On June 20, 2019 a
Party Discovery
was filed
involving a dispute between
Rendon, Edgar Benito,
and
Allstate County Mutual Insurance Company,
Allstate New Jersey Insurance Company,
Gonzalez, Alberto,
for Injury or Damage - Motor Vehicle (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Filed
5/12/2023 7:21 PM
Hidalgo County District Clerks
Reviewed By: Priscilla Rivas
CAUSE NO. C-2719-19-J
IN THE DISTRICT COURT
EDGAR BENITO RENDON
v.
430TH JUDICIAL DISTRICT
ALBERTO GONZALEZ, ALLSTATE
COUNTY MUTUAL INSURANCE
COMPANY AND ALLSTATE NEW
HIDALGO COUNTY, TEXAS
JERSEY INSURANCE COMPANY
MOTION TO COMPEL DEPOSITION OF THE CORPORATE
REPRESENTATIVE OF ALLSTATE NEW JERSEY INSURANCE COMPANY
COMES NOW, Plaintiff Edgar Benito Rendon, in the above-entitled and numbered cause,
and files this Motion to Compel Deposition of the Corporate Representative of Allstate New
Jersey Insurance Company. Plaintiff asks that the Court compel Defendant’s corporate
representative to be produced for deposition. In support thereof, Plaintiff respectfully show the
Court the following:
This is a claim for damages under Plaintiff’s UM/UIM insurance coverage. Plaintiff was
involved in a motor vehicle collision on or about June 27, 2017 wherein Plaintiff sustained
injuries and damages. The at-fault driver in this collision did not maintain auto liability
coverage. Defendant Allstate New Jersey Insurance Company issued an auto insurance policy
to Plaintiff that provided benefits for uninsured and underinsured motorist coverage that was in
effect at the time of the crash.
Plaintiff has made several attempts to confer with counsel for Defendant on a deposition
date for the Defendant’s corporate representative. After no responses, Plaintiff unilaterally
noticed the deposition, which was quashed. Plaintiff now seeks the Court’s intervention to
compel a corporate representative for Defendant be produced for deposition.
Electronically Filed
5/12/2023 7:21 PM
Hidalgo County District Clerks
Reviewed By: Priscilla Rivas
WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that this Motion be granted
and that Defendant be compelled to produce a corporate representative within ten (10) days of
the date of the hearing on this Motion. Plaintiff further prays for any and all other relief, in law
or in equity, to which he is so justly entitled.
Respectfully submitted,
By: Natalie M. Arledge_____
Natalie M. Arledge
Texas Bar No. 24073464
COWEN | RODRIGUEZ | PEACOCK, P.C.
6243 W IH-10, STE 801
San Antonio, TX 78201
T (210) 941-1301
F (210) 880-9461
Email for Service: efilings@cowenlaw.com
COUNSEL FOR PLAINTIFF
CERTIFICATE OF CONFERENCE
I conferred with defense counsel by regarding the issues in this Motion. The disputes in
this Motion remain unresolved.
By: Natalie M. Arledge_____
Natalie M. Arledge
MOTION TO COMPEL DEPOSITION PAGE 2 OF 3
Electronically Filed
5/12/2023 7:21 PM
Hidalgo County District Clerks
Reviewed By: Priscilla Rivas
CERTIFICATE OF SERVICE
I certify that a copy of the foregoing document was served on the following counsel of
record pursuant to the Texas Rules of Civil Procedure on May 12, 2023.
Rosemary Conrad-Sandoval Via E-Serve
Roerig, Oliveira & Fisher, L.L.P.
10225 N. 10th Street.
McAllen, Texas 78504
ATTORNEYS FOR DEFENDANT
ALLSTATE COUNTY MUTUAL
INSURANCE COMPANY
Marion R. Lawler III
Edmundo Leandro III
LAWLER & ASSOCIATES, P.C.
805 Media Luna Street, Suite 620
Brownsville, Texas 78520
ATTORNEYS FOR DEFENDANT
ALLSTATE NEW JERSEY INSURANCE COMPANY
By: Natalie M. Arledge_____
Natalie M. Arledge
MOTION TO COMPEL DEPOSITION PAGE 3 OF 3
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Michael Cowen
Bar No. 795306
efilings@cmbtrial.com
Envelope ID: 75610937
Filing Code Description: Motion (No Fee)
Filing Description: Plaintiff's Motion to Compel Deposition of the Corporate
Representative of Allstate New Jersey Insurance Company
Status as of 5/15/2023 9:10 AM CST
Associated Case Party: EdgarBenitoRendon
Name BarNumber Email TimestampSubmitted Status
Michael Cowen efilings@cowenlaw.com 5/12/2023 7:21:40 PM SENT
Roberto Salazar robertsalazarlaw@gmail.com 5/12/2023 7:21:40 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Marion R.Lawler nmartinez@lawler3firm.com 5/12/2023 7:21:40 PM SENT
Rosemary Sandoval rsandoval@rofllp.com 5/12/2023 7:21:40 PM SENT
ROBERTO SALAZAR corina@robertsalazar.com 5/12/2023 7:21:40 PM SENT
E LEANDRO ELEANDRO@LAWLER3FIRM.COM 5/12/2023 7:21:40 PM SENT
Nikki Pugmire nikkip@rofllp.com 5/12/2023 7:21:40 PM SENT
Document Filed Date
May 12, 2023
Case Filing Date
June 20, 2019
Category
Injury or Damage - Motor Vehicle (OCA)
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Preview
Electronically Filed 5/12/2023 7:21 PM Hidalgo County District Clerks Reviewed By: Priscilla Rivas CAUSE NO. C-2719-19-J IN THE DISTRICT COURT EDGAR BENITO RENDON v. 430TH JUDICIAL DISTRICT ALBERTO GONZALEZ, ALLSTATE COUNTY MUTUAL INSURANCE COMPANY AND ALLSTATE NEW HIDALGO COUNTY, TEXAS JERSEY INSURANCE COMPANY MOTION TO COMPEL DEPOSITION OF THE CORPORATE REPRESENTATIVE OF ALLSTATE NEW JERSEY INSURANCE COMPANY COMES NOW, Plaintiff Edgar Benito Rendon, in the above-entitled and numbered cause, and files this Motion to Compel Deposition of the Corporate Representative of Allstate New Jersey Insurance Company. Plaintiff asks that the Court compel Defendant’s corporate representative to be produced for deposition. In support thereof, Plaintiff respectfully show the Court the following: This is a claim for damages under Plaintiff’s UM/UIM insurance coverage. Plaintiff was involved in a motor vehicle collision on or about June 27, 2017 wherein Plaintiff sustained injuries and damages. The at-fault driver in this collision did not maintain auto liability coverage. Defendant Allstate New Jersey Insurance Company issued an auto insurance policy to Plaintiff that provided benefits for uninsured and underinsured motorist coverage that was in effect at the time of the crash. Plaintiff has made several attempts to confer with counsel for Defendant on a deposition date for the Defendant’s corporate representative. After no responses, Plaintiff unilaterally noticed the deposition, which was quashed. Plaintiff now seeks the Court’s intervention to compel a corporate representative for Defendant be produced for deposition. Electronically Filed 5/12/2023 7:21 PM Hidalgo County District Clerks Reviewed By: Priscilla Rivas WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that this Motion be granted and that Defendant be compelled to produce a corporate representative within ten (10) days of the date of the hearing on this Motion. Plaintiff further prays for any and all other relief, in law or in equity, to which he is so justly entitled. Respectfully submitted, By: Natalie M. Arledge_____ Natalie M. Arledge Texas Bar No. 24073464 COWEN | RODRIGUEZ | PEACOCK, P.C. 6243 W IH-10, STE 801 San Antonio, TX 78201 T (210) 941-1301 F (210) 880-9461 Email for Service: efilings@cowenlaw.com COUNSEL FOR PLAINTIFF CERTIFICATE OF CONFERENCE I conferred with defense counsel by regarding the issues in this Motion. The disputes in this Motion remain unresolved. By: Natalie M. Arledge_____ Natalie M. Arledge MOTION TO COMPEL DEPOSITION PAGE 2 OF 3 Electronically Filed 5/12/2023 7:21 PM Hidalgo County District Clerks Reviewed By: Priscilla Rivas CERTIFICATE OF SERVICE I certify that a copy of the foregoing document was served on the following counsel of record pursuant to the Texas Rules of Civil Procedure on May 12, 2023. Rosemary Conrad-Sandoval Via E-Serve Roerig, Oliveira & Fisher, L.L.P. 10225 N. 10th Street. McAllen, Texas 78504 ATTORNEYS FOR DEFENDANT ALLSTATE COUNTY MUTUAL INSURANCE COMPANY Marion R. Lawler III Edmundo Leandro III LAWLER & ASSOCIATES, P.C. 805 Media Luna Street, Suite 620 Brownsville, Texas 78520 ATTORNEYS FOR DEFENDANT ALLSTATE NEW JERSEY INSURANCE COMPANY By: Natalie M. Arledge_____ Natalie M. Arledge MOTION TO COMPEL DEPOSITION PAGE 3 OF 3 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Michael Cowen Bar No. 795306 efilings@cmbtrial.com Envelope ID: 75610937 Filing Code Description: Motion (No Fee) Filing Description: Plaintiff's Motion to Compel Deposition of the Corporate Representative of Allstate New Jersey Insurance Company Status as of 5/15/2023 9:10 AM CST Associated Case Party: EdgarBenitoRendon Name BarNumber Email TimestampSubmitted Status Michael Cowen efilings@cowenlaw.com 5/12/2023 7:21:40 PM SENT Roberto Salazar robertsalazarlaw@gmail.com 5/12/2023 7:21:40 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Marion R.Lawler nmartinez@lawler3firm.com 5/12/2023 7:21:40 PM SENT Rosemary Sandoval rsandoval@rofllp.com 5/12/2023 7:21:40 PM SENT ROBERTO SALAZAR corina@robertsalazar.com 5/12/2023 7:21:40 PM SENT E LEANDRO ELEANDRO@LAWLER3FIRM.COM 5/12/2023 7:21:40 PM SENT Nikki Pugmire nikkip@rofllp.com 5/12/2023 7:21:40 PM SENT