On June 30, 2021 a
Party Discovery
was filed
involving a dispute between
Ferguson, Angela,
and
Arch, Daniel Paul,
Capps Rent-A-Car, Inc.,
Nexius Solutions, Inc.,
Nwon, Llc.,
Velex, Inc.,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
3/15/2022 9:37 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
]§,,
Strainers,
‘- w . r
(£2? ms ?‘ai.f"‘£;‘
.
\ Martin Reyes DEPUTY
1755 Wittington Place, Suite 750, Dallas, TX 75234
Telephone (972) 488—5555 ~ Facsimile (972) 488-5590 ~ (800) 346-4405
Hayley@WDSLegal.com ~ www.WrittenDeposition.com
Cause No. DC-21-08491
ANGELA FERGUSON § IN THE DISTRICT COURT OF
§
vs. §
§ DALLAS COUNTY, TEXAS
DANIEL PAUL ARCH; VELEX, INC; NEXIUS §
SOLUTIONS, LLC; NWON, LLC; and PROJECT §
PEOPLE U.S., INC. § lOlST JUDICIAL DISTRICT
CERTIFICATION
Rule 203 Filing
RECORDS FROM: ADVANCED HEART CARE, P.A. BILLING-Billing Records —
Our Ref #: 72616.002
WITNESS: Janet Cannon
On 02/10/22 a deposition on written questions was conducted and records from the above named facility pertaining to
ANGELA FERGUSON were obtained by Deposition on Written Questions. The above named witness was duly sworn by,
A. A. Kingdom, a notary public and the non-stenographic recording of the written deposition is a true record of the witness’
testimony.
The taxable cost to be paid by R. Wayne Gordon, TBA 08206500; attorney for Daniel Paul Arch, et al, is $170.50.
This charge is for the preparation of the completed Deposition by Written Questions with original exhibits.
The transcript with attached exhibits, if any was delivered on 02/23/22 to:
R. Wayne Gordon
Touchstone, Bernays, Johnston, Beall, Smith & Stollenwerck, LLP
1717 Main Street, Suite 3400
Dallas, TX 75201
A copy of this certificate was served on all parties pursuant to TRCP Rule 203.3 by certified mail, postage prepaid,
hand delivered or_X_Wby telephone document transfer to the following:
John C. Nohinek (Witherite Law Group, PLLC)
R. Wayne Gordon (Touchstone, Bernays, Johnston, Beall, Smith & Stollenwerck, LLP)
Pursuant to Texas Rules of Civil Procedure 203, I, the undersigned Notary Public in and for the State of Texas do hereby
certify the above to be true as stated.
Given under my hand and seal of office, this 23rd day of February, 2022.
NOTARY N THE STATE OF TEXAS
BRlAN NA GHERARDI
.,
PUBLW
'“,’—-to’a
firming”,
Egan, _ (7:3. Notary Public
sigifiwf STATE OF TEXAS
*
ID# 128132055
My Cumin; Exp. gov. 03.
2021.
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.
Envelope ID: 62607161
Status as of 3/15/2022 9:43 AM CST
Associated Case Party: PROJECT PEOPLE U.S. INC.
Name BarNumber Email TimestampSubmitted Status
Lisa Ball DallasHC@Hanover.com 3/15/2022 9:37:34 AM SENT
Associated Case Party: ANGELA FERGUSON
Name BarNumber Email TimestampSubmitted Status
Carol Caudle carol.caudle@witheritelaw.com 3/ 15/2022 9:37:34 AM SENT
John Nohinek john.nohinek@witheritelaw.com 3/15/2022 9:37:34 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
MICHAEL MARTINEZ mikegmartinezlaw@gmail.com 3/15/2022 9:37:34 AM SENT
Associated Case Party: VELEX, INC.
Name BarNumber Email TimestampSubmitted Status
R. Wayne Gordon wayne.gordon@tbjbs.com 3/15/2022 9:37:34 AM SENT
Andrew Fifield andrew.fifield@tbjbs.com 3/15/2022 9:37:34 AM SENT
Angelina Chairez angelina.chairez@tbjbs.com 3/15/2022 9:37:34 AM SENT
Heather Vandever heather.vandever@tbjbs.com 3/15/2022 9:37:34 AM SENT
John Couch john.couch@tbjbs.com 3/15/2022 9:37:34 AM SENT
Clarissa Anderson clarissa.anderson@tbjbs.com 3/15/2022 9:37:34 AM SENT
Document Filed Date
March 15, 2022
Case Filing Date
June 30, 2021
Category
MOTOR VEHICLE ACCIDENT
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FILED 3/15/2022 9:37 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS ]§,, Strainers, ‘- w . r (£2? ms ?‘ai.f"‘£;‘ . \ Martin Reyes DEPUTY 1755 Wittington Place, Suite 750, Dallas, TX 75234 Telephone (972) 488—5555 ~ Facsimile (972) 488-5590 ~ (800) 346-4405 Hayley@WDSLegal.com ~ www.WrittenDeposition.com Cause No. DC-21-08491 ANGELA FERGUSON § IN THE DISTRICT COURT OF § vs. § § DALLAS COUNTY, TEXAS DANIEL PAUL ARCH; VELEX, INC; NEXIUS § SOLUTIONS, LLC; NWON, LLC; and PROJECT § PEOPLE U.S., INC. § lOlST JUDICIAL DISTRICT CERTIFICATION Rule 203 Filing RECORDS FROM: ADVANCED HEART CARE, P.A. BILLING-Billing Records — Our Ref #: 72616.002 WITNESS: Janet Cannon On 02/10/22 a deposition on written questions was conducted and records from the above named facility pertaining to ANGELA FERGUSON were obtained by Deposition on Written Questions. The above named witness was duly sworn by, A. A. Kingdom, a notary public and the non-stenographic recording of the written deposition is a true record of the witness’ testimony. The taxable cost to be paid by R. Wayne Gordon, TBA 08206500; attorney for Daniel Paul Arch, et al, is $170.50. This charge is for the preparation of the completed Deposition by Written Questions with original exhibits. The transcript with attached exhibits, if any was delivered on 02/23/22 to: R. Wayne Gordon Touchstone, Bernays, Johnston, Beall, Smith & Stollenwerck, LLP 1717 Main Street, Suite 3400 Dallas, TX 75201 A copy of this certificate was served on all parties pursuant to TRCP Rule 203.3 by certified mail, postage prepaid, hand delivered or_X_Wby telephone document transfer to the following: John C. Nohinek (Witherite Law Group, PLLC) R. Wayne Gordon (Touchstone, Bernays, Johnston, Beall, Smith & Stollenwerck, LLP) Pursuant to Texas Rules of Civil Procedure 203, I, the undersigned Notary Public in and for the State of Texas do hereby certify the above to be true as stated. Given under my hand and seal of office, this 23rd day of February, 2022. NOTARY N THE STATE OF TEXAS BRlAN NA GHERARDI ., PUBLW '“,’—-to’a firming”, Egan, _ (7:3. Notary Public sigifiwf STATE OF TEXAS * ID# 128132055 My Cumin; Exp. gov. 03. 2021. 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. Envelope ID: 62607161 Status as of 3/15/2022 9:43 AM CST Associated Case Party: PROJECT PEOPLE U.S. INC. Name BarNumber Email TimestampSubmitted Status Lisa Ball DallasHC@Hanover.com 3/15/2022 9:37:34 AM SENT Associated Case Party: ANGELA FERGUSON Name BarNumber Email TimestampSubmitted Status Carol Caudle carol.caudle@witheritelaw.com 3/ 15/2022 9:37:34 AM SENT John Nohinek john.nohinek@witheritelaw.com 3/15/2022 9:37:34 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status MICHAEL MARTINEZ mikegmartinezlaw@gmail.com 3/15/2022 9:37:34 AM SENT Associated Case Party: VELEX, INC. Name BarNumber Email TimestampSubmitted Status R. Wayne Gordon wayne.gordon@tbjbs.com 3/15/2022 9:37:34 AM SENT Andrew Fifield andrew.fifield@tbjbs.com 3/15/2022 9:37:34 AM SENT Angelina Chairez angelina.chairez@tbjbs.com 3/15/2022 9:37:34 AM SENT Heather Vandever heather.vandever@tbjbs.com 3/15/2022 9:37:34 AM SENT John Couch john.couch@tbjbs.com 3/15/2022 9:37:34 AM SENT Clarissa Anderson clarissa.anderson@tbjbs.com 3/15/2022 9:37:34 AM SENT