Preview
Electronically Filed
12/13/2018 4:41 PM
Hidalgo County District Clerks
Reviewed By: Celeste De La Rosa
CAUSE NO.C-4445-17-G
ALICIA PERALES IN THE DISTRICT COURT
AS REPRESENTATIVE OF THE
ESTATE OF MARIO A. PERALES,
AND AS NEXT OF FRIEND OF
S.M. PERALES AND
M.PERALES, JR., MINOR CHILDREN
370TH JUDICIAL DISTRICT
vs.
DANIEL SIEGER,INDIVIDUALLY
AND AS AN AGENT OF DEFENDANT
PEOPLE READY,INC. and
TEXAS SAI,INC. HIDALGO COUNTY,TEXAS
DEFENDANT'S,TEXAS SAI,INC. CROSS-NOTICE OF INTENTION TO TAKE ORAL
AND VIDEOTAPED DEPOSITION OF DANIEL SIEGER
To: Defendant/Cross-Defendant, Daniel Sieger, by and through his counsel of record:
Hon. Analisa Figueroa
Law Office of Analisa Figueroa, PLLC
514 Paredes Avenue, Suite H
Brownsville, Texas 78521
PLEASE TAKE NOTICE that pursuant to Texas Rule of Civil Procedure 199.1(a),
199.2 and 199.5, the oral and videotaped deposition of defendant, DANIEL SIEGER, will be
taken at Hill & Romero located at 3700 N. 10th Street, Suite 220, McAllen, Texas 78501 on
Friday, January 4, 2019 beginning at 1:30 p.m.(CST) and continuing from day to day until
completed, before a certified court reporter.
PLEASE TAKE FURTHER NOTICE that pursuant to Texas Rule of Civil Procedure
199.1(c), the deposition will be recorded by videotape. Therefore, a video technician will be
present.
PLEASE TAKE FURTHER NOTICE that in connection with the taking of this
deposition and pursuant to Rule 199.2(b)(2)(5) of the Texas Rules of Civil Procedure, the
62466: 10384272
Electronically Filed
12/13/2018 4:41 PM
Hidalgo County District Clerks
Reviewed By: Celeste De La Rosa
deponent shall produce the documents and tangible items identified in the attached subpoena
duces tecum and described in Exhibit "A," which is attached hereto and incorporated herein by
reference for all purposes the same as if written verbatim herein, at the commencement of the
taking ofthe deposition.
PLEASE TAKE FURTHER NOTICE that pursuant to Texas Rules of Civil Procedure
199.2(b)(4) and 199.5(a)(3), the persons who may attend the deposition shall be the witness, the
parties, spouses of parties, counsel, employees of counsel and the court reporter taking the
deposition and videographer videotaping it.
You are invited to attend and cross-examine the witness.
Respectfully submitted,
ROYSTON, R, VICKERY & WILLIAMS,
L.L.P.
4
By:
Javier Go alez
Texas State Bar No. 00787561
E-Mail: Javier.Gonzalezgroystonlaw.com
Attorney for Defendant,
TEXAS SAI,INC.
Of Counsel:
ROYSTON,RAYZOR,VICKERY & WILLIAMS,L.L.P.
55 Cove Circle
P. O. Box 3509
Brownsville, Texas 78523-3509
Tel: (956) 542-4377
Fax: (956) 542-4370
62466: 10384272
Electronically Filed
12/13/2018 4:41 PM
Hidalgo County District Clerks
Reviewed By: Celeste De La Rosa
CERTIFICATE OF SERVICE
I certify that on the ay of December, 2018, a true and correct copy of the
foregoing document was caused to be served upon all counsel of record via E-File/E-Service/E-
Mail and/or Regular U.S. Mail, as follows:
Hon. Ricardo Gonzalez
Oxford & Gonzalez
124 S. 12th
Edinburg, Texas 78540
Hon. Michael S. Beckelman
Hon. Michelle R. Scheiffele
Wilson, Elser, Moskowitz, Edelman & Dicker, LLP
909 Fannin Street, Suite 3300
Houston, Texas 77010
Hon. Analisa Figueroa
Law Office of Analisa Figueroa, PLLC
514 Paredes Avenue, Suite H
Brownsville, Texas 78521
0,
Of Royston, ayzor, Vickery & Williams, L.L.P.
62466: 10384272
Electronically Filed
12/13/2018 4:41 PM
Hidalgo County District Clerks
Reviewed By: Celeste De La Rosa
EXHIBIT "A"
SUBPOENA DUCES TECUM
1. Any and all notes, documents, statements, reports or diaries kept as a result of the
incident in question or relating to it, not produced in written discovery already.
2. Any and all photographs, videotapes or audio recordings relevant to the incident
in question or relating to it, not produced in written discovery already.
3. A current driver's license, and any other licenses or certifications, educational or
otherwise, held or obtained by you from August of2017 to the present.
4. Any and all documents and items relating to or referring to your medical
treatment and bills as a result of the incident in question or relating to it not
produced in written discovery already.
5. Any documents from any arrests, criminal convictions or probation conditions.
9. Any documents or items you intend to use at trial.
10. Any documents, video or photographs on any ofthe defendants or their business.
11. Any documents or items from your employment with PeopleReady, Inc.,
including but not limited to your employment/personnel file.
12. Any documents or items from your employment with True Blue Enterprises, Inc.,
including but not limited to your employment/personnel file.
13. Any documents or items from your employment with Blue Team Restoration,
LLC,including but not limited to your employment/personnel file.
62466: 10384272
Preview
Electronically Filed 12/13/2018 4:41 PM Hidalgo County District Clerks Reviewed By: Celeste De La Rosa CAUSE NO.C-4445-17-G ALICIA PERALES IN THE DISTRICT COURT AS REPRESENTATIVE OF THE ESTATE OF MARIO A. PERALES, AND AS NEXT OF FRIEND OF S.M. PERALES AND M.PERALES, JR., MINOR CHILDREN 370TH JUDICIAL DISTRICT vs. DANIEL SIEGER,INDIVIDUALLY AND AS AN AGENT OF DEFENDANT PEOPLE READY,INC. and TEXAS SAI,INC. HIDALGO COUNTY,TEXAS DEFENDANT'S,TEXAS SAI,INC. CROSS-NOTICE OF INTENTION TO TAKE ORAL AND VIDEOTAPED DEPOSITION OF DANIEL SIEGER To: Defendant/Cross-Defendant, Daniel Sieger, by and through his counsel of record: Hon. Analisa Figueroa Law Office of Analisa Figueroa, PLLC 514 Paredes Avenue, Suite H Brownsville, Texas 78521 PLEASE TAKE NOTICE that pursuant to Texas Rule of Civil Procedure 199.1(a), 199.2 and 199.5, the oral and videotaped deposition of defendant, DANIEL SIEGER, will be taken at Hill & Romero located at 3700 N. 10th Street, Suite 220, McAllen, Texas 78501 on Friday, January 4, 2019 beginning at 1:30 p.m.(CST) and continuing from day to day until completed, before a certified court reporter. PLEASE TAKE FURTHER NOTICE that pursuant to Texas Rule of Civil Procedure 199.1(c), the deposition will be recorded by videotape. Therefore, a video technician will be present. PLEASE TAKE FURTHER NOTICE that in connection with the taking of this deposition and pursuant to Rule 199.2(b)(2)(5) of the Texas Rules of Civil Procedure, the 62466: 10384272 Electronically Filed 12/13/2018 4:41 PM Hidalgo County District Clerks Reviewed By: Celeste De La Rosa deponent shall produce the documents and tangible items identified in the attached subpoena duces tecum and described in Exhibit "A," which is attached hereto and incorporated herein by reference for all purposes the same as if written verbatim herein, at the commencement of the taking ofthe deposition. PLEASE TAKE FURTHER NOTICE that pursuant to Texas Rules of Civil Procedure 199.2(b)(4) and 199.5(a)(3), the persons who may attend the deposition shall be the witness, the parties, spouses of parties, counsel, employees of counsel and the court reporter taking the deposition and videographer videotaping it. You are invited to attend and cross-examine the witness. Respectfully submitted, ROYSTON, R, VICKERY & WILLIAMS, L.L.P. 4 By: Javier Go alez Texas State Bar No. 00787561 E-Mail: Javier.Gonzalezgroystonlaw.com Attorney for Defendant, TEXAS SAI,INC. Of Counsel: ROYSTON,RAYZOR,VICKERY & WILLIAMS,L.L.P. 55 Cove Circle P. O. Box 3509 Brownsville, Texas 78523-3509 Tel: (956) 542-4377 Fax: (956) 542-4370 62466: 10384272 Electronically Filed 12/13/2018 4:41 PM Hidalgo County District Clerks Reviewed By: Celeste De La Rosa CERTIFICATE OF SERVICE I certify that on the ay of December, 2018, a true and correct copy of the foregoing document was caused to be served upon all counsel of record via E-File/E-Service/E- Mail and/or Regular U.S. Mail, as follows: Hon. Ricardo Gonzalez Oxford & Gonzalez 124 S. 12th Edinburg, Texas 78540 Hon. Michael S. Beckelman Hon. Michelle R. Scheiffele Wilson, Elser, Moskowitz, Edelman & Dicker, LLP 909 Fannin Street, Suite 3300 Houston, Texas 77010 Hon. Analisa Figueroa Law Office of Analisa Figueroa, PLLC 514 Paredes Avenue, Suite H Brownsville, Texas 78521 0, Of Royston, ayzor, Vickery & Williams, L.L.P. 62466: 10384272 Electronically Filed 12/13/2018 4:41 PM Hidalgo County District Clerks Reviewed By: Celeste De La Rosa EXHIBIT "A" SUBPOENA DUCES TECUM 1. Any and all notes, documents, statements, reports or diaries kept as a result of the incident in question or relating to it, not produced in written discovery already. 2. Any and all photographs, videotapes or audio recordings relevant to the incident in question or relating to it, not produced in written discovery already. 3. A current driver's license, and any other licenses or certifications, educational or otherwise, held or obtained by you from August of2017 to the present. 4. Any and all documents and items relating to or referring to your medical treatment and bills as a result of the incident in question or relating to it not produced in written discovery already. 5. Any documents from any arrests, criminal convictions or probation conditions. 9. Any documents or items you intend to use at trial. 10. Any documents, video or photographs on any ofthe defendants or their business. 11. Any documents or items from your employment with PeopleReady, Inc., including but not limited to your employment/personnel file. 12. Any documents or items from your employment with True Blue Enterprises, Inc., including but not limited to your employment/personnel file. 13. Any documents or items from your employment with Blue Team Restoration, LLC,including but not limited to your employment/personnel file. 62466: 10384272