Preview
FILED
TARRANT COUNTY
342-314929-20 1/31/2020 1:46 PM
CAUSE NO. ____________ THOMAS A. WILDER
DISTRICT CLERK
AMBER EATON, § IN THE DISTRICT COURT
Plaintiff, §
§
v. § ____ JUDICIAL DISTRICT
§
SYDNEY SANCHEZ AND §
EDUARDO SANCHEZ, §
Defendants. § TARRANT COUNTY, TEXAS
PLAINTIFF'S ORIGINAL PETITION. DEMAND FOR JURY TRIAL,
RULE 193.7 NOTICE AND FIRST SET OF WRITTEN DISCOVERY TO DEFENDANTS
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, AMBER EATON, hereinafter “Plaintiff”, complaining of and about
SYDNEY SANCHEZ and EDUARDO SANCHEZ, hereinafter collectively “Defendants”, and for
cause of action would respectfully show the Court the following:
DISCOVERY CONTROL PLAN LEVEL
1. Plaintiff intends that discovery be conducted under Discovery Level 3.
PARTIES AND SERVICE
2. Plaintiff, AMBER EATON, is an individual and resident of the State of Texas whose
address for service is 9330 LBJ Freeway, Suite 120, Dallas, Texas 75243. The last three digits of
Plaintiff’s drivers’ license number are 331and the last three digits of Plaintiff’s social security number
are 330.
3. Defendant, SYDNEY SANCHEZ, is an individual and resident of the State of Texas
and may be served with process at the following address: 4321 Woodglen Drive, Grapevine, Texas
76051, or wherever she may be found. Service of said Defendant may be had by personal delivery.
4. Defendant, EDUARDO SANCHEZ, is an individual and resident of the State of Texas
and may be served with process at the following address: 4321 Woodglen Drive, Grapevine, Texas
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 1 of 48
76051, or wherever he may be found. Service of said Defendant may be had by personal delivery.
JURISDICTION AND VENUE
5. The subject matter in controversy is within the jurisdictional limits of this court. Venue
in Tarrant County is proper in this cause under Section 15.002(a)(1) of the Texas Civil Practice and
Remedies Code because all or a substantial part of the events or omissions giving rise to this lawsuit
occurred in this county. In accordance with Rule 47 of the Texas Rules of Civil Procedure, Plaintiff
seeks monetary relief over $200,000.00 but not more than $1,000,000.00.
FACTS
6. On or about February 7, 2018, Plaintiff was travelling southbound on 360 in Fort
Worth, Texas, when another vehicle, being driven by Defendant Sydney Sanchez and owned by
Defendant Eduardo Sanchez, suddenly and violently crashed into the rear of Plaintiff’s vehicle,
causing Plaintiff to sustain extensive bodily injuries and damages such that Plaintiff required. Due to
Defendants’ careless driving and lack of regard for the traffic laws, Plaintiff was forced to suffer the
damages claimed herein.
NEGLIGENCE OF DEFENDANT SYDNEY SANCHEZ
7. Defendant had a duty to exercise the degree of care that a reasonably careful person
would use to avoid harm to others under circumstances similar to those described herein.
8. Plaintiff’s injuries were proximately caused by Defendant’s negligent, careless and
reckless disregard of said duty.
9. The negligent, careless and reckless disregard of duty of Defendant consisted of, but is
not limited to, the following acts and omissions:
A. In that Defendant failed to keep a proper lookout for Plaintiff’s safety that
would have been maintained by a person of ordinary prudence under the same
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 2 of 48
or similar circumstances;
B. In that Defendant failed to operate their motor vehicle in an effort to avoid the
collision complained of;
C. In that Defendant failed to keep such distance away from Plaintiff’s motor
vehicle as a person using ordinary prudent care would have done;
D. In that Defendant was operating their motor vehicle at a rate of speed which
was greater than that would have been operated by a person of ordinary
prudence under the same or similar circumstances; and
E. In that Defendant failed to apply their brakes to their motor vehicle in a timely
and prudent manner and/or wholly failed to apply their brakes in order to avoid
the collision in question.
NEGLIGENT ENTRUSTMENT OF DEFENDANT EDUARDO SANCHEZ
10. On February 3, 2018, Defendant Eduardo Sanchez was the owner of the vehicle
operated by Defendant Sydney Sanchez.
11. Defendant Eduardo Sanchez entrusted the vehicle to Defendant Sydney Sanchez, a
reckless and incompetent driver.
12. Defendant Eduardo Sanchez knew, or through the exercise of reasonable care should
have known, that Defendant Sydney Sanchez was a reckless and incompetent driver.
13. As described herein, Defendant Sydney Sanchez was negligent on the occasion in
question.
14. Defendant Sydney Sanchez’s negligence was the proximate cause of Plaintiff's
damages.
DAMAGES
15. As a direct and proximate result of the occurrence made the basis of this lawsuit,
Plaintiff sustained bodily injuries and incurred the following damages:
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 3 of 48
A. Reasonable medical care and expenses in the past, which were incurred by
Plaintiff for the necessary care and treatment of the injuries resulting from the
accident complained of herein and such charges are reasonable and were usual
and customary charges for such services in Tarrant County, Texas;
B. Reasonable and necessary medical care and expenses which will in all
reasonable probability be incurred in the future;
C. Physical pain and suffering in the past;
D. Physical pain and suffering in the future;
E. Mental anguish in the past; and
F. Mental anguish in the future.
DEMAND FOR JURY TRIAL
16. Pursuant to Rule 216 of the Texas Rules of Civil Procedure, Plaintiff hereby demands
a trial by jury and tenders the jury fee herewith.
RULE 193.7 NOTICE TO DEFENDANTS
17. Pursuant to Rule 193.7 of the Texas Rules of Civil Procedure, Plaintiff intends to use
against Defendants in any legal pretrial proceeding or at trial all documents produced to Plaintiffs in
response to written discovery. This notice is given to Defendants within ten (10) days after Defendants
have actual notice that all documents produced by Defendants to Plaintiff in this lawsuit will be offered
at trial, thereby satisfying the requirement of authentication or identification as a condition precedent
to admissibility pursuant to the Rule 901(a) of the Texas Rules of Evidence.
REQUEST FOR WRITTEN DISCOVERY TO DEFENDANTS
18. Pursuant to the Texas Rules of Civil Procedure, Defendants are hereby requested to
provide answers and/or responses to the following requests for written discovery within fifty (50) days
of service of the requests, which are being served herewith and are attached hereto, and include the
following: Plaintiff’s First Request for Admissions to Defendants; Plaintiff’s Request for Disclosure
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 4 of 48
to Defendants; Plaintiff’s First Set of Interrogatories to Defendants; and Plaintiff’s First Request for
Production to Defendants.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully prays that Defendants be
cited to appear and answer herein, and that upon a final hearing of the cause, judgment be entered for
Plaintiff against Defendants for damages in an amount within the jurisdictional limits of the Court;
together with pre-judgment interest (from the date of injury through the date of judgment) at the
maximum rate allowed by law; post-judgment interest at the legal rate, costs of court; and such other
and further relief to which Plaintiff may be entitled at law or in equity.
Respectfully submitted,
ALMASRI & MARZWANIAN LAW GROUP PLLC
By: /s/ Hazim Mandavia
Sam Almasri
Texas Bar No. 24053071
Email: sam@theamlawgroup.com
Hazim Mandavia
Texas Bar No. 24096984
Email: hazim@theamlawgroup.com
9330 LBJ Freeway, Suite 120
Dallas, Texas 75243
Tel. (214) 227-2777
Fax. (214) 227-2271
Attorneys for Plaintiff
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 5 of 48
CAUSE NO. ____________
AMBER EATON, § IN THE DISTRICT COURT
Plaintiff, §
§
v. § ____ JUDICIAL DISTRICT
§
SYDNEY SANCHEZ AND §
EDUARDO SANCHEZ, §
Defendants. § TARRANT COUNTY, TEXAS
PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS
TO DEFENDANT SYDNEY SANCHEZ
TO: DEFENDANT, SYDNEY SANCHEZ, 4321 Woodglen Drive, Grapevine, Texas 76051, or
wherever she may be found.
You are notified that Plaintiff demands that within 50 days after the service of these requests,
Defendant specifically admit or deny the facts requested as set forth herein. A failure to specifically
answer any request, or an evasive answer to any request, will be taken as an admission of truth of such
request.
Respectfully submitted,
ALMASRI & MARZWANIAN LAW GROUP PLLC
By: /s/ Hazim Mandavia
Sam Almasri
Texas Bar No. 24053071
Email: sam@theamlawgroup.com
Hazim Mandavia
Texas Bar No. 24096984
Email: hazim@theamlawgroup.com
9330 LBJ Freeway, Suite 120
Dallas, Texas 75243
Tel. (214) 227-2777
Fax. (214) 227-2271
Attorneys for Plaintiff
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 6 of 48
DEFINITIONS AND INSTRUCTIONS
1. As used herein, the terms, “you” an “your”, shall refer to Defendant, Defendant’s attorneys,
agents, and all other natural persons or business or legal entities acting or purporting to act for or on
behalf of Defendant, whether authorized to do so or not.
2. “Person”: The term “person” shall include individuals, associations, partnerships,
corporations, and any other type of entity or institution whether formed for business purposes or any
other purposes.
3. “Settlement”, as used herein, means:
(a) an oral or written, disclosed or undisclosed agreement, bargain, contract, settlement,
partial settlement, limited settlement, arrangement, deal, understanding, loan arrangement, credit
arrangement, contingent settlement, limitation on the amount of liability or judgment, or a promise by
or between plaintiff and any defendant or between any defendant herein whereby plaintiff or defendant
have in any way released or compromised, in whole or in part, directly or indirectly, or agreed to do
so in the future, any of the matters in controversy in this lawsuit whether before, after or during trial
or before or after any jury verdict is returned herein or a judgment is entered or rendered herein;
(b) any resolution of the differences between the Defendant and Plaintiff by loan to the
Defendant or any other device which is repayable in whole or in part out of any judgment the
Defendant may recover against defendant;
(c) “Mary Carter Agreements” as that term is used under Texas Law.
4. Unless a specific date or dates is set forth in any specific question herein, you are directed
that each question shall be answered for the period of time up to and including the present date.
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 7 of 48
REQUESTS FOR ADMISSION
REQUEST FOR ADMISSION NO. 1: Admit or deny that you did not maintain a proper lookout at
the time of the collision made the basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 2: Admit or deny that you failed to take action to avoid the
collision made the basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 3: Admit or deny that no other entity contributed to the collision
made the basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 4: Admit or deny that you were under care of a physician at
the time of the collision made the basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 5: Admit or deny that at the time of the collision made the basis
of this lawsuit you did not have a valid Texas Drivers’ License.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 6: Admit or deny that you consumed drugs, medicines, or
alcoholic beverages within twenty-four (24) hours prior to said occurrence.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 7: Admit or deny that you were driving above the speed limit
just prior to impact with Plaintiff’s vehicle.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 8: Admit or deny that you failed to follow all traffic laws during
the moments prior to impact with Plaintiff’s vehicle.
ADMIT OR DENY: _____
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 8 of 48
REQUEST FOR ADMISSION NO. 9: Admit or deny that you had failed to perform reasonable
maintenance on your vehicle to assure its ability to operate in safe manner prior to collision made the
basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 10: Admit or deny that your actions contributed to the collision
made the basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 11: Admit or deny that you have ever had your drivers’ license
revoked for any reason.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 12: Admit or deny that you have received a traffic citation in
the past five years.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 13: Admit or deny that you received a traffic citation in relation
to the collision made the basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 14: Admit or deny that you have been in more than one motor
vehicle accident in the past five years.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 15: Admit or deny that you were distracted just prior to the
impact in relation to the collision made the basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 16: Admit or deny that you saw Plaintiff’s vehicle prior to the
impact in relation to collision made the basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 17: Admit or deny that you wore corrective lenses for any
purpose in 2017.
ADMIT OR DENY: _____
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 9 of 48
REQUEST FOR ADMISSION NO. 18: Admit or deny that you were taking any medication in the
24 hour period prior to the collision made the basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 19: Admit or deny that you were on your cell phone at any time
within the 10 minutes preceding the impact in relation to the collision made the basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 20: Admit or deny that you have been involved in more than
one motor vehicle collision in the past ten years.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 21: Admit or deny that you received a traffic citation in the ten
years prior to the collision made the basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 22: Admit or deny that your drivers’ license had been revoked
during any period of time prior to the collision made the basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 23: Admit or deny that you owned the vehicle involved in the
collision made the basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 24: Admit or deny that you did not have a valid drivers’ license
at the time of the collision made the basis of this lawsuit.
ADMIT OR DENY: _____
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 10 of 48
CAUSE NO. ____________
AMBER EATON, § IN THE DISTRICT COURT
Plaintiff, §
§
v. § ____ JUDICIAL DISTRICT
§
SYDNEY SANCHEZ AND §
EDUARDO SANCHEZ, §
Defendants. § TARRANT COUNTY, TEXAS
PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS
TO DEFENDANT EDUARDO SANCHEZ
TO: DEFENDANT, EDUARDO SANCHEZ, 4321 Woodglen Drive, Grapevine, Texas 76051, or
wherever he may be found.
You are notified that Plaintiff demands that within 50 days after the service of these requests,
Defendant specifically admit or deny the facts requested as set forth herein. A failure to specifically
answer any request, or an evasive answer to any request, will be taken as an admission of truth of such
request.
Respectfully submitted,
ALMASRI & MARZWANIAN LAW GROUP PLLC
By: /s/ Hazim Mandavia
Sam Almasri
Texas Bar No. 24053071
Email: sam@theamlawgroup.com
Hazim Mandavia
Texas Bar No. 24096984
Email: hazim@theamlawgroup.com
9330 LBJ Freeway, Suite 120
Dallas, Texas 75243
Tel. (214) 227-2777
Fax. (214) 227-2271
Attorneys for Plaintiff
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 11 of 48
DEFINITIONS AND INSTRUCTIONS
2. As used herein, the terms, “you” an “your”, shall refer to Defendant, Defendant’s attorneys,
agents, and all other natural persons or business or legal entities acting or purporting to act for or on
behalf of Defendant, whether authorized to do so or not.
2. “Person”: The term “person” shall include individuals, associations, partnerships,
corporations, and any other type of entity or institution whether formed for business purposes or any
other purposes.
3. “Settlement”, as used herein, means:
(a) an oral or written, disclosed or undisclosed agreement, bargain, contract, settlement,
partial settlement, limited settlement, arrangement, deal, understanding, loan arrangement, credit
arrangement, contingent settlement, limitation on the amount of liability or judgment, or a promise by
or between plaintiff and any defendant or between any defendant herein whereby plaintiff or defendant
have in any way released or compromised, in whole or in part, directly or indirectly, or agreed to do
so in the future, any of the matters in controversy in this lawsuit whether before, after or during trial
or before or after any jury verdict is returned herein or a judgment is entered or rendered herein;
(b) any resolution of the differences between the Defendant and Plaintiff by loan to the
Defendant or any other device which is repayable in whole or in part out of any judgment the
Defendant may recover against defendant;
(c) “Mary Carter Agreements” as that term is used under Texas Law.
4. Unless a specific date or dates is set forth in any specific question herein, you are directed
that each question shall be answered for the period of time up to and including the present date.
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 12 of 48
REQUESTS FOR ADMISSION
REQUEST FOR ADMISSION NO. 1: Admit or deny that you knew that Defendant Sydney
Sanchez had been involved in a motor vehicle collision in the ten years prior to the collision made the
basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 2: Admit or deny that you knew that Defendant Sydney
Sanchez received a traffic citation in the ten years prior to the collision made the basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 3: Admit or deny that you knew Defendant Sydney Sanchez’s
drivers’ license had been revoked during any period of time prior to the collision made the basis of
this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 4: Admit or deny that you owned the vehicle involved in the
collision made the basis of this lawsuit.
ADMIT OR DENY: _____
REQUEST FOR ADMISSION NO. 5: Admit or deny that you knew Defendant Sydney Sanchez
did not have a valid drivers’ license at the time of the collision made the basis of this lawsuit.
ADMIT OR DENY: _____
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 13 of 48
CAUSE NO. ____________
AMBER EATON, § IN THE DISTRICT COURT
Plaintiff, §
§
v. § ____ JUDICIAL DISTRICT
§
SYDNEY SANCHEZ AND §
EDUARDO SANCHEZ, §
Defendants. § TARRANT COUNTY, TEXAS
PLAINTIFF’S REQUEST FOR DISCLOSURE TO DEFENDANTS
TO: DEFENDANTS, SYDNEY SANCHEZ, 4321 Woodglen Drive, Grapevine, Texas 76051, or
wherever she may be found; and EDUARDO SANCHEZ, 4321 Woodglen Drive, Grapevine, Texas
76051, or wherever he may be found.
Pursuant to Rule 194 of the Texas Rules of Civil Procedure, you are requested to disclose,
within 50 days of service of this request, the information or material as set forth herein. A response to
a request under Rule 194.2(f) is due according to Rule 195.2 of the Texas Rules of Civil Procedure.
The disclosures must be signed in accordance with Texas Rules of Civil Procedure, Rule 191.3,
and delivered to the undersigned attorney. If you fail to comply with the requirements above, the
Court may order sanctions against you in accordance with the Texas Rules of Civil Procedure.
Respectfully submitted,
ALMASRI & MARZWANIAN LAW GROUP PLLC
By: /s/ Hazim Mandavia
Sam Almasri
Texas Bar No. 24053071
Email: sam@theamlawgroup.com
Hazim Mandavia
Texas Bar No. 24096984
Email: hazim@theamlawgroup.com
9330 LBJ Freeway, Suite 120
Dallas, Texas 75243
Tel. (214) 227-2777
Fax. (214) 227-2271
Attorneys for Plaintiffs
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 14 of 48
REQUESTS FOR DISCLOSURE
REQUEST FOR DISCLOSURE R.194.2(a).: State the correct names of the parties to the lawsuit.
RESPONSE:
REQUEST FOR DISCLOSURE R.194.2(b).: State the name, address, and telephone number of any
potential parties.
RESPONSE:
REQUEST FOR DISCLOSURE R.194.2(c).: State the legal theories and, in general, the factual
bases for your claims or defenses.
RESPONSE:
REQUEST FOR DISCLOSURE R.194.2(d).: State the amount and any method of calculating
economic damages.
RESPONSE:
REQUEST FOR DISCLOSURE R.194.2(e).: State the name, address, and telephone number of
persons having knowledge of relevant facts, and a brief statement of each identified person's
connection with the case.
RESPONSE:
REQUEST FOR DISCLOSURE R.194.2(f).: For any testifying expert, state:
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 expert's mental impressions and a brief summary
of the basis for them, or if the expert is not retained by, employed by, or
otherwise subject to your control, documents reflecting such information;
4. if the expert is retained by, employed by, or otherwise subject to your control:
A) produce 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) produce the expert's current resume and bibliography.
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 15 of 48
RESPONSE:
REQUEST FOR DISCLOSURE R.194.2(g).: Produce any indemnity and insuring agreements as
described in Rule 192.3(f).
RESPONSE:
REQUEST FOR DISCLOSURE R.194.2(h).: Produce any settlement agreements as described in
Rule 192.3(g).
RESPONSE:
REQUEST FOR DISCLOSURE R.194.2(i).: Produce any witness statements as described in Rule
192.3(h).
RESPONSE:
REQUEST FOR DISCLOSURE R.194.2(j).: If this is a suit alleging physical or mental injury and
damages from the occurrence that is the subject of the case, produce 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.
RESPONSE:
REQUEST FOR DISCLOSURE R.194.2(k).: Produce all medical records and bills obtained by
the responding party by virtue of an authorization furnished by the requesting party.
RESPONSE:
REQUEST FOR DISCLOSURE 194.2(l).: Produce the name, address, and telephone number of
any person who may be designated as a responsible third party.
RESPONSE:
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 16 of 48
CAUSE NO. ____________
AMBER EATON, § IN THE DISTRICT COURT
Plaintiff, §
§
v. § ____ JUDICIAL DISTRICT
§
SYDNEY SANCHEZ AND §
EDUARDO SANCHEZ, §
Defendants. § TARRANT COUNTY, TEXAS
PLAINTIFF’S FIRST SET OF INTERROGATORIES
TO DEFENDANT SYDNEY SANCHEZ
TO: DEFENDANT, SYDNEY SANCHEZ, 4321 Woodglen Drive, Grapevine, Texas 76051, or
wherever she may be found.
You are hereby instructed to answer the following interrogatories separately, fully, in writing,
and under oath if required by Rule 197.2(d) of the Texas Rules of Civil Procedure. The answers shall
be served upon the undersigned counsel within 50 days after the service of these interrogatories.
Your failure to make timely answers or objections may subject you to sanctions as provided
in Rule 221 of the Texas Rules of Civil Procedure.
Respectfully submitted,
ALMASRI & MARZWANIAN LAW GROUP PLLC
By: /s/ Hazim Mandavia
Sam Almasri
Texas Bar No. 24053071
Email: sam@theamlawgroup.com
Hazim Mandavia
Texas Bar No. 24096984
Email: hazim@theamlawgroup.com
9330 LBJ Freeway, Suite 120
Dallas, Texas 75243
Tel. (214) 227-2777
Fax. (214) 227-2271
Attorneys for Plaintiff
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 17 of 48
DEFINITIONS AND INSTRUCTIONS
1. As used herein, the terms "you" and "your" shall refer to Defendant, Defendant’s
attorneys, agents, and all other natural persons or business or legal entities acting or purporting to act
for or on behalf of Defendant, whether authorized to do so or not.
2. As used herein, the term "documents" shall mean all writings of every kind, source and
authorship, both originals and all nonidentical copies thereof, in your possession, custody, or control,
or known by you to exist, irrespective of whether the writing is one intended for or transmitted
internally by you, or intended for or transmitted to any other person or entity, including without
limitation any government agency, department, administrative, or private entity or person. The term
shall include handwritten, typewritten, printed, photocopied, photographic, or recorded matter. It shall
include communications in words, symbols, pictures, sound recordings, films, tapes, and information
stored in, or accessible through, computer or other information storage or retrieval systems, together
with the codes and/or programming instructions and other materials necessary to understand and use
such systems. For purposes of illustration and not limitation, the term shall include: affidavits;
agendas; agreements; analyses; announcements; bills, statements, and other records of obligations and
expenditures; books; brochures; bulletins; calendars; canceled checks, vouchers, receipts and other
records of payments; charts or drawings; check registers; checkbooks; circulars; collateral files and
contents; contracts; corporate bylaws; corporate charters; correspondence; credit files and contents;
deeds of trust; deposit slips; diaries; drafts; files; guaranty agreements; instructions; invoices; ledgers,
journals, balance sheets, profit and loss statements, and other sources of financial data; letters; logs,
notes, or memoranda of telephonic or face-to-face conversations; manuals; memoranda of all kinds,
to and from any persons, agencies, or entities; minutes; minute books; notes; notices; parts lists;
papers; press releases; printed matter (including books, articles, speeches, and newspaper clippings);
purchase orders; records; records of administrative, technical, and financial actions taken or
recommended; reports; safety deposit boxes and contents and records of entry; schedules; security
agreements; specifications; statements of bank accounts; statements; interviews; stock transfer
ledgers; technical and engineering reports, evaluations, advice, recommendations, commentaries,
conclusions, studies, test plans, manuals, procedures, data, reports, results, and conclusions;
summaries, notes, and other records and recordings of any conferences, meetings, visits, statements,
interviews or telephone conversations; telegrams; teletypes and other communications sent or
received; transcripts of testimony; UCC instruments; work papers; and all other writings, the contents
of which relate to, discuss, consider, or otherwise refer to the subject matter of the particular discovery
requested.
3. In accordance with Tex. R. Civ. P. Rule 192.7, a document is deemed to be in your
possession, custody or control if you either have physical possession of the item or have a right to
possession of the item that is equal or superior to the person who has physical control of the item.
4. "Person": The term "person" shall include individuals, associations, partnerships,
corporations, and any other type of entity or institution whether formed for business purposes or any
other purposes.
Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant
Page 18 of 48
5. "Identify" or "Identification":
(a) When used in reference to a person, "identify" or "identification" means to state
his or her full name, present or last known residence address, present or last known business
address and telephone number.
(b) When used in reference to a public or private corporation, governmental entity,
partnership or association, "identify" or "identification" means to state its full name, present
or last known business address or operating address, the name of its Chief Executive Officer
and telephone number.
(c) When used in reference to a document, "identify" or "identification" shall
include statement of the following:
(i) the title, heading, or caption, if any, of such document;
(ii) the identifying number(s), letter(s), or combination thereof, if any; and
the significance or meaning of such number(s), letter(s), or combination thereof,
Preview
FILED TARRANT COUNTY 342-314929-20 1/31/2020 1:46 PM CAUSE NO. ____________ THOMAS A. WILDER DISTRICT CLERK AMBER EATON, § IN THE DISTRICT COURT Plaintiff, § § v. § ____ JUDICIAL DISTRICT § SYDNEY SANCHEZ AND § EDUARDO SANCHEZ, § Defendants. § TARRANT COUNTY, TEXAS PLAINTIFF'S ORIGINAL PETITION. DEMAND FOR JURY TRIAL, RULE 193.7 NOTICE AND FIRST SET OF WRITTEN DISCOVERY TO DEFENDANTS TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, AMBER EATON, hereinafter “Plaintiff”, complaining of and about SYDNEY SANCHEZ and EDUARDO SANCHEZ, hereinafter collectively “Defendants”, and for cause of action would respectfully show the Court the following: DISCOVERY CONTROL PLAN LEVEL 1. Plaintiff intends that discovery be conducted under Discovery Level 3. PARTIES AND SERVICE 2. Plaintiff, AMBER EATON, is an individual and resident of the State of Texas whose address for service is 9330 LBJ Freeway, Suite 120, Dallas, Texas 75243. The last three digits of Plaintiff’s drivers’ license number are 331and the last three digits of Plaintiff’s social security number are 330. 3. Defendant, SYDNEY SANCHEZ, is an individual and resident of the State of Texas and may be served with process at the following address: 4321 Woodglen Drive, Grapevine, Texas 76051, or wherever she may be found. Service of said Defendant may be had by personal delivery. 4. Defendant, EDUARDO SANCHEZ, is an individual and resident of the State of Texas and may be served with process at the following address: 4321 Woodglen Drive, Grapevine, Texas Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 1 of 48 76051, or wherever he may be found. Service of said Defendant may be had by personal delivery. JURISDICTION AND VENUE 5. The subject matter in controversy is within the jurisdictional limits of this court. Venue in Tarrant County is proper in this cause under Section 15.002(a)(1) of the Texas Civil Practice and Remedies Code because all or a substantial part of the events or omissions giving rise to this lawsuit occurred in this county. In accordance with Rule 47 of the Texas Rules of Civil Procedure, Plaintiff seeks monetary relief over $200,000.00 but not more than $1,000,000.00. FACTS 6. On or about February 7, 2018, Plaintiff was travelling southbound on 360 in Fort Worth, Texas, when another vehicle, being driven by Defendant Sydney Sanchez and owned by Defendant Eduardo Sanchez, suddenly and violently crashed into the rear of Plaintiff’s vehicle, causing Plaintiff to sustain extensive bodily injuries and damages such that Plaintiff required. Due to Defendants’ careless driving and lack of regard for the traffic laws, Plaintiff was forced to suffer the damages claimed herein. NEGLIGENCE OF DEFENDANT SYDNEY SANCHEZ 7. Defendant had a duty to exercise the degree of care that a reasonably careful person would use to avoid harm to others under circumstances similar to those described herein. 8. Plaintiff’s injuries were proximately caused by Defendant’s negligent, careless and reckless disregard of said duty. 9. The negligent, careless and reckless disregard of duty of Defendant consisted of, but is not limited to, the following acts and omissions: A. In that Defendant failed to keep a proper lookout for Plaintiff’s safety that would have been maintained by a person of ordinary prudence under the same Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 2 of 48 or similar circumstances; B. In that Defendant failed to operate their motor vehicle in an effort to avoid the collision complained of; C. In that Defendant failed to keep such distance away from Plaintiff’s motor vehicle as a person using ordinary prudent care would have done; D. In that Defendant was operating their motor vehicle at a rate of speed which was greater than that would have been operated by a person of ordinary prudence under the same or similar circumstances; and E. In that Defendant failed to apply their brakes to their motor vehicle in a timely and prudent manner and/or wholly failed to apply their brakes in order to avoid the collision in question. NEGLIGENT ENTRUSTMENT OF DEFENDANT EDUARDO SANCHEZ 10. On February 3, 2018, Defendant Eduardo Sanchez was the owner of the vehicle operated by Defendant Sydney Sanchez. 11. Defendant Eduardo Sanchez entrusted the vehicle to Defendant Sydney Sanchez, a reckless and incompetent driver. 12. Defendant Eduardo Sanchez knew, or through the exercise of reasonable care should have known, that Defendant Sydney Sanchez was a reckless and incompetent driver. 13. As described herein, Defendant Sydney Sanchez was negligent on the occasion in question. 14. Defendant Sydney Sanchez’s negligence was the proximate cause of Plaintiff's damages. DAMAGES 15. As a direct and proximate result of the occurrence made the basis of this lawsuit, Plaintiff sustained bodily injuries and incurred the following damages: Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 3 of 48 A. Reasonable medical care and expenses in the past, which were incurred by Plaintiff for the necessary care and treatment of the injuries resulting from the accident complained of herein and such charges are reasonable and were usual and customary charges for such services in Tarrant County, Texas; B. Reasonable and necessary medical care and expenses which will in all reasonable probability be incurred in the future; C. Physical pain and suffering in the past; D. Physical pain and suffering in the future; E. Mental anguish in the past; and F. Mental anguish in the future. DEMAND FOR JURY TRIAL 16. Pursuant to Rule 216 of the Texas Rules of Civil Procedure, Plaintiff hereby demands a trial by jury and tenders the jury fee herewith. RULE 193.7 NOTICE TO DEFENDANTS 17. Pursuant to Rule 193.7 of the Texas Rules of Civil Procedure, Plaintiff intends to use against Defendants in any legal pretrial proceeding or at trial all documents produced to Plaintiffs in response to written discovery. This notice is given to Defendants within ten (10) days after Defendants have actual notice that all documents produced by Defendants to Plaintiff in this lawsuit will be offered at trial, thereby satisfying the requirement of authentication or identification as a condition precedent to admissibility pursuant to the Rule 901(a) of the Texas Rules of Evidence. REQUEST FOR WRITTEN DISCOVERY TO DEFENDANTS 18. Pursuant to the Texas Rules of Civil Procedure, Defendants are hereby requested to provide answers and/or responses to the following requests for written discovery within fifty (50) days of service of the requests, which are being served herewith and are attached hereto, and include the following: Plaintiff’s First Request for Admissions to Defendants; Plaintiff’s Request for Disclosure Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 4 of 48 to Defendants; Plaintiff’s First Set of Interrogatories to Defendants; and Plaintiff’s First Request for Production to Defendants. PRAYER WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully prays that Defendants be cited to appear and answer herein, and that upon a final hearing of the cause, judgment be entered for Plaintiff against Defendants for damages in an amount within the jurisdictional limits of the Court; together with pre-judgment interest (from the date of injury through the date of judgment) at the maximum rate allowed by law; post-judgment interest at the legal rate, costs of court; and such other and further relief to which Plaintiff may be entitled at law or in equity. Respectfully submitted, ALMASRI & MARZWANIAN LAW GROUP PLLC By: /s/ Hazim Mandavia Sam Almasri Texas Bar No. 24053071 Email: sam@theamlawgroup.com Hazim Mandavia Texas Bar No. 24096984 Email: hazim@theamlawgroup.com 9330 LBJ Freeway, Suite 120 Dallas, Texas 75243 Tel. (214) 227-2777 Fax. (214) 227-2271 Attorneys for Plaintiff Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 5 of 48 CAUSE NO. ____________ AMBER EATON, § IN THE DISTRICT COURT Plaintiff, § § v. § ____ JUDICIAL DISTRICT § SYDNEY SANCHEZ AND § EDUARDO SANCHEZ, § Defendants. § TARRANT COUNTY, TEXAS PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT SYDNEY SANCHEZ TO: DEFENDANT, SYDNEY SANCHEZ, 4321 Woodglen Drive, Grapevine, Texas 76051, or wherever she may be found. You are notified that Plaintiff demands that within 50 days after the service of these requests, Defendant specifically admit or deny the facts requested as set forth herein. A failure to specifically answer any request, or an evasive answer to any request, will be taken as an admission of truth of such request. Respectfully submitted, ALMASRI & MARZWANIAN LAW GROUP PLLC By: /s/ Hazim Mandavia Sam Almasri Texas Bar No. 24053071 Email: sam@theamlawgroup.com Hazim Mandavia Texas Bar No. 24096984 Email: hazim@theamlawgroup.com 9330 LBJ Freeway, Suite 120 Dallas, Texas 75243 Tel. (214) 227-2777 Fax. (214) 227-2271 Attorneys for Plaintiff Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 6 of 48 DEFINITIONS AND INSTRUCTIONS 1. As used herein, the terms, “you” an “your”, shall refer to Defendant, Defendant’s attorneys, agents, and all other natural persons or business or legal entities acting or purporting to act for or on behalf of Defendant, whether authorized to do so or not. 2. “Person”: The term “person” shall include individuals, associations, partnerships, corporations, and any other type of entity or institution whether formed for business purposes or any other purposes. 3. “Settlement”, as used herein, means: (a) an oral or written, disclosed or undisclosed agreement, bargain, contract, settlement, partial settlement, limited settlement, arrangement, deal, understanding, loan arrangement, credit arrangement, contingent settlement, limitation on the amount of liability or judgment, or a promise by or between plaintiff and any defendant or between any defendant herein whereby plaintiff or defendant have in any way released or compromised, in whole or in part, directly or indirectly, or agreed to do so in the future, any of the matters in controversy in this lawsuit whether before, after or during trial or before or after any jury verdict is returned herein or a judgment is entered or rendered herein; (b) any resolution of the differences between the Defendant and Plaintiff by loan to the Defendant or any other device which is repayable in whole or in part out of any judgment the Defendant may recover against defendant; (c) “Mary Carter Agreements” as that term is used under Texas Law. 4. Unless a specific date or dates is set forth in any specific question herein, you are directed that each question shall be answered for the period of time up to and including the present date. Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 7 of 48 REQUESTS FOR ADMISSION REQUEST FOR ADMISSION NO. 1: Admit or deny that you did not maintain a proper lookout at the time of the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 2: Admit or deny that you failed to take action to avoid the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 3: Admit or deny that no other entity contributed to the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 4: Admit or deny that you were under care of a physician at the time of the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 5: Admit or deny that at the time of the collision made the basis of this lawsuit you did not have a valid Texas Drivers’ License. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 6: Admit or deny that you consumed drugs, medicines, or alcoholic beverages within twenty-four (24) hours prior to said occurrence. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 7: Admit or deny that you were driving above the speed limit just prior to impact with Plaintiff’s vehicle. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 8: Admit or deny that you failed to follow all traffic laws during the moments prior to impact with Plaintiff’s vehicle. ADMIT OR DENY: _____ Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 8 of 48 REQUEST FOR ADMISSION NO. 9: Admit or deny that you had failed to perform reasonable maintenance on your vehicle to assure its ability to operate in safe manner prior to collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 10: Admit or deny that your actions contributed to the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 11: Admit or deny that you have ever had your drivers’ license revoked for any reason. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 12: Admit or deny that you have received a traffic citation in the past five years. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 13: Admit or deny that you received a traffic citation in relation to the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 14: Admit or deny that you have been in more than one motor vehicle accident in the past five years. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 15: Admit or deny that you were distracted just prior to the impact in relation to the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 16: Admit or deny that you saw Plaintiff’s vehicle prior to the impact in relation to collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 17: Admit or deny that you wore corrective lenses for any purpose in 2017. ADMIT OR DENY: _____ Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 9 of 48 REQUEST FOR ADMISSION NO. 18: Admit or deny that you were taking any medication in the 24 hour period prior to the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 19: Admit or deny that you were on your cell phone at any time within the 10 minutes preceding the impact in relation to the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 20: Admit or deny that you have been involved in more than one motor vehicle collision in the past ten years. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 21: Admit or deny that you received a traffic citation in the ten years prior to the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 22: Admit or deny that your drivers’ license had been revoked during any period of time prior to the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 23: Admit or deny that you owned the vehicle involved in the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 24: Admit or deny that you did not have a valid drivers’ license at the time of the collision made the basis of this lawsuit. ADMIT OR DENY: _____ Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 10 of 48 CAUSE NO. ____________ AMBER EATON, § IN THE DISTRICT COURT Plaintiff, § § v. § ____ JUDICIAL DISTRICT § SYDNEY SANCHEZ AND § EDUARDO SANCHEZ, § Defendants. § TARRANT COUNTY, TEXAS PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT EDUARDO SANCHEZ TO: DEFENDANT, EDUARDO SANCHEZ, 4321 Woodglen Drive, Grapevine, Texas 76051, or wherever he may be found. You are notified that Plaintiff demands that within 50 days after the service of these requests, Defendant specifically admit or deny the facts requested as set forth herein. A failure to specifically answer any request, or an evasive answer to any request, will be taken as an admission of truth of such request. Respectfully submitted, ALMASRI & MARZWANIAN LAW GROUP PLLC By: /s/ Hazim Mandavia Sam Almasri Texas Bar No. 24053071 Email: sam@theamlawgroup.com Hazim Mandavia Texas Bar No. 24096984 Email: hazim@theamlawgroup.com 9330 LBJ Freeway, Suite 120 Dallas, Texas 75243 Tel. (214) 227-2777 Fax. (214) 227-2271 Attorneys for Plaintiff Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 11 of 48 DEFINITIONS AND INSTRUCTIONS 2. As used herein, the terms, “you” an “your”, shall refer to Defendant, Defendant’s attorneys, agents, and all other natural persons or business or legal entities acting or purporting to act for or on behalf of Defendant, whether authorized to do so or not. 2. “Person”: The term “person” shall include individuals, associations, partnerships, corporations, and any other type of entity or institution whether formed for business purposes or any other purposes. 3. “Settlement”, as used herein, means: (a) an oral or written, disclosed or undisclosed agreement, bargain, contract, settlement, partial settlement, limited settlement, arrangement, deal, understanding, loan arrangement, credit arrangement, contingent settlement, limitation on the amount of liability or judgment, or a promise by or between plaintiff and any defendant or between any defendant herein whereby plaintiff or defendant have in any way released or compromised, in whole or in part, directly or indirectly, or agreed to do so in the future, any of the matters in controversy in this lawsuit whether before, after or during trial or before or after any jury verdict is returned herein or a judgment is entered or rendered herein; (b) any resolution of the differences between the Defendant and Plaintiff by loan to the Defendant or any other device which is repayable in whole or in part out of any judgment the Defendant may recover against defendant; (c) “Mary Carter Agreements” as that term is used under Texas Law. 4. Unless a specific date or dates is set forth in any specific question herein, you are directed that each question shall be answered for the period of time up to and including the present date. Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 12 of 48 REQUESTS FOR ADMISSION REQUEST FOR ADMISSION NO. 1: Admit or deny that you knew that Defendant Sydney Sanchez had been involved in a motor vehicle collision in the ten years prior to the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 2: Admit or deny that you knew that Defendant Sydney Sanchez received a traffic citation in the ten years prior to the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 3: Admit or deny that you knew Defendant Sydney Sanchez’s drivers’ license had been revoked during any period of time prior to the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 4: Admit or deny that you owned the vehicle involved in the collision made the basis of this lawsuit. ADMIT OR DENY: _____ REQUEST FOR ADMISSION NO. 5: Admit or deny that you knew Defendant Sydney Sanchez did not have a valid drivers’ license at the time of the collision made the basis of this lawsuit. ADMIT OR DENY: _____ Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 13 of 48 CAUSE NO. ____________ AMBER EATON, § IN THE DISTRICT COURT Plaintiff, § § v. § ____ JUDICIAL DISTRICT § SYDNEY SANCHEZ AND § EDUARDO SANCHEZ, § Defendants. § TARRANT COUNTY, TEXAS PLAINTIFF’S REQUEST FOR DISCLOSURE TO DEFENDANTS TO: DEFENDANTS, SYDNEY SANCHEZ, 4321 Woodglen Drive, Grapevine, Texas 76051, or wherever she may be found; and EDUARDO SANCHEZ, 4321 Woodglen Drive, Grapevine, Texas 76051, or wherever he may be found. Pursuant to Rule 194 of the Texas Rules of Civil Procedure, you are requested to disclose, within 50 days of service of this request, the information or material as set forth herein. A response to a request under Rule 194.2(f) is due according to Rule 195.2 of the Texas Rules of Civil Procedure. The disclosures must be signed in accordance with Texas Rules of Civil Procedure, Rule 191.3, and delivered to the undersigned attorney. If you fail to comply with the requirements above, the Court may order sanctions against you in accordance with the Texas Rules of Civil Procedure. Respectfully submitted, ALMASRI & MARZWANIAN LAW GROUP PLLC By: /s/ Hazim Mandavia Sam Almasri Texas Bar No. 24053071 Email: sam@theamlawgroup.com Hazim Mandavia Texas Bar No. 24096984 Email: hazim@theamlawgroup.com 9330 LBJ Freeway, Suite 120 Dallas, Texas 75243 Tel. (214) 227-2777 Fax. (214) 227-2271 Attorneys for Plaintiffs Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 14 of 48 REQUESTS FOR DISCLOSURE REQUEST FOR DISCLOSURE R.194.2(a).: State the correct names of the parties to the lawsuit. RESPONSE: REQUEST FOR DISCLOSURE R.194.2(b).: State the name, address, and telephone number of any potential parties. RESPONSE: REQUEST FOR DISCLOSURE R.194.2(c).: State the legal theories and, in general, the factual bases for your claims or defenses. RESPONSE: REQUEST FOR DISCLOSURE R.194.2(d).: State the amount and any method of calculating economic damages. RESPONSE: REQUEST FOR DISCLOSURE R.194.2(e).: State the name, address, and telephone number of persons having knowledge of relevant facts, and a brief statement of each identified person's connection with the case. RESPONSE: REQUEST FOR DISCLOSURE R.194.2(f).: For any testifying expert, state: 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 expert's mental impressions and a brief summary of the basis for them, or if the expert is not retained by, employed by, or otherwise subject to your control, documents reflecting such information; 4. if the expert is retained by, employed by, or otherwise subject to your control: A) produce 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) produce the expert's current resume and bibliography. Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 15 of 48 RESPONSE: REQUEST FOR DISCLOSURE R.194.2(g).: Produce any indemnity and insuring agreements as described in Rule 192.3(f). RESPONSE: REQUEST FOR DISCLOSURE R.194.2(h).: Produce any settlement agreements as described in Rule 192.3(g). RESPONSE: REQUEST FOR DISCLOSURE R.194.2(i).: Produce any witness statements as described in Rule 192.3(h). RESPONSE: REQUEST FOR DISCLOSURE R.194.2(j).: If this is a suit alleging physical or mental injury and damages from the occurrence that is the subject of the case, produce 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. RESPONSE: REQUEST FOR DISCLOSURE R.194.2(k).: Produce all medical records and bills obtained by the responding party by virtue of an authorization furnished by the requesting party. RESPONSE: REQUEST FOR DISCLOSURE 194.2(l).: Produce the name, address, and telephone number of any person who may be designated as a responsible third party. RESPONSE: Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 16 of 48 CAUSE NO. ____________ AMBER EATON, § IN THE DISTRICT COURT Plaintiff, § § v. § ____ JUDICIAL DISTRICT § SYDNEY SANCHEZ AND § EDUARDO SANCHEZ, § Defendants. § TARRANT COUNTY, TEXAS PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT SYDNEY SANCHEZ TO: DEFENDANT, SYDNEY SANCHEZ, 4321 Woodglen Drive, Grapevine, Texas 76051, or wherever she may be found. You are hereby instructed to answer the following interrogatories separately, fully, in writing, and under oath if required by Rule 197.2(d) of the Texas Rules of Civil Procedure. The answers shall be served upon the undersigned counsel within 50 days after the service of these interrogatories. Your failure to make timely answers or objections may subject you to sanctions as provided in Rule 221 of the Texas Rules of Civil Procedure. Respectfully submitted, ALMASRI & MARZWANIAN LAW GROUP PLLC By: /s/ Hazim Mandavia Sam Almasri Texas Bar No. 24053071 Email: sam@theamlawgroup.com Hazim Mandavia Texas Bar No. 24096984 Email: hazim@theamlawgroup.com 9330 LBJ Freeway, Suite 120 Dallas, Texas 75243 Tel. (214) 227-2777 Fax. (214) 227-2271 Attorneys for Plaintiff Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 17 of 48 DEFINITIONS AND INSTRUCTIONS 1. As used herein, the terms "you" and "your" shall refer to Defendant, Defendant’s attorneys, agents, and all other natural persons or business or legal entities acting or purporting to act for or on behalf of Defendant, whether authorized to do so or not. 2. As used herein, the term "documents" shall mean all writings of every kind, source and authorship, both originals and all nonidentical copies thereof, in your possession, custody, or control, or known by you to exist, irrespective of whether the writing is one intended for or transmitted internally by you, or intended for or transmitted to any other person or entity, including without limitation any government agency, department, administrative, or private entity or person. The term shall include handwritten, typewritten, printed, photocopied, photographic, or recorded matter. It shall include communications in words, symbols, pictures, sound recordings, films, tapes, and information stored in, or accessible through, computer or other information storage or retrieval systems, together with the codes and/or programming instructions and other materials necessary to understand and use such systems. For purposes of illustration and not limitation, the term shall include: affidavits; agendas; agreements; analyses; announcements; bills, statements, and other records of obligations and expenditures; books; brochures; bulletins; calendars; canceled checks, vouchers, receipts and other records of payments; charts or drawings; check registers; checkbooks; circulars; collateral files and contents; contracts; corporate bylaws; corporate charters; correspondence; credit files and contents; deeds of trust; deposit slips; diaries; drafts; files; guaranty agreements; instructions; invoices; ledgers, journals, balance sheets, profit and loss statements, and other sources of financial data; letters; logs, notes, or memoranda of telephonic or face-to-face conversations; manuals; memoranda of all kinds, to and from any persons, agencies, or entities; minutes; minute books; notes; notices; parts lists; papers; press releases; printed matter (including books, articles, speeches, and newspaper clippings); purchase orders; records; records of administrative, technical, and financial actions taken or recommended; reports; safety deposit boxes and contents and records of entry; schedules; security agreements; specifications; statements of bank accounts; statements; interviews; stock transfer ledgers; technical and engineering reports, evaluations, advice, recommendations, commentaries, conclusions, studies, test plans, manuals, procedures, data, reports, results, and conclusions; summaries, notes, and other records and recordings of any conferences, meetings, visits, statements, interviews or telephone conversations; telegrams; teletypes and other communications sent or received; transcripts of testimony; UCC instruments; work papers; and all other writings, the contents of which relate to, discuss, consider, or otherwise refer to the subject matter of the particular discovery requested. 3. In accordance with Tex. R. Civ. P. Rule 192.7, a document is deemed to be in your possession, custody or control if you either have physical possession of the item or have a right to possession of the item that is equal or superior to the person who has physical control of the item. 4. "Person": The term "person" shall include individuals, associations, partnerships, corporations, and any other type of entity or institution whether formed for business purposes or any other purposes. Plaintiff’s Original Petition, Jury Demand, Rule 193.7 Notice and Discovery Request to Defendant Page 18 of 48 5. "Identify" or "Identification": (a) When used in reference to a person, "identify" or "identification" means to state his or her full name, present or last known residence address, present or last known business address and telephone number. (b) When used in reference to a public or private corporation, governmental entity, partnership or association, "identify" or "identification" means to state its full name, present or last known business address or operating address, the name of its Chief Executive Officer and telephone number. (c) When used in reference to a document, "identify" or "identification" shall include statement of the following: (i) the title, heading, or caption, if any, of such document; (ii) the identifying number(s), letter(s), or combination thereof, if any; and the significance or meaning of such number(s), letter(s), or combination thereof,