Preview
FILED
4/9/2020 2:07 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Loaidi Grove DEPUTY
Cause No. DC-18—18232
Carla Washington In the District Court of
vs. Dallas County, Texas
wwwwwmmm
Primose Houston South Houston, et. al 44th Judicial District
NOTICE OF INTENTION T0 TAKE DEPOSITIONJBX WRITTEN QUESTIONS
To Plaintiffls) by and through their attorney(s) of record: Willie C. Briscoe (The Briscoe Law
Firm,
PLLC). To other party/parties by and through their attomey(s) of record:
YOU WILL TAKE NOTICE THAT twenty (20) days after service of a copy hereof with attached
questions, a deposition by written questions will be taken of Custodian of Records at the address listed
below:
26 - WENDY'S (Employment)
2910 PINE MILL DRIVE, PINE BLUFF, AR 71601
Before a Notary Public for:
U.S. Legal Support Inc.
16825 Northchase Dr., Suite 800
Houston, TX 77060
Which deposition with attached questions
may be used in evidence upon the trial of the above-styled and
numbered cause pending above named court. Notice is further given that request is hereby made as
in the
authorized under Rules 176 and 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 bring and produce for
inspection and photocopying a true and correct copy of records described in the attached
Written
Questions 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.
Emily DeJong Pyle
SBA # 24069598
emily@ahblaw.net
Adkerson, Hauder & Bezney, P.C.
1700 Pacific Avenue
Suite 4450
Dallas,TX 75201
Phone: 214-740-2500; Fax: 214-740-2501
Attorney for Defendant(s)
/s/ Emily DeJong Pyle
Emily DeJong Pyle
Order No.: [29017 (Amy Honey)
CERTIFICATE 0F SERVICE
Ihereby certify that a true and correct copy of the foregoing Notice of Intention to Take Deposition upon
Written Questions was served to the respective parties and/or attorneys of record by certified mail
with return receipt requested; hand delivery; fax; _x_ electronic serve; or UPS.
Dated: 04/09/2020
By permission: /s/ Jessie Hebert
Emily DeJong Pyle
Should you desire copies of
the so obtained, contact our firm.
713-653—7100
Order Nu; 129017 (Amy Honey)
Cause No. DC-18-18232
Carla Washington In the District Court of
vs. mmwaaaa
Dallas County, Texas
Primose Houston South Houston, et. al 44th Judicial District
ATTORNEYS OF RECORD:
Emily DeJong Pyle
Adkerson. Hauder & Bezney, P.C.
1700 Pacific Avenue
Suite 4450
Dallas, TX 75201
Phone: 214-740-2500 Fax: 214-740-2501
Attorney for Defendant(s): Primrose Houston South Housing, L.P., et. al
Willie C. Briscoe
The Briscoe Law Firm, PLLC
12700 Park Centrak Drive
Suite 520
Dallas, TX 75251
Phone: 972-521-6868 Fax: 281-254-7789
Attorney for Plaintiff(s): Carla Washington
Order No. : 129017 (Amy Honey)
Cause No: DC-18-18232
Carla Washington § In the District Court of
§
vs. Dallas County, Texas
g
Primose Houston South Houston, et. al 44th Judicial District
g
WAIVER OF NOTICE
THE PARTIES TO THE ABOVE AGREE TO WAIVE THE TWENTY (20) DAY NOTICE PERIOD FOR THE
ISSUANCE OF A SUBPOENA TO TAKE THE DEPOSITION BY WRITTEN QUESTION OF THE CUSTODIAN
OF RECORDS FOR THE FOLLOWING:
I |
26 WENDY'S (Employment)
I ]
27 DONALD'S (Employment)
[ ]
28 ARBY'S (Employment)
[ ]
29 ARLINGTON INDEPENDENT SCHOOL DISTRICT (Employment)
A SUBPOENA AS AUTHORIZED UNDER RULES 176 AND 200, TEXAS RULES OF CIVIL PROCEDURE,
WILL BE ISSUED FORTHWITH TO DIRECT THE ABOVE NAMED CUSTODIAN OF RECORDS TO MAKE
ALL RECORDS PERTAINING T0:
Carla Washington
AVAILABLE FOR PHOTOGRAPHIC REPRODUCTION. AND TO ANSWER THE DIRECT AND CROSS
WRITTEN QUESTIONS, IF ANY. SAID DEPOSITION, WHEN SO TAKEN, MAY BE RETURNED INTO COURT
TO BE USED IN EVIDENCE UPON THE TRIAL 0F THE ABOVE-NUMBERED CAUSE.
Emily DeJong Pyle
Adkerson, Hauder & Bezney, P.C.
Dallas, TX
ATTORNEY FOR Defendant
“CHECK MARK 0R cmcu:
YES [ ]
WAIVE THE NOTICE PERIOD. N0 [ |
D0 NOT WAIVE THE NOTICE PERIOD.
YES [ 1
N0 [ |
Please send A COPYofthe records indicated above. paper copies CD- only
YES [ ] NO [ ]
Please send X-RAY FILMS and legal papers indicated above.
YES [ ]
NO [ ]
Please send NEGA TIVE DEPOSITION (legal papers)
Please contact Amy Honey if you have any questions. Order Number: 129017
YES [ ]
NO [ ]
PLEASE DIRECT BILL THE COMPANY INDICATED BELOW
Insurance Co. Bill t0: Adjuster:
Address: Adj Phone:
City Claim#:
State, Zip DOL:
Return to: U.S. Legal Support Inc. Phone: 713-653-7100 FAX: 281-673-6292 or txrecords@uslegalsupport.com
Dated:
Signed
Printed Name
NOTE: THE CHARGE FOR EACH RECORD WILL BE $60.00 AND .55 PER PAGE. THE CHARGE FOR X-RAY
FILMS WILL BE $15.00 PER FILM.
Cause No. DC—18-18232
Carla Washington § In the District Court of
§
vs. § Dallas County, Texas
§
Primose Houston South Houston, et. a1 § 44th Judicial District
DIRECT QUESTIONS T0 BE PROPOUNDED TO THE WITNESS
Custodian of Records for: WENDY'S
Records Pertaining to: Carla Washington
Type of Records: any and all employment file records, including but not limited t0, personnel records,
application for employment, correSpondence and/or memoranda, records reflating to
reviews and/or promotions, days absent and/or time lost, pre—employment physical(s),
post—employment physical(s), post—offer physical(s), employment history, correSpondence,
medical records, letters of recommendation, reasons for termination or leaving,
reprimands, time cards, time sheets, records relating to lost wages, workers’ compensation
records and/or claims, insurance records and/or claims, payroll records, W-2 forms, W—4
forms, 1099 forms, and any other records contained in your office(s) pertaining to the
employment of Carla Washington; DOB: 10/10/1962; SSN: xxx—xx-9215
1. Please state your full name, address, telephone number: occupation and official title.
ANSWER
2. I am the custodian for
(Please insert facility or practitioner name.)
3. Have you received a subpoena duces tecum for the production of those documents listed above?
ANSWER
4. Are you among those who have possession, custody, control of, or access to the documents requested
above?
ANSWER
5. Were the records requested above made in the regular course of business?
ANSWER
6. Was it in the regular course of business of the above listed facility or practitioner for a person with
knowledge of the act, event, condition, opinion, or diagnosis recorded to make the record 0r to transmit
information thereof t0 be included in such record?
ANSWER
Order Na. 1290l7.026 (Amy Honey)
State whether these records were made at the time or shortly after the time of the transactions recorded?
ANSWER
Were these records kept as described in the preceding questions?
ANSWER
Does the source of the information, and the method and circumstance of its preparation, establish the
trustworthiness of the records?
ANSWER
10. Please release exact duplicates of the records as requested in the subpoena duces tecum or the originals
thereof for photocopying for attachment to this deposition. Have you done as requested? If not, why not?
ANSWER
11. Are there any records, documents, papers, correspondence or tangible matters of any kind pertaining to
Carla Washington that you have NOT provided to the notaly public taking your deposition?
ANSWER
12. Please describe all papers, documents, records. correspondence, or tangible matters of any kind that you
have not provided to the notary public taking your deposition and explain why you have NOT provided
them.
ANSWER
l3. Are you aware that it may be necessary to subpoena you or your employer to court at the time of the trial
of this case, if you have not provided to the notary public taking your deposition all papers, documents,
records. correspondence, or tangible matters of any kind pertaining to Carla Washington?
ANSWER
WITNESS (Custodian of Records)
Before me, the undersigned authority, on this day personally appeared
, custodian of records for the above listed. 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 of the original records.
SWORN TO AND SUBSCRIBED before me this day of ,
20
NOTARY PUBLIC
Order No.: 129017.026 (Amy Honey)
Cause No. DC-18-18232
§
Carla Washington In the District Court of
g
vs. Dallas County, Texas
g
Primose Houston South Houston, et. a] 44th Judicial District
g
§
NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS
To Plaintiff(s) by and through their attorney(s) of record: Willie C. Briscoe (The Briscoe Law Firm,
PLLC). To other party/parties by and through their attomey(s) of record:
YOU WILL TAKE NOTICE THAT twenty (20) days after service of a copy hereof with attached
questions, a deposition by written questions will be taken of Custodian of Records at the address listed
below:
26 - WENDY'S (Employment)
2910 PINE MILL DRIVE, PINE BLUFF, AR 71601
Before a Notary Public for:
U.S. Legal Support Inc.
16825 Northchase Dr., Suite 800
Houston, TX 77060
Which may be used in evidence upon the trial of the above-styied and
deposition with attached questions
numbered cause pending above named coun. Notice is further given that request is hereby made as
in the
authorized under Ruies 176 and 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 bring and produce for
inspection and photocopying a true and correct copy of records described in the attached Written
Questions 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.
Emily DeJong Pyle
SBA # 24069598
emily@ahblaw.net
Adkerson, Hauder & Bezney, P.C.
1700 Pacific Avenue
Suite 4450
Dallas,TX 75201
Phone: 214-740-2500; Fax: 214-740-2501
Attorney for Defendant“)
Emily DeJong Pyle
/s/
Emily DeJong Pyle
Order No.: 12901 7 (Amy Haney)
CERTIFICATE 0F SERVICE
Ihereby certify that a true and correct copy of the foregoing Notice of Intention to Take Deposition upon
__
Written Questions was served to the respective parties and/or attorneys of record by certified mail
with return receipt requested; _ hand delivery;____ fax; _x_ electronic serve; or UPS.
Dated: 04/09/2020
By permission: ls/ Jessie Hebert
Emily DeJong Pyle
Should you desire copies of
the so obtained, contact our firm.
713—653-7100
Order No; 129017 (Amy Honey)
Cause No. DC-18-18232
§
Carla Washington § In the District Court of
§
vs. Dallas County, Texas
g
Primose Houston South Houston, et. al 44th Judicial District
g
ATTORNEYS OF RECORD:
Emily DeJong Pyle
Adkerson, Hauder &
Bezney. P.C.
I700 Pacific Avenue
Suite 4450
Dallas, TX 75201
Phone: 214-740-2500 Fax: 214-740-2501
Attorney for Defendant(s): Primrose Houston South Housing, L.P., et. a1
Willie C. Briscoe
The Briscoe Law Finn, PLLC
12700 Park Centrak Drive
Suite520
Dallas, TX 7525]
Phone: 972-521-6868 Fax: 281-254-7789
Attorney for Plaintiff(s): Carla Washington
Order No. : 129017 (Amy Honey)
Cause N0. DC-18-18232
Carla Washington § In the District Court of
§
vs. § Dallas County, Texas
§
Primose Houston South Houston, et. a] § 44th Judicial District
DIRECT UESTIONS T0 BE PROPOUNDED TO THE WITNESS
Custodian of Records for: DONALD’S
Records Pertaining to: Carla Washington
Type of Records: any and employment file records, including but not limited to, personnel records,
all
application for employment, correspondence and/or memoranda, records relating to
reviews and/or promotions, days absent and/or time lost, pre—employment physical(s),
post-employment physical(s), post-offer physical(s), employment history, correspondence,
medical records, letters of recommendation, reasons for termination or leaving,
reprimands, time cards, time sheets, records relating to lost wages, workers‘ compensation
records and/or claims, insurance records and/or claims, payroll records, W-2 forms, W-4
forms, 1099 forms, and any other records contained in your office(s) pertaining to the
employment of Carla Washington; DOB: 10/10/1962; SSN: xxx-xx-9215
1. Please state your fiJll name, address, telephone number, occupation and official title.
ANSWER
2. I am the custodian for
(Please insen facility or practitioner name.)
3. Have you received a subpoena duces tecum for the production of those documents listed above?
ANSWER
4. Are you among those who have possession, custody, control of, or access to the documents requested
above?
ANSWER
S. Were the records requested above made in the regular course of business?
ANSWER
6. Was it in the regular course of business of the above listed facility or practitioner for a person with
knowledge 0f the act, event, condition, opinion, or diagnosis recorded to make the record or to transmit
information thereof t0 be included in such record?
ANSWER
Order No.: 129017.027 (Amy Honey)
State whether these records were made at the time or shortly after the time of the transactions recorded?
ANSWER
Were these records kept as described in the preceding questions?
ANSWER
Does the source of the information, and the method and circumstance of its preparation, estabiish the
trustworthiness of the records?
ANSWER
10. Please release exact duplicates of the records as requested in the subpoena duces tecum or the originals
thereof for photocopying for attachment t0 this deposition. Have you done as requested? If not, why not?
ANSWER
11. Are there any records, documents, papers, correspondence or tangible matters of any kind pertaining to
Carla Washington that you have NOT provided t0 the notary public taking your deposition?
ANSWER
12. Please describe papers, documents, records, correspondence, or tangible matters of any kind that you
all
have not provided to the notary public taking your deposition and explain why you have NOT provided
them.
ANSWER
13. Are you aware that it may be necessary to subpoena you or your employer to court at the time of the trial
of this case, if you have not provided to the notary public taking your deposition all papers, documents.
records, correspondence, or tangible matters 0f any kind pertaining to Carla Washington?
ANSWER
WITNESS (Custodian of Records)
Before me, the undersigned authority, on this day personally appeared
custodian of records for the above listed, known to me to
,
be the person whose name
subscribed to the foregoing instrument in the capacity therein stated, who being first
is
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 of the original records.
SWORN TO AND SUBSCRIBED before me this day of , 20
NOTARY PUBLIC
Order No.; 129017.027 (Amy Honey)
Cause N0. DC-18-18232
Carla Washington In the District Court of
vs. mwmmwwmm
Dallas County, Texas
Primose Houston South Houston, et. al 44th Judicial District
NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS
To Plaintiffls) by and through their attorney(s) of record: Willie C. Briscoe (The Briscoe Law Firm,
PLLC). To other party/parties by and through their attomey(s) of record:
YOU WILL TAKE NOTICE THAT twenty (20) days after service of a copy hereof with attached
questions, a deposition by written questions will be taken of Custodian of Records at the address listed
below:
26 - WENDY'S (Employment)
2910 PINE MILL DRIVE, PINE BLUFF, AR 71601
Before a Notary Public for:
U.S. Legal Support Inc.
16825 Northchase Dr., Suite 800
Houston, TX 77060
Which may be used in evidence upon the trial of the above-styled and
deposition with attached questions
numbered cause pending above named court. Notice is further given that request is hereby made as
in the
authorized under Rules 176 and 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 bring and produce for
inspection and photocopying a true and correct copy of records described in the attached Written
Questions and to turn aII 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.
Emily DeJong Pyle
SBA # 24069598
emily@ahblaw.net
Adkerson, Hauder & Bezney, P.C.
1700 Pacific Avenue
Suite 4450
Dallas, TX 75201
Phone: 214-740-2500; Fax: 214-740—2501
Attorney for Defendant(s)
/s/ Emily DeJong Pyle
Emily DeJong Pyle
Order No.2 129017 (Amy Hnncy)
CERTIFICATE OF SERVICE
Ihereby certify that a true and correct copy of the foregoing Notice of Intention t0 Take Deposition upon
Written Questions was served to the respective parties and/or attorneys of record by certified mail
with return receipt requested; _ hand delivery;_ fax; _x_ _
electronic serve; or UPS.
Dated: 04/09/2020
By permission: ls/ Jessie Hebert
Emily DeJong Pyle
Should you desire copies of
the so obtained, contact our firm.
71 3-653-7100
Order No; 129017 (Amy Honey)
Cause No. DC-18-18232
§
Carla Washington § In the District Court 0f
§
vs.
Dallas County, Texas
g
Primose Houston South Houston, et. al 44th Judicial District
g
ATTORNEYS 0F RECORD:
Emily DeJong Pyle
Adkerson, Hauder &
Bezney, P.C.
I700 Pacific Avenue
Suite 4450
Dallas, TX 75201
Phone: 214-740-2500 Fax: 214—740-2501
Attorney for Defendant(s): Primrose Houston South Housing, L.P., et. a1
Willie C. Bn'scoe
The Briscoe Law Firm, PLLC
12700 Park Centrak Drive
Suite 520
Dallas, TX 75251
Phone: 972-521-6868 Fax: 281-254-7789
Attorney for Plaintiffls): Carla Washington
Order No. : 129017 (Amy Honey)
Cause No. DC-18-18232
Carla Washington § In the District Court of
§
vs. § Dallas County, Texas
§
Primose Houston South Houston, et. al § 44th Judicial District
DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS
Custodian of Records for: ARBY‘S
Records Pertaining to: Carla Washington
Type of Records: any and employment file records, including but not limited to, personnel records,
all
application for employment, correspondence and/or memoranda, records relating t0
reviews and/or promotions, days absent and/or time lost, pre-employment physicaKs),
post—employment physical(s), post-offer physical(s), employment history, correspondence,
medical records, letters of recommendation, reasons for termination or leaving,
reprimands, time cards, time sheets, records relating to lost wages, workers' compensation
records and/or claims, insurance records and/or claims, payroll records, W-2 forms, W-4
forms, 1099 forms, and any other records contained in your office(s) pertaining to the
employment 0f Carla Washington; DOB: 10/10/1962; SSN: xxx-xx-9215
1. Please state your full name, address, telephone number, occupation and official title.
ANSWER
2. I am the custodian for
(Please insert facility or practitioner name.)
3. Have you received a subpoena duces tecum for the production of those documents listed above?
ANSWER
4. Are you among those who have possession, custody, control of. or access to the documents requested
above?
ANSWER
5. Were the records requested above made in the regular courSe of business?
ANSWER
6. Was it in the regular
course of business of the above listed facility or practitioner for a person with
knowledge of the opinion, or diagnosis recorded to make the record or to transmit
act, event, condition,
information thereof to be included in such record?
ANSWER
Order No.: 1290l7.028 (Amy Honey)
State whether these records were made at the time or shortly after the time of the transactions recorded?
ANSWER
Were these records kept as described in the preceding questions?
ANSWER
Does the source of the information, and the method and circumstance of its preparation, establish the
trustworthiness of the records?
ANSWER
10. Please release exact duplicates of the records as requested in the subpoena duces tecum 0r
the originals
thereof for photocopying for attachment to this deposition. Have you done as requested? If
not, why not?
ANSWER
11. Are there any records, documents, papers. correspondence or tangible matters 0f any kind pertaining to
Carla Washington that you have NOT provided to the notary public taking your deposition?
ANSWER
12. Please describeall papers, documents, records, correspondence, or tangible matters
of any kind that you
have not provided to the notary public taking your deposition and explain why you have NOT
provided
them.
ANSWER
13. Are you aware that it may be necessaly to subpoena you or your employer to court at the time 0f the trial
of this case, if you have not provided to the notary public taking your deposition all
papers, documents.
records, correspondence, or tangible matters of any kind pertaining to Carla Washington?
ANSWER
WITNESS (Custodian of Records)
Before me, the undersigned authority, on this day personally appeared
custodian of records for the above listed. knowu to me to
,
be the person whose name
subscribed to the foregoing instrument in the capacity therein stated, who being first
is
duly sworn, stated upon his/her oath that the answers to the foregoing questions are true and correct. 1 further
certify that the records attached hereto are exact duplicates of the original records.
SWORN T0 AND SUBSCRIBED before me this day of , 20
NOTARY PUBLIC
Order Na: 1290l7.028 (Amy Honey)
Cause No. DC-18-18232
Carla Washington In the District Court of
vs. wwwwwwmm
Dallas County, Texas
Primose Houston South Houston, et. al 44th Judicial District
NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS
To Plaintiff(s) by and through their attorney(s) of record: Willie C. Briscoe (The Briscoe Law Firm,
PLLC). To other party/parties by and through their attorney(s) of record:
YOU WILL TAKE NOTICE THAT twenty (20) days after service of a copy hereof with attached
questions, a deposition by written questions will be taken of Custodian of Records at the address listed
below:
26 - WENDY'S (Employment)
2910 PINE MILL DRIVE, PINE BLUFF, AR 71601
Before a Notary Public for:
U.S. Legal Support Inc.
16825 Northchase Dr., Suite 800
Houston, TX 77060
Which may be used in evidence upon the trial of the above-styled and
deposition with attached questions
numbered cause pending above named court. Notice is further given that request is hereby made as
in the
authorized under Rules 176 and 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 bring and produce for
inspection and photocopying a true and correct copy of records described in the attached Written
Questions 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.
Emily DeJong Pyle
SBA # 24069598
emily@ahblaw.net
Adkerson, I-Iauder & Bezney, P.C.
1700 Pacific Avenue
Suite 4450
Dallas, TX 75201
Phone: 214-740-2500; Fax: 214—740-250]
Attorney for Defendant(s)
Emily DeJong Pyle
/s/
Emily DeJong Pyle
Order No; 119017 (Amy Honey)
CERTIFICATE OF SERVICE
Ihereby certify that a true and correct copy of the foregoing Notice of Intention to Take Deposition upon
Written Questions was served to the respective parties and/or attorneys of record
with return receipt requested; ___ hand delivery;
_ _x_
fax; __
electronic serve; or
_
by
UPS.
certified mail
Dated: 04/09/2020
By permission: ls/ Jessie Hebefl
Emily DeJong Pyle
Should you desire copies of
the so obtained, contact our firm.
713-653-7100
Order No.: 129017 (Amy Honey)
Cause N0. DC-18-18232
§
Carla Washington § In the District Court of
§
vs. Dallas County, Texas
g
Primose Houston South Houston, et. a] 44th Judicial District
g
ATTORNEYS 0F RECORD:
Emily DeJong Pyle
Adkerson, Hauder &
Bezney, P.C.
1700 Pacific Avenue
Suite 4450
Dallas, TX 75201
Phone: 214-740-2500 Fax: 214-740-2501
Attorney for Defendant(s): Primrose Houston South Housing, L.P., et. al
Willie C. Briscoe
The Briscoe Law Firm, PLLC
12700 Park Centrak Dn've
Suite 520
Dallas, TX 75251
Phone: 972-521-6868 Fax: 28 [-254-7789
Attorney for Plaintiff(s): Carla Washington
Order Nu. : 129017 (Amy Honey)
Cause No. DC-18-18232
Carla Washington In the District Court of
vs. mmmma
Dallas County, Texas
Primose Houston South Houston, et. al 44th Judicial District
DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS
Custodian of Records for: ARLINGTON INDEPENDENT SCHOOL DISTRICT
Records Pertaining to: Carla Washington
Type of Records: any and alt employment file records, including but not limited to, personnel records,
application for employment, correspondence and/or memoranda, records relating to
reviews and/or promotions, days absent and/or time lost, pre—employment physical(s),
post—employment physical(s), post-offer physicaKs), employment history, correspondence,
medical records, letters of recommendation, reasons for termination or leaving,
reprimands, time cards, time sheets, records relating to lost wages, workers’ compensation
records and/or claims, insurance records and/or claims, payroll records, W-2 forms, W-4
forms, 1099 forms, and any other records contained in your office(s) pertaining to the
employment 0f Carla Washington; DOB: 10/10/1962; SSN: xxx—xx-9215
1. Please state your full name, address, telephone number, occupation and official title.
ANSWER
2. I am the custodian for
(Please insert facility or practitioner name.)
3. Have you received a subpoena duces tecum for the production ofthose documents listed above?
ANSWER
4. Are you among those who have possession, custody, control of, or access to the documents requested
above?
ANSWER
5. Were the records requested above made in the regular course of business?
ANSWER
6. Was it in the regular course of business of the above listed facility or practitioner for a person with
knowledge of the act, event, condition, opinion, or diagnosis recorded to make the record or to transmit
information thereof t0 be included in such record?
ANSWER
Order Nu: l290l7.029 (Amy Honey)
State whether these records were made at the time or shortly after the time of the transactions recorded?
ANSWER
Were these records kept as described in the preceding questions?
ANSWER
Does the source of the information, and the method and circumstance of its preparation, establish the
trustworthiness of the records?
ANSWER
10. Please release exact duplicates of the records as requested in the subpoena duces
tecum or the originals
thereof for photocopying for attachment to this deposition. Have
you done as requested? 1f not, why not?
ANSWER
11. Are there any records, documents, papers, correspondence or tangible matters of
any kind pertaining to
Carla Washington that you have NOT provided to the notary public taking
your deposition?
ANSWER
12. Please describe papers, documents, records, correSpondence, or tangible matters of
all
any kind that you
have not provided to the notary public taking your deposition and explain
why you have NOT provided
them.
ANSWER
13. Are you aware that it may be necessary to subpoena you or your employer to court at
the time of the trial
of this case, if you have not provided to the notary public taking your deposition
all papers, documents,
records, correspondence, or tangible matters of any kind pertaining to Carla Washington?
ANSWER
WITNESS (Custodian of Records)
Before me, the undersigned authority, on this day personally appeared
,custodian of records for the above listed, known to me to
be the person whose name is subscribed to the foregoing instrument in the capacity therein stated, who being
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FILED 4/9/2020 2:07 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Loaidi Grove DEPUTY Cause No. DC-18—18232 Carla Washington In the District Court of vs. Dallas County, Texas wwwwwmmm Primose Houston South Houston, et. al 44th Judicial District NOTICE OF INTENTION T0 TAKE DEPOSITIONJBX WRITTEN QUESTIONS To Plaintiffls) by and through their attorney(s) of record: Willie C. Briscoe (The Briscoe Law Firm, PLLC). To other party/parties by and through their attomey(s) of record: YOU WILL TAKE NOTICE THAT twenty (20) days after service of a copy hereof with attached questions, a deposition by written questions will be taken of Custodian of Records at the address listed below: 26 - WENDY'S (Employment) 2910 PINE MILL DRIVE, PINE BLUFF, AR 71601 Before a Notary Public for: U.S. Legal Support Inc. 16825 Northchase Dr., Suite 800 Houston, TX 77060 Which deposition with attached questions may be used in evidence upon the trial of the above-styled and numbered cause pending above named court. Notice is further given that request is hereby made as in the authorized under Rules 176 and 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 bring and produce for inspection and photocopying a true and correct copy of records described in the attached Written Questions 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. Emily DeJong Pyle SBA # 24069598 emily@ahblaw.net Adkerson, Hauder & Bezney, P.C. 1700 Pacific Avenue Suite 4450 Dallas,TX 75201 Phone: 214-740-2500; Fax: 214-740-2501 Attorney for Defendant(s) /s/ Emily DeJong Pyle Emily DeJong Pyle Order No.: [29017 (Amy Honey) CERTIFICATE 0F SERVICE Ihereby certify that a true and correct copy of the foregoing Notice of Intention to Take Deposition upon Written Questions was served to the respective parties and/or attorneys of record by certified mail with return receipt requested; hand delivery; fax; _x_ electronic serve; or UPS. Dated: 04/09/2020 By permission: /s/ Jessie Hebert Emily DeJong Pyle Should you desire copies of the so obtained, contact our firm. 713-653—7100 Order Nu; 129017 (Amy Honey) Cause No. DC-18-18232 Carla Washington In the District Court of vs. mmwaaaa Dallas County, Texas Primose Houston South Houston, et. al 44th Judicial District ATTORNEYS OF RECORD: Emily DeJong Pyle Adkerson. Hauder & Bezney, P.C. 1700 Pacific Avenue Suite 4450 Dallas, TX 75201 Phone: 214-740-2500 Fax: 214-740-2501 Attorney for Defendant(s): Primrose Houston South Housing, L.P., et. al Willie C. Briscoe The Briscoe Law Firm, PLLC 12700 Park Centrak Drive Suite 520 Dallas, TX 75251 Phone: 972-521-6868 Fax: 281-254-7789 Attorney for Plaintiff(s): Carla Washington Order No. : 129017 (Amy Honey) Cause No: DC-18-18232 Carla Washington § In the District Court of § vs. Dallas County, Texas g Primose Houston South Houston, et. al 44th Judicial District g WAIVER OF NOTICE THE PARTIES TO THE ABOVE AGREE TO WAIVE THE TWENTY (20) DAY NOTICE PERIOD FOR THE ISSUANCE OF A SUBPOENA TO TAKE THE DEPOSITION BY WRITTEN QUESTION OF THE CUSTODIAN OF RECORDS FOR THE FOLLOWING: I | 26 WENDY'S (Employment) I ] 27 DONALD'S (Employment) [ ] 28 ARBY'S (Employment) [ ] 29 ARLINGTON INDEPENDENT SCHOOL DISTRICT (Employment) A SUBPOENA AS AUTHORIZED UNDER RULES 176 AND 200, TEXAS RULES OF CIVIL PROCEDURE, WILL BE ISSUED FORTHWITH TO DIRECT THE ABOVE NAMED CUSTODIAN OF RECORDS TO MAKE ALL RECORDS PERTAINING T0: Carla Washington AVAILABLE FOR PHOTOGRAPHIC REPRODUCTION. AND TO ANSWER THE DIRECT AND CROSS WRITTEN QUESTIONS, IF ANY. SAID DEPOSITION, WHEN SO TAKEN, MAY BE RETURNED INTO COURT TO BE USED IN EVIDENCE UPON THE TRIAL 0F THE ABOVE-NUMBERED CAUSE. Emily DeJong Pyle Adkerson, Hauder & Bezney, P.C. Dallas, TX ATTORNEY FOR Defendant “CHECK MARK 0R cmcu: YES [ ] WAIVE THE NOTICE PERIOD. N0 [ | D0 NOT WAIVE THE NOTICE PERIOD. YES [ 1 N0 [ | Please send A COPYofthe records indicated above. paper copies CD- only YES [ ] NO [ ] Please send X-RAY FILMS and legal papers indicated above. YES [ ] NO [ ] Please send NEGA TIVE DEPOSITION (legal papers) Please contact Amy Honey if you have any questions. Order Number: 129017 YES [ ] NO [ ] PLEASE DIRECT BILL THE COMPANY INDICATED BELOW Insurance Co. Bill t0: Adjuster: Address: Adj Phone: City Claim#: State, Zip DOL: Return to: U.S. Legal Support Inc. Phone: 713-653-7100 FAX: 281-673-6292 or txrecords@uslegalsupport.com Dated: Signed Printed Name NOTE: THE CHARGE FOR EACH RECORD WILL BE $60.00 AND .55 PER PAGE. THE CHARGE FOR X-RAY FILMS WILL BE $15.00 PER FILM. Cause No. DC—18-18232 Carla Washington § In the District Court of § vs. § Dallas County, Texas § Primose Houston South Houston, et. a1 § 44th Judicial District DIRECT QUESTIONS T0 BE PROPOUNDED TO THE WITNESS Custodian of Records for: WENDY'S Records Pertaining to: Carla Washington Type of Records: any and all employment file records, including but not limited t0, personnel records, application for employment, correSpondence and/or memoranda, records reflating to reviews and/or promotions, days absent and/or time lost, pre—employment physical(s), post—employment physical(s), post—offer physical(s), employment history, correSpondence, medical records, letters of recommendation, reasons for termination or leaving, reprimands, time cards, time sheets, records relating to lost wages, workers’ compensation records and/or claims, insurance records and/or claims, payroll records, W-2 forms, W—4 forms, 1099 forms, and any other records contained in your office(s) pertaining to the employment of Carla Washington; DOB: 10/10/1962; SSN: xxx—xx-9215 1. Please state your full name, address, telephone number: occupation and official title. ANSWER 2. I am the custodian for (Please insert facility or practitioner name.) 3. Have you received a subpoena duces tecum for the production of those documents listed above? ANSWER 4. Are you among those who have possession, custody, control of, or access to the documents requested above? ANSWER 5. Were the records requested above made in the regular course of business? ANSWER 6. Was it in the regular course of business of the above listed facility or practitioner for a person with knowledge of the act, event, condition, opinion, or diagnosis recorded to make the record 0r to transmit information thereof t0 be included in such record? ANSWER Order Na. 1290l7.026 (Amy Honey) State whether these records were made at the time or shortly after the time of the transactions recorded? ANSWER Were these records kept as described in the preceding questions? ANSWER Does the source of the information, and the method and circumstance of its preparation, establish the trustworthiness of the records? ANSWER 10. Please release exact duplicates of the records as requested in the subpoena duces tecum or the originals thereof for photocopying for attachment to this deposition. Have you done as requested? If not, why not? ANSWER 11. Are there any records, documents, papers, correspondence or tangible matters of any kind pertaining to Carla Washington that you have NOT provided to the notaly public taking your deposition? ANSWER 12. Please describe all papers, documents, records. correspondence, or tangible matters of any kind that you have not provided to the notary public taking your deposition and explain why you have NOT provided them. ANSWER l3. Are you aware that it may be necessary to subpoena you or your employer to court at the time of the trial of this case, if you have not provided to the notary public taking your deposition all papers, documents, records. correspondence, or tangible matters of any kind pertaining to Carla Washington? ANSWER WITNESS (Custodian of Records) Before me, the undersigned authority, on this day personally appeared , custodian of records for the above listed. 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 of the original records. SWORN TO AND SUBSCRIBED before me this day of , 20 NOTARY PUBLIC Order No.: 129017.026 (Amy Honey) Cause No. DC-18-18232 § Carla Washington In the District Court of g vs. Dallas County, Texas g Primose Houston South Houston, et. a] 44th Judicial District g § NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS To Plaintiff(s) by and through their attorney(s) of record: Willie C. Briscoe (The Briscoe Law Firm, PLLC). To other party/parties by and through their attomey(s) of record: YOU WILL TAKE NOTICE THAT twenty (20) days after service of a copy hereof with attached questions, a deposition by written questions will be taken of Custodian of Records at the address listed below: 26 - WENDY'S (Employment) 2910 PINE MILL DRIVE, PINE BLUFF, AR 71601 Before a Notary Public for: U.S. Legal Support Inc. 16825 Northchase Dr., Suite 800 Houston, TX 77060 Which may be used in evidence upon the trial of the above-styied and deposition with attached questions numbered cause pending above named coun. Notice is further given that request is hereby made as in the authorized under Ruies 176 and 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 bring and produce for inspection and photocopying a true and correct copy of records described in the attached Written Questions 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. Emily DeJong Pyle SBA # 24069598 emily@ahblaw.net Adkerson, Hauder & Bezney, P.C. 1700 Pacific Avenue Suite 4450 Dallas,TX 75201 Phone: 214-740-2500; Fax: 214-740-2501 Attorney for Defendant“) Emily DeJong Pyle /s/ Emily DeJong Pyle Order No.: 12901 7 (Amy Haney) CERTIFICATE 0F SERVICE Ihereby certify that a true and correct copy of the foregoing Notice of Intention to Take Deposition upon __ Written Questions was served to the respective parties and/or attorneys of record by certified mail with return receipt requested; _ hand delivery;____ fax; _x_ electronic serve; or UPS. Dated: 04/09/2020 By permission: ls/ Jessie Hebert Emily DeJong Pyle Should you desire copies of the so obtained, contact our firm. 713—653-7100 Order No; 129017 (Amy Honey) Cause No. DC-18-18232 § Carla Washington § In the District Court of § vs. Dallas County, Texas g Primose Houston South Houston, et. al 44th Judicial District g ATTORNEYS OF RECORD: Emily DeJong Pyle Adkerson, Hauder & Bezney. P.C. I700 Pacific Avenue Suite 4450 Dallas, TX 75201 Phone: 214-740-2500 Fax: 214-740-2501 Attorney for Defendant(s): Primrose Houston South Housing, L.P., et. a1 Willie C. Briscoe The Briscoe Law Finn, PLLC 12700 Park Centrak Drive Suite520 Dallas, TX 7525] Phone: 972-521-6868 Fax: 281-254-7789 Attorney for Plaintiff(s): Carla Washington Order No. : 129017 (Amy Honey) Cause N0. DC-18-18232 Carla Washington § In the District Court of § vs. § Dallas County, Texas § Primose Houston South Houston, et. a] § 44th Judicial District DIRECT UESTIONS T0 BE PROPOUNDED TO THE WITNESS Custodian of Records for: DONALD’S Records Pertaining to: Carla Washington Type of Records: any and employment file records, including but not limited to, personnel records, all application for employment, correspondence and/or memoranda, records relating to reviews and/or promotions, days absent and/or time lost, pre—employment physical(s), post-employment physical(s), post-offer physical(s), employment history, correspondence, medical records, letters of recommendation, reasons for termination or leaving, reprimands, time cards, time sheets, records relating to lost wages, workers‘ compensation records and/or claims, insurance records and/or claims, payroll records, W-2 forms, W-4 forms, 1099 forms, and any other records contained in your office(s) pertaining to the employment of Carla Washington; DOB: 10/10/1962; SSN: xxx-xx-9215 1. Please state your fiJll name, address, telephone number, occupation and official title. ANSWER 2. I am the custodian for (Please insen facility or practitioner name.) 3. Have you received a subpoena duces tecum for the production of those documents listed above? ANSWER 4. Are you among those who have possession, custody, control of, or access to the documents requested above? ANSWER S. Were the records requested above made in the regular course of business? ANSWER 6. Was it in the regular course of business of the above listed facility or practitioner for a person with knowledge 0f the act, event, condition, opinion, or diagnosis recorded to make the record or to transmit information thereof t0 be included in such record? ANSWER Order No.: 129017.027 (Amy Honey) State whether these records were made at the time or shortly after the time of the transactions recorded? ANSWER Were these records kept as described in the preceding questions? ANSWER Does the source of the information, and the method and circumstance of its preparation, estabiish the trustworthiness of the records? ANSWER 10. Please release exact duplicates of the records as requested in the subpoena duces tecum or the originals thereof for photocopying for attachment t0 this deposition. Have you done as requested? If not, why not? ANSWER 11. Are there any records, documents, papers, correspondence or tangible matters of any kind pertaining to Carla Washington that you have NOT provided t0 the notary public taking your deposition? ANSWER 12. Please describe papers, documents, records, correspondence, or tangible matters of any kind that you all have not provided to the notary public taking your deposition and explain why you have NOT provided them. ANSWER 13. Are you aware that it may be necessary to subpoena you or your employer to court at the time of the trial of this case, if you have not provided to the notary public taking your deposition all papers, documents. records, correspondence, or tangible matters 0f any kind pertaining to Carla Washington? ANSWER WITNESS (Custodian of Records) Before me, the undersigned authority, on this day personally appeared custodian of records for the above listed, known to me to , be the person whose name subscribed to the foregoing instrument in the capacity therein stated, who being first is 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 of the original records. SWORN TO AND SUBSCRIBED before me this day of , 20 NOTARY PUBLIC Order No.; 129017.027 (Amy Honey) Cause N0. DC-18-18232 Carla Washington In the District Court of vs. mwmmwwmm Dallas County, Texas Primose Houston South Houston, et. al 44th Judicial District NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS To Plaintiffls) by and through their attorney(s) of record: Willie C. Briscoe (The Briscoe Law Firm, PLLC). To other party/parties by and through their attomey(s) of record: YOU WILL TAKE NOTICE THAT twenty (20) days after service of a copy hereof with attached questions, a deposition by written questions will be taken of Custodian of Records at the address listed below: 26 - WENDY'S (Employment) 2910 PINE MILL DRIVE, PINE BLUFF, AR 71601 Before a Notary Public for: U.S. Legal Support Inc. 16825 Northchase Dr., Suite 800 Houston, TX 77060 Which may be used in evidence upon the trial of the above-styled and deposition with attached questions numbered cause pending above named court. Notice is further given that request is hereby made as in the authorized under Rules 176 and 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 bring and produce for inspection and photocopying a true and correct copy of records described in the attached Written Questions and to turn aII 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. Emily DeJong Pyle SBA # 24069598 emily@ahblaw.net Adkerson, Hauder & Bezney, P.C. 1700 Pacific Avenue Suite 4450 Dallas, TX 75201 Phone: 214-740-2500; Fax: 214-740—2501 Attorney for Defendant(s) /s/ Emily DeJong Pyle Emily DeJong Pyle Order No.2 129017 (Amy Hnncy) CERTIFICATE OF SERVICE Ihereby certify that a true and correct copy of the foregoing Notice of Intention t0 Take Deposition upon Written Questions was served to the respective parties and/or attorneys of record by certified mail with return receipt requested; _ hand delivery;_ fax; _x_ _ electronic serve; or UPS. Dated: 04/09/2020 By permission: ls/ Jessie Hebert Emily DeJong Pyle Should you desire copies of the so obtained, contact our firm. 71 3-653-7100 Order No; 129017 (Amy Honey) Cause No. DC-18-18232 § Carla Washington § In the District Court 0f § vs. Dallas County, Texas g Primose Houston South Houston, et. al 44th Judicial District g ATTORNEYS 0F RECORD: Emily DeJong Pyle Adkerson, Hauder & Bezney, P.C. I700 Pacific Avenue Suite 4450 Dallas, TX 75201 Phone: 214-740-2500 Fax: 214—740-2501 Attorney for Defendant(s): Primrose Houston South Housing, L.P., et. a1 Willie C. Bn'scoe The Briscoe Law Firm, PLLC 12700 Park Centrak Drive Suite 520 Dallas, TX 75251 Phone: 972-521-6868 Fax: 281-254-7789 Attorney for Plaintiffls): Carla Washington Order No. : 129017 (Amy Honey) Cause No. DC-18-18232 Carla Washington § In the District Court of § vs. § Dallas County, Texas § Primose Houston South Houston, et. al § 44th Judicial District DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS Custodian of Records for: ARBY‘S Records Pertaining to: Carla Washington Type of Records: any and employment file records, including but not limited to, personnel records, all application for employment, correspondence and/or memoranda, records relating t0 reviews and/or promotions, days absent and/or time lost, pre-employment physicaKs), post—employment physical(s), post-offer physical(s), employment history, correspondence, medical records, letters of recommendation, reasons for termination or leaving, reprimands, time cards, time sheets, records relating to lost wages, workers' compensation records and/or claims, insurance records and/or claims, payroll records, W-2 forms, W-4 forms, 1099 forms, and any other records contained in your office(s) pertaining to the employment 0f Carla Washington; DOB: 10/10/1962; SSN: xxx-xx-9215 1. Please state your full name, address, telephone number, occupation and official title. ANSWER 2. I am the custodian for (Please insert facility or practitioner name.) 3. Have you received a subpoena duces tecum for the production of those documents listed above? ANSWER 4. Are you among those who have possession, custody, control of. or access to the documents requested above? ANSWER 5. Were the records requested above made in the regular courSe of business? ANSWER 6. Was it in the regular course of business of the above listed facility or practitioner for a person with knowledge of the opinion, or diagnosis recorded to make the record or to transmit act, event, condition, information thereof to be included in such record? ANSWER Order No.: 1290l7.028 (Amy Honey) State whether these records were made at the time or shortly after the time of the transactions recorded? ANSWER Were these records kept as described in the preceding questions? ANSWER Does the source of the information, and the method and circumstance of its preparation, establish the trustworthiness of the records? ANSWER 10. Please release exact duplicates of the records as requested in the subpoena duces tecum 0r the originals thereof for photocopying for attachment to this deposition. Have you done as requested? If not, why not? ANSWER 11. Are there any records, documents, papers. correspondence or tangible matters 0f any kind pertaining to Carla Washington that you have NOT provided to the notary public taking your deposition? ANSWER 12. Please describeall papers, documents, records, correspondence, or tangible matters of any kind that you have not provided to the notary public taking your deposition and explain why you have NOT provided them. ANSWER 13. Are you aware that it may be necessaly to subpoena you or your employer to court at the time 0f the trial of this case, if you have not provided to the notary public taking your deposition all papers, documents. records, correspondence, or tangible matters of any kind pertaining to Carla Washington? ANSWER WITNESS (Custodian of Records) Before me, the undersigned authority, on this day personally appeared custodian of records for the above listed. knowu to me to , be the person whose name subscribed to the foregoing instrument in the capacity therein stated, who being first is duly sworn, stated upon his/her oath that the answers to the foregoing questions are true and correct. 1 further certify that the records attached hereto are exact duplicates of the original records. SWORN T0 AND SUBSCRIBED before me this day of , 20 NOTARY PUBLIC Order Na: 1290l7.028 (Amy Honey) Cause No. DC-18-18232 Carla Washington In the District Court of vs. wwwwwwmm Dallas County, Texas Primose Houston South Houston, et. al 44th Judicial District NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS To Plaintiff(s) by and through their attorney(s) of record: Willie C. Briscoe (The Briscoe Law Firm, PLLC). To other party/parties by and through their attorney(s) of record: YOU WILL TAKE NOTICE THAT twenty (20) days after service of a copy hereof with attached questions, a deposition by written questions will be taken of Custodian of Records at the address listed below: 26 - WENDY'S (Employment) 2910 PINE MILL DRIVE, PINE BLUFF, AR 71601 Before a Notary Public for: U.S. Legal Support Inc. 16825 Northchase Dr., Suite 800 Houston, TX 77060 Which may be used in evidence upon the trial of the above-styled and deposition with attached questions numbered cause pending above named court. Notice is further given that request is hereby made as in the authorized under Rules 176 and 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 bring and produce for inspection and photocopying a true and correct copy of records described in the attached Written Questions 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. Emily DeJong Pyle SBA # 24069598 emily@ahblaw.net Adkerson, I-Iauder & Bezney, P.C. 1700 Pacific Avenue Suite 4450 Dallas, TX 75201 Phone: 214-740-2500; Fax: 214—740-250] Attorney for Defendant(s) Emily DeJong Pyle /s/ Emily DeJong Pyle Order No; 119017 (Amy Honey) CERTIFICATE OF SERVICE Ihereby certify that a true and correct copy of the foregoing Notice of Intention to Take Deposition upon Written Questions was served to the respective parties and/or attorneys of record with return receipt requested; ___ hand delivery; _ _x_ fax; __ electronic serve; or _ by UPS. certified mail Dated: 04/09/2020 By permission: ls/ Jessie Hebefl Emily DeJong Pyle Should you desire copies of the so obtained, contact our firm. 713-653-7100 Order No.: 129017 (Amy Honey) Cause N0. DC-18-18232 § Carla Washington § In the District Court of § vs. Dallas County, Texas g Primose Houston South Houston, et. a] 44th Judicial District g ATTORNEYS 0F RECORD: Emily DeJong Pyle Adkerson, Hauder & Bezney, P.C. 1700 Pacific Avenue Suite 4450 Dallas, TX 75201 Phone: 214-740-2500 Fax: 214-740-2501 Attorney for Defendant(s): Primrose Houston South Housing, L.P., et. al Willie C. Briscoe The Briscoe Law Firm, PLLC 12700 Park Centrak Dn've Suite 520 Dallas, TX 75251 Phone: 972-521-6868 Fax: 28 [-254-7789 Attorney for Plaintiff(s): Carla Washington Order Nu. : 129017 (Amy Honey) Cause No. DC-18-18232 Carla Washington In the District Court of vs. mmmma Dallas County, Texas Primose Houston South Houston, et. al 44th Judicial District DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS Custodian of Records for: ARLINGTON INDEPENDENT SCHOOL DISTRICT Records Pertaining to: Carla Washington Type of Records: any and alt employment file records, including but not limited to, personnel records, application for employment, correspondence and/or memoranda, records relating to reviews and/or promotions, days absent and/or time lost, pre—employment physical(s), post—employment physical(s), post-offer physicaKs), employment history, correspondence, medical records, letters of recommendation, reasons for termination or leaving, reprimands, time cards, time sheets, records relating to lost wages, workers’ compensation records and/or claims, insurance records and/or claims, payroll records, W-2 forms, W-4 forms, 1099 forms, and any other records contained in your office(s) pertaining to the employment 0f Carla Washington; DOB: 10/10/1962; SSN: xxx—xx-9215 1. Please state your full name, address, telephone number, occupation and official title. ANSWER 2. I am the custodian for (Please insert facility or practitioner name.) 3. Have you received a subpoena duces tecum for the production ofthose documents listed above? ANSWER 4. Are you among those who have possession, custody, control of, or access to the documents requested above? ANSWER 5. Were the records requested above made in the regular course of business? ANSWER 6. Was it in the regular course of business of the above listed facility or practitioner for a person with knowledge of the act, event, condition, opinion, or diagnosis recorded to make the record or to transmit information thereof t0 be included in such record? ANSWER Order Nu: l290l7.029 (Amy Honey) State whether these records were made at the time or shortly after the time of the transactions recorded? ANSWER Were these records kept as described in the preceding questions? ANSWER Does the source of the information, and the method and circumstance of its preparation, establish the trustworthiness of the records? ANSWER 10. Please release exact duplicates of the records as requested in the subpoena duces tecum or the originals thereof for photocopying for attachment to this deposition. Have you done as requested? 1f not, why not? ANSWER 11. Are there any records, documents, papers, correspondence or tangible matters of any kind pertaining to Carla Washington that you have NOT provided to the notary public taking your deposition? ANSWER 12. Please describe papers, documents, records, correSpondence, or tangible matters of all any kind that you have not provided to the notary public taking your deposition and explain why you have NOT provided them. ANSWER 13. Are you aware that it may be necessary to subpoena you or your employer to court at the time of the trial of this case, if you have not provided to the notary public taking your deposition all papers, documents, records, correspondence, or tangible matters of any kind pertaining to Carla Washington? ANSWER WITNESS (Custodian of Records) Before me, the undersigned authority, on this day personally appeared ,custodian of records for the above listed, known to me to be the person whose name is subscribed to the foregoing instrument in the capacity therein stated, who being