On March 21, 2024 a
Exhibit,Appendix
was filed
involving a dispute between
and
for Debt/Contract - Debt/Contract
in the District Court of Harris County.
Preview
2024-18401 / Court: 129
EXHIBIT D
Required Disclosures
CAUSE NO
NEW FOREST HOMEOWNERS IN THE DISTRICT COURT OF
ASSOCIATION, INC.
Plaintiff,
Vv. HARRIS COUNTY, TEXAS
JOSHUA DAVILA
Defendant. JUDICIAL DISTRICT
DEFENDANT’S DISCLOSURES
TO: NEW FOREST HOMEOWNERS ASSOCIATION, INC., Plaintiff, by and through its
attorney of record Trisha Taylor Farine, Daughtry & Farine, P.C., 17044 El Camino Real,
Houston, Texas 77058.
1 R.194.2(b)(1): the correct names of the parties to the lawsuit;
RESPONSE:
R.194.2(b)(2): the name, address, and telephone number of any potential parties;
RESPONSE:
R.194.2(b)(3): the legal theories and, in general, the factual basis of all of your claims or
defenses;
RESPONSE:
R.194.2(b)(4): the computation of each category of damages claimed by the responding
party — who must also make available for inspection and copying the documents or other
evidentiary material, unless privileged or protected from disclosure, on which each
computation is based, including materials bearing on the nature and extent of injuries
suffered;
RESPONSE:
5 R.194.2(b)(5): the name, address, and telephone number of persons having knowledge of
relevant facts, and a brief statement of each identified person’s connection with the case;
RESPONSE:
R194.2(b)(6): a copy — or description by category location — of all documents,
electronically stored information, and tangible things that the responding party has in its
possession, custody, or control, and may use to support its claims or defenses, unless the
use would be solely for impeachment;
RESPONSE:
R.194.2(b)(7): Produce any indemnity and insuring agreements as described in
Rule 192.3(f).
RESPONSE:
R.194.2(b)(8): Produce any settlement agreements as described in Rule 192.3(g).
RESPONSE:
R.194.2(b)(9): Produce any witness statements as described in Rule 192.3(h)
RESPONSE:
10. R.194.2(b)(10): in a suit alleging physical or mental injury and damages from the
occurrence that is the subject of the case, all medical records, and bills that are reasonably
related to the injuries or damages asserted or, in lieu thereof, an authorization permitting
the disclosure of such medical records and bills;
RESPONSE:
11 R.194.2(b)(11): in a suit alleging physical or mental injury and damages from the
occurrence that is the subject of the case, all medical records and bills obtained by the
responding party by virtue of an authorization furnished by the requesting party;
RESPONSE:
12. R.194.2(b)(12): Produce the name, address, and telephone number of any person
who may be designated as a responsible third party.
RESPONSE:
Respectfully submitted,
BY:
- Name
- Street Address
- City, State ZIP
- Telephone
- E-mail
BY:
- Name
- Street Address
- City, State ZIP
- Telephone
- E-mail
CERTIFICATE OF SERVICE
The undersigned attorney hereby certifies that a true and correct copy of the foregoing
Defendant's Disclosures have been forwarded to individuals listed below by the method indicated
below on this the of 202.
Via E-service: farine.filing@daughtryfarine.com
Daughtry & Farine, P.C.
17044 El Camino Real
Houston, TX 77058
Attorneys for Plaintiff
(Signature)
(Name)
Document Filed Date
March 21, 2024
Case Filing Date
March 21, 2024
Category
Debt/Contract - Debt/Contract
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