On May 27, 2020 a
Party Discovery
was filed
involving a dispute between
Rhea, Clendon,
and
Allstate Fire And Casualty Insurance Company,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
10/19/2020 3:19 PM
FELICIA PITRE
DISTRICT CLERK
N0. DC-20-07324 DALLAS CO., TEXAS
Dorothy Strogen DEPUTY
§ IN THE DISTRICT COURT OF
CLENDON RHEA §
§
vs. § DALLAS COUNTY, TEXAS
§
ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY §
§ IN THE 95TH JUDICIAL DISTRICT
NOTICE OF INTENTION
T0 TAKE DEPOSITION BY WRITTEN QUESTIONS
To Plaintiff(s) by and through their attorney(s) of record: CAMILO VALENCIA
To other party/parties by and through their attorney(s) of record:
You will please take notice that twenty (20) days from the service of a copy hereof with attached questions, a deposition
be taken of Custodian of Records for: ALLSTATE INSURANCE COMPANY C/O CT
by written questions will
CORPORATION SYSTEMS before a Notary Public for Compex Legal Services, Inc. 3201 Cherry Ridge Drive, Suite
B207, San Antonio, TX 78230-4825 or its designated agent, which deposition with attached questions 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 under Rules 176 and 200, Texas Rules 0f Civil
Procedure, t0 the officer taking the deposition to issue a subpoena duces tecum and cause it to be served on the Witness to produce
Any and all insurance records stored in any format, including but not limited t0 correspondence, payments, payment
history, policy information, declarations page, complete claim files, records 0f any liens, color photos, and damage repair
estimates, injury records or claim and any other documents contained within any insurance file and/or claim file, pertaining
t0 Clendon Rhea; DOL: 11/09/2019; Claim N0.: 0568174114. And to turn all such records over to the officer authorized to take
this deposition so that photographic reproductions of the same may be made and attached to said deposition.
YOUNG CHRISTIAN JENKINS
SUSAN L. FLORENCE & ASSOCIATES
1201 ELM STREET, SUITE 5050
DALLAS, TX 75270
FAX 214-659-4390
214-659-4300
ATTORNEY FOR DEFENDANT
STATE BAR#: 24034505
W 2: :
hereby certify that a true and correct copy of the foregoing instrument has been forwarded to Counsel of Record by hand
W
I all
delivery, FAX, and/or certified mail, return receipt requested, on this day.
Dated: 10/08/2020
Compex Order N0. TX0030303-005
EMAIL: TEXASCS@COMPEXLEGAL.COM
N0. DC-20-07324
§ IN THE DISTRICT COURT OF
CLENDON RHEA §
§
vs. § DALLAS COUNTY, TEXAS
§
ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY §
§ IN THE 95TH JUDICIAL DISTRICT
DIRECT QUESTIONS TO BE PROPOUNDED TO
THE CUSTODIAN OF RECORDS FOR:
ALLSTATE INSURANCE COMPANY C/O CT CORPORATION SYSTEMS
From 11/09/2019 t0 11/09/2019
1. Please state your full name, occupation and official title.
Answer:
2. Please state by whom you are employed and the business address.
Answer:
3. Did you receive a subpoena for the production 0f records pertaining t0 Clendon Rhea ?
Answer:
4. Are the documents and or things pertaining t0 Clendon Rhea ,
as outlined in the subpoena duces tecum, in your custody or
subj ect t0 your control, supervision or direction?
Answer:
5. Have you provided copies 0f the documents and or things as listed in the subpoena, t0 be attached to this deposition? If not,
Why not?
Answer:
6. If you answered “yes” to question no. 5, are the documents and 0r things Which you have provided true and correct copies 0f
the originals?
Answer:
7. Were such documents and or things kept in the regular course of business of this facility?
Answer:
8. Was it regular course 0f business of this facility for a person With knowledge of the acts, events, conditions, 0r opinion
recorded to make record 0r t0 transmit information thereof t0 be included in such record?
Answer:
Compex Order N0. TX0030303-005
Page 1 of 2
9. Were the entries 0n these records made at 0r shortly after the time 0f the transaction recorded?
Answer:
10. Was the method 0f preparation of these records trustworthy?
Answer:
WITNESS (Custodian 0f Records)
Before me, the undersigned authority, on this day personally appeared
known t0 me to be the person whose name is subscribed to the foregoing instrument in the capacity therein stated, who being first
duly sworn, stated upon his/her oath that the answers to the foregoing questions are true and correct. I further certify that the
records attached hereto are exact duplicates 0f the original records.
SWORN TO AND SUBSCRIBED before me this day 0f ,
20
NOTARY PUBLIC
Compex Order N0. TX0030303-005
Page 2 of 2
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.
Michael Cortez on behalf of YOUNG JENKINS
Bar No. 24034505
michael.cortez@compexlegal.com
Envelope ID: 47316891
Status as of 10/20/2020 3:35 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
CAMILO VALENCIA eService@benabbott.com 10/19/2020 3:19:14 PM SENT
Young Jenkins dallaslegal@allstate.com 10/19/2020 3:19:14 PM SENT
Document Filed Date
October 19, 2020
Case Filing Date
May 27, 2020
Category
MOTOR VEHICLE ACCIDENT
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED 10/19/2020 3:19 PM FELICIA PITRE DISTRICT CLERK N0. DC-20-07324 DALLAS CO., TEXAS Dorothy Strogen DEPUTY § IN THE DISTRICT COURT OF CLENDON RHEA § § vs. § DALLAS COUNTY, TEXAS § ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY § § IN THE 95TH JUDICIAL DISTRICT NOTICE OF INTENTION T0 TAKE DEPOSITION BY WRITTEN QUESTIONS To Plaintiff(s) by and through their attorney(s) of record: CAMILO VALENCIA To other party/parties by and through their attorney(s) of record: You will please take notice that twenty (20) days from the service of a copy hereof with attached questions, a deposition be taken of Custodian of Records for: ALLSTATE INSURANCE COMPANY C/O CT by written questions will CORPORATION SYSTEMS before a Notary Public for Compex Legal Services, Inc. 3201 Cherry Ridge Drive, Suite B207, San Antonio, TX 78230-4825 or its designated agent, which deposition with attached questions 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 under Rules 176 and 200, Texas Rules 0f Civil Procedure, t0 the officer taking the deposition to issue a subpoena duces tecum and cause it to be served on the Witness to produce Any and all insurance records stored in any format, including but not limited t0 correspondence, payments, payment history, policy information, declarations page, complete claim files, records 0f any liens, color photos, and damage repair estimates, injury records or claim and any other documents contained within any insurance file and/or claim file, pertaining t0 Clendon Rhea; DOL: 11/09/2019; Claim N0.: 0568174114. And to turn all such records over to the officer authorized to take this deposition so that photographic reproductions of the same may be made and attached to said deposition. YOUNG CHRISTIAN JENKINS SUSAN L. FLORENCE & ASSOCIATES 1201 ELM STREET, SUITE 5050 DALLAS, TX 75270 FAX 214-659-4390 214-659-4300 ATTORNEY FOR DEFENDANT STATE BAR#: 24034505 W 2: : hereby certify that a true and correct copy of the foregoing instrument has been forwarded to Counsel of Record by hand W I all delivery, FAX, and/or certified mail, return receipt requested, on this day. Dated: 10/08/2020 Compex Order N0. TX0030303-005 EMAIL: TEXASCS@COMPEXLEGAL.COM N0. DC-20-07324 § IN THE DISTRICT COURT OF CLENDON RHEA § § vs. § DALLAS COUNTY, TEXAS § ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY § § IN THE 95TH JUDICIAL DISTRICT DIRECT QUESTIONS TO BE PROPOUNDED TO THE CUSTODIAN OF RECORDS FOR: ALLSTATE INSURANCE COMPANY C/O CT CORPORATION SYSTEMS From 11/09/2019 t0 11/09/2019 1. Please state your full name, occupation and official title. Answer: 2. Please state by whom you are employed and the business address. Answer: 3. Did you receive a subpoena for the production 0f records pertaining t0 Clendon Rhea ? Answer: 4. Are the documents and or things pertaining t0 Clendon Rhea , as outlined in the subpoena duces tecum, in your custody or subj ect t0 your control, supervision or direction? Answer: 5. Have you provided copies 0f the documents and or things as listed in the subpoena, t0 be attached to this deposition? If not, Why not? Answer: 6. If you answered “yes” to question no. 5, are the documents and 0r things Which you have provided true and correct copies 0f the originals? Answer: 7. Were such documents and or things kept in the regular course of business of this facility? Answer: 8. Was it regular course 0f business of this facility for a person With knowledge of the acts, events, conditions, 0r opinion recorded to make record 0r t0 transmit information thereof t0 be included in such record? Answer: Compex Order N0. TX0030303-005 Page 1 of 2 9. Were the entries 0n these records made at 0r shortly after the time 0f the transaction recorded? Answer: 10. Was the method 0f preparation of these records trustworthy? Answer: WITNESS (Custodian 0f Records) Before me, the undersigned authority, on this day personally appeared known t0 me to be the person whose name is subscribed to the foregoing instrument in the capacity therein stated, who being first duly sworn, stated upon his/her oath that the answers to the foregoing questions are true and correct. I further certify that the records attached hereto are exact duplicates 0f the original records. SWORN TO AND SUBSCRIBED before me this day 0f , 20 NOTARY PUBLIC Compex Order N0. TX0030303-005 Page 2 of 2 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. Michael Cortez on behalf of YOUNG JENKINS Bar No. 24034505 michael.cortez@compexlegal.com Envelope ID: 47316891 Status as of 10/20/2020 3:35 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status CAMILO VALENCIA eService@benabbott.com 10/19/2020 3:19:14 PM SENT Young Jenkins dallaslegal@allstate.com 10/19/2020 3:19:14 PM SENT