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FILED
10/16/2023 3:19 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Marissa Gomez DEPUTY
CAUSE NO. DC-22-07776
JESUS HERNANDEZ, § IN THE DISTRICT COURT
§
§
§
Plaintiff, §
§
v. § DALLAS COUNTY, TEXAS
§
SOUTHERN SOLAR, LLC, AND §
GOODLEAP, LLC F/KA/ PARAMOUNT §
EQUITY MORTGAGE D/B/A LOANPAL §
§
§
Defendants. § 95th JUDICIAL DISTRICT
PLAINTIFF’S PRETRIAL DISCLOSURES
TO: Defendant, Southern Solar, LLC, by and through its attorneys of record, Martin P. Averill,
The Averill Firm, 12610 Jupiter Road, Suite 1410, Dallas, Texas 75238.
Plaintiff, Jesus Hernandez, serves these Pretrial Disclosures, as required by Texas Rule of
Civil Procedure 194.4:
(l) the name and, if not previously provided, the address, and telephone number of each
witness--separate1y identifying those the party expects to present and those it may call if
the need arises;
Response:
Plaintiff intends to call the following witnesses at trial:
Jesus Hernandez
c/o Chris Amell
Amell Law, PLLC
450 Century Pkwy, Suite 250
Allen, TX 75013
Tel: (972)-516-43 85
Plaintiff
PLADJTIFF’S PRETRIAL DISCLOSURES Page 1
Juana Hernandez
c/o Chris Amell
Amell Law, PLLC
450 Century Pkwy, Suite 250
Allen, TX 75013
Tel: (972)-516-43 85
Plaintiff’s wife who was present during Defendant’s negotiations and misrepresentations
concerning the benefits of the solar panel system
Roberto Navarro
2550 Shupe Ct.
Irving, TX 75060
Tel: 469-279-9510
Witness who was present during Defendant’s negotiations and misrepresentations concerning the
benefits of the solar panel system
Bertha Navarro
2550 Shupe Ct.
Irving, TX 75060
Tel: 214-760-6321
Witness who was present during Defendant’s negotiations and misrepresentations concerning the
benefits of the solar panel system
John Guajardo
c/o Martin P. Averill
The Averill Firm
12610 Jupiter Road, Suite 1410
Dallas, Texas 75238
Defendant Southern Solar, LLC representative
Joshua Moore
c/o Martin P. Averill
The Averill Firm
12610 Jupiter Road, Suite 1410
Dallas, Texas 75238
Defendant Southern Solar, LLC representative
Josue Hernandez
c/o Chris Arnell
Arnell Law, PLLC
450 Century Pkwy, Suite 250
Allen, TX 75013
Tel: (903)-900-3238
Plaintiff’s son who was present during Defendant’s negotiations and misrepresentations
concerning the benefits of the solar panel system
PLADJTIFF’S PRETRIAL DISCLOSURES Page 2
(2) an identification of each document or other exhibits, including summaries of other
evidence--separately identifying those items the party expects to offer and those it may
offer if the need arises;
Response:
Plaintiff intends to offer the following exhibits at trial:
1. Photovoltaic (Solar) Installation Agreement between Plaintiff and Southern Solar, LLC.
2. Loanpal Agreement for solar panel installation.
3. Receipts depicting amounts Plaintiff has paid under the Loanpal Agreement.
4. Text messages between Plaintiff and Southern Solar employees.
5. Invoices depicting amounts Plaintiff has paid for electric bills since the installation of the
solar panels in question.
6. Annual and monthly summaries of electrical consumption for Plaintiff’s property.
7. Welcome Letter from Southern Solar to Plaintiff.
Respectfully submitted,
By: /s/ Chris Arnell
Chris Arnell
State Bar No. 24104322
Chris@arnelllaw.com
ARNELL LAW, PLLC
450 Century Parkway
Suite 250
Allen, Texas 75013
Telephone: (972) 516-43 85
ATTORNEY FOR PLAINTIFF
PLAINTIFF’S PRETRIAL DISCLOSURES Page 3
CERTIFICATE OF SERVICE
I hereby cettify that on the 16th day of October 2023, a true and correct copy of the
foregoing document was served on all known counsel of record, pursuant to the Texas Rules of
Civil Procedure utilizing the Court’s electronic filing system.
/s/ Chris Arnell
Chris Arnell
PLAINTIFF’S PRETRIAL DISCLOSURES Page 4
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.
Giao Arnell on behalf of Christopher Arnell
Bar No. 24104322
giao@arnelllaw.com
Envelope ID: 80637731
Filing Code Description: Miscellanous Event
Filing Description: PRE-TRIAL DISCLOSURES
Status as of 10/16/2023 3:24 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Philip DRacusin eservicehou@cwlaw.com 10/16/2023 3:19:14 PM SENT
Giao Arnell giao@arnelllaw.com 10/16/2023 3:19:14 PM SENT
Ashley Burch averillfirm.asmith@gmail.com 10/16/2023 3:19:14 PM SENT
Associated Case Party: SOUTHERN SOLAR, LLC
Name BarNumber Email TimestampSubmitted Status
Martin PAverill averillfirm@gmail.com 10/16/2023 3:19:14 PM SENT
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FILED 10/16/2023 3:19 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Marissa Gomez DEPUTY CAUSE NO. DC-22-07776 JESUS HERNANDEZ, § IN THE DISTRICT COURT § § § Plaintiff, § § v. § DALLAS COUNTY, TEXAS § SOUTHERN SOLAR, LLC, AND § GOODLEAP, LLC F/KA/ PARAMOUNT § EQUITY MORTGAGE D/B/A LOANPAL § § § Defendants. § 95th JUDICIAL DISTRICT PLAINTIFF’S PRETRIAL DISCLOSURES TO: Defendant, Southern Solar, LLC, by and through its attorneys of record, Martin P. Averill, The Averill Firm, 12610 Jupiter Road, Suite 1410, Dallas, Texas 75238. Plaintiff, Jesus Hernandez, serves these Pretrial Disclosures, as required by Texas Rule of Civil Procedure 194.4: (l) the name and, if not previously provided, the address, and telephone number of each witness--separate1y identifying those the party expects to present and those it may call if the need arises; Response: Plaintiff intends to call the following witnesses at trial: Jesus Hernandez c/o Chris Amell Amell Law, PLLC 450 Century Pkwy, Suite 250 Allen, TX 75013 Tel: (972)-516-43 85 Plaintiff PLADJTIFF’S PRETRIAL DISCLOSURES Page 1 Juana Hernandez c/o Chris Amell Amell Law, PLLC 450 Century Pkwy, Suite 250 Allen, TX 75013 Tel: (972)-516-43 85 Plaintiff’s wife who was present during Defendant’s negotiations and misrepresentations concerning the benefits of the solar panel system Roberto Navarro 2550 Shupe Ct. Irving, TX 75060 Tel: 469-279-9510 Witness who was present during Defendant’s negotiations and misrepresentations concerning the benefits of the solar panel system Bertha Navarro 2550 Shupe Ct. Irving, TX 75060 Tel: 214-760-6321 Witness who was present during Defendant’s negotiations and misrepresentations concerning the benefits of the solar panel system John Guajardo c/o Martin P. Averill The Averill Firm 12610 Jupiter Road, Suite 1410 Dallas, Texas 75238 Defendant Southern Solar, LLC representative Joshua Moore c/o Martin P. Averill The Averill Firm 12610 Jupiter Road, Suite 1410 Dallas, Texas 75238 Defendant Southern Solar, LLC representative Josue Hernandez c/o Chris Arnell Arnell Law, PLLC 450 Century Pkwy, Suite 250 Allen, TX 75013 Tel: (903)-900-3238 Plaintiff’s son who was present during Defendant’s negotiations and misrepresentations concerning the benefits of the solar panel system PLADJTIFF’S PRETRIAL DISCLOSURES Page 2 (2) an identification of each document or other exhibits, including summaries of other evidence--separately identifying those items the party expects to offer and those it may offer if the need arises; Response: Plaintiff intends to offer the following exhibits at trial: 1. Photovoltaic (Solar) Installation Agreement between Plaintiff and Southern Solar, LLC. 2. Loanpal Agreement for solar panel installation. 3. Receipts depicting amounts Plaintiff has paid under the Loanpal Agreement. 4. Text messages between Plaintiff and Southern Solar employees. 5. Invoices depicting amounts Plaintiff has paid for electric bills since the installation of the solar panels in question. 6. Annual and monthly summaries of electrical consumption for Plaintiff’s property. 7. Welcome Letter from Southern Solar to Plaintiff. Respectfully submitted, By: /s/ Chris Arnell Chris Arnell State Bar No. 24104322 Chris@arnelllaw.com ARNELL LAW, PLLC 450 Century Parkway Suite 250 Allen, Texas 75013 Telephone: (972) 516-43 85 ATTORNEY FOR PLAINTIFF PLAINTIFF’S PRETRIAL DISCLOSURES Page 3 CERTIFICATE OF SERVICE I hereby cettify that on the 16th day of October 2023, a true and correct copy of the foregoing document was served on all known counsel of record, pursuant to the Texas Rules of Civil Procedure utilizing the Court’s electronic filing system. /s/ Chris Arnell Chris Arnell PLAINTIFF’S PRETRIAL DISCLOSURES Page 4 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. Giao Arnell on behalf of Christopher Arnell Bar No. 24104322 giao@arnelllaw.com Envelope ID: 80637731 Filing Code Description: Miscellanous Event Filing Description: PRE-TRIAL DISCLOSURES Status as of 10/16/2023 3:24 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Philip DRacusin eservicehou@cwlaw.com 10/16/2023 3:19:14 PM SENT Giao Arnell giao@arnelllaw.com 10/16/2023 3:19:14 PM SENT Ashley Burch averillfirm.asmith@gmail.com 10/16/2023 3:19:14 PM SENT Associated Case Party: SOUTHERN SOLAR, LLC Name BarNumber Email TimestampSubmitted Status Martin PAverill averillfirm@gmail.com 10/16/2023 3:19:14 PM SENT