Motion,Ex Parte: Gloria Zarate DBA Zarate Sons Brokerage VS. Maria Mendez DBA S&S Trucking Company,Saul Mendez, Jr.,C&I Transport, Inc.

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                                CAUSE NO. CL-21-2049-E

  GLORIA ZARATE DBA ZARATE                §               IN THE COUNTY COURT
  & SONS BROKERAGE                        §
      Plaintiff,                          §
                                          §
  v.                                      §             AT LAW NUMBER FIVE (5)
                                          §
  MARIA MENDEZ D/B/A S&S                  §
  TRUCKING COMPANY                        §
      Defendants                                       HIDALGO COUNTY, TEXAS


   PLAINTIFFS REQUEST FOR ADMISSIONS TO DEFENDANT MARIA
             MENDEZ DBA S&S TRUCKING COMPANY

TO:    Defendant, MARIA MENDEZ D/B/A S&S TRUCKING COMPANY, by and
       through her attorney of record, Ruben Ramirez, Law Office of Ruben
       Ramirez, 520 West Pecan Blvd., McAllen, Texas 78501.

       Pursuant to Rule 198, Texas Rules of Civil Procedure, you are requested to

admit or deny the truth of statements or opinions of fact or of the application of law

to fact, including the genuineness of any documents served with these requests or

otherwise furnished or made available for inspection and copying. This request

extends to all matters set forth in the accompanying attachments.

       Each matter of which an admission is requested will be admitted unless, within

thirty (30) days after service of this request, you serve upon the Plaintiff, through the

undersigned attorney of record, a written answer or objection concerning such matter,

either specifically denying the matter of which an admission is requested or setting

forth in detail the reasons why you cannot truthfully either admit or deny the matter.




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                                                                                EXHIBIT A
                                       Respectfully submitted,

                                       CARRIGAN & ANDERSON, P.L.L.C.

                                By:    __/s/Stephen P. Carrigan___________
                                       STEPHEN P. CARRIGAN
                                       State Bar No. 03877000
                                       DAVID M. ANDERSON
                                       State Bar No. 24064815
                                       101 N. Shoreline Blvd., Suite 420
                                       Corpus Christi, Texas 78401
                                       (361) 884-4433 - Telephone
                                       (361) 884-4434 - Facsimile
                                       Email: scarrigan@ccatriallaw.com
                                       Email: danderson@ccatriallaw.com
                                       Legal assistant: wwatson@ccatriallaw.com
                                       Legal assistant: rkubik@ccatriallaw.com

                                       ATTORNEYS FOR PLAINTIFF

                          CERTIFICATE OF SERVICE

      I hereby certify that a true and correct copy of the foregoing document has
been provided to all counsel of record in accordance with the Texas Rules of Civil
Procedure via electronic service on this 2nd day of June, 2022.

Ruben Ramirez
Law Office of Ruben Ramirez
520 West Pecan Blvd.
McAllen, Texas 78501
Rubenramirezlaw@yahoo.com

                                              /s/ Stephen P. Carrigan




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                     DEFINITIONS AND INSTRUCTIONS

1.    "PERSONS" includes natural persons, firms, partnerships, associations, joint
ventures, and corporations.


2.    "DOCUMENTS AND TANGIBLE THINGS" includes, but is not limited to all
papers, books, accounts, drawings, graphs, charts, photographs, films, electronic or
videotape recordings, and any other data compilations from which information can
be obtained and translated, if necessary.


3.     "SUPPLEMENTATION" To the extent certain requests have been previously
responded to and the responses at the time they were given were incorrect or
incomplete or since then have become inaccurate or incomplete, it is requested that
the prior responses be supplemented.


4.    "DATE IN QUESTION" refers to on or about December 10, 2019.

5.    "INCIDENT" refers to the incident made the basis of this suit which is
described in Plaintiff's Original Petition and Amended Petitions, if any.


6.    “DESIGNATED TIME PERIOD” Unless otherwise stated in the specific
request, the time period applicable to the following discovery requests is from one
year prior to and including the date in question, through the present date.




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        PLAINTIFF’S FIRST SET OF REQUESTS FOR ADMISSIONS
     TO DEFENDANT MARIA MENDEZ DBA S&S TRUCKING COMPANY


1.    Admit or Deny that you owe Plaintiff money.

      RESPONSE:

2.    Admit or Deny that you owe the amount stated in Exhibit A.

      RESPONSE:


3.    Admit or Deny that you have not paid the attached Exhibit A.

      RESPONSE:




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