Preview
FILED
12/9/2020 9:26 AM
FELICIA PITR‘E
DISTRICT CLERK
DALLAS 00., TEXAS
No. Dc-20-o7324 Martin Re; es DEPUTY
IN THE DISTRICT COURT OF
CLENDON RHEA Martin Re yes
vs. DALLAS COUNTY, TEXAS
ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY
IN THE 95TH JUDICIAL DISTRICT
OFFICERS 203 CERTIFICATION OF
DEPOSITION UPON WRITTEN QUESTIONS
Records Pertaining To: CLENDON RHEA
Pursuant to Texas Rules of Civil Procedure Rule 203, the undersigned Notary Public in and for the State of Texas
|
do hereby certify that Lettv Maqailanes was duly sworn, and the
a true record of the him/her as witness/custodian of records for Allstate
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deposition transcript is testimony given by
Insurance Company clo CT Corporation Systems.
The charge for preparation of the completed deposition transcript and any copies of exhibits is: $ y
paid for by: YOUNG CHRISTIAN JENKINS, SBN: 24034505, Attorney for Defendant, ALLSTATE FIRE AND
CASUALTY INSURANCE COMPANY
The deposition transcript was submitted to said custodian of records on 11/04/2020 . for examination
and signature, and was returned to the officer on that date, and any changes made by the witness/custodian of
records in the foregoing transcript are attached thereto or incorporated therein, and said witness/custodian of
records returned the transcript on the date of examination; the original transcript, together with copies of all exhibits
'
was delivered by certied mail or hand delivery to:
YOUNG CHRISTIAN JENKINS
SUSAN L. FLORENCE & ASSOCIATES
1201 ELM STREET, SUITE 5050
DALLAS, TX 75270
and a copy of this certificate was delivered by certied mail or hand delivery to all parties pursuant to Texas Rule
of Civil Procedure 21 (a). A copy of this certificate has been filed with the appropriate court in DALLAS County, Texas
GIVEN UNDER MY HAND AND SEAL OF OFFICE ON THIS THE 24TH DAY OF NOVEMBER, 2020.
THIS IS NOT AN INVOICE. \\\“mmm
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Public.
Stateof
Compex Legal Servrces, Inc.
Texas
asst-g" 3201 Cherry Ridge Drive, Suite 3207
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San Antonio, TX 78230—4825
-
(210) 646-6424 Fax (210) 599-7621
Cc:
BEN ABBOTT & ASSOCIATES, Attorney For Plaintiff
Order No. TX0030303-001
EMAIL: TexasCS@compexlegal.com
ITIN B AT TESTIYO PODC ME NS
The State of Texas, County of Dallas
To any Sheriff or Constable of the State of Texas or other person authorized to serve subpoenas under RULE 176
0F T.R.C.P. GREETINGS YOU ARE HEREBY COMAMNDED TO SUBPOENA AND SUMMON THE
— —
FOLLOWING WITNESS(ES).' Custodian of Insurance Records for:
ALLSTATE INSURANCE COMPANY C/O CT CORPORATION SYSTEMS
to be and appear before a Notary Public of my designation for Compex Legal Services, lnc., 3201 Cherry Ridge,
Suite B207, San Antonio, TX 78230 or its designated agent, on the forthwith day of Instanter 2020 at the ofce of
the custodian and there under oath to make answers of certain written questions to be propounded to the witness and
to bring and produce for inspection and photocopying a true and correct copy of Any and all insurance records
stored in any format, including but not limited to correspondence, payments, payment history, policy
information, declarations page, complete claim files, records of any liens, color photos, and damage repair
estimates, injury records or claim and any other documents contained within any insurance le and/or claim
file, pertaining to Clendon Rhea; DOL: 11/05/2016; Claim No.: 0438515355., and at any and all times
whatsoever, then and there to give evidence at the instance of the Defendant, ALLSTATE FIRE AND CASUALTY
INSURANCE COMPANY represented by YOUNG CHRISTIAN JENKINS, in that certain Cause No. DC—20-
07324, gending on the docket in the IN THE 95THJUDICIAL DISTRICT at DALLAS County. This Subpoena is I
issued under and by virtue of Rule 200 and Notice ofDeposition Upon Written Questions on le with the above
named court, styled
CLENDON RHEA
VS.
ALLSTATE FIRE AND CASUALTY INSURANCE COWANY
and there remain from day to day and time to time until discharged according to law. Pursuant to 176.8
Enforcement of Subpoena. (a) Contempt. Failure by any person without adequate excuse to obey a subpoena
served upon that person may be deemed a contempt ofthe court om which the subpoena is issued or a district court
in the county in which the subpoena is served, and may be punished by ne or connement, or both.
Pursuant to HIPAA§I64.512(e); RULES 176 AND 200, TEXAS RULES 0F CIVIL PROCEDURE this
subpoena is issued in accordance with and by virtue of a notice duly served and on le with the above named court,
and falls under exception to condentially, RULE 509(c)(4), TEXAS RULES OF EVIDENCE, HIPAA
Verication attached and incorporated illy herein.
Order No. TX0030303-001
Page 1 of 1
Order Number: TX0030303—001 * TXO 0 3 0 3 O 3 - 0 0 1 *
WITNESS MY HAND, This 08th day of October, 2020
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Notary Public for the State of Texas
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"Imam
OFFICER'S RETURN
Came to hand this 08 DAY OF October, 2020 at 09:00 A.M. and executed this by delivering same to the within named
witness, all fees have been tendered in accordance with the T.R C.P.
Service by: X Hand Delivery
Certied Mail
Electronic
Witness Signature of Receipt and »
Officer’s Signature
Acceptance of Subpoena
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: 48770652
Status as of 12/9/2020 5:15 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
CAMILO VALENCIA eService@benabbott.com 12/9/2020 9:26:32 AM SENT
Young Jenkins dallaslegal@allstate.com 12/9/2020 9:26:32 AM SENT
Preview
FILED 12/9/2020 9:26 AM FELICIA PITR‘E DISTRICT CLERK DALLAS 00., TEXAS No. Dc-20-o7324 Martin Re; es DEPUTY IN THE DISTRICT COURT OF CLENDON RHEA Martin Re yes vs. DALLAS COUNTY, TEXAS ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY IN THE 95TH JUDICIAL DISTRICT OFFICERS 203 CERTIFICATION OF DEPOSITION UPON WRITTEN QUESTIONS Records Pertaining To: CLENDON RHEA Pursuant to Texas Rules of Civil Procedure Rule 203, the undersigned Notary Public in and for the State of Texas | do hereby certify that Lettv Maqailanes was duly sworn, and the a true record of the him/her as witness/custodian of records for Allstate g deposition transcript is testimony given by Insurance Company clo CT Corporation Systems. The charge for preparation of the completed deposition transcript and any copies of exhibits is: $ y paid for by: YOUNG CHRISTIAN JENKINS, SBN: 24034505, Attorney for Defendant, ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY The deposition transcript was submitted to said custodian of records on 11/04/2020 . for examination and signature, and was returned to the officer on that date, and any changes made by the witness/custodian of records in the foregoing transcript are attached thereto or incorporated therein, and said witness/custodian of records returned the transcript on the date of examination; the original transcript, together with copies of all exhibits ' was delivered by certied mail or hand delivery to: YOUNG CHRISTIAN JENKINS SUSAN L. FLORENCE & ASSOCIATES 1201 ELM STREET, SUITE 5050 DALLAS, TX 75270 and a copy of this certificate was delivered by certied mail or hand delivery to all parties pursuant to Texas Rule of Civil Procedure 21 (a). A copy of this certificate has been filed with the appropriate court in DALLAS County, Texas GIVEN UNDER MY HAND AND SEAL OF OFFICE ON THIS THE 24TH DAY OF NOVEMBER, 2020. THIS IS NOT AN INVOICE. \\\“mmm a ”1% saw?” :5 {S9 E fig ‘ a '. it’d/EL e 2 ’14} =. okay”! and: f ~.,‘{qmw§_§.- g g Notar Public. Stateof Compex Legal Servrces, Inc. Texas asst-g" 3201 Cherry Ridge Drive, Suite 3207 e "’Imunii\\\\‘ San Antonio, TX 78230—4825 - (210) 646-6424 Fax (210) 599-7621 Cc: BEN ABBOTT & ASSOCIATES, Attorney For Plaintiff Order No. TX0030303-001 EMAIL: TexasCS@compexlegal.com ITIN B AT TESTIYO PODC ME NS The State of Texas, County of Dallas To any Sheriff or Constable of the State of Texas or other person authorized to serve subpoenas under RULE 176 0F T.R.C.P. GREETINGS YOU ARE HEREBY COMAMNDED TO SUBPOENA AND SUMMON THE — — FOLLOWING WITNESS(ES).' Custodian of Insurance Records for: ALLSTATE INSURANCE COMPANY C/O CT CORPORATION SYSTEMS to be and appear before a Notary Public of my designation for Compex Legal Services, lnc., 3201 Cherry Ridge, Suite B207, San Antonio, TX 78230 or its designated agent, on the forthwith day of Instanter 2020 at the ofce of the custodian and there under oath to make answers of certain written questions to be propounded to the witness and to bring and produce for inspection and photocopying a true and correct copy of Any and all insurance records stored in any format, including but not limited to correspondence, payments, payment history, policy information, declarations page, complete claim files, records of any liens, color photos, and damage repair estimates, injury records or claim and any other documents contained within any insurance le and/or claim file, pertaining to Clendon Rhea; DOL: 11/05/2016; Claim No.: 0438515355., and at any and all times whatsoever, then and there to give evidence at the instance of the Defendant, ALLSTATE FIRE AND CASUALTY INSURANCE COMPANY represented by YOUNG CHRISTIAN JENKINS, in that certain Cause No. DC—20- 07324, gending on the docket in the IN THE 95THJUDICIAL DISTRICT at DALLAS County. This Subpoena is I issued under and by virtue of Rule 200 and Notice ofDeposition Upon Written Questions on le with the above named court, styled CLENDON RHEA VS. ALLSTATE FIRE AND CASUALTY INSURANCE COWANY and there remain from day to day and time to time until discharged according to law. Pursuant to 176.8 Enforcement of Subpoena. (a) Contempt. Failure by any person without adequate excuse to obey a subpoena served upon that person may be deemed a contempt ofthe court om which the subpoena is issued or a district court in the county in which the subpoena is served, and may be punished by ne or connement, or both. Pursuant to HIPAA§I64.512(e); RULES 176 AND 200, TEXAS RULES 0F CIVIL PROCEDURE this subpoena is issued in accordance with and by virtue of a notice duly served and on le with the above named court, and falls under exception to condentially, RULE 509(c)(4), TEXAS RULES OF EVIDENCE, HIPAA Verication attached and incorporated illy herein. Order No. TX0030303-001 Page 1 of 1 Order Number: TX0030303—001 * TXO 0 3 0 3 O 3 - 0 0 1 * WITNESS MY HAND, This 08th day of October, 2020 \ «u ' ‘ weuqe..,: mm’” a )KII/ 3,4 "-40:15!- Notary Public for the State of Texas 4’mzy "Imam OFFICER'S RETURN Came to hand this 08 DAY OF October, 2020 at 09:00 A.M. and executed this by delivering same to the within named witness, all fees have been tendered in accordance with the T.R C.P. Service by: X Hand Delivery Certied Mail Electronic Witness Signature of Receipt and » Officer’s Signature Acceptance of Subpoena 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: 48770652 Status as of 12/9/2020 5:15 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status CAMILO VALENCIA eService@benabbott.com 12/9/2020 9:26:32 AM SENT Young Jenkins dallaslegal@allstate.com 12/9/2020 9:26:32 AM SENT