On March 30, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Lopez, David,
and
Hotze, Steven F,
Liberty Center For God And Country,
for PERSONAL INJ (NON-AUTO)
in the District Court of Harris County.
Preview
NOW COMES, Plaintiff, David Lopez and files this Motion to Compel Responses to
Interrogatories sent to the Liberty Center for God and Count and would show the court as
ACKGROUND
Plaintiff David Lopez has brought this suit against Stephen F. Hotze
served interrogatories on he Center ed to
Every interrogatory propounded to the Center seeks information relevant to at least
one of the cause of action set forth above
Plaintiff requests that the Court compel Defendant Center to provide complete
answers and responses, as required by EXAS ULEOF IVIL ROCEDURE 193.1, to Interrogatories
Nos. and 14 within 10 days of the Court’s order.
RGUMENT UTHORITIES
A Court may compel a party to respond to a discovery request and to adequately
respond to discovery requests.
The purpose of discovery is to "seek the truth, so that disputes may be decided
what the facts reveal, not by what facts are concealed." Jampole v. Touchy, 673 S.W 2d 569, 573
(Tex. 1984). Discovery may be obtained about any matter relevant to the subject matter of the
case or likely to lead to the discovery of admissible evidence. Information is discoverable as long
as it appears "reasonably calculated to lead to the discovery of admissible evidence." Id.
Interrogatories , 1 ,and1 all request information relevant to Plaintiff's claims
and Defendant denial vicarious liability.
Interrogatory # List the names, address and contact information of all Private
Investigators retained by Liberty Center for God and Country to investigate the alleged
voter fraud in Harris County leading up to the 2020 election
Interrogatory # Please list all investigators and/or assistants including their names,
addresses and contact information and any employment information Liberty Center for
God and Country and/or Steven Hotze kept on file who were involved in the investigation
or surveillance of David Lopez including the individual who moved David Lopez’s truck
and searched his vehicle for the alleged missing ballots.
Interrogatory Please describe what the budget was given to each Private
Investigator in order to investigate voter fraud and any financial incentive to locate fraud
in the 2020 presidential election.
Interrogatory # : Please describe in detail how Mark Aguirre and/or his company were
retained to investigate voter fraud in the 2020 presidential election.
Plaintiff has alleged Hotze and the Center are vicariously liable for the torts
committed against Lopez by Mark Aguirre and other investigators working for the Center In press
conferences Hotze has referred numerous times to “our investigators” and to Mark Aguirre as “one
of our investigators.” Mr. Aguirre told Houston Police officer J. Valera that he “was part of the
Liberty Center” and was investigating voter fraud In a letter to President Trump posted on the
Center’s website, Hotze acknowledges he “hired 20 private investigators to discover, expose and
disrupt the massive vote harvesting election fraud scheme of the Democrat communists in Harris
County, Houston, Texas (See affidavit of Houston Police Officer Valera marked hereto as
Exhibit and Hotze’s letter to President Trump marked hereto as Exhibit
Interrogatories 1 ,and1 seek relevant information as to how and why David
Lopez was targeted by the Center.
errogatory # : Please list the name of the individual and/or individuals that provided
information to the Liberty Center for God and Country or Steven Hotze and/or investigators
that lead to the belief that the Plaintiff was involved in the alleged voter fraud for the 2020
election.
Interrogatory # : Please describe the thought process on why Liberty Center for God
and Country or Steven Hotze believed that David Lopez was guilty of voter fraud.
Interrogatory # Please describe in detail why David Lopez was suspected of voter
fraud.
nformati as to why investigators working for the Center targeted and assaulted
Plaintiff and what information the Center provided to the private investigators is directly
discoverable and relevant to Plaintiff's claims
Interrogatories and seek information as to the means and methods used by the
Center to identify and target alleged participants in voter fraud such as Plaintiff.
Interrogatory # Please list the name and addresses of all individuals who were
implicated in a voter fraud scheme for the 2020 presidential election by any investigation
conducted by any private investigator retained by Liberty Center for God and Country
and/or Steven Hotze and the name of the private investigator and/or individual who
implicated the person or persons who were allegedly involved in voter fraud.
Interrogatory # : Please list all individuals that Liberty Center for God and Country had
under surveillance for the past 5 years.
Prior individuals targeted, implicated and/or kept under surveillance by the Center
could have relevant information as to the methods used to target and implicate individuals such as
Plaintiff Such information is relevant and certainly discoverable on the issues of pattern and
practice of hiring private investigators to surveil individuals like David Lopez.
ONCLUSION
The requested information goes to the heart of Plaintiff's case and should be
produced to Plaintiff in complete answers and responses to his written discovery requests.
For the foregoing reasons, Plaintiff David Lopez asks the Court to compel Defendant to
fully answer and/or respond to Plaintiff's written discovery requests within 10 days of the Court’s
order and for such other and further relief, at law or in equity, that Plaintiff may show himself to
be justly entitled
Respectfully submitted,
BRAZIL & DUNN, LLP
/s/ K. Scott Brazil
K. Scott Brazil
13231 Champion Forest Dr., Suite 406
Houston, Texas 77068
Telephone (281) 580
Facsimile (281) 580
scott@brazilanddunn.com
LAW OFFICE OF DICKY GRIGG, P.C
Dicky Grigg
Dicky Grigg
4407 Bee Caves Rd., Suite 111 Bldg 1
West Lake Hills, Texas 7874
Telephone (512) 474
Facsimile (512) 582
dicky @grigg law.com
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
Plaintiff Supplemental Brief in Support of Plaintiff’s Motion to Compel Production of
Documents from District Attorney Pursuant to Subpoena have been served upon all counsel of
record in compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on this the 12th
July,
/s/__K. Scott Brazil
K. Scott Brazil
Document Filed Date
July 12, 2021
Case Filing Date
March 30, 2021
Category
PERSONAL INJ (NON-AUTO)
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Preview
NOW COMES, Plaintiff, David Lopez and files this Motion to Compel Responses to Interrogatories sent to the Liberty Center for God and Count and would show the court as ACKGROUND Plaintiff David Lopez has brought this suit against Stephen F. Hotze served interrogatories on he Center ed to Every interrogatory propounded to the Center seeks information relevant to at least one of the cause of action set forth above Plaintiff requests that the Court compel Defendant Center to provide complete answers and responses, as required by EXAS ULEOF IVIL ROCEDURE 193.1, to Interrogatories Nos. and 14 within 10 days of the Court’s order. RGUMENT UTHORITIES A Court may compel a party to respond to a discovery request and to adequately respond to discovery requests. The purpose of discovery is to "seek the truth, so that disputes may be decided what the facts reveal, not by what facts are concealed." Jampole v. Touchy, 673 S.W 2d 569, 573 (Tex. 1984). Discovery may be obtained about any matter relevant to the subject matter of the case or likely to lead to the discovery of admissible evidence. Information is discoverable as long as it appears "reasonably calculated to lead to the discovery of admissible evidence." Id. Interrogatories , 1 ,and1 all request information relevant to Plaintiff's claims and Defendant denial vicarious liability. Interrogatory # List the names, address and contact information of all Private Investigators retained by Liberty Center for God and Country to investigate the alleged voter fraud in Harris County leading up to the 2020 election Interrogatory # Please list all investigators and/or assistants including their names, addresses and contact information and any employment information Liberty Center for God and Country and/or Steven Hotze kept on file who were involved in the investigation or surveillance of David Lopez including the individual who moved David Lopez’s truck and searched his vehicle for the alleged missing ballots. Interrogatory Please describe what the budget was given to each Private Investigator in order to investigate voter fraud and any financial incentive to locate fraud in the 2020 presidential election. Interrogatory # : Please describe in detail how Mark Aguirre and/or his company were retained to investigate voter fraud in the 2020 presidential election. Plaintiff has alleged Hotze and the Center are vicariously liable for the torts committed against Lopez by Mark Aguirre and other investigators working for the Center In press conferences Hotze has referred numerous times to “our investigators” and to Mark Aguirre as “one of our investigators.” Mr. Aguirre told Houston Police officer J. Valera that he “was part of the Liberty Center” and was investigating voter fraud In a letter to President Trump posted on the Center’s website, Hotze acknowledges he “hired 20 private investigators to discover, expose and disrupt the massive vote harvesting election fraud scheme of the Democrat communists in Harris County, Houston, Texas (See affidavit of Houston Police Officer Valera marked hereto as Exhibit and Hotze’s letter to President Trump marked hereto as Exhibit Interrogatories 1 ,and1 seek relevant information as to how and why David Lopez was targeted by the Center. errogatory # : Please list the name of the individual and/or individuals that provided information to the Liberty Center for God and Country or Steven Hotze and/or investigators that lead to the belief that the Plaintiff was involved in the alleged voter fraud for the 2020 election. Interrogatory # : Please describe the thought process on why Liberty Center for God and Country or Steven Hotze believed that David Lopez was guilty of voter fraud. Interrogatory # Please describe in detail why David Lopez was suspected of voter fraud. nformati as to why investigators working for the Center targeted and assaulted Plaintiff and what information the Center provided to the private investigators is directly discoverable and relevant to Plaintiff's claims Interrogatories and seek information as to the means and methods used by the Center to identify and target alleged participants in voter fraud such as Plaintiff. Interrogatory # Please list the name and addresses of all individuals who were implicated in a voter fraud scheme for the 2020 presidential election by any investigation conducted by any private investigator retained by Liberty Center for God and Country and/or Steven Hotze and the name of the private investigator and/or individual who implicated the person or persons who were allegedly involved in voter fraud. Interrogatory # : Please list all individuals that Liberty Center for God and Country had under surveillance for the past 5 years. Prior individuals targeted, implicated and/or kept under surveillance by the Center could have relevant information as to the methods used to target and implicate individuals such as Plaintiff Such information is relevant and certainly discoverable on the issues of pattern and practice of hiring private investigators to surveil individuals like David Lopez. ONCLUSION The requested information goes to the heart of Plaintiff's case and should be produced to Plaintiff in complete answers and responses to his written discovery requests. For the foregoing reasons, Plaintiff David Lopez asks the Court to compel Defendant to fully answer and/or respond to Plaintiff's written discovery requests within 10 days of the Court’s order and for such other and further relief, at law or in equity, that Plaintiff may show himself to be justly entitled Respectfully submitted, BRAZIL & DUNN, LLP /s/ K. Scott Brazil K. Scott Brazil 13231 Champion Forest Dr., Suite 406 Houston, Texas 77068 Telephone (281) 580 Facsimile (281) 580 scott@brazilanddunn.com LAW OFFICE OF DICKY GRIGG, P.C Dicky Grigg Dicky Grigg 4407 Bee Caves Rd., Suite 111 Bldg 1 West Lake Hills, Texas 7874 Telephone (512) 474 Facsimile (512) 582 dicky @grigg law.com ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE Plaintiff Supplemental Brief in Support of Plaintiff’s Motion to Compel Production of Documents from District Attorney Pursuant to Subpoena have been served upon all counsel of record in compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on this the 12th July, /s/__K. Scott Brazil K. Scott Brazil