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DEPOSITION SUBPOENA TO TESTIFY OR PRODUCE DOCUMENTS OR THINGS
THE STATE OF TEXAS
To any Sheriff or Constable of the State of Texas or other person authorized to serve subpoenas under RULE 176
OF TEXAS RULES OF CIVIL PROCEDURE - GREETINGS -
You are hereby commanded to subpoena and summon the following witness(es):
Custodian of Records for:
T-MOBILE USA, INC.
C/O CORPORATION SERVICE CO., 211 E. 7TH STREET, SUITE 620
AUSTIN, TX 78701
to be and appear before a Notary Public for RecordTrak, A Magna Legal Services Co. or its designated agent, on 02/08/2024, at
2:00 p.m. CST at the office of the custodian for T-MOBILE USA, INC. (or some other mutually agreeable time and location) and
there under oath to make answers of certain written questions to be propounded to the witness and to bring and produce for
inspection and photocopying.
All cell phone records in relation to phone number 956-463-1931 for Brianna Puente. All incoming and outgoing calls, data usage,
raw data, text messages, multimedia, internet usage from 12:00 am CST on 7/5/2022 through 11:59 pm CST on 7/6/2022
PHONE RECORDS SSN:
at any and all times whatsoever, then and there to give evidence at the instance of the Defendant(s)
represented by JOHN PLUMLEE, Esq., Attorney of Record, in that Certain Cause No. C-2551-22-J, pending on the
docket of the DISTRICT Court of the 430th JUDICIAL DISTRICT of HIDALGO County, Texas and there remain from
day to day and time to time until discharged according to law.
This Subpoena is issued under and by virtue of Rule 200 of the Texas Rules of Civil Procedure and Notice of Deposition
Upon Written Questions on file with the above named court, styled
BRIANNA PUENTE INDIVIDUALLY AND AS PARENT OF ISAAC TREVINOAND LORENZO TREVINO,
MINOR CHILDREN Plaintiffs LORENZO RUELAS; Intervenor
v.
J OHNSON SPECIALTY TOOLS, LLC AND OSCARE MURILLOSALAZAR,
WITNESS MY HAND, on January 19, 2024
oent hes
1, CHERYL L. CROMWELL
Notary Public, State of Texas|
Comm. Expires 10-31-2024
% MT Notary ID 5577164
SIGNATURE OF ISSUING OFFICER
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. TEX.R.CIV.P. 176.8(A).
CAUSE NO. C-2551-22-J
BRIANNA PUENTE INDIVIDUALLY AND AS IN THE DISTRICT COURT
PARENT OF ISAAC TREVINOAND LORENZO
TREVINO, MINOR CHILDREN Plaintiffs LORENZO
430th JUDICIAL DISTRICT
RUELAS; Intervenor
Plaintiff(s),
HIDALGO COUNTY, TEXAS
v.
JOHNSON SPECIALTY TOOLS, LLC AND OSCARE
MURILLOSALAZAR,
Defendant(s).
DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS
Custodian of Records for: T-MOBILE USA, INC.
Records Pertaining To: PHONE RECORDS
Type of Records:
All cell phone records in relation to phone number 956-463-1931 for Brianna Puente. All incoming and outgoing calls,
data usage, raw data, text messages, multimedia, internet usage from 12:00 am CST on 7/5/2022 through 11:59 pm CST
on 7/6/2022
1. Please state your full name, address, telephone number, occupations and official title.
ANSWER.
2 Tam the custodian for
(Please insert facility or practitioner name.)
3. Have you received a subpoena duces tecum for the production of those documents listed above?
ANSWER.
4. Are you among those who have possession, custody, control of, or access to the documents requested above?
ANSWER.
Were the records requested above made in the regular course of business?
ANSWER
In the regular course of business did the person who signed or otherwise prepared these records either have personal
knowledge of the entries on these records or obtain the information from sources who have such personal knowledge
to make such records?
ANSWER
State whether these records were made at the time or shortly after the time of the transactions recorded.
ANSWER
Were these records kept as described in the preceding questions?
ANSWER
Does the source of the information, and the method and circumstance of its preparation, establish the trustworthiness
of the records?
ANSWER
10 Please release exact duplicates of the records as requested in the subpoena duces tecum or the originals thereof for
photocopying for attachment to this deposition. Identify how many pages have been released. Have you done as
requested? If not, why not?
ANSWER
11 Are there any records, documents, papers, correspondence, or tangible matters of any kind pertaining to PHONE
RECORDS that you have NOT provided to the notary public taking your deposition?
ANSWER
12 Please describe all papers, documents, records, correspondence, or tangible matters of any kind that you have NOT
provided to the notary public taking your deposition and explain why you have NOT provided them.
ANSWER
13 Are you aware that it may be necessary to subpoena your or your employer to court at the time of the trial of this case,
if you have not provided to the notary public taking your deposition all papers, documents, records, correspondence,
or tangible matters of any kind pertaining to PHONE RECORDS?
ANSWER
WITNESS (Custodian of Records)
Before me, the undersigned authority, on this day personally appeared
, custodian of records for the above listed, known to me to be the person whose name is
subscribed to the foregoing instrument in the capacity therein stated, who being first duly sworn, stated upon his/her oath
that the answers to the foregoing questions are true and correct. I further certify that the records attached hereto are exact
duplicates of the original records.
SWORN TO AND SUBSCRIBED before me this day of 20
NOTARY PUBLIC
409561.1
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DEPOSITION SUBPOENA TO TESTIFY OR PRODUCE DOCUMENTS OR THINGS THE STATE OF TEXAS To any Sheriff or Constable of the State of Texas or other person authorized to serve subpoenas under RULE 176 OF TEXAS RULES OF CIVIL PROCEDURE - GREETINGS - You are hereby commanded to subpoena and summon the following witness(es): Custodian of Records for: T-MOBILE USA, INC. C/O CORPORATION SERVICE CO., 211 E. 7TH STREET, SUITE 620 AUSTIN, TX 78701 to be and appear before a Notary Public for RecordTrak, A Magna Legal Services Co. or its designated agent, on 02/08/2024, at 2:00 p.m. CST at the office of the custodian for T-MOBILE USA, INC. (or some other mutually agreeable time and location) and there under oath to make answers of certain written questions to be propounded to the witness and to bring and produce for inspection and photocopying. All cell phone records in relation to phone number 956-463-1931 for Brianna Puente. All incoming and outgoing calls, data usage, raw data, text messages, multimedia, internet usage from 12:00 am CST on 7/5/2022 through 11:59 pm CST on 7/6/2022 PHONE RECORDS SSN: at any and all times whatsoever, then and there to give evidence at the instance of the Defendant(s) represented by JOHN PLUMLEE, Esq., Attorney of Record, in that Certain Cause No. C-2551-22-J, pending on the docket of the DISTRICT Court of the 430th JUDICIAL DISTRICT of HIDALGO County, Texas and there remain from day to day and time to time until discharged according to law. This Subpoena is issued under and by virtue of Rule 200 of the Texas Rules of Civil Procedure and Notice of Deposition Upon Written Questions on file with the above named court, styled BRIANNA PUENTE INDIVIDUALLY AND AS PARENT OF ISAAC TREVINOAND LORENZO TREVINO, MINOR CHILDREN Plaintiffs LORENZO RUELAS; Intervenor v. J OHNSON SPECIALTY TOOLS, LLC AND OSCARE MURILLOSALAZAR, WITNESS MY HAND, on January 19, 2024 oent hes 1, CHERYL L. CROMWELL Notary Public, State of Texas| Comm. Expires 10-31-2024 % MT Notary ID 5577164 SIGNATURE OF ISSUING OFFICER 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. TEX.R.CIV.P. 176.8(A). CAUSE NO. C-2551-22-J BRIANNA PUENTE INDIVIDUALLY AND AS IN THE DISTRICT COURT PARENT OF ISAAC TREVINOAND LORENZO TREVINO, MINOR CHILDREN Plaintiffs LORENZO 430th JUDICIAL DISTRICT RUELAS; Intervenor Plaintiff(s), HIDALGO COUNTY, TEXAS v. JOHNSON SPECIALTY TOOLS, LLC AND OSCARE MURILLOSALAZAR, Defendant(s). DIRECT QUESTIONS TO BE PROPOUNDED TO THE WITNESS Custodian of Records for: T-MOBILE USA, INC. Records Pertaining To: PHONE RECORDS Type of Records: All cell phone records in relation to phone number 956-463-1931 for Brianna Puente. All incoming and outgoing calls, data usage, raw data, text messages, multimedia, internet usage from 12:00 am CST on 7/5/2022 through 11:59 pm CST on 7/6/2022 1. Please state your full name, address, telephone number, occupations and official title. ANSWER. 2 Tam the custodian for (Please insert facility or practitioner name.) 3. Have you received a subpoena duces tecum for the production of those documents listed above? ANSWER. 4. Are you among those who have possession, custody, control of, or access to the documents requested above? ANSWER. Were the records requested above made in the regular course of business? ANSWER In the regular course of business did the person who signed or otherwise prepared these records either have personal knowledge of the entries on these records or obtain the information from sources who have such personal knowledge to make such records? ANSWER State whether these records were made at the time or shortly after the time of the transactions recorded. ANSWER Were these records kept as described in the preceding questions? ANSWER Does the source of the information, and the method and circumstance of its preparation, establish the trustworthiness of the records? ANSWER 10 Please release exact duplicates of the records as requested in the subpoena duces tecum or the originals thereof for photocopying for attachment to this deposition. Identify how many pages have been released. Have you done as requested? If not, why not? ANSWER 11 Are there any records, documents, papers, correspondence, or tangible matters of any kind pertaining to PHONE RECORDS that you have NOT provided to the notary public taking your deposition? ANSWER 12 Please describe all papers, documents, records, correspondence, or tangible matters of any kind that you have NOT provided to the notary public taking your deposition and explain why you have NOT provided them. ANSWER 13 Are you aware that it may be necessary to subpoena your or your employer to court at the time of the trial of this case, if you have not provided to the notary public taking your deposition all papers, documents, records, correspondence, or tangible matters of any kind pertaining to PHONE RECORDS? ANSWER WITNESS (Custodian of Records) Before me, the undersigned authority, on this day personally appeared , custodian of records for the above listed, known to me to be the person whose name is subscribed to the foregoing instrument in the capacity therein stated, who being first duly sworn, stated upon his/her oath that the answers to the foregoing questions are true and correct. I further certify that the records attached hereto are exact duplicates of the original records. SWORN TO AND SUBSCRIBED before me this day of 20 NOTARY PUBLIC 409561.1