CAUSE NO.

219-cv-653435

JUAN GONZALEZ, § IN THE DISTRICT COURT OF

§
Plaintiff, §
§
vs. § 219TH JUDICIAL DISTRICT
§
TEXAS TRUCKING §
GROUP, INC, §
§ COLLIN COUNTY, TEXAS
Defendants.

PLAINTIFF JUAN GONZALEZ

FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

TO: Defendant Texas Trucking Group Inc, 21 S. Main Street, Temple, Texas 76501. by and
through their attorneys of record.

Plaintiff, Juan Gonzalez, serves this First Request for Production of Documents to

Defendant, Texas Trucking Group, Inc pursuant to Rule 196 of the Texas Rules of Civil

Procedure. Defendant must produce all requested documents for inspection and copying, not

more than 30 days after service, to 4835 Lyndon B Johnson Frwy, Suite 750 Dallas, Texas

75244. You must supplement your answers in accordance with the Texas Rules of Civil

Procedure.

DEFINITIONS

1. “You”, “your”, and “Plaintiff” shall refer to Defendant Texas Trucking Inc, and any
attorneys, assigns, agents, and representatives, as well as each other person acting,
authorized to act, or purporting to act on his/her behalf, presently or formerly.

2. “Lawsuit” means the above-entitled and numbered cause.

3. “Petition” means Plaintiffs’ Original petition, and any amended or supplemental version
filed thereafter.

______________________________________________________________________________
________________________’S Page 1
FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
4. “Person(s)” means all-natural persons, corporations, partnerships, sole proprietorships,
unions, associations, firms, federations, and any other kind of entity.

5. “Communication” means statements, discussions, conversations, correspondences,

speeches, meetings, remarks, questions, answers, panel discussions, and symposia,
whether written or oral. The terms include, without limitation or generality, both
communications and statements which are face-to-face, and those which are transmitted
by means of intercom, telephone, computer television, radio, or the mail.

6. “Date” means the exact date, month, and year, if ascertainable, or, if not, the best
available approximation.
II.
REQUESTS FOR PRODUCTION

REQUEST NO. 1:

Any an all driving records, including, but not limited to accident reports and traffic violations

pertinent to the employee Richard Jones.

RESPONSE:

REQUEST NO. 2:

All Dash Camera video and/or speedometer used by any vehicle driven by Richard Jones

RESPONSE:

REQUEST NO. 3:

All documents regarding drug, physical and mental health records for employee Richard Jones.

RESPONSE:

______________________________________________________________________________
________________________’S Page 2
FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
 Respectfully submitted,

____________________________________

Cody L. Towns
Texas Bar No. 24034713
TOWNS LAW FIRM, P.C.
4835 Lyndon B Johnson Frwy, Suite 750
Dallas, Texas 75244
(469) 421-1500 Telephone
(469) 421-1505 Facsimile
E-Mail: ctowns@townslawfirm.com
ATTORNEYS FOR PLAINTIFF

______________________________________________________________________________
________________________’S Page 3
FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
 CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing has been served on all
counsel of record on this 26th day of October 2020.

Cody L. Towns

______________________________

Via e-file
Javier Villarreal
Daniel Torres
LAW OFFICES OF JAVIER VILLARREAL, PLLC
2401 Wildflower Drive, Suite A
Brownsville, TX 78526

ATTORNEYS FOR DEFENDANT

______________________________________________________________________________
________________________’S Page 4
FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
______________________________________________________________________________
________________________’S Page 5
FIRST REQUEST FOR PRODUCTION OF DOCUMENTS