On May 07, 2018 a
NTC INTENT ASHLEY HOLBERT - DISCOVERY
was filed
involving a dispute between
Holbert, Ashley,
Holbert, Donna,
and
Catapult Energy Services Group, Llc,
Catapult Energy Services Group Llc,
Cretic Energy Services, Llc,
Cretic Energy Services Llc,
Ngp Energy Capital Management, Llc,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
Preview
FILED
DALLAS COUNTY
10/30/2019 4:19 PM
FELICIA PITRE
DISTRICT CLERK
Margaret Thomas
NO. DC-18-05978
ASHLEY HOLBERT, Individually and as ) IN THE 101“ DISTRICT COURT
Next Friend of K.H., a Minor and as )
Representative of the Estate of ROWDY LEE )
HOLBERT, Deceased, and DONNA )
HOLBERT, )
)
Plaintiffs, )
)
And
i
BIG B CRANE, LLC and INTERNATIONAL )
COMPANY 0F HANOVER S.E., ) IN AND FOR
)
Intervenors, )
)
VS. )
)
CRETIC ENERGY SERVICES, LLC; )
CATAPULT ENERGY SERVICES GROUP, )
LLC; NGP CAPITAL MANAGEMENT, LLC; )
and SERVA CORPORATION, )
)
Defendants. ) DALLAS COUNTY, TEXAS
DEFENDANTS CRETIC ENERGY SERVICES LLC' CATAPULT
ENERGY SERVICES GROUP LLC and NGP CAPITAL MANAGEMENT LLC’S
NOTICE 0F INTENTION T0 TAKE THE ORAL AND VIDEO DEPOSITION
0F PLAINTIFF ASHLEY HOLBERT
T0: by and through their attorneys of record, Charles M. Noteboom and Brian W.
Plaintiffs,
Butcher, Noteboom Law Firm, 669 Airport Freeway, Suite 100, Hurst, TX 76053.
Pursuant to Rule 199 of the Texas Rules of Civil Procedure, Defendants hereby give notice
of their intention to take the oral deposition of the following witness on the date, at the time and
place reflected below:
WITNESS: Ashley Holbert
DATE: Monday, November 1 1, 201 9
TIME: 10:00 am.
Deposition Notice of Ashley Holbert Page 1
PLACE: Noteboom Law Firm
669 Airport Freeway, Suite 100
Hurst, TX 76053
The deposition will be taken before a court reporter or other person authorized to take
and record the witness‘ testimony. You are further given notice that said deposition may be
videotaped contemporaneously with the recording to be made by a certified court reporter. The
deposition will continue fiom day to day until completed.
You are invited to attend and cross-examine.
Respectfully submitted,
PETERSON FARRIS BYRD & PARKER
A Professional Corporation
P. O. Box 9620
Amarillo, TX 79105—9620
(806) 374—5317; FAX; 372—2107
By \W <>th
_______.,
Thomas D. Farris,
tfarris@pf-lawfirm.com
H 4
SB# 06844700
Chris D. Parker; SB#] 5479100
cparker@pf-lawfirm.com
Deposition Notice of Ashley Holbert Page 2
CERTIFICATE 0F SERVICE
Ihereby certify that on this day of 2019, I electronically filed
the foregoing document With the Clerk of the above—named court, using the electronic case filing
system of the court. Pursuant to Rule 21a of the Texas Rules of Civil Procedure, the following
attorneys ofreoord were served electronically:
Charles M. Noteboom
BrianW. Butcher
Noteboom Law Firm
669 Airport Freeway, Suite 100
Hurst, TX 76053
butcher@noteboom.com
M. Forest Nelson
John Holman Barr
Burt Barr & Associates, LLP
P.O. Box 223667
TX 75222-3667
f
Dallas,
jbarr@bbamcom
Thomas D. Farris
Deposition Notice of Ashley Holbert Page 3
Document Filed Date
October 30, 2019
Case Filing Date
May 07, 2018
Category
OTHER PERSONAL INJURY
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FILED DALLAS COUNTY 10/30/2019 4:19 PM FELICIA PITRE DISTRICT CLERK Margaret Thomas NO. DC-18-05978 ASHLEY HOLBERT, Individually and as ) IN THE 101“ DISTRICT COURT Next Friend of K.H., a Minor and as ) Representative of the Estate of ROWDY LEE ) HOLBERT, Deceased, and DONNA ) HOLBERT, ) ) Plaintiffs, ) ) And i BIG B CRANE, LLC and INTERNATIONAL ) COMPANY 0F HANOVER S.E., ) IN AND FOR ) Intervenors, ) ) VS. ) ) CRETIC ENERGY SERVICES, LLC; ) CATAPULT ENERGY SERVICES GROUP, ) LLC; NGP CAPITAL MANAGEMENT, LLC; ) and SERVA CORPORATION, ) ) Defendants. ) DALLAS COUNTY, TEXAS DEFENDANTS CRETIC ENERGY SERVICES LLC' CATAPULT ENERGY SERVICES GROUP LLC and NGP CAPITAL MANAGEMENT LLC’S NOTICE 0F INTENTION T0 TAKE THE ORAL AND VIDEO DEPOSITION 0F PLAINTIFF ASHLEY HOLBERT T0: by and through their attorneys of record, Charles M. Noteboom and Brian W. Plaintiffs, Butcher, Noteboom Law Firm, 669 Airport Freeway, Suite 100, Hurst, TX 76053. Pursuant to Rule 199 of the Texas Rules of Civil Procedure, Defendants hereby give notice of their intention to take the oral deposition of the following witness on the date, at the time and place reflected below: WITNESS: Ashley Holbert DATE: Monday, November 1 1, 201 9 TIME: 10:00 am. Deposition Notice of Ashley Holbert Page 1 PLACE: Noteboom Law Firm 669 Airport Freeway, Suite 100 Hurst, TX 76053 The deposition will be taken before a court reporter or other person authorized to take and record the witness‘ testimony. You are further given notice that said deposition may be videotaped contemporaneously with the recording to be made by a certified court reporter. The deposition will continue fiom day to day until completed. You are invited to attend and cross-examine. Respectfully submitted, PETERSON FARRIS BYRD & PARKER A Professional Corporation P. O. Box 9620 Amarillo, TX 79105—9620 (806) 374—5317; FAX; 372—2107 By \W <>th _______., Thomas D. Farris, tfarris@pf-lawfirm.com H 4 SB# 06844700 Chris D. Parker; SB#] 5479100 cparker@pf-lawfirm.com Deposition Notice of Ashley Holbert Page 2 CERTIFICATE 0F SERVICE Ihereby certify that on this day of 2019, I electronically filed the foregoing document With the Clerk of the above—named court, using the electronic case filing system of the court. Pursuant to Rule 21a of the Texas Rules of Civil Procedure, the following attorneys ofreoord were served electronically: Charles M. Noteboom BrianW. Butcher Noteboom Law Firm 669 Airport Freeway, Suite 100 Hurst, TX 76053 butcher@noteboom.com M. Forest Nelson John Holman Barr Burt Barr & Associates, LLP P.O. Box 223667 TX 75222-3667 f Dallas, jbarr@bbamcom Thomas D. Farris Deposition Notice of Ashley Holbert Page 3