Preview
FILED
10/6/2022 3:54 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Jenifer Trujillo DEPUTY
CAUSE NO. DC-19-18649
LI HUANG, (1) Individually; (2) on Behalf of IN THE DISTRICT COURT
Her Wrongfully Deceased Husband,
YU LUO; and as Next Friend of Their
Surviving Child, Minor Xxxxxx Xxx;
ZHIMING LUO, Individually;
SHIGUO WANG, (1) Individually; and as
(2) Next Friend of Minor, Xxxxx Xxxx;
and XIAOLI WEL, Individually,
Plaintiffs,
vs. DALLAS COUNTY, TEXAS
NORTHPARK PARTNERS, L.P.,
NORTHPARK MANAGEMENT COMPANY,
NORTHPARK LAND PARTNERS, L.P.,
NORTHPARK SECURITY, INC.,
and
CHRISTOPHER RYAN SHAW,
Defendants. 134th JUDICIAL DISTRICT
DEFENDANTS NORTHPARK LAND PARTNERS, LP, NORTHPARK PARTNERS, LP,
NORTHPARK MANAGEMENT COMPANY, AND NORTHPARK SECURITY, INC.’S
OBJECTIONS TO PLAINTIFFS' SEPTEMBER OF 2022 NOTICE OF INTENTION TO
TAKE DEPOSITION BY WRITTEN QUESTIONS OF THE DALLAS POLICE
DEPARTMENT AND MOTION FOR PROTECTION
L INTRODUCTION
On September 28, 2022, Defendants' counsel was served with Plaintiffs' September of 2022
Notice of Intention to Take Depositions on Written Questions of the Dallas Police Department (the
"Notice"), a true and correct copy of which is attached hereto as Exhibit "A," and incorporated
herein as if set forth verbatim. In the Notice, Plaintiffs seek, among other things, the "instances of
NORTHPARK DEFENDANTS' OBJECTIONS TO PLAINTIFFS' SEPTEMBER OF 2022 NOTICE OF INTENTION
TO TAKE DEPOSITION BY WRITTEN QUESTIONS OF THE DALLAS POLICE DEPARTMENT AND MOTION
FOR PROTECTION P.1
alleged criminal conduct reported to it" at NorthPark Center for the time periods of 2008, 2009,
2010, 2011, 2012, 2013, 2014, 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022. By way of
example, Plaintiffs seek the following information for each of the aforementioned years:
|
10. For each of the following years, please state the total number of reported instandes of
aggravated assault (or Texas Penal Code 22.02) at NorthPark Mall (8687 N. Central Expy.,
Dallas, Texas 75225):
|
ll. For cach of the following years, please state the total number of reported instances of
robbery (or ‘Texas Penal Code 29.02) at NorthPark Mall (8687 N. Central Expy., Dallas, ‘Texas
5295)
$225
12; Yor each of the following years, please state the total number of reported instances of
aggravated obbery (or Texas Penal Code 29.03) at NorthPark Mall (8687 N. Central Expy.
Dallas, Texas 75225):
|
The Notice seeks the same information for (13) unlawful carrying ofa weapon, (14)
murder, (15) capital murder, (16) criminal trespass, (17) disorderly conduct, (18) criminal
mischief, (19) manslaughter, (20) burglary of vehicles, (21) injury to a child, elderly individual, or
disabled individual, (22) deadly conduct, (23) unauthorized use of a vehicle, and (24) theft.
Plaintiffs seek to obtain records from the DPD between the years 2008 and 2022; seeking the DPD
to calculate the "number of instances" for each separate crime.
IL. TIMELINESS
Pursuant to Rule 200.3 of the Texas Rules of Civil Procedure, objections to a party’s
Deposition on Written Questions must be served on all parties within ten days after the notice is
served. Defendant’s objections to Plaintiffs Deposition on Written Questions are thus timely filed.
NORTHPARK DEFENDANTS' OBJECTIONS TO PLAINTIFFS' SEPTEMBER OF 2022 NOTICE OF INTENTION
TO TAKE DEPOSITION BY WRITTEN QUESTIONS OF THE DALLAS POLICE DEPARTMENT AND MOTION
FOR PROTECTION P.2
Ti. ARGUMENT AND AUTHORITIES
A discovery request is outside the scope of discovery when (1) it asks for information that
is not relevant, or (2) the information requested will not lead to admissible evidence.' Furthermore,
a request for all documents without limitation on subject matter is overbroad.” Plaintiff's requests
seek documents that are entirely irrelevant to this litigation and not likely to lead to the discovery
of admissible evidence. Additionally, the discovery sought is unreasonably cumulative or
duplicative. Tex. R. Civ. P. 192,4(a). Further, the burden and expense of the proposed discovery
outweighs its likely benefit. Tex. R. Civ. P. 192.4(b).
Defendants further object to these requests as overly broad and not limited as to scope, as
Plaintiffs seek the totality of North Park Center, of which the Court previously limited the scope
of Plaintiffs' requests to the non-HVAC areas of NorthPark. Plaintiff's requests are not sufficiently
limited to the area in which the incident occurred on March 11, 2019. Defendant further objects to
these requests as not limited in time as the requests seek "number of instances" dating back to 2008
through the present time, despite the incident occurring on March 11, 2019. Plaintiffs’ requests
seek discovery covering an unreasonably long time period that is impermissibly overbroad.*
Plaintiffs' Notice seeks documents that are entirely irrelevant to this litigation and not likely to lead
to the discovery of admissible evidence. Accordingly, Plaintiff's requests “[are] not merely an
impermissible fishing expedition; [they are] an effort to dredge the lake in hopes of finding fish.”*
Defendants further object to Plaintiffs' Notice as violative of this Court’s prior discovery
order of August 14, 2020, whereas this Court limited the timeframe for which information relating
' TRCP 192.3(a); see In re CSX Corp., 124 S.W.3d 149, 152 (Tex. 2003); Axelson, Inc. v. McIthany, 798 S.W.2d
550, 553 (Tex. 1990).
? Texaco, Inc. v Sanderson, 898 S.W.2d 813, 815 (Tex. 1995).
3 In re Am. Optical, 988 $.W.2d 711, 713 (Tex. 1998); see also Dillard Dep't Stores, Inc. v. Hall, 909 S.W.2d 491,
492 (Tex. 1995); K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1996).
* Texaco, Inc. v. Sanderson, 898 S.W.2d 813, 815 (Tex. 1995)(citing Loftin v. Martin, 776 S.W.2d 145, 148 (Tex.
1989))
NORTHPARK DEFENDANTS' OBJECTIONS TO PLAINTIFFS' SEPTEMBER OF 2022 NOTICE OF INTENTION
TO TAKE DEPOSITION BY WRITTEN QUESTIONS OF THE DALLAS POLICE DEPARTMENT AND MOTION
FOR PROTECTION P.3
to the reporting of incidents at NorthPark was ordered to be produced for a ten-year period between
3-11-2009 and 3-11-2019. (Attached hereto as “Exhibit B”). Plaintiffs most recent requests in the
Notice go far beyond the ten-year timeframe previously ordered. None of these crimes, except
aggravated assault, have anything to do with the incident made the subject of this litigation.*
Plaintiffs' Notice further expand the types and locations of incidents that were previously
limited by this Court in the attached Order. By way of example, Plaintiffs seek the DPD to review
its files for a fourteen-year period of time, and calculate the number of "reported instances" for
each of the crimes mentioned herein including aggravated assault, robbery, aggravated robbery,
unlawful carrying of a weapon, murder, capital murder, criminal trespass, disorderly conduct,
criminal mischief, manslaughter, burglary of vehicles, injury to a child, elderly individual, or
disabled individual, deadly conduct, unauthorized use of a vehicle, and theft.
Lastly, Defendants object to these requests as duplicative, in part, of Plaintiffs' prior
Deposition Upon Written Questions served to the Dallas Police Department on or about March 16,
2020, seeking similar, if not almost identical information, for the time period of March 11, 2009
through March 10, 2019, and requesting (a) arrest warrants, (b) incident reports, (c) arrest logs, (d)
incident logs, (e) incident responses, (f) crime reports, (g) police reports, (h) search warrants, (i)
arrest warrants, (j) citations, (k) warnings, (1) complaints, (m) notices, (n) affidavits; and (0)
statements (the "March Notice"). The records the March Notice sought the above records for the
following crimes: (1) Criminal Trespass, (2) Criminal Trespass Warning, (3) Poss Cont Sub, (4)
Crim Mischief, (5) Man Del Cont Sub, (6)Public Intoxication, (7) Assault, (8) Disorderly Conduct,
(9) Robbery, (10) BMV, (11) Warrant Hold, (12) Warrant-Dallas PD, (13) Resist Arrest Search or
5 Even with aggravated assault (which involves serious bodily injury, use of a deadly weapon, or both), the only
known reported instance of aggravated assault where a vehicle was used as a deadly weapon, is the incident that
forms the basis of this litigation.
NORTHPARK DEFENDANTS' OBJECTIONS TO PLAINTIFFS' SEPTEMBER OF 2022 NOTICE OF INTENTION
TO TAKE DEPOSITION BY WRITTEN QUESTIONS OF THE DALLAS POLICE DEPARTMENT AND MOTION
FOR PROTECTION P.4
Transport, (14) Unauthorized Use of Motor Veh, (15) Theft of Prop (Auto Acc), (16) Traf Vio-
Duty on Strike Unattended Veh, (16) Fail to ID, (17) DWI, (18) Reckless Damage, (19) Evading
Arrest Detention, (20) Manslaughter, and (21) Homicide. Plaintiffs March Notice to the DPD
produced fourteen volumes with over 13,000 pages of incident reports for the subject time period.
Essentially, in Plaintiffs’ most recent Notice to the DPD, Plaintiffs seek "generally
accurate" data on reports of crime for a fourteen-year span, that may not have been the reported
crime in reality or even a crime to begin with. Obtaining this information does nothing to advance
this case in any appreciable manner. Therefore, pursuant to Rule 192. (a) of the Texas Rules of
Civil Procedure, the NorthPark Defendants seek a Protective Order precluding Plaintiffs from
engaging in this form of a discovery request.
Respectfully Submitted,
/s/ Michael A. Miller
MICHAEL A. MILLER
State Bar No. 14100650
mmiller@mklawpe.com
MILLER KNAUFF LAW FIRM
Three Forest Plaza
12221 Merit Drive, Suite 1210
Dallas, Texas 75251
(469) 916-2552
(469) 916-2555 fax
ATTORNEYS FOR DEFENDANT
NORTHPARK PARTNERS, LP,
NORTHPARK LAND PARTNERS, LP
NORTHPARK MANAGEMENT COMPANY
NORTHPARK SECURITY, INC.
NORTHPARK DEFENDANTS' OBJECTIONS TO PLAINTIFFS' SEPTEMBER OF 2022 NOTICE OF INTENTION
TO TAKE DEPOSITION BY WRITTEN QUESTIONS OF THE DALLAS POLICE DEPARTMENT AND MOTION
FOR PROTECTION P.5
CERTIFICATE OF SERVICE
Thereby certify that a true and correct copy of the foregoing instrument has been forwarded
to all counsel of record in accordance with the Texas Rules of Civil Procedure this 6th day of
October 2022.
Via E-Service
Mare C. Lenahan
P. Wes Black
Lenahan Law, P.L.L.C.
2655 Villa Creek, Suite 204
Dallas, Texas 75234
wes@|lenahanlaw.com
Law@LenahanLaw.com
Counsel for Plaintiffs
Via First Class Mail
Christopher Ryan Shaw
(TDCI Inmate #0234485 1)
c/o Texas Department of Criminal Justice
Louis C. Powledge Unit
1400 FM 3452
Palestine, Texas 75803
DOB: 07-14-1990
/s/ Michael A. Miller
MICHAEL A. MILLER
NORTHPARK DEFENDANTS' OBJECTIONS TO PLAINTIFFS' SEPTEMBER OF 2022 NOTICE OF INTENTION
TO TAKE DEPOSITION BY WRITTEN QUESTIONS OF THE DALLAS POLICE DEPARTMENT AND MOTION
FOR PROTECTION P.6
Date: 9/28/2022
Cause No. DC-19-18649
DALLAS COUNT’
134TH JUDICIAL DISTRICT
Style: LI HUANG, INDIVIDUALLY AND ON BEHALF OF YU LUO AND
AS NEXT FRIEND OF Y.L., ZHIMING LUO, SHIGUO WANG, ET AL
vs
NORTHPARK PARTNERS, L.P., NORTHPARK MANAGEMENT COMPANY,
NORTHPARK LAND PARTNERS, L.P., ET AL
REE: NorthPark Mall (8687 N. Central ixpwy, Dallas, ‘1X 75225)
Attorney: Mare C. Lenahan
Law@Lenahan.com
Firm: Lenahan Law, P.L.L.C.
For: Plaintiff
NOTICE OF DEPOSITION ON WRITTEN QUESTIONS
Record Depositions: Type/Scope:
City of Dallas WRIT EN QUESTIONS
c/o Custodian of Records for Dallas Police Department
1500 Marilla Street, Room 5D South
Dallas, TX 75201
214-671-3345
DEFENDANT'S
EXHIBIT
A
Discovery Records, Inc.
woww.discoveryrecordsine.com
1290 S. Main Street, Suite 108
Grapevine, TX 76051
Ph. (817) 424-3672 Fax (817) 424-3692,
Digital Fax Line (817) 200-7478
PLEASE RETURN
THIS COVER SHEET
September 28, 2022
Michacl A. Miller
Miller Knauff Law Firm
Three Forest Plaza
12221 Merit Drive, Suite 1210 469-916-2552
Dallas, TX 75251 Vax 469-916-2555
WAIVER & NOTICE OF WRITTEN QUESTIONS
Re: Cause No. DC-19-18649
In the 134TH JUDICIAL DISTRICT, DALLAS County
LI HUANG, INDIVIDUALLY AND ON BEHALF OF YU LUO AND
AS NEXT FRIEND OF Y.L., ZHIMING LUO, SHIGUO WANG, ET AL
VS.
NORTHPARK PARTNERS, L.P., NORTHPARK MANAGEMENT COMPANY,
NORTHPARK LAND PARTNERS, L.P., BT AL
Re: NorthPark Mall (8687 N. Central Expwy, Dallas, TX 75225)
Discovery Records, Inc. will be obtaining records from the location(s) attached. ‘The cost for cach
record will be $70.00 plus .50 cents per page. You can choose to purchase all, or a selected portion.
Please check the appropriate boxes and return.
Yes No
Will you WAIVE the notice period? Q Q
Do you want copies of ALL records? Q Q
Authorized Signature
Delivered 9/28/2022
Date CMRR __
Ete 23 pgs
RECORD LOCATIONS: eves
Q 237184 City of Dallas WRI JN QUESTIONS
c/o Custodian of Records for Dallas Police Department
1500 Marilla Street, Room SD South
Dallas, TX 75201
214-671-3345 214-671-4635
CAUSE No. DC-19-18649
Lr HUANG, IN THE 134TH JUDICIAL
Yu Luo;
MINOR XXXXXXK XXX;
ZHIMING LUO,
SHIGUO WANG,
MINOR XXXXX XXXX;
AND
XIAOLI WEI;
PLAINTIFFS,
Vv. DisTRICT COURT OF
NORTHPARK PARTNERS, L.P.;
NORTHPARK MANAGEMENT COMPANY;
NORTHPARK LAND PARTNERS, L.P.
(INDIVIDUALLY AND IN REM);
NORTHPARK SECURITY, INC.;
AND;
CHRISTOPHER RYAN SHAW,
DEFENDANTS. DALLAS COUNTY, TEXAS
PLAINTIFFS’ SEPTEMBER OF 2022 NOTICE OF INTENTION TO TAKE
DEPOSITIONS ON WRITTEN QUESTIONS OF THE DALLAS POLICE DEPARTMENT
To: Michael A. Miller and Clark S. Butler, MILLER KNAUFF LAW FirM, Three Forest Plaza,
12221 Merit Drive, Suite 1210, Dallas, Texas 75251.
You will please take notice that 20 days after service hereof, Plaintiffs will seek third-party
discovery of:
Dallas Police Department
1400 South Botham Jean Boulevard
Dallas, Texas 75215;
as authorized under Rule 200 of the TEXAS RULES OF CIVIL PROCEDURE, and before a
representative of (or any Notary Public designated by):
Li Huang, et al. v. NorthPark Partners, L.P et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 1 of 21
Discovery Records, Inc.
1290 South Main Street, Suite 108
Grapevine, ‘Texas 76051
817.424.3672
817.424.3692 fax
The Depositions will be on the written questions attached to this notice as Exhibit A. It is to
be used in the above-styled cause.
DATED: September23, 2022.
Respectfully submitted,
47 LE
Marc C. Lenahan
State Bar No. 24007546
Law@LenahanLaw.com
P. Wes Black
State Bar No. 24009904
Wes@LenahanLaw.com
LENAHAN Law, P.L.L.C.
2655 Villa Creek, Suite 204
Dallas, Texas 75234
214.295.1008
888.473.2820 toll-free
214.295.2664 fax
ATTORNEYS FOR PLAINTIFFS
Li Huang, et al. v. NorthPark Partners, LP et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 2 of 21
CERTIFICATE OF SERVICE
I certify that a true copy of the foregoing document was served on counsel of record, as
well as interested counsel, per the TRCP on this as day of agt 52022.
Michael A. Miller
Clark S. Butler
MILLER KNAUFF LAW FIRM
Three Forest Plaza
12221 Menit Drive
Suite 1210
Dallas, Texas 75251
fF LW
Marc C. Lenahan
Li Huang, et al. v. NorthPark Partners, L.P et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 3 of 21
EXHIBIT A
Direct Questions Propounded to the Witness:
Please state your name, work address, and work phone.
Answer:
Name:
Address:
Cell:
email:
2 Does the Dallas Police Department maintain records of reported criminal conduct
occurring at physical addresses within the City of Dallas?
Answer:
3 Are you familiar with the manner in which the Dallas Police Department documents
instances of alleged criminal conduct reported to it?
Answer:
4. Are you familiar with the database(s) used by the Dallas Police Department to catalog and
access reported incidents of criminal conduct?
Answer:
2 Are you familiar with the use of the database(s) to retrieve information regarding the
number of reported instances of criminal conduct at a given address?
Answer:
Li Huang, et al. v. NorthPark Partners, L.P et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 4 of 21
6 I am qualified to answer questions with the regard to the number of reported instances of
criminal conduct at a given address based upon the following:
Answer:
My position with regard to the Dallas Police Department is:
My familiarity, training, and/or experience with the resources necessary to answer questions with
regard to the number of reported instances at a given address includes:
7 Does the Dallas Police Department use databases of reported criminal conduct to make
reports to Federal or State agencies regarding crime statistics?
Answer:
8 Do Federal or State agencies rely on the statistical data provided by the Dallas Police
Department maintained in its databases of reported criminal conduct?
Answer:
9 Based on your understanding of the manner in which the Dallas Police Department
documents and catalogs instances of reported criminal conduct, do you believe that the
information you provide herein regarding the number of reports of criminal conduct at a given
address is generally accurate?
Answer:
Li Huang, et al. v. NorthPark Partners, LP. et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 5 of 21
10. For each of the following years, please state the total number of reported instances of
aggravated assault (or Texas Penal Code 22.02) at NorthPark Mall (8687 N. Central Expy.,
Dallas, Texas 75225):
Answer:
. 2008:
2009:
2010
2011
2012
2013
2014:
2015
2016:
2017
2018
2019
2020:
2021
2022
Li Huang, et al. v. NorthPark Partners, LP et al.:
Plaintiffs’ DW/Qs to Dallas Police Department Page 6 of 21
ll. For each of the following years, please state the total number of reported instances of
robbery (or Texas Penal Code 29.02) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas
75225):
Answer:
2008
2009:
2010:
2011
2012
2013:
2014:
2015:
2016:
2017
2018:
2019:
2020:
2021
2022
Li Huang, et al. v. NorthPark Partners, L.P et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 7 of 21
1 For each of the following years, please state the total number of reported instances of
aggravated robbery (or Texas Penal Code 29.03) at NorthPark Mall (8687 N. Central Expy.,
Dallas, Texas 75225):
Answer:
. 2008
2009:
2010:
2011
2012
2013
2014:
2015
2016:
2017
2018:
2019:
2020:
2021
2022
Li Huang, et al. v. NorthPark Partners, LP et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 8 of 21
13. For each of the following years, please state the total number of reported instances of
unlawful carrying of a weapon (or Texas Penal Code 46.02) at NorthPark Mall (8687 N.
Central Expy., Dallas, Texas 75225):
Answer:
2008:
2009:
2010:
2011
2012
2013
2014:
2015:
2016
2017
2018:
2019:
2020:
2021
2022.
Li Huang, et al.'v. North Park Partners, L.P et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 9 of 21
14. For each of the following years, please state the total number of reported instances of
murder (or Texas Penal Code 19.02) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas
75225):
Answer:
. 2008
2009
2010
2011
2012
2013
2014:
2015
2016
2017
2018
2019
2020:
2021
2022
Li Huang, et al. v. NorthPark Partners, L.P et al.:
Plaintiffs’ DW/Qs to Dallas Police Department Page 10 of 21
15. For each of the following years, please state the total number of reported instances of
capital murder (or Texas Penal Code 19.03) at NorthPark Mall (8687 N. Central Expy., Dallas,
Texas 75225):
Answer:
2008:
2009
2010.
2011
2012
2013
2014:
2015.
2016
2017
2018
2019
2020:
2021
2022
Li Huang, et al. v. NorthPark Partners, LP et al.:
Plaintiffs’ DW/Qs to Dallas Police Department Page 11 of 21
16. For each of the following years, please state the total number of reported instances of
criminal trespass (or Texas Penal Code 30.052) at NorthPark Mall (8687 N. Central Expy.,
Dallas, Texas 75225):
Answer:
2008
2009:
2010:
2011
2012:
2013:
2014:
2015
2016:
2017
2018:
2019
2020:
2021
2022
Li Huang, et al. v. NorthPark Partners, L.P. et al.:
Plaintiffs’ DW/Qs to Dallas Police Department Page 12 of 21
17. For each of the following years, please state the total number of reported instances of
disorderly conduct (or Texas Penal Code 42.01) at NorthPark Mall (8687 N. Central Expy.,
Dallas, Texas 75225):
Answer:
. 2008:
2009:
2010
2011
2012
2013
2014
2015
2016:
2017
2018:
2019
2020
2021
2022
Li Huang, et al. v. NorthPark Partners, LP et al.:
Plaintiffs’ DW/Qs to Dallas Police Department Page 13 of21
18. For each of the following years, please state the total number of reported instances of
criminal mischief (or Texas Penal Code 28.03) at NorthPark Mall (8687 N. Central Expy.,
Dallas, Texas 75225):
Answer:
. 2008:
2009
2010:
2011
2012:
2013
2014
2015
2016
2017
2018
2019
2020:
2021
2022:
Li Huang, et al. v. NorthPark Partners, L.P et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 14 of 21
19. For each of the following years, please state the total number of reported instances of
manslaughter (or Texas Penal Code 19.04) at NorthPark Mall (8687 N. Central Expy., Dallas,
Texas 75225):
Answer:
2008:
2009:
2010:
2011
2012
2013:
2014
2015.
2016
2017
2018:
2019
2020
2021
2022:
Li Huang, et al. v. NorthPark Partners, L.P et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 15 of 21
20. For each of the following years, please state the total number of reported instances of
burglary of vehicles (or Texas Penal Code 30.04) at NorthPark Mall (8687 N. Central Expy.,
Dallas, Texas 75225):
Answer:
2008:
2009
2010:
2011
2012
2013:
2014:
2015
2016:
2017
2018
2019
2020:
2021
2022
Li Huang, et al. v. North Park Partners, L.P et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 16 of21
21. For each of the following years, please state the total number of reported instances of
injury to a child, elderly individual, or disabled individual (or Texas Penal Code 22.04)
at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225):
2008:
2009
2010
2011
2012
2013
2014
2015:
2016:
2017
2018
2019:
2020:
2021
2022:
Li Huang, et al. v. NorthPark Partners, LP et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 17 of 21
22. For each of the following years, please state the total number of reported instances of
deadly conduct (or Texas Penal Code 22.05) at NorthPark Mall (8687 N. Central Expy., Dallas,
‘Texas 75225):
Answer:
2008:
2009:
2010:
2011
2012:
2013
2014:
2015:
2016:
2017
2018:
2019
2020:
2021
2022
Li Huang, et al. v. NorthPark Partners, LP et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 18 of 21
23. For each of the following years, please state the total number of reported instances of
unauthorized use of a vehicle (or Texas Penal Code 31.07) at NorthPark Mall (8687 N.
Central Expy., Dallas, Texas 75225):
Answer:
. 2008:
2009
2010:
2011
2012
2013
2014:
2015
2016:
2017
2018
2019:
2020:
2021
2022
Li Huang, et al. v. NorthPark Partners, L.P et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 19 of21
24. For each of the following years, please state the total number of reported instances of
theft (or Texas Penal Code 31.03) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas
75225):
Answer:
2008
2009:
2010
2011
2012
2013
2014:
2015:
2016
2017
2018
2019
2020:
2021
2022:
Li Huang, et al. v. NorthPark Partners, L.P et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 20 of 21
WITNESS AND CUSTODIAN OF RECORDS
SWORN and SIGNED on this the day of , 202. to certify which
witness my hand and seal of office.
Name:
Notary in and for the State of
iD Huang, et al. v. NorthPark Partners, LP et al.:
Plaintiffs’ DWQs to Dallas Police Department Page 21 of 21
Discovery Records, Inc.
www.discoveryrecordsine.com
1290 S, Main Street, Suite 108
Grapevine, TX 76051
Ph, (817) 424-3672 Fax (817) 424-3692
Toll Free (866) 463-3732
PLEASE RETURN
THIS COVER SHEET
March 16, 2020
Michael A. Miller
The Miller Law Firm
3811 Turtle Creek Blvd., Suite 1950 469-916-2552
Dallas, TX 75219 Fax 469-916-2555
WAIVER & NOTICE OF WRITTEN QUESTIONS
Re: Cause No. DC-19-18649
In the 134TH JUDICIAL DISTRICT, DALLAS County
LI HUANG, INDIVIDUALLY AND ON BEHALF OF YU LUO AND AS NEXT FRIEND OF
Y.L., ZHIMING LUO, SHIGUO WANG, ET AL
VS.
NORTHPARK PARTNERS, L.P., NORTHPARK MANAGEMENTCOMPANY,
NORTHPARK LAND PARTNERS, L.P., ET AL
Re: Location: 8687 N. Central Expy., Dallas, TX 75225
Discovery Records, Inc. will be obtaining records from the location(s) attached. The cost for each
record will be $55.00 plus .50 cents per page. You can choose to purchase all, or a selected portion.
Please check the appropriate boxes and return.
Yes No
Will you WAIVE the notice period? Q Q
Do you want copies of ALL records? Q Q
Authorized Signature
Delivered 3/16/2020
Date
Mail
Fax 53 pes
Hand
DEFENDANT'S
EXHIBIT
B
RECORD LOCATIONS: TYPE:
QC] 205488 Dallas Police Department CRIMINAL INCIDENT
1400 South Lamar
Dallas, TX 75201
214-671-3345 214-671-4635
Discovery Records, Inc.
www.discoveryrecordsinc.com
1290 S. Main Street, Suite 108
Grapevine, TX 76051
Ph. (817) 424-3672 Fax (817) 424-3692
Toll Free (866) 463-3732
Cause No. DC-19-18649
LI HUANG, INDIVIDUALLY AND ON BEHALF IN THE DISTRICT COURT
OF YU LUO AND AS NEXT FRIEND OF Y.L.,
ZHIMING LUO, SHIGUO WANG, ET AL
VS DALLAS COUNTY, TEXAS
NORTHPARK PARTNERS, L.P., NORTHPARK
MANAGEMENTCOMPANY, NORTHPARK
LAND PARTNERS, L.P., ET AL 134TH JUDICIAL DISTRICT
NOTICE OF INTENTION
TO TAKE DEPOSITION BY WRITTEN QUESTIONS
To: Defendant(s), by and through their Attomey of Record:
Michael A, Miller
3811 Turtle Creek Blvd., Suite 1950
Dallas, TX 75219
469-916-2552 Fax 469-916-2555
And the witnesses as identified in the attached deposition(s)
You will please take notice that after (20) days from the service of a copy hereof with attached questions, a deposition by
written questions will be taken of the witness: CUSTODIAN OF CRIMINAL INCIDENT RECORDS FOR:
Dallas Police Department
1400 South Lamar
Dallas, TX 75201 214-671-3345
Before a Notary Public, or other Officer authorized to administer oaths, with Discovery Records Inc, 1290 S. Main Street,
Suite 108, Grapevine, Texas 76051, or their designated agent; at the office of the summoned witness.
Which deposition with attached questions and exhibits may be used in evidence upon the trial of the above styled and
numbered cause pending in the above named court. Notice is further given that request is hereby made as authorized under
Rule 200, Texas Rules of Civil Procedure, to the Officer authorized to take this deposition to issue a Subpoena Duces
Tecum and cause it to be served on the witness to produce:
ANY AND ALL RECORDS, DOCUMENTS, AND TANGIBLE ITEMS (INCLUDING ELECTRONIC OR
MAGNETIC DATA), AS REQUESTED IN THE ATTACHED
EXHIBIT A
LIST OF PRODUCTION REQUESTS STARTING WITH EXHIBIT "B" THRU EXHIBIT "UU"
* PLEASE ATTACH DOCUMENTS ACCORDINGLY TO EACH SEPARATE EXHIBIT
and turn such records over to the Officer authorized to take this deposition so that inspection and photocopying of the same
may be made and attached to said deposition.
Discfile/205488
Respectfully submitted:
POP be
Mare C. Lenahan
State Bar No. 24007546
Lenahan Law, P.L.L.C.
One Metro Square West
2655 Villa Creek, Suite 204
Dallas, TX 75234
Phone 214-295-1008 Fax 214-295-2664
Law@Lenahanlaw.com
Attorney for: Plaintiffs,
Li Huang, et al
Certificate of Service
I certify that a true and exact copy of the foregoing Notice of Intention To Take Deposition by Written
Questions was provided to the respective parties or attorneys of record, pursuant to Rule (21a), by:
Certified mail, postage prepaid Date: 03/16/2020
Hand delivery
X_ Telephonic document transfer
Sworn to and subscribe before me on this the 16 day of March, 2020 .
KAZ Notary Pub in and for WES4/ MY
DAVID B MARTIN
va
a
PU BLIC
XAS
COMM. EXP. 10/17/22
State of Texas NOTARY ID 191557-4
Exhibit A
FOR THE ATTACHED
LIST OF PRODUCTION REQUESTS
STARTING WITH
EXHIBIT "B" THRU EXHIBIT "UU"
e PLEASE ATTACH DOCUMENTS ACCORDINGLY
TO EACH SEPARATE EXHIBIT
Exhibit B:
1 With regard to incidents identified as “CRIMINAL TRESPASS’, please
produce:
arrest reports;
incident reports;
arrest logs;
incident logs;
incident responses;
crime reports;
police reports;
search warrants;
arrest warrants;
citations;
warnings;
complaints;
notices;
affidavits; and
statements;
For:
° Incidents occurring during the 10 years from March 11, 2009, through
March 10, 2019; and
. anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a
“NorthPark Center’).
Exhibit C:
1 With regard to incidents identified as “CRIMINAL TRESPASS”, please
produce:
arrest reports;
incident reports;
arrest logs;
incident logs;
incident responses;
crime reports;
police reports;
search warrants;
arrest warrants;
citations;
warnings;
complaints;
notices;
affidavits; and
statements;
For:
. Incidents occurring during the 1 year from March 11, 2019, through
March 10, 2020; and
. anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a
“NorthPark Center’).
Exhibit D:
1 With regard to incidents identified as “CRIMINAL TRESPASS WARNING’,
please produce:
arrest reports;
incident reports;
arrest logs;
incident logs;
incident responses;
crime reports;
police reports;
search warrants;
arrest warrants;
citations;
warnings;
complaints;
notices;
affidavits; and
statements;
For:
. Incidents occurring during the 10 years from March 11, 2009, through
March 10, 2019; and
. anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a
“NorthPark Center”).
Exhibit E:
1 With regard to incidents identified as “CRIMINAL TRESPASS WARNING’,
please produce:
arrest reports;
incident reports;
arrest logs;
incident logs;
incident responses;
crime reports;
police reports;
search warrants;
arrest warrants;
citations;
warnings;
complaints;
notices;
affidavits; and
statements;
For:
. Incidents occurring during the 1 year from March 11, 2019, through
March 10, 2020; and
. anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a
“NorthPark Center").
Exhibit F:
1 With regard to incidents identified as “POSS CONT SUB’ (all types), please
produce:
arrest reports;
incident reports;
arrest logs;
incident logs;
incident responses;
crime reports;
police reports;
search warrants;
arrest warrants;
citations;
warnings;
complaints;
notices;
affidavits; and
statements;
For:
. Incidents occurring during the 10 years from March 11, 2009, through
March 10, 2019; and
. anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a
“NorthPark Center’).
Exhibit G:
1 With regard to incidents identified as "POSS CONT SUB" (all types), please
produce:
arrest reports;
incident reports;
arrest logs;
incident logs;
incident responses;
crime reports;
police reports;
search warrants;
arrest warrants;
citations;
warnings;
complaints;
notices;
affidavits; and
statements;
For:
. Incidents occurring during the 1 year from March 11, 2019, through
March 10, 2020; and
. anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a
"NorthPark Center’).
Exhibit H:
1 With regard to incidents identified as “CRIM MISCHIEF” (all types), please
produce:
arrest reports;
incident reports;
arrest logs;
incident logs;
incident responses;
crime reports;
police reports;
search warrants;
arrest warrants;
citations;
warnings;
complaints;
notices;
affidavits; and
statements;
For:
. Incidents occurring during the 10 years from March 11, 2009, through
March 10, 2019; and
. anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a
"NorthPark Center").
Exhibit |:
1
With regard to incidents identified as "CRIM MISCHIEF" (all types), please
produce:
arrest reports;
incident reports;
arrest logs;
incident logs;
incident responses;
crime reports;
police reports;
search warrants;
arrest warrants;
citations;
warnings;
complaints;
notices;
affidavits; and
statements;
For:
. Incidents occurring during the 1 year from March 11, 2019, through
March 10, 2020; and
° anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a
“NorthPark Center”).
Exhibit J:
1 With regard to incidents identified as "MAN DEL CONT SUB’ (all types),
please produce:
arrest reports;
incident reports;
arrest logs;
incident logs;
incident responses;
crime reports;
police reports;
search warrants;
arrest warrants;
citations;
warnings;
complaints;
notices;
affidavits; and
statements;
For:
. Incidents occurring during the 10 years from March 11, 2009, through
March 10, 2019; and
. anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a
“NorthPark Center").
Exhibit K:
1 With regard to incidents identified as “MAN DEL CONT SUB’ (all types),
please produce:
arrest reports;
incident reports;
arrest logs;
incident logs;
incident responses;
crime reports;
police reports;
search warrants;
arrest warrants;
citations;
warnings;
complaints;
notices;
affidavits; and
statements;
For:
. Incidents occurring during the 1 year from March 11, 2019, through
March 10, 2020; and
. anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a
“NorthPark Center’).
Exhibit L:
1 With regard to incidents identified as “PUBLIC INTOXICATION,” please
produce:
arrest reports;
incident reports;
arrest logs;
incident logs;
incident responses;
crime reports;
police reports;
search warrants;
arrest warrants;
citations;
warnings;
complaints;
notices;
affidavits; and
statements;
For:
. Incidents occurring during the 10 years from March 11, 2009, through
March 10, 2019; and
° anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a
“NorthPark Center’),
Exhibit M:
1
Preview
FILED 10/6/2022 3:54 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Jenifer Trujillo DEPUTY CAUSE NO. DC-19-18649 LI HUANG, (1) Individually; (2) on Behalf of IN THE DISTRICT COURT Her Wrongfully Deceased Husband, YU LUO; and as Next Friend of Their Surviving Child, Minor Xxxxxx Xxx; ZHIMING LUO, Individually; SHIGUO WANG, (1) Individually; and as (2) Next Friend of Minor, Xxxxx Xxxx; and XIAOLI WEL, Individually, Plaintiffs, vs. DALLAS COUNTY, TEXAS NORTHPARK PARTNERS, L.P., NORTHPARK MANAGEMENT COMPANY, NORTHPARK LAND PARTNERS, L.P., NORTHPARK SECURITY, INC., and CHRISTOPHER RYAN SHAW, Defendants. 134th JUDICIAL DISTRICT DEFENDANTS NORTHPARK LAND PARTNERS, LP, NORTHPARK PARTNERS, LP, NORTHPARK MANAGEMENT COMPANY, AND NORTHPARK SECURITY, INC.’S OBJECTIONS TO PLAINTIFFS' SEPTEMBER OF 2022 NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS OF THE DALLAS POLICE DEPARTMENT AND MOTION FOR PROTECTION L INTRODUCTION On September 28, 2022, Defendants' counsel was served with Plaintiffs' September of 2022 Notice of Intention to Take Depositions on Written Questions of the Dallas Police Department (the "Notice"), a true and correct copy of which is attached hereto as Exhibit "A," and incorporated herein as if set forth verbatim. In the Notice, Plaintiffs seek, among other things, the "instances of NORTHPARK DEFENDANTS' OBJECTIONS TO PLAINTIFFS' SEPTEMBER OF 2022 NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS OF THE DALLAS POLICE DEPARTMENT AND MOTION FOR PROTECTION P.1 alleged criminal conduct reported to it" at NorthPark Center for the time periods of 2008, 2009, 2010, 2011, 2012, 2013, 2014, 2015, 2016, 2017, 2018, 2019, 2020, 2021, and 2022. By way of example, Plaintiffs seek the following information for each of the aforementioned years: | 10. For each of the following years, please state the total number of reported instandes of aggravated assault (or Texas Penal Code 22.02) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225): | ll. For cach of the following years, please state the total number of reported instances of robbery (or ‘Texas Penal Code 29.02) at NorthPark Mall (8687 N. Central Expy., Dallas, ‘Texas 5295) $225 12; Yor each of the following years, please state the total number of reported instances of aggravated obbery (or Texas Penal Code 29.03) at NorthPark Mall (8687 N. Central Expy. Dallas, Texas 75225): | The Notice seeks the same information for (13) unlawful carrying ofa weapon, (14) murder, (15) capital murder, (16) criminal trespass, (17) disorderly conduct, (18) criminal mischief, (19) manslaughter, (20) burglary of vehicles, (21) injury to a child, elderly individual, or disabled individual, (22) deadly conduct, (23) unauthorized use of a vehicle, and (24) theft. Plaintiffs seek to obtain records from the DPD between the years 2008 and 2022; seeking the DPD to calculate the "number of instances" for each separate crime. IL. TIMELINESS Pursuant to Rule 200.3 of the Texas Rules of Civil Procedure, objections to a party’s Deposition on Written Questions must be served on all parties within ten days after the notice is served. Defendant’s objections to Plaintiffs Deposition on Written Questions are thus timely filed. NORTHPARK DEFENDANTS' OBJECTIONS TO PLAINTIFFS' SEPTEMBER OF 2022 NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS OF THE DALLAS POLICE DEPARTMENT AND MOTION FOR PROTECTION P.2 Ti. ARGUMENT AND AUTHORITIES A discovery request is outside the scope of discovery when (1) it asks for information that is not relevant, or (2) the information requested will not lead to admissible evidence.' Furthermore, a request for all documents without limitation on subject matter is overbroad.” Plaintiff's requests seek documents that are entirely irrelevant to this litigation and not likely to lead to the discovery of admissible evidence. Additionally, the discovery sought is unreasonably cumulative or duplicative. Tex. R. Civ. P. 192,4(a). Further, the burden and expense of the proposed discovery outweighs its likely benefit. Tex. R. Civ. P. 192.4(b). Defendants further object to these requests as overly broad and not limited as to scope, as Plaintiffs seek the totality of North Park Center, of which the Court previously limited the scope of Plaintiffs' requests to the non-HVAC areas of NorthPark. Plaintiff's requests are not sufficiently limited to the area in which the incident occurred on March 11, 2019. Defendant further objects to these requests as not limited in time as the requests seek "number of instances" dating back to 2008 through the present time, despite the incident occurring on March 11, 2019. Plaintiffs’ requests seek discovery covering an unreasonably long time period that is impermissibly overbroad.* Plaintiffs' Notice seeks documents that are entirely irrelevant to this litigation and not likely to lead to the discovery of admissible evidence. Accordingly, Plaintiff's requests “[are] not merely an impermissible fishing expedition; [they are] an effort to dredge the lake in hopes of finding fish.”* Defendants further object to Plaintiffs' Notice as violative of this Court’s prior discovery order of August 14, 2020, whereas this Court limited the timeframe for which information relating ' TRCP 192.3(a); see In re CSX Corp., 124 S.W.3d 149, 152 (Tex. 2003); Axelson, Inc. v. McIthany, 798 S.W.2d 550, 553 (Tex. 1990). ? Texaco, Inc. v Sanderson, 898 S.W.2d 813, 815 (Tex. 1995). 3 In re Am. Optical, 988 $.W.2d 711, 713 (Tex. 1998); see also Dillard Dep't Stores, Inc. v. Hall, 909 S.W.2d 491, 492 (Tex. 1995); K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1996). * Texaco, Inc. v. Sanderson, 898 S.W.2d 813, 815 (Tex. 1995)(citing Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989)) NORTHPARK DEFENDANTS' OBJECTIONS TO PLAINTIFFS' SEPTEMBER OF 2022 NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS OF THE DALLAS POLICE DEPARTMENT AND MOTION FOR PROTECTION P.3 to the reporting of incidents at NorthPark was ordered to be produced for a ten-year period between 3-11-2009 and 3-11-2019. (Attached hereto as “Exhibit B”). Plaintiffs most recent requests in the Notice go far beyond the ten-year timeframe previously ordered. None of these crimes, except aggravated assault, have anything to do with the incident made the subject of this litigation.* Plaintiffs' Notice further expand the types and locations of incidents that were previously limited by this Court in the attached Order. By way of example, Plaintiffs seek the DPD to review its files for a fourteen-year period of time, and calculate the number of "reported instances" for each of the crimes mentioned herein including aggravated assault, robbery, aggravated robbery, unlawful carrying of a weapon, murder, capital murder, criminal trespass, disorderly conduct, criminal mischief, manslaughter, burglary of vehicles, injury to a child, elderly individual, or disabled individual, deadly conduct, unauthorized use of a vehicle, and theft. Lastly, Defendants object to these requests as duplicative, in part, of Plaintiffs' prior Deposition Upon Written Questions served to the Dallas Police Department on or about March 16, 2020, seeking similar, if not almost identical information, for the time period of March 11, 2009 through March 10, 2019, and requesting (a) arrest warrants, (b) incident reports, (c) arrest logs, (d) incident logs, (e) incident responses, (f) crime reports, (g) police reports, (h) search warrants, (i) arrest warrants, (j) citations, (k) warnings, (1) complaints, (m) notices, (n) affidavits; and (0) statements (the "March Notice"). The records the March Notice sought the above records for the following crimes: (1) Criminal Trespass, (2) Criminal Trespass Warning, (3) Poss Cont Sub, (4) Crim Mischief, (5) Man Del Cont Sub, (6)Public Intoxication, (7) Assault, (8) Disorderly Conduct, (9) Robbery, (10) BMV, (11) Warrant Hold, (12) Warrant-Dallas PD, (13) Resist Arrest Search or 5 Even with aggravated assault (which involves serious bodily injury, use of a deadly weapon, or both), the only known reported instance of aggravated assault where a vehicle was used as a deadly weapon, is the incident that forms the basis of this litigation. NORTHPARK DEFENDANTS' OBJECTIONS TO PLAINTIFFS' SEPTEMBER OF 2022 NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS OF THE DALLAS POLICE DEPARTMENT AND MOTION FOR PROTECTION P.4 Transport, (14) Unauthorized Use of Motor Veh, (15) Theft of Prop (Auto Acc), (16) Traf Vio- Duty on Strike Unattended Veh, (16) Fail to ID, (17) DWI, (18) Reckless Damage, (19) Evading Arrest Detention, (20) Manslaughter, and (21) Homicide. Plaintiffs March Notice to the DPD produced fourteen volumes with over 13,000 pages of incident reports for the subject time period. Essentially, in Plaintiffs’ most recent Notice to the DPD, Plaintiffs seek "generally accurate" data on reports of crime for a fourteen-year span, that may not have been the reported crime in reality or even a crime to begin with. Obtaining this information does nothing to advance this case in any appreciable manner. Therefore, pursuant to Rule 192. (a) of the Texas Rules of Civil Procedure, the NorthPark Defendants seek a Protective Order precluding Plaintiffs from engaging in this form of a discovery request. Respectfully Submitted, /s/ Michael A. Miller MICHAEL A. MILLER State Bar No. 14100650 mmiller@mklawpe.com MILLER KNAUFF LAW FIRM Three Forest Plaza 12221 Merit Drive, Suite 1210 Dallas, Texas 75251 (469) 916-2552 (469) 916-2555 fax ATTORNEYS FOR DEFENDANT NORTHPARK PARTNERS, LP, NORTHPARK LAND PARTNERS, LP NORTHPARK MANAGEMENT COMPANY NORTHPARK SECURITY, INC. NORTHPARK DEFENDANTS' OBJECTIONS TO PLAINTIFFS' SEPTEMBER OF 2022 NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS OF THE DALLAS POLICE DEPARTMENT AND MOTION FOR PROTECTION P.5 CERTIFICATE OF SERVICE Thereby certify that a true and correct copy of the foregoing instrument has been forwarded to all counsel of record in accordance with the Texas Rules of Civil Procedure this 6th day of October 2022. Via E-Service Mare C. Lenahan P. Wes Black Lenahan Law, P.L.L.C. 2655 Villa Creek, Suite 204 Dallas, Texas 75234 wes@|lenahanlaw.com Law@LenahanLaw.com Counsel for Plaintiffs Via First Class Mail Christopher Ryan Shaw (TDCI Inmate #0234485 1) c/o Texas Department of Criminal Justice Louis C. Powledge Unit 1400 FM 3452 Palestine, Texas 75803 DOB: 07-14-1990 /s/ Michael A. Miller MICHAEL A. MILLER NORTHPARK DEFENDANTS' OBJECTIONS TO PLAINTIFFS' SEPTEMBER OF 2022 NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS OF THE DALLAS POLICE DEPARTMENT AND MOTION FOR PROTECTION P.6 Date: 9/28/2022 Cause No. DC-19-18649 DALLAS COUNT’ 134TH JUDICIAL DISTRICT Style: LI HUANG, INDIVIDUALLY AND ON BEHALF OF YU LUO AND AS NEXT FRIEND OF Y.L., ZHIMING LUO, SHIGUO WANG, ET AL vs NORTHPARK PARTNERS, L.P., NORTHPARK MANAGEMENT COMPANY, NORTHPARK LAND PARTNERS, L.P., ET AL REE: NorthPark Mall (8687 N. Central ixpwy, Dallas, ‘1X 75225) Attorney: Mare C. Lenahan Law@Lenahan.com Firm: Lenahan Law, P.L.L.C. For: Plaintiff NOTICE OF DEPOSITION ON WRITTEN QUESTIONS Record Depositions: Type/Scope: City of Dallas WRIT EN QUESTIONS c/o Custodian of Records for Dallas Police Department 1500 Marilla Street, Room 5D South Dallas, TX 75201 214-671-3345 DEFENDANT'S EXHIBIT A Discovery Records, Inc. woww.discoveryrecordsine.com 1290 S. Main Street, Suite 108 Grapevine, TX 76051 Ph. (817) 424-3672 Fax (817) 424-3692, Digital Fax Line (817) 200-7478 PLEASE RETURN THIS COVER SHEET September 28, 2022 Michacl A. Miller Miller Knauff Law Firm Three Forest Plaza 12221 Merit Drive, Suite 1210 469-916-2552 Dallas, TX 75251 Vax 469-916-2555 WAIVER & NOTICE OF WRITTEN QUESTIONS Re: Cause No. DC-19-18649 In the 134TH JUDICIAL DISTRICT, DALLAS County LI HUANG, INDIVIDUALLY AND ON BEHALF OF YU LUO AND AS NEXT FRIEND OF Y.L., ZHIMING LUO, SHIGUO WANG, ET AL VS. NORTHPARK PARTNERS, L.P., NORTHPARK MANAGEMENT COMPANY, NORTHPARK LAND PARTNERS, L.P., BT AL Re: NorthPark Mall (8687 N. Central Expwy, Dallas, TX 75225) Discovery Records, Inc. will be obtaining records from the location(s) attached. ‘The cost for cach record will be $70.00 plus .50 cents per page. You can choose to purchase all, or a selected portion. Please check the appropriate boxes and return. Yes No Will you WAIVE the notice period? Q Q Do you want copies of ALL records? Q Q Authorized Signature Delivered 9/28/2022 Date CMRR __ Ete 23 pgs RECORD LOCATIONS: eves Q 237184 City of Dallas WRI JN QUESTIONS c/o Custodian of Records for Dallas Police Department 1500 Marilla Street, Room SD South Dallas, TX 75201 214-671-3345 214-671-4635 CAUSE No. DC-19-18649 Lr HUANG, IN THE 134TH JUDICIAL Yu Luo; MINOR XXXXXXK XXX; ZHIMING LUO, SHIGUO WANG, MINOR XXXXX XXXX; AND XIAOLI WEI; PLAINTIFFS, Vv. DisTRICT COURT OF NORTHPARK PARTNERS, L.P.; NORTHPARK MANAGEMENT COMPANY; NORTHPARK LAND PARTNERS, L.P. (INDIVIDUALLY AND IN REM); NORTHPARK SECURITY, INC.; AND; CHRISTOPHER RYAN SHAW, DEFENDANTS. DALLAS COUNTY, TEXAS PLAINTIFFS’ SEPTEMBER OF 2022 NOTICE OF INTENTION TO TAKE DEPOSITIONS ON WRITTEN QUESTIONS OF THE DALLAS POLICE DEPARTMENT To: Michael A. Miller and Clark S. Butler, MILLER KNAUFF LAW FirM, Three Forest Plaza, 12221 Merit Drive, Suite 1210, Dallas, Texas 75251. You will please take notice that 20 days after service hereof, Plaintiffs will seek third-party discovery of: Dallas Police Department 1400 South Botham Jean Boulevard Dallas, Texas 75215; as authorized under Rule 200 of the TEXAS RULES OF CIVIL PROCEDURE, and before a representative of (or any Notary Public designated by): Li Huang, et al. v. NorthPark Partners, L.P et al.: Plaintiffs’ DWQs to Dallas Police Department Page 1 of 21 Discovery Records, Inc. 1290 South Main Street, Suite 108 Grapevine, ‘Texas 76051 817.424.3672 817.424.3692 fax The Depositions will be on the written questions attached to this notice as Exhibit A. It is to be used in the above-styled cause. DATED: September23, 2022. Respectfully submitted, 47 LE Marc C. Lenahan State Bar No. 24007546 Law@LenahanLaw.com P. Wes Black State Bar No. 24009904 Wes@LenahanLaw.com LENAHAN Law, P.L.L.C. 2655 Villa Creek, Suite 204 Dallas, Texas 75234 214.295.1008 888.473.2820 toll-free 214.295.2664 fax ATTORNEYS FOR PLAINTIFFS Li Huang, et al. v. NorthPark Partners, LP et al.: Plaintiffs’ DWQs to Dallas Police Department Page 2 of 21 CERTIFICATE OF SERVICE I certify that a true copy of the foregoing document was served on counsel of record, as well as interested counsel, per the TRCP on this as day of agt 52022. Michael A. Miller Clark S. Butler MILLER KNAUFF LAW FIRM Three Forest Plaza 12221 Menit Drive Suite 1210 Dallas, Texas 75251 fF LW Marc C. Lenahan Li Huang, et al. v. NorthPark Partners, L.P et al.: Plaintiffs’ DWQs to Dallas Police Department Page 3 of 21 EXHIBIT A Direct Questions Propounded to the Witness: Please state your name, work address, and work phone. Answer: Name: Address: Cell: email: 2 Does the Dallas Police Department maintain records of reported criminal conduct occurring at physical addresses within the City of Dallas? Answer: 3 Are you familiar with the manner in which the Dallas Police Department documents instances of alleged criminal conduct reported to it? Answer: 4. Are you familiar with the database(s) used by the Dallas Police Department to catalog and access reported incidents of criminal conduct? Answer: 2 Are you familiar with the use of the database(s) to retrieve information regarding the number of reported instances of criminal conduct at a given address? Answer: Li Huang, et al. v. NorthPark Partners, L.P et al.: Plaintiffs’ DWQs to Dallas Police Department Page 4 of 21 6 I am qualified to answer questions with the regard to the number of reported instances of criminal conduct at a given address based upon the following: Answer: My position with regard to the Dallas Police Department is: My familiarity, training, and/or experience with the resources necessary to answer questions with regard to the number of reported instances at a given address includes: 7 Does the Dallas Police Department use databases of reported criminal conduct to make reports to Federal or State agencies regarding crime statistics? Answer: 8 Do Federal or State agencies rely on the statistical data provided by the Dallas Police Department maintained in its databases of reported criminal conduct? Answer: 9 Based on your understanding of the manner in which the Dallas Police Department documents and catalogs instances of reported criminal conduct, do you believe that the information you provide herein regarding the number of reports of criminal conduct at a given address is generally accurate? Answer: Li Huang, et al. v. NorthPark Partners, LP. et al.: Plaintiffs’ DWQs to Dallas Police Department Page 5 of 21 10. For each of the following years, please state the total number of reported instances of aggravated assault (or Texas Penal Code 22.02) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225): Answer: . 2008: 2009: 2010 2011 2012 2013 2014: 2015 2016: 2017 2018 2019 2020: 2021 2022 Li Huang, et al. v. NorthPark Partners, LP et al.: Plaintiffs’ DW/Qs to Dallas Police Department Page 6 of 21 ll. For each of the following years, please state the total number of reported instances of robbery (or Texas Penal Code 29.02) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225): Answer: 2008 2009: 2010: 2011 2012 2013: 2014: 2015: 2016: 2017 2018: 2019: 2020: 2021 2022 Li Huang, et al. v. NorthPark Partners, L.P et al.: Plaintiffs’ DWQs to Dallas Police Department Page 7 of 21 1 For each of the following years, please state the total number of reported instances of aggravated robbery (or Texas Penal Code 29.03) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225): Answer: . 2008 2009: 2010: 2011 2012 2013 2014: 2015 2016: 2017 2018: 2019: 2020: 2021 2022 Li Huang, et al. v. NorthPark Partners, LP et al.: Plaintiffs’ DWQs to Dallas Police Department Page 8 of 21 13. For each of the following years, please state the total number of reported instances of unlawful carrying of a weapon (or Texas Penal Code 46.02) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225): Answer: 2008: 2009: 2010: 2011 2012 2013 2014: 2015: 2016 2017 2018: 2019: 2020: 2021 2022. Li Huang, et al.'v. North Park Partners, L.P et al.: Plaintiffs’ DWQs to Dallas Police Department Page 9 of 21 14. For each of the following years, please state the total number of reported instances of murder (or Texas Penal Code 19.02) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225): Answer: . 2008 2009 2010 2011 2012 2013 2014: 2015 2016 2017 2018 2019 2020: 2021 2022 Li Huang, et al. v. NorthPark Partners, L.P et al.: Plaintiffs’ DW/Qs to Dallas Police Department Page 10 of 21 15. For each of the following years, please state the total number of reported instances of capital murder (or Texas Penal Code 19.03) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225): Answer: 2008: 2009 2010. 2011 2012 2013 2014: 2015. 2016 2017 2018 2019 2020: 2021 2022 Li Huang, et al. v. NorthPark Partners, LP et al.: Plaintiffs’ DW/Qs to Dallas Police Department Page 11 of 21 16. For each of the following years, please state the total number of reported instances of criminal trespass (or Texas Penal Code 30.052) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225): Answer: 2008 2009: 2010: 2011 2012: 2013: 2014: 2015 2016: 2017 2018: 2019 2020: 2021 2022 Li Huang, et al. v. NorthPark Partners, L.P. et al.: Plaintiffs’ DW/Qs to Dallas Police Department Page 12 of 21 17. For each of the following years, please state the total number of reported instances of disorderly conduct (or Texas Penal Code 42.01) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225): Answer: . 2008: 2009: 2010 2011 2012 2013 2014 2015 2016: 2017 2018: 2019 2020 2021 2022 Li Huang, et al. v. NorthPark Partners, LP et al.: Plaintiffs’ DW/Qs to Dallas Police Department Page 13 of21 18. For each of the following years, please state the total number of reported instances of criminal mischief (or Texas Penal Code 28.03) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225): Answer: . 2008: 2009 2010: 2011 2012: 2013 2014 2015 2016 2017 2018 2019 2020: 2021 2022: Li Huang, et al. v. NorthPark Partners, L.P et al.: Plaintiffs’ DWQs to Dallas Police Department Page 14 of 21 19. For each of the following years, please state the total number of reported instances of manslaughter (or Texas Penal Code 19.04) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225): Answer: 2008: 2009: 2010: 2011 2012 2013: 2014 2015. 2016 2017 2018: 2019 2020 2021 2022: Li Huang, et al. v. NorthPark Partners, L.P et al.: Plaintiffs’ DWQs to Dallas Police Department Page 15 of 21 20. For each of the following years, please state the total number of reported instances of burglary of vehicles (or Texas Penal Code 30.04) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225): Answer: 2008: 2009 2010: 2011 2012 2013: 2014: 2015 2016: 2017 2018 2019 2020: 2021 2022 Li Huang, et al. v. North Park Partners, L.P et al.: Plaintiffs’ DWQs to Dallas Police Department Page 16 of21 21. For each of the following years, please state the total number of reported instances of injury to a child, elderly individual, or disabled individual (or Texas Penal Code 22.04) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225): 2008: 2009 2010 2011 2012 2013 2014 2015: 2016: 2017 2018 2019: 2020: 2021 2022: Li Huang, et al. v. NorthPark Partners, LP et al.: Plaintiffs’ DWQs to Dallas Police Department Page 17 of 21 22. For each of the following years, please state the total number of reported instances of deadly conduct (or Texas Penal Code 22.05) at NorthPark Mall (8687 N. Central Expy., Dallas, ‘Texas 75225): Answer: 2008: 2009: 2010: 2011 2012: 2013 2014: 2015: 2016: 2017 2018: 2019 2020: 2021 2022 Li Huang, et al. v. NorthPark Partners, LP et al.: Plaintiffs’ DWQs to Dallas Police Department Page 18 of 21 23. For each of the following years, please state the total number of reported instances of unauthorized use of a vehicle (or Texas Penal Code 31.07) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225): Answer: . 2008: 2009 2010: 2011 2012 2013 2014: 2015 2016: 2017 2018 2019: 2020: 2021 2022 Li Huang, et al. v. NorthPark Partners, L.P et al.: Plaintiffs’ DWQs to Dallas Police Department Page 19 of21 24. For each of the following years, please state the total number of reported instances of theft (or Texas Penal Code 31.03) at NorthPark Mall (8687 N. Central Expy., Dallas, Texas 75225): Answer: 2008 2009: 2010 2011 2012 2013 2014: 2015: 2016 2017 2018 2019 2020: 2021 2022: Li Huang, et al. v. NorthPark Partners, L.P et al.: Plaintiffs’ DWQs to Dallas Police Department Page 20 of 21 WITNESS AND CUSTODIAN OF RECORDS SWORN and SIGNED on this the day of , 202. to certify which witness my hand and seal of office. Name: Notary in and for the State of iD Huang, et al. v. NorthPark Partners, LP et al.: Plaintiffs’ DWQs to Dallas Police Department Page 21 of 21 Discovery Records, Inc. www.discoveryrecordsine.com 1290 S, Main Street, Suite 108 Grapevine, TX 76051 Ph, (817) 424-3672 Fax (817) 424-3692 Toll Free (866) 463-3732 PLEASE RETURN THIS COVER SHEET March 16, 2020 Michael A. Miller The Miller Law Firm 3811 Turtle Creek Blvd., Suite 1950 469-916-2552 Dallas, TX 75219 Fax 469-916-2555 WAIVER & NOTICE OF WRITTEN QUESTIONS Re: Cause No. DC-19-18649 In the 134TH JUDICIAL DISTRICT, DALLAS County LI HUANG, INDIVIDUALLY AND ON BEHALF OF YU LUO AND AS NEXT FRIEND OF Y.L., ZHIMING LUO, SHIGUO WANG, ET AL VS. NORTHPARK PARTNERS, L.P., NORTHPARK MANAGEMENTCOMPANY, NORTHPARK LAND PARTNERS, L.P., ET AL Re: Location: 8687 N. Central Expy., Dallas, TX 75225 Discovery Records, Inc. will be obtaining records from the location(s) attached. The cost for each record will be $55.00 plus .50 cents per page. You can choose to purchase all, or a selected portion. Please check the appropriate boxes and return. Yes No Will you WAIVE the notice period? Q Q Do you want copies of ALL records? Q Q Authorized Signature Delivered 3/16/2020 Date Mail Fax 53 pes Hand DEFENDANT'S EXHIBIT B RECORD LOCATIONS: TYPE: QC] 205488 Dallas Police Department CRIMINAL INCIDENT 1400 South Lamar Dallas, TX 75201 214-671-3345 214-671-4635 Discovery Records, Inc. www.discoveryrecordsinc.com 1290 S. Main Street, Suite 108 Grapevine, TX 76051 Ph. (817) 424-3672 Fax (817) 424-3692 Toll Free (866) 463-3732 Cause No. DC-19-18649 LI HUANG, INDIVIDUALLY AND ON BEHALF IN THE DISTRICT COURT OF YU LUO AND AS NEXT FRIEND OF Y.L., ZHIMING LUO, SHIGUO WANG, ET AL VS DALLAS COUNTY, TEXAS NORTHPARK PARTNERS, L.P., NORTHPARK MANAGEMENTCOMPANY, NORTHPARK LAND PARTNERS, L.P., ET AL 134TH JUDICIAL DISTRICT NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS To: Defendant(s), by and through their Attomey of Record: Michael A, Miller 3811 Turtle Creek Blvd., Suite 1950 Dallas, TX 75219 469-916-2552 Fax 469-916-2555 And the witnesses as identified in the attached deposition(s) You will please take notice that after (20) days from the service of a copy hereof with attached questions, a deposition by written questions will be taken of the witness: CUSTODIAN OF CRIMINAL INCIDENT RECORDS FOR: Dallas Police Department 1400 South Lamar Dallas, TX 75201 214-671-3345 Before a Notary Public, or other Officer authorized to administer oaths, with Discovery Records Inc, 1290 S. Main Street, Suite 108, Grapevine, Texas 76051, or their designated agent; at the office of the summoned witness. Which deposition with attached questions and exhibits may be used in evidence upon the trial of the above styled and numbered cause pending in the above named court. Notice is further given that request is hereby made as authorized under Rule 200, Texas Rules of Civil Procedure, to the Officer authorized to take this deposition to issue a Subpoena Duces Tecum and cause it to be served on the witness to produce: ANY AND ALL RECORDS, DOCUMENTS, AND TANGIBLE ITEMS (INCLUDING ELECTRONIC OR MAGNETIC DATA), AS REQUESTED IN THE ATTACHED EXHIBIT A LIST OF PRODUCTION REQUESTS STARTING WITH EXHIBIT "B" THRU EXHIBIT "UU" * PLEASE ATTACH DOCUMENTS ACCORDINGLY TO EACH SEPARATE EXHIBIT and turn such records over to the Officer authorized to take this deposition so that inspection and photocopying of the same may be made and attached to said deposition. Discfile/205488 Respectfully submitted: POP be Mare C. Lenahan State Bar No. 24007546 Lenahan Law, P.L.L.C. One Metro Square West 2655 Villa Creek, Suite 204 Dallas, TX 75234 Phone 214-295-1008 Fax 214-295-2664 Law@Lenahanlaw.com Attorney for: Plaintiffs, Li Huang, et al Certificate of Service I certify that a true and exact copy of the foregoing Notice of Intention To Take Deposition by Written Questions was provided to the respective parties or attorneys of record, pursuant to Rule (21a), by: Certified mail, postage prepaid Date: 03/16/2020 Hand delivery X_ Telephonic document transfer Sworn to and subscribe before me on this the 16 day of March, 2020 . KAZ Notary Pub in and for WES4/ MY DAVID B MARTIN va a PU BLIC XAS COMM. EXP. 10/17/22 State of Texas NOTARY ID 191557-4 Exhibit A FOR THE ATTACHED LIST OF PRODUCTION REQUESTS STARTING WITH EXHIBIT "B" THRU EXHIBIT "UU" e PLEASE ATTACH DOCUMENTS ACCORDINGLY TO EACH SEPARATE EXHIBIT Exhibit B: 1 With regard to incidents identified as “CRIMINAL TRESPASS’, please produce: arrest reports; incident reports; arrest logs; incident logs; incident responses; crime reports; police reports; search warrants; arrest warrants; citations; warnings; complaints; notices; affidavits; and statements; For: ° Incidents occurring during the 10 years from March 11, 2009, through March 10, 2019; and . anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a “NorthPark Center’). Exhibit C: 1 With regard to incidents identified as “CRIMINAL TRESPASS”, please produce: arrest reports; incident reports; arrest logs; incident logs; incident responses; crime reports; police reports; search warrants; arrest warrants; citations; warnings; complaints; notices; affidavits; and statements; For: . Incidents occurring during the 1 year from March 11, 2019, through March 10, 2020; and . anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a “NorthPark Center’). Exhibit D: 1 With regard to incidents identified as “CRIMINAL TRESPASS WARNING’, please produce: arrest reports; incident reports; arrest logs; incident logs; incident responses; crime reports; police reports; search warrants; arrest warrants; citations; warnings; complaints; notices; affidavits; and statements; For: . Incidents occurring during the 10 years from March 11, 2009, through March 10, 2019; and . anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a “NorthPark Center”). Exhibit E: 1 With regard to incidents identified as “CRIMINAL TRESPASS WARNING’, please produce: arrest reports; incident reports; arrest logs; incident logs; incident responses; crime reports; police reports; search warrants; arrest warrants; citations; warnings; complaints; notices; affidavits; and statements; For: . Incidents occurring during the 1 year from March 11, 2019, through March 10, 2020; and . anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a “NorthPark Center"). Exhibit F: 1 With regard to incidents identified as “POSS CONT SUB’ (all types), please produce: arrest reports; incident reports; arrest logs; incident logs; incident responses; crime reports; police reports; search warrants; arrest warrants; citations; warnings; complaints; notices; affidavits; and statements; For: . Incidents occurring during the 10 years from March 11, 2009, through March 10, 2019; and . anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a “NorthPark Center’). Exhibit G: 1 With regard to incidents identified as "POSS CONT SUB" (all types), please produce: arrest reports; incident reports; arrest logs; incident logs; incident responses; crime reports; police reports; search warrants; arrest warrants; citations; warnings; complaints; notices; affidavits; and statements; For: . Incidents occurring during the 1 year from March 11, 2019, through March 10, 2020; and . anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a "NorthPark Center’). Exhibit H: 1 With regard to incidents identified as “CRIM MISCHIEF” (all types), please produce: arrest reports; incident reports; arrest logs; incident logs; incident responses; crime reports; police reports; search warrants; arrest warrants; citations; warnings; complaints; notices; affidavits; and statements; For: . Incidents occurring during the 10 years from March 11, 2009, through March 10, 2019; and . anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a "NorthPark Center"). Exhibit |: 1 With regard to incidents identified as "CRIM MISCHIEF" (all types), please produce: arrest reports; incident reports; arrest logs; incident logs; incident responses; crime reports; police reports; search warrants; arrest warrants; citations; warnings; complaints; notices; affidavits; and statements; For: . Incidents occurring during the 1 year from March 11, 2019, through March 10, 2020; and ° anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a “NorthPark Center”). Exhibit J: 1 With regard to incidents identified as "MAN DEL CONT SUB’ (all types), please produce: arrest reports; incident reports; arrest logs; incident logs; incident responses; crime reports; police reports; search warrants; arrest warrants; citations; warnings; complaints; notices; affidavits; and statements; For: . Incidents occurring during the 10 years from March 11, 2009, through March 10, 2019; and . anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a “NorthPark Center"). Exhibit K: 1 With regard to incidents identified as “MAN DEL CONT SUB’ (all types), please produce: arrest reports; incident reports; arrest logs; incident logs; incident responses; crime reports; police reports; search warrants; arrest warrants; citations; warnings; complaints; notices; affidavits; and statements; For: . Incidents occurring during the 1 year from March 11, 2019, through March 10, 2020; and . anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a “NorthPark Center’). Exhibit L: 1 With regard to incidents identified as “PUBLIC INTOXICATION,” please produce: arrest reports; incident reports; arrest logs; incident logs; incident responses; crime reports; police reports; search warrants; arrest warrants; citations; warnings; complaints; notices; affidavits; and statements; For: . Incidents occurring during the 10 years from March 11, 2009, through March 10, 2019; and ° anywhere on the premises of 8687 N. Central Expy, Dallas, TX 75225 (a/k/a “NorthPark Center’), Exhibit M: 1