On November 26, 2012 a
Party Discovery
was filed
involving a dispute between
Bocanegra, Maria Alba,
and
Ivic, Franka,
Ivic, Mihael,
Misho'S Oyster Inc,
Vann, Michael,
Vann, Patrick,
for OTHER CIVIL
in the District Court of Harris County.
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CAUSE NO. 2012 69632
MARIA ALBA BOCANEGRA, IN THE DISTRICT COURT OF
INDIVIDUALLY AND, AS NEXT OF
FRIEND OF ALBA JOCELIN OSORNIO,
AND AS REPRESENTATIVE OF THE
ESTATE OF JOSE SANTOS OSORNIO
Plaintiff
HARRIS COUNTY, T E X A S
MISHO’S OYSTER, INC., D/B/A MISHO’S
SEAFOOD INC., MIHAEL IVIC, FRANKA
IVIS AND MICHAEL VANN D/B/A
CLEAR LAKE ELECTRICAL SERVICE
Defendants. JUDICIAL DISTRICT
DEFENDANT S MOTION TO COMPEL
COMPLETE RESPONSES TO INTERROGATORIES
TO THE HONORABLE JUDGE OF SAID COURT:
Defendant Michael Vann d/b/a Clear Lake Electrical Service’s (hereinafter “Vann”) files
the following Motion to Compel Complete Responses to Interrogatories and would show the
Court as follows:
On or about June 25, 2014, Defendant, Vann propounded its first set of interrogatories to
Plaintiff. Plaintiff served Objections and Answers Defendant First Interrogatories on or about
July 25, . (A true and correct copy is attached as Exhibit “A”).
Plaintiff’s answers to the above referenced discovery requests were improper,
unresponsive, and lodged with unfounded objections.
A trial court may compel a party to respond adequately to interrogatories and requests for
production. Tex. R. Civ. P. 215.1(b). Plaintiff did not respond adequately to Defendant’s first
set of interrogatories nos. 1,2,3,4, 5, and 7 as required by Texas Rule of Civil Procedure 193.1.
Therefore, The Court should overrule Plaintiff’s objections to interrogatories and compel
Plaintiff to completely answer to Defendant’s first interrogatories nos. 1, 2,3, 4, 5, and 7.
PRAYER
For these reasons, Defendant asks this Court to set this motion for hearing and, after the
hearing, to compel Plaintiff to serve adequate responses to Defendant’s discovery requests as
outlined above.
Respectfully Submitted,
BAKER & PATTERSON, L.L.P.
By: /s/ Kip Patterson
Kip Patterson
Texas Bar No. 15602850
601 Sawyer St., Suite 110
Houston, Texas 77007
Telephone: 713-623-8116
Facsimile: 713-623-0290
Email: kpatterson@bakpatlaw.com
Counsel for defendant Michael Vann d/b/a Clear
Lake Electrical
CERTIFICATE OF CONFERENCE
I certify that I attempted to confer with Plaintiff’s counsel and have made a reasonable
effort to work out our differences without the necessity of court intervention. We were unable to
reach an agreement.
/s/ Kip Patterson
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served on all known
counsel of record in compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on
the 8th day of August 2014.
Sameh O. Aly
Fayez H. Hatamleh
Abogado Aly, PLLC
6969 Gulf Freeway, Suite 500
Houston, Texas 77087
John C. Cardenas
1350 NASA Parkway, Suite 200
Houston, Texas 77058
/s/ Kip Patterson
Document Filed Date
August 08, 2014
Case Filing Date
November 26, 2012
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CAUSE NO. 2012 69632 MARIA ALBA BOCANEGRA, IN THE DISTRICT COURT OF INDIVIDUALLY AND, AS NEXT OF FRIEND OF ALBA JOCELIN OSORNIO, AND AS REPRESENTATIVE OF THE ESTATE OF JOSE SANTOS OSORNIO Plaintiff HARRIS COUNTY, T E X A S MISHO’S OYSTER, INC., D/B/A MISHO’S SEAFOOD INC., MIHAEL IVIC, FRANKA IVIS AND MICHAEL VANN D/B/A CLEAR LAKE ELECTRICAL SERVICE Defendants. JUDICIAL DISTRICT DEFENDANT S MOTION TO COMPEL COMPLETE RESPONSES TO INTERROGATORIES TO THE HONORABLE JUDGE OF SAID COURT: Defendant Michael Vann d/b/a Clear Lake Electrical Service’s (hereinafter “Vann”) files the following Motion to Compel Complete Responses to Interrogatories and would show the Court as follows: On or about June 25, 2014, Defendant, Vann propounded its first set of interrogatories to Plaintiff. Plaintiff served Objections and Answers Defendant First Interrogatories on or about July 25, . (A true and correct copy is attached as Exhibit “A”). Plaintiff’s answers to the above referenced discovery requests were improper, unresponsive, and lodged with unfounded objections. A trial court may compel a party to respond adequately to interrogatories and requests for production. Tex. R. Civ. P. 215.1(b). Plaintiff did not respond adequately to Defendant’s first set of interrogatories nos. 1,2,3,4, 5, and 7 as required by Texas Rule of Civil Procedure 193.1. Therefore, The Court should overrule Plaintiff’s objections to interrogatories and compel Plaintiff to completely answer to Defendant’s first interrogatories nos. 1, 2,3, 4, 5, and 7. PRAYER For these reasons, Defendant asks this Court to set this motion for hearing and, after the hearing, to compel Plaintiff to serve adequate responses to Defendant’s discovery requests as outlined above. Respectfully Submitted, BAKER & PATTERSON, L.L.P. By: /s/ Kip Patterson Kip Patterson Texas Bar No. 15602850 601 Sawyer St., Suite 110 Houston, Texas 77007 Telephone: 713-623-8116 Facsimile: 713-623-0290 Email: kpatterson@bakpatlaw.com Counsel for defendant Michael Vann d/b/a Clear Lake Electrical CERTIFICATE OF CONFERENCE I certify that I attempted to confer with Plaintiff’s counsel and have made a reasonable effort to work out our differences without the necessity of court intervention. We were unable to reach an agreement. /s/ Kip Patterson CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served on all known counsel of record in compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on the 8th day of August 2014. Sameh O. Aly Fayez H. Hatamleh Abogado Aly, PLLC 6969 Gulf Freeway, Suite 500 Houston, Texas 77087 John C. Cardenas 1350 NASA Parkway, Suite 200 Houston, Texas 77058 /s/ Kip Patterson