 by the court. The party requesting the subpoena may move for such an order at
any time after an objection is made.

(e) Protective orders. A person commanded to appear at a deposition, hearing,
or trial, or to produce and permit inspection and copying of designated documents and
things may move for a protective order under Rule 192.6(b)—before the time specified
for compliance-either in the court in which the action is pending or in a district court in
the county where the subpoena was served. The person must serve the motion on all
parties in accordance with Rule 21a. A person need not comply with the part of a
Subpoena from which protection is sought under this paragraph unless ordered to do so
by the court. The party requesting the subpoena may seek such an order at any time after
the motion for protection is ﬁled.

CONTEMPT. FAILURE BY ANY PERSON WITHOUT ADEQUATE EXCUSE TO
--

OBEY A SUBPOENA SERVED UPON THAT PERSON MAY BE DEEMED A
CONTEMPT OF THE COURT FROM WHICH THE SUBPOENA IS ISSUED OR A
DISTRICT COURT IN THE COUNTY IN WHICH THE SUBPOENA IS SERVED,
AND MAY BE PUNISHED BY FINE OR CONFINEMENT, OR BOTH. TEXAS RULE
OF CIVIL PROCEDURE 176.8 (A).

ISSEUD ON OCTOBER 14, 2022

This subpoena was issued at the request of Plaintiff Weldon Contractors, LLC d/b/a
Weldon Contractors (”Weldon") whose attorneys of record are Todd R. Nectoux and
Michael T. Pipkin, Merit Tower, 12222 Merit Drive, Suite 1450, Dallas, Texas 75251-3297,
Telephone: (214) 369-3008. You may contact Weldon's attorney to arrange another time
and date for the deposition on written questions and production of documents.

Respectfully submitted,

THOMAS, FELDMAN 8: WILSHUSEN, L.L.P.

By: ls/ Todd R. Nectoux
TODD R. NECTOUX
State Bar No. 24032899
—
Email: tnectoux@ttandw.com
MICHAEL T. PIPKIN

Suarosm REQUIRING Art’s/slums AT DerosmoN AND PRODUCTION or DOCUMENTS PAGE 6
ro THE Cusroolm or RECORDS or EMA ENGINEERING
State Bar No. 24122988
Email: mgiykinai’tfamlw.com
Merit Tower
12222 Merit Drive, Suite 1450
Dallas, Texas 75251-3297
Telephone: (214) 369-3008
Fax: (214) 369-8393

COUNSEL FOR PLAINTIFF VVELDON
CONTRACTORS, LLC D/B/A WELDON
CONTRACTORS

MEMORANDUM OF ACCEPTANCE

I accepted service of this subpoena and a witness fee of $11 on behalf of EMA
Engineering on the _
day of 2022.

Signature

Printed Name

Title

OFFICER’S RETURN

Came to hand this day of 2022 and executed this the
clay of 2022 in the following manner: By delivering a true copy
hereof and a witness fee of $11.00 to Custodian of Records for EMA Engineering, located
at 328 S. Broadway Ave., Tyler, Texas 75702.

Returned this day of 2022.

PROCESS SERVER

SUBPOENA REQUIRING APPEARANCE AT DEPOSITION AND PRODUCTION or Documsms PAGE 7
TO THE CusroomN or RECORDS OF EMA ENGINEERING
EXHIBIT ”A”
DIRECT QUESTIONS TO EMA ENGINEERING

gggrggian of Records For: EMA Engineering.

Records Pertaining To: The development and construction of Francisco Medrano Middle
School, located at 9815 Brockbank Drive in Dallas, Texas, and Ann Richards Middle
School, located at 3831 N. Prairie Creek Road in Dallas, Texas. (the ”Project”).

1. Please state your full name, occupation, ofﬁcial title, and business address:

Answer:

2. Are you the custodian of records for EMA Engineering ("EMA")?

Answer:

3. If you are the custodian of records for EMA, do you have in your possession,
custody or control, or have access to, any of the documents described in Exhibit
"B"?

Answer:

4. Please state what search has been made by you or others at your direction for
the documents listed in Exhibit ”B.”

Answer:

5. Were the documents listed in question no. 3 made and kept in the regular course
of daily business activities of EMA and did you maintain the records as part of
your ofﬁcial duties as the custodian of records for EMA?

Answer:

SUBPOENA REQUIRING APPEARANCE AT Deposmou AND PRODUCUONOFDOCUMEN‘I‘S Places
To THE Cusrooum or Rroonos or EMA ENGINEERING
6. Were the entries made in the records at or near the time of the acts or events
reﬂected in the business records? If not, identify which entries were not made
at or near the time of the acts or events reflected in the business records.

Answer:

7. Were the entries made by a person(s) whose duty it is to make such entries or
by someone under their direct supervision and control? If not, identify which
entries were not made by the person(s) whose duty it is to make such entries.

Answer:

8. Did the person(s) who made the enh'ies have personal knowledge of the acts or
events contained therein or obtain the information from a person(s) having such
personal knowledge? Please identify which entries, if any, were not made by a
person(s) with personal knowledge.

Answer:

9. Are the copies which have been marked and attached to this depositiou true and
correct copies of the original records for you and/or of EMA?

Answer:

By:

Name:

Title:

SUIPOBNA RwunuNc AmARANCE A'r bamsmoumnPnonucnon osDocumaNTs PAGE9
Tome Cusmnw: or RECORDS or EMA ENGINEERING
VERIFICATION

STATE OF 5
COUNTY OF 8

Before me, the undersigned notary, on this day personally appeared
the affiant, whose identity is known to me. After I administered an
oath, affiant testiﬁed as follows:

. I am capable of making this verification.
“My name is
I have read EMA Engineering’s responses to Direct Questions to EMA Engineering. The
facts stated in it are within my personal knowledge and are true and correct.”

Sworn to and subscribed before me by on . 2022.

Notary Public, in and for the State of
My commission expires:

SUBPOENA REQUIRING APPEARANCE A'l' Derosmonmnl’sonvcnon cpl-30cm PAGE 10
TOTHE Cusroom or Reconosos EMA ENGINEERING
EXHIBIT ”B"
DUCES TECUM
I. DEFINITIONS

1. The term ”document” or ”documents” is intended to be comprehensive and to
include, without limitation:

(a) Any data or information that exists in electronic, magnetic, or native form.

(b) Any agreement, personnel record, personnel ﬁle or portion thereof, letter,
report, record, list, summary, memorandum, note, study, chart, analysis,
graph, data sheet, statistical record, notebook, diary, drawing, blueprint,
diagram, photograph, form, book, telegram, publication, newspaper
clipping, advertisement, manager’s report, management report, activity
report, incident report, and all other writings of any kind or character
whatsoever, whether or not stored electronically, including drafts and
copies of the foregoing, as well as all reproductions or other facsimiles
thereof by whatever means made, and all copies which are not identical by
reason of shorthand or longhand written notes, initials, identification
marks, or other modiﬁcations.

agreement, any writing or document with respect to a contract, proposed
contract or an agreement; of any type or nature, wherever located, or owned
or in the custody of whomever, together with each and every other
document, memorandum, record, or data compilation, by whatever
method compiled and however made or stored with regard to same, or
arising Out of same, or related to same, respectively, without limitation.

(d) Any data or information that is, has been, or is suitable to be kept, located
or stored in, with or in the vicinity of a computer, computer records, or of
computer-related instrumentalities, whether kept, located or stored on
print-out paper or other paper, or on ﬂoppy discs, computer discs, CD5,
diskettes, flash drives, photos, text messages, cloud-based storage, on the
software, on or in the memory banks of the computer itself, or elsewhere,
including but not limited to, e-mail, e-mail files, text files, image files,
databases, Internet history ﬁles, calendars, and schedules, or otherwise
electronically stored information.

Simon“ REQUIRING APPEARANCE AT Derosrrtou AND Pnooucnou or ﬁocumams PAGE 11
To me Cusmouw or RECORDS or EMA ENGINEERING
(e) Any data, representations, pictures, voice recordings, pictorial recordings
of any kind whatsoever recorded on magnetic tape, cellulose film, or any
other form of electronic recording including, but not necessarily limited to,
tape recordings, videotape recordings, motion picture films, still
photographs or other types of visual and sound recordings.

2. The term ”person” or ”persons" shall include natural persons, individuals,
companies, ﬁrms, proprietorships, partnerships, corporations, associations, trusts,
banking associations, public corporations, municipal corporations, state
governments, local governments, governmental agencies, political subdivisions,
and any other legal, business, professional, or public entity.

3. ”Communication" or "communications” as that term is used herein shall include,
but is not limited to, all correspondence, letters, emails, text messages,
memoranda, faxes, emails, conversation by telephone calls, records of
conversations, either in writing or upon any mechanical, electrical recording
device and oral conversation.

4. The terms “you” ”your” and ”EMA" means EMA Engineering and its affiliates,
underwriters, agents, employees, officers, directors, shareholders, partners,
corporate parents, representatives, subsidiaries and affiliates.

5. The term "Weldon” means Plaintiff Weldon Contractors, LLC d/b/a Weldon
Contractors.

6. The term "Defendants" means separately, each Defendant CZOT/MGS LLC
(”CZOT") and Hartford Fire Insurance Company ("Hartford”).

7. The terms ”you" “your" and "Endur" means Endur Contractors, LLC and its
afﬁliates, underwriters, agents, employees, officers, directors, shareholders,
partners, corporate parents, representatives, subsidiaries and affiliates.

8. 'Ihe term "Property" shall mean the real estate and improvements thereon located
at 9815 Brockbank Drive in Dallas, Texas and 3831 N. Prairie Creek Road in Dallas,
Texas.

9. The term "Project" shall mean the development, construction, financing, and
operation management of the project or projects known as The Francisco Medrano
Middle School and Ann Richards Middle School project, comprised of renovations

Susroemi REQUIRING APPEARANCE A1" Deposrnou AND Pkooucnon orDocuunN'Is Pace 12
to ms CusromAN or RECORDS or EMA ENGINEERING
to two school buildings building, located at 9815 Brockbank Drive in Dallas, Texas
and 3831 N. Prairie Creek Road in Dallas, Texas, respectively.

10. The term “Owner" shall mean the owner of the Property, Dallas Independent
School District.

11. The use of ”an " is conjunctive and disjunctive, so that it includes "and," "or,”
and ”and/or.”

12. Any undefined term shall have its common meaning.

II. DO U E TE

Please produce the following:

1. All documents reﬂecting or evidencing all written or oral contracts and
agreements between EMA and the Owner relating to the Project including any
attachments, amendments, supplements, and change orders to any such contract,
and any drafts and non-identical copies.

All documents reflecting or evidencing all written or oral contracts and
agreements between EMA and CZOT relating to the Project including any
attachments, amendments, supplements, and change orders to any such contract,
and any drafts and non-identical copies.

All documents prepared by EMA for the Project.

All documents provided to EMA for the Project.

All documents reviewed by EMA for the Project.

All versions of drawings related to the Project.

All versions of plans relating to the Project.

All versions of Specifications relating to the Project.

All versions of the project manual relating to the Project.

Susroam REQUIRING APPEARANCE AT Derosmou AND Pnooucnon osDocwsm's Pace 13
Ton-Is Cummm or RECORDS or EMA ENGINEERING
10. All models, maps, diagrams, drawings, sketches, graphs, charts, pictures, reports,
studies, graphic representations, or visual aids relating to the Project.

11. All request for information and other similar design information requests
regarding the Project.

12. All reports and laboratory test results relating to investigations and inspections
relating to the Project, including but not limited to, green tags and City
investigations and inspections.

13. All documents produced relating to Weldon’s work on the Project.

14. All documents produced relating to Endur’s work on the Project.

15. All documents produced relating to heat pump piping on the Project.

16. All documents relating to value engineering efforts related to the Project.

l7. All inspection reports relating to the Project.

18. All inspection reports relating to Weldon’s work on the Project.

19. All inspection reports relating to Endur’s work on the Project.

20. All inspection reports relating to the heat pump piping on the Project.

21. All pictures, videos, or other visual media relating to the Project.

22. All communications regarding the Project.

23. All communications between you and Defendants regarding the Project or
Property.

24. All communications between you and any person or entity regarding the Project
or Property.

25. All communications between you and Endur regarding the Project or Property.

26. All communications between you and the Owner regarding the Project.
SunrosNA REQUIRING APPEARANCE Ar Durosmm AND Pkooucnou or DOCUMENTS PAGE 14
To THE CusroomN or Rscoaos or EMA ENGINEERmc
27. All documents you relied upon relating to the Project.

28. All notices you sent relating to the Project.

29. All punch lists relating to the Project.

30. All daily logs, reports, and diaries relating to the Project.

31. All memoranda, reports, minutes, or records relating to all meetings regarding the
Project, including but not limited to, late-construction meetings, progress
meetings, periodic, or special subcontract meetings and Owner/General
Contractor meetings.

32. All internal memoranda, communications, and personal notes of meetings and
telephone conversations relating to the Project.

33. All schedules, updates, bar charts, CPM diagrams and all related documents
created by or for EMA regarding scheduling of the Project.

34. All schedules, schedule updates, schedule analysis, reports, and documents
regarding the schedule, schedule delays, acceleration, labor inefficiency, or loss of
productivity that pertain to the Project.

35. All written notices, written complaints, or documentation of oral complaints from
or by any party, individual, or entity concerning the quality of the work, labor and
materials provided by Weldon in connection with the Project.

36. All written notices, written complaints, or documentation of oral complaints from
or by any party, individual, or entity concerning the timeliness of the work, labor
and materials provided by Weldon in cannection with the Project.

37. All written notices, written complaints, or documentation of oral complaints from
or by any party, individual, or entity concerning the quality of the work, labor and
materials provided by Endur in connection with the Project.

38. All written notices, written complaints, or documentation of oral complaints from
or by any party, individual, or entity concerning the timeliness of the work, labor
and materials provided by Endur in connection with the Project.

Suaroem. RsomiuNc APPEARANCE Ar Deposmou AND PnooucnON or DOCUMENTS PROS 15
Toms Cusronwq or Rscoms or EMA ENGINEERING

Case Info

Judge

WHITMORE, BRIDGETT Track Judge’s New Case

Case No.

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Document Filed Date

October 20, 2022

Case Filing Date

July 26, 2021

County

Parties

CONWAY, JONATHAN C Attorney for the Defendant
CZOT / MGS LLC Defendant
HARTFORD FIRE INSURANCE COMPANY Defendant
JETER, JUSTIN LEE Attorney for the Defendant
NECTOUX, TODD Attorney for the Plaintiff
WELDON CONTRACTORS, LLC D/B/A WELDON CONTRACTORS Plaintiff
Michael Pipkin Attorneys for Plaintiffs
Sabrina Allen Attorneys for Plaintiffs
Richard Thomas Attorney
Warren Leake Attorneys for Defendants
James Ewing Attorneys for Plaintiffs
Chantesia Hodges Attorneys for Plaintiffs

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Party Discovery: WELDON CONTRACTORS, LLC D/B/A WELDON CONTRACTORS vs. CZOT / MGS LLCet al

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