Preview
FILED
9/28/2023 5:20 PM
FELICIA PITRE
DISTRICT CLERK
DC-22-15312 DALLAS CO., TEXAS
Keith Wilkins vs. La Frontera Holdings, LLC Harper Ream DEPUTY
SUBPOENA DUCES TECUM
C ounty of Dallas
THE STATE OF TEXAS
Greeting, to any Sheriff or Constable of the State of Texas or other person authorized to serve subpoenas under Rule I76 of
Texas Rules of Civil Procedure: You are hereby commanded to subpoena and summon the following witness(es):
Designated Custodian of Record; for: PTW INDUSTRIAL SERVICES, LLC
to be and appear before a Notary Public of my designation for Written Deposition Service, LLC,
1755 Whittington Place,
Suite 750, Dallas, TX
75234, on or afler 10/11/2023 at the office of the summoned witness. There under oath to make answers
of certain written questions to be propounded to the witness and to bring and produce for inspection and photocopying ANY
AND ALL EMPLOYMENT AND PAYROLL RECORDS, INCLUDING BUT NOT LIMITED TO, THE EMPLOYMENT FILE,
COMPENSATION RECORDS. EMPLOYMENT APPLICATIONS, RESUMES, TRAINING RECORDS. ATTENDANCE OR
TIME RECORDS. PERFORMANCE EVALUATIONS, INCIDENT OR ACCIDENT REPORTS, INSURANCE RECORDS,
WORKERS AND/OR UNEMPLOYMENT COMPENSATION, LISTING OF SALARY FOR EACH YEAR, WAGE AND
PAYROLL FILES, W-2 FORMS, 1099 FORMS, DISCIPLINARY RECORDS, SICK TIME REPORTS, MEDICAL BENEFITS OR
OTHER BENEFITS THAT MAY HAVE BEEN PAID OR AVAILABLE TO THE INDIVIDUAL, 401K AND RETIREMENT
PLANS, REPRIMANDS. NOTICES, RESIGNATIONS, TERMINATION RECORDS, CORRESPONDENCE, EVERY SUCH
RECORD, INCLUDING BUT NOT LIMITED TO, THOSE EXISTING IN ELECTRONIC OR MAGNETIC FORM, AND ANY
OTHER THING IN POSSESSION. CUSTODY 0R CONTROL OF SAID WITNESS PERTAINING TO KEITH ALLEN
WILKINS; DOB: ; at any and all times whatsoever.
Then and there to give evidence at the instance of the Defendant, La Frontera Holdings, LLC, represented by Walter A.
Herring wherring@bbhsllp.c0m Texas Bar No. 09535300 Attorney of Record, in that Certain Cause No. DC-22-15312,
pending on the docket of the Di trict Court of the 68th Judicial District of Dallas Coun Texas.
This Subpoena is issued under and by virtue of Rule 200 and Notice of Deposition Upon Written Questions on file with the
above named court, styled
Keith Wilkins vs. La Fronlera Holdings, LLC
' '
and there remain from day to day and time to time un charge according to law.
WITNESS MY HAND, this day 0
‘
\‘\\\ullu,,,
N WHiTESIDES
"fig/z, No‘ary public,
. ----
z
State of Texas
-10 23 NOTARY UBLIC
e C 0mm. Expires 12—07
We °= 46426
Contempt. Failure by any person without adequate excuse to obey a subpoena served
erson may be deemed a contempt of the court from which the subpoena is issued or a district court in the county in
which the subpoena is served, and may be punished by fine or confinement, or both. This subpoena falls under exception to
confidentiality, Rule 509 (e) Texas rules of Civil
Se \REfi‘I‘VéJRN ¢ 1%“
I
Came to hand this may of 8&1 5
avirdérlicczfi and executed this the wday of 5?71’ , 20 23 . in
the following manner: By delivering to the witness*KA2N‘ ISMSS , a true copy hereof,
with attached witness fee of$ 0D i' ->1llé1il‘* 5T SLU TC Cb'w MST/N, TX Want
Returned this 2m day of .2013 .
OrderNo. 75982.001 P5101333 SET/ER,
Jar, Mcléu
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: 80068920
Filing Code Description: Return Of Service
Filing Description: EXECUTED ATTORNEY ISSUED SUBPOENA - PTW
INDUSTRIAL SERVICES, LLC
Status as of 9/29/2023 10:09 AM CST
Associated Case Party: LA FRONTERA HOLDINGS, LLC
Name BarNumber Email TimestampSubmitted Status
Walter A.Herring wherring@bbhsllp.com 9/28/2023 5:20:25 PM SENT
Robert Blackwell bblackwell@bbhsllp.com 9/28/2023 5:20:25 PM SENT
Lindsey Reinhardt Ireinhardt@bbhsllp.com 9/28/2023 5:20:25 PM SENT
Sharon Bruner sbruner@bbhsllp.com 9/28/2023 5:20:25 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
ANTHONY GBUZBEE TBUZBEE@TXATTORNEYS.COM 9/28/2023 5:20:25 PM SENT
Associated Case Party: KEITH WILKINS
Name BarNumber Email TimestampSubmitted Status
Michael Eddington meddington@txattorneys.com 9/28/2023 5:20:25 PM SENT
Preview
FILED 9/28/2023 5:20 PM FELICIA PITRE DISTRICT CLERK DC-22-15312 DALLAS CO., TEXAS Keith Wilkins vs. La Frontera Holdings, LLC Harper Ream DEPUTY SUBPOENA DUCES TECUM C ounty of Dallas THE STATE OF TEXAS Greeting, to any Sheriff or Constable of the State of Texas or other person authorized to serve subpoenas under Rule I76 of Texas Rules of Civil Procedure: You are hereby commanded to subpoena and summon the following witness(es): Designated Custodian of Record; for: PTW INDUSTRIAL SERVICES, LLC to be and appear before a Notary Public of my designation for Written Deposition Service, LLC, 1755 Whittington Place, Suite 750, Dallas, TX 75234, on or afler 10/11/2023 at the office of the summoned witness. There under oath to make answers of certain written questions to be propounded to the witness and to bring and produce for inspection and photocopying ANY AND ALL EMPLOYMENT AND PAYROLL RECORDS, INCLUDING BUT NOT LIMITED TO, THE EMPLOYMENT FILE, COMPENSATION RECORDS. EMPLOYMENT APPLICATIONS, RESUMES, TRAINING RECORDS. ATTENDANCE OR TIME RECORDS. PERFORMANCE EVALUATIONS, INCIDENT OR ACCIDENT REPORTS, INSURANCE RECORDS, WORKERS AND/OR UNEMPLOYMENT COMPENSATION, LISTING OF SALARY FOR EACH YEAR, WAGE AND PAYROLL FILES, W-2 FORMS, 1099 FORMS, DISCIPLINARY RECORDS, SICK TIME REPORTS, MEDICAL BENEFITS OR OTHER BENEFITS THAT MAY HAVE BEEN PAID OR AVAILABLE TO THE INDIVIDUAL, 401K AND RETIREMENT PLANS, REPRIMANDS. NOTICES, RESIGNATIONS, TERMINATION RECORDS, CORRESPONDENCE, EVERY SUCH RECORD, INCLUDING BUT NOT LIMITED TO, THOSE EXISTING IN ELECTRONIC OR MAGNETIC FORM, AND ANY OTHER THING IN POSSESSION. CUSTODY 0R CONTROL OF SAID WITNESS PERTAINING TO KEITH ALLEN WILKINS; DOB: ; at any and all times whatsoever. Then and there to give evidence at the instance of the Defendant, La Frontera Holdings, LLC, represented by Walter A. Herring wherring@bbhsllp.c0m Texas Bar No. 09535300 Attorney of Record, in that Certain Cause No. DC-22-15312, pending on the docket of the Di trict Court of the 68th Judicial District of Dallas Coun Texas. This Subpoena is issued under and by virtue of Rule 200 and Notice of Deposition Upon Written Questions on file with the above named court, styled Keith Wilkins vs. La Fronlera Holdings, LLC ' ' and there remain from day to day and time to time un charge according to law. WITNESS MY HAND, this day 0 ‘ \‘\\\ullu,,, N WHiTESIDES "fig/z, No‘ary public, . ---- z State of Texas -10 23 NOTARY UBLIC e C 0mm. Expires 12—07 We °= 46426 Contempt. Failure by any person without adequate excuse to obey a subpoena served erson may be deemed a contempt of the court from which the subpoena is issued or a district court in the county in which the subpoena is served, and may be punished by fine or confinement, or both. This subpoena falls under exception to confidentiality, Rule 509 (e) Texas rules of Civil Se \REfi‘I‘VéJRN ¢ 1%“ I Came to hand this may of 8&1 5 avirdérlicczfi and executed this the wday of 5?71’ , 20 23 . in the following manner: By delivering to the witness*KA2N‘ ISMSS , a true copy hereof, with attached witness fee of$ 0D i' ->1llé1il‘* 5T SLU TC Cb'w MST/N, TX Want Returned this 2m day of .2013 . OrderNo. 75982.001 P5101333 SET/ER, Jar, Mcléu 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: 80068920 Filing Code Description: Return Of Service Filing Description: EXECUTED ATTORNEY ISSUED SUBPOENA - PTW INDUSTRIAL SERVICES, LLC Status as of 9/29/2023 10:09 AM CST Associated Case Party: LA FRONTERA HOLDINGS, LLC Name BarNumber Email TimestampSubmitted Status Walter A.Herring wherring@bbhsllp.com 9/28/2023 5:20:25 PM SENT Robert Blackwell bblackwell@bbhsllp.com 9/28/2023 5:20:25 PM SENT Lindsey Reinhardt Ireinhardt@bbhsllp.com 9/28/2023 5:20:25 PM SENT Sharon Bruner sbruner@bbhsllp.com 9/28/2023 5:20:25 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status ANTHONY GBUZBEE TBUZBEE@TXATTORNEYS.COM 9/28/2023 5:20:25 PM SENT Associated Case Party: KEITH WILKINS Name BarNumber Email TimestampSubmitted Status Michael Eddington meddington@txattorneys.com 9/28/2023 5:20:25 PM SENT