On December 06, 2018 a
Party Notice
was filed
involving a dispute between
Washington, Carla,
and
Oc Risk Management Services Llc,
Primrose Houston South Housing, L.P.,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
Preview
FILED
12/22/2022 5:26 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Jenifer Trujillo DEPUTY
CAUSE N0. DC-18-18232
CARLA WASHINGTON IN THE DISTRICT COURT
§§§§§§§§§§
Plaintiff
v.
44TH JUDICIAL DISTRICT
PRIMROSE HOUSTON SOUTH
HOUSING, L.P. D/B/A ROSEMONT AT
ASH CREEK, AND 0C RISK
MANAGEMENT SERVICES, LLC
Defendants DALLAS COUNTY, TEXAS
DEFENDANTS’ NOTICE OF INTENT TO USE DISCOVERY
TO THE HONORABLE IUDGE OF SAID COURT:
COMES NOW Defendants Primrose Houston South Housing, L.P. d/b/a Rosemont at Ash
Creek and OC Risk Management Services, LLC in the above styled and numbered cause, and files
this, Notice of Intent to Use Discovery pursuant to Texas Rules of Civil Procedure, Rule 193.7.
Defendants, Without waiving and subject to any objections, hereby give notice of intent to use all
documents provided by Plaintiff Carla Washington in her responses to Request for Disclosure,
Requests for Production, and any other documents produced by Plaintiff in connection with this
matter during the trial on the merits of this matter. Defendants hereby give notice to Plaintiff these
documents will be considered authenticated by the producing party.
This Notice includes documents received by Defendants during discovery from Plaintiff,
Bates labeled WASHINGTON 000001-000822 and WASHINGTON C 000001-002247, any
additional or supplemental documentation which may be produced by Plaintiff after the filing of
this Notice, and the photographs sent by Plaintiff on March 22, 2022 and December 9, 2022 which
are not Bates labeled.
Notice of Intent to Use Discovery Documents Page 1 of 2
1 3 59. 120
Respectfully submitted,
ADKERSON, HAUDER & BEZNEY, PC
By: /s/ Larissa Prilliman
Paul A. Bezney
State Bar No. 00787077
Larissa Prilliman
State Bar No. 24079161
1700 Pacific Avenue, Suite 4450
Dallas, Texas 75201
Telephone: 214/ 740-2500
Facsimile: 214/740-2501
E-mail: bezney@ahblaw.net
E-mail: larissa@ahblaw.net
ATTORNEYS FOR DEFENDANTS
CERTIFICATE OF SERVICE
A true and correct copy of the foregoing instrument has been served upon all the parties,
pursuant to the Texas Rules of Civil Procedure on this the 22nd day of December, 2022.
/s/ Larissa Prilliman
Larissa Prilliman
Notice of Intent to Use Discovery Documents Page 2 of 2
1 3 59. 120
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.
Larissa Prilliman
Bar No. 24079161
larissa@ahblaw.net
Envelope ID: 71264651
Status as of 12/23/2022 8:36 AM CST
Associated Case Party: CARLA WASHINGTON
Name BarNumber Email TimestampSubmitted Status
DLF Intake intake@daspitlaw.com 12/22/2022 5:26:03 PM SENT
John A Daspit 24048906 Eservice@daspitlaw.com 12/22/2022 5:26:03 PM SENT
Alma Lira Alira@proactivelegal.com 12/22/2022 5:26:03 PM SENT
Kiernan McAlpine kier@daspitlaw.com 12/22/2022 5:26:03 PM SENT
Zorica Milivojevic Zorica@daspitlaw.com 12/22/2022 5:26:03 PM SENT
Jaime Holder jholder@proactivelegal.com 12/22/2022 5:26:03 PM SENT
John Daspit e-service@daspitlaw.com 12/22/2022 5:26:03 PM SENT
Victoria Gonzales vgonzales@daspitlaw.com 12/22/2022 5:26:03 PM SENT
Jessica Bebawi bebawi@daspitlaw.com 12/22/2022 5:26:03 PM SENT
Associated Case Party: PRIMROSE HOUSTON SOUTH HOUSING, L.P.
Name BarNumber Email TimestampSubmitted Status
Paul Bezney bezney@ahblaw.net 12/22/2022 5:26:03 PM SENT
Jessica Sanchez jessicas@ahblaw.net 12/22/2022 5:26:03 PM SENT
Larissa Prilliman larissa@ahblaw.net 12/22/2022 5:26:03 PM SENT
Document Filed Date
December 22, 2022
Case Filing Date
December 06, 2018
Category
OTHER PERSONAL INJURY
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FILED 12/22/2022 5:26 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Jenifer Trujillo DEPUTY CAUSE N0. DC-18-18232 CARLA WASHINGTON IN THE DISTRICT COURT §§§§§§§§§§ Plaintiff v. 44TH JUDICIAL DISTRICT PRIMROSE HOUSTON SOUTH HOUSING, L.P. D/B/A ROSEMONT AT ASH CREEK, AND 0C RISK MANAGEMENT SERVICES, LLC Defendants DALLAS COUNTY, TEXAS DEFENDANTS’ NOTICE OF INTENT TO USE DISCOVERY TO THE HONORABLE IUDGE OF SAID COURT: COMES NOW Defendants Primrose Houston South Housing, L.P. d/b/a Rosemont at Ash Creek and OC Risk Management Services, LLC in the above styled and numbered cause, and files this, Notice of Intent to Use Discovery pursuant to Texas Rules of Civil Procedure, Rule 193.7. Defendants, Without waiving and subject to any objections, hereby give notice of intent to use all documents provided by Plaintiff Carla Washington in her responses to Request for Disclosure, Requests for Production, and any other documents produced by Plaintiff in connection with this matter during the trial on the merits of this matter. Defendants hereby give notice to Plaintiff these documents will be considered authenticated by the producing party. This Notice includes documents received by Defendants during discovery from Plaintiff, Bates labeled WASHINGTON 000001-000822 and WASHINGTON C 000001-002247, any additional or supplemental documentation which may be produced by Plaintiff after the filing of this Notice, and the photographs sent by Plaintiff on March 22, 2022 and December 9, 2022 which are not Bates labeled. Notice of Intent to Use Discovery Documents Page 1 of 2 1 3 59. 120 Respectfully submitted, ADKERSON, HAUDER & BEZNEY, PC By: /s/ Larissa Prilliman Paul A. Bezney State Bar No. 00787077 Larissa Prilliman State Bar No. 24079161 1700 Pacific Avenue, Suite 4450 Dallas, Texas 75201 Telephone: 214/ 740-2500 Facsimile: 214/740-2501 E-mail: bezney@ahblaw.net E-mail: larissa@ahblaw.net ATTORNEYS FOR DEFENDANTS CERTIFICATE OF SERVICE A true and correct copy of the foregoing instrument has been served upon all the parties, pursuant to the Texas Rules of Civil Procedure on this the 22nd day of December, 2022. /s/ Larissa Prilliman Larissa Prilliman Notice of Intent to Use Discovery Documents Page 2 of 2 1 3 59. 120 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. Larissa Prilliman Bar No. 24079161 larissa@ahblaw.net Envelope ID: 71264651 Status as of 12/23/2022 8:36 AM CST Associated Case Party: CARLA WASHINGTON Name BarNumber Email TimestampSubmitted Status DLF Intake intake@daspitlaw.com 12/22/2022 5:26:03 PM SENT John A Daspit 24048906 Eservice@daspitlaw.com 12/22/2022 5:26:03 PM SENT Alma Lira Alira@proactivelegal.com 12/22/2022 5:26:03 PM SENT Kiernan McAlpine kier@daspitlaw.com 12/22/2022 5:26:03 PM SENT Zorica Milivojevic Zorica@daspitlaw.com 12/22/2022 5:26:03 PM SENT Jaime Holder jholder@proactivelegal.com 12/22/2022 5:26:03 PM SENT John Daspit e-service@daspitlaw.com 12/22/2022 5:26:03 PM SENT Victoria Gonzales vgonzales@daspitlaw.com 12/22/2022 5:26:03 PM SENT Jessica Bebawi bebawi@daspitlaw.com 12/22/2022 5:26:03 PM SENT Associated Case Party: PRIMROSE HOUSTON SOUTH HOUSING, L.P. Name BarNumber Email TimestampSubmitted Status Paul Bezney bezney@ahblaw.net 12/22/2022 5:26:03 PM SENT Jessica Sanchez jessicas@ahblaw.net 12/22/2022 5:26:03 PM SENT Larissa Prilliman larissa@ahblaw.net 12/22/2022 5:26:03 PM SENT