Preview
FILED
10/7/2020 1:54 PM
FELICIA PITRE
DISTRICT CLERK
Cause No. DC—l9—10926
DC-19-10926 DALLAS CO., TEXAS
Darling Tellez DEPUTY
Vashone Rhodes In the
the District
District Court of
of
vs.
vs. mmmwmmww
Dallas County,
Dallas County, Texas
James Gomez 160th
160th Judicial
Judicial District
District
SECOND AMENDED
NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS
To (s) by and through
(s) by through their
their attorney(s) record: . To other
attorney(s) of record: . other party/parties
party/parties by
by and through
through their
their attorney(s)
attomey(s)
of
0f record: (Lecrone Law Firm,
record: Adam Lecrone (Lecrone Finn, P.C.)
P.C.) and
and Randall
Randall G.
G. Walters
Walters (Walters,
(Walters, Balido
Baiido & Crain,
Crain,
L.L.P.)
YOU WILL TAKE NOTICE THAT twenty (20) days
twenty (20) days after
afier service
service of a
a copy
copy hereof
hereof with
with attached
attached
questions,
questions, a
a deposition
deposition by
by written
written questions
questions will
will be
be taken
taken of Custodian
Custodian of
of Records
Records at
at the
the address
address listed
listed
below:
below:
11 -- AT&T Mobility,
Mobility, LLC (Exhibit
(Exhibit 'A')
'A')
11760
11760 U.S.
U.s. Highway 1,
1, Suite 600, North Palm Beach,
suite 600, Beach, FL 33408
Services, LLC (Exhibit
22 -- American Messaging Services, B
(Exhibit 'A')
'A')
1720
1720 Lakepointe Drive,
Drive, Suite 100, Lewisville,
Suite 100, 75057
Lewisville, TX 75057
3
3 -- Neutral Tandem (Exhibit C
(Exhibit 'A')
'A')
550 West Adams, Suite
Suite 900, Chicago, TX 60661
900, Chicago,
Before
Before a
a Notary
Notary Public for:
Public for:
U.S. Legal Support Inc.
U.S. Inc.
16825 Dr., Suite
16825 Northchase Dr., Suite 800
Houston, TX 77060
Houston,
Which deposition
deposition with
with attached questions may be
attached questions in evidence
used in
be used evidence upon thethe trial
trial of the above-styled and
the above-styled and
numbered cause
cause pending in court. Notice
the above named court.
in the is further
Notice is further given
given that request is
that request is hereby
hereby made as as
authorized under Rules
authorized Rules 176
176 and
and 200,
200, Texas Rules
Rules of Civil
Civil Procedure,
Procedure, toto the officer taking
the officer this deposition
taking this deposition
to
to issue a subpoena duces
issue a duces tecum and cause
cause it
it to
to be
be served
served on thethe witness
witness to bring and
to bring produce for
and produce for
Order
Order No : 14774
147774 (Bianca
(Bianca Beimarez)
Belmarez)
inspection and
inspection and photocopying
photocopying a a true
true and correct
correct copy
copy of records
records described in the
described in the attached
attached Written
Written
Questions
Questions and
and to
to turn
tum all
all such
such records
records over
over to the officer
to the officer authorized to take
authorized to take this
this deposition
deposition so
so that
that
photographic reproductions of
photographic reproductions of the
the same may be
be made and attached
attached to
to said
said deposition.
deposition.
Paige Eldridge
Paige Eldridge
SBA # 24096747
paige.eldridgeamitheritelaw.com
paige.eldridge@witheritelaw.com
Witherite Law Group
10440
10440 North Central Expressway,
Expressway, Suite
Suite 400
Dallas,
Dallas, TX 75231
75231
Phone: (800)
(800) 227-9732; Fax:
Attorney for
Attorney for Plaintiff(s)
Plaintiff(s)
/S/ Paige Eldridge
Paige Eldridge
Order No.1 147174
Order No, 147774 (Bianca
(Bianca Beirnarez)
Belmarez)
CERTIFICATE OF SERVICE
1I hereby
hereby certify
certify that
that a
a true
true and correct
correct copy
copy of the
the foregoing Notice of
foregoing Notice of intention to Take Deposition
Intention to upon
Deposition upon
__
Written
Written Questions
Questions was served to the
served to respective parties
the respective parties and/or
and/or attorneys
attorneys of record
record by
by certified mail
certified mail
with return
with return receipt requested; __ hand delivery;
receipt requested; __ fax;
delivery; T _
fax; X electronic serve;
electronic serve; or
or ITS.
UPS.
Dated:
Dated: 10/7/2020
By permission:
By permission: /S/ Bianca Belmarez
Paige Eldridge
Paige Eldridge
Should you
you desire
desire copies
copies of
of
the
the so
so obtained,
obtained, contact
contact our firm.
firm.
713-653-7100
Order No
No: 14- 4 (Bianca
147774 (Bianca Belmarez)
Belmaru)
Cause No. DC-19-10926
§
§
Vashone Rhodes §
§ In the District
District Court of
§§
vs.
vs. § Dallas County, Texas
§g
James Gomez § 160th Judicial District
160th Judicial District
§g
0F RECORD:
ATTORNEYS OF
Adam Lecrone
Lecrone Law Firm,
Finn, P.C.
P.C.
123
123 North Crockett
Crockett Street
Street
Suite
Suite 200
Sherman, TX 75090
Phone: 903-813-1900 Fax: Fax: 903-813-1944
Attorney for
Attorney for Defendant(s): James Gomez
Defendant(s): James
Paige Eldridge
Paige Eldridge
Witherite
Witherite Law Group
10440
10440 North Central
Central Expressway,
Expressway, Suite
Suite 400
Dallas,
Dallas, TX 75231
75231
Phone:
Phone: 214-378-6665 Fax: Fax: 214-378-6670
Attorney for
Attomey Plaintiff(s): Vashone Rhodes
for Plaintiff(s):
Randall G.
Randall G. Walters
Walters
Walters,
Walters, Balido
Balido & Crain,
Crain, L.L.P.
L.L.P.
10440 North
North Central
Central Expressway
Expressway
Suite
Suite 1550
1550
Dallas,
Dallas, TX 75231
75231
Phone: 214-749-4805
Phone: 2 14449-4805 Fax: 214-347-8381
Fax: 2 14-347-8381
Attorney for
Attorney for Defendant(s
Defendant(s):1: Exclusive Nationwide Delivery,
Exclusive Nationwide Delivery, Inc
Inc
Order No
No.
-
147774
147774 (Bianca
(Bianca Belmarez)
Belmarez)
Cause N0. DC-19-10926
Vashone Rhodes § In the District Court 0f
§
vs. § Dallas County, Texas
§
James Gomez § 160th Judicial District
SECOND AMENDED
DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS
Custodian 0f Records for: AT&T Mobility, LLC
Records Pertaining t0: James Gomez
Type 0f Records: any and all records and/or documents as described in the attached Exhibit 'A'
Please state your full name, address, telephone number, occupation and official title.
ANSWER
I am the custodian for
(Please insert facility or practitioner name.)
Have you received a subpoena duces tecum for the production 0f those documents listed above?
ANSWER
Are you among those Who have possession, custody, control 0f, 0r access t0 the documents requested
above?
ANSWER
Were the records requested above made in the regular course 0f business?
ANSWER
Was it in the regular course 0f business 0f the above listed facility 0r practitioner for a person With
knowledge 0f the act, event, condition, opinion, 0r diagnosis recorded t0 make the record 0r t0 transmit
information thereof t0 be included in such record?
ANSWER
State Whether these records were made at the time 0r shortly after the time 0f the transactions recorded?
ANSWER
Were these records kept as described in the preceding questions?
ANSWER
Does the source 0f the information, and the method and circumstance 0f its preparation, establish the
trustworthiness 0f the records?
ANSWER
Order N0.: 147774.001 (Bianca Belmarez)
10. Please release exact duplicates 0f the records as requested in the subpoena duces tecum 0r the originals
thereof for photocopying for attachment t0 this deposition. Have you done as requested? If not, Why not?
ANSWER
11. Are there any records, documents, papers, correspondence 0r tangible matters 0f any kind pertaining t0
Phone Records that you have NOT provided t0 the notary public taking your deposition?
ANSWER
12. Please describe all papers, documents, records, correspondence, 0r tangible matters 0f any kind that you
have not provided t0 the notary public taking your deposition and explain Why you have N_OT provided
them.
ANSWER
13. Are you aware that it may be necessary t0 subpoena you 0r your employer t0 court at the time 0f the trial
0f this case, if you have not provided t0 the notary public taking your deposition all papers, documents,
records, correspondence, 0r tangible matters 0f any kind pertaining t0 Phone Records?
ANSWER
WITNESS (Custodian 0f Records)
Before me, the undersigned authority, 0n this day personally appeared
,
custodian 0f records for the above listed, known t0 me t0
be the person Whose name is subscribed t0 the foregoing instrument in the capacity therein stated, Who being first
duly sworn, stated upon his/her oath that the answers t0 the foregoing questions are true and correct. I further
certify that the records attached hereto are exact duplicates 0f the original records.
SWORN TO AND SUBSCRIBED before me this day 0f ,
20
NOTARY PUBLIC
Order N0.: 147774.001 (Bianca Belmarez)
Exhibit ‘A'
Defendant Driver Name: James Gomez
DOB:1 0/06/1 966
Address: 1231 Day Miar Rd. Grand Prairie, TX 75052
FOR THE FOLLOWING PROPERTY:
All records associated with mobile number 214-755-0570 for the dates of November 27, 2018 from
6:00AM Central time to November 27, 2018 12:00pm Central Time.
*If the number is not associated with a subscriber on your network you are ordered to process this
request as a “Call and Text to Destination” search that is to include all calls, text, text message content,
voicemails, and ceII—site and sector information related to each call or text.
This request includes:
1. Specialized Location Records: A|| call, voice, text (SMS & MMS), and data connection location
information and transactions (registration of network events), related to all specialized carrier
records that may be referred to as NELOS (Network Event Location System), RTT (Round Trip
Time/Return Trip Time/Real Time Tool), PCMD (Per Call Measurement Data), TDOA (Time
Difference of Arrival) or Timing Advance Information, Mediation Records, E9—1-1, and/or Historical
GPS/Mobile Locate Information which shows GPS location (longitude and latitude) and CelI-Site and
sector of the device in relationship to the network when connected to the network for the above
referenced number.
CallIText/Data Detail Records: A|| records associated with the identified mobile number 214-755-
0570 also to include all numbers that communicate with this listed number relating to all delivered
and undelivered inbound and outbound calls, text messages, and text message content to any of the
above listed numbers, all voice mail, and all data connections from November 27, 2018 from 6:00AM
Central time to November 27, 2018 12:00pm Central Time, and to include CeII—site and sector, date,
time, direction, duration, number called or text to and/or received from, and bytes up/down,
information related to each call, text or data connection, all text message content, and voicemails, as
well as Call to Destination/Dialed Digits search for all numbers listed above. Please preserve all
cell-site and sector information related to each call, text or data connections.
Electronically Stored Records: All records associated with the identified mobile number 214-755-
0570 to include all stored communication or files, including voice mail, text messages, including
numbers text to and received from and all related content, e-mail, digital images (e.g. pictures),
contact lists, video calling, web activity (name of web site or application visited or accessed), domain
accessed, data connections (to include Internet Service Providers (ISPs), Internet protocol (IP)
addresses, (IP) Session data, (IP) Destination Data, bookmarks, data sessions, name of web sites
and/or applications accessed), date and time when all web sites, applications, and/or third party
applications were accessed and the duration of each web site, application, and/or third party
application was accessed, and any other files including all cell site and sector information associated
with each connection and/or record associated with the cell number identified as 214-755-0570
Carrier Key related to call detail, text messages, data connections, IP logs, IP Sessions, web site
and/or application connections, and cell site information.
Cloud Storage: Content stored in remote storage or ‘cloud accounts’ associated with the target
device including, but not limited to, contacts, call logs, SMS and MMS messages with associated
content including audio, video, and image files, digital images and videos, and files or documents.
Cell Site List(s): List of all ceII-sites as of December 2018 for all state(s) in which the above
records used cell locations. Cell site lists to include switch, ceII-site number, name, physical
address, longitude and latitude, all sectors associated with each cell—site, azimuth, and beam-width
of each related sector. If multiple technologies (CDMA, UMTS, GSM, LTE etc.) are referenced in
the records, all appropriate corresponding cell site lists will also be provided.
N Subscriber Records: All information for the following mobile number 214-755-0570 including:
1. All Subscriber information to include name, tax identification number (social security number
or employer identification number).
N Physical address, mailing addresses, residential addresses, business addresses, e-mail
addresses and any other address information.
Credit information obtained or used by the company to grant account status.
?@PP’
All numbers associated with account.
Billing records.
All payments to include method, date and time of payments, and location (store name,
address, and phone number of location where payment(s) were made).
." A|| Authorized users on the associated account.
8. Activation date and termination date of each device associated with the account and above
listed number(s).
9. Types of service subscriber utilized (e.g. A-Iist, AT&T Messages, friends and family).
10. Make, model, serial number, IMEI, ESN, MEID, and MAC address associated with the
above listed numbers including any and all equipment or sim card changes for the life 0f the
account.
11. All customer service and account notes.
12. Any and all number and/or account number changes prior to and after the cell number was
activated.
Any other records and other evidence relating to phone number 214-755-0570. Such records and other
evidence include correspondence and other records of contact by any person or entity about the above-
referenced account(s), the content and connection logs associated with or relating to postings,
communications and any other activities to or through the above referenced phone numbers, whether
such records or other evidence are in electronic or other form.
Cause N0. DC-19-10926
Vashone Rhodes § In the District Court 0f
§
vs. § Dallas County, Texas
§
James Gomez § 160th Judicial District
SECOND AMENDED
DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS
Custodian 0f Records for: American Messaging Services, LLC
Records Pertaining t0: James Gomez
Type 0f Records: any and all records and/or documents as described in the attached Exhibit 'B'
1. Please state your full name, address, telephone number, occupation and official title.
ANSWER
I am the custodian for
(Please insert facility or practitioner name.)
Have you received a subpoena duces tecum for the production 0f those documents listed above?
ANSWER
Are you among those Who have possession, custody, control 0f, 0r access t0 the documents requested
above?
ANSWER
Were the records requested above made in the regular course 0f business?
ANSWER
Was it in the regular course 0f business 0f the above listed facility 0r practitioner for a person With
knowledge 0f the act, event, condition, opinion, 0r diagnosis recorded t0 make the record 0r t0 transmit
information thereof t0 be included in such record?
ANSWER
State Whether these records were made at the time 0r shortly after the time 0f the transactions recorded?
ANSWER
Were these records kept as described in the preceding questions?
ANSWER
Does the source 0f the information, and the method and circumstance 0f its preparation, establish the
trustworthiness 0f the records?
ANSWER
Order N0.: 147774.002 (Bianca Belmarez)
10. Please release exact duplicates 0f the records as requested in the subpoena duces tecum 0r the originals
thereof for photocopying for attachment t0 this deposition. Have you done as requested? If not, Why not?
ANSWER
11. Are there any records, documents, papers, correspondence 0r tangible matters 0f any kind pertaining t0
Phone Records that you have NOT provided t0 the notary public taking your deposition?
ANSWER
12. Please describe all papers, documents, records, correspondence, 0r tangible matters 0f any kind that you
have not provided t0 the notary public taking your deposition and explain Why you have N_OT provided
them.
ANSWER
13. Are you aware that it may be necessary t0 subpoena you 0r your employer t0 court at the time 0f the trial
0f this case, if you have not provided t0 the notary public taking your deposition all papers, documents,
records, correspondence, 0r tangible matters 0f any kind pertaining t0 Phone Records?
ANSWER
WITNESS (Custodian 0f Records)
Before me, the undersigned authority, 0n this day personally appeared
,
custodian 0f records for the above listed, known t0 me t0
be the person Whose name is subscribed t0 the foregoing instrument in the capacity therein stated, Who being first
duly sworn, stated upon his/her oath that the answers t0 the foregoing questions are true and correct. I further
certify that the records attached hereto are exact duplicates 0f the original records.
SWORN TO AND SUBSCRIBED before me this day 0f ,
20
NOTARY PUBLIC
Order N0.: 147774.002 (Bianca Belmarez)
Exhibit ‘B‘
Defendant Driver Name: James Gomez
DOB:10/06/1966
Address: 1231 Day Miar Rd. Grand Prairie, TX 75052
FOR THE FOLLOWING PROPERTY:
All records associated with mobile number 817-452-4076 for the dates of November 27, 2018 from
6:00AM Central time to November 27, 2018 12:00pm Central Time.
*If the number is not associated with a subscriber on your network you are ordered to process this
request as a “Call and Text to Destination” search that is to include all calls, text, text message content,
voicemails, and ceII—site and sector information related to each call or text.
This request includes:
1. Specialized Location Records: A|| call, voice, text (SMS & MMS), and data connection location
information and transactions (registration of network events), related to all specialized carrier
records that may be referred to as NELOS (Network Event Location System), RTT (Round Trip
Time/Return Trip Time/Real Time Tool), PCMD (Per Call Measurement Data), TDOA (Time
Difference of Arrival) or Timing Advance Information, Mediation Records, E9—1-1, and/or Historical
GPS/Mobile Locate Information which shows GPS location (longitude and latitude) and CelI-Site and
sector of the device in relationship to the network when connected to the network for the above
referenced number.
CallIText/Data Detail Records: A|| records associated with the identified mobile number 817-452-
4076 also to include all numbers that communicate with this listed number relating to all delivered
and undelivered inbound and outbound calls, text messages, and text message content to any of the
above listed numbers, all voice mail, and all data connections from November 27, 2018 from 6:00AM
Central time to November 27, 2018 12:00pm Central Time, and to include CeII—site and sector, date,
time, direction, duration, number called or text to and/or received from, and bytes up/down,
information related to each call, text or data connection, all text message content, and voicemails, as
well as Call to Destination/Dialed Digits search for all numbers listed above. Please preserve all
cell-site and sector information related to each call, text or data connections.
Electronically Stored Records: All records associated with the identified mobile number 817-452-
4076 to include all stored communication or files, including voice mail, text messages, including
numbers text to and received from and all related content, e—mail, digital images (e.g. pictures),
contact lists, video calling, web activity (name of web site or application visited or accessed), domain
accessed, data connections (to include Internet Service Providers (ISPs), Internet protocol (IP)
addresses, (IP) Session data, (IP) Destination Data, bookmarks, data sessions, name of web sites
and/or applications accessed), date and time when all web sites, applications, and/or third party
applications were accessed and the duration of each web site, application, and/or third party
application was accessed, and any other files including all cell site and sector information associated
with each connection and/or record associated with the cell number identified as 817-452-4076.
Carrier Key related to call detail, text messages, data connections, IP logs, IP Sessions, web site
and/or application connections, and cell site information.
Cloud Storage: Content stored in remote storage or ‘cloud accounts’ associated with the target
device including, but not limited to, contacts, call logs, SMS and MMS messages with associated
content including audio, video, and image files, digital images and videos, and files or documents.
Cell Site List(s): List of all ceII-sites as of December 2018 for all state(s) in which the above
records used cell locations. Cell site lists to include switch, ceII-site number, name, physical
address, longitude and latitude, all sectors associated with each cell—site, azimuth, and beam-width
of each related sector. If multiple technologies (CDMA, UMTS, GSM, LTE etc.) are referenced in
the records, all appropriate corresponding cell site lists will also be provided.
N Subscriber Records: All information for the following mobile number 817-452-4076 including:
1. All Subscriber information to include name, tax identification number (social security number
or employer identification number).
N Physical address, mailing addresses, residential addresses, business addresses, e-mail
addresses and any other address information.
Credit information obtained or used by the company to grant account status.
?@PP’
All numbers associated with account.
Billing records.
All payments to include method, date and time of payments, and location (store name,
address, and phone number of location where payment(s) were made).
." A|| Authorized users on the associated account.
8. Activation date and termination date of each device associated with the account and above
listed number(s).
9. Types of service subscriber utilized (e.g. A-Iist, AT&T Messages, friends and family).
10. Make, model, serial number, IMEI, ESN, MEID, and MAC address associated with the
above listed numbers including any and all equipment or sim card changes for the life 0f the
account.
11. All customer service and account notes.
12. Any and all number and/or account number changes prior to and after the cell number was
activated.
Any other records and other evidence relating to phone number 817-452-4076. Such records and other
evidence include correspondence and other records of contact by any person or entity about the above-
referenced account(s), the content and connection logs associated with or relating to postings,
communications and any other activities to or through the above referenced phone numbers, whether
such records or other evidence are in electronic or other form.
Cause N0. DC-19-10926
Vashone Rhodes § In the District Court 0f
§
vs. § Dallas County, Texas
§
James Gomez § 160th Judicial District
SECOND AMENDED
DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS
Custodian 0f Records for: Neutral Tandem
Records Pertaining t0: James Gomez
Type 0f Records: any and all records and/or documents as described in the attached Exhibit 'C'
Please state your full name, address, telephone number, occupation and official title.
ANSWER
I am the custodian for
(Please insert facility or practitioner name.)
Have you received a subpoena duces tecum for the production 0f those documents listed above?
ANSWER
Are you among those Who have possession, custody, control 0f, 0r access t0 the documents requested
above?
ANSWER
Were the records requested above made in the regular course 0f business?
ANSWER
Was it in the regular course 0f business 0f the above listed facility 0r practitioner for a person With
knowledge 0f the act, event, condition, opinion, 0r diagnosis recorded t0 make the record 0r t0 transmit
information thereof t0 be included in such record?
ANSWER
State Whether these records were made at the time 0r shortly after the time 0f the transactions recorded?
ANSWER
Were these records kept as described in the preceding questions?
ANSWER
Does the source 0f the information, and the method and circumstance 0f its preparation, establish the
trustworthiness 0f the records?
ANSWER
Order No.: 147774.003 (Bianca Belmarez)
10. Please release exact duplicates 0f the records as requested in the subpoena duces tecum 0r the originals
thereof for photocopying for attachment t0 this deposition. Have you done as requested? If not, Why not?
ANSWER
11. Are there any records, documents, papers, correspondence 0r tangible matters 0f any kind pertaining t0
Phone Records that you have NOT provided t0 the notary public taking your deposition?
ANSWER
12. Please describe all papers, documents, records, correspondence, 0r tangible matters 0f any kind that you
have not provided t0 the notary public taking your deposition and explain Why you have N_OT provided
them.
ANSWER
13. Are you aware that it may be necessary t0 subpoena you 0r your employer t0 court at the time 0f the trial
0f this case, if you have not provided t0 the notary public taking your deposition all papers, documents,
records, correspondence, 0r tangible matters 0f any kind pertaining t0 Phone Records?
ANSWER
WITNESS (Custodian 0f Records)
Before me, the undersigned authority, 0n this day personally appeared
,
custodian 0f records for the above listed, known t0 me t0
be the person Whose name is subscribed t0 the foregoing instrument in the capacity therein stated, Who being first
duly sworn, stated upon his/her oath that the answers t0 the foregoing questions are true and correct. I further
certify that the records attached hereto are exact duplicates 0f the original records.
SWORN TO AND SUBSCRIBED before me this day 0f ,
20
NOTARY PUBLIC
Order No.: 147774.003 (Bianca Belmarez)
Exhibit 'C'
Defendant Driver Name: James Gomez
DOB:10/06/1966
Address: 1231 Day Miar Rd. Grand Prairie, TX 75052
FOR THE FOLLOWING PROPERTY:
AIIrecords associated with mobile number 972-264-9398 for the dates of November 27, 2018 from
6:00AM Central time to November 27, 2018 12:00pm Central Time.
*Ifthe number is not associated with a subscriber on your network you are ordered t0 process this
request as a “Call and Text to Destination” search that is to include all calls, text, text message content,
voicemails, and ceII-site and sector information related to each call or text.
This request includes:
1. Specialized Location Records: All call, voice, text (SMS & MMS), and data connection location
information and transactions (registration of network events), related to all specialized carrier
records that may be referred to as NELOS (Network Event Location System), RTT (Round Trip
Time/Return Trip Time/Real Time Tool), PCMD (Per Call Measurement Data), TDOA (Time
Difference of Arrival) or Timing Advance Information, Mediation Records, E9-1—1, and/or Historical
GPS/Mobile Locate Information which shows GPS location (longitude and latitude) and Cell—Site and
sector of the device in relationship to the network when connected to the network for the above
referenced number.
Call/TextlData Detail Records: All records associated with the identified mobile number 972-264-
9398 also to include all numbers that communicate with this listed number relating to all delivered
and undelivered inbound and outbound calls, text messages, and text message content to any of the
above listed numbers, all voice mail, and all data connections from November 27, 2018 from 6:00AM
Central time to November 27, 2018 12:00pm Central Time, and to include CeII-site and sector, date,
time, direction, duration, number called or text to and/or received from, and bytes up/down,
information related to each call, text or data connection, all text message content, and voicemails, as
well as Call to Destination/Dialed Digits search for all numbers listed above. Please preserve all
celI—site and sector information related to each call, text or data connections.
Electronically Stored Records: All records associated with the identified mobile number 972-264-
9398 to include all stored communication or files, including voice mail, text messages, including
numbers text to and received from and all related content, e—mail, digital images (e.g. pictures),
contact lists, video calling, web activity (name of web site or application visited or accessed), domain
accessed, data connections (to include Internet Service Providers (ISPs), Internet protocol (IP)
addresses, (IP) Session data, (IP) Destination Data, bookmarks, data sessions, name of web sites
and/or applications accessed), date and time when all web sites, applications, and/or third party
applications were accessed and the duration of each web site, application, and/or third party
application was accessed, and any other files including all cell site and sector information associated
with each connection and/or record associated with the cell number identified as 972—264—9398.
Carrier Key related to call detail, text messages, data connections, IP logs, IP Sessions, web site
and/or application connections, and cell site information.
Cloud Storage: Content stored in remote storage or ‘cloud accounts’ associated with the target
device including, but not limited to, contacts, call logs, SMS and MMS messages with associated
content including audio, video, and image files, d
Preview
FILED 10/7/2020 1:54 PM FELICIA PITRE DISTRICT CLERK Cause No. DC—l9—10926 DC-19-10926 DALLAS CO., TEXAS Darling Tellez DEPUTY Vashone Rhodes In the the District District Court of of vs. vs. mmmwmmww Dallas County, Dallas County, Texas James Gomez 160th 160th Judicial Judicial District District SECOND AMENDED NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS To (s) by and through (s) by through their their attorney(s) record: . To other attorney(s) of record: . other party/parties party/parties by by and through through their their attorney(s) attomey(s) of 0f record: (Lecrone Law Firm, record: Adam Lecrone (Lecrone Finn, P.C.) P.C.) and and Randall Randall G. G. Walters Walters (Walters, (Walters, Balido Baiido & Crain, Crain, L.L.P.) YOU WILL TAKE NOTICE THAT twenty (20) days twenty (20) days after afier service service of a a copy copy hereof hereof with with attached attached questions, questions, a a deposition deposition by by written written questions questions will will be be taken taken of Custodian Custodian of of Records Records at at the the address address listed listed below: below: 11 -- AT&T Mobility, Mobility, LLC (Exhibit (Exhibit 'A') 'A') 11760 11760 U.S. U.s. Highway 1, 1, Suite 600, North Palm Beach, suite 600, Beach, FL 33408 Services, LLC (Exhibit 22 -- American Messaging Services, B (Exhibit 'A') 'A') 1720 1720 Lakepointe Drive, Drive, Suite 100, Lewisville, Suite 100, 75057 Lewisville, TX 75057 3 3 -- Neutral Tandem (Exhibit C (Exhibit 'A') 'A') 550 West Adams, Suite Suite 900, Chicago, TX 60661 900, Chicago, Before Before a a Notary Notary Public for: Public for: U.S. Legal Support Inc. U.S. Inc. 16825 Dr., Suite 16825 Northchase Dr., Suite 800 Houston, TX 77060 Houston, Which deposition deposition with with attached questions may be attached questions in evidence used in be used evidence upon thethe trial trial of the above-styled and the above-styled and numbered cause cause pending in court. Notice the above named court. in the is further Notice is further given given that request is that request is hereby hereby made as as authorized under Rules authorized Rules 176 176 and and 200, 200, Texas Rules Rules of Civil Civil Procedure, Procedure, toto the officer taking the officer this deposition taking this deposition to to issue a subpoena duces issue a duces tecum and cause cause it it to to be be served served on thethe witness witness to bring and to bring produce for and produce for Order Order No : 14774 147774 (Bianca (Bianca Beimarez) Belmarez) inspection and inspection and photocopying photocopying a a true true and correct correct copy copy of records records described in the described in the attached attached Written Written Questions Questions and and to to turn tum all all such such records records over over to the officer to the officer authorized to take authorized to take this this deposition deposition so so that that photographic reproductions of photographic reproductions of the the same may be be made and attached attached to to said said deposition. deposition. Paige Eldridge Paige Eldridge SBA # 24096747 paige.eldridgeamitheritelaw.com paige.eldridge@witheritelaw.com Witherite Law Group 10440 10440 North Central Expressway, Expressway, Suite Suite 400 Dallas, Dallas, TX 75231 75231 Phone: (800) (800) 227-9732; Fax: Attorney for Attorney for Plaintiff(s) Plaintiff(s) /S/ Paige Eldridge Paige Eldridge Order No.1 147174 Order No, 147774 (Bianca (Bianca Beirnarez) Belmarez) CERTIFICATE OF SERVICE 1I hereby hereby certify certify that that a a true true and correct correct copy copy of the the foregoing Notice of foregoing Notice of intention to Take Deposition Intention to upon Deposition upon __ Written Written Questions Questions was served to the served to respective parties the respective parties and/or and/or attorneys attorneys of record record by by certified mail certified mail with return with return receipt requested; __ hand delivery; receipt requested; __ fax; delivery; T _ fax; X electronic serve; electronic serve; or or ITS. UPS. Dated: Dated: 10/7/2020 By permission: By permission: /S/ Bianca Belmarez Paige Eldridge Paige Eldridge Should you you desire desire copies copies of of the the so so obtained, obtained, contact contact our firm. firm. 713-653-7100 Order No No: 14- 4 (Bianca 147774 (Bianca Belmarez) Belmaru) Cause No. DC-19-10926 § § Vashone Rhodes § § In the District District Court of §§ vs. vs. § Dallas County, Texas §g James Gomez § 160th Judicial District 160th Judicial District §g 0F RECORD: ATTORNEYS OF Adam Lecrone Lecrone Law Firm, Finn, P.C. P.C. 123 123 North Crockett Crockett Street Street Suite Suite 200 Sherman, TX 75090 Phone: 903-813-1900 Fax: Fax: 903-813-1944 Attorney for Attorney for Defendant(s): James Gomez Defendant(s): James Paige Eldridge Paige Eldridge Witherite Witherite Law Group 10440 10440 North Central Central Expressway, Expressway, Suite Suite 400 Dallas, Dallas, TX 75231 75231 Phone: Phone: 214-378-6665 Fax: Fax: 214-378-6670 Attorney for Attomey Plaintiff(s): Vashone Rhodes for Plaintiff(s): Randall G. Randall G. Walters Walters Walters, Walters, Balido Balido & Crain, Crain, L.L.P. L.L.P. 10440 North North Central Central Expressway Expressway Suite Suite 1550 1550 Dallas, Dallas, TX 75231 75231 Phone: 214-749-4805 Phone: 2 14449-4805 Fax: 214-347-8381 Fax: 2 14-347-8381 Attorney for Attorney for Defendant(s Defendant(s):1: Exclusive Nationwide Delivery, Exclusive Nationwide Delivery, Inc Inc Order No No. - 147774 147774 (Bianca (Bianca Belmarez) Belmarez) Cause N0. DC-19-10926 Vashone Rhodes § In the District Court 0f § vs. § Dallas County, Texas § James Gomez § 160th Judicial District SECOND AMENDED DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS Custodian 0f Records for: AT&T Mobility, LLC Records Pertaining t0: James Gomez Type 0f Records: any and all records and/or documents as described in the attached Exhibit 'A' Please state your full name, address, telephone number, occupation and official title. ANSWER I am the custodian for (Please insert facility or practitioner name.) Have you received a subpoena duces tecum for the production 0f those documents listed above? ANSWER Are you among those Who have possession, custody, control 0f, 0r access t0 the documents requested above? ANSWER Were the records requested above made in the regular course 0f business? ANSWER Was it in the regular course 0f business 0f the above listed facility 0r practitioner for a person With knowledge 0f the act, event, condition, opinion, 0r diagnosis recorded t0 make the record 0r t0 transmit information thereof t0 be included in such record? ANSWER State Whether these records were made at the time 0r shortly after the time 0f the transactions recorded? ANSWER Were these records kept as described in the preceding questions? ANSWER Does the source 0f the information, and the method and circumstance 0f its preparation, establish the trustworthiness 0f the records? ANSWER Order N0.: 147774.001 (Bianca Belmarez) 10. Please release exact duplicates 0f the records as requested in the subpoena duces tecum 0r the originals thereof for photocopying for attachment t0 this deposition. Have you done as requested? If not, Why not? ANSWER 11. Are there any records, documents, papers, correspondence 0r tangible matters 0f any kind pertaining t0 Phone Records that you have NOT provided t0 the notary public taking your deposition? ANSWER 12. Please describe all papers, documents, records, correspondence, 0r tangible matters 0f any kind that you have not provided t0 the notary public taking your deposition and explain Why you have N_OT provided them. ANSWER 13. Are you aware that it may be necessary t0 subpoena you 0r your employer t0 court at the time 0f the trial 0f this case, if you have not provided t0 the notary public taking your deposition all papers, documents, records, correspondence, 0r tangible matters 0f any kind pertaining t0 Phone Records? ANSWER WITNESS (Custodian 0f Records) Before me, the undersigned authority, 0n this day personally appeared , custodian 0f records for the above listed, known t0 me t0 be the person Whose name is subscribed t0 the foregoing instrument in the capacity therein stated, Who being first duly sworn, stated upon his/her oath that the answers t0 the foregoing questions are true and correct. I further certify that the records attached hereto are exact duplicates 0f the original records. SWORN TO AND SUBSCRIBED before me this day 0f , 20 NOTARY PUBLIC Order N0.: 147774.001 (Bianca Belmarez) Exhibit ‘A' Defendant Driver Name: James Gomez DOB:1 0/06/1 966 Address: 1231 Day Miar Rd. Grand Prairie, TX 75052 FOR THE FOLLOWING PROPERTY: All records associated with mobile number 214-755-0570 for the dates of November 27, 2018 from 6:00AM Central time to November 27, 2018 12:00pm Central Time. *If the number is not associated with a subscriber on your network you are ordered to process this request as a “Call and Text to Destination” search that is to include all calls, text, text message content, voicemails, and ceII—site and sector information related to each call or text. This request includes: 1. Specialized Location Records: A|| call, voice, text (SMS & MMS), and data connection location information and transactions (registration of network events), related to all specialized carrier records that may be referred to as NELOS (Network Event Location System), RTT (Round Trip Time/Return Trip Time/Real Time Tool), PCMD (Per Call Measurement Data), TDOA (Time Difference of Arrival) or Timing Advance Information, Mediation Records, E9—1-1, and/or Historical GPS/Mobile Locate Information which shows GPS location (longitude and latitude) and CelI-Site and sector of the device in relationship to the network when connected to the network for the above referenced number. CallIText/Data Detail Records: A|| records associated with the identified mobile number 214-755- 0570 also to include all numbers that communicate with this listed number relating to all delivered and undelivered inbound and outbound calls, text messages, and text message content to any of the above listed numbers, all voice mail, and all data connections from November 27, 2018 from 6:00AM Central time to November 27, 2018 12:00pm Central Time, and to include CeII—site and sector, date, time, direction, duration, number called or text to and/or received from, and bytes up/down, information related to each call, text or data connection, all text message content, and voicemails, as well as Call to Destination/Dialed Digits search for all numbers listed above. Please preserve all cell-site and sector information related to each call, text or data connections. Electronically Stored Records: All records associated with the identified mobile number 214-755- 0570 to include all stored communication or files, including voice mail, text messages, including numbers text to and received from and all related content, e-mail, digital images (e.g. pictures), contact lists, video calling, web activity (name of web site or application visited or accessed), domain accessed, data connections (to include Internet Service Providers (ISPs), Internet protocol (IP) addresses, (IP) Session data, (IP) Destination Data, bookmarks, data sessions, name of web sites and/or applications accessed), date and time when all web sites, applications, and/or third party applications were accessed and the duration of each web site, application, and/or third party application was accessed, and any other files including all cell site and sector information associated with each connection and/or record associated with the cell number identified as 214-755-0570 Carrier Key related to call detail, text messages, data connections, IP logs, IP Sessions, web site and/or application connections, and cell site information. Cloud Storage: Content stored in remote storage or ‘cloud accounts’ associated with the target device including, but not limited to, contacts, call logs, SMS and MMS messages with associated content including audio, video, and image files, digital images and videos, and files or documents. Cell Site List(s): List of all ceII-sites as of December 2018 for all state(s) in which the above records used cell locations. Cell site lists to include switch, ceII-site number, name, physical address, longitude and latitude, all sectors associated with each cell—site, azimuth, and beam-width of each related sector. If multiple technologies (CDMA, UMTS, GSM, LTE etc.) are referenced in the records, all appropriate corresponding cell site lists will also be provided. N Subscriber Records: All information for the following mobile number 214-755-0570 including: 1. All Subscriber information to include name, tax identification number (social security number or employer identification number). N Physical address, mailing addresses, residential addresses, business addresses, e-mail addresses and any other address information. Credit information obtained or used by the company to grant account status. ?@PP’ All numbers associated with account. Billing records. All payments to include method, date and time of payments, and location (store name, address, and phone number of location where payment(s) were made). ." A|| Authorized users on the associated account. 8. Activation date and termination date of each device associated with the account and above listed number(s). 9. Types of service subscriber utilized (e.g. A-Iist, AT&T Messages, friends and family). 10. Make, model, serial number, IMEI, ESN, MEID, and MAC address associated with the above listed numbers including any and all equipment or sim card changes for the life 0f the account. 11. All customer service and account notes. 12. Any and all number and/or account number changes prior to and after the cell number was activated. Any other records and other evidence relating to phone number 214-755-0570. Such records and other evidence include correspondence and other records of contact by any person or entity about the above- referenced account(s), the content and connection logs associated with or relating to postings, communications and any other activities to or through the above referenced phone numbers, whether such records or other evidence are in electronic or other form. Cause N0. DC-19-10926 Vashone Rhodes § In the District Court 0f § vs. § Dallas County, Texas § James Gomez § 160th Judicial District SECOND AMENDED DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS Custodian 0f Records for: American Messaging Services, LLC Records Pertaining t0: James Gomez Type 0f Records: any and all records and/or documents as described in the attached Exhibit 'B' 1. Please state your full name, address, telephone number, occupation and official title. ANSWER I am the custodian for (Please insert facility or practitioner name.) Have you received a subpoena duces tecum for the production 0f those documents listed above? ANSWER Are you among those Who have possession, custody, control 0f, 0r access t0 the documents requested above? ANSWER Were the records requested above made in the regular course 0f business? ANSWER Was it in the regular course 0f business 0f the above listed facility 0r practitioner for a person With knowledge 0f the act, event, condition, opinion, 0r diagnosis recorded t0 make the record 0r t0 transmit information thereof t0 be included in such record? ANSWER State Whether these records were made at the time 0r shortly after the time 0f the transactions recorded? ANSWER Were these records kept as described in the preceding questions? ANSWER Does the source 0f the information, and the method and circumstance 0f its preparation, establish the trustworthiness 0f the records? ANSWER Order N0.: 147774.002 (Bianca Belmarez) 10. Please release exact duplicates 0f the records as requested in the subpoena duces tecum 0r the originals thereof for photocopying for attachment t0 this deposition. Have you done as requested? If not, Why not? ANSWER 11. Are there any records, documents, papers, correspondence 0r tangible matters 0f any kind pertaining t0 Phone Records that you have NOT provided t0 the notary public taking your deposition? ANSWER 12. Please describe all papers, documents, records, correspondence, 0r tangible matters 0f any kind that you have not provided t0 the notary public taking your deposition and explain Why you have N_OT provided them. ANSWER 13. Are you aware that it may be necessary t0 subpoena you 0r your employer t0 court at the time 0f the trial 0f this case, if you have not provided t0 the notary public taking your deposition all papers, documents, records, correspondence, 0r tangible matters 0f any kind pertaining t0 Phone Records? ANSWER WITNESS (Custodian 0f Records) Before me, the undersigned authority, 0n this day personally appeared , custodian 0f records for the above listed, known t0 me t0 be the person Whose name is subscribed t0 the foregoing instrument in the capacity therein stated, Who being first duly sworn, stated upon his/her oath that the answers t0 the foregoing questions are true and correct. I further certify that the records attached hereto are exact duplicates 0f the original records. SWORN TO AND SUBSCRIBED before me this day 0f , 20 NOTARY PUBLIC Order N0.: 147774.002 (Bianca Belmarez) Exhibit ‘B‘ Defendant Driver Name: James Gomez DOB:10/06/1966 Address: 1231 Day Miar Rd. Grand Prairie, TX 75052 FOR THE FOLLOWING PROPERTY: All records associated with mobile number 817-452-4076 for the dates of November 27, 2018 from 6:00AM Central time to November 27, 2018 12:00pm Central Time. *If the number is not associated with a subscriber on your network you are ordered to process this request as a “Call and Text to Destination” search that is to include all calls, text, text message content, voicemails, and ceII—site and sector information related to each call or text. This request includes: 1. Specialized Location Records: A|| call, voice, text (SMS & MMS), and data connection location information and transactions (registration of network events), related to all specialized carrier records that may be referred to as NELOS (Network Event Location System), RTT (Round Trip Time/Return Trip Time/Real Time Tool), PCMD (Per Call Measurement Data), TDOA (Time Difference of Arrival) or Timing Advance Information, Mediation Records, E9—1-1, and/or Historical GPS/Mobile Locate Information which shows GPS location (longitude and latitude) and CelI-Site and sector of the device in relationship to the network when connected to the network for the above referenced number. CallIText/Data Detail Records: A|| records associated with the identified mobile number 817-452- 4076 also to include all numbers that communicate with this listed number relating to all delivered and undelivered inbound and outbound calls, text messages, and text message content to any of the above listed numbers, all voice mail, and all data connections from November 27, 2018 from 6:00AM Central time to November 27, 2018 12:00pm Central Time, and to include CeII—site and sector, date, time, direction, duration, number called or text to and/or received from, and bytes up/down, information related to each call, text or data connection, all text message content, and voicemails, as well as Call to Destination/Dialed Digits search for all numbers listed above. Please preserve all cell-site and sector information related to each call, text or data connections. Electronically Stored Records: All records associated with the identified mobile number 817-452- 4076 to include all stored communication or files, including voice mail, text messages, including numbers text to and received from and all related content, e—mail, digital images (e.g. pictures), contact lists, video calling, web activity (name of web site or application visited or accessed), domain accessed, data connections (to include Internet Service Providers (ISPs), Internet protocol (IP) addresses, (IP) Session data, (IP) Destination Data, bookmarks, data sessions, name of web sites and/or applications accessed), date and time when all web sites, applications, and/or third party applications were accessed and the duration of each web site, application, and/or third party application was accessed, and any other files including all cell site and sector information associated with each connection and/or record associated with the cell number identified as 817-452-4076. Carrier Key related to call detail, text messages, data connections, IP logs, IP Sessions, web site and/or application connections, and cell site information. Cloud Storage: Content stored in remote storage or ‘cloud accounts’ associated with the target device including, but not limited to, contacts, call logs, SMS and MMS messages with associated content including audio, video, and image files, digital images and videos, and files or documents. Cell Site List(s): List of all ceII-sites as of December 2018 for all state(s) in which the above records used cell locations. Cell site lists to include switch, ceII-site number, name, physical address, longitude and latitude, all sectors associated with each cell—site, azimuth, and beam-width of each related sector. If multiple technologies (CDMA, UMTS, GSM, LTE etc.) are referenced in the records, all appropriate corresponding cell site lists will also be provided. N Subscriber Records: All information for the following mobile number 817-452-4076 including: 1. All Subscriber information to include name, tax identification number (social security number or employer identification number). N Physical address, mailing addresses, residential addresses, business addresses, e-mail addresses and any other address information. Credit information obtained or used by the company to grant account status. ?@PP’ All numbers associated with account. Billing records. All payments to include method, date and time of payments, and location (store name, address, and phone number of location where payment(s) were made). ." A|| Authorized users on the associated account. 8. Activation date and termination date of each device associated with the account and above listed number(s). 9. Types of service subscriber utilized (e.g. A-Iist, AT&T Messages, friends and family). 10. Make, model, serial number, IMEI, ESN, MEID, and MAC address associated with the above listed numbers including any and all equipment or sim card changes for the life 0f the account. 11. All customer service and account notes. 12. Any and all number and/or account number changes prior to and after the cell number was activated. Any other records and other evidence relating to phone number 817-452-4076. Such records and other evidence include correspondence and other records of contact by any person or entity about the above- referenced account(s), the content and connection logs associated with or relating to postings, communications and any other activities to or through the above referenced phone numbers, whether such records or other evidence are in electronic or other form. Cause N0. DC-19-10926 Vashone Rhodes § In the District Court 0f § vs. § Dallas County, Texas § James Gomez § 160th Judicial District SECOND AMENDED DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS Custodian 0f Records for: Neutral Tandem Records Pertaining t0: James Gomez Type 0f Records: any and all records and/or documents as described in the attached Exhibit 'C' Please state your full name, address, telephone number, occupation and official title. ANSWER I am the custodian for (Please insert facility or practitioner name.) Have you received a subpoena duces tecum for the production 0f those documents listed above? ANSWER Are you among those Who have possession, custody, control 0f, 0r access t0 the documents requested above? ANSWER Were the records requested above made in the regular course 0f business? ANSWER Was it in the regular course 0f business 0f the above listed facility 0r practitioner for a person With knowledge 0f the act, event, condition, opinion, 0r diagnosis recorded t0 make the record 0r t0 transmit information thereof t0 be included in such record? ANSWER State Whether these records were made at the time 0r shortly after the time 0f the transactions recorded? ANSWER Were these records kept as described in the preceding questions? ANSWER Does the source 0f the information, and the method and circumstance 0f its preparation, establish the trustworthiness 0f the records? ANSWER Order No.: 147774.003 (Bianca Belmarez) 10. Please release exact duplicates 0f the records as requested in the subpoena duces tecum 0r the originals thereof for photocopying for attachment t0 this deposition. Have you done as requested? If not, Why not? ANSWER 11. Are there any records, documents, papers, correspondence 0r tangible matters 0f any kind pertaining t0 Phone Records that you have NOT provided t0 the notary public taking your deposition? ANSWER 12. Please describe all papers, documents, records, correspondence, 0r tangible matters 0f any kind that you have not provided t0 the notary public taking your deposition and explain Why you have N_OT provided them. ANSWER 13. Are you aware that it may be necessary t0 subpoena you 0r your employer t0 court at the time 0f the trial 0f this case, if you have not provided t0 the notary public taking your deposition all papers, documents, records, correspondence, 0r tangible matters 0f any kind pertaining t0 Phone Records? ANSWER WITNESS (Custodian 0f Records) Before me, the undersigned authority, 0n this day personally appeared , custodian 0f records for the above listed, known t0 me t0 be the person Whose name is subscribed t0 the foregoing instrument in the capacity therein stated, Who being first duly sworn, stated upon his/her oath that the answers t0 the foregoing questions are true and correct. I further certify that the records attached hereto are exact duplicates 0f the original records. SWORN TO AND SUBSCRIBED before me this day 0f , 20 NOTARY PUBLIC Order No.: 147774.003 (Bianca Belmarez) Exhibit 'C' Defendant Driver Name: James Gomez DOB:10/06/1966 Address: 1231 Day Miar Rd. Grand Prairie, TX 75052 FOR THE FOLLOWING PROPERTY: AIIrecords associated with mobile number 972-264-9398 for the dates of November 27, 2018 from 6:00AM Central time to November 27, 2018 12:00pm Central Time. *Ifthe number is not associated with a subscriber on your network you are ordered t0 process this request as a “Call and Text to Destination” search that is to include all calls, text, text message content, voicemails, and ceII-site and sector information related to each call or text. This request includes: 1. Specialized Location Records: All call, voice, text (SMS & MMS), and data connection location information and transactions (registration of network events), related to all specialized carrier records that may be referred to as NELOS (Network Event Location System), RTT (Round Trip Time/Return Trip Time/Real Time Tool), PCMD (Per Call Measurement Data), TDOA (Time Difference of Arrival) or Timing Advance Information, Mediation Records, E9-1—1, and/or Historical GPS/Mobile Locate Information which shows GPS location (longitude and latitude) and Cell—Site and sector of the device in relationship to the network when connected to the network for the above referenced number. Call/TextlData Detail Records: All records associated with the identified mobile number 972-264- 9398 also to include all numbers that communicate with this listed number relating to all delivered and undelivered inbound and outbound calls, text messages, and text message content to any of the above listed numbers, all voice mail, and all data connections from November 27, 2018 from 6:00AM Central time to November 27, 2018 12:00pm Central Time, and to include CeII-site and sector, date, time, direction, duration, number called or text to and/or received from, and bytes up/down, information related to each call, text or data connection, all text message content, and voicemails, as well as Call to Destination/Dialed Digits search for all numbers listed above. Please preserve all celI—site and sector information related to each call, text or data connections. Electronically Stored Records: All records associated with the identified mobile number 972-264- 9398 to include all stored communication or files, including voice mail, text messages, including numbers text to and received from and all related content, e—mail, digital images (e.g. pictures), contact lists, video calling, web activity (name of web site or application visited or accessed), domain accessed, data connections (to include Internet Service Providers (ISPs), Internet protocol (IP) addresses, (IP) Session data, (IP) Destination Data, bookmarks, data sessions, name of web sites and/or applications accessed), date and time when all web sites, applications, and/or third party applications were accessed and the duration of each web site, application, and/or third party application was accessed, and any other files including all cell site and sector information associated with each connection and/or record associated with the cell number identified as 972—264—9398. Carrier Key related to call detail, text messages, data connections, IP logs, IP Sessions, web site and/or application connections, and cell site information. Cloud Storage: Content stored in remote storage or ‘cloud accounts’ associated with the target device including, but not limited to, contacts, call logs, SMS and MMS messages with associated content including audio, video, and image files, d