Preview
Received and E-Filed for Record
1/11/2021 12:34 PM
Melisa Miller, District Clerk
Montgomery County, Texas
Deputy Clerk, Jeff Fiore
CAUSE NO. 17-10-12820
DANIEL COHEN, INDIVIDUALLY AND AS NEXT §
FRIEND FOR RENEE COHEN , ALBERT §
COHEN, LAUREN COHEN, AND MARTIN §
COHEN, ET AL § IN THE 457th Judicial District Court
PLAINTIFF
§
MONTGOMERY COUNTY, TX
§
VS.
§
CHICAGO BRIDGE & IRON COMPANY N.V., §
ET AL §
DEFENDANT §
RETURN OF SERVICE
ON Friday, January 8, 2021 AT 10:05 AM
SUBPOENA, WITNESS FEE CHECK for service on MCDERMOTT INTERNATIONAL, INC. came to hand.
ON Monday, January 11, 2021 AT 11:20 AM, I, Jayme Chacon, PERSONALLY DELIVERED
THE ABOVE-NAMED DOCUMENTS TO: MCDERMOTT INTERNATIONAL, INC., by delivering to Steve
Stallings, 915 N. ELDRIDGE PKWY, HOUSTON, HARRIS COUNTY, TX 77079.
My name is Jayme Chacon. I am over the age of eighteen. I am not a party to this case and have no
interest in its outcome. This Return is prepared in conformity with Texas Civil Practices and Remedies
Code §132.001.
Executed in HARRIS COUNTY, TX on Monday, January 11, 2021 AT 11:20 AM.
/S/ Jayme Chacon
Jayme Chacon
1201 Louisiana, Suite 370
Houston, TX 77002
2162.001
Doc ID: 278734_1
CLERK OF THE COURT David J. Beck
Melisa Miller, District Clerk on behalf of Plaintiffs
P.O. Box 2985
Conroe, Tx 77305
THE STATE OF TEXAS
SUBPOENA
PURSUANT TO THE TEXAS RULES OF CIVIL PROCEDURE 176
Cause No. 17-10-12820
DANIEL COHEN, individually and as next § IN THE DISTRICT COURT OF
friend for RENEE COHEN, ALBERT §
COHEN, LAUREN COHEN, and MARTIN §
COHEN; BETTIE COHEN; ZEPHYR OIL §
& GAS FUNDING CO. LLC; ZEPHYR §
ACQUISITION HOLDINGS LLC; COHEN §
CAPITAL MANAGEMENT, LLC; COHEN §
ASSET MANAGEMENT LLC; and RMS §
CONTEMPORARY LLC, § MONTGOMERY COUNTY, TEXAS
§
Plaintiffs, §
§
vs. §
§
CHICAGO BRIDGE & IRON COMPANY §
N.V.; PHILIP K. ASHERMAN; §
RONALD A. BALLSCHMIEDE; and §
WESTLEY S. STOCKTON, §
§
Defendants. § 457TH JUDICIAL DISTRICT
TO ANY SHERIFF, CONSTABLE OF THE STATE OF TEXAS, OR ANY PERSON
AUTHORIZED TO EXECUTE SUBPOENAS AS PROVIDED IN RULE 176 T.R.C.P.
YOU ARE HEREBY COMMANDED TO SUMMON:
McDermott International, Inc.,
915 N. Eldridge Pkwy., Houston, TX 77079
In Harris County Texas
To be and personally appear before the 457th Judicial District Court, located in Conroe, Texas, on
the 19th day of January, 2021, at 9 o’clock A.M., to testify as a witness on behalf of the Plaintiffs
in the above styled Action, to attend from day to day until lawfully discharged. McDermott
International, Inc., through a custodian of records, will testify on the authenticity and general
1
admissibility of business records produced by Chicago Bridge & Iron Company, N.V. (McDermott
International, Inc.’s predecessor in interest) in discovery in this case. More specifically, the
witness should be familiar with the manner in which its records are created and maintained, the
manner in which the records were created and maintained by Chicago Bridge & Iron Company,
N.V., and the manner in which the records produced in discovery in this case were created and
maintained.
McDermott International, Inc. resides within one hundred fifty miles of the Courthouse of
Montgomery County, Texas, in which the above suit is pending, or may be found within such
distance at the time of the trial.
This subpoena was issued at the insistence of Plaintiffs, whose attorney of record is:
David J. Beck
Texas Bar No. 00000070
Beck Redden LLP
1221 McKinney Street, Suite 4500
Houston, Texas 77010
Phone: (713) 951-3700
Fax: (713) 951-3720
DO NOT FAIL to return this writ to said Court, with return thereon, showing the manner of
execution.
ISSUED this the 6th day of January, 2021.
Respectfully Submitted,
BECK REDDEN LLP
/s/ David J. Beck
David J. Beck
Texas Bar No. 00000070
dbeck@beckredden.com
David W. Jones
Texas Bar No. 00790980
djones@beckredden.com
Garrett S. Brawley
Texas Bar No. 24095812
gbrawley@beckredden.com
1221 McKinney, Suite 4500
Houston, Texas 77010
Phone: (713) 951-3700
2
Preview
Received and E-Filed for Record 1/11/2021 12:34 PM Melisa Miller, District Clerk Montgomery County, Texas Deputy Clerk, Jeff Fiore CAUSE NO. 17-10-12820 DANIEL COHEN, INDIVIDUALLY AND AS NEXT § FRIEND FOR RENEE COHEN , ALBERT § COHEN, LAUREN COHEN, AND MARTIN § COHEN, ET AL § IN THE 457th Judicial District Court PLAINTIFF § MONTGOMERY COUNTY, TX § VS. § CHICAGO BRIDGE & IRON COMPANY N.V., § ET AL § DEFENDANT § RETURN OF SERVICE ON Friday, January 8, 2021 AT 10:05 AM SUBPOENA, WITNESS FEE CHECK for service on MCDERMOTT INTERNATIONAL, INC. came to hand. ON Monday, January 11, 2021 AT 11:20 AM, I, Jayme Chacon, PERSONALLY DELIVERED THE ABOVE-NAMED DOCUMENTS TO: MCDERMOTT INTERNATIONAL, INC., by delivering to Steve Stallings, 915 N. ELDRIDGE PKWY, HOUSTON, HARRIS COUNTY, TX 77079. My name is Jayme Chacon. I am over the age of eighteen. I am not a party to this case and have no interest in its outcome. This Return is prepared in conformity with Texas Civil Practices and Remedies Code §132.001. Executed in HARRIS COUNTY, TX on Monday, January 11, 2021 AT 11:20 AM. /S/ Jayme Chacon Jayme Chacon 1201 Louisiana, Suite 370 Houston, TX 77002 2162.001 Doc ID: 278734_1 CLERK OF THE COURT David J. Beck Melisa Miller, District Clerk on behalf of Plaintiffs P.O. Box 2985 Conroe, Tx 77305 THE STATE OF TEXAS SUBPOENA PURSUANT TO THE TEXAS RULES OF CIVIL PROCEDURE 176 Cause No. 17-10-12820 DANIEL COHEN, individually and as next § IN THE DISTRICT COURT OF friend for RENEE COHEN, ALBERT § COHEN, LAUREN COHEN, and MARTIN § COHEN; BETTIE COHEN; ZEPHYR OIL § & GAS FUNDING CO. LLC; ZEPHYR § ACQUISITION HOLDINGS LLC; COHEN § CAPITAL MANAGEMENT, LLC; COHEN § ASSET MANAGEMENT LLC; and RMS § CONTEMPORARY LLC, § MONTGOMERY COUNTY, TEXAS § Plaintiffs, § § vs. § § CHICAGO BRIDGE & IRON COMPANY § N.V.; PHILIP K. ASHERMAN; § RONALD A. BALLSCHMIEDE; and § WESTLEY S. STOCKTON, § § Defendants. § 457TH JUDICIAL DISTRICT TO ANY SHERIFF, CONSTABLE OF THE STATE OF TEXAS, OR ANY PERSON AUTHORIZED TO EXECUTE SUBPOENAS AS PROVIDED IN RULE 176 T.R.C.P. YOU ARE HEREBY COMMANDED TO SUMMON: McDermott International, Inc., 915 N. Eldridge Pkwy., Houston, TX 77079 In Harris County Texas To be and personally appear before the 457th Judicial District Court, located in Conroe, Texas, on the 19th day of January, 2021, at 9 o’clock A.M., to testify as a witness on behalf of the Plaintiffs in the above styled Action, to attend from day to day until lawfully discharged. McDermott International, Inc., through a custodian of records, will testify on the authenticity and general 1 admissibility of business records produced by Chicago Bridge & Iron Company, N.V. (McDermott International, Inc.’s predecessor in interest) in discovery in this case. More specifically, the witness should be familiar with the manner in which its records are created and maintained, the manner in which the records were created and maintained by Chicago Bridge & Iron Company, N.V., and the manner in which the records produced in discovery in this case were created and maintained. McDermott International, Inc. resides within one hundred fifty miles of the Courthouse of Montgomery County, Texas, in which the above suit is pending, or may be found within such distance at the time of the trial. This subpoena was issued at the insistence of Plaintiffs, whose attorney of record is: David J. Beck Texas Bar No. 00000070 Beck Redden LLP 1221 McKinney Street, Suite 4500 Houston, Texas 77010 Phone: (713) 951-3700 Fax: (713) 951-3720 DO NOT FAIL to return this writ to said Court, with return thereon, showing the manner of execution. ISSUED this the 6th day of January, 2021. Respectfully Submitted, BECK REDDEN LLP /s/ David J. Beck David J. Beck Texas Bar No. 00000070 dbeck@beckredden.com David W. Jones Texas Bar No. 00790980 djones@beckredden.com Garrett S. Brawley Texas Bar No. 24095812 gbrawley@beckredden.com 1221 McKinney, Suite 4500 Houston, Texas 77010 Phone: (713) 951-3700 2