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CAUSE NO. 2020-12662 a %
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BLANCA CARLOS SANCHEZ * INTHE DISTRICTEGURT © 3
2tZ3 & &
Plaintiff * “Bho A Ze
* 24 a &
£2 wo
v. * — 333™JUDICAL DISTRICT ior
*
DEANNA ELAINE HUGHES *
Defendant
: * HARRIS COUNTY, TEXAS
DEFENDANT DEANNA ELAINE HUGHES'S FIRST OBJECTIONS AND RESPONSES TO
PLAINTIFF’S FIRST REQUEST FOR INTERROGATORIES FROM DEFENDANT
NGUYEN TO PLAINTIFF BLANCA CARLOS SANCHEZ .
TO:
Plaintiff Blanca Carlos Sanchez, by and through her attorney in charge Randal Sylvan
Boochoon, 9555 W. Sam Houston Parkway S., Suite 100, Houston, Texas 77099 via United States
Postal Service Certified Mail Return Receipt Requested on May 27, 2020
Pursuant to Tex. R. Civ. P. 197, Defendant Deanna Elaine Hughes, serves Defendant
Deanna Elaine Hughes’s First Objections and Responses to Plaintiff’s First Request for
Interrogatories from Defendant Nguyen to Plaintiff Blanca Carlos Sanchez as follows:
OBJECTION AND RESPONSE TO REQUESTS FOR INTERROGATORIES
INTERROGATORY NO. 1:
interrogatories.
Please state the full name, address, telephone number, date of birth, place of birth
driver’s license number, social security number and occupation of the person answering these
RECORDER'S MEMORANDUM
‘This instrument is of poor quakty
1/10RESPONSE TO INTEROGATORRY NO. 1:
Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant
Nguyen.
Defendant objects that the interrogatory is overly broad in that it constitutes an impermissible
fishing expedition, and is not reasonably calculated to lead to the discovery of admissible evidence. Tex.
R. Civ. P, 192.3. See generally, K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1997) (no discovery
device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant further
objects that the interrogatory seeks impermissibly to have defendant marshal its.proof. Tex. R. Civ. P.
197.1 : ~
Subject to and without waiving its objections, defendant responds that Defendant Deanna E.
Hughes, will respond when request is amended._
INTERROGATORY NO. 2:
t
State whether you were acting within the course‘and scope of any employment, service
or agency at the time of the collision, and describe the relationship of the person involved.
RESPONSE TO INTEROGATORRY NO. 2:
Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant
Nguyen.
Defendant objects that the interrogatory is overly broad in that it constitutes an impermissible
fishing expedition, and is not reasonably calculated to lead to the discovery of admissible evidence. Tex.
R. Civ. P. 192.3. See generally, K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1997) (no discovery
device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant further
objects that the interrogatory seeks impermissibly to have defendant marshal its proof. Tex. R. Civ. P.
197.1
Subject.to and without waiving its objections, defendant responds that Defendant Deanna E.
Hughes, will respond when request is amended.
INTERROGATORY NO. 3:
State the Style, Court and Cause number of any lawsuit to which you have been a party
and the final disposition of said suit.
RESPONSE TO INTEROGATORRY NO. 3:
Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant
Nguyen.
Defendant objects that the interrogatory is overly broad in that it constitutes an impermissible
fishing expedition, and is not reasonably calculated to lead to the discovery of admissible evidence. Tex.
2/10 -R. Civ. P. 192.3. See generally, K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1997) (no discovery
device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant further
objects that the interrogatory seeks impermissibly to have defendant marshal its proof. Tex. R. Civ. P.
197.1
Subject to and without waiving its objections, defendant responds that Defendant Deanna E.
Hughes, will respond when request is amended._
INTERROGATORY NO. 4:
Do you, your attorney or investigators or anyone action on your behalf, have any maps,
charts, diagrams, photographs, videos, motion pictures and/or recording taken of the scene of
this incident, or of any of the physical or mechanical objects, or of the person involved in thi9s
accident? If yes, then please indicate your willingness to allow Plaintiff’s counsel in this lawsuit
to inspect and copy or photograph the same. :
RESPONSE TO INTEROGATORRY NO. 4:
Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant
Nguyen.
Defendant objects that the interrogatory is overly broad in that it constitutes an impermissible
fishing expedition, and is not reasonably calculated to lead to the discovery of admissible evidence. Tex.
R. Civ, P. 192.3. See generally, K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1997) (no discovery
device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant further
objects that the interrogatory seeks impermissibly to have defendant marshal its proof. Tex. R. Civ. P.
197.1
Subject to and without waiving its objections, defendant responds that Defendant Deanna E.
Hughes, will respond when request is amended._
INTERROGATORY NO. 5:
Do you contend that any personal injuries or damages sustained by any Plaintiffs in this
suit were caused by an occurrence other than this accident, such as a disease or physical
condition, either before or after the incidents made the basis of this suit? If so, describe in
detail, such occurrences, disease, injury or condition.
RESPONSE TO INTEROGATORRY NO. 5:
Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant
Nguyen.
Defendant objects that the interrogatory is overly broad in that it constitutes an
impermissible fishing expedition, and is not reasonably calculated to lead to the discovery of admissible
evidence. Tex. R. Civ. P. 192.3. See generally, K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1997)
4
3/10(no discovery device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant
further objects that the interrogatory seeks impermissibly to have defendant marshal its proof. Tex. R.
Civ. P. 197.1
Subject to and without waiving its objections, defendant responds that Defendant Deanna E.
Hughes, will respond when request is amended._ .
INTERROGATORY NO. 6:
If you obtained any medical attention as a results of any injuries.you sustained in this
wreck, please state the name of any medical provider(s) who treated you, the type of medical
treatment you received you received (i,e. physical therapy, MRIs, etc.), the timeframe for which
you obtained medical treatment and list the body parts that you injured as a results of this
motor vehicle wreck.
RESPONSE TO INTEROGATORRY NO. 6:
Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant
Nguyen.
Defendant objects that the interrogatory is overly broad in that it constitutes an impermisslble
fishing expedition, and is not reasonably calculated to lead to the discovery of.admissible evidence. Tex.
R. Civ. P, 192.3. See generally, K Mart Corp. v. Sanderson, 937 $.W.2d 429, 431 (Tex. 1997) (no discovery .
device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant further
objects that the interrogatory seeks impermissibly to have defendant marshal its proof. Tex. R. Civ. P.
197.1
Subject to and without waiving its objections, defendant responds that Defendant Deanna E.
Hughes, will respond when request is amended._
INTERROGATORY NO. 7:
Do you contend that any Plaintiffs in this suit violated any traffic laws at the time or
immediately prior. to the collision. If so, describe what you contend to be the violation or give
the statute number of the violation
RESPONSE TO INTEROGATORRY NO. 7:
Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant
Nguyen. :
Defendant objects that the interrogatory is overly broad in that it constitutes an impermissible
fishing expedition, and is not reasonably calculated to lead to the discovery of admissible evidence. Tex.
R. Civ. P, 192.3. See generally, K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1997) (no discovery
device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant further
4/10°objects that the interrogatory seeks impermissibly to have defendant marshal its proof. Tex. R. Civ. P.
197.1
Subject to and without waiving Its objections, defendant responds that Defendant Deanna E.
Hughes, will respond when request is amended.
INTERROGATORY NO. 8: °
If you contend that the collision in question was an “unavoidable accident”. Describe in
detail what you believe to be the cause of the motor vehicle collision in question, to the
exclusion of the conduct of the Plaintiffs or you.
RESPONSE TO INTEROGATORRY NO. 8:
Defendant Deanna E. Hughes cannot respond to interrogatory requests for
Defendant Nguyen.
Defendant objects that the interrogatory is overly broad in that it constitutes an impermissible
fishing expedition, and is not reasonably calculated to lead to the discovery of admissible evidence. Tex.
R. Civ. P, 192.3. See generally, K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1997) (no discovery
device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant further
objects that the interrogatory seeks impermissibly to have defendant marshal its proof. Tex. R. Civ. P.
197.1
Subject to and without waiving its objections, defendant responds that Defendant Deanna E.
Hughes, will respond when request is amended._
INTERROGATORY NO. 9:
If you contend that someone else’s conduct or something else is the “sole proximate
cause” of the motor vehicle Collision in question, describe in detail the identity of that person,
or what exactly caused the collision.
RESPONSE TO INTEROGATORRY NO. 9:
Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant
Nguyen.
INTERROGATORY NO. 10:
Please describe how the accident occurred, including the direction of travel, the speed
of the respective vehicles at the time of the motor vehicle collision that forms the basis of this
lawsuit occurred.
RESPONSE TO INTEROGATORRY NO. 10:
\ 5/10Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant
Nguyen.
In the alternative, Defendant objects that the request is overly broad (see Texaco, Inc. v.
Sanderson, 898 S.W.2d 813, 815 (Tex. 1995)), unclear, vague, ambiguous, unduly burdensome
(see In re Alford Chevrolet-Geo, 997 S.W.2d 173, 181 (Tex. 1999)), global and is not reasonably
calculated to lead to the discovery of admissible evidence (see Al Parker Buick Co. v. Touchy, 788
S.W.2d 129, 130-31 (Tex. App. - Houston [1st Dist.] 1990, orig. proceeding)).
Subject to and without waiving defendant’s objections, defendant responds that
Defendant Deanna E. Hughes, will respond when amended._
INTERROGATORY NO. 11:
How fast were you traveling when the motor vehicle accident collision that forms the
basis of this lawsuit occurred?
RESPONSE TO INTEROGATORRY NO. 11:
Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant °
Nguyen.
INTERROGATORY NO. 12:
Did you have a valid driver’s license at the time of the motor vehicle collision in
question? If you did not have a valid driver’s license at the time of the collision, why not?
RESPONSE TO INTEROGATORRY NO. 12:
Defendant Deanna E. Hughes cannot respond to interrogatory requests for
Defendant Nguyen. In the alternative,
Defendant objects that the request is overly broad (see Texaco, Inc. v. Sanderson, 898
S.W.2d 813, 815 (Tex. 1995)), unclear, vague, ambiguous, unduly burdensome (see In re Alford
Chevrolet-Geo, 997 S.W.2d 173, 181 (Tex. 1999)), global and is not reasonably calculated to lead
to the discovery of admissible evidence (see Al Parker Buick Co. v. Touchy, 788 S.W.2d 129, 130-
31 (Tex. App. - Houston [1st Dist.] 1990, orig. proceeding)).
Subject to and without waiving defendant’s objections, defendant responds that
Defendant Deanna E. Hughes, will respond when amended._
INTERROGATORY NO. 13:
Has your driver’s license ever been suspended or revoked? If so, please state when it
was suspended and why it was suspended.
RESPONSE TO INTEROGATORRY NO. 13:
6/10Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant .
Nguyen. ‘
Defendant objects that the request is overly broad (see Texaco, Inc. v. Sanderson, 898
S.W.2d 813,'815 (Tex. 1995)), unclear, vague, ambiguous, unduly burdensome (see In re Alford
Chevrolet-Geo, 997 S.W.2d 173, 181 (Tex. 1999)), global and is not reasonably calculated to lead’
to the discovery of admissible evidence (see Al Parker Buick Co. v. Touchy, 788 S.W.2d 129, 130-
31 (Tex. App. - Houston [1st Dist:] 1990, orig. proceeding).
Subject to and without waiving defendant's objections, defendant responds that
Defendant Deanna‘E. Hughes, will respond when amended
INTERROGATORY NO. 14:
Have you ever been arrested or received a citation for driving without a valid license
and/or driving while license was invalid? If so, please state when such arrest or citation occurred
and in what city or county.
RESPONSE TO INTEROGATORRY NO. 14:
Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant
Nguyen.
Defendant objects that the request is overly broad (see Texaco, Inc. v. Sanderson, 898
SW.2d 813, 815 (Tex. 1995)), unclear, vague, ambiguous, unduly burdensome (see In re Alford
Chevrolet-Geo, 997 S.W.2d 173, 181 (Tex.-1999)), global and is not reasonably calculated to lead
to the discovery of admissible evidence (see Al Parker Buick Co. v. Touchy, 788 S.W.2d 129, 130-
31 (Tex. App. - Houston [1st Dist.] 1990, orig. proceeding)). ‘
‘ Subject to and without waiving defendant’ 's objections, defendant responds that
Defendant Deanna E. Hughes, will respond when amended .
" INTERROGATORY NO. 15:
‘If you a have asserted an affirmative defense of defenses in this lawsuit, please state the
factual basis for such affirmative defense.
RESPONSE TO INTEROGATORRY NO. 15: _
Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant
Nguyen.
Defendant objects that the request is overly broad (see Texaco, Inc. v. Sanderson, 898
SW.2d 813, 815 (Tex. 1995)), unclear, vague, ambiguous, unduly burdensome (see In re Alford
Chevrolet-Geo, 997 SW.2d 173, 181 (Tex. 1999)), global and is not reasonably calculated to lead
to the discovery of admissible evidence (see Al Parker Buick Co. v. Touchy, 788 S.W.2d 129, 30
31 (Tex. App. - Houston [1st Dist.] 1990, orig. proceeding)).
7/10Subject to and without waiving defendant’s objections, defendant responds that
Defendant Deanna E. Hughes, will respond when amended
INTERROGATORY NO. 16: .
State whether you, or anyone acting on your behalf, has requested Plaintiffs submit toa
medical evaluation to determine the extent the extent of the injuries they allege. If you or .
anyone acting on your behalf has not requested Plaintiffs submit to a medical evaluation and
yet you have plead that Plaintiffs’ medical treatment was unreasonable, unnecessary, due to a
pre-existing injury and/or due to an évent other than the accident made the basis of this
lawsuit, please explain how you or anyone acting on your, behalf camé to this conclusion
without ever having asked the plaintiffs to submit to a medical evaluation.
RESPONSE TO INTEROGATORRY No. 16:
Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant
Nguyen
. Defendant objects that the request is overly broad (see Texaco, Inc. v. Sanderson, 898
SW.2d 813, 815 (Tex. 1995)), unclear, vague, ambiguous, unduly burdensome (see In re Alford
Chevrolet-Geo, 997 S.W.2d 173, 181 (Tex. 1999)), global and is not reasonably calculated to lead
to the discovery of admissible evidence (see Al Parker Buick Co. v. Touchy, 788 S.W.2d 129, 130-
31 (Tex. App. - Houston [1st Dist.] 1990, orig. proceeding)).
Subject to and without waiving defendant’s objections, defendant responds that.
Defendant Deanna E. Hughes, will respond when amended
RESERVATION OF RIGHT TO AMEND AND SUPPLEMENT
Discovery and investigation into this dispute is continuing. Accordingly, Defendant Deanna E. Hughes
reserves her right to supplement and amend her discovery responses.
Respectfully submitted,
Deanna E. Hughes, Pro se
5407 Sheraton Oaks
Houston, Texas 77091
Deanna E. es, Prose
8/10DECLARATION UNDER PERJURY OF PENALTY
My name is Deore. ‘ é5 my date of birth is
Se 2/0 . and my address
is 54077 Swrcten wks Houten TA77CAL . i deciare
under penalty of perjury that the foregoing answers to Plaintiff’s Request for
Interrogatories are true and correct. :
Executed. in Harris County, State of Texas on the { (day) of /
: (month and year). . i
CERTIFICATE OF SERVICE
| certify that | have caused a true and correct copy of the above and
foregoing Defendant Deanna E. Hughes Objections and Responses to Plaintiff's
First Request for Production of Documents to be served upon plaintiff Blanca
Carlos Sanchez by and through her attorney in charge, Randall Sylvan Boochoon,
9555 W. Sam Houston PKWY S., Suite 100 Houston, Texas 77009 via United States
Postal Service Certified Mail Return Receipt Requested on /
6-21-2922. (Month, Day, Year) - -
By:
Deanna E. Hughes, Pro se
9/10
Preview
a pie 2. CAUSE NO. 2020-12662 a % 2 % BLANCA CARLOS SANCHEZ * INTHE DISTRICTEGURT © 3 2tZ3 & & Plaintiff * “Bho A Ze * 24 a & £2 wo v. * — 333™JUDICAL DISTRICT ior * DEANNA ELAINE HUGHES * Defendant : * HARRIS COUNTY, TEXAS DEFENDANT DEANNA ELAINE HUGHES'S FIRST OBJECTIONS AND RESPONSES TO PLAINTIFF’S FIRST REQUEST FOR INTERROGATORIES FROM DEFENDANT NGUYEN TO PLAINTIFF BLANCA CARLOS SANCHEZ . TO: Plaintiff Blanca Carlos Sanchez, by and through her attorney in charge Randal Sylvan Boochoon, 9555 W. Sam Houston Parkway S., Suite 100, Houston, Texas 77099 via United States Postal Service Certified Mail Return Receipt Requested on May 27, 2020 Pursuant to Tex. R. Civ. P. 197, Defendant Deanna Elaine Hughes, serves Defendant Deanna Elaine Hughes’s First Objections and Responses to Plaintiff’s First Request for Interrogatories from Defendant Nguyen to Plaintiff Blanca Carlos Sanchez as follows: OBJECTION AND RESPONSE TO REQUESTS FOR INTERROGATORIES INTERROGATORY NO. 1: interrogatories. Please state the full name, address, telephone number, date of birth, place of birth driver’s license number, social security number and occupation of the person answering these RECORDER'S MEMORANDUM ‘This instrument is of poor quakty 1/10RESPONSE TO INTEROGATORRY NO. 1: Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant Nguyen. Defendant objects that the interrogatory is overly broad in that it constitutes an impermissible fishing expedition, and is not reasonably calculated to lead to the discovery of admissible evidence. Tex. R. Civ. P, 192.3. See generally, K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1997) (no discovery device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant further objects that the interrogatory seeks impermissibly to have defendant marshal its.proof. Tex. R. Civ. P. 197.1 : ~ Subject to and without waiving its objections, defendant responds that Defendant Deanna E. Hughes, will respond when request is amended._ INTERROGATORY NO. 2: t State whether you were acting within the course‘and scope of any employment, service or agency at the time of the collision, and describe the relationship of the person involved. RESPONSE TO INTEROGATORRY NO. 2: Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant Nguyen. Defendant objects that the interrogatory is overly broad in that it constitutes an impermissible fishing expedition, and is not reasonably calculated to lead to the discovery of admissible evidence. Tex. R. Civ. P. 192.3. See generally, K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1997) (no discovery device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant further objects that the interrogatory seeks impermissibly to have defendant marshal its proof. Tex. R. Civ. P. 197.1 Subject.to and without waiving its objections, defendant responds that Defendant Deanna E. Hughes, will respond when request is amended. INTERROGATORY NO. 3: State the Style, Court and Cause number of any lawsuit to which you have been a party and the final disposition of said suit. RESPONSE TO INTEROGATORRY NO. 3: Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant Nguyen. Defendant objects that the interrogatory is overly broad in that it constitutes an impermissible fishing expedition, and is not reasonably calculated to lead to the discovery of admissible evidence. Tex. 2/10 -R. Civ. P. 192.3. See generally, K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1997) (no discovery device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant further objects that the interrogatory seeks impermissibly to have defendant marshal its proof. Tex. R. Civ. P. 197.1 Subject to and without waiving its objections, defendant responds that Defendant Deanna E. Hughes, will respond when request is amended._ INTERROGATORY NO. 4: Do you, your attorney or investigators or anyone action on your behalf, have any maps, charts, diagrams, photographs, videos, motion pictures and/or recording taken of the scene of this incident, or of any of the physical or mechanical objects, or of the person involved in thi9s accident? If yes, then please indicate your willingness to allow Plaintiff’s counsel in this lawsuit to inspect and copy or photograph the same. : RESPONSE TO INTEROGATORRY NO. 4: Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant Nguyen. Defendant objects that the interrogatory is overly broad in that it constitutes an impermissible fishing expedition, and is not reasonably calculated to lead to the discovery of admissible evidence. Tex. R. Civ, P. 192.3. See generally, K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1997) (no discovery device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant further objects that the interrogatory seeks impermissibly to have defendant marshal its proof. Tex. R. Civ. P. 197.1 Subject to and without waiving its objections, defendant responds that Defendant Deanna E. Hughes, will respond when request is amended._ INTERROGATORY NO. 5: Do you contend that any personal injuries or damages sustained by any Plaintiffs in this suit were caused by an occurrence other than this accident, such as a disease or physical condition, either before or after the incidents made the basis of this suit? If so, describe in detail, such occurrences, disease, injury or condition. RESPONSE TO INTEROGATORRY NO. 5: Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant Nguyen. Defendant objects that the interrogatory is overly broad in that it constitutes an impermissible fishing expedition, and is not reasonably calculated to lead to the discovery of admissible evidence. Tex. R. Civ. P. 192.3. See generally, K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1997) 4 3/10(no discovery device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant further objects that the interrogatory seeks impermissibly to have defendant marshal its proof. Tex. R. Civ. P. 197.1 Subject to and without waiving its objections, defendant responds that Defendant Deanna E. Hughes, will respond when request is amended._ . INTERROGATORY NO. 6: If you obtained any medical attention as a results of any injuries.you sustained in this wreck, please state the name of any medical provider(s) who treated you, the type of medical treatment you received you received (i,e. physical therapy, MRIs, etc.), the timeframe for which you obtained medical treatment and list the body parts that you injured as a results of this motor vehicle wreck. RESPONSE TO INTEROGATORRY NO. 6: Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant Nguyen. Defendant objects that the interrogatory is overly broad in that it constitutes an impermisslble fishing expedition, and is not reasonably calculated to lead to the discovery of.admissible evidence. Tex. R. Civ. P, 192.3. See generally, K Mart Corp. v. Sanderson, 937 $.W.2d 429, 431 (Tex. 1997) (no discovery . device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant further objects that the interrogatory seeks impermissibly to have defendant marshal its proof. Tex. R. Civ. P. 197.1 Subject to and without waiving its objections, defendant responds that Defendant Deanna E. Hughes, will respond when request is amended._ INTERROGATORY NO. 7: Do you contend that any Plaintiffs in this suit violated any traffic laws at the time or immediately prior. to the collision. If so, describe what you contend to be the violation or give the statute number of the violation RESPONSE TO INTEROGATORRY NO. 7: Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant Nguyen. : Defendant objects that the interrogatory is overly broad in that it constitutes an impermissible fishing expedition, and is not reasonably calculated to lead to the discovery of admissible evidence. Tex. R. Civ. P, 192.3. See generally, K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1997) (no discovery device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant further 4/10°objects that the interrogatory seeks impermissibly to have defendant marshal its proof. Tex. R. Civ. P. 197.1 Subject to and without waiving Its objections, defendant responds that Defendant Deanna E. Hughes, will respond when request is amended. INTERROGATORY NO. 8: ° If you contend that the collision in question was an “unavoidable accident”. Describe in detail what you believe to be the cause of the motor vehicle collision in question, to the exclusion of the conduct of the Plaintiffs or you. RESPONSE TO INTEROGATORRY NO. 8: Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant Nguyen. Defendant objects that the interrogatory is overly broad in that it constitutes an impermissible fishing expedition, and is not reasonably calculated to lead to the discovery of admissible evidence. Tex. R. Civ. P, 192.3. See generally, K Mart Corp. v. Sanderson, 937 S.W.2d 429, 431 (Tex. 1997) (no discovery device can be used to “fish”); Loftin v. Martin, 776 S.W.2d 145, 148 (Tex. 1989). Defendant further objects that the interrogatory seeks impermissibly to have defendant marshal its proof. Tex. R. Civ. P. 197.1 Subject to and without waiving its objections, defendant responds that Defendant Deanna E. Hughes, will respond when request is amended._ INTERROGATORY NO. 9: If you contend that someone else’s conduct or something else is the “sole proximate cause” of the motor vehicle Collision in question, describe in detail the identity of that person, or what exactly caused the collision. RESPONSE TO INTEROGATORRY NO. 9: Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant Nguyen. INTERROGATORY NO. 10: Please describe how the accident occurred, including the direction of travel, the speed of the respective vehicles at the time of the motor vehicle collision that forms the basis of this lawsuit occurred. RESPONSE TO INTEROGATORRY NO. 10: \ 5/10Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant Nguyen. In the alternative, Defendant objects that the request is overly broad (see Texaco, Inc. v. Sanderson, 898 S.W.2d 813, 815 (Tex. 1995)), unclear, vague, ambiguous, unduly burdensome (see In re Alford Chevrolet-Geo, 997 S.W.2d 173, 181 (Tex. 1999)), global and is not reasonably calculated to lead to the discovery of admissible evidence (see Al Parker Buick Co. v. Touchy, 788 S.W.2d 129, 130-31 (Tex. App. - Houston [1st Dist.] 1990, orig. proceeding)). Subject to and without waiving defendant’s objections, defendant responds that Defendant Deanna E. Hughes, will respond when amended._ INTERROGATORY NO. 11: How fast were you traveling when the motor vehicle accident collision that forms the basis of this lawsuit occurred? RESPONSE TO INTEROGATORRY NO. 11: Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant ° Nguyen. INTERROGATORY NO. 12: Did you have a valid driver’s license at the time of the motor vehicle collision in question? If you did not have a valid driver’s license at the time of the collision, why not? RESPONSE TO INTEROGATORRY NO. 12: Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant Nguyen. In the alternative, Defendant objects that the request is overly broad (see Texaco, Inc. v. Sanderson, 898 S.W.2d 813, 815 (Tex. 1995)), unclear, vague, ambiguous, unduly burdensome (see In re Alford Chevrolet-Geo, 997 S.W.2d 173, 181 (Tex. 1999)), global and is not reasonably calculated to lead to the discovery of admissible evidence (see Al Parker Buick Co. v. Touchy, 788 S.W.2d 129, 130- 31 (Tex. App. - Houston [1st Dist.] 1990, orig. proceeding)). Subject to and without waiving defendant’s objections, defendant responds that Defendant Deanna E. Hughes, will respond when amended._ INTERROGATORY NO. 13: Has your driver’s license ever been suspended or revoked? If so, please state when it was suspended and why it was suspended. RESPONSE TO INTEROGATORRY NO. 13: 6/10Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant . Nguyen. ‘ Defendant objects that the request is overly broad (see Texaco, Inc. v. Sanderson, 898 S.W.2d 813,'815 (Tex. 1995)), unclear, vague, ambiguous, unduly burdensome (see In re Alford Chevrolet-Geo, 997 S.W.2d 173, 181 (Tex. 1999)), global and is not reasonably calculated to lead’ to the discovery of admissible evidence (see Al Parker Buick Co. v. Touchy, 788 S.W.2d 129, 130- 31 (Tex. App. - Houston [1st Dist:] 1990, orig. proceeding). Subject to and without waiving defendant's objections, defendant responds that Defendant Deanna‘E. Hughes, will respond when amended INTERROGATORY NO. 14: Have you ever been arrested or received a citation for driving without a valid license and/or driving while license was invalid? If so, please state when such arrest or citation occurred and in what city or county. RESPONSE TO INTEROGATORRY NO. 14: Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant Nguyen. Defendant objects that the request is overly broad (see Texaco, Inc. v. Sanderson, 898 SW.2d 813, 815 (Tex. 1995)), unclear, vague, ambiguous, unduly burdensome (see In re Alford Chevrolet-Geo, 997 S.W.2d 173, 181 (Tex.-1999)), global and is not reasonably calculated to lead to the discovery of admissible evidence (see Al Parker Buick Co. v. Touchy, 788 S.W.2d 129, 130- 31 (Tex. App. - Houston [1st Dist.] 1990, orig. proceeding)). ‘ ‘ Subject to and without waiving defendant’ 's objections, defendant responds that Defendant Deanna E. Hughes, will respond when amended . " INTERROGATORY NO. 15: ‘If you a have asserted an affirmative defense of defenses in this lawsuit, please state the factual basis for such affirmative defense. RESPONSE TO INTEROGATORRY NO. 15: _ Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant Nguyen. Defendant objects that the request is overly broad (see Texaco, Inc. v. Sanderson, 898 SW.2d 813, 815 (Tex. 1995)), unclear, vague, ambiguous, unduly burdensome (see In re Alford Chevrolet-Geo, 997 SW.2d 173, 181 (Tex. 1999)), global and is not reasonably calculated to lead to the discovery of admissible evidence (see Al Parker Buick Co. v. Touchy, 788 S.W.2d 129, 30 31 (Tex. App. - Houston [1st Dist.] 1990, orig. proceeding)). 7/10Subject to and without waiving defendant’s objections, defendant responds that Defendant Deanna E. Hughes, will respond when amended INTERROGATORY NO. 16: . State whether you, or anyone acting on your behalf, has requested Plaintiffs submit toa medical evaluation to determine the extent the extent of the injuries they allege. If you or . anyone acting on your behalf has not requested Plaintiffs submit to a medical evaluation and yet you have plead that Plaintiffs’ medical treatment was unreasonable, unnecessary, due to a pre-existing injury and/or due to an évent other than the accident made the basis of this lawsuit, please explain how you or anyone acting on your, behalf camé to this conclusion without ever having asked the plaintiffs to submit to a medical evaluation. RESPONSE TO INTEROGATORRY No. 16: Defendant Deanna E. Hughes cannot respond to interrogatory requests for Defendant Nguyen . Defendant objects that the request is overly broad (see Texaco, Inc. v. Sanderson, 898 SW.2d 813, 815 (Tex. 1995)), unclear, vague, ambiguous, unduly burdensome (see In re Alford Chevrolet-Geo, 997 S.W.2d 173, 181 (Tex. 1999)), global and is not reasonably calculated to lead to the discovery of admissible evidence (see Al Parker Buick Co. v. Touchy, 788 S.W.2d 129, 130- 31 (Tex. App. - Houston [1st Dist.] 1990, orig. proceeding)). Subject to and without waiving defendant’s objections, defendant responds that. Defendant Deanna E. Hughes, will respond when amended RESERVATION OF RIGHT TO AMEND AND SUPPLEMENT Discovery and investigation into this dispute is continuing. Accordingly, Defendant Deanna E. Hughes reserves her right to supplement and amend her discovery responses. Respectfully submitted, Deanna E. Hughes, Pro se 5407 Sheraton Oaks Houston, Texas 77091 Deanna E. es, Prose 8/10DECLARATION UNDER PERJURY OF PENALTY My name is Deore. ‘ é5 my date of birth is Se 2/0 . and my address is 54077 Swrcten wks Houten TA77CAL . i deciare under penalty of perjury that the foregoing answers to Plaintiff’s Request for Interrogatories are true and correct. : Executed. in Harris County, State of Texas on the { (day) of / : (month and year). . i CERTIFICATE OF SERVICE | certify that | have caused a true and correct copy of the above and foregoing Defendant Deanna E. Hughes Objections and Responses to Plaintiff's First Request for Production of Documents to be served upon plaintiff Blanca Carlos Sanchez by and through her attorney in charge, Randall Sylvan Boochoon, 9555 W. Sam Houston PKWY S., Suite 100 Houston, Texas 77009 via United States Postal Service Certified Mail Return Receipt Requested on / 6-21-2922. (Month, Day, Year) - - By: Deanna E. Hughes, Pro se 9/10