On July 29, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Ackin, Len,
Adjei, Ella,
Anderson, Preshas,
Belmorris, Joshua,
Berry, Ernest,
Boozer, Antwuan,
Bradix, Dorothy,
Brewer, Chautaugua,
Brown, Alvin,
Brown, Katrina,
Brown, Kenneth,
Brown, Lauren,
Bustillos, Orlando,
Carnell, Johnny,
Chester, Kjatha,
Cisse, Sekou,
Cisses, Sekou,
Crawford, September,
Crosley, Tyler,
Davis, Kimberly,
Diggs, Jake,
Duncan, Ronnie,
Elhadi, Jihad Abd,
Ferguson, Lily,
Fisher, Rudolph,
Fisher, Sheila,
Fonteno, Bobby, Ii,
Gaston, Lastesha,
Gates, Rondalus,
Green, Ashley,
Greene, Pamela,
Harris, Jaquan,
Harrison, Carol,
Harrison, Charles,
Harrison, Edward,
Harrison, Joyce M.,
Harrison, Latasha,
Harrison, Latoya,
Harrison, Sharon,
Henry, Donmonique,
Howard, Rafael,
Issah, Willie,
Jackson, Marcus,
Johnson, Robert,
Johnson, Trenton,
Jones, Brandon,
Jones, Cedric,
Jones, Cheryl,
Jones, Edward,
Jones, Toshi,
Jones, Valencia,
Kelley, Mildred,
Kelley, Raven,
Knight-Trigg, Tamara,
Lara, Ephraim,
Lard, Lazerick,
Lee, Jada,
Lee, Laquesha,
Lee, Mariah,
Lester, Ella,
Luckey, Angela,
Martinez, Jose,
Mccray, Cornelius,
Mcpherson, Aaron,
Mcqueen, Dominika,
Mims, Stacey,
Mitchell, Benjamin,
Montgomery, Jaqueisha,
Mosley, Phyllis,
Muoka, Margaret,
Nixon, Latoya,
Nzioka, Joseph,
Oldacre, Donald,
Oldacre, Glory,
Olivarez, Gloria,
Pena, Epifani,
Pipkins, Sherry,
Porter, Michelle,
Purifoy, Wakeisha,
Rodriguez, Amber,
Rodriguez, Jazun,
Ross, Edward,
Scott, Benjamin,
Scott, Hasani,
Shelby, Kenneth,
Smith, Jermaine,
Smith, Sabrina,
Stoker, Lester,
Swope, Janice,
Talley, Kelvin,
The Estate Of Cheryl Jones,
Tienda, Alexa,
Tittel, Michael,
Walker, Latasha,
Ware, Addonais,
Ware, Tara,
Ware, T'Ara,
Washington, Eartha,
Wells, Kristy,
West, Laquita,
White, Carolyn,
White, Darla,
Whitemon, Bobby,
Whitemon, Dorothy,
White, Quinton,
White, Sandra,
Williams, Calap, Iii,
Williams, Jackie, Jr,
Woodard, Vickie,
Young, Ariel,
Young, Pamela,
and
Brewer, Chautaugua,
Davis, Kimberly,
Mars Partners, Ltd,
Oncor Electric Delivery Company Llc,
Oncor Electric Delivery Company, Llc,
Poly-America Gp, Llc,
Poly America Inc,
Poly-America Inc,
Poly-America International Inc.,
Poly-America Lp,
for PROPERTY
in the District Court of Dallas County.
Preview
FILED
2/1/2024 4:01 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Brandon Keys DEPUTY
CAUSE NO. DC-22-08610
LEN ACKLIN, Individually, et al., § IN THE DISTRICT COURT
§
Plaintiffs, §
§
vs. §
§ 191st JUDICIAL DISTRICT
POLY-AMERICA INTERNATIONAL INC., §
POLY-AMERICA, INC., POLY-AMERICA GP, §
LLC, POLY-AMERICA LP, ONCOR §
ELECTRIC DELIVERY COMPANY, LLC; §
AND MARS PARTNERS, LTD, §
§ DALLAS COUNTY, TEXAS
Defendants.
DEFENDANTS’ JOINT MOTION TO COMPEL THE DEPOSITION
OF CYNTHIA CASTLEMAN, NP
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW, Poly-America International Inc, Poly-America GP, LLC, Poly-America LP,
and Mars Partners LTD, and Oncor Electric Delivery Company, LLC (“Defendants”) and make
and file their Joint Motion to Compel Deposition of Cynthia Castleman, NP. In support of same,
Defendants would respectfully show the Court as follows:
I.
Plaintiffs filed this action in July 2022 alleging various injuries resulting from a fire in
August 2020. Trial in this case is scheduled to begin on June 3, 2024, for the first trial group of
ten plaintiffs. Cynthia Castleman, NP examined, diagnosed, and treated trial Plaintiff Chautaqua
Brewer (“Brewer”). According to Brewer’s answers to interrogatories, she is alleging the fire
caused her problems with her lungs, her breathing, and her teeth. In an effort to comprehensively
understand Brewer's alleged issues with her lungs and teeth and to effectively mount their defense,
Defendants seek to depose the nurse practitioner.
DEFENDANTS’ JOINT MOTION TO COMPEL THE DEPOSITION OF CYNTHIA CASTLEMAN, NP - PAGE 1
Defendants noticed Cynthia Castleman, NP’s deposition for January 24, 2024. See Exhibit
A, Defendants Notice of Intention to Take Oral Deposition of Cynthia Castleman, NP and
Subpoena Duces Tecum. Plaintiffs quashed her deposition for the reason that Plaintiffs’ counsel
was not available for a deposition on that date. See Exhibit B, Plaintiff’s Motion to Quash Oral
Deposition of Cynthia Castleman, NP. Subsequently, counsel for Defendants reached out to
Plaintiffs' counsel to coordinate alternative dates and times for Cynthia Castleman, NP's
deposition. However, as evidenced in Exhibit C, the email correspondence between Defendants'
and Plaintiffs' counsel, specific deposition dates have not yet been provided by Plaintiffs' counsel.
With the impending June trial date, it is crucial for Defendants to promptly conduct
depositions of key witnesses. The delay in scheduling Cynthia Castleman, NP's deposition hinders
the progress of this legal proceeding, and Defendants urgently require the opportunity to depose
important witnesses without further delay.
WHEREFORE, PREMISES CONSIDERED, Defendants respectfully request that the
Court grant their Motion to Compel Depositions and for such other and further relief, at law and
in equity, to which Defendants may be justly entitled.
Respectfully Submitted,
DEHAY & ELLISTON, L.L.P.
By: /s/ Pamela J. Williams
GARY D. ELLISTON
Texas State Bar No. 06584700
PAMELA J. WILLIAMS
Texas State Bar No. 00791936
3500 Bank of America Plaza
901 Main Street Dallas, TX 75202-3736
Telephone: (214) 210-2400
Fax: (214) 210-2500
pwilliams@dehay.com
DEFENDANTS’ JOINT MOTION TO COMPEL THE DEPOSITION OF CYNTHIA CASTLEMAN, NP - PAGE 2
ATTORNEYS FOR DEFENDANTS’
POLY-AMERICA INTERNATIONAL
INC., POLY-AMERICA GP, LLC.,
POLYAMERICA LP, and MARS
PARTNERS, LTD
COBB MARTINEZ WOODWARD
PLLC
By: /s/ Lance C. Travis
Lance C. Travis
State Bar No. 00797568
Cobb Martinez Woodward PLLC
1700 Pacific Ave., Suite 3100
Dallas, TX 75201
214-220-5236 (phone)
214-220-5299 (fax)
ltravis@cobbmartinez.com
ATTORNEYS FOR DEFENDANT
ONCOR ELECTRIC DELIVERY
COMPANY LLC
CERTIFICATE OF CONFERENCE
Counsel for movant and counsel for respondent have personally conducted a conference at
which there was a substantive discussion of every item presented to the Court in this motion and
despite best efforts the counsel have not been able to resolve those matters presented.
Certified this 1st day of February, 2024.
/s/ Pamela J. Williams
Pamela J. Williams
CERTIFICATE OF SERVICE
The undersigned certifies that a true copy of the foregoing motion was served this day on
all other attorneys of record Via E-Service.
Dated: February 1, 2024.
/s/ Pamela J. Williams
Pamela J. Williams
DEFENDANTS’ JOINT MOTION TO COMPEL THE DEPOSITION OF CYNTHIA CASTLEMAN, NP - PAGE 3
EXHIBIT A
CAUSE NO. DC-22-08610
LEN ACKLIN, Individually, et al., § IN THE DISTRICT COURT
§
Plaintiffs, §
§
vs. §
§ 191st JUDICIAL DISTRICT
POLY-AMERICA INTERNATIONAL INC., §
POLY-AMERICA, INC., POLY-AMERICA GP, §
LLC, POLY-AMERICA LP, ONCOR §
ELECTRIC DELIVERY COMPANY, LLC; §
AND MARS PARTNERS, LTD, §
§ DALLAS COUNTY, TEXAS
Defendants.
POLY-AMERICA INTERNATIONAL INC, POLY-AMERICA GP, LLC, POLY-
AMERICA LP, AND MARS PARTNERS LTD.’S NOTICE OF INTENTION TO TAKE
ORAL DEPOSITION OF CYNTHIA CASTLEMAN AND SUBPOENA DUCES TECUM
PLEASE TAKE NOTICE that, pursuant to Texas Rule of Civil Procedure 199, Poly-
America International Inc., Poly-America GP, LLC, Poly-America LP and MARS Partners, Ltd.
will take the oral deposition of the following witness:
DEPONENT: Cynthia Castleman, NP
DATE: January 24, 2024
TIME: 1:00 p.m. (CDT)
LOCATION: Advanced Surgeons & Physicians Network
4200 Twelve Oaks Drive
Houston, Texas 77027
The witness is requested to appear and produce the documents set forth in Exhibit A
attached hereto. The deposition will continue from day to day thereafter until completed and will
be taken before a certified shorthand reporter from the offices of Pohlman USA Court Reporting and
Litigation Services, Phone: (817) 201-1622. Such deposition shall be taken to be used as evidence
in the above-styled and numbered cause.
POLY-AMERICA INTERNATIONAL INC, POLY-AMERICA GP, LLC, POLY-AMERICA LP, AND MARS PARTNERS LTD’S NOTICE
OF INTENTION TO TAKE THE ORAL VIDEOCONFERENCE DEPOSITION OF CYNTHIA CASTLEMAN AND SUBPOENA DUCES
TECUM – PAGE 1
Respectfully submitted,
DEHAY & ELLISTON, L.L.P.
3500 Bank of America Plaza
901 Main Street
Dallas, TX 75202-3736
Telephone: (214) 210-2400
Fax: (214) 210-2500
By: /s/ Pamela J. Williams
GARY D. ELLISTON
Texas State Bar No. 06584700
PAMELA J. WILLIAMS
Texas State Bar No. 00791936
gelliston@dehay.com
pwilliams@dehay.com
DEService@dehay.com
ATTORNEYS FOR DEFENDANTS
POLY AMERICA INTERNATIONAL INC.,
POLY-AMERICA GP, LLC, POLY-
AMERICA LP, and MARS PARTNERS,
LTD.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that, on January 17, 2024 a true and correct copy of the foregoing
instrument has been provided to all counsel of record via e-filing, in accordance with the Texas Rules
of Civil Procedure, to all counsel of record.
/s/ Pamela J. Williams
PAMELA J. WILLIAMS
POLY-AMERICA INTERNATIONAL INC, POLY-AMERICA GP, LLC, POLY-AMERICA LP, AND MARS PARTNERS LTD’S NOTICE
OF INTENTION TO TAKE THE ORAL VIDEOCONFERENCE DEPOSITION OF CYNTHIA CASTLEMAN AND SUBPOENA DUCES
TECUM – PAGE 2
EXHIBIT A
DEFINITIONS
1. “Plaintiffs” means Chautaqua Brewer and all agents, servants, employees, representatives,
and other persons acting on their behalf.
2. “Defendant” means Poly-America International Inc, Poly-America GP, LLC, Poly-
America LP, and MARS Partners Ltd., and all agents, servants, employees, representatives,
and other persons acting on his behalf.
3. The terms “you” and “your” mean Cynthia Castleman, NP and all agents, servants,
employees, representatives, and other persons acting on her behalf.
4. “Communication” means any oral or written means of communication, including, but not
limited to, face-to-face conversation, conversation by telephone, email, text, or other means
of communication, including by documents, as defined herein.
5. “Document” means any written material, whether typed, handwritten, printed or otherwise,
or any photographic, photostatic, microfilm or other reproduction thereof; any data stored
electronically and capable of being retrieved by computer or word processor and printed
therefrom; and any recording (film, tape, videotape or other mechanical or electronic
information). It includes, but is not limited to, notes, memoranda, letters, emails, telegrams,
circulars, releases, articles, reports, analysis, charts, account books, drafts, summaries,
diaries, transcripts, agreements, contracts, deposit slips, checks, bank statements, receipts,
stock certificates and/or statements.
DOCUMENTS TO PRODUCE
1. Your entire medical and billing file pertaining to Chautauqua Brewer, including, but not
limited to, all handwritten notes, records, reports, and all radiographic images, including
x-rays, films, CT scans, and MRIs.
2. All documents reviewed by you in preparation for your evaluation or treatment of
Chautauqua Brewer and/or in preparation for your deposition.
3. Your current curriculum vitae.
4. All communications or agreements with Plaintiff’s counsel, Chautauqua Brewer, or other
individuals regarding Plaintiff or Plaintiff’s lawsuit.
5. All documents regarding financial benefits received by you for your services regarding
Chautauqua Brewer, Plaintiff’s counsel, Plaintiff’s lawsuit, or testimony in Plaintiff’s
lawsuit.
6. A list of all publications you authored or contributed to, if not included in your curriculum
vitae.
POLY-AMERICA INTERNATIONAL INC, POLY-AMERICA GP, LLC, POLY-AMERICA LP, AND MARS PARTNERS LTD’S NOTICE
OF INTENTION TO TAKE THE ORAL VIDEOCONFERENCE DEPOSITION OF CYNTHIA CASTLEMAN AND SUBPOENA DUCES
TECUM – PAGE 3
7. All documents evidencing the number, styles, and jurisdictions of the cases in which you
have testified or rendered expert opinions.
8. A list of all depositions and trial testimony given by you.
9. Any and all writings authored by you that reflect any presentations given pertaining to the
subject matter of this lawsuit.
10. Any and all materials, writings, information, or other materials you have read, reviewed,
and/or used in any manner before this deposition pertaining to this lawsuit, including, but
not limited to, medical records, notes, memorandums, medical articles, depositions,
reports, affidavits, or treatises and any other matter involved in this lawsuit.
11. Copies of all authorities, including published literature in abstract and full form, you
reviewed or relied upon in connection with the medical care or treatment of Chautauqua
Brewer.
12. Any and all affidavits, affirmations, written statements (sworn or otherwise) signed or
executed by you relating to any civil or administrative proceeding related to the medical
care or treatment of Chautauqa Brewer.
POLY-AMERICA INTERNATIONAL INC, POLY-AMERICA GP, LLC, POLY-AMERICA LP, AND MARS PARTNERS LTD’S NOTICE
OF INTENTION TO TAKE THE ORAL VIDEOCONFERENCE DEPOSITION OF CYNTHIA CASTLEMAN AND SUBPOENA DUCES
TECUM – PAGE 4
FILED
1/17/2024 3:00 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Christi Underwood DEPUTY
CAUSE NO. DC-22-08610
LEN ACKLIN, Individually, et al., § IN THE DISTRICT COURT
§
Plaintiffs, §
§
vs. §
§ 191st JUDICIAL DISTRICT
POLY-AMERICA INTERNATIONAL INC., §
POLY-AMERICA, INC., POLY-AMERICA §
GP, LLC, POLY-AMERICA LP, ONCOR §
ELECTRIC DELIVERY COMPANY, LLC; §
AND MARS PARTNERS, LTD, §
§ DALLAS COUNTY, TEXAS
Defendants.
SUBPOENA
TO: Cynthia Castleman, NP
ISSUED IN THE NAME OF THE STATE OF TEXAS
YOU ARE COMMANDED to appear before a Certified Shorthand Reporter, Notary
Public, or other officer duly authorized to administer oaths, at the offices of Advanced Surgeons
& Physicians Network located at 4200 Twelve Oaks Drive, Houston, Texas 77027 on January 24,
2024 at 1:00 pm as stated in Poly-America International Inc, Poly-America GP, LLC, Poly-
America LP, And Mars Partners LTD’s Notice of Intention to Take Oral Deposition of Cynthia
Castleman and Subpoena Duces Tecum (the “Notice”), to give oral deposition as a witness in the
above-styled civil action and to attend from day to day until lawfully discharged, and to produce
responsive documents as requested herein.
HEREIN FAIL NOT, but of this writ make due return showing how you have executed
same.
Rule 176.8(a) states: Contempt. Failure by any person without adequate excuse to obey
a subpoena served upon that person may be deemed a contempt of the court from which the
subpoena is issued or a district court in the county in which the subpoena is served, and may be
punished by fine or confinement, or both.
ISSUED ON the 17th day of January 2024
SUBPOENA – PAGE 1
Respectfully submitted,
DEHAY &ELLISTON, L.L.P.
3500 Bank of America Plaza
901 Main Street
Dallas, TX 75202-3736
Telephone: (214) 210-2400
Fax: (214) 210-2500
By: /s/ Pamela J. Williams
GARY D. ELLISTON
Texas State Bar No. 06584700
PAMELA J. WILLIAMS
Texas State Bar No. 00791936
gelliston@dehay.com
pwilliams@dehay.com
DEService@dehay.com
ATTORNEYS FOR DEFENDANT
POLY-AMERICA INTERNATIONAL
INC., POLY-AMERICA GP, LLC., POLY-
AMERICA LP, and MARS PARTNERS,
LTD
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing document has been
forwarded to all known counsel of record via certified mail, return receipt requested, and/or via
first class mail, and/or via facsimile, and/or via hand delivery, and/or via e-file on this 17th day of
January 2024.
/s/ Pamela J. Williams
PAMELA J. WILLIAMS
SUBPOENA – PAGE 2
EXHIBIT A
DEFINITIONS
1. “Plaintiffs” means Chautaqua Brewer and all agents, servants, employees, representatives,
and other persons acting on their behalf.
2. “Defendant” means Poly-America International Inc, Poly-America GP, LLC, Poly-
America LP, and MARS Partners Ltd., and all agents, servants, employees, representatives,
and other persons acting on his behalf.
3. The terms “you” and “your” mean Cynthia Castleman, NP and all agents, servants,
employees, representatives, and other persons acting on her behalf.
4. “Communication” means any oral or written means of communication, including, but not
limited to, face-to-face conversation, conversation by telephone, email, text, or other means
of communication, including by documents, as defined herein.
5. “Document” means any written material, whether typed, handwritten, printed or otherwise,
or any photographic, photostatic, microfilm or other reproduction thereof; any data stored
electronically and capable of being retrieved by computer or word processor and printed
therefrom; and any recording (film, tape, videotape or other mechanical or electronic
information). It includes, but is not limited to, notes, memoranda, letters, emails, telegrams,
circulars, releases, articles, reports, analysis, charts, account books, drafts, summaries,
diaries, transcripts, agreements, contracts, deposit slips, checks, bank statements, receipts,
stock certificates and/or statements.
DOCUMENTS TO PRODUCE
1. Your entire medical and billing file pertaining to Chautauqua Brewer, including, but not
limited to, all handwritten notes, records, reports, and all radiographic images, including
x-rays, films, CT scans, and MRIs.
2. All documents reviewed by you in preparation for your evaluation or treatment of
Chautauqua Brewer and/or in preparation for your deposition.
3. Your current curriculum vitae.
4. All communications or agreements with Plaintiff’s counsel, Chautauqua Brewer, or other
individuals regarding Plaintiff or Plaintiff’s lawsuit.
5. All documents regarding financial benefits received by you for your services regarding
Chautauqua Brewer, Plaintiff’s counsel, Plaintiff’s lawsuit, or testimony in Plaintiff’s
lawsuit.
6. A list of all publications you authored or contributed to, if not included in your curriculum
vitae.
SUBPOENA – PAGE 3
7. All documents evidencing the number, styles, and jurisdictions of the cases in which you
have testified or rendered expert opinions.
8. A list of all depositions and trial testimony given by you.
9. Any and all writings authored by you that reflect any presentations given pertaining to the
subject matter of this lawsuit.
10. Any and all materials, writings, information, or other materials you have read, reviewed,
and/or used in any manner before this deposition pertaining to this lawsuit, including, but
not limited to, medical records, notes, memorandums, medical articles, depositions,
reports, affidavits, or treatises and any other matter involved in this lawsuit.
11. Copies of all authorities, including published literature in abstract and full form, you
reviewed or relied upon in connection with the medical care or treatment of Chautauqua
Brewer.
12. Any and all affidavits, affirmations, written statements (sworn or otherwise) signed or
executed by you relating to any civil or administrative proceeding related to the medical
care or treatment of Chautauqa Brewer.
SUBPOENA – 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.
LaKesha Burrus on behalf of Pamela Williams
Bar No. 791936
lburrus@dehay.com
Envelope ID: 83497169
Filing Code Description: Miscellanous Event
Filing Description: NOTICE-SUB C CASTLEMAN NP
Status as of 1/22/2024 5:00 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
John CStewart john.stewart@oncor.com 1/17/2024 3:00:31 PM SENT
Angie Ranton angela.ranton@oncor.com 1/17/2024 3:00:31 PM SENT
Pamela J.Williams pwilliams@dehay.com 1/17/2024 3:00:31 PM SENT
Cris Page cpage@dehay.com 1/17/2024 3:00:31 PM SENT
Diane Hallmark diane.hallmark@oncor.com 1/17/2024 3:00:31 PM SENT
Christine Harvey charvey@dehay.com 1/17/2024 3:00:31 PM SENT
Adam Bell AdamB@poly-america.com 1/17/2024 3:00:31 PM SENT
Madison Pyle mpyle@dehay.com 1/17/2024 3:00:31 PM SENT
Sherri Robinson sherri.robinsoncsr@gmail.com 1/17/2024 3:00:31 PM SENT
Ruark Mershon RuarkM@poly-america.com 1/17/2024 3:00:31 PM SENT
Alexis Quezada alexisq@poly-america.com 1/17/2024 3:00:31 PM SENT
Lance Travis LTravis@cobbmartinez.com 1/17/2024 3:00:31 PM SENT
Anacorina Andrade aandrade@cobbmartinez.com 1/17/2024 3:00:31 PM SENT
Landon Dutra ldutra@cobbmartinez.com 1/17/2024 3:00:31 PM SENT
Associated Case Party: LEN ACKIN
Name BarNumber Email TimestampSubmitted Status
Jennifer Kinder 787837 jkinder@justcallkinder.net 1/17/2024 3:00:31 PM SENT
ROCIO CASTRO RCASTRO@JUSTCALLKINDER.NET 1/17/2024 3:00:31 PM SENT
Damian Sullivent dsullivent@nesslerlaw.com 1/17/2024 3:00:31 PM SENT
FRED NESSLER fwn@nesslerlaw.com 1/17/2024 3:00:31 PM SENT
Griffin McMillin gmcmillin@justcallkinder.net 1/17/2024 3:00:31 PM SENT
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.
LaKesha Burrus on behalf of Pamela Williams
Bar No. 791936
lburrus@dehay.com
Envelope ID: 83497169
Filing Code Description: Miscellanous Event
Filing Description: NOTICE-SUB C CASTLEMAN NP
Status as of 1/22/2024 5:00 PM CST
Associated Case Party: POLY-AMERICA LP
Name BarNumber Email TimestampSubmitted Status
Christine Harvey deservice@dehay.com 1/17/2024 3:00:31 PM SENT
EXHIBIT B
CAUSE NO. DC-22-08610
LEN ACKLIN, INDIVIDUALLY, ET § IN THE DISTRICT COURT
AL.; §
PLAINTIFFS, §
§
v. § 191st JUDICIAL DISTRICT
§
POLY-AMERICA INTERNATIONAL §
INC.; POLY-AMERICA, INC; POLY- §
AMERICA GP, LLC; POLY-AMERICA §
LP; ONCOR ELECTRIC DELIVERY §
COMPANY, LLC; AND MARS §
PARTNERS, LTD; §
DEFENDANTS. § DALLAS COUNTY, TEXAS
PLAINTIFF’S MOTION TO QUASH ORAL DEPOSITION OF CYNTHIA
CASTLEMAN, NP
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Len Acklin, et al. (“Plaintiffs” or “Movant”), in the above-styled and
numbered cause, and files this Motion to Quash Oral and Videotaped Deposition, and in support
thereof, would respectfully show the Court the following:
I. INTRODUCTION AND BACKGROUND
On January 17, 2024, Plaintiffs’ counsel was served with a Notice of Deposition for
Cynthia Castleman, NP. Cynthia Castleman, NP’s deposition has been set for January 24, 2024,
at 1:00 p.m. Cynthia Castleman, NP’s deposition is set in-person at the offices of Advanced
Surgeons & Physicians Network located at 4200 Twelve Oaks Drive, Houston, Texas 77027. The
Notice for Deposition is herein and incorporated by reference as Exhibit “A”, and referred to in
this Motion as the “Notice”.
II. GENERAL OBJECTIONS
Movant requests that the Court quash the Notice of Intent to Take Oral and Videotaped
PLAINTIFF’S MOTION TO QUASH ORAL DEPOSITION OF CYNTHIA CASTLEMAN, NP
PAGE 1
Deposition of Cynthia Castleman, NP, for the reason that Defendants noticed the deposition
without Plaintiffs’ counsel’s agreement. Plaintiffs’ counsel is not available for a deposition on this
date. Defendants did not confer with Plaintiffs’ counsel about depositions times or ask when
Plaintiffs’ counsel is available for a deposition. Defendants unilaterally noticed the deposition of
Cynthia Castleman, NP without agreement of Plaintiffs’ counsel. Plaintiff’s counsel does not have
any more days in January available for a deposition, and Defendant’s counsel has indicated they
are only willing to reschedule the deposition for a time in January. Plaintiffs are also opposed to
taking the deposition of Cynthia Castleman, NP before the depositions of Plaintiffs and Defendants
have been taken.
This Motion is timely as it is filed within 3 business days after receiving the Notice, and as
such the deposition is automatically stayed as provided by the Texas Rule of Civil Procedure 199.4.
PRAYER
For these reasons, Movant requests that the Court quash Defendants POLY-AMERICA
INTERNATIONAL, INC., POLY-AMERICA GP, LLC, POLY-AMERICA L.P., and MARS
PARTNERS, LTD.’S Notice of Intent to Take the Oral Deposition of Cynthia Castleman, NP; and
grant any and all relief to Plaintiffs as they may be entitled to in equity or at law.
Respectfully submitted,
KINDER LAW PLLC
By:
JENNIFER ANNE KINDER
TEXAS BAR NO. 00787837
Email: jkinder@justcallkinder.net
GRIFFIN T. MCMILLIN
TEXAS BAR NO. 24131500
Email: gmcmillin@justcallkinder.net
3701 W. Northwest Highway
Building 3, Suite 304
Dallas, Texas 75220
Tel. (214) 812-9800
PLAINTIFF’S MOTION TO QUASH ORAL DEPOSITION OF CYNTHIA CASTLEMAN, NP
PAGE 2
Fax. (214) 484-2144
ATTORNEYS FOR PLAINTIFFS
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing document has been forwarded to all
known counsel of record pursuant to the Texas Rules of Civil Procedure on this 18th day of January
2024.
Griffin T. McMillin
DeHay & Elliston, L.L.P.
3500 Bank of America Plaza
901 Main Street
Dallas, TX 75202-3736
Telephone: (214) 210-2400
Fax: (214) 210-2500
GARY D. ELLISTON
Texas State Bar No. 6584700
PAMELA J. WILLIAMS
Texas State Bar No. 00791936
ATTORNEYS FOR DEFENDANTS
POLY-AMERICA INTERNATIONAL INC.,
POLY-AMERICA GP, LLC,
POLY-AMERICA LP, AND
MARS PARTNERS, LTD
COBB MARTINEZ WOODWARD PLLC
Lance C. Travis
State Bar No. 00797568
Cobb Martinez Woodward PLLC
1700 Pacific Ave., Suite 3100
Dallas, TX 75201
214-220-5236 (phone)
214-220-5299 (fax)
ltravis@cobbmartinez.com
John C. Stewart
State Bar No. 19211525
Daniel G. Altman
State Bar No. 00793255
777 Main, Suite 747
Fort Worth, Texas 76101
(817) 215-5885 (Telephone)
(817) 215-6360 (Facsimile)
John.stewart@oncor.com
PLAINTIFF’S MOTION TO QUASH ORAL DEPOSITION OF CYNTHIA CASTLEMAN, NP
PAGE 3
Attorneys for Defendant
Oncor Electric Delivery Company, LLC
CERTIFICATE OF CONFERENCE
Plaintiff’s Counsel reached out by email to Counsel for Defendant on the issues presented
on January 18, 2024, but was unable to come to an agreement.
______________
Jennifer Anne Kinder
PLAINTIFF’S MOTION TO QUASH ORAL DEPOSITION OF CYNTHIA CASTLEMAN, NP
PAGE 4
EXHIBIT C
PLAINTIFF’S MOTION TO QUASH ORAL DEPOSITION OF CYNTHIA CASTLEMAN, NP
PAGE 5
Williams, Pamela J.
From: Williams, Pamela J.
Sent: Thursday, February 1, 2024 11 :45 AM
To: Jennifer Kinder; Griffin McMillin; Lance Travis
Cc: Page, Cris
Subject: RE: Len Acklin - deposition Cynthia Castleman
Jennifer,
The rules do not allow Plaintiffs to dictate the order in which Defendants take depositions of persons with
knowledge of relevant facts and/or trial witnesses. If we want to depose Ms. Castleman first, that is our choice .
There is no compelling reason to depose the plaintiffs or defendants before taking the deposition of Ms. Castleman. We
will depose the plaintiffs once medical records are received. We will offer our client for deposition after plaintiffs are
deposed.
Pam
0-IAY
ELIJSlU'\l u .,
Regards,
Pamela J. Williams I DeHay & Elliston, LLP
3500 Bank of America Plaza
901 Main Street
Dallas, TX 75202
Phone:214-210-2400
Direct: 214-210-2449
Fax:214-210-2500
Email: pwilliams@ dehay.com
From: Jennifer Kinder
Sent: Tuesday, January 30, 2024 12:20 PM
To: Williams, Pamela J.; Griffin McMillin ; Lance Travis
Cc: Page, Cris
Subject: RE: Len Acklin - deposition Cynthia Castleman
WARNING: External Email -Think Before You Click
We are going to insist that the Plaintiff and Defendant depositions occur first. We have also requested the deposition of
your client. Please provide dates for these 11 depositions.
Jennifer Anne Kinder
1
Kinder Law PLLC
3701 W. Northwest Highway, Suite 304
Dallas, Texas 75220
Tel (214) 812-9800
Fax (214) 484-2144
www.justec1llkindcr.net
lnstagram @justcallkinder
TikTok @badbitchlaw
Twitter: @Justcallklnder
From: Williams, Pamela J.
Sent: Tuesday, January 30, 2024 11:13 AM
To: Jennifer Kinder ; Griffin McMillin ; Lance Travis
Cc: Page, Cris
Subject: Len Acklin - deposition Cynthia Castleman
Jennifer and Griffin,
Please provide dates in February for Cynthia Castleman's deposition. We would like to avoid a Motion to Compel.
Thanks,
Pam
Regards,
Pamela J. Williams I DeHay & Elliston, LLP
3500 Bank of America Plaza
901 Main Street
Dallas, TX 75202
Pl1ur1e: 214-210-2400
Direct: 214-210-2449
Fax: 214-210-2500
Email: pwilliams@dehay.com
_ _ _ _ _ __ __ _ _ _ _ _ _ _ _ _ CONFIDENTIALITY NOTICE - This e-mail is covered by the Electronic
Communications Privacy Act, 18 U.S.C. Secs 2510-2521, and is legally privileged. This message and any attached
documents contain information from the law firm of De Hay & Elliston, L.L.P. that may be privileged and confidential and
protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent
responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination,
distribution or copying of this communication is strictly prohibited. If you have received this communication in error,
please notify us immediately by replying to the message and deleting it from your computer. Thank you.
2
_ _ _ _ _ _ _ _ __ __ _ _ _ _ _ _ CONFIDENTIALITY NOTICE - This e-mail is covered by the Electronic
Communications Privacy Act, 18 U.S.C. Secs 2510-2521, and is legally privileged. This message and any attached
documents contain information from the law firm of DeHay & Elliston, L.L.P. that may be privileged and confidential and
protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent
responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination,
distribution or copying of this communication is strictly prohibited. If you have received this communication in error,
please notify us immediately by replying to the message and deleting it from your computer. Thank you.
3
Williams, Pamela J.
From: Williams, Pamela J.
Sent: Tuesday, June 27, 2023 10:23 AM
To: Jennifer Kinder; Griffin McMillin
Cc: Page, Cris; Lance Travis
Subject: ' Len Acklin - deposition of Amber Rodriguez
Jennifer and Griffin,
We would like to depose plaintiff Amber Rodriguez. We are also following up on the deposition request for Cynthia
Castleman. Can you please provide dates in August?
Thanks,
Pam
OEWSID~
IAY
Regards,
Pamela J. Williams I DeHay & Elliston, LLP
3500 Bank of America Plaza
901 Main Street
Dallas, TX 75202
Phone: 214-210-2400
Direct: 214-210-2449
Fax:214-210-2500
Email: pw1lliams@d ehay.com
1
Williams, Pamela J.
From: Lance Travis < LTravis@cobbmartinez.com>
Sent: Wednesday, March 22, 2023 11 :34 AM
To: Jennifer Kinder; Griffin McMillin
Cc: Williams, Pamela J.
Subject: Ackin, et al v. Poly-America, et al
WARNING: External Email -Think Before You Click
Jennifer and Griffin -
All Defendants would like to discuss entry of an Agreed Scheduling Order. With a current trial setting of June 3, 2024,
we would propose discovery expiration, Daubert motions, dispositive motions, and mediation deadlines 30 days before
trial. Plaintiffs' experts to be designated 90 days before trial, and Defendants' experts 60 days before trial. Deposition
designations, motions in limine, proposed jury charges, and exhibit lists 14 days before trial. Objections to those pretrial
materials and cross-designations of depos 7 days before trial. Is this agreeable? If so, we will memorialize in an Agreed
Order for filing.
Also, all Defendants would like to start scheduling in-person depositions. Defendants would like to start with Hasani
Scott, Sabrina Smith, Chautauqua Brewer, Robert Johnson, Lequesha Lee, and Cynthia Castleman, NP. Please provide
available dates at your earliest convenience.
CMW
Lance Travis
Cobb Martinez Woodward PLLC
1700 Pacific Avenue, Suite 3100
Dallas, Texas 75201
(214) 220-5236 direct
(214) 220-5299 fax
ltravis@cobbmartinez.com
www.cobbmartinez.com
CONFIDENTIALITY NOTICE: This communication, including any attachments, may contain confidential and/or privileged information.
It is not intended for transmission to, or receipt by, any unauthorized person. If you received this message in error, please do not
read it. Please reply to the sender that you received the message in error and delete the message and any attachments or copies.
The unauthorized use, disclosure, copying, or dissemination of the contents of this message or its attachments is strictly prohibited
and may be unlawful. Unintended transmission does not constitute waiver of the attorney-client privilege or any other privilege.
_ _ _ _ _ _ _ __ _ __ _ _ __ _ _ CONFIDENTIALITY NOTICE - This e-mail is covered by the Electronic
Communications Privacy Act, 18 U.S.C. Secs 2510-2521, and is legally privileged. This message and any attached
documents contain information from the law firm of DeHay & Elliston, L.L.P. that may be privileged and confidential and
protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent
responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination,
distribution or copying of this communication is strictly prohibited. If you have received this communication in error,
please notify us immediately by replying to the message and deleting it from your computer. Thank you.
2
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.
LaKesha Burrus on behalf of Pamela Williams
Bar No. 791936
lburrus@dehay.com
Envelope ID: 84059197
Filing Code Description: Motion - Compel
Filing Description: DEFENDANTS' JOINT MOTION TO COMPEL THE
DEPOSITION OF CYNTHIA CASTLEMAN
Status as of 2/5/2024 7:29 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
John CStewart john.stewart@oncor.com 2/1/2024 4:01:47 PM SENT
Angie Ranton angela.ranton@oncor.com 2/1/2024 4:01:47 PM SENT
Pamela J.Williams pwilliams@dehay.com 2/1/2024 4:01:47 PM SENT
Cris Page cpage@dehay.com 2/1/2024 4:01:47 PM SENT
Diane Hallmark diane.hallmark@oncor.com 2/1/2024 4:01:47 PM SENT
Christine Harvey charvey@dehay.com 2/1/2024 4:01:47 PM SENT
Adam Bell AdamB@poly-america.com 2/1/2024 4:01:47 PM SENT
Madison Pyle mpyle@dehay.com 2/1/2024 4:01:47 PM SENT
Sherri Robinson sherri.robinsoncsr@gmail.com 2/1/2024 4:01:47 PM SENT
Ruark Mershon RuarkM@poly-america.com 2/1/2024 4:01:47 PM SENT
Alexis Quezada alexisq@poly-america.com 2/1/2024 4:01:47 PM SENT
Lance Travis LTravis@cobbmartinez.com 2/1/2024 4:01:47 PM SENT
Anacorina Andrade aandrade@cobbmartinez.com 2/1/2024 4:01:47 PM SENT
Landon Dutra ldutra@cobbmartinez.com 2/1/2024 4:01:47 PM SENT
Associated Case Party: LEN ACKIN
Name BarNumber Email TimestampSubmitted Status
Jennifer Kinder 787837 jkinder@justcallkinder.net 2/1/2024 4:01:47 PM SENT
ROCIO CASTRO RCASTRO@JUSTCALLKINDER.NET 2/1/2024 4:01:47 PM SENT
Damian Sullivent dsullivent@nesslerlaw.com 2/1/2024 4:01:47 PM SENT
FRED NESSLER fwn@nesslerlaw.com 2/1/2024 4:01:47 PM SENT
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.
LaKesha Burrus on behalf of Pamela Williams
Bar No. 791936
lburrus@dehay.com
Envelope ID: 84059197
Filing Code Description: Motion - Compel
Filing Description: DEFENDANTS' JOINT MOTION TO COMPEL THE
DEPOSITION OF CYNTHIA CASTLEMAN
Status as of 2/5/2024 7:29 AM CST
Associated Case Party: LEN ACKIN
FRED NESSLER fwn@nesslerlaw.com 2/1/2024 4:01:47 PM SENT
Griffin McMillin gmcmillin@justcallkinder.net 2/1/2024 4:01:47 PM SENT
Associated Case Party: POLY-AMERICA LP
Name BarNumber Email TimestampSubmitted Status
Christine Harvey deservice@dehay.com 2/1/2024 4:01:47 PM SENT
Preview
FILED 2/1/2024 4:01 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Brandon Keys DEPUTY CAUSE NO. DC-22-08610 LEN ACKLIN, Individually, et al., § IN THE DISTRICT COURT § Plaintiffs, § § vs. § § 191st JUDICIAL DISTRICT POLY-AMERICA INTERNATIONAL INC., § POLY-AMERICA, INC., POLY-AMERICA GP, § LLC, POLY-AMERICA LP, ONCOR § ELECTRIC DELIVERY COMPANY, LLC; § AND MARS PARTNERS, LTD, § § DALLAS COUNTY, TEXAS Defendants. DEFENDANTS’ JOINT MOTION TO COMPEL THE DEPOSITION OF CYNTHIA CASTLEMAN, NP TO THE HONORABLE JUDGE OF SAID COURT: COME NOW, Poly-America International Inc, Poly-America GP, LLC, Poly-America LP, and Mars Partners LTD, and Oncor Electric Delivery Company, LLC (“Defendants”) and make and file their Joint Motion to Compel Deposition of Cynthia Castleman, NP. In support of same, Defendants would respectfully show the Court as follows: I. Plaintiffs filed this action in July 2022 alleging various injuries resulting from a fire in August 2020. Trial in this case is scheduled to begin on June 3, 2024, for the first trial group of ten plaintiffs. Cynthia Castleman, NP examined, diagnosed, and treated trial Plaintiff Chautaqua Brewer (“Brewer”). According to Brewer’s answers to interrogatories, she is alleging the fire caused her problems with her lungs, her breathing, and her teeth. In an effort to comprehensively understand Brewer's alleged issues with her lungs and teeth and to effectively mount their defense, Defendants seek to depose the nurse practitioner. DEFENDANTS’ JOINT MOTION TO COMPEL THE DEPOSITION OF CYNTHIA CASTLEMAN, NP - PAGE 1 Defendants noticed Cynthia Castleman, NP’s deposition for January 24, 2024. See Exhibit A, Defendants Notice of Intention to Take Oral Deposition of Cynthia Castleman, NP and Subpoena Duces Tecum. Plaintiffs quashed her deposition for the reason that Plaintiffs’ counsel was not available for a deposition on that date. See Exhibit B, Plaintiff’s Motion to Quash Oral Deposition of Cynthia Castleman, NP. Subsequently, counsel for Defendants reached out to Plaintiffs' counsel to coordinate alternative dates and times for Cynthia Castleman, NP's deposition. However, as evidenced in Exhibit C, the email correspondence between Defendants' and Plaintiffs' counsel, specific deposition dates have not yet been provided by Plaintiffs' counsel. With the impending June trial date, it is crucial for Defendants to promptly conduct depositions of key witnesses. The delay in scheduling Cynthia Castleman, NP's deposition hinders the progress of this legal proceeding, and Defendants urgently require the opportunity to depose important witnesses without further delay. WHEREFORE, PREMISES CONSIDERED, Defendants respectfully request that the Court grant their Motion to Compel Depositions and for such other and further relief, at law and in equity, to which Defendants may be justly entitled. Respectfully Submitted, DEHAY & ELLISTON, L.L.P. By: /s/ Pamela J. Williams GARY D. ELLISTON Texas State Bar No. 06584700 PAMELA J. WILLIAMS Texas State Bar No. 00791936 3500 Bank of America Plaza 901 Main Street Dallas, TX 75202-3736 Telephone: (214) 210-2400 Fax: (214) 210-2500 pwilliams@dehay.com DEFENDANTS’ JOINT MOTION TO COMPEL THE DEPOSITION OF CYNTHIA CASTLEMAN, NP - PAGE 2 ATTORNEYS FOR DEFENDANTS’ POLY-AMERICA INTERNATIONAL INC., POLY-AMERICA GP, LLC., POLYAMERICA LP, and MARS PARTNERS, LTD COBB MARTINEZ WOODWARD PLLC By: /s/ Lance C. Travis Lance C. Travis State Bar No. 00797568 Cobb Martinez Woodward PLLC 1700 Pacific Ave., Suite 3100 Dallas, TX 75201 214-220-5236 (phone) 214-220-5299 (fax) ltravis@cobbmartinez.com ATTORNEYS FOR DEFENDANT ONCOR ELECTRIC DELIVERY COMPANY LLC CERTIFICATE OF CONFERENCE Counsel for movant and counsel for respondent have personally conducted a conference at which there was a substantive discussion of every item presented to the Court in this motion and despite best efforts the counsel have not been able to resolve those matters presented. Certified this 1st day of February, 2024. /s/ Pamela J. Williams Pamela J. Williams CERTIFICATE OF SERVICE The undersigned certifies that a true copy of the foregoing motion was served this day on all other attorneys of record Via E-Service. Dated: February 1, 2024. /s/ Pamela J. Williams Pamela J. Williams DEFENDANTS’ JOINT MOTION TO COMPEL THE DEPOSITION OF CYNTHIA CASTLEMAN, NP - PAGE 3 EXHIBIT A CAUSE NO. DC-22-08610 LEN ACKLIN, Individually, et al., § IN THE DISTRICT COURT § Plaintiffs, § § vs. § § 191st JUDICIAL DISTRICT POLY-AMERICA INTERNATIONAL INC., § POLY-AMERICA, INC., POLY-AMERICA GP, § LLC, POLY-AMERICA LP, ONCOR § ELECTRIC DELIVERY COMPANY, LLC; § AND MARS PARTNERS, LTD, § § DALLAS COUNTY, TEXAS Defendants. POLY-AMERICA INTERNATIONAL INC, POLY-AMERICA GP, LLC, POLY- AMERICA LP, AND MARS PARTNERS LTD.’S NOTICE OF INTENTION TO TAKE ORAL DEPOSITION OF CYNTHIA CASTLEMAN AND SUBPOENA DUCES TECUM PLEASE TAKE NOTICE that, pursuant to Texas Rule of Civil Procedure 199, Poly- America International Inc., Poly-America GP, LLC, Poly-America LP and MARS Partners, Ltd. will take the oral deposition of the following witness: DEPONENT: Cynthia Castleman, NP DATE: January 24, 2024 TIME: 1:00 p.m. (CDT) LOCATION: Advanced Surgeons & Physicians Network 4200 Twelve Oaks Drive Houston, Texas 77027 The witness is requested to appear and produce the documents set forth in Exhibit A attached hereto. The deposition will continue from day to day thereafter until completed and will be taken before a certified shorthand reporter from the offices of Pohlman USA Court Reporting and Litigation Services, Phone: (817) 201-1622. Such deposition shall be taken to be used as evidence in the above-styled and numbered cause. POLY-AMERICA INTERNATIONAL INC, POLY-AMERICA GP, LLC, POLY-AMERICA LP, AND MARS PARTNERS LTD’S NOTICE OF INTENTION TO TAKE THE ORAL VIDEOCONFERENCE DEPOSITION OF CYNTHIA CASTLEMAN AND SUBPOENA DUCES TECUM – PAGE 1 Respectfully submitted, DEHAY & ELLISTON, L.L.P. 3500 Bank of America Plaza 901 Main Street Dallas, TX 75202-3736 Telephone: (214) 210-2400 Fax: (214) 210-2500 By: /s/ Pamela J. Williams GARY D. ELLISTON Texas State Bar No. 06584700 PAMELA J. WILLIAMS Texas State Bar No. 00791936 gelliston@dehay.com pwilliams@dehay.com DEService@dehay.com ATTORNEYS FOR DEFENDANTS POLY AMERICA INTERNATIONAL INC., POLY-AMERICA GP, LLC, POLY- AMERICA LP, and MARS PARTNERS, LTD. CERTIFICATE OF SERVICE I HEREBY CERTIFY that, on January 17, 2024 a true and correct copy of the foregoing instrument has been provided to all counsel of record via e-filing, in accordance with the Texas Rules of Civil Procedure, to all counsel of record. /s/ Pamela J. Williams PAMELA J. WILLIAMS POLY-AMERICA INTERNATIONAL INC, POLY-AMERICA GP, LLC, POLY-AMERICA LP, AND MARS PARTNERS LTD’S NOTICE OF INTENTION TO TAKE THE ORAL VIDEOCONFERENCE DEPOSITION OF CYNTHIA CASTLEMAN AND SUBPOENA DUCES TECUM – PAGE 2 EXHIBIT A DEFINITIONS 1. “Plaintiffs” means Chautaqua Brewer and all agents, servants, employees, representatives, and other persons acting on their behalf. 2. “Defendant” means Poly-America International Inc, Poly-America GP, LLC, Poly- America LP, and MARS Partners Ltd., and all agents, servants, employees, representatives, and other persons acting on his behalf. 3. The terms “you” and “your” mean Cynthia Castleman, NP and all agents, servants, employees, representatives, and other persons acting on her behalf. 4. “Communication” means any oral or written means of communication, including, but not limited to, face-to-face conversation, conversation by telephone, email, text, or other means of communication, including by documents, as defined herein. 5. “Document” means any written material, whether typed, handwritten, printed or otherwise, or any photographic, photostatic, microfilm or other reproduction thereof; any data stored electronically and capable of being retrieved by computer or word processor and printed therefrom; and any recording (film, tape, videotape or other mechanical or electronic information). It includes, but is not limited to, notes, memoranda, letters, emails, telegrams, circulars, releases, articles, reports, analysis, charts, account books, drafts, summaries, diaries, transcripts, agreements, contracts, deposit slips, checks, bank statements, receipts, stock certificates and/or statements. DOCUMENTS TO PRODUCE 1. Your entire medical and billing file pertaining to Chautauqua Brewer, including, but not limited to, all handwritten notes, records, reports, and all radiographic images, including x-rays, films, CT scans, and MRIs. 2. All documents reviewed by you in preparation for your evaluation or treatment of Chautauqua Brewer and/or in preparation for your deposition. 3. Your current curriculum vitae. 4. All communications or agreements with Plaintiff’s counsel, Chautauqua Brewer, or other individuals regarding Plaintiff or Plaintiff’s lawsuit. 5. All documents regarding financial benefits received by you for your services regarding Chautauqua Brewer, Plaintiff’s counsel, Plaintiff’s lawsuit, or testimony in Plaintiff’s lawsuit. 6. A list of all publications you authored or contributed to, if not included in your curriculum vitae. POLY-AMERICA INTERNATIONAL INC, POLY-AMERICA GP, LLC, POLY-AMERICA LP, AND MARS PARTNERS LTD’S NOTICE OF INTENTION TO TAKE THE ORAL VIDEOCONFERENCE DEPOSITION OF CYNTHIA CASTLEMAN AND SUBPOENA DUCES TECUM – PAGE 3 7. All documents evidencing the number, styles, and jurisdictions of the cases in which you have testified or rendered expert opinions. 8. A list of all depositions and trial testimony given by you. 9. Any and all writings authored by you that reflect any presentations given pertaining to the subject matter of this lawsuit. 10. Any and all materials, writings, information, or other materials you have read, reviewed, and/or used in any manner before this deposition pertaining to this lawsuit, including, but not limited to, medical records, notes, memorandums, medical articles, depositions, reports, affidavits, or treatises and any other matter involved in this lawsuit. 11. Copies of all authorities, including published literature in abstract and full form, you reviewed or relied upon in connection with the medical care or treatment of Chautauqua Brewer. 12. Any and all affidavits, affirmations, written statements (sworn or otherwise) signed or executed by you relating to any civil or administrative proceeding related to the medical care or treatment of Chautauqa Brewer. POLY-AMERICA INTERNATIONAL INC, POLY-AMERICA GP, LLC, POLY-AMERICA LP, AND MARS PARTNERS LTD’S NOTICE OF INTENTION TO TAKE THE ORAL VIDEOCONFERENCE DEPOSITION OF CYNTHIA CASTLEMAN AND SUBPOENA DUCES TECUM – PAGE 4 FILED 1/17/2024 3:00 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Christi Underwood DEPUTY CAUSE NO. DC-22-08610 LEN ACKLIN, Individually, et al., § IN THE DISTRICT COURT § Plaintiffs, § § vs. § § 191st JUDICIAL DISTRICT POLY-AMERICA INTERNATIONAL INC., § POLY-AMERICA, INC., POLY-AMERICA § GP, LLC, POLY-AMERICA LP, ONCOR § ELECTRIC DELIVERY COMPANY, LLC; § AND MARS PARTNERS, LTD, § § DALLAS COUNTY, TEXAS Defendants. SUBPOENA TO: Cynthia Castleman, NP ISSUED IN THE NAME OF THE STATE OF TEXAS YOU ARE COMMANDED to appear before a Certified Shorthand Reporter, Notary Public, or other officer duly authorized to administer oaths, at the offices of Advanced Surgeons & Physicians Network located at 4200 Twelve Oaks Drive, Houston, Texas 77027 on January 24, 2024 at 1:00 pm as stated in Poly-America International Inc, Poly-America GP, LLC, Poly- America LP, And Mars Partners LTD’s Notice of Intention to Take Oral Deposition of Cynthia Castleman and Subpoena Duces Tecum (the “Notice”), to give oral deposition as a witness in the above-styled civil action and to attend from day to day until lawfully discharged, and to produce responsive documents as requested herein. HEREIN FAIL NOT, but of this writ make due return showing how you have executed same. Rule 176.8(a) states: Contempt. Failure by any person without adequate excuse to obey a subpoena served upon that person may be deemed a contempt of the court from which the subpoena is issued or a district court in the county in which the subpoena is served, and may be punished by fine or confinement, or both. ISSUED ON the 17th day of January 2024 SUBPOENA – PAGE 1 Respectfully submitted, DEHAY &ELLISTON, L.L.P. 3500 Bank of America Plaza 901 Main Street Dallas, TX 75202-3736 Telephone: (214) 210-2400 Fax: (214) 210-2500 By: /s/ Pamela J. Williams GARY D. ELLISTON Texas State Bar No. 06584700 PAMELA J. WILLIAMS Texas State Bar No. 00791936 gelliston@dehay.com pwilliams@dehay.com DEService@dehay.com ATTORNEYS FOR DEFENDANT POLY-AMERICA INTERNATIONAL INC., POLY-AMERICA GP, LLC., POLY- AMERICA LP, and MARS PARTNERS, LTD CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing document has been forwarded to all known counsel of record via certified mail, return receipt requested, and/or via first class mail, and/or via facsimile, and/or via hand delivery, and/or via e-file on this 17th day of January 2024. /s/ Pamela J. Williams PAMELA J. WILLIAMS SUBPOENA – PAGE 2 EXHIBIT A DEFINITIONS 1. “Plaintiffs” means Chautaqua Brewer and all agents, servants, employees, representatives, and other persons acting on their behalf. 2. “Defendant” means Poly-America International Inc, Poly-America GP, LLC, Poly- America LP, and MARS Partners Ltd., and all agents, servants, employees, representatives, and other persons acting on his behalf. 3. The terms “you” and “your” mean Cynthia Castleman, NP and all agents, servants, employees, representatives, and other persons acting on her behalf. 4. “Communication” means any oral or written means of communication, including, but not limited to, face-to-face conversation, conversation by telephone, email, text, or other means of communication, including by documents, as defined herein. 5. “Document” means any written material, whether typed, handwritten, printed or otherwise, or any photographic, photostatic, microfilm or other reproduction thereof; any data stored electronically and capable of being retrieved by computer or word processor and printed therefrom; and any recording (film, tape, videotape or other mechanical or electronic information). It includes, but is not limited to, notes, memoranda, letters, emails, telegrams, circulars, releases, articles, reports, analysis, charts, account books, drafts, summaries, diaries, transcripts, agreements, contracts, deposit slips, checks, bank statements, receipts, stock certificates and/or statements. DOCUMENTS TO PRODUCE 1. Your entire medical and billing file pertaining to Chautauqua Brewer, including, but not limited to, all handwritten notes, records, reports, and all radiographic images, including x-rays, films, CT scans, and MRIs. 2. All documents reviewed by you in preparation for your evaluation or treatment of Chautauqua Brewer and/or in preparation for your deposition. 3. Your current curriculum vitae. 4. All communications or agreements with Plaintiff’s counsel, Chautauqua Brewer, or other individuals regarding Plaintiff or Plaintiff’s lawsuit. 5. All documents regarding financial benefits received by you for your services regarding Chautauqua Brewer, Plaintiff’s counsel, Plaintiff’s lawsuit, or testimony in Plaintiff’s lawsuit. 6. A list of all publications you authored or contributed to, if not included in your curriculum vitae. SUBPOENA – PAGE 3 7. All documents evidencing the number, styles, and jurisdictions of the cases in which you have testified or rendered expert opinions. 8. A list of all depositions and trial testimony given by you. 9. Any and all writings authored by you that reflect any presentations given pertaining to the subject matter of this lawsuit. 10. Any and all materials, writings, information, or other materials you have read, reviewed, and/or used in any manner before this deposition pertaining to this lawsuit, including, but not limited to, medical records, notes, memorandums, medical articles, depositions, reports, affidavits, or treatises and any other matter involved in this lawsuit. 11. Copies of all authorities, including published literature in abstract and full form, you reviewed or relied upon in connection with the medical care or treatment of Chautauqua Brewer. 12. Any and all affidavits, affirmations, written statements (sworn or otherwise) signed or executed by you relating to any civil or administrative proceeding related to the medical care or treatment of Chautauqa Brewer. SUBPOENA – 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. LaKesha Burrus on behalf of Pamela Williams Bar No. 791936 lburrus@dehay.com Envelope ID: 83497169 Filing Code Description: Miscellanous Event Filing Description: NOTICE-SUB C CASTLEMAN NP Status as of 1/22/2024 5:00 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status John CStewart john.stewart@oncor.com 1/17/2024 3:00:31 PM SENT Angie Ranton angela.ranton@oncor.com 1/17/2024 3:00:31 PM SENT Pamela J.Williams pwilliams@dehay.com 1/17/2024 3:00:31 PM SENT Cris Page cpage@dehay.com 1/17/2024 3:00:31 PM SENT Diane Hallmark diane.hallmark@oncor.com 1/17/2024 3:00:31 PM SENT Christine Harvey charvey@dehay.com 1/17/2024 3:00:31 PM SENT Adam Bell AdamB@poly-america.com 1/17/2024 3:00:31 PM SENT Madison Pyle mpyle@dehay.com 1/17/2024 3:00:31 PM SENT Sherri Robinson sherri.robinsoncsr@gmail.com 1/17/2024 3:00:31 PM SENT Ruark Mershon RuarkM@poly-america.com 1/17/2024 3:00:31 PM SENT Alexis Quezada alexisq@poly-america.com 1/17/2024 3:00:31 PM SENT Lance Travis LTravis@cobbmartinez.com 1/17/2024 3:00:31 PM SENT Anacorina Andrade aandrade@cobbmartinez.com 1/17/2024 3:00:31 PM SENT Landon Dutra ldutra@cobbmartinez.com 1/17/2024 3:00:31 PM SENT Associated Case Party: LEN ACKIN Name BarNumber Email TimestampSubmitted Status Jennifer Kinder 787837 jkinder@justcallkinder.net 1/17/2024 3:00:31 PM SENT ROCIO CASTRO RCASTRO@JUSTCALLKINDER.NET 1/17/2024 3:00:31 PM SENT Damian Sullivent dsullivent@nesslerlaw.com 1/17/2024 3:00:31 PM SENT FRED NESSLER fwn@nesslerlaw.com 1/17/2024 3:00:31 PM SENT Griffin McMillin gmcmillin@justcallkinder.net 1/17/2024 3:00:31 PM SENT 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. LaKesha Burrus on behalf of Pamela Williams Bar No. 791936 lburrus@dehay.com Envelope ID: 83497169 Filing Code Description: Miscellanous Event Filing Description: NOTICE-SUB C CASTLEMAN NP Status as of 1/22/2024 5:00 PM CST Associated Case Party: POLY-AMERICA LP Name BarNumber Email TimestampSubmitted Status Christine Harvey deservice@dehay.com 1/17/2024 3:00:31 PM SENT EXHIBIT B CAUSE NO. DC-22-08610 LEN ACKLIN, INDIVIDUALLY, ET § IN THE DISTRICT COURT AL.; § PLAINTIFFS, § § v. § 191st JUDICIAL DISTRICT § POLY-AMERICA INTERNATIONAL § INC.; POLY-AMERICA, INC; POLY- § AMERICA GP, LLC; POLY-AMERICA § LP; ONCOR ELECTRIC DELIVERY § COMPANY, LLC; AND MARS § PARTNERS, LTD; § DEFENDANTS. § DALLAS COUNTY, TEXAS PLAINTIFF’S MOTION TO QUASH ORAL DEPOSITION OF CYNTHIA CASTLEMAN, NP TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Len Acklin, et al. (“Plaintiffs” or “Movant”), in the above-styled and numbered cause, and files this Motion to Quash Oral and Videotaped Deposition, and in support thereof, would respectfully show the Court the following: I. INTRODUCTION AND BACKGROUND On January 17, 2024, Plaintiffs’ counsel was served with a Notice of Deposition for Cynthia Castleman, NP. Cynthia Castleman, NP’s deposition has been set for January 24, 2024, at 1:00 p.m. Cynthia Castleman, NP’s deposition is set in-person at the offices of Advanced Surgeons & Physicians Network located at 4200 Twelve Oaks Drive, Houston, Texas 77027. The Notice for Deposition is herein and incorporated by reference as Exhibit “A”, and referred to in this Motion as the “Notice”. II. GENERAL OBJECTIONS Movant requests that the Court quash the Notice of Intent to Take Oral and Videotaped PLAINTIFF’S MOTION TO QUASH ORAL DEPOSITION OF CYNTHIA CASTLEMAN, NP PAGE 1 Deposition of Cynthia Castleman, NP, for the reason that Defendants noticed the deposition without Plaintiffs’ counsel’s agreement. Plaintiffs’ counsel is not available for a deposition on this date. Defendants did not confer with Plaintiffs’ counsel about depositions times or ask when Plaintiffs’ counsel is available for a deposition. Defendants unilaterally noticed the deposition of Cynthia Castleman, NP without agreement of Plaintiffs’ counsel. Plaintiff’s counsel does not have any more days in January available for a deposition, and Defendant’s counsel has indicated they are only willing to reschedule the deposition for a time in January. Plaintiffs are also opposed to taking the deposition of Cynthia Castleman, NP before the depositions of Plaintiffs and Defendants have been taken. This Motion is timely as it is filed within 3 business days after receiving the Notice, and as such the deposition is automatically stayed as provided by the Texas Rule of Civil Procedure 199.4. PRAYER For these reasons, Movant requests that the Court quash Defendants POLY-AMERICA INTERNATIONAL, INC., POLY-AMERICA GP, LLC, POLY-AMERICA L.P., and MARS PARTNERS, LTD.’S Notice of Intent to Take the Oral Deposition of Cynthia Castleman, NP; and grant any and all relief to Plaintiffs as they may be entitled to in equity or at law. Respectfully submitted, KINDER LAW PLLC By: JENNIFER ANNE KINDER TEXAS BAR NO. 00787837 Email: jkinder@justcallkinder.net GRIFFIN T. MCMILLIN TEXAS BAR NO. 24131500 Email: gmcmillin@justcallkinder.net 3701 W. Northwest Highway Building 3, Suite 304 Dallas, Texas 75220 Tel. (214) 812-9800 PLAINTIFF’S MOTION TO QUASH ORAL DEPOSITION OF CYNTHIA CASTLEMAN, NP PAGE 2 Fax. (214) 484-2144 ATTORNEYS FOR PLAINTIFFS CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing document has been forwarded to all known counsel of record pursuant to the Texas Rules of Civil Procedure on this 18th day of January 2024. Griffin T. McMillin DeHay & Elliston, L.L.P. 3500 Bank of America Plaza 901 Main Street Dallas, TX 75202-3736 Telephone: (214) 210-2400 Fax: (214) 210-2500 GARY D. ELLISTON Texas State Bar No. 6584700 PAMELA J. WILLIAMS Texas State Bar No. 00791936 ATTORNEYS FOR DEFENDANTS POLY-AMERICA INTERNATIONAL INC., POLY-AMERICA GP, LLC, POLY-AMERICA LP, AND MARS PARTNERS, LTD COBB MARTINEZ WOODWARD PLLC Lance C. Travis State Bar No. 00797568 Cobb Martinez Woodward PLLC 1700 Pacific Ave., Suite 3100 Dallas, TX 75201 214-220-5236 (phone) 214-220-5299 (fax) ltravis@cobbmartinez.com John C. Stewart State Bar No. 19211525 Daniel G. Altman State Bar No. 00793255 777 Main, Suite 747 Fort Worth, Texas 76101 (817) 215-5885 (Telephone) (817) 215-6360 (Facsimile) John.stewart@oncor.com PLAINTIFF’S MOTION TO QUASH ORAL DEPOSITION OF CYNTHIA CASTLEMAN, NP PAGE 3 Attorneys for Defendant Oncor Electric Delivery Company, LLC CERTIFICATE OF CONFERENCE Plaintiff’s Counsel reached out by email to Counsel for Defendant on the issues presented on January 18, 2024, but was unable to come to an agreement. ______________ Jennifer Anne Kinder PLAINTIFF’S MOTION TO QUASH ORAL DEPOSITION OF CYNTHIA CASTLEMAN, NP PAGE 4 EXHIBIT C PLAINTIFF’S MOTION TO QUASH ORAL DEPOSITION OF CYNTHIA CASTLEMAN, NP PAGE 5 Williams, Pamela J. From: Williams, Pamela J. Sent: Thursday, February 1, 2024 11 :45 AM To: Jennifer Kinder; Griffin McMillin; Lance Travis Cc: Page, Cris Subject: RE: Len Acklin - deposition Cynthia Castleman Jennifer, The rules do not allow Plaintiffs to dictate the order in which Defendants take depositions of persons with knowledge of relevant facts and/or trial witnesses. If we want to depose Ms. Castleman first, that is our choice . There is no compelling reason to depose the plaintiffs or defendants before taking the deposition of Ms. Castleman. We will depose the plaintiffs once medical records are received. We will offer our client for deposition after plaintiffs are deposed. Pam 0-IAY ELIJSlU'\l u ., Regards, Pamela J. Williams I DeHay & Elliston, LLP 3500 Bank of America Plaza 901 Main Street Dallas, TX 75202 Phone:214-210-2400 Direct: 214-210-2449 Fax:214-210-2500 Email: pwilliams@ dehay.com From: Jennifer Kinder Sent: Tuesday, January 30, 2024 12:20 PM To: Williams, Pamela J.; Griffin McMillin ; Lance Travis Cc: Page, Cris Subject: RE: Len Acklin - deposition Cynthia Castleman WARNING: External Email -Think Before You Click We are going to insist that the Plaintiff and Defendant depositions occur first. We have also requested the deposition of your client. Please provide dates for these 11 depositions. Jennifer Anne Kinder 1 Kinder Law PLLC 3701 W. Northwest Highway, Suite 304 Dallas, Texas 75220 Tel (214) 812-9800 Fax (214) 484-2144 www.justec1llkindcr.net lnstagram @justcallkinder TikTok @badbitchlaw Twitter: @Justcallklnder From: Williams, Pamela J. Sent: Tuesday, January 30, 2024 11:13 AM To: Jennifer Kinder ; Griffin McMillin ; Lance Travis Cc: Page, Cris Subject: Len Acklin - deposition Cynthia Castleman Jennifer and Griffin, Please provide dates in February for Cynthia Castleman's deposition. We would like to avoid a Motion to Compel. Thanks, Pam Regards, Pamela J. Williams I DeHay & Elliston, LLP 3500 Bank of America Plaza 901 Main Street Dallas, TX 75202 Pl1ur1e: 214-210-2400 Direct: 214-210-2449 Fax: 214-210-2500 Email: pwilliams@dehay.com _ _ _ _ _ __ __ _ _ _ _ _ _ _ _ _ CONFIDENTIALITY NOTICE - This e-mail is covered by the Electronic Communications Privacy Act, 18 U.S.C. Secs 2510-2521, and is legally privileged. This message and any attached documents contain information from the law firm of De Hay & Elliston, L.L.P. that may be privileged and confidential and protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by replying to the message and deleting it from your computer. Thank you. 2 _ _ _ _ _ _ _ _ __ __ _ _ _ _ _ _ CONFIDENTIALITY NOTICE - This e-mail is covered by the Electronic Communications Privacy Act, 18 U.S.C. Secs 2510-2521, and is legally privileged. This message and any attached documents contain information from the law firm of DeHay & Elliston, L.L.P. that may be privileged and confidential and protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by replying to the message and deleting it from your computer. Thank you. 3 Williams, Pamela J. From: Williams, Pamela J. Sent: Tuesday, June 27, 2023 10:23 AM To: Jennifer Kinder; Griffin McMillin Cc: Page, Cris; Lance Travis Subject: ' Len Acklin - deposition of Amber Rodriguez Jennifer and Griffin, We would like to depose plaintiff Amber Rodriguez. We are also following up on the deposition request for Cynthia Castleman. Can you please provide dates in August? Thanks, Pam OEWSID~ IAY Regards, Pamela J. Williams I DeHay & Elliston, LLP 3500 Bank of America Plaza 901 Main Street Dallas, TX 75202 Phone: 214-210-2400 Direct: 214-210-2449 Fax:214-210-2500 Email: pw1lliams@d ehay.com 1 Williams, Pamela J. From: Lance Travis < LTravis@cobbmartinez.com> Sent: Wednesday, March 22, 2023 11 :34 AM To: Jennifer Kinder; Griffin McMillin Cc: Williams, Pamela J. Subject: Ackin, et al v. Poly-America, et al WARNING: External Email -Think Before You Click Jennifer and Griffin - All Defendants would like to discuss entry of an Agreed Scheduling Order. With a current trial setting of June 3, 2024, we would propose discovery expiration, Daubert motions, dispositive motions, and mediation deadlines 30 days before trial. Plaintiffs' experts to be designated 90 days before trial, and Defendants' experts 60 days before trial. Deposition designations, motions in limine, proposed jury charges, and exhibit lists 14 days before trial. Objections to those pretrial materials and cross-designations of depos 7 days before trial. Is this agreeable? If so, we will memorialize in an Agreed Order for filing. Also, all Defendants would like to start scheduling in-person depositions. Defendants would like to start with Hasani Scott, Sabrina Smith, Chautauqua Brewer, Robert Johnson, Lequesha Lee, and Cynthia Castleman, NP. Please provide available dates at your earliest convenience. CMW Lance Travis Cobb Martinez Woodward PLLC 1700 Pacific Avenue, Suite 3100 Dallas, Texas 75201 (214) 220-5236 direct (214) 220-5299 fax ltravis@cobbmartinez.com www.cobbmartinez.com CONFIDENTIALITY NOTICE: This communication, including any attachments, may contain confidential and/or privileged information. It is not intended for transmission to, or receipt by, any unauthorized person. If you received this message in error, please do not read it. Please reply to the sender that you received the message in error and delete the message and any attachments or copies. The unauthorized use, disclosure, copying, or dissemination of the contents of this message or its attachments is strictly prohibited and may be unlawful. Unintended transmission does not constitute waiver of the attorney-client privilege or any other privilege. _ _ _ _ _ _ _ __ _ __ _ _ __ _ _ CONFIDENTIALITY NOTICE - This e-mail is covered by the Electronic Communications Privacy Act, 18 U.S.C. Secs 2510-2521, and is legally privileged. This message and any attached documents contain information from the law firm of DeHay & Elliston, L.L.P. that may be privileged and confidential and protected from disclosure. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by replying to the message and deleting it from your computer. Thank you. 2 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. LaKesha Burrus on behalf of Pamela Williams Bar No. 791936 lburrus@dehay.com Envelope ID: 84059197 Filing Code Description: Motion - Compel Filing Description: DEFENDANTS' JOINT MOTION TO COMPEL THE DEPOSITION OF CYNTHIA CASTLEMAN Status as of 2/5/2024 7:29 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status John CStewart john.stewart@oncor.com 2/1/2024 4:01:47 PM SENT Angie Ranton angela.ranton@oncor.com 2/1/2024 4:01:47 PM SENT Pamela J.Williams pwilliams@dehay.com 2/1/2024 4:01:47 PM SENT Cris Page cpage@dehay.com 2/1/2024 4:01:47 PM SENT Diane Hallmark diane.hallmark@oncor.com 2/1/2024 4:01:47 PM SENT Christine Harvey charvey@dehay.com 2/1/2024 4:01:47 PM SENT Adam Bell AdamB@poly-america.com 2/1/2024 4:01:47 PM SENT Madison Pyle mpyle@dehay.com 2/1/2024 4:01:47 PM SENT Sherri Robinson sherri.robinsoncsr@gmail.com 2/1/2024 4:01:47 PM SENT Ruark Mershon RuarkM@poly-america.com 2/1/2024 4:01:47 PM SENT Alexis Quezada alexisq@poly-america.com 2/1/2024 4:01:47 PM SENT Lance Travis LTravis@cobbmartinez.com 2/1/2024 4:01:47 PM SENT Anacorina Andrade aandrade@cobbmartinez.com 2/1/2024 4:01:47 PM SENT Landon Dutra ldutra@cobbmartinez.com 2/1/2024 4:01:47 PM SENT Associated Case Party: LEN ACKIN Name BarNumber Email TimestampSubmitted Status Jennifer Kinder 787837 jkinder@justcallkinder.net 2/1/2024 4:01:47 PM SENT ROCIO CASTRO RCASTRO@JUSTCALLKINDER.NET 2/1/2024 4:01:47 PM SENT Damian Sullivent dsullivent@nesslerlaw.com 2/1/2024 4:01:47 PM SENT FRED NESSLER fwn@nesslerlaw.com 2/1/2024 4:01:47 PM SENT 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. LaKesha Burrus on behalf of Pamela Williams Bar No. 791936 lburrus@dehay.com Envelope ID: 84059197 Filing Code Description: Motion - Compel Filing Description: DEFENDANTS' JOINT MOTION TO COMPEL THE DEPOSITION OF CYNTHIA CASTLEMAN Status as of 2/5/2024 7:29 AM CST Associated Case Party: LEN ACKIN FRED NESSLER fwn@nesslerlaw.com 2/1/2024 4:01:47 PM SENT Griffin McMillin gmcmillin@justcallkinder.net 2/1/2024 4:01:47 PM SENT Associated Case Party: POLY-AMERICA LP Name BarNumber Email TimestampSubmitted Status Christine Harvey deservice@dehay.com 2/1/2024 4:01:47 PM SENT