On September 29, 2014 a
Party Discovery
was filed
involving a dispute between
Alvarez, Eldom,
and
Hung Enterprises, Inc. A K A Hung Equities - North Hills, Inc. D B A North Hills Place Apartments,
Sunridge Management Group, Inc.,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
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FILED
DALLAS COUNTY
3/27/2015 11:48:38 AM
FELICIA PITRE
DISTRICT CLERK
CAUSE NO. DC-14-11489
ELDOM ALVAREZ § IN THE DISTRICT COURT OF
§
§
Plaintiff, §
§
v. §
§
HUNG ENTERPRISES INC. a/k/a, § DALLAS COUNTY, TEXAS
HUNG EQUITIES- NORTH HILLS, §
INC. d/b/a NORTH HILLS PLACE §
APARTMENTS, SUNRIDGE §
MANAGEMENT GROUP, INC. §
§
Defendants. § 68th JUDICIAL DISTRICT
DEFENDANT SUNRIDGE MANAGEMENT GROUP, INC.'S OBJECTIONS TO
PLAINTIFF'S NOTICE TO TAKE THE ORAL DEPOSITION OF DEFENDANT'S
EMPLOYEE MIMI TAKET
Defendant Sunridge Management Group, Inc. ("Sunridge") hereby objects to Plaintiff's
Notice to Take the Oral Deposition of Defendant's Employee Mimi Taket as described in Exhibit
"A" (the "Notice") attached hereto as follows:
1. Defendant objects to the Notice because it misnames the witness. The witness' name
is Mimi Packett, not Mimi Taket.
2. Defendant objects to Plaintiffs request for documents, which is included in the
Notice, as improper and untimely. Pursuant to Texas Rule of Civil Procedure 199.2(b)(S), requests
for production of documents or tangible things included within a notice for deposition are governed
by Texas Rule of Civil Procedure 196. TEX. R. CN. PROC. 199.2(b)(S). As such, the thirty (30) day
deadline for responses applies to any requested documents that are issued with a deposition notice.
Additionally, Texas Rule of Civil Procedure 199, comment 1 notes that a notice of deposition must
be served on the witness at least thirty (30) days before the deposition in order for requested
documents to be due for production on the date of the deposition. TEX. R. Crv. PRO C. 199, cmt 1.
20007354vl
Page 1
3. Defendant objects to Plaintiffs request for documents, which is included in the
Notice, to the extent that the request is unreasonably overbroad, vague, ambiguous, harassing and
burdensome and seeks "all documents, materials, and files, which in any way relate to" Ms. Packett's
potential testimony or to "the trial of the above-captioned lawsuit."
Respectfully Submitted,
GEORGES. McCALL
State Bar No. 13344800
George.McCall@sedgwicklaw.com
SONDRA S. ROSEBROCK
State Bar No. 24033017
Sondra.Rosebrock@sedgwicklaw.com
ANGELA M. BUCHANAN
State Bar No. 24059213
Angela.Buchanan@sedgwicklaw.com
SEDGWICK LLP
1717 Main Street, Suite 5400
Dallas, TX 75201-7367
Telephone: (469) 227-4675
Facsimile: (469) 227-8004
ATTORNEYSFORDEFENDANT
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the above and foregoing document has been
served upon the following counsel of record via facsimile and U.S. Mail on the 27th day of March,
2015 in accordance with the TEXAS RULES OF CIVIL PROCEDURE.
Roger "Rocky" Walton
Law Firm of Roger "Rocky Walton
2310 West I-20, Suite 200
Arlington, Texas 76017
817.429.3469 facsimile
20007354v1
Page 2
Document Filed Date
March 27, 2015
Case Filing Date
September 29, 2014
Category
OTHER PERSONAL INJURY
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FILED DALLAS COUNTY 3/27/2015 11:48:38 AM FELICIA PITRE DISTRICT CLERK CAUSE NO. DC-14-11489 ELDOM ALVAREZ § IN THE DISTRICT COURT OF § § Plaintiff, § § v. § § HUNG ENTERPRISES INC. a/k/a, § DALLAS COUNTY, TEXAS HUNG EQUITIES- NORTH HILLS, § INC. d/b/a NORTH HILLS PLACE § APARTMENTS, SUNRIDGE § MANAGEMENT GROUP, INC. § § Defendants. § 68th JUDICIAL DISTRICT DEFENDANT SUNRIDGE MANAGEMENT GROUP, INC.'S OBJECTIONS TO PLAINTIFF'S NOTICE TO TAKE THE ORAL DEPOSITION OF DEFENDANT'S EMPLOYEE MIMI TAKET Defendant Sunridge Management Group, Inc. ("Sunridge") hereby objects to Plaintiff's Notice to Take the Oral Deposition of Defendant's Employee Mimi Taket as described in Exhibit "A" (the "Notice") attached hereto as follows: 1. Defendant objects to the Notice because it misnames the witness. The witness' name is Mimi Packett, not Mimi Taket. 2. Defendant objects to Plaintiffs request for documents, which is included in the Notice, as improper and untimely. Pursuant to Texas Rule of Civil Procedure 199.2(b)(S), requests for production of documents or tangible things included within a notice for deposition are governed by Texas Rule of Civil Procedure 196. TEX. R. CN. PROC. 199.2(b)(S). As such, the thirty (30) day deadline for responses applies to any requested documents that are issued with a deposition notice. Additionally, Texas Rule of Civil Procedure 199, comment 1 notes that a notice of deposition must be served on the witness at least thirty (30) days before the deposition in order for requested documents to be due for production on the date of the deposition. TEX. R. Crv. PRO C. 199, cmt 1. 20007354vl Page 1 3. Defendant objects to Plaintiffs request for documents, which is included in the Notice, to the extent that the request is unreasonably overbroad, vague, ambiguous, harassing and burdensome and seeks "all documents, materials, and files, which in any way relate to" Ms. Packett's potential testimony or to "the trial of the above-captioned lawsuit." Respectfully Submitted, GEORGES. McCALL State Bar No. 13344800 George.McCall@sedgwicklaw.com SONDRA S. ROSEBROCK State Bar No. 24033017 Sondra.Rosebrock@sedgwicklaw.com ANGELA M. BUCHANAN State Bar No. 24059213 Angela.Buchanan@sedgwicklaw.com SEDGWICK LLP 1717 Main Street, Suite 5400 Dallas, TX 75201-7367 Telephone: (469) 227-4675 Facsimile: (469) 227-8004 ATTORNEYSFORDEFENDANT CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the above and foregoing document has been served upon the following counsel of record via facsimile and U.S. Mail on the 27th day of March, 2015 in accordance with the TEXAS RULES OF CIVIL PROCEDURE. Roger "Rocky" Walton Law Firm of Roger "Rocky Walton 2310 West I-20, Suite 200 Arlington, Texas 76017 817.429.3469 facsimile 20007354v1 Page 2