On August 17, 2017 a
Party Notice
was filed
involving a dispute between
Downie-Fraser, Nicole E.,
and
Sainz, Valeria,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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FILED
DALLAS COUNT
3/2/2018 9:28 AM
FELICIA PITRE
DISTRICT CLER
CAUSE NO. DC-1 7-1 0220
NICOLE E. DOWNlE-FRASER, IN THE DISTRICT COURT
Plaintiff,
v. 95th JUDICIAL DISTRICT
VALERIA SAINZ,
Defendant. DALLAS COUNTY, TEXAS
PLAINTIFF'S NOTICE OF INTENT TO USE DISCOVERY AGAINST DEFENDANT
PURSUANT TO TEX. R. CIV. P. 193.7
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW PLAINTIFF NICOLE E. DOWNIE-FRASER ("Plaintiff“) in the above
styled and numbered cause of action, and by and through the undersigned attorney files
this Notice of Intent to Use Discovery Against Defendant pursuant to Texas Rule of Civil
Procedure 193.7.
Plaintiff intends to use documents and tangible things produced by Defendant
VALERIA SAINZ, Said documents may be used against Defendant VALERIA SAINZ in
all pretrial proceedings and at time of trial against Defendant VALERIA SAINZ.
Respectfully submitted,
/s/ Cameron Dean
Cameron Dean
State Bar No. 2408291 0
Ben Abbott & Associates, PLLC
1934 Pendleton Drive
Garland, TX 75041
(972) 263-5555
(81 7) 263-5555
(972) 682-7586 Facsimile
eService@benabbott.com
ATTORNEYS FOR PLAINTIFF
PLAINTIFF'§ NGTICE 6F INTENT T6 USE DISCGVERY AGAIN§T DEFENDANT(§) PUR§UANT T6
TEX. R. CIV. P. 193.7 - Page 1
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing Notice of Intent to Use
Discovery Against Defendant(s) Pursuant to Tex. R. Civ. P. 193.7 was served in
accordance with Rule 21 of the Texas Rules of Civil Procedure on all counsel of record
and/or pro se parties on this 2nd day of March, 201 8.
/s/ Cameron Dean
Cameron Dean
PLAINTIFF'§ NGTICE 6F INTENT T6 U§E DI§CGVERY AGAINgT DEFENDANT(§) PUR§UANT T6
TEX. R. CIV. P. 193.7 - Page 2
Document Filed Date
March 02, 2018
Case Filing Date
August 17, 2017
Category
MOTOR VEHICLE ACCIDENT
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FILED DALLAS COUNT 3/2/2018 9:28 AM FELICIA PITRE DISTRICT CLER CAUSE NO. DC-1 7-1 0220 NICOLE E. DOWNlE-FRASER, IN THE DISTRICT COURT Plaintiff, v. 95th JUDICIAL DISTRICT VALERIA SAINZ, Defendant. DALLAS COUNTY, TEXAS PLAINTIFF'S NOTICE OF INTENT TO USE DISCOVERY AGAINST DEFENDANT PURSUANT TO TEX. R. CIV. P. 193.7 TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW PLAINTIFF NICOLE E. DOWNIE-FRASER ("Plaintiff“) in the above styled and numbered cause of action, and by and through the undersigned attorney files this Notice of Intent to Use Discovery Against Defendant pursuant to Texas Rule of Civil Procedure 193.7. Plaintiff intends to use documents and tangible things produced by Defendant VALERIA SAINZ, Said documents may be used against Defendant VALERIA SAINZ in all pretrial proceedings and at time of trial against Defendant VALERIA SAINZ. Respectfully submitted, /s/ Cameron Dean Cameron Dean State Bar No. 2408291 0 Ben Abbott & Associates, PLLC 1934 Pendleton Drive Garland, TX 75041 (972) 263-5555 (81 7) 263-5555 (972) 682-7586 Facsimile eService@benabbott.com ATTORNEYS FOR PLAINTIFF PLAINTIFF'§ NGTICE 6F INTENT T6 USE DISCGVERY AGAIN§T DEFENDANT(§) PUR§UANT T6 TEX. R. CIV. P. 193.7 - Page 1 CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing Notice of Intent to Use Discovery Against Defendant(s) Pursuant to Tex. R. Civ. P. 193.7 was served in accordance with Rule 21 of the Texas Rules of Civil Procedure on all counsel of record and/or pro se parties on this 2nd day of March, 201 8. /s/ Cameron Dean Cameron Dean PLAINTIFF'§ NGTICE 6F INTENT T6 U§E DI§CGVERY AGAINgT DEFENDANT(§) PUR§UANT T6 TEX. R. CIV. P. 193.7 - Page 2