On November 01, 2018 a
Defendant's Responses to Plaintiff's Requests for Disclosure
was filed
involving a dispute between
Green Water Group L L C,
and
Cruz, Virgina,
for Debt/Contract - Debt/Contract
in the District Court of Harris County.
Preview
12/28/2018 12:41 PM
Chris Daniel - District Clerk Harris County
Envelope No. 30005692
By: Danielle Gutierrez
Filed: 12/28/2018 12:41 PM
CAUSE NO. 2018-79374
GREEN WATER GROUP L.L.C. § IN THE DISTRICT COURT
Plaintiff, §
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v. §
§ HARRIS COUNTY, TEXAS
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§
VIRGINIA CRUZ §
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Defendant. § 270TH JUDICIAL DISTRICT
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DEFENDANT’S RESPONSES TO PLAINTIFF’S
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REQUESTS FOR DISCLOSURE
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(a) The correct names of the parties to the lawsuit;
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The Defendant is correctly named.
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(b) The name, address, and telephone number of any potential parties;
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None known at this time
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(c) The legal theories and, in general, the factual bases of the Responding parties'
claims or defenses;
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Defendant specifically denies all of the allegations in Plaintiff’s Original Petition. The
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real property which is the subject of this litigation is the homestead of the Defendant and
Defendant asserts that specific performance is not a remedy which is available to the Plaiintiff.
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Defendant asserts that Plaintiff has not been damaged.
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(d) The amount and any method of calculating economic damages;
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Defendant has no damages or claims for damages at this time.
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(e) The name, address, and telephone number of persons having knowledge of relevant
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facts, and a brief statement of each identified person's connection with the case;
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Defendant has knowledge of all relevant facts.
(f) For any testifying expert;
(1) The experts' name, address and telephone number;
This defendant has designated no expert witnesses at this time other than
the undersigned attorney may testify to reasonable and necessary
attorney fees.
(2) The subject matter on which the expert will testify;
(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
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subject to the control of the responding party, documents reflecting such information;
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(4) If the expert is retained by, employed by, or otherwise subject to the control
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of the responding party please produce the following:
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This defendant has not retained a testifying expert at this time. Will
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supplement.
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(a) all documents, tangible things, report, models, or data compilations that
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have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert's
testimony; and
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the expert's current resume and bibliography;
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(g) Any discoverable indemnity and insuring agreements described in Rule 192.3(f);
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(h) Any discoverable settlement agreements described in Rule 192.3(g);
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(i) Any discoverable witness statements described in Rule 193.2(h);
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(j) In a suit alleging physical or mental injury and damages from the occurrence that is
the subject of this case, please produce all medical records and bills that are reasonably related to
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the injuries or damages asserted or in lieu thereof, an authorization permitting the disclosure of
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such medical records and bills.
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(k) In a suit alleging physical or mental injury and damages from the occurrence that is
the subject of the case, all medical records and bills obtained by the responding party by virtue of
an authorization furnished by the requesting party.
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(i) The name, address and telephone number of any person who may be designated a
responsible third party.
none
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Document Filed Date
December 28, 2018
Case Filing Date
November 01, 2018
Category
Debt/Contract - Debt/Contract
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12/28/2018 12:41 PM Chris Daniel - District Clerk Harris County Envelope No. 30005692 By: Danielle Gutierrez Filed: 12/28/2018 12:41 PM CAUSE NO. 2018-79374 GREEN WATER GROUP L.L.C. § IN THE DISTRICT COURT Plaintiff, § § v. § § HARRIS COUNTY, TEXAS k § ler § VIRGINIA CRUZ § tC Defendant. § 270TH JUDICIAL DISTRICT ric ist DEFENDANT’S RESPONSES TO PLAINTIFF’S sD REQUESTS FOR DISCLOSURE es (a) The correct names of the parties to the lawsuit; rg The Defendant is correctly named. Bu (b) The name, address, and telephone number of any potential parties; n ily None known at this time ar M (c) The legal theories and, in general, the factual bases of the Responding parties' claims or defenses; of e Defendant specifically denies all of the allegations in Plaintiff’s Original Petition. The ffic real property which is the subject of this litigation is the homestead of the Defendant and Defendant asserts that specific performance is not a remedy which is available to the Plaiintiff. O Defendant asserts that Plaintiff has not been damaged. y op (d) The amount and any method of calculating economic damages; C ial Defendant has no damages or claims for damages at this time. fic (e) The name, address, and telephone number of persons having knowledge of relevant of facts, and a brief statement of each identified person's connection with the case; Un Defendant has knowledge of all relevant facts. (f) For any testifying expert; (1) The experts' name, address and telephone number; This defendant has designated no expert witnesses at this time other than the undersigned attorney may testify to reasonable and necessary attorney fees. (2) The subject matter on which the expert will testify; (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 k subject to the control of the responding party, documents reflecting such information; ler (4) If the expert is retained by, employed by, or otherwise subject to the control tC of the responding party please produce the following: ric This defendant has not retained a testifying expert at this time. Will ist supplement. sD (a) all documents, tangible things, report, models, or data compilations that es have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert's testimony; and rg (b) Bu the expert's current resume and bibliography; n (g) Any discoverable indemnity and insuring agreements described in Rule 192.3(f); ily ar none M (h) Any discoverable settlement agreements described in Rule 192.3(g); of e none ffic (i) Any discoverable witness statements described in Rule 193.2(h); yO none op C (j) In a suit alleging physical or mental injury and damages from the occurrence that is the subject of this case, please produce all medical records and bills that are reasonably related to ial the injuries or damages asserted or in lieu thereof, an authorization permitting the disclosure of fic such medical records and bills. of None Un (k) In a suit alleging physical or mental injury and damages from the occurrence that is the subject of the case, all medical records and bills obtained by the responding party by virtue of an authorization furnished by the requesting party. none (i) The name, address and telephone number of any person who may be designated a responsible third party. none k ler tC ric ist sD es rg Bu n ily ar M of e ffic yO op C ial fic of Un