You are on page 1of 2

Zachariah Tesfaye Dorsett

Plaintiff/Defendant
4347 Alysheba ln.
Friendswood, TX 77546
(505)603-7591

October 17, 2010

Robert Bone
Hoover Slovacek LLP
Defendant/Plaintiff
5847 San Felipe, Suite 2200
Houston, Texas 77057

Justice of the Peace Court, Harris County, Texas, Precint One, Place One
Zachariah Dorsett vs. Archstone Memorial Heights

ZACHARIAH DORSETT'S (1) FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS


(2)FIRST SET OF DISCOVERY OF TRIAL WITNESSES,
(3)FIRST SET OF DISCOVERY OF PERSON(S) WITH KNOWLEDGE OF RELEVANT FACTS, and
(4)REMINDER OF REQUEST FOR DISCLOSURE TO

DEFENDANT/PLAINTIFF
Archstone Memorial Heights

JURY TRIAL DEMANDED

PROPOUNDING PARTY: ZACHARIAH DORSETT


RESPONDING PARTY: Archstone Memorial Heights
REQUESTS FOR PRODUCTION OF DOCUMENTS SET NUMBER ONE:
REQUEST FOR PRODUCTION OF DOCUMENTS NO. 1

Please produce all DOCUMENTS AND THINGS (the term DOCUMENTS AND THINGS shall mean
and refer to all writings including but not limited to originals or copies of handwriting, typewriting,
computer hard copies, emails, printing, photostatic, photographic and every other means of recording
upon any sounds of symbols or combinations thereof) which show or tend to show or which evidence
all communication between Zachariah Dorsett and Archstone Memorial Heights for the period of time
between May, 22nd, 2010, and the date of YOUR response to this request for production of documents.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 2

Please produce all other DOCUMENTS AND THINGS intended for use as evidence in the above
cause.

DISCOVERY OF TRIAL WITNESSES SET NUMBER ONE:


DISCOVERY OF TRIAL WITNESSES NO. 1

Please identify any and all witnesses that Archstone Memorial Heights plans on calling to testify at trial.
Please provide their names, addresses, and telephone numbers.

DISCOVERY OF TRIAL WITNESSES NO. 2

Please identify any and all experts that Archstone Memorial Heights plans on calling to testify at trial.
Please provide their names, addresses, and telephone numbers.

DISCOVERY OF PERSON(S) WITH KNOWLEDGE OF RELEVANT FACTS SET NUMBER ONE:


DISCOVERY OF PERSON(S) WITH KNOWLEDGE OF RELEVANT FACTS NO. 1

Please provide full legal name, address and telephone number for person(s) referred to as Clerrison
Del Castillo, co-signer/Guaruntor on Lease agreement between Zachariah Dorsett and Archstone
Memorial Heights dated May 22nd, 2009.

DISCOVERY OF PERSON(S) WITH KNOWLEDGE OF RELEVANT FACTS NO. 2

Please provide full legal name, address and telephone number for person(s) referred to as Danielle
Thomson, Customer Service Associate on Lease agreement between Zachariah Dorsett and
Archstone Memorial Heights dated May 22nd, 2009.

DISCOVERY OF PERSON(S) WITH KNOWLEDGE OF RELEVANT FACTS NO. 3

Please provide fulle legal name, address and telephone number for person(s) refferred to as Renee
Renobato on Lease agreement between Zachariah Dorsett and Archstone Memorial Heights dated
May 22nd, 2009.

REMINDER OF REQUEST FOR DISCLOSURE PAST DUE, DATED JULY 2nd 2010

Please note that a request for disclosure was made on July 2nd 2010, and has not been responded to.

Signed,

Zachariah Dorsett
Plaintiff/Defendant
4347 Alysheba ln.
Friendswood, TX 77546
505.603.7591
Photoszd@gmail.com

You might also like