Preview
Filed
2/24/2017 12:20:59 PM
Annie Rebecca Elliott
District Clerk
Fort Bend County, Texas
Layla Helton
NO. 16-DCV-238130
LOTRAND, ARDS S IN THE DISTRICT COURT
FORT BEND COUNTY, TEXAS
AM AND MA’ 240TH JUDICIAL DISTRICT
CERTIFICATE OF WRITTEN DISCOVERY
TO THE ORAB DG OF SAID COURT:
Pursuan’ ocal Rul ertification is hereby made that the following documents have
been served:
1 Reque: Ps isclostte
Interrogatorie:
Request for Pred
The above-mentioned doi en! Were serv fon tl ollowing individuals and/or parties
in accordance with the Texas Rules of Civj) dure:
Joe Stephe
THE Sf. SLA’ RM
440 Coh 3 Drive, Si
Katy, TX 77494
P: (713) 224-86
F: (713) 224. 55
Attorney for Plaintiff tranda Edy ds
S
Respectfully submitt
LAW OFFICES OF KI RIC DEAS
BY: cy
Ni)oreds.
Ashley B. Meng;
SBN: 2408936
rN O
801 Louisiana Street, Suite 500
Houston, TX 77002
Phone: (713) 546-2000
Fax: (855) 610-8083
Ashley. Menage@LibertyMutual.com
Attorney for Defendant
Sam Sibi
CERTIFICATE OF SERVICE
I certifythaptn this 24 day of February, 2017, service required under these rules was made
pursuant to ule ‘La.
g B. Stephens
‘THE STEPHENSYAW FIRM
440 Cobia Dry 601
Katy,TX 77494,
7 A 000
4-0055
At ‘orney for P.
713,
Lo anda Edwards
Ashley B. Mena
YY
NO. 16-DCV-238130
LOTR ND EDWARDS § IN THE DISTRICT COURT
FORT BEND COUNTY, TEXAS
SAM AND 240TH JUDICIAL DISTRICT
8
REQUEST FOR DISCLOSURE
TO: LOTR Vy EDW by and through attorney of record, Joe Stephens, 440 Cobia
Dr. Suyé Katy, TX D4, Joe@JoeStephensLaw.com
Pursuant to Rule 94 are requested to disclose, within 30 days of service of this request,
the information or matt | desefibedin 94.2€@) - 0
Respegtfiylly submitted
WOFFIS O PATRICK & DEAS
BY; LNs Hare
SB
801 Lo
Mengg
2408:
treet, S
dS
280
Housto! 7700,
Phone: (713) 546 Qa0
Fax: (855) 60-896
Ashley. Menag&@Liby futual.co)
Attorney for Defendam
Sam Sibi
YY
CERTIFICATE OF SERVICE
I certifythaptn this 24 day of February, 2017, service required under these rules was made
pursuant to ule ‘La.
g B. Stephens
‘THE STEPHENSYAW FIRM
440 Cobia Dry 601
Katy,TX 77494,
7 A 000
4-0055
At ‘orney for P.
713,
Lo anda Edwards
Ashley B. Mena
YY
REQUEST FOR DISCLOSURE
Pursuant to Ry 194 you are requested to disclose, within 30 days of service of the request, the
informatiowor rfterial described in Rule 194 (a) through (k) as follows
é correct names of the parties to the lawsuit;
the name, address dstelephone number of any potential parties,
& the legal theopx s apd, in general, the factual bases of the responding party’s claims or
defenses fe 1 fonding party need not marshal all evidence that may be offered at trial):
(a th Ountdénd any pa ethod of calculating economic damages
© umié, addre. d lephone number of persons having knowledge of relevant facts,
and a brief s éme ofeas, h identified person’s connection with the case;
@ for any test ig expert:
() he expert’s ni: , address, and telephone number;
(2) the subject pxatter@n which the expert will testify;
(3) the geng | spbstance 5 ch expert’s mental 1impressions and opinions and a brief
summahyt the basis for or if the expert is not retained by, employed by, or
otherwise subjéct 76 the control pf the responding party, documents reflecting such
information:
(A) if the expert is\elgined by, ployesrhy or ott erwise subject to the control of the
responding part}
(A) all docume angible rdports,madels, or data compilations that
have been providedto, 1ewe§ By; orprepared by or for the expert in
anticipation of, fe exfert’s tes: ony and
(B) the expert’s curt it resumy And bibhegray rig
(g) any discoverable indemnity and insuring erge ents;
(h) any discoverable settlement agreement’
9 any discoverable witness statements:
he
@ ina suit alleging physical or mental injury a: d hae; urrence that is the
subject of the case, all medical records and bills that €asonab Qlated to the injuries or
damages asserted or, in lieu thereof, an authorizati¢ permitting: ed sclosuyef such
medical records and bills
(k) in a suit alleging physical or mental injury and damage orn je OCcUs 2 that is the
subject of the case, all medical records and bills obtained ie ding party by virtue
YY
of an authorization furnished by the requesting party.
NO. 16-DCV-238130
LOTRAND, ARDS S IN THE DISTRICT COURT
FORT BEND COUNTY, TEXAS
AM AND MA’ 240TH JUDICIAL DISTRICT
INTERROGATORIES TO PLAINTIFF
TO: LOTRAND. DWARQDS, by and through attorney of record, Joe Stephens, 440 Cobia
Dr. + SuIte b ty, 94, Joe@JoeStephensLaw.com.
Pursuant ‘© Rule 19 Yyod are requested to answer separately and fully the following
Interrogatories in wrt ag apd und oath: aid answers to be served upon Ashley B. Menage, Law
Offices of Kilpatrick & Dea: 86 Street, Suite 500, Houston, TX 77002, attorney for
Defendant:
1 Please identify yourself by mg you: §, YO date of birth, last address and all
other addresses where you lived dust é pas 6)yea) , your social security number,
driver's license number, and wl etl fou have ised yo same If so, give the other
names and state the reasons for al ame charges,
ANSWER:
2. State in detail your full education backgrou: inclu d ames d\addresses of all schools
attended, dates of attendance, and all degrees obtaifled
ANSWER:
3 State in detail your employment history for the past ten ye; acluding\th names.
addresses, and telephone numbers of all employers and immediat? sy, jok titles and
duties, wages (hourly or weekly) or salary, and all reasons for leaving
ANSWER:
4 State the full name, address, and telephone number of each prospective eng ‘that has
refused to hire you for any reason since the accident made the basis of this la\suit and state
the reasons for each refusal to hire.
ANSWER:
Des be every source of income or benefits you have had for the last ten (10) years,
ipdluding unemployment compensation, workers’ compensation, social security disability,
ete. A responsive ahstyer will include the time periods during which each was received and
the amounts f9 éwved This interrogatory does not include salaries or wages from employers
previously ted,
ANS)
What aré“ll the injure claim to have received in the accident made the basis of this
lawsuit and state you recovered from each,
ANSWER:
7 What complaints, problems, or imp At of € dy you currently have from the
injuries you claim you suffered intl cident m € bas oO lawsuit?
ANSWER:
State the name and address of each hospit in wl you hate B en treated and of each
medical doctor or other practitioner of the healin; ys whom y¢ ave Ct ulted or who
has examined or treated you for any reason since date of the gident the basis of
this lawsuit and state the reason for each visit to ea espital or m&dic; actitioner.
ANSWER:
YY
State the full name, address, and telephone number of each hospital in which you have been
treated anghof each medical doctor or other practitioner of the healing arts whom you have
consul ’vho has examined or treated you for any reason during the ten years before the
acord ade the basis of this lawsuit and state the reason for each visit to each hospital
paédical practitioner.
AN
10. State the cause sfumber » le, court, county, and state of each lawsuit filed by you or against
SY
you as a 1g It oP injucie rdceived in any accident including the accident made the basis of
this lawg at. a lawsuit ‘as}not filed in a claim made by you, state the names and addresses
of the parfies involved and the amount of any settlement.
ANSWER:
11 State in detail how the\a the SS lawsuit happened, providing the date
and time it happened and the xactJécatior
ANSWER:
12. Identify by name and dosage or € of all h6 drugs and medications, either
prescriptions or over-the-counter taken within gatts prior to the incident made the basis
of this lawsutt.
ANSWER:
©
Oy
13 If you have ever been involved in any other kind of accident 9 atrence before or after
the occurrence in question in which you were injured, state iyde
The date of each accident or occurrence:
The injuries that were sustained.
Identify by name, address and telephone number all
treated you for each injury you have identified.
ANSWER:
14. Deseribe fully each criminal offense for which you have been arrested, including the
dispositio: ef the charges and the county and state where charged.
ANSWER
15 Did any police agg westigate this accident? If you recetved any citation(s) as a result of
that investigatio the offense charged and the disposition of the case.
AN.
16 Disclos cvfhame, addr, and telephone number of any person who is expected to be
called to stify at te luding any rebuttal or impeaching witnesses the necessity of
whose testimony cet easonably be anticipated before trial.
ANSWER:
17. Disclose the name, adcdke éphong aie! any person who is expected to be
called to testify at tral co ang the of Dy endant, excluding any rebuttal or
impeaching witnesses the necessity, jose not reasonably be anticipated
before trial.
ANSWER:
18. Please identify any health issue not related ie acofd fade basis of this lawsuit that
you were seeking treatment for from any healthe: provider in five yer to the
accident made the basis of this lawsuit.
ANSWER:
YY
Respectfully submitted,
LAW OFFICES OF KILPATRICK & DEAS
BY:
Ashley B./ Mena
SBN: 240893;
801 Louisiana Street, Suite 500
Houston, TX 77002
Phone: (713) 546-2000
Fax: (855) 610-8083
Ashley.Menage@LibertyMutual.com
Attorney for Defendant
Sam Sibi
CERTIFICATE OF SERVICE
I certify that on ‘this 24” dof aky, 2017, service required under these rules was made
pursuant to Rule 21a.
Joe B. Stephens
THE STEPHENS LA’ [RM
440 Cobia Drive, Suite 601
Katy, TX 77494
P: (713) 224-0000
F: (713) 224-0055
Attorney for Plaintiff, Lotranda Edway
Yo
Ashley B. Mena
YY
STATE OF TE!
COUNTY, gC) BORT BEND §
I, Lotranda Edwagd tate on oath that I am authorized to make this affidavit, and that I
have ad the answ 6ntained in the foregoing paragraphs and that such answers within my
persona cdf are ti d correct.
AFFIANT
SUBSCRIBED AND RN TO by the above before me, the undersigned authority, on
this the day o 20
Nota; fe Wand >
The S of Te:
©
YY
NO. 16-DCV-238130
LOTRAND, ARDS S IN THE DISTRICT COURT
FORT BEND COUNTY, TEXAS
AM AND MA’ 240TH JUDICIAL DISTRICT
§
REQUEST FOR PRODUCTION
TO: LOTRAND. WARDS, by and through attorney of record, Joe Stephens, 440 Cobia
Dr. + SuIte b ty, 94, Joe@JoeStephensLaw.com
Pursuant © Rule 196, 4 are requested to produce and permit the Defendant to inspect
the following items, w; 0) da Of servi of this request a copy of said response is to be served
upon Ashley B. Menage, L: Offices of patnck & Deas, 801 Louisiana Street, Suite 500,
Houston, TX 77002, attorrle y\for Deféndgnts. SIBI and MR. MATTHEW
ABRAHAM:
All photographs, video drawings, dagra) Sere to the basis of this
lawsuit;
The Plaintiff's income tax re for five ¢ prior to the date of the incident
through the current year.
A signed authorization for tax recdxd$. Be authe tion forms will not be
&
accepted by the Custodian of Records beyd 0 days fro} Hate ther n, request ts
made that the signed forms be returned pro ptly after be dated. is attached
for your convenience.
All information, tests, data, literature and reports indicgtf extent to which the
Plaintiff intends to prove that Defendant failed to phy with agy gov rnment or
industry standards at the time of the incident made obasis2 fs suit.
The Employer's First Report of Accident relating to the acd basis of
this litigation.
Any accident or injury reports pertaining to the incident made Ahe bas this
lawsuit.
Copies of all damage appraisals, repair bills and invoices regarding the damages
claimed.
A copy of the front and back of Plaintifi’s driver's license.
portions of all treatises, periodicals, or pamphlets on a subject of history,
€dicine, or other science or art that you may offer or use in the trial of this case
under Rule 803(18) of the Texas Rules of Evidence.
10. A signed onzation for employment records. One is attached for your
conve:
décuments evidencing lost earning capacity or earnmgs lost because of the
ident bhe basis of this lawsuit.
12. d-futhorrs yn. for medical records (one is attached for your convenience).
13 €ase produce ind all filings and other written documentation between Plaintiff
and the So ecurity Administration.
14. Please sig the Oct eCUurNy erm attached hereto. The signing of this form is not
an alternative to quest for ‘rotluction No. 13.
15 A copy of al orrespople. Icing electronic or magnetic data,
regarding any ark al fens pr claims for, Biggdtion relating to the incident
made the basis of thi mit.
16 A copy of all Explanation of Benefi othe document showing
outstanding amount, pa mt or payee wyt mas or on behalf of the
plaintiff of any medical bills claip péurred a: sult of the accident made
the basis of the lawsuit.
17. All MRI, CT-Scan, x-rays or other r: d Cal oe diagnos films and reports
regarding Plaintiff.
18. A copy of all notes, notebooks, diaries, cp lendars or elegtspnic dai ich
contain entries regarding the incident m: de\the basis of uit, notes
regarding medical treatment, or, notes refe neing Sftect; Hfe incident
made the basis of this lawsuit on you or your family.
19 A copy of all medical bills and records, including r ports, e on nation lxte!
nurses’ notes, diagnosis and prognosis, made by physi¢ian c other
health professionals who have examined and/or treate he,
injuries allegedly sustained as a result of the incident ma basisrof this
suit.
20. Copies of all medical records and medical bills you will int®duce,
evidence at the trial of this cause.
21 Any letter of protection or guaranty or any other form of security that you or
yo attorney on your behalf has given to any person or entity as security for
nt for services or products out of any funds to be generated by this
“suit whether by settlement or by payment of a judgment.
Copies of all convictions that you intend to use at trial to impeach Defendant
or witness¢
Respectfully submitted,
LAW OFFICES OF KILPATRICK & DEAS
BY:
Ashley B."Mena;
240893,
801 Loyisiana Street, Suite 500
Houston TX 77002
Phone} ( 13) 546-2000
Fax: 8) 610-80
Astfey, len: Ll futual.com
ey for, refen
Sam Sib
CERTY{FICATE OP SER’ ee
I certify that on this 24 day of Febru; 7, servi shuired under these rules was made
pursuant to Rule 21a.
Joe B. Stephens
THE STEPHENS LAW FIRM
440 Cobia Drive, Suite 601
Katy, TX 77494
P: (713) 224-0000
F: (713) 224-0055
Br
Attorney for Plaintiff, Lotranda Edwards
DEC/20/2016/10E 06:15 PM CRIM LAW FIRM FAX No. 713 807 8852 P, 013
AUTHORIZATION AND CONSENT FOR
RELEASE OF DRIVING RECORD INFORMATION
are herebya orized, and | hereby give my consent to you, to furnish to THE CRIM
4900 Ty treet, Houston, TX 77002, or any representative of THE CRIM LAW
FIRM, my compl lift ving record listing all accidents and violations,
My Driver eyse Number is reflecting my full name as
, date of birth as and
address as
T hereby orkey specifically release you from any breach of confidence or any
liability in connection wit] Gur release jof|the above-described documents and information. A
photocopy of this instrument is as valid ag’th¢ original,
DATE:
RELEASOK
©
Sy
SWORN TO AND SUBSCRIBED BEFORE ( the und ed mens on this the
day of 2
NOTARY PUBLIC IN A 3D POR
THE STATE OF TEX A
REV: 3/5/04
DEC/20/2016/10E 06:15 PM CRIM LAW FIRM FAX No. 713 807 8852 POL4
AUTHORIZATION AND CONSENT FOR
WIRELESS COMMUNICATION DEVICE RECORDS
AC 9g NO
This is onze direct any corporation, partnership, or individual who has issued,
sold, rented, rl éd any fo f cellular, pager or other wireless communication device(s) and/or
services to to fumish THE CRIM LAW FIRM, 4900 Travis
Street, Houston, TX
information or opinions
account, call logs, ig
ots
0; or any representative of THE CRIM LAW FIRM, any and all
hich they
inks tion,
request regarding the detailed billing information of my
placed or received, or any other information pertaining
to the undersigned within y6 Sossession, upon presentation of this authorization.
Thereby waive any privilege I XO sath to sion. A copy of this instrument will have
the same validity as the orig
DATE:
RELEASOR
SWORN TO AND SUBSCRIBED BEFORE the underdignes Sex, on this the
day of 2
wy
NOTARY PUBLIC IN AND F
THE STATE OF TEXAS
REV: 3/5/04
Preview
Filed 2/24/2017 12:20:59 PM Annie Rebecca Elliott District Clerk Fort Bend County, Texas Layla Helton NO. 16-DCV-238130 LOTRAND, ARDS S IN THE DISTRICT COURT FORT BEND COUNTY, TEXAS AM AND MA’ 240TH JUDICIAL DISTRICT CERTIFICATE OF WRITTEN DISCOVERY TO THE ORAB DG OF SAID COURT: Pursuan’ ocal Rul ertification is hereby made that the following documents have been served: 1 Reque: Ps isclostte Interrogatorie: Request for Pred The above-mentioned doi en! Were serv fon tl ollowing individuals and/or parties in accordance with the Texas Rules of Civj) dure: Joe Stephe THE Sf. SLA’ RM 440 Coh 3 Drive, Si Katy, TX 77494 P: (713) 224-86 F: (713) 224. 55 Attorney for Plaintiff tranda Edy ds S Respectfully submitt LAW OFFICES OF KI RIC DEAS BY: cy Ni)oreds. Ashley B. Meng; SBN: 2408936 rN O 801 Louisiana Street, Suite 500 Houston, TX 77002 Phone: (713) 546-2000 Fax: (855) 610-8083 Ashley. Menage@LibertyMutual.com Attorney for Defendant Sam Sibi CERTIFICATE OF SERVICE I certifythaptn this 24 day of February, 2017, service required under these rules was made pursuant to ule ‘La. g B. Stephens ‘THE STEPHENSYAW FIRM 440 Cobia Dry 601 Katy,TX 77494, 7 A 000 4-0055 At ‘orney for P. 713, Lo anda Edwards Ashley B. Mena YY NO. 16-DCV-238130 LOTR ND EDWARDS § IN THE DISTRICT COURT FORT BEND COUNTY, TEXAS SAM AND 240TH JUDICIAL DISTRICT 8 REQUEST FOR DISCLOSURE TO: LOTR Vy EDW by and through attorney of record, Joe Stephens, 440 Cobia Dr. Suyé Katy, TX D4, Joe@JoeStephensLaw.com Pursuant to Rule 94 are requested to disclose, within 30 days of service of this request, the information or matt | desefibedin 94.2€@) - 0 Respegtfiylly submitted WOFFIS O PATRICK & DEAS BY; LNs Hare SB 801 Lo Mengg 2408: treet, S dS 280 Housto! 7700, Phone: (713) 546 Qa0 Fax: (855) 60-896 Ashley. Menag&@Liby futual.co) Attorney for Defendam Sam Sibi YY CERTIFICATE OF SERVICE I certifythaptn this 24 day of February, 2017, service required under these rules was made pursuant to ule ‘La. g B. Stephens ‘THE STEPHENSYAW FIRM 440 Cobia Dry 601 Katy,TX 77494, 7 A 000 4-0055 At ‘orney for P. 713, Lo anda Edwards Ashley B. Mena YY REQUEST FOR DISCLOSURE Pursuant to Ry 194 you are requested to disclose, within 30 days of service of the request, the informatiowor rfterial described in Rule 194 (a) through (k) as follows é correct names of the parties to the lawsuit; the name, address dstelephone number of any potential parties, & the legal theopx s apd, in general, the factual bases of the responding party’s claims or defenses fe 1 fonding party need not marshal all evidence that may be offered at trial): (a th Ountdénd any pa ethod of calculating economic damages © umié, addre. d lephone number of persons having knowledge of relevant facts, and a brief s éme ofeas, h identified person’s connection with the case; @ for any test ig expert: () he expert’s ni: , address, and telephone number; (2) the subject pxatter@n which the expert will testify; (3) the geng | spbstance 5 ch expert’s mental 1impressions and opinions and a brief summahyt the basis for or if the expert is not retained by, employed by, or otherwise subjéct 76 the control pf the responding party, documents reflecting such information: (A) if the expert is\elgined by, ployesrhy or ott erwise subject to the control of the responding part} (A) all docume angible rdports,madels, or data compilations that have been providedto, 1ewe§ By; orprepared by or for the expert in anticipation of, fe exfert’s tes: ony and (B) the expert’s curt it resumy And bibhegray rig (g) any discoverable indemnity and insuring erge ents; (h) any discoverable settlement agreement’ 9 any discoverable witness statements: he @ ina suit alleging physical or mental injury a: d hae; urrence that is the subject of the case, all medical records and bills that €asonab Qlated to the injuries or damages asserted or, in lieu thereof, an authorizati¢ permitting: ed sclosuyef such medical records and bills (k) in a suit alleging physical or mental injury and damage orn je OCcUs 2 that is the subject of the case, all medical records and bills obtained ie ding party by virtue YY of an authorization furnished by the requesting party. NO. 16-DCV-238130 LOTRAND, ARDS S IN THE DISTRICT COURT FORT BEND COUNTY, TEXAS AM AND MA’ 240TH JUDICIAL DISTRICT INTERROGATORIES TO PLAINTIFF TO: LOTRAND. DWARQDS, by and through attorney of record, Joe Stephens, 440 Cobia Dr. + SuIte b ty, 94, Joe@JoeStephensLaw.com. Pursuant ‘© Rule 19 Yyod are requested to answer separately and fully the following Interrogatories in wrt ag apd und oath: aid answers to be served upon Ashley B. Menage, Law Offices of Kilpatrick & Dea: 86 Street, Suite 500, Houston, TX 77002, attorney for Defendant: 1 Please identify yourself by mg you: §, YO date of birth, last address and all other addresses where you lived dust é pas 6)yea) , your social security number, driver's license number, and wl etl fou have ised yo same If so, give the other names and state the reasons for al ame charges, ANSWER: 2. State in detail your full education backgrou: inclu d ames d\addresses of all schools attended, dates of attendance, and all degrees obtaifled ANSWER: 3 State in detail your employment history for the past ten ye; acluding\th names. addresses, and telephone numbers of all employers and immediat? sy, jok titles and duties, wages (hourly or weekly) or salary, and all reasons for leaving ANSWER: 4 State the full name, address, and telephone number of each prospective eng ‘that has refused to hire you for any reason since the accident made the basis of this la\suit and state the reasons for each refusal to hire. ANSWER: Des be every source of income or benefits you have had for the last ten (10) years, ipdluding unemployment compensation, workers’ compensation, social security disability, ete. A responsive ahstyer will include the time periods during which each was received and the amounts f9 éwved This interrogatory does not include salaries or wages from employers previously ted, ANS) What aré“ll the injure claim to have received in the accident made the basis of this lawsuit and state you recovered from each, ANSWER: 7 What complaints, problems, or imp At of € dy you currently have from the injuries you claim you suffered intl cident m € bas oO lawsuit? ANSWER: State the name and address of each hospit in wl you hate B en treated and of each medical doctor or other practitioner of the healin; ys whom y¢ ave Ct ulted or who has examined or treated you for any reason since date of the gident the basis of this lawsuit and state the reason for each visit to ea espital or m&dic; actitioner. ANSWER: YY State the full name, address, and telephone number of each hospital in which you have been treated anghof each medical doctor or other practitioner of the healing arts whom you have consul ’vho has examined or treated you for any reason during the ten years before the acord ade the basis of this lawsuit and state the reason for each visit to each hospital paédical practitioner. AN 10. State the cause sfumber » le, court, county, and state of each lawsuit filed by you or against SY you as a 1g It oP injucie rdceived in any accident including the accident made the basis of this lawg at. a lawsuit ‘as}not filed in a claim made by you, state the names and addresses of the parfies involved and the amount of any settlement. ANSWER: 11 State in detail how the\a the SS lawsuit happened, providing the date and time it happened and the xactJécatior ANSWER: 12. Identify by name and dosage or € of all h6 drugs and medications, either prescriptions or over-the-counter taken within gatts prior to the incident made the basis of this lawsutt. ANSWER: © Oy 13 If you have ever been involved in any other kind of accident 9 atrence before or after the occurrence in question in which you were injured, state iyde The date of each accident or occurrence: The injuries that were sustained. Identify by name, address and telephone number all treated you for each injury you have identified. ANSWER: 14. Deseribe fully each criminal offense for which you have been arrested, including the dispositio: ef the charges and the county and state where charged. ANSWER 15 Did any police agg westigate this accident? If you recetved any citation(s) as a result of that investigatio the offense charged and the disposition of the case. AN. 16 Disclos cvfhame, addr, and telephone number of any person who is expected to be called to stify at te luding any rebuttal or impeaching witnesses the necessity of whose testimony cet easonably be anticipated before trial. ANSWER: 17. Disclose the name, adcdke éphong aie! any person who is expected to be called to testify at tral co ang the of Dy endant, excluding any rebuttal or impeaching witnesses the necessity, jose not reasonably be anticipated before trial. ANSWER: 18. Please identify any health issue not related ie acofd fade basis of this lawsuit that you were seeking treatment for from any healthe: provider in five yer to the accident made the basis of this lawsuit. ANSWER: YY Respectfully submitted, LAW OFFICES OF KILPATRICK & DEAS BY: Ashley B./ Mena SBN: 240893; 801 Louisiana Street, Suite 500 Houston, TX 77002 Phone: (713) 546-2000 Fax: (855) 610-8083 Ashley.Menage@LibertyMutual.com Attorney for Defendant Sam Sibi CERTIFICATE OF SERVICE I certify that on ‘this 24” dof aky, 2017, service required under these rules was made pursuant to Rule 21a. Joe B. Stephens THE STEPHENS LA’ [RM 440 Cobia Drive, Suite 601 Katy, TX 77494 P: (713) 224-0000 F: (713) 224-0055 Attorney for Plaintiff, Lotranda Edway Yo Ashley B. Mena YY STATE OF TE! COUNTY, gC) BORT BEND § I, Lotranda Edwagd tate on oath that I am authorized to make this affidavit, and that I have ad the answ 6ntained in the foregoing paragraphs and that such answers within my persona cdf are ti d correct. AFFIANT SUBSCRIBED AND RN TO by the above before me, the undersigned authority, on this the day o 20 Nota; fe Wand > The S of Te: © YY NO. 16-DCV-238130 LOTRAND, ARDS S IN THE DISTRICT COURT FORT BEND COUNTY, TEXAS AM AND MA’ 240TH JUDICIAL DISTRICT § REQUEST FOR PRODUCTION TO: LOTRAND. WARDS, by and through attorney of record, Joe Stephens, 440 Cobia Dr. + SuIte b ty, 94, Joe@JoeStephensLaw.com Pursuant © Rule 196, 4 are requested to produce and permit the Defendant to inspect the following items, w; 0) da Of servi of this request a copy of said response is to be served upon Ashley B. Menage, L: Offices of patnck & Deas, 801 Louisiana Street, Suite 500, Houston, TX 77002, attorrle y\for Deféndgnts. SIBI and MR. MATTHEW ABRAHAM: All photographs, video drawings, dagra) Sere to the basis of this lawsuit; The Plaintiff's income tax re for five ¢ prior to the date of the incident through the current year. A signed authorization for tax recdxd$. Be authe tion forms will not be & accepted by the Custodian of Records beyd 0 days fro} Hate ther n, request ts made that the signed forms be returned pro ptly after be dated. is attached for your convenience. All information, tests, data, literature and reports indicgtf extent to which the Plaintiff intends to prove that Defendant failed to phy with agy gov rnment or industry standards at the time of the incident made obasis2 fs suit. The Employer's First Report of Accident relating to the acd basis of this litigation. Any accident or injury reports pertaining to the incident made Ahe bas this lawsuit. Copies of all damage appraisals, repair bills and invoices regarding the damages claimed. A copy of the front and back of Plaintifi’s driver's license. portions of all treatises, periodicals, or pamphlets on a subject of history, €dicine, or other science or art that you may offer or use in the trial of this case under Rule 803(18) of the Texas Rules of Evidence. 10. A signed onzation for employment records. One is attached for your conve: décuments evidencing lost earning capacity or earnmgs lost because of the ident bhe basis of this lawsuit. 12. d-futhorrs yn. for medical records (one is attached for your convenience). 13 €ase produce ind all filings and other written documentation between Plaintiff and the So ecurity Administration. 14. Please sig the Oct eCUurNy erm attached hereto. The signing of this form is not an alternative to quest for ‘rotluction No. 13. 15 A copy of al orrespople. Icing electronic or magnetic data, regarding any ark al fens pr claims for, Biggdtion relating to the incident made the basis of thi mit. 16 A copy of all Explanation of Benefi othe document showing outstanding amount, pa mt or payee wyt mas or on behalf of the plaintiff of any medical bills claip péurred a: sult of the accident made the basis of the lawsuit. 17. All MRI, CT-Scan, x-rays or other r: d Cal oe diagnos films and reports regarding Plaintiff. 18. A copy of all notes, notebooks, diaries, cp lendars or elegtspnic dai ich contain entries regarding the incident m: de\the basis of uit, notes regarding medical treatment, or, notes refe neing Sftect; Hfe incident made the basis of this lawsuit on you or your family. 19 A copy of all medical bills and records, including r ports, e on nation lxte! nurses’ notes, diagnosis and prognosis, made by physi¢ian c other health professionals who have examined and/or treate he, injuries allegedly sustained as a result of the incident ma basisrof this suit. 20. Copies of all medical records and medical bills you will int®duce, evidence at the trial of this cause. 21 Any letter of protection or guaranty or any other form of security that you or yo attorney on your behalf has given to any person or entity as security for nt for services or products out of any funds to be generated by this “suit whether by settlement or by payment of a judgment. Copies of all convictions that you intend to use at trial to impeach Defendant or witness¢ Respectfully submitted, LAW OFFICES OF KILPATRICK & DEAS BY: Ashley B."Mena; 240893, 801 Loyisiana Street, Suite 500 Houston TX 77002 Phone} ( 13) 546-2000 Fax: 8) 610-80 Astfey, len: Ll futual.com ey for, refen Sam Sib CERTY{FICATE OP SER’ ee I certify that on this 24 day of Febru; 7, servi shuired under these rules was made pursuant to Rule 21a. Joe B. Stephens THE STEPHENS LAW FIRM 440 Cobia Drive, Suite 601 Katy, TX 77494 P: (713) 224-0000 F: (713) 224-0055 Br Attorney for Plaintiff, Lotranda Edwards DEC/20/2016/10E 06:15 PM CRIM LAW FIRM FAX No. 713 807 8852 P, 013 AUTHORIZATION AND CONSENT FOR RELEASE OF DRIVING RECORD INFORMATION are herebya orized, and | hereby give my consent to you, to furnish to THE CRIM 4900 Ty treet, Houston, TX 77002, or any representative of THE CRIM LAW FIRM, my compl lift ving record listing all accidents and violations, My Driver eyse Number is reflecting my full name as , date of birth as and address as T hereby orkey specifically release you from any breach of confidence or any liability in connection wit] Gur release jof|the above-described documents and information. A photocopy of this instrument is as valid ag’th¢ original, DATE: RELEASOK © Sy SWORN TO AND SUBSCRIBED BEFORE ( the und ed mens on this the day of 2 NOTARY PUBLIC IN A 3D POR THE STATE OF TEX A REV: 3/5/04 DEC/20/2016/10E 06:15 PM CRIM LAW FIRM FAX No. 713 807 8852 POL4 AUTHORIZATION AND CONSENT FOR WIRELESS COMMUNICATION DEVICE RECORDS AC 9g NO This is onze direct any corporation, partnership, or individual who has issued, sold, rented, rl éd any fo f cellular, pager or other wireless communication device(s) and/or services to to fumish THE CRIM LAW FIRM, 4900 Travis Street, Houston, TX information or opinions account, call logs, ig ots 0; or any representative of THE CRIM LAW FIRM, any and all hich they inks tion, request regarding the detailed billing information of my placed or received, or any other information pertaining to the undersigned within y6 Sossession, upon presentation of this authorization. Thereby waive any privilege I XO sath to sion. A copy of this instrument will have the same validity as the orig DATE: RELEASOR SWORN TO AND SUBSCRIBED BEFORE the underdignes Sex, on this the day of 2 wy NOTARY PUBLIC IN AND F THE STATE OF TEXAS REV: 3/5/04