Preview
FILED
3/28/2024 12:00 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS 00., TEXAS
Janieshia Reed DEPUTY
CASE N0. DC-23-l3204
DESTINATION PET, LLC
V.
LAKEWOOD MOBILE PET GROOMING, LLC
and CHRISTOPHER LACQUEMENT
AFFIDAVIT 0F SERVICE
Documents came to hand on the 25TH day of March 2024 at 3:22 PM.
I delivered, in person, a true and correct copy of the NOTICE OF INTENT TO SERVE SUBPOENA
T0 KRISTINA MEYER with the attached EXHIBIT “A” to Ms. KRISTINA MEYER at 1700
AMELIA COURT # 612, PLANO, TEXAS 75075 on the 26TH day of March 2024 at 5:20 PM.
I am not a party to this case nor am I related to, employed by or otherwise connected to [other than having
been retained to serve process in this case] any party or any party's attorney in this case; and I have no
interest in the outcome of this lawsuit.
I am over the age of eighteen (18) years of age. I am of sound mind and have never been convicted of a
felony or misdemeanor involving moral turpitude.
My name is Mohammed Chaibi, my date of birth is March 29, 1979, and my address is 3990 Spring
Valley Rd, Apt 332, Farmers Branch, Texas, 75244, USA. I declare under penalty of perjury that the
foregoing is true and correct.
Executed in Dallas, County, State of Texas, on the 26TH day of March 2024.
“WWW? Owe;
Mohammed Chaibi
Certification Number: PSC-18406
Certification Expiration: 48012026
CAUSE NO. DC-23-13204
DESTINATION PET, LLC, § IN THE DISTRICT COURT
§
Plaintiff, §
§
v. § 116"- JUDICIAL DISTRICT
§
LAKEWOOD MOBILE PET §
GROOMING, LLC and CHRISTOPHER §
LACQUEMENT, §
§
Defendants. § DALLAS COUNTY, TEXAS
NOTICE OF INTENT TO SERVE SUBPOENA TO
KRISTINA MEYER
TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
Please take notice that, pursuant to the Texas Rules of Civil Procedure, Plaintiff Destination
Pet, LLC hereby provides notice that it will serve the attached subpoena on April 4, 2024 to
Kristina Meyer.
Respectfully submitted,
OTTESON SHAPIRO LLP
By: /s/ Kevin T. Schutte
Kevin T. Schutte
Texas Bar NO. 24033050
kschutte@os.law
Direct Dial: (214) 619-8355
Madison Berberet
Texas Bar No. 24120715
mberberet@os.law
Direct Dial: (214) 619-8357
4851 Lyndon B Johnson Freeway, Suite 650
Dallas, Texas 75244
Telephone: (214) 619-8309
and
NOTICE OF INTENT TO SERVE SUBPOENA TO
KRISHNA MEYER PAGE 1
MINTZ, LEVIN, COHN, FERRIS,
GLOVSKY AND POPEO, P.C.
James Rapore (admitted pro hac vice)
JARapore@mintz.com
Century Plaza Towers
2049 Century Park East, Suite 300
Los Angeles, CA 90067
Telephone: (310) 586-3200
Amy Pearlman (admitted pro hac vice)
ARPearlman@mintz.com
One Financial Center
Boston, MA 02111
Telephone: (617) 542-6000
ATTORNEYS FOR DESTINATION PET,
LLC
QERTIFIS :ATE QF SER! IS :E
I hereby certify that on this 25th day of March, 2024, the above and foregoing document
was served on all known counsel of record in accordance with the Texas Rules of Civil Procedure.
/s/ Kevin 1". Schutte
Kevin T. Schutte
NOTICE OF INTENT TO SERVE SUBPOENA TO
KRISHNA MEYER PAGE 2
THE STATE OF TEXAS
DEPOSITION SUBPOENA WITH SUBPOENA DUCES TECUM
To any Sheriff or Constable of the State of Texas or other person authorized to serve and execute —
Greetings:
You are hereby commanded to summon: Kristina Meyer
To appear and give testimony at: Otteson Shapiro LLP
4851 Lyndon B. Johnson Freeway, Suite 650
Dallas, Texas 75244
On the 9“1 day of May, 2024 at 9:00 a.m. then and there to testify as a witness in that certain cause styled:
Cause No. DC-23-13204 Attorneys for Plaintiff Destination Pet, LLC
Kevin T. Schutte, Texas Bar No. 24033050
DESTINATION PET, LLC, Madison R. Berberet, Texas Bar No. 24120715
Otteson Shapiro LLP
v. 4851 Lyndon B. Johnson Freeway, Suite 650
Dallas, Texas 75244
LAKEWOOD MOBILE PET GROOMING, LLC and Telephone: (214) 619-8309
CHRISTOPHER LACQUEMENT,
0n the docket of the 116th Judicial District Court, Dallas County, State of Texas, and there remain from day to
day until discharged according to law. Plaintiff Destination Pet, LLC reserves the right to conduct the deposition
virtually.
You are further instructed to produce those items identified on the Subpoena Duces Tecum attached as
Exhibit “A” on or before the 19th day of April, 2024 at 5:00 pan. to the address described above or,
alternatively, electronically to counsel of record for Destination Pet, Amy Pearlman, at
ARPearlman@mintz.com.
FAILURE BY ANY PERSON WITHOUT ADE UATE EXCUSE T0 OBEY A SUBPOENA SERVED
UPON THAT PERSON MAY BE DEEMED A CON TEMPT 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 PUNISHABLE BY FINE 0R CONFINEMENT, OR BOTH
Date Kevin T. Schutte, Texas Bar No. 24033050
Madison Berberet, Texas Bar No. 24120715
Otteson Shapiro LLP
4851 Lyndon B. Johnson Freeway, Suite 650
Dallas, Texas 75244
Telephone: (214) 619-8309
NOTICE OF INTENT TO SERVE SUBPOENA TO
KRISHNA MEYER PAGE 3
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.
Courtney Poteete on behalf of Kevin Schutte
Bar No. 24033050
cpoteete@os.law
Envelope ID: 86067269
Filing Code Description: Return Of Service
Filing Description: AFFIDAVIT OF SERVICE - EXECUTED SUBPOENA
DUCES TECUM -NOT|CE OF INTENT - KRISTINA MEYER
Status as of 3/29/2024 11:43 AM CST
Associated Case Party: DESTINATION PET, LLC
Name BarNumber Email TimestampSubmitted Status
KEVIN TSCHUTTE kschutte@os.law 3/28/2024 12:00:05 PM SENT
MADISON BERBERET mberberet@os.law 3/28/2024 12:00:05 PM SENT
Associated Case Party: LAKEWOOD MOBILE PET GROOMING, LLC
Name BarNumber Email Timestam pSubmitted Status
CHRISTINE M.R|STER christine@risterlaw.com 3/28/2024 12:00:05 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Francine Ly fly@da|lascourts.org 3/28/2024 12:00:05 PM SENT
James Rapore JARapore@mintz.com 3/28/2024 12:00:05 PM SENT
Amy Pearlman ARPearIman@mintz.com 3/28/2024 12:00:05 PM SENT
Preview
FILED 3/28/2024 12:00 PM FELICIA PITRE DISTRICT CLERK DALLAS 00., TEXAS Janieshia Reed DEPUTY CASE N0. DC-23-l3204 DESTINATION PET, LLC V. LAKEWOOD MOBILE PET GROOMING, LLC and CHRISTOPHER LACQUEMENT AFFIDAVIT 0F SERVICE Documents came to hand on the 25TH day of March 2024 at 3:22 PM. I delivered, in person, a true and correct copy of the NOTICE OF INTENT TO SERVE SUBPOENA T0 KRISTINA MEYER with the attached EXHIBIT “A” to Ms. KRISTINA MEYER at 1700 AMELIA COURT # 612, PLANO, TEXAS 75075 on the 26TH day of March 2024 at 5:20 PM. I am not a party to this case nor am I related to, employed by or otherwise connected to [other than having been retained to serve process in this case] any party or any party's attorney in this case; and I have no interest in the outcome of this lawsuit. I am over the age of eighteen (18) years of age. I am of sound mind and have never been convicted of a felony or misdemeanor involving moral turpitude. My name is Mohammed Chaibi, my date of birth is March 29, 1979, and my address is 3990 Spring Valley Rd, Apt 332, Farmers Branch, Texas, 75244, USA. I declare under penalty of perjury that the foregoing is true and correct. Executed in Dallas, County, State of Texas, on the 26TH day of March 2024. “WWW? Owe; Mohammed Chaibi Certification Number: PSC-18406 Certification Expiration: 48012026 CAUSE NO. DC-23-13204 DESTINATION PET, LLC, § IN THE DISTRICT COURT § Plaintiff, § § v. § 116"- JUDICIAL DISTRICT § LAKEWOOD MOBILE PET § GROOMING, LLC and CHRISTOPHER § LACQUEMENT, § § Defendants. § DALLAS COUNTY, TEXAS NOTICE OF INTENT TO SERVE SUBPOENA TO KRISTINA MEYER TO ALL PARTIES AND THEIR COUNSEL OF RECORD: Please take notice that, pursuant to the Texas Rules of Civil Procedure, Plaintiff Destination Pet, LLC hereby provides notice that it will serve the attached subpoena on April 4, 2024 to Kristina Meyer. Respectfully submitted, OTTESON SHAPIRO LLP By: /s/ Kevin T. Schutte Kevin T. Schutte Texas Bar NO. 24033050 kschutte@os.law Direct Dial: (214) 619-8355 Madison Berberet Texas Bar No. 24120715 mberberet@os.law Direct Dial: (214) 619-8357 4851 Lyndon B Johnson Freeway, Suite 650 Dallas, Texas 75244 Telephone: (214) 619-8309 and NOTICE OF INTENT TO SERVE SUBPOENA TO KRISHNA MEYER PAGE 1 MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C. James Rapore (admitted pro hac vice) JARapore@mintz.com Century Plaza Towers 2049 Century Park East, Suite 300 Los Angeles, CA 90067 Telephone: (310) 586-3200 Amy Pearlman (admitted pro hac vice) ARPearlman@mintz.com One Financial Center Boston, MA 02111 Telephone: (617) 542-6000 ATTORNEYS FOR DESTINATION PET, LLC QERTIFIS :ATE QF SER! IS :E I hereby certify that on this 25th day of March, 2024, the above and foregoing document was served on all known counsel of record in accordance with the Texas Rules of Civil Procedure. /s/ Kevin 1". Schutte Kevin T. Schutte NOTICE OF INTENT TO SERVE SUBPOENA TO KRISHNA MEYER PAGE 2 THE STATE OF TEXAS DEPOSITION SUBPOENA WITH SUBPOENA DUCES TECUM To any Sheriff or Constable of the State of Texas or other person authorized to serve and execute — Greetings: You are hereby commanded to summon: Kristina Meyer To appear and give testimony at: Otteson Shapiro LLP 4851 Lyndon B. Johnson Freeway, Suite 650 Dallas, Texas 75244 On the 9“1 day of May, 2024 at 9:00 a.m. then and there to testify as a witness in that certain cause styled: Cause No. DC-23-13204 Attorneys for Plaintiff Destination Pet, LLC Kevin T. Schutte, Texas Bar No. 24033050 DESTINATION PET, LLC, Madison R. Berberet, Texas Bar No. 24120715 Otteson Shapiro LLP v. 4851 Lyndon B. Johnson Freeway, Suite 650 Dallas, Texas 75244 LAKEWOOD MOBILE PET GROOMING, LLC and Telephone: (214) 619-8309 CHRISTOPHER LACQUEMENT, 0n the docket of the 116th Judicial District Court, Dallas County, State of Texas, and there remain from day to day until discharged according to law. Plaintiff Destination Pet, LLC reserves the right to conduct the deposition virtually. You are further instructed to produce those items identified on the Subpoena Duces Tecum attached as Exhibit “A” on or before the 19th day of April, 2024 at 5:00 pan. to the address described above or, alternatively, electronically to counsel of record for Destination Pet, Amy Pearlman, at ARPearlman@mintz.com. FAILURE BY ANY PERSON WITHOUT ADE UATE EXCUSE T0 OBEY A SUBPOENA SERVED UPON THAT PERSON MAY BE DEEMED A CON TEMPT 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 PUNISHABLE BY FINE 0R CONFINEMENT, OR BOTH Date Kevin T. Schutte, Texas Bar No. 24033050 Madison Berberet, Texas Bar No. 24120715 Otteson Shapiro LLP 4851 Lyndon B. Johnson Freeway, Suite 650 Dallas, Texas 75244 Telephone: (214) 619-8309 NOTICE OF INTENT TO SERVE SUBPOENA TO KRISHNA MEYER PAGE 3 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. Courtney Poteete on behalf of Kevin Schutte Bar No. 24033050 cpoteete@os.law Envelope ID: 86067269 Filing Code Description: Return Of Service Filing Description: AFFIDAVIT OF SERVICE - EXECUTED SUBPOENA DUCES TECUM -NOT|CE OF INTENT - KRISTINA MEYER Status as of 3/29/2024 11:43 AM CST Associated Case Party: DESTINATION PET, LLC Name BarNumber Email TimestampSubmitted Status KEVIN TSCHUTTE kschutte@os.law 3/28/2024 12:00:05 PM SENT MADISON BERBERET mberberet@os.law 3/28/2024 12:00:05 PM SENT Associated Case Party: LAKEWOOD MOBILE PET GROOMING, LLC Name BarNumber Email Timestam pSubmitted Status CHRISTINE M.R|STER christine@risterlaw.com 3/28/2024 12:00:05 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Francine Ly fly@da|lascourts.org 3/28/2024 12:00:05 PM SENT James Rapore JARapore@mintz.com 3/28/2024 12:00:05 PM SENT Amy Pearlman ARPearIman@mintz.com 3/28/2024 12:00:05 PM SENT