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DEFENDANT MICHELLE LOVE-BAKER, INDIVIDUALLY,
RULE 194 DISCLOSURES
1 (a) Correct names of the parties to the lawsuit:
IT IS UNKNOWN IF OTHER PARTIES HAVE ANY INTEREST. The only party
named and still a Defendant is MICHELLE LOVE-BAKER.
(b) (NAME, ADDRESS, AND TELEPHONE NUMBER OF ANY POTENTIAL PARTIES)
MICHELLE LOVE-BAKER
12002 Live Oak Drive
Magnolia,
Texas 77354
or
c/o Patrick L. Hoskins
Attorney
Chamber of Commerce Building
14015 Park Drive, Suite 200
Tomball, Texas 77377
Patrick L. Hoskins
Attorney
Chamber of Commerce Building
14015 Park Drive, Suite 200
Tomball, Texas 77377
(Attorneys fees)
2 (c) the legal theories and, in general, the factual bases of the
responding party’s claims or defenses (the responding party need
not marshall all evidence that may be offered at trial):
Claim defense based on [1] The papers referenced in the
Plaintiffs’ suit, on their face, do not reflect anything
demonstrating that the primary obligor, a Texas Corporation, has
defaulted under or breached the terms and conditions of the
Page 1 of 5
Plaintiff's pleadings to which all parties’ attention is directed.
Defendant, MICHELLE LOVE-BAKER, Individually, denies any cause of
action exists solely against said Defendant.
{e) 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.
The identities of all parties with knowledge are designated on the
list above and the primary relevant parties believed to have
knowledge are below listed.
MICHELLE LOVE-BAKER
12002 Live Oak Drive
Magnolia,
Texas 77354
or
c/o Patrick L. Hoskins
Attorney
Chamber of Commerce Building
14015 Park Drive, Suite 200
Tomball, Texas 77377
Kimberly Hardy Churchwell a/k/a Kimberly Andrews
12311 Post Oak Court
Magnolia, Texas 77354
Kirk Alan English and Tanna Ren English
11942 Rainy Oaks Drive
Magnolia, Texas 77354
[£] for any testifying expert: Name/address/, phone number:
[1] MICHELLE LOVE-BAKER
12002 Live Oak Drive
Magnolia,
Texas 77354
Page 2 of 5
Attorneys fees, if applicable.
[3] the general substance of the expert’s mental impressions and
opinions and a brief summary of the basis for them, or if the
expert is not retained by, employed by, or otherwise subject
to the control of the responding party, documents reflecting
such information.
None available at present as Defendant, MICHELLE LOVE-BAKER,
Individually’s present opinion is that suit was pre-maturely
and/or wrongfully filed against wrong person;
As to attorneys fees, just fees basis and time and expenses.
[4] If the expert is retained by, employed by, or otherwise
subject to the control of the responding party:
(A) N/A at present
(B) N/A at present
(g) any discoverable indemnity and insuring agreements.
Not applicable, there are no insuring agreements or indemnity.
(h) any discoverable settlement agreements:
No settlement agreements.
(3) any discoverable witness statements:
Not applicable- none known to date. No statements known to
Defendant, MICHELLE LOVE-BAKER, Individually, as declarant.
Page 3 of 5
——— ee _ —e — eee eee on —
and bills obtained by the responding party by virtue of a
authorization furnished by the requesting party. Answer: N/A
(1) the name, address, and telephone number of any person who may be
designated as a responsible third party.
Answe: N/A none known.
Ir.
Further, Defendant, MICHELLE LOVE-BAKER, Individually, makes this
disclosure, but not by limitation or waiver of any of the foregoing responses
and reserving the right and privilege to amend this Defendants’ disclosure and
further reserving the right for trial amendment. This response is being made
as compelled under Texas Rules of Civil Procedure and not waiving any plead
defense or any other defense.
RESPECTFULLY SUBMITTED, this the 26° day of April, 2013.
PATRICK L. HOSKINS, P.
BY
YS \ \
RICK L. HOSKINS
TBA No.: 10029400
Chamber of Commerce Building
14015 Park Drive, Suite 200
Tomball, Texas 77377
(281) 351-4545 [TELEPHONE]
(281) 351-4045 [TELECOPIER]
Attorney for Defendant,
MICHELLE LOVE-BAKER, Individually
Page 4 of 5
SE EE ENE EBS OR NENT ————e aM nae Ae ARS AMMA MR ANE
Plaintiff, as required by the Texas Rules of Civil cedure on this the 29% day
of April, 2013.
PATR: L. HOS!
¢:\MYDOCS\WPWINS\CLIENTS
\LOVE-BAKER. MICHELLE.VS.18T. VICTORIA. NATL.BNK. 1, DIST. RARRIS.CNTY.R19¢.DISCL.
ANS. AFFD1.WED
Page 5 of 5
VEL ENUANI OS o vuage Mike Uv. Miiler, rPresiaing
DEFENDANT MICHELLE LOVE-BAKER, INDIVIDUALLY,
ULE 194 DISCLOSURES
AFFIDAVIT AND VERIFICATION
THE STATE OF TEXAS §
COUNTY OF HARRIS s
BEFORE ME, the undersigned authority, a Notary Public in and for the
foregoing State and County, on this day personally appeared MICHELLE LOVE-
BAKER, (hereinafter “Defendant”) who, known to me to be a credible person
and after being first by me duly sworn, upon her oath says she is authorized
as named Defendant to answer, and, who deposed under oath as follows:
“My name is MICHELLE LOVE-BAKER; I, the undersigned, am of sound mind,
ever the age of eighteen (18) years, and fully competent to make oath;
"I am one named Defendant with personal knowledge and responsibility for
the affairs of me as named Defendant. I have never been convicted of a crime
and am fully competent to make this Affidavit. I am responsible for my
personal records and files. I have personal knowledge of the facts stated
in this Affidavit from my direct involvement in the matter leading up to the
responses to the ongoing litigation, dealing with the defense law firm and
attorney on behalf of me and communications with counsel in this case. The
statements herein are all true and correct.
-l-
counsel of record as related to the allegations of Plaintiff which has been
compiled from my records and/or personal knowledge, generated at or near the
time of the transactions and entries and I am personally familiar with the
responses and able to respond to the disclosure requests as well as this
affidavit. I verify the responses are true, accurate and correct to the best
of my personal knowledge. I have read the Defendant’s Disclosures and the
contents of this Affidavit and verify same, and I am authorized to make this
Affidavit.
"Further, Affiant sayeth not."
MICHELLE, LOVE-BAKER, Affiant
SIGNED AND SWORN TO BEFORE ME, the undersigned authority, a Notary
Public in and for said State and County, on this the ek day of Ag Re ,
2013, by the said MICHELLE LOVE-BAKER, who is known to me or upon proper
proof of identification known to me to be the person whose signature appears
above, and in capacity therein stated.
a Nhe ELIZABETH ANN LEE NOTARY PUBLIC, STATE~OF TEXAS
{ptary Public, State of Texas Printed Notary Name: él. zabeyt let
My Commission Expires
us June 20, 2015 My Commission Expires: Sung IO, kos
a
+ \MYDOCS \HPWIN9\CLIENTS\LOVE~BAKER.MICHELLE.VS.1ST.VICTORTA, NATL.BNK. 11" DIST. HARRIS. CNTY R194. DISCL.ANS .AFFD1.WPD
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DEFENDANT MICHELLE LOVE-BAKER, INDIVIDUALLY, RULE 194 DISCLOSURES 1 (a) Correct names of the parties to the lawsuit: IT IS UNKNOWN IF OTHER PARTIES HAVE ANY INTEREST. The only party named and still a Defendant is MICHELLE LOVE-BAKER. (b) (NAME, ADDRESS, AND TELEPHONE NUMBER OF ANY POTENTIAL PARTIES) MICHELLE LOVE-BAKER 12002 Live Oak Drive Magnolia, Texas 77354 or c/o Patrick L. Hoskins Attorney Chamber of Commerce Building 14015 Park Drive, Suite 200 Tomball, Texas 77377 Patrick L. Hoskins Attorney Chamber of Commerce Building 14015 Park Drive, Suite 200 Tomball, Texas 77377 (Attorneys fees) 2 (c) the legal theories and, in general, the factual bases of the responding party’s claims or defenses (the responding party need not marshall all evidence that may be offered at trial): Claim defense based on [1] The papers referenced in the Plaintiffs’ suit, on their face, do not reflect anything demonstrating that the primary obligor, a Texas Corporation, has defaulted under or breached the terms and conditions of the Page 1 of 5 Plaintiff's pleadings to which all parties’ attention is directed. Defendant, MICHELLE LOVE-BAKER, Individually, denies any cause of action exists solely against said Defendant. {e) 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. The identities of all parties with knowledge are designated on the list above and the primary relevant parties believed to have knowledge are below listed. MICHELLE LOVE-BAKER 12002 Live Oak Drive Magnolia, Texas 77354 or c/o Patrick L. Hoskins Attorney Chamber of Commerce Building 14015 Park Drive, Suite 200 Tomball, Texas 77377 Kimberly Hardy Churchwell a/k/a Kimberly Andrews 12311 Post Oak Court Magnolia, Texas 77354 Kirk Alan English and Tanna Ren English 11942 Rainy Oaks Drive Magnolia, Texas 77354 [£] for any testifying expert: Name/address/, phone number: [1] MICHELLE LOVE-BAKER 12002 Live Oak Drive Magnolia, Texas 77354 Page 2 of 5 Attorneys fees, if applicable. [3] the general substance of the expert’s mental impressions and opinions and a brief summary of the basis for them, or if the expert is not retained by, employed by, or otherwise subject to the control of the responding party, documents reflecting such information. None available at present as Defendant, MICHELLE LOVE-BAKER, Individually’s present opinion is that suit was pre-maturely and/or wrongfully filed against wrong person; As to attorneys fees, just fees basis and time and expenses. [4] If the expert is retained by, employed by, or otherwise subject to the control of the responding party: (A) N/A at present (B) N/A at present (g) any discoverable indemnity and insuring agreements. Not applicable, there are no insuring agreements or indemnity. (h) any discoverable settlement agreements: No settlement agreements. (3) any discoverable witness statements: Not applicable- none known to date. No statements known to Defendant, MICHELLE LOVE-BAKER, Individually, as declarant. Page 3 of 5 ——— ee _ —e — eee eee on — and bills obtained by the responding party by virtue of a authorization furnished by the requesting party. Answer: N/A (1) the name, address, and telephone number of any person who may be designated as a responsible third party. Answe: N/A none known. Ir. Further, Defendant, MICHELLE LOVE-BAKER, Individually, makes this disclosure, but not by limitation or waiver of any of the foregoing responses and reserving the right and privilege to amend this Defendants’ disclosure and further reserving the right for trial amendment. This response is being made as compelled under Texas Rules of Civil Procedure and not waiving any plead defense or any other defense. RESPECTFULLY SUBMITTED, this the 26° day of April, 2013. PATRICK L. HOSKINS, P. BY YS \ \ RICK L. HOSKINS TBA No.: 10029400 Chamber of Commerce Building 14015 Park Drive, Suite 200 Tomball, Texas 77377 (281) 351-4545 [TELEPHONE] (281) 351-4045 [TELECOPIER] Attorney for Defendant, MICHELLE LOVE-BAKER, Individually Page 4 of 5 SE EE ENE EBS OR NENT ————e aM nae Ae ARS AMMA MR ANE Plaintiff, as required by the Texas Rules of Civil cedure on this the 29% day of April, 2013. PATR: L. HOS! ¢:\MYDOCS\WPWINS\CLIENTS \LOVE-BAKER. MICHELLE.VS.18T. VICTORIA. NATL.BNK. 1, DIST. RARRIS.CNTY.R19¢.DISCL. ANS. AFFD1.WED Page 5 of 5 VEL ENUANI OS o vuage Mike Uv. Miiler, rPresiaing DEFENDANT MICHELLE LOVE-BAKER, INDIVIDUALLY, ULE 194 DISCLOSURES AFFIDAVIT AND VERIFICATION THE STATE OF TEXAS § COUNTY OF HARRIS s BEFORE ME, the undersigned authority, a Notary Public in and for the foregoing State and County, on this day personally appeared MICHELLE LOVE- BAKER, (hereinafter “Defendant”) who, known to me to be a credible person and after being first by me duly sworn, upon her oath says she is authorized as named Defendant to answer, and, who deposed under oath as follows: “My name is MICHELLE LOVE-BAKER; I, the undersigned, am of sound mind, ever the age of eighteen (18) years, and fully competent to make oath; "I am one named Defendant with personal knowledge and responsibility for the affairs of me as named Defendant. I have never been convicted of a crime and am fully competent to make this Affidavit. I am responsible for my personal records and files. I have personal knowledge of the facts stated in this Affidavit from my direct involvement in the matter leading up to the responses to the ongoing litigation, dealing with the defense law firm and attorney on behalf of me and communications with counsel in this case. The statements herein are all true and correct. -l- counsel of record as related to the allegations of Plaintiff which has been compiled from my records and/or personal knowledge, generated at or near the time of the transactions and entries and I am personally familiar with the responses and able to respond to the disclosure requests as well as this affidavit. I verify the responses are true, accurate and correct to the best of my personal knowledge. I have read the Defendant’s Disclosures and the contents of this Affidavit and verify same, and I am authorized to make this Affidavit. "Further, Affiant sayeth not." MICHELLE, LOVE-BAKER, Affiant SIGNED AND SWORN TO BEFORE ME, the undersigned authority, a Notary Public in and for said State and County, on this the ek day of Ag Re , 2013, by the said MICHELLE LOVE-BAKER, who is known to me or upon proper proof of identification known to me to be the person whose signature appears above, and in capacity therein stated. a Nhe ELIZABETH ANN LEE NOTARY PUBLIC, STATE~OF TEXAS {ptary Public, State of Texas Printed Notary Name: él. zabeyt let My Commission Expires us June 20, 2015 My Commission Expires: Sung IO, kos a + \MYDOCS \HPWIN9\CLIENTS\LOVE~BAKER.MICHELLE.VS.1ST.VICTORTA, NATL.BNK. 11" DIST. HARRIS. CNTY R194. DISCL.ANS .AFFD1.WPD -2-