Preview
Electronically Filed
12/27/2023 10:59 AM
Hidalgo County District Clerks
Reviewed By: Valerie Garza
398th District Court of HIDALGO County, Texas
100 N . CLOSNER , 2ND FLOOR EDINBURG TX 78539
CASE #: C- 4368-23-H
JULIAN TORRES III AND , ANDREA TORRES
Plaintiff
vs
GENERAL MOTORS LLC
Defendant
AFFIDAVIT OF SERVICE
I, LINDELL CHARLES , make statement to the fact;
That I am a competent person more than 18 years of age or older and not a party to
this action, nor interested in outcome of the suit. That I received the documents
stated below on 12/08/23 10:04 pm, instructing for same to be delivered upon BAYWAY
CADILLAC C/O CUSTODIAN OF RECORDS.
That I delivered to: BAYWAY CADILLAC C/O CUSTODIAN OF RECORDS. By Delivering to
Dimitrios Platsas, GM
the following COVER LETTER; NOTICE OF SUBPOENA DUCES TECUM; CERTIFICATE OF
SERVICE BY E-MAIL; SUBPOENA; AFFIDAVIT
at this address 11111 Southwest Fwy.
Houston, Harris County, TX 77074
Manner of Delivery By PERSONALLY delivering the document(s) to the person above.
Delivered on Tuesday DEC 19, 2023 2:08 pm
My name is LINDELL CHARLES, my date of birth is AUG 22nd, 1971, and my address is
9734 Raisbeck Place Houston TX 77044 and U.S.A. I declare under penalty of perjury
that the foregoing is true and correct.
Executed in Fort Bend County, State of Texas, on the 22nd day of December, 2023.
d•
LINDELL CHARLES 928 Declarant
TX Certification#: PSC-324 Exp. 09/30/2025
AX02A23C01162 Service Fee: 95.00 PCP Inv#: A23CO1162
Witness Fee: 1.00
Mileage Fee: .00 Reference : TORRES, ANDREA
Barker, John
eaffidavits @pcpusa.net E- FILE RETURN
Electronically Filed
12/27/2023 10:59 AM
Hidalgo County District Clerks
Reviewed By: Valerie Garza
CAUSE NO. C-4368-23-H
STATE OF TEXAS
JULIAN TORRES III AND, §
ANDREA TORRES §
§ IN THE DISTRICT COURT
Plaintiffs, §
§
vs. § 398TH JUDICIAL DISTRICT
§
GENERAL MOTORS LLC, §
§ HIDALGO COUNTY, TEXAS
Defendant. §
SUBPOENA
To: Any sheriff or constable of the State of Texas or other person authorized to serve and
execute subpoena as provided in Texas Rule of Civil Procedure 176.5.
You are commanded to summon:
Custodian of Records of Bayway Cadillac, 10150 Southwest Fwy., Houston, TX
77074, to produce and permit inspection and copying of documents and/or tangible things in
his/her possession, custody, and/or control, which may be used as evidence in the above
captioned cause, to: John D. Barker, Attorney for Plaintiffs, located at 1363 Shermer Rd., Ste.
212, Northbrook, IL 60062 by January 8, 2024 at 1:00 p.m.
THE CUSTODIAN OF RECORDS IS COMMANDED TO PRODUCE AND PERMIT
INSPECTION AND COPYING OF THE FOLLOWING DOCUMENTS AND/OR
TANGIBLE THINGS:
1) All purchase and/or leasing documents for the 2022 Cadillac Escalade; VIN:
1GYS3DKL7NR272878;
AND
2) All repair records for the 2022 Cadillac Escalade; VIN: 1GYS3DKL7NR272878.
• Purchase and/or leasing documents shall include but not be limited to the following:
the purchase and or/lease agreement, any financing agreements, any applications for
credit or financing, any documents reflecting the appraisal of a trade-in vehicle used
towards the purchase and/or lease of the subject vehicle, the dealer re-cap worksheet
showing the profit made from the sale or lease of the subject vehicle, the pre-sale delivery
inspection records, all documents reflecting the certificate of origin for the subject
vehicle, the window sticker (buyer’s guide) for the subject vehicle, the sales tax form
submitted to the State, and any other documents not already mentioned contained with
Electronically Filed
12/27/2023 10:59 AM
Hidalgo County District Clerks
Reviewed By: Valerie Garza
the deal bag or deal folder.
• Repair records shall include but not be limited to the following: All records, reports,
memorandum, or data compilation, in any form, made by a person with knowledge or
transmitted by a person with knowledge, if kept in the course of regularly conducted
business activity, including but not limited to all Mechanical documents and Lemon
Law documents (defined below) in your possession and/or control:
o The term “Mechanical documents” means: all Bulletin(s), Service Bulletin(s),
Technical Service Bulletin(s), Dealer Service Bulletin(s), Recall(s), Campaign(s),
Owner Notification(s), Customer Satisfaction Notification(s), Memorandum(s),
Field Service Report(s), Inter Company Correspondence(s), Article(s), Diagnosis
Flow Chart(s),Technical Assistance document(s), Diagnosis Check List(s),
Service Information(s), diagnostic trouble code(s), diagnostic trouble code
description, diagnostic trouble code definition(s), Troubleshooting document(s),
Diagnostic report(s), Part failure code(s), Part failure code description(s),
Comeback document(s), Repeat repair document(s), No Problem Found
document(s), Warranty denied document(s), Service Manual section(s), Tech line
document(s), Complaint Investigation(s), Development(s), Defect
Investigation(s), Complaint Investigation(s), Quality feedback document(s),
Guidelines, Field Report(s), Shop Manual(s), diagnosis flow chart(s), Diagnosis
check list(s), Technician reference document(s), technical manual(s), Service
Manual(s), TSM, CAIR, CAS, DR, Warranty denial incident form, Customer
satisfaction Notification, Dial VIP system documents, WJ documents, Advance
Service information, Technical Service Bulletin, warranty claim, warranty claim
submission, warranty and policy manual, Repair Set, Labor and Coding entries,
Parts entries, Repair Summary Entries, Service write up entries, No Problem
Found documents, repeat repairs documents, comeback documents, warranty
statements, service warranty prior approval, Special Service Instructions,
unauthorized repair techniques documents, unacceptable repair techniques
documents, Warranty and Policy register Journal, Service Tip, Article, No
Problem Found Procedure document, Product Concern Talking Paper, Info(s),
Technical Service Bulletin, Field Update, Field Communication, VSSM Service
Library article, RSE conference call, RSE training, Know-How video, Lotus
Notes, DCS, VME, TAC, VLE, TVIE, IDL documents, Service Know-how
seminar, TAC PI documents, field product report, dealer service manager VME
documents, PTT conference call, IDL know-how training, IDL broadcast,
Corporate Bulletin, Diagnostic Trouble Codes, Subsequent Repair Attempt
documents, Dealer Technical Support Line documents, Comeback worksheet,
Comeback track, ISIS documents, Tech line worksheet, Warranty Regular Claim,
Warranty Claim, Interactive Network, documents, Warranty Repair History,
Failed part description, hotline documents, Emergency Order, Shop Manual,
Trouble Shooting Manual, Diagnostic Trouble Code Guide, Technical Service
Bulletins, Hi-Scan read outs, Warranty Policy and Procedures Manual, Customer
Satisfaction Team recommendations, Repair Assistance, Repeat repairs
documents, Shop comebacks documents, Repair Assistance Claims, Request for
Electronically Filed
12/27/2023 10:59 AM
Hidalgo County District Clerks
Reviewed By: Valerie Garza
reimbursement of non-repair claims, Warrantable repair claim, TDN documents,
Dealer Daily Authorization Repair documents, Acknowledgment of goodwill
service documents, Customer Service file, Customer Service Order, subsequent
repair attempt documents, technical assistance hotline, hotline reference No.,
Technical Assistance Hotline Worksheet, Technical Services Group, Customer
Service Order Hotline Order, Dealer Service Information, Warranty information,
goodwill claims, request for owner retention goodwill adjustment, Technical
Assistance Center documents, Assistance Center documents, Policy Adjustment
Request, Quality Monitoring Report, Electrical Condition Indicator Report, DCS
documents, Warranty Bulletins, Customer Goodwill Consideration documents,
Repeat Repair Attempt Procedures, Regional Assistance documents, Technical
Assistance documents, Technical Assistance request, Reference Bulletin,
Notification of repeat repair, Service manager Bulletin, Goodwill prior approval
log, Goodwill Log, DCS claim submission, non-DCS claim submission and any
and all other documents referencing investigations, inquiries, solutions,
diagnostics discussions and/or repair- related communications involving the
defects, nonconformities, symptoms and/or conditions outlined in the subject
vehicle’s repair documentation for the same make, year and model as the subject
vehicle as well as those documents involving the subject vehicle.
o The term “Lemon Law documents” means: any and all documents relating to
Lemon Law Situations, Lemon Law Prevention, Repeat Repair Attempts,
Consumer Protection Laws, Lemon Laws, Lemon Law Manuals, Lemon Law
Complaints, and Magnusson Moss Act, State lemon Laws and/or Lemon Law
advice. This Term includes but is not limited to all Sales and Service
Agreements, Warranty Policy & Procedures, Parts & Service Policy and
Procedure Manual, Operation Manuals, Procedures documents(s), Policy
document(s), Policy Manual(s), Procedure Manual(s), Warranty Administration
Manual(s), Warranty Policy Manual(s), Service Policies and Procedures,
Warranty Administration document(s), Guidelines, Sales and Service
Agreements, Warranty Policy & Procedures, Parts & Service Policy and
Procedure Manual, Repair Attempt Procedures, Lemon Law Manuals, Operation
Manuals, Policy Manual(s), Procedure Manual(s), Warranty Administration
Manual(s), Warranty Policy Manual(s), Service Policies and Procedures,
Warranty Administration document(s), Guidelines, Lemon Law Situation
documents, Lemon Law Prevention Document(s), Warranty Policy & Procedures,
Prevent Lemon Law Complaint documents, Lemon Law advice and any other
document that relates to Lemon Laws, vehicle repurchases and/or warrantor
liability involving vehicle repairs.
Electronically Filed
12/27/2023 10:59 AM
Hidalgo County District Clerks
Reviewed By: Valerie Garza
This subpoena was issued at the request of Plaintiffs, whose attorney of record is: John D.
Barker, Krohn & Moss, Ltd., 1363 Shermer Rd., Ste. 212, Northbrook, IL 60062.
ISSUED on December 7, 2023
By:
John D. Barker
Attorney for Plaintiffs
Texas Bar No. 24072753
jbarker@consumerlawcenter.com
KROHN & MOSS, LTD.
1363 Shermer Rd., Ste. 212
Northbrook, IL 60062
Phone: (312) 578-9428
Fax: (866) 289-0898
NOTE: 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. TEX. R. CIV. P. 176.8(a).
Electronically Filed
12/27/2023 10:59 AM
Hidalgo County District Clerks
Reviewed By: Valerie Garza
CAUSE NO. C-4368-23-H
STATE OF TEXAS
JULIAN TORRES III AND, §
ANDREA TORRES §
§ IN THE DISTRICT COURT
Plaintiffs, §
§
vs. § 398TH JUDICIAL DISTRICT
§
GENERAL MOTORS LLC, §
§ HIDALGO COUNTY, TEXAS
Defendant. §
AFFIDAVIT
I, ____________________ (please print your name), being first duly sworn on oath, state
as follows:
1. That I am the Custodian of Records of Bayway Cadillac.
2. That as the Custodian of Records, I have personal knowledge of the contents of
any records in my possession or someone with personal knowledge of the record’s
contents transmitted the information to me.
3. That my response pursuant to Plaintiffs’ Subpoena Duces Tecum contains each
and every document, record, report, memorandum, or data compilation, including
but not limited to the purchase and or/lease agreement, any financing agreements,
any applications for credit or financing, any documents reflecting the appraisal of
a trade-in vehicle used towards the purchase and/or lease of the subject vehicle,
the dealer re-cap worksheet showing the profit made from the sale or lease of the
subject vehicle, the pre-sale delivery inspection records, all documents reflecting
the certificate of origin for the subject vehicle, the window sticker (buyer’s guide)
for the subject vehicle, the sales tax form submitted to the State, and any other
documents not already mentioned contained with the deal bag or deal folder, all
invoices, papers, repair orders, Mechanical Documents and Lemon Law
documents pertaining to the purchase and repair history of the 2022 Cadillac
Escalade; VIN: 1GYS3DKL7NR272878.
4. That all of the aforementioned documents, records, reports, memorandum, or data
compilation were kept in the course of regularly conducted business activity.
5. That my response contains photostatic copies of documents that have not been
altered or changed in any way during my custody of said documents.
6. That the Response to Plaintiffs’ Subpoena Duces Tecum pursuant to Texas Rule
Electronically Filed
12/27/2023 10:59 AM
Hidalgo County District Clerks
Reviewed By: Valerie Garza
of Civil Procedure 176 is complete in accordance with Plaintiffs’ request.
FURTHER AFFIANT SAYETH NOT.
__________________________________________
Custodian of Records, Bayway Cadillac
SUBSCRIBED AND SWORN to before me
this _____ day of ________________, 2023.
____________________________________
NOTARY PUBLIC
Preview
Electronically Filed 12/27/2023 10:59 AM Hidalgo County District Clerks Reviewed By: Valerie Garza 398th District Court of HIDALGO County, Texas 100 N . CLOSNER , 2ND FLOOR EDINBURG TX 78539 CASE #: C- 4368-23-H JULIAN TORRES III AND , ANDREA TORRES Plaintiff vs GENERAL MOTORS LLC Defendant AFFIDAVIT OF SERVICE I, LINDELL CHARLES , make statement to the fact; That I am a competent person more than 18 years of age or older and not a party to this action, nor interested in outcome of the suit. That I received the documents stated below on 12/08/23 10:04 pm, instructing for same to be delivered upon BAYWAY CADILLAC C/O CUSTODIAN OF RECORDS. That I delivered to: BAYWAY CADILLAC C/O CUSTODIAN OF RECORDS. By Delivering to Dimitrios Platsas, GM the following COVER LETTER; NOTICE OF SUBPOENA DUCES TECUM; CERTIFICATE OF SERVICE BY E-MAIL; SUBPOENA; AFFIDAVIT at this address 11111 Southwest Fwy. Houston, Harris County, TX 77074 Manner of Delivery By PERSONALLY delivering the document(s) to the person above. Delivered on Tuesday DEC 19, 2023 2:08 pm My name is LINDELL CHARLES, my date of birth is AUG 22nd, 1971, and my address is 9734 Raisbeck Place Houston TX 77044 and U.S.A. I declare under penalty of perjury that the foregoing is true and correct. Executed in Fort Bend County, State of Texas, on the 22nd day of December, 2023. d• LINDELL CHARLES 928 Declarant TX Certification#: PSC-324 Exp. 09/30/2025 AX02A23C01162 Service Fee: 95.00 PCP Inv#: A23CO1162 Witness Fee: 1.00 Mileage Fee: .00 Reference : TORRES, ANDREA Barker, John eaffidavits @pcpusa.net E- FILE RETURN Electronically Filed 12/27/2023 10:59 AM Hidalgo County District Clerks Reviewed By: Valerie Garza CAUSE NO. C-4368-23-H STATE OF TEXAS JULIAN TORRES III AND, § ANDREA TORRES § § IN THE DISTRICT COURT Plaintiffs, § § vs. § 398TH JUDICIAL DISTRICT § GENERAL MOTORS LLC, § § HIDALGO COUNTY, TEXAS Defendant. § SUBPOENA To: Any sheriff or constable of the State of Texas or other person authorized to serve and execute subpoena as provided in Texas Rule of Civil Procedure 176.5. You are commanded to summon: Custodian of Records of Bayway Cadillac, 10150 Southwest Fwy., Houston, TX 77074, to produce and permit inspection and copying of documents and/or tangible things in his/her possession, custody, and/or control, which may be used as evidence in the above captioned cause, to: John D. Barker, Attorney for Plaintiffs, located at 1363 Shermer Rd., Ste. 212, Northbrook, IL 60062 by January 8, 2024 at 1:00 p.m. THE CUSTODIAN OF RECORDS IS COMMANDED TO PRODUCE AND PERMIT INSPECTION AND COPYING OF THE FOLLOWING DOCUMENTS AND/OR TANGIBLE THINGS: 1) All purchase and/or leasing documents for the 2022 Cadillac Escalade; VIN: 1GYS3DKL7NR272878; AND 2) All repair records for the 2022 Cadillac Escalade; VIN: 1GYS3DKL7NR272878. • Purchase and/or leasing documents shall include but not be limited to the following: the purchase and or/lease agreement, any financing agreements, any applications for credit or financing, any documents reflecting the appraisal of a trade-in vehicle used towards the purchase and/or lease of the subject vehicle, the dealer re-cap worksheet showing the profit made from the sale or lease of the subject vehicle, the pre-sale delivery inspection records, all documents reflecting the certificate of origin for the subject vehicle, the window sticker (buyer’s guide) for the subject vehicle, the sales tax form submitted to the State, and any other documents not already mentioned contained with Electronically Filed 12/27/2023 10:59 AM Hidalgo County District Clerks Reviewed By: Valerie Garza the deal bag or deal folder. • Repair records shall include but not be limited to the following: All records, reports, memorandum, or data compilation, in any form, made by a person with knowledge or transmitted by a person with knowledge, if kept in the course of regularly conducted business activity, including but not limited to all Mechanical documents and Lemon Law documents (defined below) in your possession and/or control: o The term “Mechanical documents” means: all Bulletin(s), Service Bulletin(s), Technical Service Bulletin(s), Dealer Service Bulletin(s), Recall(s), Campaign(s), Owner Notification(s), Customer Satisfaction Notification(s), Memorandum(s), Field Service Report(s), Inter Company Correspondence(s), Article(s), Diagnosis Flow Chart(s),Technical Assistance document(s), Diagnosis Check List(s), Service Information(s), diagnostic trouble code(s), diagnostic trouble code description, diagnostic trouble code definition(s), Troubleshooting document(s), Diagnostic report(s), Part failure code(s), Part failure code description(s), Comeback document(s), Repeat repair document(s), No Problem Found document(s), Warranty denied document(s), Service Manual section(s), Tech line document(s), Complaint Investigation(s), Development(s), Defect Investigation(s), Complaint Investigation(s), Quality feedback document(s), Guidelines, Field Report(s), Shop Manual(s), diagnosis flow chart(s), Diagnosis check list(s), Technician reference document(s), technical manual(s), Service Manual(s), TSM, CAIR, CAS, DR, Warranty denial incident form, Customer satisfaction Notification, Dial VIP system documents, WJ documents, Advance Service information, Technical Service Bulletin, warranty claim, warranty claim submission, warranty and policy manual, Repair Set, Labor and Coding entries, Parts entries, Repair Summary Entries, Service write up entries, No Problem Found documents, repeat repairs documents, comeback documents, warranty statements, service warranty prior approval, Special Service Instructions, unauthorized repair techniques documents, unacceptable repair techniques documents, Warranty and Policy register Journal, Service Tip, Article, No Problem Found Procedure document, Product Concern Talking Paper, Info(s), Technical Service Bulletin, Field Update, Field Communication, VSSM Service Library article, RSE conference call, RSE training, Know-How video, Lotus Notes, DCS, VME, TAC, VLE, TVIE, IDL documents, Service Know-how seminar, TAC PI documents, field product report, dealer service manager VME documents, PTT conference call, IDL know-how training, IDL broadcast, Corporate Bulletin, Diagnostic Trouble Codes, Subsequent Repair Attempt documents, Dealer Technical Support Line documents, Comeback worksheet, Comeback track, ISIS documents, Tech line worksheet, Warranty Regular Claim, Warranty Claim, Interactive Network, documents, Warranty Repair History, Failed part description, hotline documents, Emergency Order, Shop Manual, Trouble Shooting Manual, Diagnostic Trouble Code Guide, Technical Service Bulletins, Hi-Scan read outs, Warranty Policy and Procedures Manual, Customer Satisfaction Team recommendations, Repair Assistance, Repeat repairs documents, Shop comebacks documents, Repair Assistance Claims, Request for Electronically Filed 12/27/2023 10:59 AM Hidalgo County District Clerks Reviewed By: Valerie Garza reimbursement of non-repair claims, Warrantable repair claim, TDN documents, Dealer Daily Authorization Repair documents, Acknowledgment of goodwill service documents, Customer Service file, Customer Service Order, subsequent repair attempt documents, technical assistance hotline, hotline reference No., Technical Assistance Hotline Worksheet, Technical Services Group, Customer Service Order Hotline Order, Dealer Service Information, Warranty information, goodwill claims, request for owner retention goodwill adjustment, Technical Assistance Center documents, Assistance Center documents, Policy Adjustment Request, Quality Monitoring Report, Electrical Condition Indicator Report, DCS documents, Warranty Bulletins, Customer Goodwill Consideration documents, Repeat Repair Attempt Procedures, Regional Assistance documents, Technical Assistance documents, Technical Assistance request, Reference Bulletin, Notification of repeat repair, Service manager Bulletin, Goodwill prior approval log, Goodwill Log, DCS claim submission, non-DCS claim submission and any and all other documents referencing investigations, inquiries, solutions, diagnostics discussions and/or repair- related communications involving the defects, nonconformities, symptoms and/or conditions outlined in the subject vehicle’s repair documentation for the same make, year and model as the subject vehicle as well as those documents involving the subject vehicle. o The term “Lemon Law documents” means: any and all documents relating to Lemon Law Situations, Lemon Law Prevention, Repeat Repair Attempts, Consumer Protection Laws, Lemon Laws, Lemon Law Manuals, Lemon Law Complaints, and Magnusson Moss Act, State lemon Laws and/or Lemon Law advice. This Term includes but is not limited to all Sales and Service Agreements, Warranty Policy & Procedures, Parts & Service Policy and Procedure Manual, Operation Manuals, Procedures documents(s), Policy document(s), Policy Manual(s), Procedure Manual(s), Warranty Administration Manual(s), Warranty Policy Manual(s), Service Policies and Procedures, Warranty Administration document(s), Guidelines, Sales and Service Agreements, Warranty Policy & Procedures, Parts & Service Policy and Procedure Manual, Repair Attempt Procedures, Lemon Law Manuals, Operation Manuals, Policy Manual(s), Procedure Manual(s), Warranty Administration Manual(s), Warranty Policy Manual(s), Service Policies and Procedures, Warranty Administration document(s), Guidelines, Lemon Law Situation documents, Lemon Law Prevention Document(s), Warranty Policy & Procedures, Prevent Lemon Law Complaint documents, Lemon Law advice and any other document that relates to Lemon Laws, vehicle repurchases and/or warrantor liability involving vehicle repairs. Electronically Filed 12/27/2023 10:59 AM Hidalgo County District Clerks Reviewed By: Valerie Garza This subpoena was issued at the request of Plaintiffs, whose attorney of record is: John D. Barker, Krohn & Moss, Ltd., 1363 Shermer Rd., Ste. 212, Northbrook, IL 60062. ISSUED on December 7, 2023 By: John D. Barker Attorney for Plaintiffs Texas Bar No. 24072753 jbarker@consumerlawcenter.com KROHN & MOSS, LTD. 1363 Shermer Rd., Ste. 212 Northbrook, IL 60062 Phone: (312) 578-9428 Fax: (866) 289-0898 NOTE: 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. TEX. R. CIV. P. 176.8(a). Electronically Filed 12/27/2023 10:59 AM Hidalgo County District Clerks Reviewed By: Valerie Garza CAUSE NO. C-4368-23-H STATE OF TEXAS JULIAN TORRES III AND, § ANDREA TORRES § § IN THE DISTRICT COURT Plaintiffs, § § vs. § 398TH JUDICIAL DISTRICT § GENERAL MOTORS LLC, § § HIDALGO COUNTY, TEXAS Defendant. § AFFIDAVIT I, ____________________ (please print your name), being first duly sworn on oath, state as follows: 1. That I am the Custodian of Records of Bayway Cadillac. 2. That as the Custodian of Records, I have personal knowledge of the contents of any records in my possession or someone with personal knowledge of the record’s contents transmitted the information to me. 3. That my response pursuant to Plaintiffs’ Subpoena Duces Tecum contains each and every document, record, report, memorandum, or data compilation, including but not limited to the purchase and or/lease agreement, any financing agreements, any applications for credit or financing, any documents reflecting the appraisal of a trade-in vehicle used towards the purchase and/or lease of the subject vehicle, the dealer re-cap worksheet showing the profit made from the sale or lease of the subject vehicle, the pre-sale delivery inspection records, all documents reflecting the certificate of origin for the subject vehicle, the window sticker (buyer’s guide) for the subject vehicle, the sales tax form submitted to the State, and any other documents not already mentioned contained with the deal bag or deal folder, all invoices, papers, repair orders, Mechanical Documents and Lemon Law documents pertaining to the purchase and repair history of the 2022 Cadillac Escalade; VIN: 1GYS3DKL7NR272878. 4. That all of the aforementioned documents, records, reports, memorandum, or data compilation were kept in the course of regularly conducted business activity. 5. That my response contains photostatic copies of documents that have not been altered or changed in any way during my custody of said documents. 6. That the Response to Plaintiffs’ Subpoena Duces Tecum pursuant to Texas Rule Electronically Filed 12/27/2023 10:59 AM Hidalgo County District Clerks Reviewed By: Valerie Garza of Civil Procedure 176 is complete in accordance with Plaintiffs’ request. FURTHER AFFIANT SAYETH NOT. __________________________________________ Custodian of Records, Bayway Cadillac SUBSCRIBED AND SWORN to before me this _____ day of ________________, 2023. ____________________________________ NOTARY PUBLIC