On September 16, 2020 a
Request,Application
was filed
involving a dispute between
Luna, Angelica,
R, K,
and
Cheema, Vikram Singh,
Northgate Hospitality Inc,
Northgate Hotel Llc,
North Villa Inn,
for PERSONAL INJ (NON-AUTO)
in the District Court of Harris County.
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ANGELICA LUNA, Individually and on IN THE DISTRICT COURT
behalf of the estate of K.R., a Minor Child
JUDICIAL DISTRICT
HOSPITALITY, INC. d/b/a NORTH
VILLA INN and VIKRAM SINGH
HARRIS COUNTY, TEXAS
Defendant, Northgate Hospitality, Inc. (h
try Upon Property Pursuant tot Rule 196.7.
the pool available for inspection at a mutually agreeable time and date.
Jefferson County, Texas. The style
LLC d/b/a North Villa Inn, et. al.; In the
are coordinating with all
wsuits. As stated
G:\Bush Matters\01130\14773 North Villa\Pleadings\Harris County Lawsuit - Pleadings\Def Resp to Motion to Entry - Pool Inspection\Def's Rsp
to Motion to Entry.doc 1
above, Defendant is more than willing to make the pool available for inspection at a
mutually agreeable time and date.
Defendant objects to the protocol requested by the Plaintiff as a mutually agreeable
protocol will need to be circulated and agreed upon by all parties and experts.
Further, Defendant’s expert will need to review a
testing methods, etc. outlined in the Plaintiff’s proposed protocol.
WHEREFORE, PREMISES CONSIDERED, DEFENDANT further requests all other
y show itself justly entitled.
BUSH & RAMIREZ, PLLC
William S. Bush; SBN: 03497500
Steven B. Tran; SBN: 24025685
5615 Kirby Drive, Suite 900
Houston, Texas 77005
Telephone: (713) 626-1555
Facsimile: (713) 622-8077
Email: wsbush.atty@bushramirez.com
Email: btran@bushramirez.com
ITALITY INC.
G:\Bush Matters\01130\14773 North Villa\Pleadings\Harris County Lawsuit - Pleadings\Def Resp to Motion to Entry - Pool Inspection\Def's Rsp
to Motion to Entry.doc 2
I hereby certify that a copy of forgoing instrument has been sent to all interested counsel by
service on this 11 day of August, 2021.
J.P. Morgan Chase Tower
Lewis Brisbois Bisgaard & Smith, LLP
Mary “Amy” Cazes Greene
500 Dallas Street, Suite 1300
Via E-Filing & Email
Steven B. Tran
G:\Bush Matters\01130\14773 North Villa\Pleadings\Harris County Lawsuit - Pleadings\Def Resp to Motion to Entry - Pool Inspection\Def's Rsp
to Motion to Entry.doc 3
Document Filed Date
August 11, 2021
Case Filing Date
September 16, 2020
Category
PERSONAL INJ (NON-AUTO)
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ANGELICA LUNA, Individually and on IN THE DISTRICT COURT behalf of the estate of K.R., a Minor Child JUDICIAL DISTRICT HOSPITALITY, INC. d/b/a NORTH VILLA INN and VIKRAM SINGH HARRIS COUNTY, TEXAS Defendant, Northgate Hospitality, Inc. (h try Upon Property Pursuant tot Rule 196.7. the pool available for inspection at a mutually agreeable time and date. Jefferson County, Texas. The style LLC d/b/a North Villa Inn, et. al.; In the are coordinating with all wsuits. As stated G:\Bush Matters\01130\14773 North Villa\Pleadings\Harris County Lawsuit - Pleadings\Def Resp to Motion to Entry - Pool Inspection\Def's Rsp to Motion to Entry.doc 1 above, Defendant is more than willing to make the pool available for inspection at a mutually agreeable time and date. Defendant objects to the protocol requested by the Plaintiff as a mutually agreeable protocol will need to be circulated and agreed upon by all parties and experts. Further, Defendant’s expert will need to review a testing methods, etc. outlined in the Plaintiff’s proposed protocol. WHEREFORE, PREMISES CONSIDERED, DEFENDANT further requests all other y show itself justly entitled. BUSH & RAMIREZ, PLLC William S. Bush; SBN: 03497500 Steven B. Tran; SBN: 24025685 5615 Kirby Drive, Suite 900 Houston, Texas 77005 Telephone: (713) 626-1555 Facsimile: (713) 622-8077 Email: wsbush.atty@bushramirez.com Email: btran@bushramirez.com ITALITY INC. G:\Bush Matters\01130\14773 North Villa\Pleadings\Harris County Lawsuit - Pleadings\Def Resp to Motion to Entry - Pool Inspection\Def's Rsp to Motion to Entry.doc 2 I hereby certify that a copy of forgoing instrument has been sent to all interested counsel by service on this 11 day of August, 2021. J.P. Morgan Chase Tower Lewis Brisbois Bisgaard & Smith, LLP Mary “Amy” Cazes Greene 500 Dallas Street, Suite 1300 Via E-Filing & Email Steven B. Tran G:\Bush Matters\01130\14773 North Villa\Pleadings\Harris County Lawsuit - Pleadings\Def Resp to Motion to Entry - Pool Inspection\Def's Rsp to Motion to Entry.doc 3