On July 11, 2019 a
Request,Application
was filed
involving a dispute between
Hoorman, James,
and
Dauda, Suraji,
Fedex Custom Critical, Inc.,
Fesi Dfw Truck Centers,
Fe-Si Dfw Truck Centers, Lp,
Muhungi, Frances Kamau,
Muhuti, Alex,
Ngugi, Paul,
Paramount Fleet Services, Llc,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
3/25/2020 8:45 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Darling Tellez DEPUTY
NO. DC-19-09814
JAMES HOORMAN § IN THE DISTRICT COURT
Plaintiff,
é
V. § 160TH JUDICIAL DISTRICT
§
PAUL NGUGI, PARAMOUNT FLEET §
SERVICES LLC, SURAJI DAUDA, §
FESI DFW TRUCK CENTERS AND §
FEDEX CUSTOM CRITICAL, INC §
Defendants. § OF DALLAS COUNTY, TEXAS
SUPPLEMENTAL AND AMENDED RESPONSES TO
REQUESTS FOR PRODUCTION
To: SURAJI DAUDA and FEDEX CUSTOM CRITICAL, INC
NOW COMES PAUL NGUGI, Defendant, and files these Supplemental and Amended
responses t0 the Requests for Production previously propounded by SURAJI DAUDA and
FEDEX CUSTOM CRITICAL, INC pursuant t0 Rule 196 of the Texas Rules 0f Civil Procedure.
Any and all objections or privileges heretofore asserted With respect t0 said Requests for
Production that have not been overruled by court order are not waived and remain in full force
and effect, except to the extent specifically reflected by these Supplemental and Amended
I‘CSpODSCS.
Respectfully submitted,
AKWURUOHA LAW FIRM PC
By:
/5/ 1w 0, WI
Lui O. Akwuruoha
Texas Bar N0. 24004 1 64
Email: 1akwuruoha@sbcglobal.net
1140 Empire Central Drive
Suite 205
Paul Ngugi & Paramount Fleet Services Supplemental and Amended Response Page I
Dallas, TX 75247
Tel. (214) 631-2500
Fax. (214) 631-0900
Attorney for Defendants
PAUL NGUGI and PARAMOUNT FLEET
SERVICES LLC
Paul Ngugi & Paramount Fleet Services Supplemental and Amended Response Page 2
SUPPLEMENTAL AND AMENDED RESPONSES
TO DISCOVERY REQUESTS
12. Identify and provide contact information for all persons on your premises
including employees, independent contractors, customers, Visitors, business associates, and
anyone else on the premises 0n the date of the accident.
RESPONSE:
1. Suraji Dauda (Co-Defendant)
2. Saul Flores (2 14-434-7 1 3 1)
3. Saul Amigos (469-508-6210)
4. Francis Kamau Muhungi (515-770-4525)
16. Review the Video ch03_20170818091259 (which our paralegal has provided to you again
by separated email) and identify the man in grey shirt Who exits the tractor at the end 0f the
Video; and
RESPONSE
After a review 0f the Video ch03_20170818091259, Paul Ngugi is unable t0 identify the
man in grey shirt.
17. and provide contact information for
identify all independent contractors who
worked for paramount or Ngugi in August 0f 2017.
RESPONSE:
4. Francis Kamau Muhungi (5 1 5-770-4525)
Carina Transporters
Paul Ngugi & Paramount Fleet Services Supplemental and Amended Response Page 3
NO. DC-19-09814
JAMES HOORMAN § IN THE DISTRICT COURT
Plaintiff, §
§
V. § 160TH JUDICIAL DISTRICT
§
PAUL NGUGI, PARAMOUNT FLEET §
SERVICES LLC, SURAJI DAUDA,
FESI DFW TRUCK CENTERS AND
FEDEX CUSTOM CRITICAL, INC
Defendants. § OF DALLAS COUNTY, TEXAS
SUPPLEMENTAL AND AMENDED RESPONSES TO
REQUESTS FOR PRODUCTION
T0: SURAJI DAUDA and FEDEX CUSTOM CRITICAL, INC
NOW COMES PARAMOUNT FLEET SERVICES LLC, Defendant, and files these
Supplemental and Amended responses t0 the Requests for Production previously propounded by
SURAJI DAUDA and FEDEX CUSTOM CRITICAL, INC pursuant t0 Rule 196 0f the Texas
Rules of Civil Procedure.
Any and all objections or privileges heretofore asserted With respect t0 said Requests for
Production that have not been overruled by court order are not waived and remain in full force
and effect, except to the extent specifically reflected by these Supplemental and Amended
I'CSpOIlSCS.
Respectfully submitted,
AKWURUOHA LAW FIRM PC
By:
IS/ Jed 0. W
Lui O. Akwuruoha
Texas Bar N0. 24004 1 64
Email: lakwuruoha@sbcglobal.net
Paul Ngugi & Paramount Fleet Services Supplemental and Amended Response Page 4
1140 Empire Central Drive
Suite 205
Dallas, TX 75247
Tel. (2 14) 63 1-2500
Fax. (2 14) 63 1-0900
Attorney for Defendants
PAUL NGUGI and PARAMOUNT FLEET
SERVICES LLC
CERTIFICATE OF SERVICE
I certify thaton March 25, 2020 a true and correct copy of Defendants' Response to
Plaintiffs Requests for Production was served all counsel 0f record by Electronic filing manager.
Including each person listed below:
ISI Jed 0. WI
Lui O. Akwuruoha
Daryoush Toofanian
RAD LAW FIRM
8001 LBJ Freeway,
Suite 300
75251
Dallas, Texas
dtoofanian@radlawfirm.com
efileDT@radlawfirm.com
Counsel for Plaintiff
Dena Choate
2600 Dallas Parkway, Suite 380
Frisco Texas 75034
dchoate@reiddennis.com
Counsel for Fedex Custom Critical and Suraji Daudi
David A. McFarland
Timothy E. Headley
THOMPSON, COE, COUS]NS, & IRONS, LLP
700 North Pearl Street, 25th Floor
Dallas, Texas 75201
dmcfarland@thompsoncoe.com
theadley@thompsoncoe.com
Counsel for FE-SI
Paul Ngugi & Paramount Fleet Services Supplemental and Amended Response Page 5
Document Filed Date
March 25, 2020
Case Filing Date
July 11, 2019
Category
MOTOR VEHICLE ACCIDENT
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FILED 3/25/2020 8:45 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Darling Tellez DEPUTY NO. DC-19-09814 JAMES HOORMAN § IN THE DISTRICT COURT Plaintiff, é V. § 160TH JUDICIAL DISTRICT § PAUL NGUGI, PARAMOUNT FLEET § SERVICES LLC, SURAJI DAUDA, § FESI DFW TRUCK CENTERS AND § FEDEX CUSTOM CRITICAL, INC § Defendants. § OF DALLAS COUNTY, TEXAS SUPPLEMENTAL AND AMENDED RESPONSES TO REQUESTS FOR PRODUCTION To: SURAJI DAUDA and FEDEX CUSTOM CRITICAL, INC NOW COMES PAUL NGUGI, Defendant, and files these Supplemental and Amended responses t0 the Requests for Production previously propounded by SURAJI DAUDA and FEDEX CUSTOM CRITICAL, INC pursuant t0 Rule 196 of the Texas Rules 0f Civil Procedure. Any and all objections or privileges heretofore asserted With respect t0 said Requests for Production that have not been overruled by court order are not waived and remain in full force and effect, except to the extent specifically reflected by these Supplemental and Amended I‘CSpODSCS. Respectfully submitted, AKWURUOHA LAW FIRM PC By: /5/ 1w 0, WI Lui O. Akwuruoha Texas Bar N0. 24004 1 64 Email: 1akwuruoha@sbcglobal.net 1140 Empire Central Drive Suite 205 Paul Ngugi & Paramount Fleet Services Supplemental and Amended Response Page I Dallas, TX 75247 Tel. (214) 631-2500 Fax. (214) 631-0900 Attorney for Defendants PAUL NGUGI and PARAMOUNT FLEET SERVICES LLC Paul Ngugi & Paramount Fleet Services Supplemental and Amended Response Page 2 SUPPLEMENTAL AND AMENDED RESPONSES TO DISCOVERY REQUESTS 12. Identify and provide contact information for all persons on your premises including employees, independent contractors, customers, Visitors, business associates, and anyone else on the premises 0n the date of the accident. RESPONSE: 1. Suraji Dauda (Co-Defendant) 2. Saul Flores (2 14-434-7 1 3 1) 3. Saul Amigos (469-508-6210) 4. Francis Kamau Muhungi (515-770-4525) 16. Review the Video ch03_20170818091259 (which our paralegal has provided to you again by separated email) and identify the man in grey shirt Who exits the tractor at the end 0f the Video; and RESPONSE After a review 0f the Video ch03_20170818091259, Paul Ngugi is unable t0 identify the man in grey shirt. 17. and provide contact information for identify all independent contractors who worked for paramount or Ngugi in August 0f 2017. RESPONSE: 4. Francis Kamau Muhungi (5 1 5-770-4525) Carina Transporters Paul Ngugi & Paramount Fleet Services Supplemental and Amended Response Page 3 NO. DC-19-09814 JAMES HOORMAN § IN THE DISTRICT COURT Plaintiff, § § V. § 160TH JUDICIAL DISTRICT § PAUL NGUGI, PARAMOUNT FLEET § SERVICES LLC, SURAJI DAUDA, FESI DFW TRUCK CENTERS AND FEDEX CUSTOM CRITICAL, INC Defendants. § OF DALLAS COUNTY, TEXAS SUPPLEMENTAL AND AMENDED RESPONSES TO REQUESTS FOR PRODUCTION T0: SURAJI DAUDA and FEDEX CUSTOM CRITICAL, INC NOW COMES PARAMOUNT FLEET SERVICES LLC, Defendant, and files these Supplemental and Amended responses t0 the Requests for Production previously propounded by SURAJI DAUDA and FEDEX CUSTOM CRITICAL, INC pursuant t0 Rule 196 0f the Texas Rules of Civil Procedure. Any and all objections or privileges heretofore asserted With respect t0 said Requests for Production that have not been overruled by court order are not waived and remain in full force and effect, except to the extent specifically reflected by these Supplemental and Amended I'CSpOIlSCS. Respectfully submitted, AKWURUOHA LAW FIRM PC By: IS/ Jed 0. W Lui O. Akwuruoha Texas Bar N0. 24004 1 64 Email: lakwuruoha@sbcglobal.net Paul Ngugi & Paramount Fleet Services Supplemental and Amended Response Page 4 1140 Empire Central Drive Suite 205 Dallas, TX 75247 Tel. (2 14) 63 1-2500 Fax. (2 14) 63 1-0900 Attorney for Defendants PAUL NGUGI and PARAMOUNT FLEET SERVICES LLC CERTIFICATE OF SERVICE I certify thaton March 25, 2020 a true and correct copy of Defendants' Response to Plaintiffs Requests for Production was served all counsel 0f record by Electronic filing manager. Including each person listed below: ISI Jed 0. WI Lui O. Akwuruoha Daryoush Toofanian RAD LAW FIRM 8001 LBJ Freeway, Suite 300 75251 Dallas, Texas dtoofanian@radlawfirm.com efileDT@radlawfirm.com Counsel for Plaintiff Dena Choate 2600 Dallas Parkway, Suite 380 Frisco Texas 75034 dchoate@reiddennis.com Counsel for Fedex Custom Critical and Suraji Daudi David A. McFarland Timothy E. Headley THOMPSON, COE, COUS]NS, & IRONS, LLP 700 North Pearl Street, 25th Floor Dallas, Texas 75201 dmcfarland@thompsoncoe.com theadley@thompsoncoe.com Counsel for FE-SI Paul Ngugi & Paramount Fleet Services Supplemental and Amended Response Page 5