Preview
Electronically Filed
8/28/2020 5:32 PM
Hidalgo County District Clerks
Reviewed By: Marie Villarreal
No. C-5246-l9-D
RAUL J. CANALES AND EZEQUIEL ROSALES : IN THE DISTRICT COURT OF
GONZALEZ
vs. : HIDALGO COUNTY, TEXAS
MS TRANSPORTATION, LLC AND :
SEBASTIAN S. MACIAS : 206TH JUDICIAL DISTRICT
NOTICE OF INTENTION
TO TAKE DEPOSITION BY WRITTEN QUESTIONS
To Defendant by and through their attomey(s) ofrecord: Douglas E. Chaves (Chaves, Obregon & Perales, LLP)
To other party/parties by and through their attomey(s) ofrecord:
You will please take notice that twenty (20) days from the service of a copy hereof with attached questions, a deposition by written
questions will be taken of Custodian of Records for:
TRI-RECYCLING (Employment)
12407 HIGHWAY 290 EAST
MANOR, TX 78653
before a Notary Public for Republic Services, Inc.
2123 W. Governors Circle #100
Houston, TX 77092
713—957-0094 Fax 713-957-0540
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 Rule
200, Texas Rules of Civil Procedure, to the officer taking this deposition to issue a subpoena duces tecum and cause it to be
served on the witness to produce any and all records as described on the attached questions and/or Exhibit(s) and any other such
record in the possession, custody 0r control of the said witness, and every such record t0 which the witness may have access,
pertaining to:
RAUL J. CANALES, III
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.
Langdon Smith
Jim S. Adler & Associates
3D International Tower
1900 West Loop South, 20th Floor
Houston, TX 77027
713-777-4000 Fax 713-781-2514
Attorney for Plaintiff
SBA # 00797456
W
I hereby certify that a true and correct copy of the foregoing instrument has been forwarded to all Counsel of Record by hand
delivery, FAX, and/or certified mail, return receipt requested, on this day.
Dated: €( gt)
oa'o
by
£604
Order N0. 89628 -|
Electronically Filed
8/28/2020 5:32 PM
Hidalgo County District Clerks
Reviewed By: Marie Villarreal
No. C-5246-19-D
RAUL J. CANALES AND EZEQUIEL ROSALES : IN THE DISTRICT COURT OF
GONZALEZ
vs. : HIDALGO COUNTY, TEXAS
MS TRANSPORTATION, LLC AND :
SEBASTIAN S. MACIAS : 206TH JUDICIAL DISTRICT
DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS
Custodian of Records for: TRI—RECYCLING
Records Pertaining To: RAUL J. CANALES, III
Type of Records: Any and all records, including but not limited to, job descriptions, application for employment, payroll,
timesheets/cards, employment earnings ledgers, quarterly statements, W-2 Forms and 1099 Forms
pertaining t0 RAUL J. CANALES, III.
1. State your full name, address and occupation.
Answer :
2. Are you able to identify these records as the originals or true and correct copies ofthe originals?
Answer:
3. Were these records made and kept in the regular course ofbusiness?
Answer:
4. In the regular course of business, did the person who signed or otherwise prepared these records either have personal
knowledge of the entries on these records or obtain the information from sources who have such personal knowledge to make
such records?
Answer:
5. Are these records under your care, supervision, directions, custody or control?
Answer:
6. Are these records made at a time closely related to or simultaneous with the occurrence recorded on these records?
Answer:
Electronically Filed
8/28/2020 5:32 PM
Hidalgo County District Clerks
Reviewed By: Marie Villarreal
7. Were these records kept as described in the previous questions?
Answer:
8. Please gather any and all of such records together and deliver same to the officer taking your deposition for inspection and
photocopying. (This will be at no expense to you, and the officer will return the original records to you afier they have been
both inspected and copied.) Have you done as requested? Ifnot, why not?
Answer:
WITNESS (Custodian of Records)
Before me, the undersigned authority, on this day personally appeared ,
known to 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 fin‘ther celtify that the
records attached hereto are exact duplicates of the original records.
SWORN TO AND SUBSCRIBED before me this day of ,
20
NOTARY PUBLIC
My Commission Expires:
Order No. 89628.001
Preview
Electronically Filed 8/28/2020 5:32 PM Hidalgo County District Clerks Reviewed By: Marie Villarreal No. C-5246-l9-D RAUL J. CANALES AND EZEQUIEL ROSALES : IN THE DISTRICT COURT OF GONZALEZ vs. : HIDALGO COUNTY, TEXAS MS TRANSPORTATION, LLC AND : SEBASTIAN S. MACIAS : 206TH JUDICIAL DISTRICT NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS To Defendant by and through their attomey(s) ofrecord: Douglas E. Chaves (Chaves, Obregon & Perales, LLP) To other party/parties by and through their attomey(s) ofrecord: You will please take notice that twenty (20) days from the service of a copy hereof with attached questions, a deposition by written questions will be taken of Custodian of Records for: TRI-RECYCLING (Employment) 12407 HIGHWAY 290 EAST MANOR, TX 78653 before a Notary Public for Republic Services, Inc. 2123 W. Governors Circle #100 Houston, TX 77092 713—957-0094 Fax 713-957-0540 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 Rule 200, Texas Rules of Civil Procedure, to the officer taking this deposition to issue a subpoena duces tecum and cause it to be served on the witness to produce any and all records as described on the attached questions and/or Exhibit(s) and any other such record in the possession, custody 0r control of the said witness, and every such record t0 which the witness may have access, pertaining to: RAUL J. CANALES, III 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. Langdon Smith Jim S. Adler & Associates 3D International Tower 1900 West Loop South, 20th Floor Houston, TX 77027 713-777-4000 Fax 713-781-2514 Attorney for Plaintiff SBA # 00797456 W I hereby certify that a true and correct copy of the foregoing instrument has been forwarded to all Counsel of Record by hand delivery, FAX, and/or certified mail, return receipt requested, on this day. Dated: €( gt) oa'o by £604 Order N0. 89628 -| Electronically Filed 8/28/2020 5:32 PM Hidalgo County District Clerks Reviewed By: Marie Villarreal No. C-5246-19-D RAUL J. CANALES AND EZEQUIEL ROSALES : IN THE DISTRICT COURT OF GONZALEZ vs. : HIDALGO COUNTY, TEXAS MS TRANSPORTATION, LLC AND : SEBASTIAN S. MACIAS : 206TH JUDICIAL DISTRICT DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS Custodian of Records for: TRI—RECYCLING Records Pertaining To: RAUL J. CANALES, III Type of Records: Any and all records, including but not limited to, job descriptions, application for employment, payroll, timesheets/cards, employment earnings ledgers, quarterly statements, W-2 Forms and 1099 Forms pertaining t0 RAUL J. CANALES, III. 1. State your full name, address and occupation. Answer : 2. Are you able to identify these records as the originals or true and correct copies ofthe originals? Answer: 3. Were these records made and kept in the regular course ofbusiness? Answer: 4. In the regular course of business, did the person who signed or otherwise prepared these records either have personal knowledge of the entries on these records or obtain the information from sources who have such personal knowledge to make such records? Answer: 5. Are these records under your care, supervision, directions, custody or control? Answer: 6. Are these records made at a time closely related to or simultaneous with the occurrence recorded on these records? Answer: Electronically Filed 8/28/2020 5:32 PM Hidalgo County District Clerks Reviewed By: Marie Villarreal 7. Were these records kept as described in the previous questions? Answer: 8. Please gather any and all of such records together and deliver same to the officer taking your deposition for inspection and photocopying. (This will be at no expense to you, and the officer will return the original records to you afier they have been both inspected and copied.) Have you done as requested? Ifnot, why not? Answer: WITNESS (Custodian of Records) Before me, the undersigned authority, on this day personally appeared , known to 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 fin‘ther celtify that the records attached hereto are exact duplicates of the original records. SWORN TO AND SUBSCRIBED before me this day of , 20 NOTARY PUBLIC My Commission Expires: Order No. 89628.001