On March 24, 2023 a
Party Discovery
was filed
involving a dispute between
Hernandez-Rodriguez, Lourdes Nayeli,
and
American National Logistics, Inc.,
Chambers, Brandon,
Mckenzie, Herman,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
7/31/2023 3:00 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Terri Kilgore DEPUTY
NO. DC-23-03860
LOURDES NAYELI HERNANDEZ- IN THE DISTRICT COURT
§§§§§§§§§§§
RODRIGUEZ,
Plaintiff,
vs. DALLAS COUNTY, TEXAS
BRANDON CHAMBERS, HERMAN
MCKENZIE, and AMERICAN
NATIONAL LOGISTICS, INC.,
Defendants. 14thJUDICIAL DISTRICT
DEFENDANT BRANDON CHAMBERS’ CERTIFICATE
OF WRITTEN DISCOVERY DIRECTED TO PLAINTIFF
TO THE CLERK OF THIS HONORABLE COURT:
COMES NOW Defendant, BRANDON CHAMBERS, and files this Certificate
of Written Discovery and states the discovery set forth was properly served to all counsel of
record via e-mail onJuly 31, 2023.
1. Defendant Brandon Chambers’ First Set of Interrogatories To Plaintiff;
and
2. Defendant Brandon Chambers’ First Request For Production of
Documents To Plaintiff.
Respectfully submitted,
Wow
D. BROOKE OSBURN
State Bar N0. 24055324
j. MATTHEW CROSS
State Bar N0. 24007054
JONATHAN BOGGUS
State Bar N0. 24133392
SMITH OSBURN CROSS
6320 Southwest Blvd.
Suite 101
Fort Worth, Texas 76109
Telephone :(817)877—3336
Telecopier :(817) 877-5538
E-Mail: service@soc—law.com
ATTORNEYS FOR DEFENDANT
BRANDON CHAMBERS
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Defendant Brandon
Chambers’ Certificate of Written Discovery was sent to Mr. Shawn Hashemi, attorney for
Plaintiff, at Chalaki Law, P.C., 3234 Commander Drive, Suite 100, Carrollton, Texas 75006, by
e-mail efile@chalakilaw.com; and to Mr. Mike H. Bassett, attorney for Defendants Herman
McKenzie and American National Logistics, Inc., at The Bassett Firm, Two Turtle Creek
Village, Suite 1300, Dallas, Texas 75219, by e-mail efile@thebassettfirm.com, onJuly 31, 2023.
D. BROOKE OSBURN
OW
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Nancy Kennedy on behalf of Brooke Osburn
Bar No. 24055324
nkennedy@soc-law.com
Envelope ID: 78047956
Filing Code Description: Certificate Of Written Discovery
Filing Description:
Status as of 7/31/2023 3:22 PM CST
Associated Case Party: AMERICAN NATIONAL LOGISTICS, INC.
Name BarNumber Email TimestampSubmitted Status
Mike H.Bassett efile@thebassettfirm.com 7/31/2023 3:00:36 PM SENT
Associated Case Party: LOURDES NAYELIHERNANDEZ-RODRIGUEZ
Name BarNumber Email TimestampSubmitted Status
Shawn Hashemi efile@chalakilaw.com 7/31/2023 3:00:36 PM SENT
Document Filed Date
July 31, 2023
Case Filing Date
March 24, 2023
Category
MOTOR VEHICLE ACCIDENT
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FILED 7/31/2023 3:00 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Terri Kilgore DEPUTY NO. DC-23-03860 LOURDES NAYELI HERNANDEZ- IN THE DISTRICT COURT §§§§§§§§§§§ RODRIGUEZ, Plaintiff, vs. DALLAS COUNTY, TEXAS BRANDON CHAMBERS, HERMAN MCKENZIE, and AMERICAN NATIONAL LOGISTICS, INC., Defendants. 14thJUDICIAL DISTRICT DEFENDANT BRANDON CHAMBERS’ CERTIFICATE OF WRITTEN DISCOVERY DIRECTED TO PLAINTIFF TO THE CLERK OF THIS HONORABLE COURT: COMES NOW Defendant, BRANDON CHAMBERS, and files this Certificate of Written Discovery and states the discovery set forth was properly served to all counsel of record via e-mail onJuly 31, 2023. 1. Defendant Brandon Chambers’ First Set of Interrogatories To Plaintiff; and 2. Defendant Brandon Chambers’ First Request For Production of Documents To Plaintiff. Respectfully submitted, Wow D. BROOKE OSBURN State Bar N0. 24055324 j. MATTHEW CROSS State Bar N0. 24007054 JONATHAN BOGGUS State Bar N0. 24133392 SMITH OSBURN CROSS 6320 Southwest Blvd. Suite 101 Fort Worth, Texas 76109 Telephone :(817)877—3336 Telecopier :(817) 877-5538 E-Mail: service@soc—law.com ATTORNEYS FOR DEFENDANT BRANDON CHAMBERS CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Defendant Brandon Chambers’ Certificate of Written Discovery was sent to Mr. Shawn Hashemi, attorney for Plaintiff, at Chalaki Law, P.C., 3234 Commander Drive, Suite 100, Carrollton, Texas 75006, by e-mail efile@chalakilaw.com; and to Mr. Mike H. Bassett, attorney for Defendants Herman McKenzie and American National Logistics, Inc., at The Bassett Firm, Two Turtle Creek Village, Suite 1300, Dallas, Texas 75219, by e-mail efile@thebassettfirm.com, onJuly 31, 2023. D. BROOKE OSBURN OW Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Nancy Kennedy on behalf of Brooke Osburn Bar No. 24055324 nkennedy@soc-law.com Envelope ID: 78047956 Filing Code Description: Certificate Of Written Discovery Filing Description: Status as of 7/31/2023 3:22 PM CST Associated Case Party: AMERICAN NATIONAL LOGISTICS, INC. Name BarNumber Email TimestampSubmitted Status Mike H.Bassett efile@thebassettfirm.com 7/31/2023 3:00:36 PM SENT Associated Case Party: LOURDES NAYELIHERNANDEZ-RODRIGUEZ Name BarNumber Email TimestampSubmitted Status Shawn Hashemi efile@chalakilaw.com 7/31/2023 3:00:36 PM SENT