On April 12, 2023 a
Exhibit,Appendix
was filed
involving a dispute between
De La Garza, Felipa,
and
H-E-B, Lp,
for Injury or Damage - Other (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Filed
EXHIBIT A 11/27/2023 12:00 AM
Hidalgo County District Clerks
Reviewed By: Jeremy Longoria
CAUSE NO.: C-1460-23-J
FELIPA DE LA GARZA § IN THE DISTRICT COURT
Plaintiff §
§
§
§
v. § 430TH JUDICIAL DISTRICT
§
§
H-E-B, L.P. §
Defendant § HIDALGO COUNTY, TEXAS
PLAINTIFF’S NOTICE OF INTENTION TO
TAKE THE VIDEOTAPED DEPOSITION OF RANDY CORTEZ
To: DEFENDANT, H-E-B, L.P., by and through its attorney of record:
Victor V. Vicinaiz
Zuleida Lopez-Habbouche
ROERIG, OLIVEIRA & FISHER, L.L.P.
10225 N. 10th Street
McAllen, Texas 78504
PLEASE TAKE NOTICE that pursuant to the provisions of TEX. R. CIV. P. 199, you are hereby
notified that the videotaped deposition of RANDY CORTEZ, will be taken on December 15, 2023, at 1:00
p.m. and such deposition shall be taken at the law offices of ROERIG, OLIVEIRA & FISHER, L.L.P.
located at 10225 N. 10th Street, McAllen, Texas 78504. Service of this Notice has the effect of a subpoena
served on the parties, in accordance with Rule 176, Texas Rules of Civil Procedure. Such deposition will be
recorded by non-stenographic means (videotape) only and will not be recorded stenographically. The answers
will be used as testimony at trial in the above-styled and numbered cause.
PLAINTIFF’S NOTICE OF INTENTION TO TAKE THE VIDEOTAPED DEPOSITION OF RANDY CORTEZ
1
Electronically Filed
11/27/2023 12:00 AM
Hidalgo County District Clerks
Respectfully Submitted, Reviewed By: Jeremy Longoria
HERNANDEZ LAW FIRM, P.C.
4841 S. Jackson Road
Edinburg, Texas 78539
Telephone: (956) 369-4480
Facsimile: (979) 822-6001
Daniel M.L. Hernandez
efiling@hdzfirm.com
State Bar No. 24034479
ATTORNEY FOR PLAINTIFF
THE RICKY ROD LAW GROUP, P.L.L.C.
505 W. Cano Street
Edinburg, Texas 78539
Telephone: (956) 294-0071
/s/ Ricardo P. Rodriguez, Jr.
Ricardo P. Rodriguez, Jr.
State Bar No. 24029801
Email: rick@rickyrodlaw.com
ATTORNEY FOR PLAINTIFF
CERTIFICATE OF SERVICE
This will certify that a true and correct copy of the foregoing document has been served on all counsel
of record in accordance with the Texas Rules of Civil Procedure on November 24, 2023.
___________________________________
Daniel M.L. Hernandez
PLAINTIFF’S NOTICE OF INTENTION TO TAKE THE VIDEOTAPED DEPOSITION OF RANDY CORTEZ
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.
Envelope ID: 81926524
Filing Code Description: Notice
Filing Description: Notice of Deposition of Luz Morales
Status as of 11/27/2023 8:26 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Raul De La Garza rdelagarza@rofllp.com 11/24/2023 3:16:44 PM SENT
Leslie Hernandez leslieh@rofllp.com 11/24/2023 3:16:44 PM SENT
Carolina Mendo carolinam@rofllp.com 11/24/2023 3:16:44 PM SENT
Associated Case Party: H-E-B, LP
Name BarNumber Email TimestampSubmitted Status
Zuleida Lopez-Habbouche zlopez@rofllp.com 11/24/2023 3:16:44 PM SENT
Victor V.Vicinaiz vvicinaiz@rofllp.com 11/24/2023 3:16:44 PM SENT
Associated Case Party: FELIPA DE LA GARZA
Name BarNumber Email TimestampSubmitted Status
Daniel Hernandez daniel@hdzfirm.com 11/24/2023 3:16:44 PM SENT
Ricardo Rodriguez, III ricky@rickyrodlaw.com 11/24/2023 3:16:44 PM SENT
Ricardo Rodriguez rick@rickyrodlaw.com 11/24/2023 3:16:44 PM SENT
Daniel Hernandez efiling@hdzfirm.com 11/24/2023 3:16:44 PM SENT
Document Filed Date
January 12, 2024
Case Filing Date
April 12, 2023
Category
Injury or Damage - Other (OCA)
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Electronically Filed EXHIBIT A 11/27/2023 12:00 AM Hidalgo County District Clerks Reviewed By: Jeremy Longoria CAUSE NO.: C-1460-23-J FELIPA DE LA GARZA § IN THE DISTRICT COURT Plaintiff § § § § v. § 430TH JUDICIAL DISTRICT § § H-E-B, L.P. § Defendant § HIDALGO COUNTY, TEXAS PLAINTIFF’S NOTICE OF INTENTION TO TAKE THE VIDEOTAPED DEPOSITION OF RANDY CORTEZ To: DEFENDANT, H-E-B, L.P., by and through its attorney of record: Victor V. Vicinaiz Zuleida Lopez-Habbouche ROERIG, OLIVEIRA & FISHER, L.L.P. 10225 N. 10th Street McAllen, Texas 78504 PLEASE TAKE NOTICE that pursuant to the provisions of TEX. R. CIV. P. 199, you are hereby notified that the videotaped deposition of RANDY CORTEZ, will be taken on December 15, 2023, at 1:00 p.m. and such deposition shall be taken at the law offices of ROERIG, OLIVEIRA & FISHER, L.L.P. located at 10225 N. 10th Street, McAllen, Texas 78504. Service of this Notice has the effect of a subpoena served on the parties, in accordance with Rule 176, Texas Rules of Civil Procedure. Such deposition will be recorded by non-stenographic means (videotape) only and will not be recorded stenographically. The answers will be used as testimony at trial in the above-styled and numbered cause. PLAINTIFF’S NOTICE OF INTENTION TO TAKE THE VIDEOTAPED DEPOSITION OF RANDY CORTEZ 1 Electronically Filed 11/27/2023 12:00 AM Hidalgo County District Clerks Respectfully Submitted, Reviewed By: Jeremy Longoria HERNANDEZ LAW FIRM, P.C. 4841 S. Jackson Road Edinburg, Texas 78539 Telephone: (956) 369-4480 Facsimile: (979) 822-6001 Daniel M.L. Hernandez efiling@hdzfirm.com State Bar No. 24034479 ATTORNEY FOR PLAINTIFF THE RICKY ROD LAW GROUP, P.L.L.C. 505 W. Cano Street Edinburg, Texas 78539 Telephone: (956) 294-0071 /s/ Ricardo P. Rodriguez, Jr. Ricardo P. Rodriguez, Jr. State Bar No. 24029801 Email: rick@rickyrodlaw.com ATTORNEY FOR PLAINTIFF CERTIFICATE OF SERVICE This will certify that a true and correct copy of the foregoing document has been served on all counsel of record in accordance with the Texas Rules of Civil Procedure on November 24, 2023. ___________________________________ Daniel M.L. Hernandez PLAINTIFF’S NOTICE OF INTENTION TO TAKE THE VIDEOTAPED DEPOSITION OF RANDY CORTEZ 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. Envelope ID: 81926524 Filing Code Description: Notice Filing Description: Notice of Deposition of Luz Morales Status as of 11/27/2023 8:26 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Raul De La Garza rdelagarza@rofllp.com 11/24/2023 3:16:44 PM SENT Leslie Hernandez leslieh@rofllp.com 11/24/2023 3:16:44 PM SENT Carolina Mendo carolinam@rofllp.com 11/24/2023 3:16:44 PM SENT Associated Case Party: H-E-B, LP Name BarNumber Email TimestampSubmitted Status Zuleida Lopez-Habbouche zlopez@rofllp.com 11/24/2023 3:16:44 PM SENT Victor V.Vicinaiz vvicinaiz@rofllp.com 11/24/2023 3:16:44 PM SENT Associated Case Party: FELIPA DE LA GARZA Name BarNumber Email TimestampSubmitted Status Daniel Hernandez daniel@hdzfirm.com 11/24/2023 3:16:44 PM SENT Ricardo Rodriguez, III ricky@rickyrodlaw.com 11/24/2023 3:16:44 PM SENT Ricardo Rodriguez rick@rickyrodlaw.com 11/24/2023 3:16:44 PM SENT Daniel Hernandez efiling@hdzfirm.com 11/24/2023 3:16:44 PM SENT