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CAUSE NO. 22
MARISOL GARDUNO IN THE DISTRICT COURT OF
FORT BEND COUNTY, TEXAS
WEIQIANG HUANG JUDICIAL DISTRICT
DEFENDANT WEIQIANG HUANG ANSWERS TO PLAINTIFF
FIRST SET OF INTERROGATORIES
TO: Marisol Garduno, Plaintiff by and through Counsel of Record:
Jonathan C. Kieschnick
State Bar No.
ARTHY ASSOCIATES, PLLC
7225 El Camino Real, Suite
Houston, Texas 77058
Tel: (281) 538
csimile (281) 538
Email: jck@jck law.com
In accordance with Defendant, Weiqiang Huang serves her Answers
to Plaintiffs First Set of Interrogatories
Respectfully submitted,
INDOW TEPHENS CHULTZ
By:
Albert Williams III
State Bar No. 24096122
One Riverwalk Place
700 N. St. Mary’s Street, Suite 1700
San Antonio, Texas 78205
(210) 227 2200 (telephone)
(210) 227 4602 (facsimile)
awilliams@lsslaw.com
Counsel for Defendant Weiqiang Huang
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Defendant, Weiqiang Huang
serves her Answers and Objections to Plaintiff’s First Set of Interrogatories was served via
facsimile and/or electronic service on the day of May n the following counsel of
record:
Jonathan C. Kieschnick
State Bar No.
ARTHY ASSOCIATES, PLLC
7225 El Camino Real, Suite
Houston, Texas 77058
Tel: (281) 538
csimile (281) 538
Email: jck@jck law.com
___________________________
Albert Williams III
DEFENDANT WEIQIANG HUANG’S ANSWERS TO PLAINTIFF’S
FIRST SET OF INTERROGATORIES
1. State your complete name, address, social security number, driver's license number and date
of birth.
ANSWER: Defendant objects to this interrogatory as stated because it requests Defendant to
provide his social security number which constitutes privileged information that, if released in
a public document, could cause undue harm and invasion of Defendant’s privacy and property
rights. Additionally, Defendant objects to disclosing his social security number on the grounds
that that interrogatory seeks information that is not relevant nor is the information sought
likely to lead to the discovery of admissible evidence. Subject to and without waiving the
foregoing:
Name: Weiqiang Huang
Address: 1014 Lake Field Road, Richmond, Texas 77469
DL: 46161103
DOB: 08/18/1984
2. State your complete marital history, including the name or names of current and former
spouses, the date of marriage, the date of dissolution of marriage, and the names and ages of
children, if any.
ANSWER: Defendant objects on the basis that this request seeks information that is not
relevant nor reasonably calculated to lead to the discovery of admissible evidence.
3. State your employment history for the ten (10) years prior to the incident and up to and
including the date this case is tried, listing the name, address and telephone number of each
employer, the name of your immediate supervisor while working for each employer, your job
title and the nature of your duties at each employment, the period of time you worked for each
employer and the reason each employment was terminated.
ANSWER: Defendant objects on the basis that this request is overly broad, vague, ambiguous,
and constitutes a prohibited fishing expedition in violation of In re CSX Corp., 124 S.W.3rd 149
(Tex. 2003); K-Mart v. Sanderson, 937 S.W.2d 429 (Tex. 1996); Dillard Department Stores, Inc.
v. Hall, 909 S.W.2d 491 (Tex. 1995); and Loftin v. Martin, 776 S.W.2d 145 (Tex. 1989) and as
an impermissible fishing expedition which seeks information beyond the subject matter of this
case and which will not aid in the resolution of this dispute.
4. Identify, by name, address and telephone number, all persons you will call (whether live, by
deposition or by affidavit) to testify at trial.
ANSWER: Defendant reserves the right to call all persons identified in discovery by any party
hereto. See also Defendant’s Disclosure.
5. Please list in numerical order the names of all insurers, policy numbers and limits of liability
of any and all insurance policies and agreements, including any and all primary coverage,
secondary coverage, excess insurance coverage of any type, kind or character, between the
Defendant, and any and all insurance firms, corporations or businesses carrying on insurance
business, by reason of which the insurance firm, corporation or business may be liable to
satisfy all or part of the judgment which may be rendered in this action against the Defendant,
or to indemnify or reimburse the Defendant for payment made to satisfy such judgment. This
request includes complete information regarding the limits of all insurance coverage in effect
at the time of the incident in question. Although insurance documents may be provided in
response to Plaintiff's Request for Production, Plaintiff will still expect an answer to this
interrogatory in that it is a sworn answer as to the existence of liability insurance.
ANSWER: Defendant objects to this interrogatory as stated as it is duplicative of Requests for
Disclosure.
6. If you have ever pled guilty to, been indicted or convicted of any crime other than traffic
violations, please state:
a. The nature of the offense.
b. The date.
c. The county and state in which you were tried.
d. The sentence given you.
ANSWER: Defendant objects on the basis that this request exceeds the scope of discovery under
Tex.R.Civ.P. 192.3 and seeks information that is not relevant nor reasonably calculated to lead
to the discovery of admissible evidence.
7. State the date of each and every vehicular collision of which you have been involved, as well
as the names, addresses and telephone numbers of the persons involved.
ANSWER: Defendant objects to this interrogatory, as stated, because it is vague, overbroad in
terms of time and scope, is unduly burdensome, and constitutes a "fishing expedition." See In
Re CSX Corp., 124 S.W.3d 149 (Tex. 2003); K-Mart Corp. v. Sanderson, 937 S.W.2d 429 (Tex.
1996); Dillard Dept. Stores, Inc., v. Hall, 909 S.W.2d 491 (Tex. 1995); and Loftin v. Martin, 776
S.W.2d 145 (Tex. 1989).
8. If you have ever had a license to operate a motor vehicle suspended or revoked, please state:
a. When and where it was suspended or revoked.
b. Why it was suspended or revoked.
c. The period of such suspension or revocation.
d. Whether such suspension or revocation was lifted.
ANSWER: Defendant objects on the basis that this request seeks information that is not
relevant nor reasonably calculated to lead to the discovery of admissible evidence.
9. If you have ever been involved in any other legal action, either as a Defendant or as a Plaintiff,
please give a description of the nature of such action, including the court and cause number.
ANSWER: Defendant objects to this interrogatory, as stated, because it is vague, overbroad in
terms of time and scope, is unduly burdensome, and constitutes a "fishing expedition." See In
Re CSX Corp., 124 S.W.3d 149 (Tex. 2003); K-Mart Corp. v. Sanderson, 937 S.W.2d 429 (Tex.
1996); Dillard Dept. Stores, Inc., v. Hall, 909 S.W.2d 491 (Tex. 1995); and Loftin v. Martin, 776
S.W.2d 145 (Tex. 1989).
10. Were you the operator of a vehicle involved in the incident made the basis of this litigation?
ANSWER: Defendant was the owner of the vehicle involved in the incident made the basis of
this litigation.
11. Were you the owner of the vehicle in question on the date and time of the incident made the
basis of this litigation? If not, please state the name and address of the owner of the vehicle.
ANSWER: Defendant was the owner of the vehicle involved in the incident made the basis of
this litigation.
12. Were you given permission to drive the vehicle in question? If so, give the name, address and
telephone number of the person that gave you permission?
ANSWER: Not applicable.
13. Were you operating the vehicle in question at the time of the incident while in the course and
scope of employment? If so, provide the name, address and telephone number of your
employer at the time of the incident?
ANSWER: Defendant was not in the course and scope of employment at the time of the accident
made basis of this suit.
14. Were you charged with any violation of the law arising out of the incident made the basis of
this litigation? If so, state the plea entered by you to such charge and the results of the charge.
ANSWER: Defendant objects on the basis that this request exceeds the scope of discovery under
Tex.R.Civ.P. 192.3 and seeks information that is not relevant nor reasonably calculated to lead
to the discovery of admissible evidence.
15. State, in detail and completely, the manner in which you assert that the incident made the basis
of this litigation occurred.
ANSWER: Defendant objects as overbroad, unduly burdensome, and harassing. Defendant
further objects as an impermissible attempt to limit the testimony of Defendant and require
Defendant to marshal evidence.
16. Did you have a wireless communication device/cellular phone in your vehicle at the time of
the incident made the basis of this litigation? If so, were you using the wireless
communication device/cellular phone at the time of the incident made the basis of this
litigation?
ANSWER: Defendant objects on the basis that this request is overly broad, vague, ambiguous,
and constitutes a prohibited fishing expedition in violation of In re CSX Corp., 124 S.W.3rd 149
(Tex. 2003); K-Mart v. Sanderson, 937 S.W.2d 429 (Tex. 1996); Dillard Department Stores, Inc.
v. Hall, 909 S.W.2d 491 (Tex. 1995); and Loftin v. Martin, 776 S.W.2d 145 (Tex. 1989) and as
an impermissible fishing expedition which seeks information beyond the subject matter of this
case and which will not aid in the resolution of this dispute. Subject to and without waiving the
foregoing, Defendant was not using their cell phone at the time of this accident.
17. State whether or not you were familiar with the scene of the incident made the basis of this
litigation prior thereto.
ANSWER: Defendant objects to this interrogatory to the extent that it seeks to unfairly limit
future testimony at deposition or in trial, as the question is more properly one to be asked at
Defendant’s deposition, if one is taken.
18. State the speed of your vehicle at all times material to the incident made the basis of this
litigation, including specifically your speed at the time of impact, and if your brakes were
applied at the time of impact, please state your speed before applying your brakes.
ANSWER: Defendant objects to this interrogatory to the extent that it seeks to unfairly limit
future testimony at deposition or in trial, as the question is more properly one to be asked at
Defendant’s deposition, if one is taken. Defendant further objects to this request as calling for
speculation.
19. Please state completely and fully all representations, statements, declarations or admissions
made by the Plaintiff or any agents, servants or employees of the Plaintiff.
ANSWER: Defendant objects to this request on the grounds that Plaintiff has equal, if not
superior, access to the information and/or documents sought. If a moving party can obtain
the desired information without resort to discovery, good cause does not exist for producing
same.
20. Detail your actions for the eight (8) hours immediately preceding the incident in question,
including, but not limited to, your activities and locations during this time, and any and all
driving done by you during this period.
ANSWER: Defendant objects on the basis that this request is overly broad, vague, ambiguous,
and constitutes a prohibited fishing expedition in violation of In re CSX Corp., 124 S.W.3rd 149
(Tex. 2003); K-Mart v. Sanderson, 937 S.W.2d 429 (Tex. 1996); Dillard Department Stores, Inc.
v. Hall, 909 S.W.2d 491 (Tex. 1995); and Loftin v. Martin, 776 S.W.2d 145 (Tex. 1989) and as
an impermissible fishing expedition which seeks information beyond the subject matter of this
case and which will not aid in the resolution of this dispute.
21. State in detail what intoxicating beverages, if any, you had consumed and what drugs or
medications (prescription or non-prescription), if any, you had taken during the 24-hour
period immediately preceding the incident. Include in your answer the time of consumption,
the amount and type of alcohol, drugs or medication, and where or from whom it was
acquired.
ANSWER: Defendant objects on the basis that this request is overly broad, vague,
ambiguous, and constitutes a prohibited fishing expedition in violation of In re CSX Corp., 124
S.W.3rd 149 (Tex. 2003); K-Mart v. Sanderson, 937 S.W. 2d 429 (Tex. 1996); Dillard
Department Stores, Inc. v. Hall, 909 S.W. 2d 491 (Tex. 1995); and Loftin v. Martin, 776 S.W. 2d
145 (Tex. 1989). Defendant further objects on the basis that this request exceeds the scope of
discovery under Tex.R.Civ.P. 192.3 and seeks information that is not relevant nor reasonably
calculated to lead to the discovery of admissible evidence. Subject to and without waiving
such objections, Defendant was not impaired by any intoxicating substance at the time of the
incident in question.
22. Please state whether you intend to impeach Plaintiff or any of Plaintiff's witnesses with
evidence of a criminal conviction, pursuant to Tex. R. Civ. Evid. 609. If so, please describe
such evidence by giving the name of the accused, the nature of the crime, and the date of the
conviction.
ANSWER: Defendant is not aware of any at this time. Defendant reserves the right to utilize
any criminal information disclosed in discovery by any party and any information disclosed in
depositions in this matter.
23. Describe in detail what damage, if any was done to the vehicles in the incident, and give the
cost of repair to the vehicles.
ANSWER: Defendant objects to this interrogatory as stated as it is duplicative of Requests for
Disclosure. Subject to and without waiving the foregoing objection, Defendant would answer
as follows: see Defendant’s disclosures
24. Describe in detail what injuries, if any, you received in the incident.
ANSWER: Defendant objects as overbroad, unduly burdensome, and harassing. Defendant
further objects as an impermissible attempt to limit the testimony of Defendant and require
Defendant to marshal evidence.
25. Please state the name and address of each expert consulted whose opinions or impressions
have been reviewed by any expert witness whom you expect to call at the trial of this case.
ANSWER: Defendant objects to this interrogatory as stated because it impermissibly requests
information about Defendant’s testifying expert witnesses in violation of Tex.R.Civ.P. 197.1
which allows parties to request another party to designate and disclose information concerning
testifying expert witnesses only through a request for disclosure under Tex.R.Civ.P. 194 and
through depositions and reports under Tex.R.Civ.P. 195. See In re City of Georgetown, 53
S.W.3d 328 (Tex. 2001).
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CAUSE NO. 22 MARISOL GARDUNO IN THE DISTRICT COURT OF FORT BEND COUNTY, TEXAS WEIQIANG HUANG JUDICIAL DISTRICT DEFENDANT WEIQIANG HUANG ANSWERS TO PLAINTIFF FIRST SET OF INTERROGATORIES TO: Marisol Garduno, Plaintiff by and through Counsel of Record: Jonathan C. Kieschnick State Bar No. ARTHY ASSOCIATES, PLLC 7225 El Camino Real, Suite Houston, Texas 77058 Tel: (281) 538 csimile (281) 538 Email: jck@jck law.com In accordance with Defendant, Weiqiang Huang serves her Answers to Plaintiffs First Set of Interrogatories Respectfully submitted, INDOW TEPHENS CHULTZ By: Albert Williams III State Bar No. 24096122 One Riverwalk Place 700 N. St. Mary’s Street, Suite 1700 San Antonio, Texas 78205 (210) 227 2200 (telephone) (210) 227 4602 (facsimile) awilliams@lsslaw.com Counsel for Defendant Weiqiang Huang CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Defendant, Weiqiang Huang serves her Answers and Objections to Plaintiff’s First Set of Interrogatories was served via facsimile and/or electronic service on the day of May n the following counsel of record: Jonathan C. Kieschnick State Bar No. ARTHY ASSOCIATES, PLLC 7225 El Camino Real, Suite Houston, Texas 77058 Tel: (281) 538 csimile (281) 538 Email: jck@jck law.com ___________________________ Albert Williams III DEFENDANT WEIQIANG HUANG’S ANSWERS TO PLAINTIFF’S FIRST SET OF INTERROGATORIES 1. State your complete name, address, social security number, driver's license number and date of birth. ANSWER: Defendant objects to this interrogatory as stated because it requests Defendant to provide his social security number which constitutes privileged information that, if released in a public document, could cause undue harm and invasion of Defendant’s privacy and property rights. Additionally, Defendant objects to disclosing his social security number on the grounds that that interrogatory seeks information that is not relevant nor is the information sought likely to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing: Name: Weiqiang Huang Address: 1014 Lake Field Road, Richmond, Texas 77469 DL: 46161103 DOB: 08/18/1984 2. State your complete marital history, including the name or names of current and former spouses, the date of marriage, the date of dissolution of marriage, and the names and ages of children, if any. ANSWER: Defendant objects on the basis that this request seeks information that is not relevant nor reasonably calculated to lead to the discovery of admissible evidence. 3. State your employment history for the ten (10) years prior to the incident and up to and including the date this case is tried, listing the name, address and telephone number of each employer, the name of your immediate supervisor while working for each employer, your job title and the nature of your duties at each employment, the period of time you worked for each employer and the reason each employment was terminated. ANSWER: Defendant objects on the basis that this request is overly broad, vague, ambiguous, and constitutes a prohibited fishing expedition in violation of In re CSX Corp., 124 S.W.3rd 149 (Tex. 2003); K-Mart v. Sanderson, 937 S.W.2d 429 (Tex. 1996); Dillard Department Stores, Inc. v. Hall, 909 S.W.2d 491 (Tex. 1995); and Loftin v. Martin, 776 S.W.2d 145 (Tex. 1989) and as an impermissible fishing expedition which seeks information beyond the subject matter of this case and which will not aid in the resolution of this dispute. 4. Identify, by name, address and telephone number, all persons you will call (whether live, by deposition or by affidavit) to testify at trial. ANSWER: Defendant reserves the right to call all persons identified in discovery by any party hereto. See also Defendant’s Disclosure. 5. Please list in numerical order the names of all insurers, policy numbers and limits of liability of any and all insurance policies and agreements, including any and all primary coverage, secondary coverage, excess insurance coverage of any type, kind or character, between the Defendant, and any and all insurance firms, corporations or businesses carrying on insurance business, by reason of which the insurance firm, corporation or business may be liable to satisfy all or part of the judgment which may be rendered in this action against the Defendant, or to indemnify or reimburse the Defendant for payment made to satisfy such judgment. This request includes complete information regarding the limits of all insurance coverage in effect at the time of the incident in question. Although insurance documents may be provided in response to Plaintiff's Request for Production, Plaintiff will still expect an answer to this interrogatory in that it is a sworn answer as to the existence of liability insurance. ANSWER: Defendant objects to this interrogatory as stated as it is duplicative of Requests for Disclosure. 6. If you have ever pled guilty to, been indicted or convicted of any crime other than traffic violations, please state: a. The nature of the offense. b. The date. c. The county and state in which you were tried. d. The sentence given you. ANSWER: Defendant objects on the basis that this request exceeds the scope of discovery under Tex.R.Civ.P. 192.3 and seeks information that is not relevant nor reasonably calculated to lead to the discovery of admissible evidence. 7. State the date of each and every vehicular collision of which you have been involved, as well as the names, addresses and telephone numbers of the persons involved. ANSWER: Defendant objects to this interrogatory, as stated, because it is vague, overbroad in terms of time and scope, is unduly burdensome, and constitutes a "fishing expedition." See In Re CSX Corp., 124 S.W.3d 149 (Tex. 2003); K-Mart Corp. v. Sanderson, 937 S.W.2d 429 (Tex. 1996); Dillard Dept. Stores, Inc., v. Hall, 909 S.W.2d 491 (Tex. 1995); and Loftin v. Martin, 776 S.W.2d 145 (Tex. 1989). 8. If you have ever had a license to operate a motor vehicle suspended or revoked, please state: a. When and where it was suspended or revoked. b. Why it was suspended or revoked. c. The period of such suspension or revocation. d. Whether such suspension or revocation was lifted. ANSWER: Defendant objects on the basis that this request seeks information that is not relevant nor reasonably calculated to lead to the discovery of admissible evidence. 9. If you have ever been involved in any other legal action, either as a Defendant or as a Plaintiff, please give a description of the nature of such action, including the court and cause number. ANSWER: Defendant objects to this interrogatory, as stated, because it is vague, overbroad in terms of time and scope, is unduly burdensome, and constitutes a "fishing expedition." See In Re CSX Corp., 124 S.W.3d 149 (Tex. 2003); K-Mart Corp. v. Sanderson, 937 S.W.2d 429 (Tex. 1996); Dillard Dept. Stores, Inc., v. Hall, 909 S.W.2d 491 (Tex. 1995); and Loftin v. Martin, 776 S.W.2d 145 (Tex. 1989). 10. Were you the operator of a vehicle involved in the incident made the basis of this litigation? ANSWER: Defendant was the owner of the vehicle involved in the incident made the basis of this litigation. 11. Were you the owner of the vehicle in question on the date and time of the incident made the basis of this litigation? If not, please state the name and address of the owner of the vehicle. ANSWER: Defendant was the owner of the vehicle involved in the incident made the basis of this litigation. 12. Were you given permission to drive the vehicle in question? If so, give the name, address and telephone number of the person that gave you permission? ANSWER: Not applicable. 13. Were you operating the vehicle in question at the time of the incident while in the course and scope of employment? If so, provide the name, address and telephone number of your employer at the time of the incident? ANSWER: Defendant was not in the course and scope of employment at the time of the accident made basis of this suit. 14. Were you charged with any violation of the law arising out of the incident made the basis of this litigation? If so, state the plea entered by you to such charge and the results of the charge. ANSWER: Defendant objects on the basis that this request exceeds the scope of discovery under Tex.R.Civ.P. 192.3 and seeks information that is not relevant nor reasonably calculated to lead to the discovery of admissible evidence. 15. State, in detail and completely, the manner in which you assert that the incident made the basis of this litigation occurred. ANSWER: Defendant objects as overbroad, unduly burdensome, and harassing. Defendant further objects as an impermissible attempt to limit the testimony of Defendant and require Defendant to marshal evidence. 16. Did you have a wireless communication device/cellular phone in your vehicle at the time of the incident made the basis of this litigation? If so, were you using the wireless communication device/cellular phone at the time of the incident made the basis of this litigation? ANSWER: Defendant objects on the basis that this request is overly broad, vague, ambiguous, and constitutes a prohibited fishing expedition in violation of In re CSX Corp., 124 S.W.3rd 149 (Tex. 2003); K-Mart v. Sanderson, 937 S.W.2d 429 (Tex. 1996); Dillard Department Stores, Inc. v. Hall, 909 S.W.2d 491 (Tex. 1995); and Loftin v. Martin, 776 S.W.2d 145 (Tex. 1989) and as an impermissible fishing expedition which seeks information beyond the subject matter of this case and which will not aid in the resolution of this dispute. Subject to and without waiving the foregoing, Defendant was not using their cell phone at the time of this accident. 17. State whether or not you were familiar with the scene of the incident made the basis of this litigation prior thereto. ANSWER: Defendant objects to this interrogatory to the extent that it seeks to unfairly limit future testimony at deposition or in trial, as the question is more properly one to be asked at Defendant’s deposition, if one is taken. 18. State the speed of your vehicle at all times material to the incident made the basis of this litigation, including specifically your speed at the time of impact, and if your brakes were applied at the time of impact, please state your speed before applying your brakes. ANSWER: Defendant objects to this interrogatory to the extent that it seeks to unfairly limit future testimony at deposition or in trial, as the question is more properly one to be asked at Defendant’s deposition, if one is taken. Defendant further objects to this request as calling for speculation. 19. Please state completely and fully all representations, statements, declarations or admissions made by the Plaintiff or any agents, servants or employees of the Plaintiff. ANSWER: Defendant objects to this request on the grounds that Plaintiff has equal, if not superior, access to the information and/or documents sought. If a moving party can obtain the desired information without resort to discovery, good cause does not exist for producing same. 20. Detail your actions for the eight (8) hours immediately preceding the incident in question, including, but not limited to, your activities and locations during this time, and any and all driving done by you during this period. ANSWER: Defendant objects on the basis that this request is overly broad, vague, ambiguous, and constitutes a prohibited fishing expedition in violation of In re CSX Corp., 124 S.W.3rd 149 (Tex. 2003); K-Mart v. Sanderson, 937 S.W.2d 429 (Tex. 1996); Dillard Department Stores, Inc. v. Hall, 909 S.W.2d 491 (Tex. 1995); and Loftin v. Martin, 776 S.W.2d 145 (Tex. 1989) and as an impermissible fishing expedition which seeks information beyond the subject matter of this case and which will not aid in the resolution of this dispute. 21. State in detail what intoxicating beverages, if any, you had consumed and what drugs or medications (prescription or non-prescription), if any, you had taken during the 24-hour period immediately preceding the incident. Include in your answer the time of consumption, the amount and type of alcohol, drugs or medication, and where or from whom it was acquired. ANSWER: Defendant objects on the basis that this request is overly broad, vague, ambiguous, and constitutes a prohibited fishing expedition in violation of In re CSX Corp., 124 S.W.3rd 149 (Tex. 2003); K-Mart v. Sanderson, 937 S.W. 2d 429 (Tex. 1996); Dillard Department Stores, Inc. v. Hall, 909 S.W. 2d 491 (Tex. 1995); and Loftin v. Martin, 776 S.W. 2d 145 (Tex. 1989). Defendant further objects on the basis that this request exceeds the scope of discovery under Tex.R.Civ.P. 192.3 and seeks information that is not relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving such objections, Defendant was not impaired by any intoxicating substance at the time of the incident in question. 22. Please state whether you intend to impeach Plaintiff or any of Plaintiff's witnesses with evidence of a criminal conviction, pursuant to Tex. R. Civ. Evid. 609. If so, please describe such evidence by giving the name of the accused, the nature of the crime, and the date of the conviction. ANSWER: Defendant is not aware of any at this time. Defendant reserves the right to utilize any criminal information disclosed in discovery by any party and any information disclosed in depositions in this matter. 23. Describe in detail what damage, if any was done to the vehicles in the incident, and give the cost of repair to the vehicles. ANSWER: Defendant objects to this interrogatory as stated as it is duplicative of Requests for Disclosure. Subject to and without waiving the foregoing objection, Defendant would answer as follows: see Defendant’s disclosures 24. Describe in detail what injuries, if any, you received in the incident. ANSWER: Defendant objects as overbroad, unduly burdensome, and harassing. Defendant further objects as an impermissible attempt to limit the testimony of Defendant and require Defendant to marshal evidence. 25. Please state the name and address of each expert consulted whose opinions or impressions have been reviewed by any expert witness whom you expect to call at the trial of this case. ANSWER: Defendant objects to this interrogatory as stated because it impermissibly requests information about Defendant’s testifying expert witnesses in violation of Tex.R.Civ.P. 197.1 which allows parties to request another party to designate and disclose information concerning testifying expert witnesses only through a request for disclosure under Tex.R.Civ.P. 194 and through depositions and reports under Tex.R.Civ.P. 195. See In re City of Georgetown, 53 S.W.3d 328 (Tex. 2001).