On December 17, 2019 a
Party Discovery
was filed
involving a dispute between
Canales, Raul J,
Rosales Gonzalez, Ezequiel,
and
Macias, Sebastian S,
Ms Transportation, Llc,
for Injury or Damage - Motor Vehicle (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Filed
1/4/2021 12:00 AM
No. C-5246-19-D Hidalgo County District Clerks
Reviewed By: Oneida Lamas
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
AMENDED NOTICE OF INTENTION
TO TAKE DEPOSITION BY WRITTEN QUESTIONS
To Defendant by and through their attorney(s) of record: Douglas E. Chaves (Chaves, Obregon & Perales, LLP)
To other party/parties by and through their attorney(s) of record:
You will please take notice that twenty (20) days fi'om the service 0f a copy hereof with attached questions, a deposition by written
questions will be taken of Custodian of Records for:
T-MOBILE USA, INC. LAW ENFORCEMENT RELATIONS GROUP (Phone Records)
4 SYLVAN WAY
PARSIPPANY, NJ 07054
before a Notary Public for Republic Services, Inc.
2123 W. Governors Circle #100
Houston, TX 77092
713-957-0094 Fax 713-957-0540
0r 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 fithher 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 or control of the said witness, and every such record to which the witness may have access,
pertaining to:
CELL PHONE NUMBER: 956-803-7171
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 Plaintifi
SBA # 00797456
byw
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: I
u 3! 9°39
Order No. 90646 _\
Electronically Filed
1/4/2021 12:00 AM
Hidalgo County District Clerks
Reviewed By: Oneida Lamas
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: T-MOBILE USA, INC. LAW ENFORCEMENT RELATIONS GROUP
Records Pertaining To: CELL PHONE NUMBER: 956-803-7171
Type ofRecords: Any and all cell phone records regarding CELL PHONE NUMBER: 956-803-7171 from 09:26 AM to
01:26 PM on 09/12/2018 including but not limited t0, incoming and outgoing call logs, text messages and
data usage. (PLEASE PROVIDE RECORDS IN CENTRAL STANDARD TIME)
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 of the originals?
Answer:
3. Were these records made and kept in the regular course of business?
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 fiom 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
1/4/2021 12:00 AM
Hidalgo County District Clerks
Reviewed By: Oneida Lamas
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? If not, why not?
Answer:
WITNESS (01stodian 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 further certify that the
records attached hereto are exact duplicates 0f the original records.
SWORN TO AND SUBSCRIBED before me this day of , 20
NOTARY PUBLIC
My Commission Expires:
Order No. 90646.001
Document Filed Date
January 04, 2021
Case Filing Date
December 17, 2019
Category
Injury or Damage - Motor Vehicle (OCA)
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Preview
Electronically Filed 1/4/2021 12:00 AM No. C-5246-19-D Hidalgo County District Clerks Reviewed By: Oneida Lamas 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 AMENDED NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS To Defendant by and through their attorney(s) of record: Douglas E. Chaves (Chaves, Obregon & Perales, LLP) To other party/parties by and through their attorney(s) of record: You will please take notice that twenty (20) days fi'om the service 0f a copy hereof with attached questions, a deposition by written questions will be taken of Custodian of Records for: T-MOBILE USA, INC. LAW ENFORCEMENT RELATIONS GROUP (Phone Records) 4 SYLVAN WAY PARSIPPANY, NJ 07054 before a Notary Public for Republic Services, Inc. 2123 W. Governors Circle #100 Houston, TX 77092 713-957-0094 Fax 713-957-0540 0r 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 fithher 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 or control of the said witness, and every such record to which the witness may have access, pertaining to: CELL PHONE NUMBER: 956-803-7171 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 Plaintifi SBA # 00797456 byw 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: I u 3! 9°39 Order No. 90646 _\ Electronically Filed 1/4/2021 12:00 AM Hidalgo County District Clerks Reviewed By: Oneida Lamas 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: T-MOBILE USA, INC. LAW ENFORCEMENT RELATIONS GROUP Records Pertaining To: CELL PHONE NUMBER: 956-803-7171 Type ofRecords: Any and all cell phone records regarding CELL PHONE NUMBER: 956-803-7171 from 09:26 AM to 01:26 PM on 09/12/2018 including but not limited t0, incoming and outgoing call logs, text messages and data usage. (PLEASE PROVIDE RECORDS IN CENTRAL STANDARD TIME) 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 of the originals? Answer: 3. Were these records made and kept in the regular course of business? 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 fiom 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 1/4/2021 12:00 AM Hidalgo County District Clerks Reviewed By: Oneida Lamas 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? If not, why not? Answer: WITNESS (01stodian 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 further certify that the records attached hereto are exact duplicates 0f the original records. SWORN TO AND SUBSCRIBED before me this day of , 20 NOTARY PUBLIC My Commission Expires: Order No. 90646.001