Preview
FILED
9/16/2020 3:38 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Darling Tellez DEPUTY
US. Legaf
Support
A Record Retrieval Company
September l6, 2020
Exhibit ‘A' Records Request Please contact us.-
Phone: (713) 653-7150
Fax: (28 I) 6 73-6292
Attn: Exhibit 'A' - Records Custodian swpraductionCiuslegalsupport.com
Texas Department of Public Safety - Motor Carrier Bureau
6200 Guadalupe Street, Bldg. P
Austin, TX 78752
Records pertaining to: James Gomez
DOB: 10/06/1966 ; SSN:
Records Requested: any and all records and/or documents as described in the attached Exhibit 'A'
Dear Sir’Madam:
U.S. Legal Support Inc. is a records retrieval service company that provides litigation support to the legal and insurance
industry. Our attomey/client has requested that we locate records specified in the enclosed legal documents, within 20
(lays.
Please provide all requested documentation and complete each document accurately and completely. Please
check that all
copies are legible, and that no information SUBPOENA WITH
is omitted. Enclosed is a A DEPOSITION BY
WRITTEN QUESTIONS AND/OR AFFIDAVIT. Please assist us by:
. Answering ALL questions.
. SIGN the deposition by written questions and/or affidavit.
#leH
. Have the signatures NOTARIZED.
. Return all ORIGINAL completed documents with a legible copy of the records to:
U.S. LEGAL SUPPORT, INC.
RECORDS DIVISION
16825 NORTHCHASE DRIVE, SUITE 800
HOUSTON, TEXAS 77060
m
***FEE NOT!FICATION***
D0 NOT COMPLETE THE REQUEST WITHOUT US LEGAL SUPPORT APPROVAL FOR
ANY FEES OVER $75.00.
Call (7 l 3) 653-71 50 ask for an expediter and reference thefollowing
number when calling: 147768.001. We will be happy
to assist you in completing this request.
Best regards,
U.S. Legal Support Inc.
Order No.2 |47768.00| Bianca Belmarez
DEPOSITION SUBPOENA TO PRODUCE DOCUMENTS 0R THINGS
The State 0f Texas
County of Dallas
To any Sheriff or Constable of the State of Texas or other person authorized to serve subpoenas under RULE 176 0F T.R.C.P. —
GREETINGS — YOU ARE HEREBY COMMANDED TO SUBPOENA AND SUMMON THE FOLLOWING WITNESS:
CUSTODIAN OF RECORDS FOR:
Texas Department of Public Safety - Motor Carrier Bureau
to be and appear before a Notary Public of my designation in the State of Texas for U.S. Legal Support lnc., 16825 Northchase Dr.,
Suite 800, Houston, TX 77060 0n the forthwith day 0f instanter, 2020 but in any case, no later than 20 days. at the office of the
custodian and there to make answers under oath of certain written questions to be propounded to the Custodian of Records and to
bring and produce for inspection and photocopying a true and correct copy of the duces tecum. any and all records and/or
documents as described in the attached Exhibit ‘A' at any and all times whatsoever, then and there to give evidence at the instance
of the Plaintiff represented by Paige Eldridge in that certain Cause No. DC-l9-10926 pending on the docket, In The District Court Of
Dallas County, Texas 160th Judicial District . This subpoena is issued under and by virtue of authority of a notice duly served and
on file with the above named court, in which
Vashone Rhodes
iSIare the Plaintiff(s) and
James Gomez
isiare the Defendant(s)
and there remain from day to day and time to time until discharged according to law. Pursuant to rule 176.8 Enforcement of
Subpoena. (a) Contempt. Failure by any person without adequate excuse to obey a subpoena served upon that person 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.
Pursuant to HIPAA §164.512(e); Rules 176 and 200. Texas Rules of Civil Procedure this subpoena is issued in accordance with
and by virtue of a notice duly served and on file with the above named court, and falls under exception to confidentiality, Rule
509(c)(4) Texas Rules of Evidence. HIPAA Verification attached and incorporated fully herein.
WITNESS MY HAND, this Lth day of September, 2_02_0.
“"2359, IHERESA CASES
"’-’—’=
Notary Pubiic. State at Texas
9W [36%
..... CommExpiras 09-13«2022
) 6‘5
q.....}\o‘ Nozavy m 125623618
NOTARY PUBLIC
OrderNo 147768.001 (Bianca Belmarez)
OFFICER'S RETURN
Came to hand this day of ,
20 at AM PM and executed this by delivering same to the within
named witness , all fees have been tendered in accordance with the Texas Rules of Civil Procedure.
Witness Signature of Receipt Officers Signature
And acceptance of subpoena
Order N0. [47768.00] (Bianca Belmarez)
Cause No. 9619-10926
§
Vashone Rhodes In The District Court Of
g
vs.
Dallas County, Texas
g
James Gomez 160th Judicial District
g
§
NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS
To (s) by and through their attornefls) ofrecord: To other pany/parties by and through their attorneyt's)
.
of record: Adam Lecrone (Lecrone Law Firm. P.C.) and Randall G. Walters (Walters. Balido &
Crain.
L.L.P.)
YOU WILL TAKE NOTICE THAT twenty (20) days after service of a copy hereof with attached
questions‘ a deposition by written questions will be taken of Custodian of Records at the address listed
below:
1 - Texas Department of Public Safety - Motor Carrier Bureau (Exhibit 'A')
6200 Guadalupe Street, Bldg. P, Austin, TX 78752
Before a Notary Public for:
U.S. Legal Support Inc.
168.25 Northchase Dr., Suite 800
Houston, TX 77060
Which deposition with attached questions may be uSed in evidence upon the
ofthe above—styled and
trial
numbered cause pending in the above named court. Notice is further given
is hereby made as
that request
authorized under Rules 176 and 200. Texas Rules of Civil Procedure. to the officer
taking this deposition
to issue a subpoena duces tecum and cause to be served on the witness to bring and produce for
'lt
inspection and photocopying a true and correct copy of records described in
the attached Wrinen
Questions and to tum all such records over to the officer authorized to take this
deposition so that
photographic reproductions ofthe same may be made and attached to said deposition.
Paige Eldridge
SBA # 24096747
paige.eldridge@witheritelaw.com
Witherite Law Group
10440 North Central Expressway, Suite 400
Dallas,TX 75231
Phone: (800) 227—9732; Fax:
Wm amtgcw n
Attorney for Plaintiffls)
P‘aige Eldfidge
Order No 147768 (Blum'n Belmnrez)
CERTIFlCATE OF SERVICE
l hereby celtify that a true and correct copy of the foregoing Notice of Intention to Take Deposition upon
Written Questions was served to the respective parties and? r attorneys of record by __ cenified mail
with return receipt requested: m hand delivery; _ fax; ielectronic serve; or _____ UPS.
Dated:
qk
“fl (m
By pennission: gm
Hf’aige tldridge
Should you desire copies of
the so obtained, contact our firm.
713-653-7100
Order Na 147768 (Blanca Belmnrez)
Cause N0. DC-l9-10926
§
Vashone Rhodes § In The District Court 0f
§
vs. § Dallas County, Texas
§
James Gomez 160th Judicial District
g
ATTORNEYS OF RECORD:
Adam Lecrone
Lecrone Law Firm. P.C.
l23 North Crocken Street
Suite 200
Sherman TX 75090
Phone: 903-8 l 3-l 900 Fax: 903-8 3-1
l 944
Attorney for Defendant(s): James Gomez
Paige Eldridge
Witherite Law Group
10440 Noah Central Expressway, Suite 400
Dallas. TX 7523]
Phone: 214-378-6665 Fax: 214-378-6670
Attorney for Plaintiff(s): Vashone Rhodes
Randal} G. Walters
Walters, Balido & Crain. L.L.P.
10440 North Central Expressway
Suite 1550
Dallas, TX 75231
Phone: 214-749-4805 Fax: 214-347-838]
Anomey for Defendant(s): Exclusive Nationwide Delivery. Inc.
Order No {47768 (Bianca Belmnm)
Cause No. DC-l 9-10926
Vashone Rhodes § In The District Court Of
§
vs. § Dallas County, Texas
§
James Gomez § 160th Judicial District
DIRECT QUESTlONS T0 BE PROPOUNDED T0 THE WITNESS w
Custodian of Records for: Texas Department of Public Safety - Motor Carrier Bureau
Records Pertaining to: James Gomez
Type of Records: any and all records and/or documents as described in the attached Exhibit 'A'
1. Please state your full name, address. telephone number, occupation and official title.
ANSWER
TJ
I am the custodian for
(Please insert facility or practitioner name.)
3. Have you received a subpoena duces tecum for the production of those documents listed above?
ANSWER
4. Are you among those who have possession, custody. control of. or access to the documents requested
above?
ANSWER
5. Were the records requested above made in the regular course of business?
ANSWER
6. Was it in the regular course of business of the above listed facility or practitioner for a person with
knowledge of the act, event. condition. opinion. or diagnosis recorded to make the record or to transmit
information thereofto be included in such record?
ANSWER
7. State whether these records were made at the time or shortly afier the time of the transactions recorded?
ANSWER
8. Were these records kept as described in the preceding questions?
ANSWER
9. Does the source of the information. and the method and circumstance of its preparation, establish the
trustworthiness of the records?
ANSWER
Order No 147168.001 (Blanca Belmarcz)
Please release exact duplicates ofthe records as requested in the subpoena duces tecum or the originais
thereof for photocopying for attachment to this deposition. Have you done as requested? If not. why not?
ANSWER
Are there any records, documents. papers. correspondence or tangible matters 0f any kind pertaining to
James Gomez that you have NOT provided to the notary public taking your deposition?
ANSWER
12. Please describe all papers. documents. records. correspondence. or tangible matters of any kind that you
have not provided to the notary public taking your deposition and explain why you have NOT provided
them.
ANSWER
I3. Are you aware that it may be necessary to subpoena you or your employer to court at the time ot‘the trial
of this case. if you have not provided to the notary public taking your deposition all papers. documents.
records. correspondence. or tangible matters of any kind pertaining to James Gomez?
ANSWER
WlTN ESS (Custodian of Records)
Before me, the undersigned aulhnril‘y. on this day personally appeared
. custodian of records for the above listed. known to me to
be the person whose name
subscribed to the foregoing instrument in the capacity therein stated, who being first
is
duly sworn. stated upon his/her oath that the answers to the foregoing questions are true and correct. l further
cenify that the records attached hereto are exact duplicates of the original records.
SWORN T0 AND SUBSCRIBED before me this day of 2O
NOTARY PUBLIC
Order Nn 147768.00l (Bianca Belmarez)
EXHIBIT “A"
TO: Texas Department of Public Safety
Motor Carrier Division
6200 Guadalupe Street
Austin, TX 78752
RE: PIaintiff/Driver: Vashone Rhodes
CMV/Truck Driver: James Gomez (CDL #01359088 and DOB: 10/06/1966)
Truck Company: Exclusive Nationwide Delivery, Inc. (USDOT #1 836771)
Date of Injury: 11/27/2018
RECORDS REGARDING TRUCK DRW§BITR4LJCK COMPANY HISTORY:
1. Any and all motor carrier records for Exclusive Nationwide Delivery (USDOT #1836771).
2. Any and all motor carrierlCDL records for driver, James Gomez (CDL #01359088 and
DOB: 10/06/1966).
EXHIBIT “B":
TO: TXDOT
125 E. 11th Street
Austin, TX 78701
(512) 463-8588
TxDOT_ORR@txdot.gov
Email:
(TXDOT no longer accepts open records requests by fax)
RE: Plaintifleriver: Vashone Rhodes
CMV/Truck Driver: James Gomez (CDL #01359088 and DOB: 10/06/1966)
Truck Company: Exclusive Nationwide Delivery, inc. (USDOT #1 836771)
Date of Injury: 11/27/2018
RECORDS REGARDING TRUCK DRIVQRNRUCK COMPANY HISTORY:
’1.
Any and all prior investigation records for Exclusive Nationwide Delivery (USDOT
#1836771).
Any and ail prior investigation records for driver, James Gomez (CDL #01359088 and
DOB: 10/06/1966).
EXHIBIT “C":
Our normalcell phone records requests on truck driver. James Gomez (CDL #01359088 and
DOB: 10/06/1966) to the following providers from 6:00 a.m. to 12:00 p.m. on 11/27/2018:
214-755-0570 AT&T
817-452-4076 American Messaging Services, LLC (headquarters)
1720 Lakepointe Drive. Suite 100
Lewisville, TX 75057
972-264-9398 Neutral Tandem (headquarters)
550 West Adams, Suite 900
Chicago, Ii. 60661
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: 463001 05
Status as of 9/1 7/2020 8:58 AM CST
Associated Case Party: VASHONE RHODES
Name BarNumber Email TimestampSubmitted Status
Amy Witherite 788698 amy.witherite@witheritelaw.com 9/16/2020 3:38:41 PM SENT
Paige Eldridge paige.eldridge@ewlawyers.com 9/16/2020 3:38:41 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Craig Laird PCL@LAIRD.LAWYER 9/16/2020 3:38:41 PM SENT
PAIGE VELDRIDGE paiqe.eldridqe@ewlawyers.com 9/16/2020 3:38:41 PM ERROR
Associated Case Party: JAMES GOMEZ
Name BarNumber Email TimestampSubmitted Status
Adam LeCrone eservice@lecronelaw.com 9/1 6/2020 3:38:41 PM SENT
Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC
Name BarNumber Email TimestampSubmitted Status
Randall GWaIters waItersedocsnotifications@wbclawfirm.com 9/16/2020 3:38:41 PM SENT
Nadine K Weatherall nadine.weatherall@wbclawfirm.com 9/16/2020 3:38:41 PM SENT
Preview
FILED 9/16/2020 3:38 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Darling Tellez DEPUTY US. Legaf Support A Record Retrieval Company September l6, 2020 Exhibit ‘A' Records Request Please contact us.- Phone: (713) 653-7150 Fax: (28 I) 6 73-6292 Attn: Exhibit 'A' - Records Custodian swpraductionCiuslegalsupport.com Texas Department of Public Safety - Motor Carrier Bureau 6200 Guadalupe Street, Bldg. P Austin, TX 78752 Records pertaining to: James Gomez DOB: 10/06/1966 ; SSN: Records Requested: any and all records and/or documents as described in the attached Exhibit 'A' Dear Sir’Madam: U.S. Legal Support Inc. is a records retrieval service company that provides litigation support to the legal and insurance industry. Our attomey/client has requested that we locate records specified in the enclosed legal documents, within 20 (lays. Please provide all requested documentation and complete each document accurately and completely. Please check that all copies are legible, and that no information SUBPOENA WITH is omitted. Enclosed is a A DEPOSITION BY WRITTEN QUESTIONS AND/OR AFFIDAVIT. Please assist us by: . Answering ALL questions. . SIGN the deposition by written questions and/or affidavit. #leH . Have the signatures NOTARIZED. . Return all ORIGINAL completed documents with a legible copy of the records to: U.S. LEGAL SUPPORT, INC. RECORDS DIVISION 16825 NORTHCHASE DRIVE, SUITE 800 HOUSTON, TEXAS 77060 m ***FEE NOT!FICATION*** D0 NOT COMPLETE THE REQUEST WITHOUT US LEGAL SUPPORT APPROVAL FOR ANY FEES OVER $75.00. Call (7 l 3) 653-71 50 ask for an expediter and reference thefollowing number when calling: 147768.001. We will be happy to assist you in completing this request. Best regards, U.S. Legal Support Inc. Order No.2 |47768.00| Bianca Belmarez DEPOSITION SUBPOENA TO PRODUCE DOCUMENTS 0R THINGS The State 0f Texas County of Dallas To any Sheriff or Constable of the State of Texas or other person authorized to serve subpoenas under RULE 176 0F T.R.C.P. — GREETINGS — YOU ARE HEREBY COMMANDED TO SUBPOENA AND SUMMON THE FOLLOWING WITNESS: CUSTODIAN OF RECORDS FOR: Texas Department of Public Safety - Motor Carrier Bureau to be and appear before a Notary Public of my designation in the State of Texas for U.S. Legal Support lnc., 16825 Northchase Dr., Suite 800, Houston, TX 77060 0n the forthwith day 0f instanter, 2020 but in any case, no later than 20 days. at the office of the custodian and there to make answers under oath of certain written questions to be propounded to the Custodian of Records and to bring and produce for inspection and photocopying a true and correct copy of the duces tecum. any and all records and/or documents as described in the attached Exhibit ‘A' at any and all times whatsoever, then and there to give evidence at the instance of the Plaintiff represented by Paige Eldridge in that certain Cause No. DC-l9-10926 pending on the docket, In The District Court Of Dallas County, Texas 160th Judicial District . This subpoena is issued under and by virtue of authority of a notice duly served and on file with the above named court, in which Vashone Rhodes iSIare the Plaintiff(s) and James Gomez isiare the Defendant(s) and there remain from day to day and time to time until discharged according to law. Pursuant to rule 176.8 Enforcement of Subpoena. (a) Contempt. Failure by any person without adequate excuse to obey a subpoena served upon that person 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. Pursuant to HIPAA §164.512(e); Rules 176 and 200. Texas Rules of Civil Procedure this subpoena is issued in accordance with and by virtue of a notice duly served and on file with the above named court, and falls under exception to confidentiality, Rule 509(c)(4) Texas Rules of Evidence. HIPAA Verification attached and incorporated fully herein. WITNESS MY HAND, this Lth day of September, 2_02_0. “"2359, IHERESA CASES "’-’—’= Notary Pubiic. State at Texas 9W [36% ..... CommExpiras 09-13«2022 ) 6‘5 q.....}\o‘ Nozavy m 125623618 NOTARY PUBLIC OrderNo 147768.001 (Bianca Belmarez) OFFICER'S RETURN Came to hand this day of , 20 at AM PM and executed this by delivering same to the within named witness , all fees have been tendered in accordance with the Texas Rules of Civil Procedure. Witness Signature of Receipt Officers Signature And acceptance of subpoena Order N0. [47768.00] (Bianca Belmarez) Cause No. 9619-10926 § Vashone Rhodes In The District Court Of g vs. Dallas County, Texas g James Gomez 160th Judicial District g § NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS To (s) by and through their attornefls) ofrecord: To other pany/parties by and through their attorneyt's) . of record: Adam Lecrone (Lecrone Law Firm. P.C.) and Randall G. Walters (Walters. Balido & Crain. L.L.P.) YOU WILL TAKE NOTICE THAT twenty (20) days after service of a copy hereof with attached questions‘ a deposition by written questions will be taken of Custodian of Records at the address listed below: 1 - Texas Department of Public Safety - Motor Carrier Bureau (Exhibit 'A') 6200 Guadalupe Street, Bldg. P, Austin, TX 78752 Before a Notary Public for: U.S. Legal Support Inc. 168.25 Northchase Dr., Suite 800 Houston, TX 77060 Which deposition with attached questions may be uSed in evidence upon the ofthe above—styled and trial numbered cause pending in the above named court. Notice is further given is hereby made as that request authorized under Rules 176 and 200. Texas Rules of Civil Procedure. to the officer taking this deposition to issue a subpoena duces tecum and cause to be served on the witness to bring and produce for 'lt inspection and photocopying a true and correct copy of records described in the attached Wrinen Questions and to tum all such records over to the officer authorized to take this deposition so that photographic reproductions ofthe same may be made and attached to said deposition. Paige Eldridge SBA # 24096747 paige.eldridge@witheritelaw.com Witherite Law Group 10440 North Central Expressway, Suite 400 Dallas,TX 75231 Phone: (800) 227—9732; Fax: Wm amtgcw n Attorney for Plaintiffls) P‘aige Eldfidge Order No 147768 (Blum'n Belmnrez) CERTIFlCATE OF SERVICE l hereby celtify that a true and correct copy of the foregoing Notice of Intention to Take Deposition upon Written Questions was served to the respective parties and? r attorneys of record by __ cenified mail with return receipt requested: m hand delivery; _ fax; ielectronic serve; or _____ UPS. Dated: qk “fl (m By pennission: gm Hf’aige tldridge Should you desire copies of the so obtained, contact our firm. 713-653-7100 Order Na 147768 (Blanca Belmnrez) Cause N0. DC-l9-10926 § Vashone Rhodes § In The District Court 0f § vs. § Dallas County, Texas § James Gomez 160th Judicial District g ATTORNEYS OF RECORD: Adam Lecrone Lecrone Law Firm. P.C. l23 North Crocken Street Suite 200 Sherman TX 75090 Phone: 903-8 l 3-l 900 Fax: 903-8 3-1 l 944 Attorney for Defendant(s): James Gomez Paige Eldridge Witherite Law Group 10440 Noah Central Expressway, Suite 400 Dallas. TX 7523] Phone: 214-378-6665 Fax: 214-378-6670 Attorney for Plaintiff(s): Vashone Rhodes Randal} G. Walters Walters, Balido & Crain. L.L.P. 10440 North Central Expressway Suite 1550 Dallas, TX 75231 Phone: 214-749-4805 Fax: 214-347-838] Anomey for Defendant(s): Exclusive Nationwide Delivery. Inc. Order No {47768 (Bianca Belmnm) Cause No. DC-l 9-10926 Vashone Rhodes § In The District Court Of § vs. § Dallas County, Texas § James Gomez § 160th Judicial District DIRECT QUESTlONS T0 BE PROPOUNDED T0 THE WITNESS w Custodian of Records for: Texas Department of Public Safety - Motor Carrier Bureau Records Pertaining to: James Gomez Type of Records: any and all records and/or documents as described in the attached Exhibit 'A' 1. Please state your full name, address. telephone number, occupation and official title. ANSWER TJ I am the custodian for (Please insert facility or practitioner name.) 3. Have you received a subpoena duces tecum for the production of those documents listed above? ANSWER 4. Are you among those who have possession, custody. control of. or access to the documents requested above? ANSWER 5. Were the records requested above made in the regular course of business? ANSWER 6. Was it in the regular course of business of the above listed facility or practitioner for a person with knowledge of the act, event. condition. opinion. or diagnosis recorded to make the record or to transmit information thereofto be included in such record? ANSWER 7. State whether these records were made at the time or shortly afier the time of the transactions recorded? ANSWER 8. Were these records kept as described in the preceding questions? ANSWER 9. Does the source of the information. and the method and circumstance of its preparation, establish the trustworthiness of the records? ANSWER Order No 147168.001 (Blanca Belmarcz) Please release exact duplicates ofthe records as requested in the subpoena duces tecum or the originais thereof for photocopying for attachment to this deposition. Have you done as requested? If not. why not? ANSWER Are there any records, documents. papers. correspondence or tangible matters 0f any kind pertaining to James Gomez that you have NOT provided to the notary public taking your deposition? ANSWER 12. Please describe all papers. documents. records. correspondence. or tangible matters of any kind that you have not provided to the notary public taking your deposition and explain why you have NOT provided them. ANSWER I3. Are you aware that it may be necessary to subpoena you or your employer to court at the time ot‘the trial of this case. if you have not provided to the notary public taking your deposition all papers. documents. records. correspondence. or tangible matters of any kind pertaining to James Gomez? ANSWER WlTN ESS (Custodian of Records) Before me, the undersigned aulhnril‘y. on this day personally appeared . custodian of records for the above listed. known to me to be the person whose name subscribed to the foregoing instrument in the capacity therein stated, who being first is duly sworn. stated upon his/her oath that the answers to the foregoing questions are true and correct. l further cenify that the records attached hereto are exact duplicates of the original records. SWORN T0 AND SUBSCRIBED before me this day of 2O NOTARY PUBLIC Order Nn 147768.00l (Bianca Belmarez) EXHIBIT “A" TO: Texas Department of Public Safety Motor Carrier Division 6200 Guadalupe Street Austin, TX 78752 RE: PIaintiff/Driver: Vashone Rhodes CMV/Truck Driver: James Gomez (CDL #01359088 and DOB: 10/06/1966) Truck Company: Exclusive Nationwide Delivery, Inc. (USDOT #1 836771) Date of Injury: 11/27/2018 RECORDS REGARDING TRUCK DRW§BITR4LJCK COMPANY HISTORY: 1. Any and all motor carrier records for Exclusive Nationwide Delivery (USDOT #1836771). 2. Any and all motor carrierlCDL records for driver, James Gomez (CDL #01359088 and DOB: 10/06/1966). EXHIBIT “B": TO: TXDOT 125 E. 11th Street Austin, TX 78701 (512) 463-8588 TxDOT_ORR@txdot.gov Email: (TXDOT no longer accepts open records requests by fax) RE: Plaintifleriver: Vashone Rhodes CMV/Truck Driver: James Gomez (CDL #01359088 and DOB: 10/06/1966) Truck Company: Exclusive Nationwide Delivery, inc. (USDOT #1 836771) Date of Injury: 11/27/2018 RECORDS REGARDING TRUCK DRIVQRNRUCK COMPANY HISTORY: ’1. Any and all prior investigation records for Exclusive Nationwide Delivery (USDOT #1836771). Any and ail prior investigation records for driver, James Gomez (CDL #01359088 and DOB: 10/06/1966). EXHIBIT “C": Our normalcell phone records requests on truck driver. James Gomez (CDL #01359088 and DOB: 10/06/1966) to the following providers from 6:00 a.m. to 12:00 p.m. on 11/27/2018: 214-755-0570 AT&T 817-452-4076 American Messaging Services, LLC (headquarters) 1720 Lakepointe Drive. Suite 100 Lewisville, TX 75057 972-264-9398 Neutral Tandem (headquarters) 550 West Adams, Suite 900 Chicago, Ii. 60661 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: 463001 05 Status as of 9/1 7/2020 8:58 AM CST Associated Case Party: VASHONE RHODES Name BarNumber Email TimestampSubmitted Status Amy Witherite 788698 amy.witherite@witheritelaw.com 9/16/2020 3:38:41 PM SENT Paige Eldridge paige.eldridge@ewlawyers.com 9/16/2020 3:38:41 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Craig Laird PCL@LAIRD.LAWYER 9/16/2020 3:38:41 PM SENT PAIGE VELDRIDGE paiqe.eldridqe@ewlawyers.com 9/16/2020 3:38:41 PM ERROR Associated Case Party: JAMES GOMEZ Name BarNumber Email TimestampSubmitted Status Adam LeCrone eservice@lecronelaw.com 9/1 6/2020 3:38:41 PM SENT Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC Name BarNumber Email TimestampSubmitted Status Randall GWaIters waItersedocsnotifications@wbclawfirm.com 9/16/2020 3:38:41 PM SENT Nadine K Weatherall nadine.weatherall@wbclawfirm.com 9/16/2020 3:38:41 PM SENT