On December 10, 2019 a
Party Discovery
was filed
involving a dispute between
Cantu Zavala, Roberto C.,
and
Long, Mary Lynn,
Mesilla Valley Transportation Solutions, Llc,
Mvt Services Llc Dba Mesilla Valley Transportation,
for Injury or Damage - Motor Vehicle (OCA)
in the District Court of Hidalgo County.
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I
V
Electronically Filed
'
'
2/25/2020 2:01 PM
Hidalgo County District Clerks
Reviewed By: Mireya Reyna
CAUSE NO. C—5141—19-D
ROBERTO C. CANTU ZAVALA IN THE DISTRICT COURT
Plaintifi
vs. 2o6TH JUDIICAL DISTRICT
MARY LYNN LONG, MVT mmmmmmmmmmm
TRANSPORTATION LLC DBA MESILLA
VALLEY TRANSPORTATION and MESILLA
VALLEY TRANSPORTATION SOLUTIONS,
LLC
Defendant HIDALGO COUNTY, TEXAS
DEFENDANT MARY LYNN LONG’S OBJECTION TO PLAINTIFF’S
NOTICE OF INTENT TO USE DOCUMENTS PRODUCED IN
RESPONSE TO WRITTEN DISCOVERY PER TRCP RULE 193.7
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES Defendant, MARY LYNN LONG, and files this Objection to
Plaintiff’s Notice of Intent to Use Documents Produced in Response to Written
Discovery Per TRCP Rule 193.7, and would respectfully show as follows:
I.
Defendant objects to Plaihtiff’s Notice to Use Documents Produced in
Response to Written Discovery as vague and overly broad, as Plaintiff fails to
identify any specific documents, but rather, generally refers t0 “all documents”
produced by Defendant in discovery. Defendants further objects as such
unidentified documents may be hearsay and/ 0r not properly authenticated.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Defendant, MARY LYNN LONG,
prays the Court grants her objection -t0 Plaintiffs Notice to Use Documents
6FB5206.docx 1
Electronically Filed
2/25/2020 2:01 PM
Hidalgo County District Clerks
Reviewed By: Mireya Reyna
Produced in Response to Written Discovery and further prays for such other
and further relief, both general 0r specific, to Which he may be entitled.
Respectfully submitted,
/ S/ Stephen D. Navarro
DAVID L. ORTEGA
State Bar No. 0079 1377
STEPHEN D. NAVARRO
State Bar No. 00792712
Telephone: (2 1 O) 73 1-6351
Facsimile: (210) 785—2951
E—mail: dortega@namanhowellcom v
E—mail: snavarro@namanhowell.com
NAMAN, HOWELL, SMITH 8r,LEE, PLLC
10001 Reunion Place, Suite 600
San Antonio, Texas 782 16
ATTORNEY FOR DEFENDANT
MARY LYNN LONG
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing
was served in accordance with the Texas Rules of Civil Procedure on this the
25th day of February, 2020, to the following counsel of record:
Ricardo A. Garcia
Lino H. Ochoa
Lourdes G. Vella
Romero Rendon
Garcia 8r,Ochoa, LLP
820 S. Main
McAllen, Texas 78501
Via Email: service®o~lawfirm com
/S/ Stephen D. Navarro
DAVID L. ORTEGA
STEPHEN D. NAVARRO
6FB5206.docx
Document Filed Date
February 25, 2020
Case Filing Date
December 10, 2019
Category
Injury or Damage - Motor Vehicle (OCA)
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I V Electronically Filed ' ' 2/25/2020 2:01 PM Hidalgo County District Clerks Reviewed By: Mireya Reyna CAUSE NO. C—5141—19-D ROBERTO C. CANTU ZAVALA IN THE DISTRICT COURT Plaintifi vs. 2o6TH JUDIICAL DISTRICT MARY LYNN LONG, MVT mmmmmmmmmmm TRANSPORTATION LLC DBA MESILLA VALLEY TRANSPORTATION and MESILLA VALLEY TRANSPORTATION SOLUTIONS, LLC Defendant HIDALGO COUNTY, TEXAS DEFENDANT MARY LYNN LONG’S OBJECTION TO PLAINTIFF’S NOTICE OF INTENT TO USE DOCUMENTS PRODUCED IN RESPONSE TO WRITTEN DISCOVERY PER TRCP RULE 193.7 TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES Defendant, MARY LYNN LONG, and files this Objection to Plaintiff’s Notice of Intent to Use Documents Produced in Response to Written Discovery Per TRCP Rule 193.7, and would respectfully show as follows: I. Defendant objects to Plaihtiff’s Notice to Use Documents Produced in Response to Written Discovery as vague and overly broad, as Plaintiff fails to identify any specific documents, but rather, generally refers t0 “all documents” produced by Defendant in discovery. Defendants further objects as such unidentified documents may be hearsay and/ 0r not properly authenticated. PRAYER WHEREFORE, PREMISES CONSIDERED, Defendant, MARY LYNN LONG, prays the Court grants her objection -t0 Plaintiffs Notice to Use Documents 6FB5206.docx 1 Electronically Filed 2/25/2020 2:01 PM Hidalgo County District Clerks Reviewed By: Mireya Reyna Produced in Response to Written Discovery and further prays for such other and further relief, both general 0r specific, to Which he may be entitled. Respectfully submitted, / S/ Stephen D. Navarro DAVID L. ORTEGA State Bar No. 0079 1377 STEPHEN D. NAVARRO State Bar No. 00792712 Telephone: (2 1 O) 73 1-6351 Facsimile: (210) 785—2951 E—mail: dortega@namanhowellcom v E—mail: snavarro@namanhowell.com NAMAN, HOWELL, SMITH 8r,LEE, PLLC 10001 Reunion Place, Suite 600 San Antonio, Texas 782 16 ATTORNEY FOR DEFENDANT MARY LYNN LONG CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing was served in accordance with the Texas Rules of Civil Procedure on this the 25th day of February, 2020, to the following counsel of record: Ricardo A. Garcia Lino H. Ochoa Lourdes G. Vella Romero Rendon Garcia 8r,Ochoa, LLP 820 S. Main McAllen, Texas 78501 Via Email: service®o~lawfirm com /S/ Stephen D. Navarro DAVID L. ORTEGA STEPHEN D. NAVARRO 6FB5206.docx