On December 22, 2020 a
Response - Answer/Response
was filed
involving a dispute between
Zolilla, Mirta,
and
Luna, Francisco,
for Contract - Consumer/Commercial/Debt (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Submitted
4/12/2021 10:30 AM
Hidalgo County Clerk
Accepted by: Ester Espinoza
exhibit a
CAUSE NO. CL-20-4670-E
DR. MIRTA ZORILLA § IN THE COUNTY COURT
§
Plaintiff, §
§
v. § AT LAW NUMBERS
§
FRANCISCO R. LUNA D/B/A F&R
LANDSCAPING
§
Defendant § HIDALGO COUNTY, TEXAS
DEFENDANT'S RESPONSE TO PLAINTIFF'S REQUEST FOR DISCLOSURE
To Plaintiff, Dr. Mirta Zorilla, by and through her attorney of record, Keith Livesay.
NOW COMES, FRANCISCO R. LUNA D/B/A F &R Landscaping, Defendant and submits
his response to Plaintiffs Request for Disclosure.
Law Office Of Javier Villalobos, P.C.
5804 N. 23rd Street
McAllen Texas 78504
Tel. (956) 687-4000
Fax. (956) 687-4001
By: /s/ Javier Villalobos
State Bar No. 00794793
Attorney for Plaintiff
Electronically Submitted
4/12/2021 10:30 AM
Hidalgo County Clerk
Accepted by: Ester Espinoza
CERTIFICATE OF SERVICE
I certify that on April 12, 2021 a true and correct copy of Defendants response to Plaintiffs
Request for Disclosure was served on opposing counsel
/s/ Javier Villalobos
JAVIER VILLALOBOS
Electronically Submitted
4/12/2021 10:30 AM
Hidalgo County Clerk
Accepted by: Ester Espinoza
(A) The correct names of the parties to this lawsuit;
Francisco R. Luna d/b/a F&R Landscaping – Defendant
Mirta Zorilla – Plaintiff
(B) The name, address and telephone number of any potential parties;
None.
(C) The legal theories and in general, the factual basis of the responding parties claim or
defenses;
Plaintiff and Defendant entered into an agreement and Defendant Mirta Zorilla
without cause or notice failed to pay all amounts due and owing to Plaintiff. Plaintiff prosecuted
claim and obtained judgment against defendant. Defendant did not file motion for new trial and
judgment became final. Time has run out on this current attempt to set aside judgment.
(D) The amount and any method of calculating economic damages;
As stated in judgment
(E) The name, address, and telephone number of persons having knowledge of relevant facts,
and a brief statement of each identified persons in connection with the case;
Francisco Luna
Mr. Luna has personal knowledge of agreement entered with Ms. Mirta Zorilla
Rosario R. Luna
Mrs. Luna has personal knowledge of agreement entered with Ms. Mirta Zorilla and
worked performed.
Mirta Zorilla
Ms. Zorilla has personal knowledge of agreement entered with F&R Landscaping.
Patty Mata
Ms. Mata has knowledge of work performed for Ms. Zorilla.
All counsel of record have information on litigation of underlying case.
(F) For any testifying expert;
(1) the expert's name, address and telephone number;
(2) the subject matter on which the expert will testify;
(3) the general substance of the experts' mental impressions and opinions and a
brief summary of the basis for them, or if the expert is not retained by,
Electronically Submitted
4/12/2021 10:30 AM
Hidalgo County Clerk
Accepted by: Ester Espinoza
employed by or otherwise subject to the control of the responding party,
documents reflecting such information;
(4) if the expert is retained by, employed by or otherwise subject to the control of
the responding party:
(a) all documents, tangible things, reports, models or data compilations
that have been provided to, reviewed by or prepared by or for the
expert in anticipation of the expert's testimony; and
(b) the expert's current resume and bibliography.
Plaintiff’s counsel will testify as to attorney fees if any, filings, discovery and necessary
work needed for prosecution of this matter.
None.
(G) Any indemnity and insuring agreements;
None.
(H) Any settlement agreements;
None.
(I) Any witness statements;
None
(J) In a suit alleging physical or mental injury and damages from the occurrence that is the
subject of the case, all medical records and bills that are reasonably related to the injuries or
damages asserted or, in lieu thereof, an authorization permitting the disclosure of such
medical records and bills;
Not applicable. .
(K) In a suit alleging physical or mental injury and damages form the occurrence that is the
subject of the case, all medical records and bills obtained by the responding party by virtue of
any authorization furnished by the requesting party;
Not applicable.
(L) The name, address, and telephone number of any person who may be designated as a
responsible third party;
None.
Document Filed Date
April 26, 2024
Case Filing Date
December 22, 2020
Category
Contract - Consumer/Commercial/Debt (OCA)
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Electronically Submitted 4/12/2021 10:30 AM Hidalgo County Clerk Accepted by: Ester Espinoza exhibit a CAUSE NO. CL-20-4670-E DR. MIRTA ZORILLA § IN THE COUNTY COURT § Plaintiff, § § v. § AT LAW NUMBERS § FRANCISCO R. LUNA D/B/A F&R LANDSCAPING § Defendant § HIDALGO COUNTY, TEXAS DEFENDANT'S RESPONSE TO PLAINTIFF'S REQUEST FOR DISCLOSURE To Plaintiff, Dr. Mirta Zorilla, by and through her attorney of record, Keith Livesay. NOW COMES, FRANCISCO R. LUNA D/B/A F &R Landscaping, Defendant and submits his response to Plaintiffs Request for Disclosure. Law Office Of Javier Villalobos, P.C. 5804 N. 23rd Street McAllen Texas 78504 Tel. (956) 687-4000 Fax. (956) 687-4001 By: /s/ Javier Villalobos State Bar No. 00794793 Attorney for Plaintiff Electronically Submitted 4/12/2021 10:30 AM Hidalgo County Clerk Accepted by: Ester Espinoza CERTIFICATE OF SERVICE I certify that on April 12, 2021 a true and correct copy of Defendants response to Plaintiffs Request for Disclosure was served on opposing counsel /s/ Javier Villalobos JAVIER VILLALOBOS Electronically Submitted 4/12/2021 10:30 AM Hidalgo County Clerk Accepted by: Ester Espinoza (A) The correct names of the parties to this lawsuit; Francisco R. Luna d/b/a F&R Landscaping – Defendant Mirta Zorilla – Plaintiff (B) The name, address and telephone number of any potential parties; None. (C) The legal theories and in general, the factual basis of the responding parties claim or defenses; Plaintiff and Defendant entered into an agreement and Defendant Mirta Zorilla without cause or notice failed to pay all amounts due and owing to Plaintiff. Plaintiff prosecuted claim and obtained judgment against defendant. Defendant did not file motion for new trial and judgment became final. Time has run out on this current attempt to set aside judgment. (D) The amount and any method of calculating economic damages; As stated in judgment (E) The name, address, and telephone number of persons having knowledge of relevant facts, and a brief statement of each identified persons in connection with the case; Francisco Luna Mr. Luna has personal knowledge of agreement entered with Ms. Mirta Zorilla Rosario R. Luna Mrs. Luna has personal knowledge of agreement entered with Ms. Mirta Zorilla and worked performed. Mirta Zorilla Ms. Zorilla has personal knowledge of agreement entered with F&R Landscaping. Patty Mata Ms. Mata has knowledge of work performed for Ms. Zorilla. All counsel of record have information on litigation of underlying case. (F) For any testifying expert; (1) the expert's name, address and telephone number; (2) the subject matter on which the expert will testify; (3) the general substance of the experts' mental impressions and opinions and a brief summary of the basis for them, or if the expert is not retained by, Electronically Submitted 4/12/2021 10:30 AM Hidalgo County Clerk Accepted by: Ester Espinoza employed by or otherwise subject to the control of the responding party, documents reflecting such information; (4) if the expert is retained by, employed by or otherwise subject to the control of the responding party: (a) all documents, tangible things, reports, models or data compilations that have been provided to, reviewed by or prepared by or for the expert in anticipation of the expert's testimony; and (b) the expert's current resume and bibliography. Plaintiff’s counsel will testify as to attorney fees if any, filings, discovery and necessary work needed for prosecution of this matter. None. (G) Any indemnity and insuring agreements; None. (H) Any settlement agreements; None. (I) Any witness statements; None (J) In a suit alleging physical or mental injury and damages from the occurrence that is the subject of the case, all medical records and bills that are reasonably related to the injuries or damages asserted or, in lieu thereof, an authorization permitting the disclosure of such medical records and bills; Not applicable. . (K) In a suit alleging physical or mental injury and damages form the occurrence that is the subject of the case, all medical records and bills obtained by the responding party by virtue of any authorization furnished by the requesting party; Not applicable. (L) The name, address, and telephone number of any person who may be designated as a responsible third party; None.