On October 25, 2023 a
Deposition/Answers on Written Questions Margaret Hairell - Deposition/Answers on Written Questions
was filed
involving a dispute between
and
for Sec 401.001 Probate Will Independent Executor/rix
in the District Court of Galveston County.
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139132023 10:56 AM
Dwight D. Sullivan
County Clerk
Galveston County, Texas
PR-0084418
ESTATE OF § IN THE PROBATE COURT
ROBERT EDWARD HAWKINS, § OF
DECEASED § GALVESTON COUNTY, TEXAS
APPLICANT, THOMAS J. HAWKINS,
NOTICE OF INTENTION TO TAKE DEPOSITION ON WRITTEN QUESTIONS
Pursuant to Rule 200 of the Texas Rules of Civil Procedure, please take notice that after (10)
days from the service of a copy hereof with attached questions, a deposition by written questions will
be taken of the following witness:
MARGARET HAIRELL
4110 Alabama Ave
Dickinson, Texas 77539
The deposition will be taken at the witness’ address as given above and will be taken before
and by a Notary Public, an officer of the State of Louisiana, which deposition with attached questions
may be used in evidence upon the trial of the above styled and numbered cause pending in the above-
named court.
Respectfully submitted,
By: /S/ JamesS. Tittle
JAMES S. TITTLE
T.B.A. No. 00798193
107 Landing Blvd., Ste. F
League City, Texas 77586
(281) 332-1400 Telephone
(281) 332-8885 Facsimile
Email: James@LeagueCityLaw.com
Attomey for Applicant
PR-0084418
ESTATE OF § IN THE PROBATE COURT
ROBERT EDWARD HAWKINS, § OF
DECEASED § GALVESTON COUNTY, TEXAS
DEPOSITION UPON WRITTEN QUESTIONS
OF THE WITNESS, MARGARET HAIRELL
1 Please state your name, address and telephone number for the record.
ANSWER:
MARGARET HAIRELL , 4110 Alabama Ave., Dickinson, Texas 77539
2 Please confirm if you are a resident of Galveston County, Texas and if you are unable to attend
the court proceedings scheduled for this matter?
ANSWER:
I live in Dickinson, Texas. However, it would not be possible for me to personally appear at the
proceedings due to work and personal obligations.
3 Please describe how you were acquainted with ROBERT EDWARD HAWKINS, Deceased.
Please include a description of your relationship and the period of time such relationship existed.
ANSWER:
Lwasa personal
sonal friend
imiend ¢of ROBERT EDWARD HAWKINS for 8 years before witnessing his Will. [had
a chance to speak with him. see his Identification, and confirm that he was of sound mind for the purpose
of witnessing his Will.
4 Have you had an opportunity to review a copy of the written Last Will and Testament of ROBERT
EDWARD HAWKINS dated October 4, 2023? A copy of the Will is attached hereto as Exhibit “A”.
=
ANSWER:
Yes. I have had an opportunity to review the Will.
5 To the best of your knowledge, was ROBERT EDWARD HAWKINS, Decedent, of sound mind
and over the age of 18 years old on October 4, 2023?
ANSWER:
Yes. To the best of my knowledge ROBERT EDWARD HAWKINS was of sound mind, was able to
clearly communicate, and he was also over 18 years of age on October 4, 2023
6. Please describe if you are familiar with the handwriting and the signature of ROBERT EDWARD
HAWKINS, Decedent?
ANSWER:
Yes. I am familiar with both the handwriting and signature of ROBERT EDWARD HAWKINS. I
witnessed him sign this Will, and I recognize the signature on the October 4, 2023 Will to be that of
ROBERT EDWARD HAWKINS. This is the same Will I witnessed him execute on October 4, 2023.
7. Please describe specifically how you became familiar with the handwriting and signature of
ROBERT EDWARD HAWKINS, Decedent?
ANSWER:
Lam familiar with ROBERT EDWARD HAWKINS signature because I watched him sign his Will.
8 Do you believe that the document shown to you which purports to be the Last Will and Testament
of ROBERT EDWARD HAWKINS, Decedent, is signed by ROBERT EDWARD HAWKINS?
ANSWER:
Yes. Based on my past experience with ROBERT EDWARD HAWKINS I recognize his handwriting
and signature on the Will, and I believe that he signed the Will because I watched him sign it.
9 Do you believe ROBERT EDWARD HAWKINS executed the Will dated October 4, 2023 was
done as the free act and deed of ROBERT EDWARD HAWKINS?
ANSWER:
Yes. I believe ROBERT EDWARD HAWKINS executed the Will of his own free will. No one forced
him to sign anything. — =
10. Do you have any financial interest in the estate of ROBERT EDWARD HAWKINS, deceased?
ANSWER:
No.1 do not have any financial interest in the estate.
Trangia 7 barnatl
MARGARET HAIRELL
I Saws! N Peste{ a Notary Public in and for the State of Texas, do hereby
certify that the foregoing answers of the witness were by the said witness and were sworn and subscribed
before me.
th
Given under my hand and seal of office on this [2 _day of Decenleot 2023.
SMRUTIL viNUB PATEL
Notary ID #128779712 Notary Public; State of Texas
dy Commission Expires
October 21, 2027
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139132023 10:56 AM Dwight D. Sullivan County Clerk Galveston County, Texas PR-0084418 ESTATE OF § IN THE PROBATE COURT ROBERT EDWARD HAWKINS, § OF DECEASED § GALVESTON COUNTY, TEXAS APPLICANT, THOMAS J. HAWKINS, NOTICE OF INTENTION TO TAKE DEPOSITION ON WRITTEN QUESTIONS Pursuant to Rule 200 of the Texas Rules of Civil Procedure, please take notice that after (10) days from the service of a copy hereof with attached questions, a deposition by written questions will be taken of the following witness: MARGARET HAIRELL 4110 Alabama Ave Dickinson, Texas 77539 The deposition will be taken at the witness’ address as given above and will be taken before and by a Notary Public, an officer of the State of Louisiana, which deposition with attached questions may be used in evidence upon the trial of the above styled and numbered cause pending in the above- named court. Respectfully submitted, By: /S/ JamesS. Tittle JAMES S. TITTLE T.B.A. No. 00798193 107 Landing Blvd., Ste. F League City, Texas 77586 (281) 332-1400 Telephone (281) 332-8885 Facsimile Email: James@LeagueCityLaw.com Attomey for Applicant PR-0084418 ESTATE OF § IN THE PROBATE COURT ROBERT EDWARD HAWKINS, § OF DECEASED § GALVESTON COUNTY, TEXAS DEPOSITION UPON WRITTEN QUESTIONS OF THE WITNESS, MARGARET HAIRELL 1 Please state your name, address and telephone number for the record. ANSWER: MARGARET HAIRELL , 4110 Alabama Ave., Dickinson, Texas 77539 2 Please confirm if you are a resident of Galveston County, Texas and if you are unable to attend the court proceedings scheduled for this matter? ANSWER: I live in Dickinson, Texas. However, it would not be possible for me to personally appear at the proceedings due to work and personal obligations. 3 Please describe how you were acquainted with ROBERT EDWARD HAWKINS, Deceased. Please include a description of your relationship and the period of time such relationship existed. ANSWER: Lwasa personal sonal friend imiend ¢of ROBERT EDWARD HAWKINS for 8 years before witnessing his Will. [had a chance to speak with him. see his Identification, and confirm that he was of sound mind for the purpose of witnessing his Will. 4 Have you had an opportunity to review a copy of the written Last Will and Testament of ROBERT EDWARD HAWKINS dated October 4, 2023? A copy of the Will is attached hereto as Exhibit “A”. = ANSWER: Yes. I have had an opportunity to review the Will. 5 To the best of your knowledge, was ROBERT EDWARD HAWKINS, Decedent, of sound mind and over the age of 18 years old on October 4, 2023? ANSWER: Yes. To the best of my knowledge ROBERT EDWARD HAWKINS was of sound mind, was able to clearly communicate, and he was also over 18 years of age on October 4, 2023 6. Please describe if you are familiar with the handwriting and the signature of ROBERT EDWARD HAWKINS, Decedent? ANSWER: Yes. I am familiar with both the handwriting and signature of ROBERT EDWARD HAWKINS. I witnessed him sign this Will, and I recognize the signature on the October 4, 2023 Will to be that of ROBERT EDWARD HAWKINS. This is the same Will I witnessed him execute on October 4, 2023. 7. Please describe specifically how you became familiar with the handwriting and signature of ROBERT EDWARD HAWKINS, Decedent? ANSWER: Lam familiar with ROBERT EDWARD HAWKINS signature because I watched him sign his Will. 8 Do you believe that the document shown to you which purports to be the Last Will and Testament of ROBERT EDWARD HAWKINS, Decedent, is signed by ROBERT EDWARD HAWKINS? ANSWER: Yes. Based on my past experience with ROBERT EDWARD HAWKINS I recognize his handwriting and signature on the Will, and I believe that he signed the Will because I watched him sign it. 9 Do you believe ROBERT EDWARD HAWKINS executed the Will dated October 4, 2023 was done as the free act and deed of ROBERT EDWARD HAWKINS? ANSWER: Yes. I believe ROBERT EDWARD HAWKINS executed the Will of his own free will. No one forced him to sign anything. — = 10. Do you have any financial interest in the estate of ROBERT EDWARD HAWKINS, deceased? ANSWER: No.1 do not have any financial interest in the estate. Trangia 7 barnatl MARGARET HAIRELL I Saws! N Peste{ a Notary Public in and for the State of Texas, do hereby certify that the foregoing answers of the witness were by the said witness and were sworn and subscribed before me. th Given under my hand and seal of office on this [2 _day of Decenleot 2023. SMRUTIL viNUB PATEL Notary ID #128779712 Notary Public; State of Texas dy Commission Expires October 21, 2027