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JUSTIN JORDAN, IN THE DISTRICT COURT
VS. OF HARRIS COUNTY, T E X A S
VOPAK TERMINAL DEER PARK INC.
AND VOPAK NORTH AMERICA INC.
(d/b/a VOPAK AMERICAS), 129TH JUDICIAL DISTRICT
DEFENDANTS’ NOTICE OF INTENT TO SERVE
SUBPOENA DUCES TECUM TO KARRI VAUGHN
TO: Karri Vaughn, 57 CR 412, Dayton, Texas 77535
Please take notice that Defendants, Vopak Terminal Deer Park Inc., and Vopak North
America Inc. will serve non-party Karri Vaughn the subpoena duces tecum and Request for
Production of Documents attached hereto collectively as Exhibit “A” ten (10) days from this date,
for inspection and copying of the documents requested therein, at 10:00 a.m. on February 28, 2018,
or at an earlier time and place mutually agreeable, at the offices of Bracewell LLP, South Tower
Respectfully submitted,
BRACEWELL LLP
/s/ William A. Moss
Christopher L. Dodson
State Bar No. 24050519
William A. Moss
State Bar No. 24078041
Email: Chris.dodson@bracewell.com
Email: Will.moss@bracewell.com
TTORNEYS FOR EFENDANT
ERMINAL EER
MERICA
MERICA
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing pleading has been forwarded
Jim Cole
ILLIAMS
302 W. Forrest Street
Email: jcole@ceswlaw.com
/s/ William A. Moss
William A. Moss
JUSTIN JORDAN, IN THE DISTRICT COURT
VS. OF HARRIS COUNTY, T E X A S
VOPAK TERMINAL DEER PARK INC.
AND VOPAK NORTH AMERICA INC.
(d/b/a VOPAK AMERICAS), 129TH JUDICIAL DISTRICT
SUBPOENA DUCES TECUM TO KARRI VAUGHN
TO ANY SHERIFF OR CONSTABLE OF THE STATE OF TEXAS OR OTHER PERSON
AUTHORIZED TO SERVE AND EXECUTE SUBPOENAS AS PROVIDED IN RULE 1
RULES OF CIVIL PROCEDURE.
YOU ARE HEREBY COMMANDED TO SUMMON:
To provide to produce at the offices of BRACEWELL LLP, South Tower Pennzoil Place, 711 Louisiana,
Suite 2300, Houston, Texas 77002 by February 28, 2018, the following books, papers, documents, or
other tangible things, to wit: SEE ATTACHED EXHIBIT A.
to return this writ to said Court, with return thereon, showing the manner of
Respectfully submitted,
BRACEWELL LLP
/s/ William A. Moss
Christopher L. Dodson
State Bar No. 24050519
William A. Moss
State Bar No. 24078041
Email: Chris.dodson@bracewell.com
Email: Will.moss@bracewell.com
TTORNEYS FOR EFENDANT
ERMINAL EER
MERICA
MERICA
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Came to hand the day of ______, 2018, at o'clock _.m., and executed the ____
day of ______, 2018, at _____ o'clock _.m., by delivering to the within named
__________________________ in person at ___________________________________________ in
_____________________, a true copy of this Subpoena, and tendering said witness the sum of $10.00.
By Deputy:
Sheriff/Constable
____________
By:
Person who is not a party to the suit, and is not l
18 years of age
ACCEPTANCE OF SERVICE OF SUBPOENA BY WITNESS PER RULE 176 T.R.C
I, the undersigned witness name ceipt of a copy thereof, and hereby
subpoena, and will produce documents on said date and time directed in this
subpoena.
Rule 176.8(a) Contempt. Failure by any person without adequate excuse to obey a subpoena served
upon that person may be deemed a contempt of the court from which the subpoena is issued or a
district court in the county in which the subpoena is served, a
confinement, or both.
SIGNATURE OF WITNESS DATE
************************************************************************************
for the following reasons:
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EXHIBIT “A”
REQUESTS FOR PRODUCTION
All pictures, images, or videos of November 17, 2016 to present.
ANSWER:
All cell phone(s) and text message records for November 16, 2016 to present with, relating to, or
mentioning Plaintiff Justin Jordan, the Lawsuit, or his alleged injuries, including but not limited
to the identification and time of incoming and outgoing calls and text messages.
ANSWER:
All images, pictures, videos, posts, or content from any social media account you maintain,
including, but not limited to Facebook, Instagram, and Twitter, concerning or referring to
rom November 16, 2016 to present.
ANSWER:
For each Facebook account maintained by you, please produce your account data for the period
of November 16, 2016 through present. You may download and print your Facebook data by
logging onto your Facebook account, selecting “Account Settings” under the “Account” tab on
your homepage, clicking on the “learn more” link beside the “Download Your Information” tab,
page.
ANSWER:
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Please produce a complete compete of all pictures and content for each Instagram account
maintained by you for the period of November 16, 2016 through p
ANSWER:
Please produce a complete compete of all pictures and content for each Twitter account
maintained by you for the period of November 16, 2016 through p
ANSWER:
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JUSTIN JORDAN, IN THE DISTRICT COURT VS. OF HARRIS COUNTY, T E X A S VOPAK TERMINAL DEER PARK INC. AND VOPAK NORTH AMERICA INC. (d/b/a VOPAK AMERICAS), 129TH JUDICIAL DISTRICT DEFENDANTS’ NOTICE OF INTENT TO SERVE SUBPOENA DUCES TECUM TO KARRI VAUGHN TO: Karri Vaughn, 57 CR 412, Dayton, Texas 77535 Please take notice that Defendants, Vopak Terminal Deer Park Inc., and Vopak North America Inc. will serve non-party Karri Vaughn the subpoena duces tecum and Request for Production of Documents attached hereto collectively as Exhibit “A” ten (10) days from this date, for inspection and copying of the documents requested therein, at 10:00 a.m. on February 28, 2018, or at an earlier time and place mutually agreeable, at the offices of Bracewell LLP, South Tower Respectfully submitted, BRACEWELL LLP /s/ William A. Moss Christopher L. Dodson State Bar No. 24050519 William A. Moss State Bar No. 24078041 Email: Chris.dodson@bracewell.com Email: Will.moss@bracewell.com TTORNEYS FOR EFENDANT ERMINAL EER MERICA MERICA CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing pleading has been forwarded Jim Cole ILLIAMS 302 W. Forrest Street Email: jcole@ceswlaw.com /s/ William A. Moss William A. Moss JUSTIN JORDAN, IN THE DISTRICT COURT VS. OF HARRIS COUNTY, T E X A S VOPAK TERMINAL DEER PARK INC. AND VOPAK NORTH AMERICA INC. (d/b/a VOPAK AMERICAS), 129TH JUDICIAL DISTRICT SUBPOENA DUCES TECUM TO KARRI VAUGHN TO ANY SHERIFF OR CONSTABLE OF THE STATE OF TEXAS OR OTHER PERSON AUTHORIZED TO SERVE AND EXECUTE SUBPOENAS AS PROVIDED IN RULE 1 RULES OF CIVIL PROCEDURE. YOU ARE HEREBY COMMANDED TO SUMMON: To provide to produce at the offices of BRACEWELL LLP, South Tower Pennzoil Place, 711 Louisiana, Suite 2300, Houston, Texas 77002 by February 28, 2018, the following books, papers, documents, or other tangible things, to wit: SEE ATTACHED EXHIBIT A. to return this writ to said Court, with return thereon, showing the manner of Respectfully submitted, BRACEWELL LLP /s/ William A. Moss Christopher L. Dodson State Bar No. 24050519 William A. Moss State Bar No. 24078041 Email: Chris.dodson@bracewell.com Email: Will.moss@bracewell.com TTORNEYS FOR EFENDANT ERMINAL EER MERICA MERICA -2- Came to hand the day of ______, 2018, at o'clock _.m., and executed the ____ day of ______, 2018, at _____ o'clock _.m., by delivering to the within named __________________________ in person at ___________________________________________ in _____________________, a true copy of this Subpoena, and tendering said witness the sum of $10.00. By Deputy: Sheriff/Constable ____________ By: Person who is not a party to the suit, and is not l 18 years of age ACCEPTANCE OF SERVICE OF SUBPOENA BY WITNESS PER RULE 176 T.R.C I, the undersigned witness name ceipt of a copy thereof, and hereby subpoena, and will produce documents on said date and time directed in this subpoena. Rule 176.8(a) Contempt. Failure by any person without adequate excuse to obey a subpoena served upon that person may be deemed a contempt of the court from which the subpoena is issued or a district court in the county in which the subpoena is served, a confinement, or both. SIGNATURE OF WITNESS DATE ************************************************************************************ for the following reasons: -3- EXHIBIT “A” REQUESTS FOR PRODUCTION All pictures, images, or videos of November 17, 2016 to present. ANSWER: All cell phone(s) and text message records for November 16, 2016 to present with, relating to, or mentioning Plaintiff Justin Jordan, the Lawsuit, or his alleged injuries, including but not limited to the identification and time of incoming and outgoing calls and text messages. ANSWER: All images, pictures, videos, posts, or content from any social media account you maintain, including, but not limited to Facebook, Instagram, and Twitter, concerning or referring to rom November 16, 2016 to present. ANSWER: For each Facebook account maintained by you, please produce your account data for the period of November 16, 2016 through present. You may download and print your Facebook data by logging onto your Facebook account, selecting “Account Settings” under the “Account” tab on your homepage, clicking on the “learn more” link beside the “Download Your Information” tab, page. ANSWER: -4- Please produce a complete compete of all pictures and content for each Instagram account maintained by you for the period of November 16, 2016 through p ANSWER: Please produce a complete compete of all pictures and content for each Twitter account maintained by you for the period of November 16, 2016 through p ANSWER: -5-