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ANTONIO VELAZQUEZ {wa @Mfi é “OHM“ .,Cow FEE.3F..4:
HIRE
1009 ACADIA DR DIS iRICT CLERK
PLANo,Tx75023 {mm qfl‘ W43 flfiniAth‘Agéségo"
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10/30/2020
134T” DISTRICT COURT
600 COMMERCE ST STE 101 .
DALLAS, TX 75202
To whom itmay concern
II
am her by answering to the suit against me, with the responses to the questions provided in the
,package delivered to me, unfortunately |do not'have an attorney as lwas looking and they are out of
my budget. Ido not know how to go about this. hope
l this letter reaches on time. Iwould liketo get this
matter resolved as soon as possible.
‘Sincerely,
ANTONIO VELAZQUEZ
Title
H
FORM NO. 353-3 - CITATION ESERVE
THE STATE 0F TEXAS I
CITATION
To: ANTONIO VELAZQUEZ DC-20-0728l
1325 SHERRYE DRVAPT D
PLANO TEXAS 75074
CHAD DIETZ
GREETIN GS: vs.
You hav'e been sued. You may employ an attorney. If you or your attorney do not file a wn'tten JOSUE SEGURA, et al
answer with the clerk who issued this citationby 10 o 'clock a m. of the Monday next following the
expiration of twenty days after you were served this citationand PLAINTIFF'S FIRST AMENDED
PETITION & REQUEST FOR DISCLOSURE, a default judgment may be taken against you. ISSUED THIS
Your answer should be addressed to the clerk of the 134th District Court at 600 Commerce Street, Ste. 25th day of August, 2020
101, Dallas, Texas 75202.
Said Plaintifi'being CHAD DIETZ FELICIA PITRE
Clerk District Courts,
Filed in said Court 21st day of August, 2020 against Dallas County, Texas
JOSUE SEGURA, et a1
For Suit, said suitbeing numbered DC-20-07281, the nature of which demand lsas follows:
I
By: ANGELA CONEJO, Deputy
Suit on MOTOR VEHICLE ACCIDENT etc. as shown on said petition & REQUEST FOR
DISCLOSURE, a copy ofwhich accompanies this citation.If this citation isnot served, itshall be
retumed unexecuted. Attorney for Plaintiff
ROCIO GOSEWEHR HERNANDEZ
WITNESS: FELICIA PITRE, Clerk of the Disfi'ictCourts of Dallas, County Texas. SNELLINGS LAW P.L.L.C.
Given under my hand and the Seal of said Court at office this 25th day of August, 2020. 5750 GENESISCOURT STE 205
FRISCO TEXAS 75034
ATTEST: FELICIA PITRE, Clerk of th? District Courts of Dallas, County, Texas M‘mlllflmu 214-387-0387
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”DALLAS COUNTY—
”'"HIJHMIH‘V‘ SERVICE FEES
NOT PAID
PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO
DEFENDANT ANTONIO VALAZS QUEZ
1. Admit that your employment as a tattoo artist at Bold Stroke Studios began on or before
October 26, 2015.
RESPONSE: 3e 3 i
2. Admit you were emploYed as a tattoo artist atBold Stroke Studios on December 15,
201 8.
RESPONSE: k5?)
3. Admit that as of August, 19, 2020, the date on which these requests were drafied, you
were stillemployed as a tattoo artist at Bold Stroke Studios
RESPONSE: ‘56
4. Admit that you did not take more than two weeks off fiom your employment as a tattoo
artist atBold Stroke Studios between December 15, 2018 and August 19, 20207
RESPONSE; 0N3 QvV \MMSM
5. Admit that you are specifically mentioned by name on Bold Stroke Studios Facebook
page in online reviews dated February 16, 2020, November 1, 2019, August 5, 2018,
August 18, 2017, December 18, 2016, April 17, 2016, and March 26, 2016.
RESPONSE: (50)
6. Admit that Bold Stroke Studios provides you with instructions about where your work
isto be performed.
RESPONSE: \595
7. Admit that Bold Stroke Studios prohibits you fiom performing work as a tattoo artist
anywhere other than Bold Stroke Studios.
/
RESPONSE: 032)
8. Admitthfit Bold Stroke Studios required that you attend meetings or take training
courses, when hin'ng you as a tattoo artist.
Amended Petition and Discovery Requests
Plaintiff‘s First Page 12 of 17
RESPONSEAbQ)
Admit that Bold Stroke Studios’ success is largely dependent on your work as a tattoo
-
artist.
RESPONSE: NO
10. Admit that Bold Stroke Studios prohibits you fiom delegating your work as a tattoo
artist to others.
RESPONSE; Mm \ Apm— mu NW)“ 5M5 WW4
11. Admit that you are required to submit regular reports (oral or written) regarding work
you have performed to Bold Stroke Studios.
RESPONSE: M0
12. AgAdmit that Bold Stroke Studios provides the tools, materials, and equipment used by
you as a tattoo artist.
RESPONSE: M0
13. Admit that Bold Stroke Studios prohibits you from working for another tattoo parlor.
RESPONSE: no
14. Admit that you learned about sterile practices as part ofyour training to become a tattoo
artist.
RESPONSE: «a
15. Admit that you learned to use germicidal soap to clean your hands and the skin area of
the client to be tattooed, as part ofyour training to become a tattoo artist.
16.
RESPONSE: Gnu“ sou?
Admit that you failed to use germicidal
K3 039$, wiédg wo 0M
soap t0 clean your hands and the
kox‘c’xo
M
skin area of
the client to be tattooed, when tattooing Chad Dietz.
RESPONSE: No
17. Admit that you learned to wear clean apparel and rubber gloves while tattooing a client,
as part of your training to become a tattoo artist.
RESPONSE: \SQS
Amended Petition and Discovery Requests
Plaintiff s First Page 13 of l7
18. Admit that you failed to wear clean apparel and rubber gloves while tattooing a client,
when tattooing Chad Dietz.
RESPONSENO
19. Admit that you learned to use sterile tools and equipment while tattooing a client, as
part of your training to become a tattoo artist.
RESPONSE: .
[fies
20. Admit that you failed to use sterile tools and equipment while tattooing a client, when
tattooing Chad Dietz. '
RESPONSE; N o
21. Admit that you learned to keep the tattoo studio in a sanitary condition, as part of your
training to become a tattoo artist.
RESPONSES”
22. Admit that you failed to keep the tattoo studio in sanitary condition, when tattooing
'
Chad Dietz.
RESPONSENO
23. Admit that you learned about communicable diseases, including Hepatitis B, as part of
>
your training to become a tattoo artist.
RESPONSE: 363
24. Admit that you knew that Hepatitis B ishighly contagious, and easily transmitted from
one person to another by Various means, when you tattooed Chad Dietz on December
7
15, 2018.
I
RESPONSE: NO
25. Admit that you knew that communicable diseases, such as hepatitis B, can be
transmitted by failing to use germicidal soap to clean your hands and the skin area of
the client to be tattooed.
Amended Petition and Discovery Requésts
Plaintiff’s First Page 14 of 17
RESPONSE: ‘58} 50%» “p
I
26. Admit that you knew that communicable diseases, such as hepatitis B, can be
transmitted by failing to wear clean apparel and rubber gloves while tattooing a client.
RESPONSE: \DCS
27. Admit that you knew that communicable diseases, such as hepatitis B, can be
transmitted by failing to use sterile tools and equipment while tattooing a client.
RESPONSE:
gal 3c \ “SC 90w ov d; “28““ 0f do Vto‘ AKS'MQCA'
28. Admit that you knew that communicable diseases, such as hepatitis B, can be
transmitted by failing to keep the tattoo studio in a sanitary condition.
RESPONSE; N05q 5:“ SSNXM WV song
29. Admit. that you knew that communicable diseases, such as hepatitis B, can be
transmitted through contaminated needles.
RESPONSE: “Q;
30. Admit that Bold Stroke Studios offered your services as a tattoo artist as part of a social
media promotion that run in November of 201 8.
RESPONSE: \bqj
31. Admit that Chad Dietz won a 3-hour tattoo session, with you as the tattoo artist, as part
0f the social media promotion run by Bold Stroke Studio in November of 2018.
RESPONSEzch
32. Admit that you contacted Chad Dietz on December 1,201 8, via text message, to inform
him that he had won a 3-hour tattoo session and that you would be his tattoo artist.
RESPONSE: \ Aic‘, moi $Moy owflev 5Q “\é Wflghfi M8 \o WM
-\V\0\v\\= \ Cow’cacéreé -
33. Admit that you had to reschedule your appointment to complete Chad Dietz’ tattoo due
to illness. ‘
Amended Petition and Discovery Requests
Plaintiffs First Page 15 of 17
RESPONSE:
\593 t
34. Admit thatvyou completed the tattoo that Chad Dietz won through the Bold Stroke
Studios social media promotion‘ on December 15, 201 8.
RESPONSE: \AU
35. Admit that you posted a photograph of the tattoo work done on Chad Dictz, by you at
Bold Stroke Studios, afier his tattoo was complete, in December of 2018.
RESPONSE. ‘5“ 3
'
36. Admit that you announced your retirement fiom tattooing, for personal and financial
reasons, via social medial on November 22, 2018.
RESPONSE: CS, \me N QNM 54$»le GM 3AM) going “’th
Rout \Q
37. Admit that one of the reasons you announced your retirement fiom tattooing, was your
positive diagnosis for Hepatitis B.
RESPONSE: No‘-
38. Admit that despite announcing your retirement fiom tattooing on November 22, 201 8,
you were back on the job as a tattoo artist at Bold Stroke Studios on December 6, 2018.
RESPONSE. \QQS, 0\ \ éetfifié *0 3&0» *0 52, RWEw~\o\\4\9w€ uSOb
39.
avg
Admit that informed Bold
HM
Stroke
3 W0 [K4
Studios of your Hepatltis B
V \*V\
diagnosis on or wbefore
December 15, 2018.
RESPONSE: M
40. Admit that Bold Stroke Studios offered you something of value, in addition to your
usual compensation, in exchange for your continued employment at Bold Stroke
Studios, afier you announced your retirement from tattooing on November 22, 201 8.
RESPONSE: N0
41. -
Admit that you were positive for Hepatitis B at the time that you tattooed Chad Dietz
a
on December 15, 2018.
RESPONSE: MO ‘
Amended Petition and Diséovery Requests
Plaintiff’s First -
Page 16 0f 17
positiv e for Hepatitis B when you tattooed Chad Dietz
42. Admit that you knéw you were
0n December 15, 2018.
RESéONSE: NO \
\f. f
Plaintiff s First Amended Petition
and Discovery Reqixests Page l 7 of 17
Preview
So 2w- oqam m 20 ocr ‘5 E AH D 59-3 ANTONIO VELAZQUEZ {wa @Mfi é “OHM“ .,Cow FEE.3F..4: HIRE 1009 ACADIA DR DIS iRICT CLERK PLANo,Tx75023 {mm qfl‘ W43 flfiniAth‘Agéségo" I T2223” 10/30/2020 134T” DISTRICT COURT 600 COMMERCE ST STE 101 . DALLAS, TX 75202 To whom itmay concern II am her by answering to the suit against me, with the responses to the questions provided in the ,package delivered to me, unfortunately |do not'have an attorney as lwas looking and they are out of my budget. Ido not know how to go about this. hope l this letter reaches on time. Iwould liketo get this matter resolved as soon as possible. ‘Sincerely, ANTONIO VELAZQUEZ Title H FORM NO. 353-3 - CITATION ESERVE THE STATE 0F TEXAS I CITATION To: ANTONIO VELAZQUEZ DC-20-0728l 1325 SHERRYE DRVAPT D PLANO TEXAS 75074 CHAD DIETZ GREETIN GS: vs. You hav'e been sued. You may employ an attorney. If you or your attorney do not file a wn'tten JOSUE SEGURA, et al answer with the clerk who issued this citationby 10 o 'clock a m. of the Monday next following the expiration of twenty days after you were served this citationand PLAINTIFF'S FIRST AMENDED PETITION & REQUEST FOR DISCLOSURE, a default judgment may be taken against you. ISSUED THIS Your answer should be addressed to the clerk of the 134th District Court at 600 Commerce Street, Ste. 25th day of August, 2020 101, Dallas, Texas 75202. Said Plaintifi'being CHAD DIETZ FELICIA PITRE Clerk District Courts, Filed in said Court 21st day of August, 2020 against Dallas County, Texas JOSUE SEGURA, et a1 For Suit, said suitbeing numbered DC-20-07281, the nature of which demand lsas follows: I By: ANGELA CONEJO, Deputy Suit on MOTOR VEHICLE ACCIDENT etc. as shown on said petition & REQUEST FOR DISCLOSURE, a copy ofwhich accompanies this citation.If this citation isnot served, itshall be retumed unexecuted. Attorney for Plaintiff ROCIO GOSEWEHR HERNANDEZ WITNESS: FELICIA PITRE, Clerk of the Disfi'ictCourts of Dallas, County Texas. SNELLINGS LAW P.L.L.C. Given under my hand and the Seal of said Court at office this 25th day of August, 2020. 5750 GENESISCOURT STE 205 FRISCO TEXAS 75034 ATTEST: FELICIA PITRE, Clerk of th? District Courts of Dallas, County, Texas M‘mlllflmu 214-387-0387 ‘ u 4! , . Q a _ ‘N‘ ’1’ I I? ”1,1 'Rocio@SnellingsIniuryLaw.com "Ir Deputy 0fl’p «. S'ervicega25nellingsInjuryLawxom , 1 \uumm Q“ 435.. \\V ”,0 \‘ -'.;.-;-'-~ Q ..... ‘3‘. ”DALLAS COUNTY— ”'"HIJHMIH‘V‘ SERVICE FEES NOT PAID PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT ANTONIO VALAZS QUEZ 1. Admit that your employment as a tattoo artist at Bold Stroke Studios began on or before October 26, 2015. RESPONSE: 3e 3 i 2. Admit you were emploYed as a tattoo artist atBold Stroke Studios on December 15, 201 8. RESPONSE: k5?) 3. Admit that as of August, 19, 2020, the date on which these requests were drafied, you were stillemployed as a tattoo artist at Bold Stroke Studios RESPONSE: ‘56 4. Admit that you did not take more than two weeks off fiom your employment as a tattoo artist atBold Stroke Studios between December 15, 2018 and August 19, 20207 RESPONSE; 0N3 QvV \MMSM 5. Admit that you are specifically mentioned by name on Bold Stroke Studios Facebook page in online reviews dated February 16, 2020, November 1, 2019, August 5, 2018, August 18, 2017, December 18, 2016, April 17, 2016, and March 26, 2016. RESPONSE: (50) 6. Admit that Bold Stroke Studios provides you with instructions about where your work isto be performed. RESPONSE: \595 7. Admit that Bold Stroke Studios prohibits you fiom performing work as a tattoo artist anywhere other than Bold Stroke Studios. / RESPONSE: 032) 8. Admitthfit Bold Stroke Studios required that you attend meetings or take training courses, when hin'ng you as a tattoo artist. Amended Petition and Discovery Requests Plaintiff‘s First Page 12 of 17 RESPONSEAbQ) Admit that Bold Stroke Studios’ success is largely dependent on your work as a tattoo - artist. RESPONSE: NO 10. Admit that Bold Stroke Studios prohibits you fiom delegating your work as a tattoo artist to others. RESPONSE; Mm \ Apm— mu NW)“ 5M5 WW4 11. Admit that you are required to submit regular reports (oral or written) regarding work you have performed to Bold Stroke Studios. RESPONSE: M0 12. AgAdmit that Bold Stroke Studios provides the tools, materials, and equipment used by you as a tattoo artist. RESPONSE: M0 13. Admit that Bold Stroke Studios prohibits you from working for another tattoo parlor. RESPONSE: no 14. Admit that you learned about sterile practices as part ofyour training to become a tattoo artist. RESPONSE: «a 15. Admit that you learned to use germicidal soap to clean your hands and the skin area of the client to be tattooed, as part ofyour training to become a tattoo artist. 16. RESPONSE: Gnu“ sou? Admit that you failed to use germicidal K3 039$, wiédg wo 0M soap t0 clean your hands and the kox‘c’xo M skin area of the client to be tattooed, when tattooing Chad Dietz. RESPONSE: No 17. Admit that you learned to wear clean apparel and rubber gloves while tattooing a client, as part of your training to become a tattoo artist. RESPONSE: \SQS Amended Petition and Discovery Requests Plaintiff s First Page 13 of l7 18. Admit that you failed to wear clean apparel and rubber gloves while tattooing a client, when tattooing Chad Dietz. RESPONSENO 19. Admit that you learned to use sterile tools and equipment while tattooing a client, as part of your training to become a tattoo artist. RESPONSE: . [fies 20. Admit that you failed to use sterile tools and equipment while tattooing a client, when tattooing Chad Dietz. ' RESPONSE; N o 21. Admit that you learned to keep the tattoo studio in a sanitary condition, as part of your training to become a tattoo artist. RESPONSES” 22. Admit that you failed to keep the tattoo studio in sanitary condition, when tattooing ' Chad Dietz. RESPONSENO 23. Admit that you learned about communicable diseases, including Hepatitis B, as part of > your training to become a tattoo artist. RESPONSE: 363 24. Admit that you knew that Hepatitis B ishighly contagious, and easily transmitted from one person to another by Various means, when you tattooed Chad Dietz on December 7 15, 2018. I RESPONSE: NO 25. Admit that you knew that communicable diseases, such as hepatitis B, can be transmitted by failing to use germicidal soap to clean your hands and the skin area of the client to be tattooed. Amended Petition and Discovery Requésts Plaintiff’s First Page 14 of 17 RESPONSE: ‘58} 50%» “p I 26. Admit that you knew that communicable diseases, such as hepatitis B, can be transmitted by failing to wear clean apparel and rubber gloves while tattooing a client. RESPONSE: \DCS 27. Admit that you knew that communicable diseases, such as hepatitis B, can be transmitted by failing to use sterile tools and equipment while tattooing a client. RESPONSE: gal 3c \ “SC 90w ov d; “28““ 0f do Vto‘ AKS'MQCA' 28. Admit that you knew that communicable diseases, such as hepatitis B, can be transmitted by failing to keep the tattoo studio in a sanitary condition. RESPONSE; N05q 5:“ SSNXM WV song 29. Admit. that you knew that communicable diseases, such as hepatitis B, can be transmitted through contaminated needles. RESPONSE: “Q; 30. Admit that Bold Stroke Studios offered your services as a tattoo artist as part of a social media promotion that run in November of 201 8. RESPONSE: \bqj 31. Admit that Chad Dietz won a 3-hour tattoo session, with you as the tattoo artist, as part 0f the social media promotion run by Bold Stroke Studio in November of 2018. RESPONSEzch 32. Admit that you contacted Chad Dietz on December 1,201 8, via text message, to inform him that he had won a 3-hour tattoo session and that you would be his tattoo artist. RESPONSE: \ Aic‘, moi $Moy owflev 5Q “\é Wflghfi M8 \o WM -\V\0\v\\= \ Cow’cacéreé - 33. Admit that you had to reschedule your appointment to complete Chad Dietz’ tattoo due to illness. ‘ Amended Petition and Discovery Requests Plaintiffs First Page 15 of 17 RESPONSE: \593 t 34. Admit thatvyou completed the tattoo that Chad Dietz won through the Bold Stroke Studios social media promotion‘ on December 15, 201 8. RESPONSE: \AU 35. Admit that you posted a photograph of the tattoo work done on Chad Dictz, by you at Bold Stroke Studios, afier his tattoo was complete, in December of 2018. RESPONSE. ‘5“ 3 ' 36. Admit that you announced your retirement fiom tattooing, for personal and financial reasons, via social medial on November 22, 2018. RESPONSE: CS, \me N QNM 54$»le GM 3AM) going “’th Rout \Q 37. Admit that one of the reasons you announced your retirement fiom tattooing, was your positive diagnosis for Hepatitis B. RESPONSE: No‘- 38. Admit that despite announcing your retirement fiom tattooing on November 22, 201 8, you were back on the job as a tattoo artist at Bold Stroke Studios on December 6, 2018. RESPONSE. \QQS, 0\ \ éetfifié *0 3&0» *0 52, RWEw~\o\\4\9w€ uSOb 39. avg Admit that informed Bold HM Stroke 3 W0 [K4 Studios of your Hepatltis B V \*V\ diagnosis on or wbefore December 15, 2018. RESPONSE: M 40. Admit that Bold Stroke Studios offered you something of value, in addition to your usual compensation, in exchange for your continued employment at Bold Stroke Studios, afier you announced your retirement from tattooing on November 22, 201 8. RESPONSE: N0 41. - Admit that you were positive for Hepatitis B at the time that you tattooed Chad Dietz a on December 15, 2018. RESPONSE: MO ‘ Amended Petition and Diséovery Requests Plaintiff’s First - Page 16 0f 17 positiv e for Hepatitis B when you tattooed Chad Dietz 42. Admit that you knéw you were 0n December 15, 2018. RESéONSE: NO \ \f. f Plaintiff s First Amended Petition and Discovery Reqixests Page l 7 of 17