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CAUSE NO.

201716162

Julissa Duran § IN THE DISTRICT COURT OF


§
Plaintiff, §
§
§
VS. §
HARRIS COUNTY, TEXAS
§
§
Jennifer Thibeaux §
§
Defendant. §
270TH JUDICIAL DISTRICT

DEFENDANT’S MOTION TO STRIKE PLAINTIFF’S DISCOVERY RESPONSES, MOTION FOR


SANCTIONS, AND FOR COSTS AND FEES

TO THE HONORABLE JUDGE OF SAID COURT:

Pursuant to Texas Rule of Civil Procedure 215.1(b), Defendant, JENNIFER THIBEAUX, files this

Motion to Strike Plaintiff’s Discovery Responses, Motion for Sanctions, and for Costs and Fees and

would respectfully show the Court as follows:

I. BACKGROUND

Plaintiff JULISSA DURAN filed this action on March 8, 2017. The Cause was handled under Level

2 Discovery Rules. The Court established a Discovery Period end date of May 18, 2018. During the

Discovery period and in accordance with the Rules, Defendant filed and served requests and notices to

Plaintiff; and motions to the Court. Plaintiff failed to respond to most of Defendant’s Discovery

requests offering little to no communication during the discovery period. Plaintiff and her counsel

abused the discovery process through late or no answers; no cooperation with inspection of originals;

and excuses absent evidence or legal authority with the existence of Plaintiff’s own social media

Cause No. 201716162


DEFENDANT’S MOTION TO STRIKE DISCOVERY RESPONSES, MOTION FOR SANCTIONS, AND FOR COSTS AND FEES
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providing controverting evidence of said excuses. There is no rational reason for discovery evasion or

abuse in accordance with the Rules.

II. Background

For the Court’s understanding, Defendant documents the chronology of Defendant’s discovery

activity to include requests, notices, and motions as follows:

• Defendant’s First Request for Production

o served January 10, 2018 [EXHIBIT A],


o Answers due February 10, 2018,
o Plaintiff filed responses late February 20, 2018, hours after Defendant’s Motion to
Compel,
o Defendant made numerous conference attempts to resolve deficient production
answers, inquiry into when supplementation would occur, and inspection of Plaintiff’s
originals with no response/resolution from Plaintiff as of the date of this filing;

• Defendant’s Motion to Compel Plaintiff to Answer Defendant’s First Request for Production

o Filed and served February 20, 2018 [EXHIBIT B],


o the Court denied the motion citing, “moot”;

• Defendant’s Request for Disclosures and Preservation of Evidence

o served February 26, 2018 [EXHIBIT C],


o Answers due March 28, 2018,
o Plaintiff never served responses as of the date of this filing,
o Defendant made conference attempts on May 1, 2018 and May 15, 2018 for resolution
outside of the court with no response from Plaintiff;

• Defendant’s Motion to Quash & Motion for Protective Order to Plaintiff

o Filed and served February 27, 2018 [EXHIBIT D]


o Plaintiff filed no opposition to the motion,
o The Court granted the Defendant’s Motion;

• Defendant’s Request for Admissions

o served February 28, 2018 [EXHIBIT E];

Cause No. 201716162


DEFENDANT’S MOTION TO STRIKE DISCOVERY RESPONSES, MOTION FOR SANCTIONS, AND FOR COSTS AND FEES
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• Defendant’s Motion to Compel Further Discovery to Plaintiff for Defendant’s First Request for
Discovery and Allowing Inspection of Originals

o Filed and served March 15, 2018 [EXHIBIT F],


o hearing date for Submission Docket was March 26, 2018,
o Plaintiff served opposition to this motion 45 minutes before the 8:00am hearing time;
failed to notify Defendant of opposition response; and outside of the boundaries of the
Rules for motion responses,
o as of the date of this filing, supplementation of discovery for Defendant’s First Request
for Production and inspection was not allowed by Plaintiff,
o the court has not ruled on the matter as of the date of this filing;

• Defendant’s Request for Interrogatories

o served March 23, 2018 [EXHIBIT G],


o Answers due April 23, 2018,
o Plaintiff served answers late, after the end of the discovery period, without agreement,
▪ Plaintiff’s answers were signed by Plaintiff’s Counsel Sean Roberts, unsigned by
Plaintiff; unsworn, and served 28 days after the deadline and 3 days after the
end of the discovery period on May 21, 2018 [EXHIBIT H]
o Defendant made conference attempt on May 1, 2018 for resolution outside of the
court, 18 days before the end of the discovery period with no response from Plaintiff;

• Defendant’s Notice of Intent to Use Plaintiff’s Production Evidence in Pre-Trial and Trial
Proceedings

o served March 27, 2018 [EXHIBIT I]


o Plaintiff served no response and no objections;

• Defendant’s Notice of Intention to Inspect Plaintiff’s Originals

o served March 28, 2018 [EXHIBIT J],


o contained a summary of all prior attempts to request inspection of Plaintiff’s originals,
o Defendant made additional conference attempts on May 1, 2018 and May 15, 2018 for
resolution outside of the court with no response from Plaintiff;

• Defendant’s Second Request for Production

o served March 29, 2018 [EXHIBIT K],


o answers due April 30, 2018,
o Plaintiff served responses late, after the end of the discovery period, without
agreement,
▪ Plaintiff’s answers were signed by Plaintiff’s counsel Sean Roberts, served 21
days after the deadline and 3 days after the end of the discovery period on May
21, 2018 [EXHIBIT H]

Cause No. 201716162


DEFENDANT’S MOTION TO STRIKE DISCOVERY RESPONSES, MOTION FOR SANCTIONS, AND FOR COSTS AND FEES
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o Defendant made conference attempts on May 1, 2018 for resolution outside of the
court and eighteen (18) days prior to the end of the discovery period with no response
from Plaintiff

• Defendant’s Motion to Compel Plaintiff to Respond to Defendant’s Discovery Requests and for
Costs and Fees

o Filed May 15, 2018 [EXHIBIT L],


o The matter is due to be heard on June 4, 2018 on Submission;

• Defendant requested Deposition dates from Plaintiff to secure Plaintiff’s deposition

o Discussions occurring in March 2018 with Plaintiff’s counsel failing to offer deposition
dates for Plaintiff.

Plaintiff evaded discovery responses and failed to respond to Defendant’s numerous requests

for conference. Additionally, Plaintiff failed to attempt conference, failed to request extensions, or

seemingly address the matters before their own cause of action. In sum, the Plaintiff filed this

groundless and harassing action over fifteen (15) months ago; and has subsequently ignored the

lawsuit and the Texas Rules of Civil Procedure almost entirely since the beginning of the Discovery

Period. With the Discovery period now closed, the Plaintiff failed to respond to multiple discovery

requests in whole, or part during the Discovery Period. Defendant should be entitled to the striking of

Plaintiff’s discovery responses made outside of the discovery period; to the striking of improperly

served/filed responses; and to sanctions awarded as a result of discovery abuse, evasion, and a failure

to allow inspection.

II. ARGUMENT AND AUTHORITIES

A. PLAINTIFF’S DISCOVERY RESPONSES SHOULD BE STRICKEN.

1. Plaintiff’s Interrogatories were late, unsworn, and not signed by the Plaintiff; Sanctions
Should Be Assessed.

The Texas Rules of Civil Procedure require that “a responding party - not an agent or

attorney as otherwise permitted by Rule 14 - must sign the answers under oath . TEX. R. CIV. P.

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DEFENDANT’S MOTION TO STRIKE DISCOVERY RESPONSES, MOTION FOR SANCTIONS, AND FOR COSTS AND FEES
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197.2(d). As aforementioned, Plaintiff was served the Defendant’s Request for Interrogatories

on March 23, 2018 [EXHIBIT G]. Plaintiff’s answers were due April 23, 2018. Plaintiff served

answers by email on May 21, 2018 – twenty-eight (28) days late and three (3) days after the

end of the discovery period [EXHIBIT H]. Plaintiff’s answers were solely signed by her Counsel –

Sean Roberts and emailed from Anjali Sharma to Defendant.

Additionally, Plaintiff failed to serve answers to Defendant’s Request for Interrogatories

within the 30 days as outlined by the Rules. The Texas Rules of Civil Procedure require that “the

responding party must serve a written response on the requesting party within 30 days after

service of the interrogatories, except that a defendant served with interrogatories before the

defendant's answer is due need not respond until 50 days after service of the interrogatories.

TEX R. CIV. P. 197.2(a). Despite Defendant’s attempt to confer with Plaintiff on May 1, 2018

[EXHIBIT O] regarding the lateness of the response, Plaintiff not only failed to serve answers to

the discovery request during the discovery period, but Plaintiff’s counsel failed to respond to

the attempt at conference.

Finally, the Plaintiff’s counsel Anjali Sharma on May 17, 2018 offered up an excuse for

late responses that the Plaintiff had undergone intense surgery [EXHIBIT M]. For the court’s

viewing, I would offer Plaintiff’s own social media postings [EXHIBIT N] as controverting

evidence of Plaintiff’s very active social calendar between January 2018 to the end of the

Discovery period - May 18, 2018. It appears that the Plaintiff found the time to attend galas,

vacations, and other social/charity events during the discovery period with no lapse in her

calendar that would make “intense surgery” a viable or believable barrier to cooperating with

discovery requests over the past five (5) months in Plaintiff’s own cause of action. The Texas

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DEFENDANT’S MOTION TO STRIKE DISCOVERY RESPONSES, MOTION FOR SANCTIONS, AND FOR COSTS AND FEES
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Rules of Civil Procedure 215.2(b) offers court intervention solutions for discovery abuse and

evasion that Defendant respectfully requests the Court consider.

2. Plaintiff’s Answers and Production Related to Defendant’s Second Request for Production
were Late and Served after the Discovery Period Ended; Should be Barred from Use; and
Plaintiff Sanctioned.

The Texas Rules of Civil Procedure require that “a party who fails to make, amend, or

supplement a discovery response in a timely manner may not introduce in evidence the material or

information that was not timely disclosed, or offer the testimony of a witness (other than a named

party) who was not timely identified”. TEX. R. CIV. P. 193.6(a). Plaintiff was served with Defendant’s

Second Request for Production on March 29, 2018, with answers due on April 30, 2018 [EXHIBIT K].

Defendant attempted conference with Plaintiff on May 1, 2018 to address the late responses [EXHIBIT

O]. Plaintiff never responded to the Defendant until after Defendant filed a third Motion to Compel

because of Plaintiff’s discovery abuse [EXHIBIT L]. On May 16, 2018, Plaintiff’s counsel Anjali Sharma

indicated that Plaintiff knew the responses were late and that Plaintiff had undergone intensive

surgery [EXHIBIT M]. The Defendant would respectfully direct the Court to review controverting

evidence of the Plaintiff during the same time period [EXHIBIT N]. Ultimately the Plaintiff produced no

valid reason for the delay. The Defendant would request that the court require evidence such as work

attendance records and medical documentation supporting the reasons for a delay. Plaintiff’s answers

to Defendant’s Second Request for Production should be stricken and barred from use in further

proceedings. Additionally, production Bates labeled DURAN 000143 – 000228 should be barred from

use because the production was produced outside of the discovery period without agreement from

Defendant. Finally, Plaintiff and her counsel should be sanctioned for the delays, lack of cooperation,

and lack of truth about their actions in accordance with the Texas Rules of Civil Procedure, 215.2(b).

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DEFENDANT’S MOTION TO STRIKE DISCOVERY RESPONSES, MOTION FOR SANCTIONS, AND FOR COSTS AND FEES
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B. PLAINTIFF’S FAILURE TO RESPOND TO DEFENDANT’S REQUEST FOR DISCLOSURE SHOULD BAR
ANY OF PLAINTIFF’S EVIDENCE OR WITNESSES FROM USE IN ALL FURTHER PROCEEDINGS AND
THE PLAINTIFF SANCTIONED.

The Texas Rules of Civil Procedure require that “a party who fails to make, amend, or

supplement a discovery response in a timely manner may not introduce in evidence the material or

information that was not timely disclosed, or offer the testimony of a witness (other than a named

party) who was not timely identified”. TEX. R. CIV. P. 193.6(a). Defendant served a Request for

Disclosure to Plaintiff on February 26, 2018. Defendant attempted conference with Plaintiff’s counsel

regarding the matter on May 1, 2018 [EXHIBIT O] with no response from the Plaintiff. The Discovery

period ended on May 18, 2018. As of the date of this filing, Plaintiff has failed to address the

Disclosures answers despite Defendant’s attempts to resolve outside of the court. Plaintiff’s evidence

and witnesses related to Defendant’s Request for Disclosure should be barred from use in all further

proceedings because Plaintiff failed to serve answers in accordance with the Rules. Plaintiff and/or her

counsel should be sanctioned for the discovery abuse and lack of cooperation.

C. PLAINTIFF’S LACK OF SUPPLEMENTATION OF DISCOVERY ANSWERS AND PRODUCTION EVIDENCE


SHOULD BE DISALLOWED IN ALL FURTHER PROCEEDINGS AND THE PLAINTIFF SANCTIONED.

The Texas Rules of Civil Procedure require that “a party who fails to make, amend, or

supplement a discovery response in a timely manner may not introduce in evidence the material or

information that was not timely disclosed, or offer the testimony of a witness (other than a named

party) who was not timely identified”. TEX. R. CIV. P. 193.6(a). Here Plaintiff initially responded to

Defendant’s First Request for Production on February 20, 2018 with responses on questions 6, 8, 10,

14, 19, 29-35, and 39(a-k) as “Plaintiff will supplement” [EXHIBIT P]. Defendant made numerous

requests to inquire as to when supplementation would occur. Plaintiff never responded to Defendant,

however did address the issue on March 26, 2018 in Plaintiff’s Response to Defendant’s Motion to

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DEFENDANT’S MOTION TO STRIKE DISCOVERY RESPONSES, MOTION FOR SANCTIONS, AND FOR COSTS AND FEES
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Compel – II(4) and II(5) arguing that, “the trial in this matter is set for June 18, 2018. Ms. Duran has

been and is currently working to provide all documents in response to defendant’s discovery requests.

She is absolutely not attempting to abuse the discovery process.” [EXHIBIT Q]. Defendant would direct

the court to the Defendant’s First Request for Production [EXHIBIT A] served on January 10, 2018. To

illuminate the Plaintiff’s discovery avoidance and abuse, Defendant asked Plaintiff for her Resume in

request number 35 of which Plaintiff responded, “Plaintiff will supplement”. It is inconceivable that a

reasonably prudent person holding a professional position should take months to produce a

resume/work history of her own work experience and still to date be unable to produce the evidence.

The Plaintiff claimed in her sworn Affidavit filed with the court on September 27, 2017 that her job was

in jeopardy [EXHIBIT R]. The Defendant’s request for work history information is proper and within the

scope of discovery based on Plaintiff’s allegations; and Plaintiff had a duty to respond in accordance

with the Rules during the Discovery period. Defendant is requesting that the court strike the answers

and evidence related to Defendant’s First Request for Production request numbers 6, 8, 10, 14, 19, 29-

35, and 39(a-k) as there was never an adequate response provided or evidence produced. Defendant is

also requesting the court sanction Plaintiff and/or her counsel for this clear abuse of the discovery

process in accordance with the Rules.

D. PLAINTIFF’S EVASION OF ALLOWING DEFENDANT TO INSPECT PLAINTIFF’S PRODUCTION


EVIDENCE SHOLD BE DISALLOWED IN ALL FURTHER PROCEEDINGS AND THE PLAINTIFF
SANCTIONED.

The Texas Rules of Civil Procedure require that “Subject to any objections stated in the

response, the responding party must produce the requested documents or tangible things within the

person's possession, custody or control at either the time and place requested or the time and place

stated in the response, unless otherwise agreed by the parties or ordered by the court, and must

provide the requesting party a reasonable opportunity to inspect them”. TEX. R. CIV. P. 196.3(a). Here,

Cause No. 201716162


DEFENDANT’S MOTION TO STRIKE DISCOVERY RESPONSES, MOTION FOR SANCTIONS, AND FOR COSTS AND FEES
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Defendant made numerous requests contained in the original discovery request and in numerous

attempts at conference to resolve this matter [EXHIBIT J]. It was necessary for Defendant to formally

serve notice of intention to inspect Plaintiff’s production evidence, however Plaintiff failed to respond

to the notice or take any action [EXHIBIT J]. The discovery period is now closed and the Plaintiff never

allowed inspection. Defendant is requesting all production evidence contained in Bates labeled DURAN

000001 – 000142 to be barred from use in all further proceedings and the Plaintiff and/or her counsel

sanctioned for the discovery abuse.

E. DEFENDANT IS ENTITLED TO COSTS ANF FEES

Because Plaintiff has failed to comply with the Texas Rules of Civil Procedure and has

improperly withheld relevant discovery, Plaintiff should be required to pay Defendant’s costs and fees

incurred in preparing, filing, and presenting this Motion. In granting a motion to strike and motion for

sanctions, a court ''''shall, after opportunity for hearing, require a party whose conduct necessitated

the motion or attorney advising such conduct or both of them to pay . . . the reasonable expenses

incurred in obtaining the order, including attorney fees," unless such an award would be unjust. TEX. R.

CIV. P. 215.1(d) (emphasis added). Because there are no exigent circumstances to justify Plaintiff’s

conduct here, an award of costs and fees is appropriate

IV. PRAYER

Based on the foregoing, the Defendant respectfully requests that this Court:

1. Grant this motion to strike Plaintiff’s Discovery Responses and Production made outside of

the Discovery Period including Bates labeled DURAN 000143 – 000238;

2. Grant this motion to bar all evidence and witness information related to the Defendant’s

Request for Disclosures because the Plaintiff never served answers ;

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DEFENDANT’S MOTION TO STRIKE DISCOVERY RESPONSES, MOTION FOR SANCTIONS, AND FOR COSTS AND FEES
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3. Grant this motion to bar all evidence and witness information related to the production

evidence Plaintiff failed to supplement;

4. Grant this motion to bar all evidence Bates labeled DURAN 000001 – 000142 because

Plaintiff failed to allow inspection of originals;

5. Order Plaintiff to pay all costs and reasonable fees incurred by Defendant in this action;

6. Order Plaintiff’s counsel, Sean Alan Roberts (Texas Bar: 00797328) and Anjali Sharma

(Texas Bar: 24094403) to pay Sanctions to Defendant resulting from discovery abuse,

discovery delays, discovery evasion, and withholding discovery;

7. Order such further relief to which the Defendant is entitled; and

8. A proposed order granting the motion has been attached for the Court’s review [EXHIBIT S]

V. CERTIFICATE OF CONFERENCE

Efforts to resolve these matters without court intervention were attempted as evidenced by

the Certificate of Conference included herein [EXHIBIT O].

Respectfully submitted,

Defendant’s Signature

JENNIFER THIBEAUX
191 Boulevard Rene-Levesque Est
Montreal, QC, Canada
713-510-7714

PRO SE

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DEFENDANT’S MOTION TO STRIKE DISCOVERY RESPONSES, MOTION FOR SANCTIONS, AND FOR COSTS AND FEES
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CERTIFICATE OF SERVICE
I do hereby certify that I have eFiled with the Harris County Courts and served a true and correct
copy of the instrument on Plaintiff’s counsel of record in accordance with Tex. R. Civ. P. 21a on the
1st day of June, 2018.

Defendant’s Signature

Cause No. 201716162


DEFENDANT’S MOTION TO STRIKE DISCOVERY RESPONSES, MOTION FOR SANCTIONS, AND FOR COSTS AND FEES
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EXHIBIT A
1/10/2018 7:49 PM
Chris Daniel - District Clerk Harris County
Envelope No. 21751557
By: Danielle Gutierrez
Filed: 1/10/2018 7:49 PM

CAUSE NO. 201716162

Julissa Duran § IN THE DISTRICT COURT OF


§
Plaintiff, §
§
§
HARRIS COUNTY, TEXAS

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VS. §

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§

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§
Jennifer Thibeaux §

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§
270TH JUDICIAL DISTRICT

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Defendant. §

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DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF

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TO: Plaintiff JULISSA DURAN, c/o alleged attorney of record SEAN A. ROBERTS, alleged State Bar #
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00797328; and THE ROBERTS LAW FIRM.


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Pursuant to Rules 193 and 196 of the Texas Rules of Civil Procedure, the woman, Jennifer Thibeaux,
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defendant herein, requests that you produce certain documents, tangible things, recordings and other data
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compilations from which information can be obtained or translated, if necessary, into reasonable, usable
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forms, which are in the possession, custody or control of you, your agents, servants or attorneys. You
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must make a written response to each Request that states the materials will be produced as requested, and
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that you will comply with this Request, except to the extent that you object, and state the specific reasons
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for your objections. Your written responses are to be served and the requested items are to be produced no
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later than thirty (30) standard calendar days from the date you receive these Requests and prior to any

hearing and no less than thirty (30) standard calendar days prior to trial. Written response of requested

items are to be served to Jennifer Thibeaux, care of PO Box 352, Waco, TX 76703. Certified copies will

be sufficient with the originals expected to be produced for inspection by Defendant by request, at any

hearing and at trial.

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DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF 1
In responding to the following Requests for Production, you should furnish all information and items

within your possession, custody or control, including information in the possession, custody or control of

your employees, agents, attorney, or investigators, and all persons acting in your behalf and not merely

such information within your personal knowledge.

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The following terms are defined as follows:

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1. “PLAINTIFF” when used refers to the named “JULISSA DURAN” and her agents, attorneys,

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representatives, predecessors, successors, heirs and assigns.

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2. “YOU” or “YOUR” when used refers to “JULISSA DURAN”, her respective agents, attorneys,

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representatives, predecessors, successors, heirs and assigns.
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3. “DEFENDANT”, “defendant”, or “Defendant” when used refers to the woman Jennifer
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Thibeaux, her respective agents, attorneys, representatives, predecessors, successors, heirs and
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assigns.
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4. “IDENTIFY” or “IDENTITY”:
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For purposes of this specific request


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(a) When used in reference to a natural person or persons, means to state his or her present or last
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known address, business and home telephone number (including area code), title or position
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and place of employment.


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(b) When used in reference to a governmental or business entity, means to state its present or last
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known mailing address, state of incorporation, if any, Employer Identification Number (EIN)
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or Taxpayer Identification number (TIN) or both, area code and telephone number, and
names and titles of persons with proper authority within the entity who may be contacted
regarding this cause of action.

(c) If referring to documents, means to state with respect thereto its date, author or signer,
addressee, type of document, all other information with sufficient particularity to enable it to
be identified, its present or last known location, its custodian or custodians, and all persons to

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DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF 2
whom the document or a copy thereof was distributed. If a document is claimed to be
privileged, the privilege claimed and the grounds therefore should be stated.

5. “DOCUMENT” or “RECORD” shall mean writings of every kind, source, and authorship, both
originals and all non-identical 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

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government agency, department, administrative entity, or personnel. The term shall include

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handwritten, typewritten, printed, photocopied, photographic, or recorded matter. It shall include
communications in words, symbols, pictures, sound recordings, films, tapes, and information

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stored in, or accessible through, computer or other information storage retrieval systems, together

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with the codes and/or programming instructions and other material necessary to understand and

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use such systems. For purposes of illustration and not limitation, the terms shall include:

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correspondence; transcripts of testimony; letters; notes; reports; papers; files; books; records;
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contracts; agreements; telegrams; teletypes and other communications sent or received; diaries;
calendars; logs; notes or memoranda of telephonic or face-to-face conversations; drafts; work
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papers; agendas; bulletins; notices; circulars; announcements; instructions; schedules, minutes,


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summaries, and other records and recordings of any conferences, meetings, visits, statements,
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interviews, or telephone conversations; bills, statements, and other records of obligations and
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expenditures; canceled checks, vouchers, receipts, and other records of payments; ledgers,
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journals, balance sheets, profit and loss statements, and other sources of financial data; analyses;
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statements; interviews, affidavits; printed matter (including published books, articles, speeches,
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and newspaper clippings); press releases; charts; drawings; maps; plats; specification manuals;
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brochures; parts lists; memoranda of all kinds to and from any persons, agencies, or entities;
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technical and engineering reports, evaluations, advice, recommendations, commentaries,


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conclusions, studies, test plans, manuals, procedures, data reports, results, and conclusions;
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records of administrative, technical, and financial actions taken or recommended; and all other
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writings the contents of which relate to, discuss, consider, or otherwise refer to the subject matter
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of the particular discovery requested.

If any document requested to be identified was but is no longer in existence, state whether it is:

1.) Missing or lost,

2.) Destroyed,

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DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF 3
3.) Transferred voluntarily or involuntarily to others, and if so, to whom or

4.) Otherwise disposed of; and in each instance explain the circumstances surrounding and
authorization of such disposition thereof, state the appropriate date thereof and describe its
contents.

6. “REFER(S) TO”, “Relate(s) To”, “Relating To”, “Pertaining To” shall mean referring to, referred

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to, comprising, comprised of, alluding to, responding to, connected with, commenting on, in

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respect of, about, regarding, discussing, showing, deciding, mentioning, reflecting, analyzing,

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constituting, evidencing, and all other words of similar import. These terms include documents,

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things and information that may support, sustain, refute and/or contradict an allegation and/or

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defense in the matter at hand.

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7. “INCIDENT(S)” shall mean the events and occurrences comprising, relating or stemming from

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your claims and allegations asserted in this lawsuit.
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8. “PERSON” includes the plural, as well as the singular, and means any natural person or
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individual – when identified as such, or association, business organization, partnership,
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corporation (parent, subsidiary or affiliate), governmental organization, or formal or informal


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group, subdivision or affiliate thereof.


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9. Plural words include their singular equivalent; singular words include their plural equivalent.
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10. “AND” and “OR” shall be construed either conjunctively or disjunctively as required by the
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context to bring within the scope of these requests any document that might be deemed outside its
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scope by another construction.


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11. “COMMUNICATION” shall mean and include every manner or means of transmitting,
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disclosure, transfer, or exchange, and every form of transmission, disclosure, transfer or exchange
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of information, whether orally, electronically, or by document and whether face-to-face, by


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telephone, mail, personal delivery, by computer or otherwise.

12. “STATEMENT” shall mean and include any written or graphic statement or otherwise adopted or
approved by the user in making it, and stenographic, mechanical, electrical or other recording or
transcription thereof which is a substantially verbatim recital of an oral statement by the person
making it and contemporaneously recorded.

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DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF 4
13. “DESCRIBE IN DETAIL” shall mean to give a complete, accurate and full description
concerning the matter about which inquiry is made, including the full name, address and
telephone number of persons involved, if appropriate, along with dates, times, places, amounts
and other particulars which make the answer to the interrogatory fair and meaningful.

14. “COMPLAINT” when used refers to your Original Complaint/Petition/Affidavit/Citation on file


with the papers in this lawsuit, and any amendment thereto.

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15. “NOTE” when used shall refer to any written promise by one party to pay money to another party

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or to bearer which relates to this lawsuit, including but not limited to any: promissory note, loan

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agreement, collateral note, joint note, installment note, demand note, executed note, mortgage

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note, negotiable note, non-recourse note, recourse note, renewal note, sale note, secured note, or

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unsecured note.

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16. Each request for production of documents is to be deemed a continuing one. If, after serving an
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answer to any request for an admission, you obtain or become aware of any further information
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pertaining to that requested production of documents, you are requested to serve a supplemental
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answer setting forth such information.


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REQUESTS FOR PRODUCTION


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1. Produce any and all written or recorded statements or reports in the care, custody or control of
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you or any of your agents or representatives obtained from any person having knowledge of facts
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taken prior to the filing of this lawsuit which will be used as the legal basis for defamation claims
under Texas law to be used in Plaintiff’s lawsuit
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2. Produce all writings, drawings, graphs, charts, photographs, or other tangible items of any kind
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intended to be used by you as exhibits at the trial of this case.


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3. Produce all writings, drawings, graphs, charts, photographs, or other tangible items of any kind
that you intend to admit as evidence at the trial of this case.

4. Produce copies of all letters or correspondence between the Defendant and Plaintiff which will be
used as the legal basis for defamation claims under Texas law to be used in Plaintiff’s lawsuit.

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DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF 5
5. Produce copies of all letters or correspondence from Plaintiff to Defendant prior to filing this
lawsuit which identifies the Plaintiff’s complaint of Defendant’s defamation.

6. Produce a copy of all letters or correspondence between you and any other person or entities
relating to the conduct and incidents which will be used as the legal basis for defamation claims
under Texas law to be used in Plaintiff’s lawsuit.

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7. Produce copies of any and all telephone message slips, notes, or other correspondence reflecting

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oral and/or telephone conversations between you and any other person or entity relating to the

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conduct and incidents which will be used as the legal basis for defamation claims under Texas

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law to be used in Plaintiff’s lawsuit.

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8. Produce copies of all expert reports which in any way relate to this lawsuit. If such reports are not

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in writing, but were given verbally, Defendant requests that the reports be reduced to writing and

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provided to Defendant which will be used as the legal basis for defamation claims under Texas
law to be used in Plaintiff’s lawsuit. Da
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9. Produce copies of all statements and/or admission you contend were made by Defendant or any
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past or present employee or agent of Defendant or any other person acting on behalf of Defendant
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which will be used as the legal basis for defamation claims under Texas law to be used in
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Plaintiff’s lawsuit.
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10. Produce any and all reports, publications, or other documents evidencing any standards, laws,
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regulations, or industry standards which you contend Defendant violated with respect to the
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subject matter of this lawsuit which will be used as the legal basis for defamation claims under
Texas law to be used in Plaintiff’s lawsuit.
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11. Produce all documents which form the basis of your contention that Defendant, or any of her
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representatives, agents, or employees, is/are responsible for the injuries and/or damages allegedly
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sustained by you which will be used as the legal basis for defamation claims under Texas law to
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be used in Plaintiff’s lawsuit

12. Produce all documents that reflect, refer or relate to monies received by you from any source
which relate to the incidents, conduct, injuries or claims involved in this lawsuit.

13. Produce all documents that reflect, refer or relate to monies paid by you to any person or entity
which relates to the incidents, conduct, injuries or claims involved in this lawsuit.

Cause No. 201716162


DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF 6
14. Produce all documents that reflect, refer or relate to your costs associated with your pursuit of this
lawsuit.

15. Produce all pleadings and other documents reflecting the nature of the claims and defenses, and
the disposition of such claims, at issue any lawsuit or other legal action in which you have been
involved, either as a plaintiff or as a defendant, other than the above-styled lawsuit.

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16. Produce all correspondence, reports and other records relating to any claim which you have made

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against any person or entity other than Defendant as a result of the incidents and conduct which

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will be used as the legal basis for defamation claims under Texas law to be used in Plaintiff’s

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lawsuit.

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17. Produce all diaries, calendars or any other lists or notes kept by you which relate to the incidents

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or conduct made the basis of this suit or any injuries or damages allegedly sustained by you as a

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result of such incidents or conduct which will be used as the legal basis for defamation claims
under Texas law to be used in Plaintiff’s lawsuit.Da
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18. Produce any and all records or documents pertaining to any economic losses allegedly sustained
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by you as a result, in whole or in part, of the conduct and incident at issue which will be used as
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the legal basis for defamation claims under Texas law to be used in Plaintiff’s lawsuit.
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19. Produce all documents signed by Defendant or any alleged representative, agent or employee of
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Defendant prior to the institution of this suit which will be used as the legal basis for defamation
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claims under Texas law to be used in Plaintiff’s lawsuit.


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20. Produce copies of any and all documents evidencing any conduct, action, and/or omission
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allegedly committed by Defendant and relevant to your claims which will be used as the legal
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basis for defamation claims under Texas law to be used in Plaintiff’s lawsuit.
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21. Produce all correspondence and unprivileged documents between you and any entity or person
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concerning any of the events, incidents, conduct or alleged damages which form the basis of any
of the claims asserted by you which will be used as the legal basis for defamation claims under
Texas law to be used in Plaintiff’s lawsuit.

22. Produce all documents you received from or gave to Defendant concerning or relating to any of
the damages, conditions, or events giving rise to or which will be used as the legal basis for
defamation claims under Texas law to be used in Plaintiff’s lawsuit.

Cause No. 201716162


DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF 7
23. Produce copies of all documents supporting any claim for damages you contend were caused by
the actions and/or omission of Defendant which will be used as the legal basis for defamation
claims under Texas law to be used in Plaintiff’s lawsuit.

24. Produce copies of all documents and supporting materials, events, recordings, or any other
evidence to be used in this lawsuit to support claims made by Plaintiff referenced in paragraph
one (1) in her Affidavit [EXHIBIT A] filed with the 270th Judicial Court on September 27, 2017

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in which Plaintiff states under oath, “I have been mentality tormented by my ex-boyfriend’s

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girlfriend, Jennifer Thibeaux, for the past year.” which will be used as the legal basis for
defamation claims under Texas law to be used in Plaintiff’s lawsuit.

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25. Produce the identity of Plaintiff’s ex-boyfriend Plaintiff references in paragraph one (1) in her

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Affidavit [EXHIBIT A] filed with the 270th Judicial Court on September 27, 2017 in which

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Plaintiff states under oath, “I have been mentality tormented by my ex-boyfriend’s girlfriend,
Jennifer Thibeaux, for the past year”, including all documents to support the claim of personal
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relationships between Plaintiff and Defendant including supporting materials referring to dates
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Plaintiff alleges relationships.
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26. Produce the identity of Plaintiff’s employer(s) that are connected to and pertain to the basis of the
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claims being made by you in this lawsuit.


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27. Produce the identity of all Plaintiff employer supervisor(s) that are connected to and pertain to the
basis of the claims being made by you in this lawsuit.
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28. Produce copies of documents and supporting materials Plaintiff references in paragraph two (2) in
her Affidavit [EXHIBIT A] filed with the 270th Judicial Court on September 27, 2017 in which
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Plaintiff states under oath, “Jennifer Thibeaux has sent letters to my boss of two years at Cotton
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Ranch Events to try to get me fired. She has sent him a couple of letters with false allegations.”
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which will be used as the legal basis for defamation claims under Texas law to be used in
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Plaintiff’s lawsuit.

29. Produce copies of Plaintiff’s employment performance records at Cotton Ranch Events to include
performance evaluations, performance appraisals, performance improvement plans, performance
related pay docking, and performance bonuses.

Cause No. 201716162


DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF 8
30. Produce copies of Plaintiff’s employment attendance, leave of absence, leave with pay, leave
without pay, and disciplinary records at Cotton Ranch Events during her entire tenure of
employment.

31. Produce copies of any documentation from Cotton Ranch Events or the clients if Cotton Ranch
Events that references Plaintiff’s job performance, job future, and/or job security during her
employment tenure.

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32. Produce copies of any documentation from Plaintiff’s employer Cotton Ranch Events relating to

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salary pay increases, decreases, or bonuses paid during Plaintiff’s employment tenure.

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33. Produce copies of Plaintiff’s past two (2) years employment pay stubs from Cotton Ranch Events.

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34. Produce copies of Plaintiff’s request for medical leave from Cotton Ranch Events.

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35. Produce a copy of Plaintiff’s job history resume to include company and/or organization name,
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place of business, job title, supervisor identifying information, description of Plaintiff’s job role,
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reason for Plaintiff’s employment termination, Plaintiff’s education and certificates, and any
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other job-related work that comprises Plaintiff’s work history as an adult over the past 30 years.
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36. Produce copies of the documents Plaintiff references in paragraph three (3) in her Affidavit
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[EXHIBIT A] filed with the 270th Judicial Court on September 27, 2017 in which Plaintiff states
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under oath, “Jennifer Thibeaux has also sent letters to Absolutely! Katy Magazine in October and
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stated in the letter that I shouldn’t have survived cancer.” which have made the basis of the claims
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being made by you in this lawsuit. Additionally, Plaintiff is requested to produce the original
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documents in this request for inspection by Defendant. Plaintiff is also requested to produce the
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evidence of the form of transmission of said documents either physical or electronic for each and
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every document which pertain to or makes the basis of the claims being made by you in this
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lawsuit.
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37. Produce copies of documents the Plaintiff alleges were sent from Defendant to any and all
magazine publications which have made the basis of the claims being made by you in this
lawsuit. Additionally, Plaintiff is requested to produce the original documents in this request for
inspection by Defendant. Plaintiff is also requested to produce the evidence of the form of
transmission of said documents either physical or electronic for each and every document which
pertain to or makes the basis of the claims being made by you in this lawsuit.

Cause No. 201716162


DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF 9
38. Produce copies of any and all documents reflecting, evidencing, or comprising any note, letter,
electronic mail, facsimile transmission, social media posting, live broadcast, recorded broadcast,
or other form of communication as defined in “COMMUNICATION” within this
DEFENDANT’S FIRST REQUEST FOR PRODUCTION which pertain to or makes the basis of
the claims being made by you in this lawsuit.

39. Produce copies of medical documents Plaintiff references in paragraph four (4) in her Affidavit

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[EXHIBIT A] filed with the 270th Judicial Court on September 27, 2017 in which Plaintiff states,

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“With her sending letters to my work place and to the magazines defaming my character with
false allegations, it has really put me in a bad depression and had to see Dr. Patricia Salvato.”

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which have made the basis of the claims being made by you in this lawsuit. Defendant requests

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the following documents based on Plaintiff’s claims in this lawsuit:

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a. Produce the evidence of the date of Plaintiff’s original medical diagnosis of depression or
any other illness Plaintiff alleges which pertain to or makes the basis of the claims being
made by you in this lawsuit.
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b. Produce copies of physician(s) documentation pertaining to the medical diagnosis of


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depression or any other illness Plaintiff alleges which pertain to or makes the basis of the
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claims being made by you in this lawsuit.


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c. Produce copies of physician(s) documentation of Plaintiff’s physical symptoms of the


medical diagnosis of depression or any other illness Plaintiff alleges which pertains to or
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makes the basis of the claims being made by you in this lawsuit.
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d. Produce the identity of the treating physician(s) that extended and/or agreed with the
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medical diagnosis of depression or any illness Plaintiff alleges which pertain to or makes
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the basis of the claims being made by you in this lawsuit.


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e. Produce the overall dates of treatment by the treating physician(s) that extended or agreed
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with the medical diagnosis of depression or any illness Plaintiff alleges which pertain to
or makes the basis of the claims being made by you in this lawsuit.

f. Produce copies of the medical treatment records and treatment notes pertaining to
Plaintiff’s medical diagnosis of depression or any illness Plaintiff alleges which pertain to
or makes the basis of the claims being made by you in this lawsuit.

Cause No. 201716162


DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF 10
g. Produce copies of the medication scripts prescribed by treating physicians to Plaintiff for
the diagnosis of depression or any illness Plaintiff alleges which pertain to or makes the
basis of the claims being made by you in this lawsuit.

h. Produce the identity of the pharmacy or pharmacies in which the Plaintiff filled medicine
prescriptions related to depression or any illness Plaintiff alleges which pertain to or
makes the basis of the claims being made by you in this lawsuit.

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i. Produce copies of the prescription records at each and every pharmacy Plaintiff filled

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medicine prescriptions related to depression or any illness Plaintiff alleges which pertain

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to or makes the basis of the claims being made by you in this lawsuit.

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j. Produce copies of the prescription records of all prescription medications Plaintiff has

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taken in the past five (5) years from the date of this request.

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k. Produce copies of the over-the-counter medications taken by Plaintiff to treat the medical
diagnosis of depression or any other illness Plaintiff alleges which pertain to or makes the
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basis of the claims being made by you in this lawsuit.
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40. Produce copies of documents and/or evidence to be used in this lawsuit to support claims made
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by Plaintiff referenced in paragraph six (6) in her Affidavit filed with the 270 th Judicial Court on
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September 27, 2017 in which Plaintiff states under oath, “It’s a horrible feeling having to watch
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over my should every time I leave and arrive home. Her ongoing conduct gives me concern for
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the safety of sixteen-year-old daughter and myself. We live in constant fear for our lives.” which
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have made the basis of the claims being made by you in this lawsuit.
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41. If not previously produced in response to the foregoing requests for production, produce copies of
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all documents upon which you rely in support of your contention that Defendant committed any
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wrongdoing or improper act or omission that has harmed you in any way.
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42. Any other manner of thing that will go to responsively address each and every thing as said to be
wanting in Defendant’s answer not already covered by this request.

Cause No. 201716162


DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF 11
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EXHIBIT B
2/20/20189:57:00AM
ChrisDaniel-DistrictClerk
2/20/2018 9:57 AM
HarrisCounty
Chris Daniel - District Clerk Harris County
EnvelopeNo:22627097
Envelope No. 22627097
By:GUTIERREZ,DANIELLEBy: Danielle Gutierrez
Filed:2/20/20189:57:00AM
Filed: 2/20/2018 9:57 AM

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EXHIBIT C
2/26/2018 6:46 AM
Chris Daniel - District Clerk Harris County
Envelope No. 22753897
By: Danielle Gutierrez
Filed: 2/26/2018 6:46 AM

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EXHIBIT D
2/27/2018 11:09 PM
Chris Daniel - District Clerk Harris County
Envelope No. 22819800
By: Danielle Gutierrez
Filed: 2/27/2018 11:09 PM

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EXHIBIT E
2/28/20183:50:00PM
ChrisDaniel-DistrictClerk
2/28/2018 3:50 PM
HarrisCounty
Chris Daniel - District Clerk Harris County
EnvelopeNo:22845695
Envelope No. 22845695
By:GUTIERREZ,DANIELLEBy: Danielle Gutierrez
Filed:2/28/20183:50:00PM
Filed: 2/28/2018 3:50 PM

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EXHIBIT F
3/15/2018 5:25 PM
Chris Daniel - District Clerk Harris County
Envelope No. 23209096
By: Danielle Gutierrez
Filed: 3/15/2018 5:25 PM

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EXHIBIT G
3/23/2018 7:59 AM
Chris Daniel - District Clerk Harris County
Envelope No. 23372506
By: SASHA PRINCE
Filed: 3/23/2018 7:59 AM

CAUSE NO. 201716162

Julissa Duran § IN THE DISTRICT COURT OF


§
Plaintiff, §
§
§

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VS. HARRIS COUNTY, TEXAS

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§
§

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§
Jennifer Thibeaux §

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§
270TH JUDICIAL DISTRICT

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Defendant. §

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DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF
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TO: Plaintiff JULISSA DURAN, c/o alleged attorney of record SEAN A. ROBERTS, alleged State Bar
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# 00797328; and THE ROBERTS LAW FIRM.


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Pursuant to the Texas Rules of Civil Procedure, Rule 197, JENNIFER THIBEAUX,
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Defendant herein hereby submits the following Interrogatories to Plaintiff JULISSA DURAN.
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Defendant requests that Plaintiff serve her answers, in writing and under oath, to the
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Defendant at Jennifer Thibeaux, PO. Box 352, Waco, TX, 76703, within thirty (30) days of service
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of these Interrogatories. Certified copies will be sufficient with the originals expected to be
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produced for inspection by Defendant by request, at any hearing and at trial.

I. INSTRUCTIONS

A. These interrogatories are deemed continuing. Plaintiff is requested to provide, by way of

supplementary responses, such as additional information as may hereafter be obtained by

Cause No. 201716162


DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF 1
the Plaintiff, or any person on Plaintiff’s behalf, that will augment, supplement or otherwise

modify the answers now given in response to the following interrogatories.

B. If any of these interrogatories cannot be responded to in full, answer to the extent possible,

specifying the reasons for Plaintiff’s inability to answer the remainder and stating what

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information Plaintiffs have concerning the unanswered portions

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C. Identify each and every document that once existed but which no longer exists, or for which

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you cannot locate a copy in your possession or control.

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D. For any interrogatory which is objected to on the ground of any privilege, including

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attorney-client work product doctrine, please provide the following information:

1. approximate date; Da
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2. type of document (e.g. letter, email, memo);
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3. a general description of its subject matter;


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4. identification of author and address, if applicable;


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5. identification of all recipients;


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6. present location and custodian;


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7. any other description necessary to enable the custodian to locate the particular
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document.
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II. DEFINITIONS

The following terms are defined as follows:

1. “PLAINTIFF” when used refers to the named “JULISSA DURAN” and her agents,
attorneys, representatives, predecessors, successors, heirs and assigns.

Cause No. 201716162


DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF 2
2. “YOU” or “YOUR” when used refers to “JULISSA DURAN”, her respective agents,
attorneys, representatives, predecessors, successors, heirs and assigns.

3. “DEFENDANT”, “defendant”, or “Defendant” when used refers to the woman JENNIFER


THIBEAUX, her respective agents, attorneys, representatives, predecessors, successors,
heirs and assigns.

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4. “IDENTIFY” or “IDENTITY”:

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For purposes of this specific request

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(a) When used in reference to a natural person or persons, means to state his or her

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present or last known address, business and home telephone number (including

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area code), title or position and place of employment.
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(b) When used in reference to a governmental or business entity, means to state its
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present or last known mailing address, state of incorporation, if any, Employer


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Identification Number (EIN) or Taxpayer Identification number (TIN) or both, area


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code and telephone number, and names and titles of persons with proper authority
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within the entity who may be contacted regarding this cause of action.
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(c) If referring to documents, means to state with respect thereto its date, author or
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signer, addressee, type of document, all other information with sufficient


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particularity to enable it to be identified, its present or last known location, its


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custodian or custodians, and all persons to whom the document or a copy thereof
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was distributed. If a document is claimed to be privileged, the privilege claimed and


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the grounds therefore should be stated.

5. “DOCUMENT” or “RECORD” shall mean writings of every kind, source, and authorship,
both originals and all non-identical 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

Cause No. 201716162


DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF 3
entity, or personnel. 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 retrieval systems, together
with the codes and/or programming instructions and other material necessary to
understand and use such systems. For purposes of illustration and not limitation, the

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terms shall include: correspondence; transcripts of testimony; letters; notes; reports;

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papers; files; books; records; contracts; agreements; telegrams; teletypes and other

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communications sent or received; diaries; calendars; logs; notes or memoranda of

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telephonic or face-to-face conversations; drafts; work papers; agendas; bulletins;

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notices; circulars; announcements; instructions; schedules, minutes, summaries, and

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other records and recordings of any conferences, meetings, visits, statements,
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interviews, or telephone conversations; bills, statements, and other records of
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obligations and expenditures; canceled checks, vouchers, receipts, and other records of
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payments; ledgers, journals, balance sheets, profit and loss statements, and other
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sources of financial data; analyses; statements; interviews, affidavits; printed matter


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(including published books, articles, speeches, and newspaper clippings); press releases;
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charts; drawings; maps; plats; specification manuals; brochures; parts lists; memoranda
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of all kinds to and from any persons, agencies, or entities; technical and engineering
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reports, evaluations, advice, recommendations, commentaries, conclusions, studies,


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test plans, manuals, procedures, data reports, results, and conclusions; records of
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administrative, technical, and financial actions taken or recommended; and all other
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writings the contents of which relate to, discuss, consider, or otherwise refer to the
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subject matter of the particular discovery requested.


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If any document requested to be identified was but is no longer in existence, state whether
it is:

1.) Missing or lost,

2.) Destroyed,

Cause No. 201716162


DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF 4
3.) Transferred voluntarily or involuntarily to others, and if so, to whom or

4.) Otherwise disposed of; and in each instance explain the circumstances surrounding and
authorization of such disposition thereof, state the appropriate date thereof and
describe its contents.

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6. “REFER(S) TO”, “Relate(s) To”, “Relating To”, “Pertaining To” shall mean referring to,

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referred to, comprising, comprised of, alluding to, responding to, connected with,

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commenting on, in respect of, about, regarding, discussing, showing, deciding,

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mentioning, reflecting, analyzing, constituting, evidencing, and all other words of similar

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import. These terms include documents, things and information that may support,

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sustain, refute and/or contradict an allegation and/or defense in the matter at hand.

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7. “INCIDENT(S)” shall mean the events and occurrences comprising, relating or stemming
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from your claims and allegations asserted in this lawsuit.
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8. “PERSON” includes the plural, as well as the singular, and means any natural person or
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individual – when identified as such, or association, business organization, partnership,


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corporation (parent, subsidiary or affiliate), governmental organization, or formal or


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informal group, subdivision or affiliate thereof.


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9. Plural words include their singular equivalent; singular words include their plural
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equivalent.
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10. “AND” and “OR” shall be construed either conjunctively or disjunctively as required by
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the context to bring within the scope of these requests any document that might be
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deemed outside its scope by another construction.

11. “COMMUNICATION” shall mean and include every manner or means of transmitting,
disclosure, transfer, or exchange, and every form of transmission, disclosure, transfer or
exchange of information, whether orally, electronically, or by document and whether
face-to-face, by telephone, mail, personal delivery, by computer or otherwise.

Cause No. 201716162


DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF 5
12. “STATEMENT” shall mean and include any written or graphic statement or otherwise
adopted or approved by the user in making it, and stenographic, mechanical, electrical
or other recording or transcription thereof which is a substantially verbatim recital of an
oral statement by the person making it and contemporaneously recorded.

13. “DESCRIBE IN DETAIL” shall mean to give a complete, accurate and full description

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concerning the matter about which inquiry is made, including the full name, address and

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telephone number of persons involved, if appropriate, along with dates, times, places,
amounts and other particulars which make the answer to the interrogatory fair and

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meaningful.

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14. “COMPLAINT” when used refers to your Original Complaint/Petition/Affidavit/Citation

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on file with the papers in this lawsuit, and any amendment thereto.
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15. “NOTE” when used shall refer to any written promise by one party to pay money to
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another party or to bearer which relates to this lawsuit, including but not limited to any:
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promissory note, loan agreement, collateral note, joint note, installment note, demand
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note, executed note, mortgage note, negotiable note, non-recourse note, recourse
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note, renewal note, sale note, secured note, or unsecured note.


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III. INTERROGATORIES
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INTERROGATORY NO. 1: Identify the full name and address of every person you believe has
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knowledge regarding the facts of this lawsuit and describe in detail the nature of their
knowledge.
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ANSWER:

INTERROGATORY NO. 2: Please provide a list of all documents you are aware of that are
relevant to this litigation, including the document type, date, author, and current
location/custodian.

ANSWER:

Cause No. 201716162


DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF 6
INTERROGATORY NO. 3: Please list all documents that evidence your financial losses suffered in
connection with this lawsuit including the calculation of losses alleged.

ANSWER:

INTERROGATORY NO. 4: Please provide the first date of your medical diagnosis of Depression
requiring prescribed medication.

ANSWER:

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INTERROGATORY NO. 5: Please provide a list of your treating physician(s) who treated or

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continue to treat you for the medical diagnosis of Depression by including the physician(s) full
name(s), and medical office address(es) where you were treated/examined/diagnosed.

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ANSWER:

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INTERROGATORY NO. 6: In your production evidence you produced a document Bates labeled

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000024 that contained a letter to Pete Bell of Cotton Holdings regarding you and your social
media Instagram.com/justjules2000 postings. The author of the letter is signed “Katy, TX
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Native”. Describe in detail why you allege that this letter was authored by the Defendant?
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ANSWER:
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INTERROGATORY NO. 7: In your production evidence you produced a document Bates labeled
000024 that contained a letter to Pete Bell of Cotton Holdings regarding you and your social
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media Instagram.com/justjules2000 postings. The author of the letter is signed “Katy, TX


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Native”. List the evidence you have that supports that the Defendant is in any way connected to
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the letter.
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ANSWER:
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INTERROGATORY NO. 8: In your production evidence you produced a document Bates labeled
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000017 that contained a fax to Pete Bell of Cotton Holdings regarding you and your social
media Instagram.com/justjules2000 postings. The author of the fax is “Selena Gourlenia”.
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Describe in detail why you allege that this letter was authored by the Defendant?
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INTERROGATORY NO. 9: In your production evidence you produced a document Bates labeled
000017 that contained a fax to Pete Bell of Cotton Holdings regarding you and your social
media Instagram.com/justjules2000 postings. The fax is from “Selena Gourlenia”. List the
evidence you have that supports that the Defendant is in any way connected to the document.

ANSWER:

Cause No. 201716162


DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF 7
INTERROGATORY NO. 10: In your production evidence you produced a document Bates labeled
000034 that contains a letter to Patti Parish Kaminski of Absolutely! Katy Magazine regarding
you and your social media Instagram.com/justjules2000 postings. The author of the letter is
signed “A Disappointed Loyal Reader”. Describe in detail why you allege that this letter was
authored by the Defendant?

ANSWER:

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INTERROGATORY NO. 11: In your production evidence you produced a document Bates labeled

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000034 that contained a letter to Patti Parish Kaminski of Absolutely! Katy Magazine regarding
you and your social media Instagram.com/justjules2000 postings. The author of the letter is

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signed “A Disappointed Loyal Reader”. List the evidence you have that supports that the

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Defendant is in any way connected to the letter.

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ANSWER:

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INTERROGATORY NO. 12: In your production evidence you produced a document Bates labeled

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000028 that contained a fax to Patti Parish Kaminski of Absolutely! Katy Magazine regarding
you and your social media Instagram.com/justjules2000 postings. The fax is from “Selena
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Gourlenia”. Describe in detail why you allege that this letter was authored by the Defendant?
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ANSWER:
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INTERROGATORY NO. 13: In your production evidence you produced a document Bates labeled
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000028 that contained a fax to Patti Parish Kaminski of Absolutely! Katy Magazine regarding
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you and your social media Instagram.com/justjules2000 postings. The fax is from “Selena
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Gourlenia”. List the evidence you have that supports that the Defendant is in any way
connected to the evidence.
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ANSWER:
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INTERROGATORY NO. 14: In your August 23, 2017 sworn Affidavit filed with the court on
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September 27, 2017 and sworn in by Notary Public Marsha R. Campbell [NOTARY ID:
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126008997], you allege that two letters were sent to your boss from the Defendant. Please
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provide the letters you allege were sent from the Defendant to your boss.
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ANSWER:
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INTERROGATORY NO. 15: In your August 23, 2017 sworn Affidavit filed with the court on
September 27, 2017 and sworn in by Notary Public Marsha R. Campbell [NOTARY ID:
126008997], you allege that letters to your boss at Cotton Ranch Events contained false
allegations. Please provide the allegations made in those letters and describe in detail the
reason(s) those allegations are false.

ANSWER:

Cause No. 201716162


DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF 8
INTERROGATORY NO. 16: In your August 23, 2017 sworn Affidavit filed with the court on
September 27, 2017 and sworn in by Notary Public Marsha R. Campbell [NOTARY ID:
126008997], you allege that letters were sent to Absolutely! Katy Magazine from the
Defendant. Please provide the letters you allege were sent from the Defendant.

ANSWER:

INTERROGATORY NO. 17: In your August 23, 2017 sworn Affidavit filed with the court on

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September 27, 2017 and sworn in by Notary Public Marsha R. Campbell [NOTARY ID:

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126008997], you allege that the Defendant sent letters to magazines [plural]. Please provide a
list of all magazines that you allege the Defendant sent letters to about you.

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ANSWER:

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INTERROGATORY NO. 18: In your August 23, 2017 sworn Affidavit filed with the court on

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September 27, 2017 and sworn in by Notary Public Marsha R. Campbell [NOTARY ID:
126008997], you allege that the Defendant defamed your character. Please describe in detail

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the events and incidents that you allege evidence the Defendant defaming your character.

ANSWER: Da
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INTERROGATORY NO. 19: In your August 23, 2017 sworn Affidavit filed with the court on
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September 27, 2017 and sworn in by Notary Public Marsha R. Campbell [NOTARY ID:
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126008997], you allege that the Defendant defamed your character. Please provide a list of all
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documents you are aware of that are relevant to this defamation lawsuit, including the
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document type, date, author, and current location/custodian.


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ANSWER:
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INTERROGATORY NO. 20: Describe in detail all disparaging/negative/condescending remarks


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authored by you online using the social media platform Instragram.com/justjules2000 March 6,
2016 to present?
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ANSWER:
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INTERROGATORY NO. 21: Describe in detail all disparaging/negative/condescending remarks


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authored by you online using the social media platform Twitter.com/julissa_duran March 6,
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2016 to present?

ANSWER:

INTERROGATORY NO. 22: Describe in detail the video you posted online of you mocking
another person’s image/demeanor/physical appearance/attire using the social media platform
Twitter.com/julissa_duran on or about February 3, 2017?

ANSWER:

Cause No. 201716162


DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF 9
INTERROGATORY NO. 23: Please describe in detail the Cease and Desist letter you, an agent
acting on your behalf, or attorney representing you received from the Defendant and Cris
Dishman on or about November 21, 2016 asking you Julissa Duran to stop “cyber following,
making false accusation, making false statement, bullying, harassment, or any other
defamatory, slanderous or libelous statement made against Cris Dishman and Jennifer
Thibeaux”?

ANSWER:

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INTERROGATORY NO. 24: Please describe in detail the Cease and Desist letter you, an agent
acting on your behalf, or attorney representing you received from Cris Dishman on or about

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July 11, 2017 asking you Julissa Duran to stop “cyber following, making false accusation, making

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false statement, bullying, harassment, or any other defamatory, slanderous or libelous
statement made against Cris Dishman and Jennifer Thibeaux”?

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ANSWER:

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Respectfully submitted,
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Defendant’s Signature
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PO BOX 352
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WACO, TX 76703
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713-510-7714
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Cause No. 201716162


DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF 10
CERTIFICATE OF SERVICE

I do hereby certify that I have eFiled with the Harris County Courts and mailed a true and
correct copy of DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF to the plaintiff on
the 23rd day of March, 2018 at the following address

SEAN A. ROBERTS
2555 NORTH MACGREGOR, SUITE 200 Defendant’s Signature

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HOUSTON, TEXAS 77004

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Cause No. 201716162


DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF 11
EXHIBIT H
CAUSE NO. 201716162

JULISSA DURAN § IN THE DISTRICT COURT


§
Plaintiff §
§
v. § HARRIS COUNTY, TEXAS
§
JENNIFER THIBEAUX §
§
Defendant. § 270TH JUDICIAL DISTRICT

PLAINTIFF JULISSA DURAN’S RESPONSES TO DEFENDANT’S


SECOND SET OF REQUEST FOR PRODUCTION AND FIRST SET OF
INTERROGATORIES

To: Defendant, JENNIFER THIBEAUX, P.O. Box 352, Waco, Texas 76703.
Pursuant to the Texas Rules of Civil Procedure, Plaintiff, Julissa Duran, serves

these responses to Defendant’s Second Set of Request for Production and First Set of

Interrogatories.

Respectfully submitted,

Roberts Markland LLP

/s/ Sean A. Roberts


________________________
SEAN A. ROBERTS
State Bar No. 00797328
ANJALI SHARMA
State Bar No. 24094403
2555 North MacGregor, Suite 200
Houston, Texas 77004
(713) 630-0900 (Telephone)
(713) 630-0991 (Fax)
sr@robertsmarkland.com
as@robertsmarkland.com

ATTORNEYS FOR PLAINTIFF


CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing
instrument has been forwarded to all known counsel of record on this 21ST day of May,
2018.
Jennifer Thibeaux
P.O. Box 352
Waco, Texas 76703

DEFENDANT

/s/ Sean A. Roberts


Sean A. Roberts

Plaintiff’s Response to Defendant’s Second Set of Request for Production


1. In Plaintiff’s Original Petition filed with the Court on March 8, 2017, you allege that
defamation, “caused special damages to Plaintiff”. Produce any and all evidence of
special damages that you allege including the calculation of alleged damages.
Plaintiff will supplement.
2. In Plaintiff’s Original Petition filed with the Court on March 8, 2017, you allege that
the Defendant, “published online, in social media, and in written letters, disparaging
and defamatory statement about the Plaintiff.” Produce the specific evidence of
statements about you from the Defendant that were published online.
See Bates Labeled documents DURAN 000143-DURAN 000228.
3. In Plaintiff’s Original Petition filed with the Court on March 8, 2017, you allege that
the Defendant, “published online, in social media, and in written letters, disparaging
and defamatory statement about the Plaintiff.” Produce the specific evidence of
statements about you from the Defendant that were published in social media.
See Bates Labeled documents DURAN 000143-DURAN 000228.
4. In Plaintiff’s Original Petition filed with the Court on March 8, 2017, you allege that
the Defendant, “published online, in social media, and in written letters, disparaging
and defamatory statement about the Plaintiff.” Produce evidence of the methods and
chain of custody of collecting data from the social media you allege contains
“disparaging and defamatory statements about the Plaintiff.”
See Bates Labeled documents DURAN 000143-DURAN 000228.
5. In Plaintiff’s Original Petition filed with the Court on March 8, 2017, you allege that
the Defendant, “published online, in social media, and in written letters, disparaging
and defamatory statement about the Plaintiff.” Produce the specific evidence of
statements about you from the Defendant that were written in latters.
See Bates Labeled documents DURAN 000143-DURAN 000228.
6. In Plaintiff’s Original Petition filed with the Court on March 8, 2017, you allege that,
“the word published by the Defendant were false.” Produce the specific evidence that
the “words” you allege were published by the Defendant were false about you, the
Plaintiff.
Plaintiff will supplement.
7. In Plaintiff’s Original Petition filed with the Court on March 8, 2017, you allege that
the Defendant, “has engaged in cause of conduct intended to harass and startle the
Plaintiffs through the online publication of libelous and defamatory statements.”
Produce evidence of the “cause of conduct” that you allege the Defendant engaged in.
See Bates Labeled documents DURAN 000143-DURAN 000228.
8. Produce any and all written or recorded statements, job evaluations, performance
improvement plans, or any other job status/performance related evidence from your
employer Cotton Ranch Events, a subsidiary of Cotton Holdings that your job was
and/or is in jeopardy as a result of actions taken by defendant.
None.
9. Produce any and all written or recorded statements, email communications,
transcribed voicemails, transcribed voice conversations, or any other form of
communication as defined in this Request from Absolutely! Katy Magazine evidence
that Absolutely! Katy Magazine communicated to you that they received letter from the
Defendant about you, the Plaintiff.
See Bates Labeled documents DURAN 000143-DURAN 000228.
10. Produce any and all written or recorded statements, email communication,
transcribed voicemails, transcribed voice conversations, or any other form of
communication as defined in this Request from Cotton Ranch Events, a subsidiary of
Cotton Holdings evidencing that Cotton Ranch Events, a subsidiary of Cotton Holdings
communicated to you that they received letters from the Defendant about you, the
Plaintiff.
None.
11. Produce any and all documented evidence and communication between you and
Cris Dishman regarding the Defendant to include text messages, email communication,
social media communication, recorded statements, transcribed telephone voicemails,
transcribed phone conversation and any other form of communication defined in the
Definitions section of this Request.
Plaintiff will supplement.
12. Produce any and all documented evidence and communication between you and
Caroline Dazzio Brown, also known as Caroline Dazzio, regarding the Defendant to
include text messages, email communication, social media communication, recorded
statements, transcribed telephone voicemails, transcribed phone conversation and any
other form of communication defined in the Definitions section of this Request.
See Bates Labeled documents DURAN 000143-DURAN 000228.
13. Produce any and all documented evidence and communication between you and
Bubba McDowell regarding the Defendant to include text messages, email
communication, social media communication, recorded statements, transcribed
telephone voicemails, transcribed phone conversations and any other form of
communication defied in the Definitions section of this Request.
See Bates Labeled documents DURAN 000143-DURAN 000228.
14. Produce any and all documented evidence and communication between you and
Floy Johnson regarding the Defendant to include text messages, email communication,
social media communication, recorded statements, transcribed telephone voicemails,
transcribed phone conversations and any other form of communication defied in the
Definitions section of this Request.
None.
15. Produce any and all Cease and Desist letters sent to you; or to any agent acting on
your behalf; or to an attorney representing you from the Defendant.
See Bates Labeled documents DURAN 000143-DURAN 000228.
16. Produce any and all Cease and Desist letters sent to you; or to an agent acting on
your behalf; or to an attorney representing you from the Cris Dishman.
See Bates Labeled documents DURAN 000143-DURAN 000228.
17. Produce any and all police reports you have filed or that you have been recorded in,
in the past five years.
Plaintiff will supplement.
Plaintiff’s Response to Defendant’s First Set of Interrogatories
Identify the full name and address of every person you believe has knowledge
regarding the facts of this lawsuit and describe in detail the nature of their knowledge.
1. Soleil Rucker – Daughter
22361 Colonial Parkway #12202
Katy, Texas 77449

Caroline Dazzio Brown


11511 Royal Ivory Crossing
Houston, Texas 77082
Please provide a list of all documents you are aware of that are relevant to this
litigation, including the document type, date, author and current location/custodian.
2. Cease & Desist Response to Attorney Luis Acevedo from Jennifer Thibeaux on
November 21st, 2016.
Cyber Bully Exposed Fax from Selenia Gourlenia on November 10, 2016 to Pete
Bell.
Letter to Pete Bell from Katy Native
Cyber Bully Exposed Fax to
Letter to Absolutely! Katy from Loyal Reader
#Bully Book – Author Jennifer “DrJ” Thibeaux published on December 16, 2016.
Social Media Stalking Subtweets
Social Media Picture of Jennifer Thibeaux Stalking Plaintiff on LinkedIn.
Please list all documents that evidence your financial losses suffered in connection with
this lawsuit including the calculation of losses alleged.
3. No financial loss just mental anguish on Julissa Duran and daughter Soleil
Rucker fearing for our lives since she had treats on Jennifer Thibeaux’s Facebook
post on August 31st, 2016 and letter to Absolutely! Katy stating “I don’t know
how this woman was blessed with recovery after being so hateful towards
others.”
Please provide the first date of your medical diagnosis of depression requiring
prescribed medication.
4. Date not sure of but it was shortly after all of the harassment started in
November 10th, 2016.
Please provide a list of your treating physician(s) who treated or continue to treat you
for the medical diagnosis of Depression by including the physician(s) full name(s), and
medical office address(s) where you were treated/examined/diagnosed.
5. Dr. Patricia D. Salvato, MD - 6301 Richmond Ave #101 Houston, Texas 77054
In your production evidence you produced a document Bates Labeled 000024 that
contained a letter to Pete Bell of Cotton Holdings regarding you and your social media
Instagram.com/justjules2000 postings. The author of the letter is signed “Katy, TX
Native”. Describe in detail why you allege that this letter was authored by the
defendant?
6. Detail - The Defendant’s boyfriend Cris Dishman called Julissa Duran, the
Plaintiff on November 1st, 2016 at 9:59 p.m. screaming at Julissa Duran regarding
the Instagram Post, dated in October 2016 that Jennifer Thibeaux has attached to
the letter to Pete Bell as “Katy, TX Native”. In the background the defendant is
calling the Plaintiff a “fucking bitch.” I asked Mr. Dishman to let me speak to
Jennifer Thibeaux to resolve this matter and he would not put her on the phone.
On November 10th, 2016 Jennifer Thibeaux sent an anonymous letter to Pete Bell
with the same attachment’s that Cris Dishman and Jennifer Thibeaux called the
Plaintiff about. On November 21st, 2016, Jennifer Thibeaux responded to Julissa
Duran’s Cease and Desist letter from Attorney Luis Acevedo with the exact
attachments sent to Pete Bell on November 10th, 2016. It is evident that Jennifer
Thibeaux sent the letter to Pete Bell with exact attachment she sent in her 10 page
response to Attorney Acevedo signed by Jennifer Thibeaux.
In your production evidence you produced a document Bates Labeled 000024 that
contained a letter to Pete Bell of Cotton Holdings regarding you and your social media
Instagram.com/justjules2000 postings. The author of the letter is signed “Katy, TX
Native”. List the evidence you have that supports that the Defendant is in any way
connected to the letter.
7. List of Evidence – Jennifer Thibeaux sent the exact same attachments in Pete
Bell’s letter dated November 10th and Response to Julissa Duran’s Cease & Desist
letter to Attorney Luis Acevedo dated November 21st, 2016.
In your production evidence you produced a document Bates Labeled 000017 that
contained a faxed to Pete Bell of Cotton Holdings regarding you and your social media
Instagram.com/justjules2000 postings. The author of the fact is “Selena Gourlenia”.
Describe in detail why you allege that this letter was authored by the Defendant?
8. Detail - The Defendant’s boyfriend Cris Dishman called Julissa Duran, the
Plaintiff on November 1st, 2016 at 9:59 p.m. screaming at Julissa Duran regarding
the Instagram Post, dated in October 2016 that Jennifer Thibeaux has attached to
the fax to Pete Bell from Selena Gourlenia. In the background the defendant is
calling the Plaintiff a “fucking bitch.” I asked Mr. Dishman to let me speak to
Jennifer Thibeaux to resolve this matter and he would not put her on the phone.
On November 10th, 2016 Jennifer Thibeaux sent a fax letter to Pete Bell under a
factious name that does not exist, with the same attachments that Cris Dishman
and Jennifer Thibeaux called the Plaintiff about on November 1st, 2016. The IP
address on the fax is from a hotel in Florida that Ms. Thibeaux stayed at during
her time Florida where she sent the fax to Mr. Bell. On November 21st, 2016,
Jennifer Thibeaux responded to Julissa Duran’s Cease and Desist letter from
Attorney Luis Acevedo with the exact attachments sent via fax to Pete Bell on
November 10th, 2016. It is evident that Jennifer Thibeaux sent the fax to Pete Bell
with exact attachments from Julissa Duran’s Instagram account that Jennifer
Thibeaux sent in her response to Attorney Acevedo signed by Jennifer Thibeaux.
In your production evidence you produced a document Bates Labeled 000017 that
contained a faxed to Pete Bell of Cotton Holdings regarding you and your social media
Instagram.com/justjules2000 postings. The author of the fact is “Selena Gourlenia”.
List the evidence you have that support that the Defendant is in any way connected to
the document.
9. Jennifer Thibeaux sent the exact same attachments in Pete Bell’s letter dated
November 10th and Response to Julissa Duran’s Cease & Desist letter to Attorney
Luis Acevedo dated November 21st, 2016.
In your production evidence you produced a document Bates Labeled 000034 that
contains a letter to Patti Parish Kaminski of Absolutely! Katy Magazine regarding you
and your social media instagram.com/justjules2000 posting. The author of the letter is
signed “A Disappointed Loyal Reader”. Describe in detail why you allege that this
letter was authored by the Defendant?
10. Detail - The Defendant’s boyfriend Cris Dishman called Julissa Duran, the
Plaintiff on November 1st, 2016 at 9:59 p.m. screaming at Julissa Duran regarding
the Instagram Post, dated in October 2016 that Jennifer Thibeaux has attached to
the letter to Patti Parrish-Kaminski.” In the background the defendant is calling
the Plaintiff a “fucking bitch.” I asked Mr. Dishman to let me speak to Jennifer
Thibeaux to resolve this matter and he would not put her on the phone. On
November 10th, 2016 Jennifer Thibeaux sent an anonymous letter to Patti Parrish-
Kaminski with the same attachments (Instagram post) that Cris Dishman and
Jennifer Thibeaux called the Plaintiff about. If the letter was truly written by “A
Disappointed Loyal Reader,” why didn’t the reader make a copy from her
October issue of the magazine with Julissa Duran on the cover of Absolutely!
Katy since she calls herself “A disappointed Loyal Reader,” and not stalk Julissa
Duran’s Instagram account and print a copy of the cover from her account. Also
using the word “homework” in this letter and Mr. Pete Bell’s letter shows that
it’s the same person writing the letter. Jennifer uses the same word and sentences
in her letters that prove they were written by her. On November 21st, 2016,
Jennifer Thibeaux responded to Julissa Duran’s Cease and Desist letter from
Attorney Luis Acevedo with the exact attachments Jennifer Thibeaux to Patti
Parrish-Kaminski on November 10th, 2016. It is evident that Jennifer Thibeaux
sent the letter to Patti Parrish-Kaminski with exact attachment she sent in her 10
page Cease & Desist response to Attorney Acevedo signed by Jennifer Thibeaux.
In your production evidence you produced a document Bates Labeled 000034 that
contains a letter to Patti Parish Kaminski of Absolutely! Katy Magazine regarding you
and your social media instagram.com/justjules2000 posting. The author of the letter is
signed “A Disappointed Loyal Reader”. List the evidence you have that supports that
the Defendant is in any way connected to the letter.
11. Jennifer Thibeaux sent the exact same attachments in Patti Parrish-Kaminski’s
letter dated November 10th and Response to Julissa Duran’s Cease & Desist letter
to Attorney Luis Acevedo dated November 21st, 2016.
In your production evidence you produced a document Bates Labeled 000028 that
contained a fax to Patti Parish Kaminski of Absolutely! Katy Magazine regarding you
and your social media Instagram.com/justjules2000 postings. The fax is from “Selena
Gourlenia”. Describe in full detail why you allege that this letter was authored by the
Defendant?
12. Detail - The Defendant’s boyfriend Cris Dishman called Julissa Duran, the
Plaintiff on November 1st, 2016 at 9:59 p.m. screaming at Julissa Duran regarding
the Instagram Post, dated in October 2016 that Jennifer Thibeaux has attached to
the fax to Patti Parrish-Kaminski from Selena Gourlenia. In the background the
defendant is calling the Plaintiff a “fucking bitch.” I asked Mr. Dishman to let me
speak to Jennifer Thibeaux to resolve this matter and he would not put her on the
phone. On November 10th, 2016 Jennifer Thibeaux sent a fax letter to Patti
Parrish-Kaminski under a factious name that does not exist, with the same
attachments that Cris Dishman and Jennifer Thibeaux called the Plaintiff about
on November 1st, 2016. The IP address on the fax is from a hotel in Florida that
Ms. Thibeaux stayed at during her time Florida where she sent the fax to Mrs.
Parrish-Kaminski. On November 21st, 2016, Jennifer Thibeaux responded to
Julissa Duran’s Cease and Desist letter from Attorney Luis Acevedo with the
exact attachments sent via fax to Patti Parrish-Kaminski on November 10th, 2016.
It is evident that Jennifer Thibeaux sent the fax to Patti Parrish-Kaminski with
exact attachments from Julissa Duran’s Instagram account that Jennifer Thibeaux
sent in her response to Attorney Acevedo on November 21st, 2016 signed by
Jennifer Thibeaux.
In your production evidence you produced a document Bates Labeled 000028 that
contained a fax to Patti Parish Kaminski of Absolutely! Katy Magazine regarding you
and your social media Instagram.com/justjules2000 postings. The fax is from “Selena
Gourlenia”. List the evidence that you have that supports that the Defendant is in any
way connected to the evidence.
13. Jennifer Thibeaux sent the exact same attachments in Patti Parrish-Kaminski’s
letter dated November 10th, 2016 from a factious Selena Goulenia and Response
to Julissa Duran’s Cease & Desist letter to Attorney Luis Acevedo dated
November 21st, 2016.
In your August 23, 2017 sworn Affidavit filed with the court on September 27, 2017 and
sworn in by Notary Public Marsha R. Campbell [NOTARY ID: 126008992], you allege
that two letters were sent to your boss from the Defendant. Please provide the letters
you allege were sent from the Defendant to your boss.
14. Typed letter addressed to Pete Bell from “Katy, TX Native” and fax sent to Pete
Bell from a factious person named Selena Gourlenia. Attachment.
In your August 23, 2017 sworn Affidavit filed with the court on September 27, 2017 and
sworn in by Notary Public Marsha R. Campbell [NOTARY ID: 126008992], you allege
that letters to your boss at Cotton Ranch Events contained false allegations. Please
provide the allegation made in those letters and describe in detail the reason(s) those
allegations are false.
15. My boss Mr. Bell follows all of my social media and see’s everything that is
posted. False Allegation is being called a cyber bully/bully when the Julissa
Duran is the one being stalked, harassed and bullied on social media and bullied
through my employment with letters, creating fake Instagram accounts (Katy
Proud Lady) and following Cotton Ranch Events to make comments on the
account about Julissa Duran modeling a wedding dress stating “it’s about time
there is a plus size model used. Katy did it right.” All done by Jennifer Thibeaux.
In your August 23, 2017 sworn Affidavit filed with the court on September 27, 2017 and
sworn in by Notary Public Marsha R. Campbell [NOTARY ID: 126008992], you allege
that letters were sent to Absolutely! Katy Magazine from the Defendant. Please provide
the letters you allege were sent from the Defendant.
16. Typed letter addressed to Absolutely! Katy from “Disappointed Loyal Reader”
and fax sent to Patti Parrish-Kaminski from a factious person named Selena
Gourlenia.
In your August 23, 2017 sworn Affidavit filed with the court on September 27, 2017 and
sworn in by Notary Public Marsha R. Campbell [NOTARY ID: 126008992], you allege
that the Defendant swent letters to magazines [plural]. Please provide a list of all
magazines that you allege the Defendant sent letters to about you.
17. Absolutely! Katy
In your August 23, 2017 sworn Affidavit filed with the court on September 27, 2017 and
sworn in by Notary Public Marsha R. Campbell [NOTARY ID: 126008992], you allege
that the Defendant defamed your character. Please provide describe in detail the events
and incidents that you allege evidence the Defendant defaming your character.
18. Jennifer Thibeaux tried to defame Julissa Duran on her Facebook post on August
31st with all the false allegations of Julissa Duran being obsessed with Jennifer
Thibeaux’s life and her having to deal with me for 5 months. I didn’t know
Jennifer Thibeaux existed until May 2016. Jennifer Thibeaux had no right to
plaster my face and my company’s name on Facebook.
Letters to Pete Bell, Jennifer Thibeaux is defaming by accusing Julissa Duran of
being a cyber bully/bully are false allegations. I’ve done nothing to Ms. Thibeaux
but send her a message on Facebook and Twitter to speak to her woman to
woman about Cris Dishman cheating on both of us for months. I’ve never posted
Jennifer Thibeaux’s name or picture on social media. Jennifer Thibeaux in turn
has set out to physically harm my wellbeing and my employment. Jennifer
Thibeaux has shown evidence in her own letters to Mr. Pete Bell that she has
stalked Julissa Duran by stating in the letters that she has looked at my
Instagram and Twitter accounts.
Letters to Patti-Parrish Kaminski and Absolutely! Katy, Jennifer Thibeaux is
defaming Julissa Duran by accusing me of being a cyber bully/bully are false
allegations. Jennifer stalked my Instagram account and sent in a copy of my
Instagram post of Julissa Duran on the cover of the October Breast Cancer
Awareness Month Issue. Jennifer Thibeaux stats that I hate, bulling, and anger
filled rants from this so called “inspiration.” These are false allegations. Lara Bell
who also worked for Absolutely! Katy is the person that asked me to be on the
cover of the magazine follows me on all social media and I was chosen because I
was a true inspiration to women with breast cancer.
In your August 23, 2017 sworn Affidavit filed with the court on September 27, 2017 and
sworn in by Notary Public Marsha R. Campbell [NOTARY ID: 126008992], you allege
that the Defendant defamed your character. Please provide a list of all documents that
you are aware of that are relevant to this defamation lawsuit, including the document
type, date, author, and current location/custodian.
19. Jennifer Thibeaux’s Facebook Post – August 31st, 2016
Typed Letter to Pete Bell on November 10th, 2016
Fax Letter to Pete Bell on November 10th, 2016
Typed Letter to Patti Parrish-Kaminski on November 10th, 2016
Faxed Letter to Absolutely! Katy on November 10th, 2016
Describe in detail all disparaging/negative/condescending remarks authored by you
online using the social media platform Instagram.com/justjules2000 March 6, 2016 to
present?
20. Julissa Duran does not post negative remarks on social media.
Describe in detail all disparaging/negative/condescending remarks authored by you
online using the social media platform Twitter.com/julissa_duran March 6, 2016 to
present?
21. Julissa Duran does not post negative remarks on social media.
Describe in detail the video you posted online of you mocking another person’s
image/demeanor/physical appearance/attire using the social media platform
Twitter.com/julissa_duran on or about February 3, 2017?
22. Plaintiff objects to this request for production because of the lack of relevancy
of the documents, the request is overbroad and not reasonably tailored to lead to
the discovery of admissible evidence.
Please describe the Cease and Desist letter you, an agent acting on your behalf, or
attorney representing you received from the Defendant and Cris Dishman on or about
November 21, 2016 asking you Julissa Duran to stop “cyber following, making false
accusation, making false statement, bullying, harassment, or any other defamatory,
slanderous or libelous statement made against Cris Dishman and Jennifer Thibeaux”?
23. Plaintiff objects to this request for production because of the lack of relevancy
of the documents, the request is overbroad and not reasonably tailored to lead to
the discovery of admissible evidence.
Please describe in detail the Cease and Desist letter you, an agent acting on your behalf,
or attorney representing you received from Cris Dishman on or about July 11, 2017
asking you Julissa Duran.
24. Plaintiff objects to this request for production because of the lack of relevancy
of the documents, the request is overbroad and not reasonably tailored to lead to
the discovery of admissible evidence.
EXHIBIT I
3/27/2018 12:56 PM
Chris Daniel - District Clerk Harris County
Envelope No. 23455412
By: Danielle Gutierrez
Filed: 3/27/2018 12:56 PM

CAUSE NO. 201716162

Julissa Duran § IN THE DISTRICT COURT OF


§
Plaintiff, §
§
§

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VS. HARRIS COUNTY, TEXAS

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§
§

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§
Jennifer Thibeaux §

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§
270TH JUDICIAL DISTRICT

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Defendant. §

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DEFENDANT’S NOTICE OF INTENTION TO USE PLAINTIFF’S PRODUCTION

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DOCUMENTS IN PRE-TRIAL PROCEEDINGS AND TRIAL
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TO: Plaintiff, JULISSA DURAN, c/o attorney of record Sean Alan Roberts, 2555 N. MacGregor Way,
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Houston, Texas 77004


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Pursuant to the Texas Rules of Civil Procedure, Rule 193.7:


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Production of Documents Self-Authenticating A party's production of a


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document in response to written discovery authenticates the document


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for use against that party in any pretrial proceeding or at trial unless -
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within ten days or a longer or shorter time ordered by the court, after
the producing party has actual notice that the document will be used -
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the party objects to the authenticity of the document, or any part of it,
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stating the specific basis for objection. An objection must be either on


the record or in writing and must have a good faith factual and legal
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basis. An objection made to the authenticity of only part of a document


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does not affect the authenticity of the remainder. If objection is made,


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the party attempting to use the document should be given a reasonable


opportunity to establish its authenticity.

Defendant, Jennifer Thibeaux intends to use Production documents submitted by the Plaintiff,

Bates labeled DURAN 000001 – 000142, and received by Defendant on February 24, 2018 as part of

Defendant’s First Request for Production filed on January 10, 2018 in all further proceedings in

Cause No. 201716162


DEFENDANT’S NOTICE OF INTENTION TO USE PLAINTIFF’S PRODUCTION DOCUMENTS IN PRE-TRIAL PROCEEDINGS AND TRIAL
1
accordance with the T.R.C.P, Rule 193.7. Plaintiff has ten (10) days to file any objections to production

documents Bates labeled, DURAN 000001 - 000142 she has made available thus far. Should the Plaintiff

supplement production with further documents, Defendant, upon review and inspection of the Plaintiff’s

production documents will serve additional notice as deemed appropriate.

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Respectfully submitted,

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Defendant’s Signature

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JENNIFER THIBEAUX

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PO BOX 352
WACO, TX 76703

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713-510-7714
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PRO SE
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- Signed on the 27th Day of March, 2018 by Defendant JENNIFER THIBEAUX


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Cause No. 201716162


DEFENDANT’S NOTICE OF INTENTION TO USE PLAINTIFF’S PRODUCTION DOCUMENTS IN PRE-TRIAL PROCEEDINGS AND TRIAL
2
CERTIFICATE OF SERVICE
I do hereby certify that I have eFiled with the Harris County Courts and served a true and correct copy of
the instrument on Plaintiff’s counsel of record in accordance with Tex. R. Civ. P. 21a on the 27th day of
March, 2018.

Defendant’s Signature

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Cause No. 201716162


DEFENDANT’S NOTICE OF INTENTION TO USE PLAINTIFF’S PRODUCTION DOCUMENTS IN PRE-TRIAL PROCEEDINGS AND TRIAL
3
EXHIBIT J
3/28/2018 11:52 AM
Chris Daniel - District Clerk Harris County
Envelope No. 23485851
By: Anna Evetts
Filed: 3/28/2018 11:52 AM

CAUSE NO. 201716162

Julissa Duran § IN THE DISTRICT COURT OF


§
Plaintiff, §
§
§

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VS. HARRIS COUNTY, TEXAS

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§
§

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§
Jennifer Thibeaux §

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§
270TH JUDICIAL DISTRICT

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Defendant. §

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DEFENDANT’S NOTICE OF INTENTION TO INSPECT PLAINTIFF’S PRODUCTION

DOCUMENT ORIGINALS Da
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TO: Plaintiff, JULISSA DURAN, c/o attorney of record Sean Alan Roberts, 2555 N. MacGregor Way,
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Houston, Texas 77004


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As you are aware, Defendant, JENNIFER THIBEAUX, has made numerous attempts to request
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inspection of Plaintiff, JULLISSA DURAN’s production documents Bates labeled DURAN 000001 –
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000142. Defendant has communicated in length the issues with Plaintiff’s production evidence including
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making requests to inspect the originals of said production evidence. Pursuant to the Texas Rules of Civil
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Procedure, Rule 191.2:


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191.2 Conference Parties and their attorneys are expected to cooperate


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in discovery and to make any agreements reasonably necessary for the


efficient disposition of the case. All discovery motions or requests for
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hearings relating to discovery must contain a certificate by the party


filing the motion or request that a reasonable effort has been made to
resolve the dispute without the necessity of court intervention and the
effort failed.

Cause No. 201716162


DEFENDANT’S NOTICE OF INTENTION TO INSPECT PLAINTIFF’S PRODUCTION DOCUMENT ORIGINALS
1
Due to the Defendant’s numerous requests for inspection made, it was necessary to formally

document the attempts in preparation for court intervention if further delay continues.

Additionally, pursuant to the Texas Rules of Civil Procedure, Rule 196.3(a), 196.3(b), and

196.3(c):

196.3 Production (a) Time and place of production. Subject to any

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objections stated in the response, the responding party must produce

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the requested documents or tangible things within the person's
possession, custody or control at either the time and place requested or

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the time and place stated in the response, unless otherwise agreed by

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the parties or ordered by the court, and must provide the requesting
party a reasonable opportunity to inspect them. (b) Copies. The

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responding party may produce copies in lieu of originals unless a

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question is raised as to the authenticity of the original or in the
circumstances it would be unfair to produce copies in lieu of originals. If

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originals are produced, the responding party is entitled to retain the
originals while the requesting party inspects and copies them. (c)
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Organization. The responding party must either produce documents and
tangible things as they are kept in the usual course of business or
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organize and label them to correspond with the categories in the
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request.
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Defendant has made numerous requests to inspect production evidence produced by Plaintiff
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since January 10, 2018. Today marks the 77th day since Defendant has requested inspection of Plaintiff’s
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originals. In those 77 days, numerous requests for inspection were made. The following dates constitute
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the good faith efforts made by the Defendant to request inspection of the documents:
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1. January 10, 2018 – Contained within the Defendant’s First Request for Production filed
with the court.
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2. February 20, 2018 – An email to Plaintiff’s counsel requesting inspection immediately.


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3. February 26, 2018 – an email and USPS Priority mailed letter detailing production
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deficiencies including a request to inspect Plaintiff’s documents.

4. March 13, 2018 – an email detailing production deficiencies including a request to


inspect Plaintiff’s documents.

5. March 16, 2018 – a Motion to Compel Further Discovery detailing Defendant’s attempts
at conference regarding inspection of Plaintiff’s documents.

Cause No. 201716162


DEFENDANT’S NOTICE OF INTENTION TO INSPECT PLAINTIFF’S PRODUCTION DOCUMENT ORIGINALS
2
6. March 20, 2018 – an email detailing production deficiencies including a request to
inspect Plaintiff’s documents.

7. March 28, 2018 – an email detailing a final request for inspection of Bates labeled
DURAN 000001 – 000142.

The Defendant reminds the Plaintiff that this lawsuit was filed by her over one year ago.

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Defendant reminds the Plaintiff that the burden of proof in a lawsuit rests with the Plaintiff. Defendant

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reminds the Plaintiff that legal claims made against the Defendant will require evidence. Defendant

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reminds the Plaintiff that there should be no surprise that the Defendant is exercising her right to inspect

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documents produced by Plaintiff. Defendant reminds the Plaintiff that the lawsuit filed by the Plaintiff is a

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Defamation lawsuit and the Plaintiff will need to meet the legal standards of Defamation in accordance

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with Texas law.
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Furthermore, Defendant finds the lack of cooperation to be an abuse of the Discovery process and
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in direct conflict with the Texas Rules of Civil Procedure. The Plaintiff is hereby notified by the
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Defendant that any further delay, avoidance, or lack of communication regarding allowing
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inspection of Plaintiff’s originals of production evidence will result in a necessity to seek remedy
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with the Court.


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Respectfully submitted,
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Defendant’s Signature
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JENNIFER THIBEAUX
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PO BOX 352
WACO, TX 76703
713-510-7714

PRO SE

- Signed on the 28th Day of March, 2018 by Defendant JENNIFER THIBEAUX

Cause No. 201716162


DEFENDANT’S NOTICE OF INTENTION TO INSPECT PLAINTIFF’S PRODUCTION DOCUMENT ORIGINALS
3
CERTIFICATE OF SERVICE
I do hereby certify that I have eFiled with the Harris County Courts and served a true and correct copy of
the instrument on Plaintiff’s counsel of record in accordance with Tex. R. Civ. P. 21a on the 28th day of
March, 2018.

Defendant’s Signature

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Cause No. 201716162


DEFENDANT’S NOTICE OF INTENTION TO INSPECT PLAINTIFF’S PRODUCTION DOCUMENT ORIGINALS
4
EXHIBIT K
3/29/2018 1:29 AM
Chris Daniel - District Clerk Harris County
Envelope No. 23507558
By: Danielle Gutierrez
Filed: 3/29/2018 1:29 AM

CAUSE NO. 201716162

Julissa Duran § IN THE DISTRICT COURT OF


§
Plaintiff, §
§
§

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VS. HARRIS COUNTY, TEXAS

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§
§

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§
Jennifer Thibeaux §

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§
270TH JUDICIAL DISTRICT

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Defendant. §

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DEFENDANT’S SECOND REQUEST FOR PRODUCTION TO PLAINTIFF
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TO: Plaintiff JULISSA DURAN, c/o alleged attorney of record SEAN A. ROBERTS, alleged State Bar
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# 00797328; and THE ROBERTS LAW FIRM.


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Pursuant to Rules 193 and 196 of the Texas Rules of Civil Procedure, the woman,
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Jennifer Thibeaux, defendant herein, requests that you produce certain documents, tangible
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things, recordings and other data compilations from which information can be obtained or
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translated, if necessary, into reasonable, usable forms, which are in the possession, custody or
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control of you, your agents, servants or attorneys. You must make a written response to each
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Request that states the materials will be produced as requested, and that you will comply with

this Request, except to the extent that you object, and state the specific reasons for your

objections. Your written responses are to be served and the requested items are to be

produced no later than thirty (30) standard calendar days from the date you receive these

Cause No. 201716162


DEFENDANT’S SECOND REQUEST FOR PRODUCTION TO PLAINTIFF
1
Requests and prior to any hearing and no less than thirty (30) standard calendar days prior to

trial. Written responses of requested items are to be served to Jennifer Thibeaux, care of PO

Box 352, Waco, TX 76703. Certified copies will be sufficient with the originals expected to be

produced for inspection by Defendant by request, at any hearing and at trial.

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I. INSTRUCTIONS

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In responding to the following Requests for Production, you should furnish all

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information and items within your possession, custody or control, including information in the

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possession, custody or control of your employees, agents, attorney, or investigators, and all

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persons acting in your behalf and not merely such information within your personal knowledge.

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II. DEFINITIONS
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The following terms are defined as follows:
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1. “PLAINTIFF” when used refers to the named “JULISSA DURAN” and her agents,
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attorneys, representatives, predecessors, successors, heirs and assigns.


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2. “YOU” or “YOUR” when used refers to “JULISSA DURAN”, her respective agents,
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attorneys, representatives, predecessors, successors, heirs and assigns.


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3. “DEFENDANT”, “defendant”, or “Defendant” when used refers to the woman JENNIFER


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THIBEAUX, her respective agents, attorneys, representatives, predecessors, successors,


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heirs and assigns.


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4. “IDENTIFY” or “IDENTITY”:

For purposes of this specific request

(a) When used in reference to a natural person or persons, means to state his or her
present or last known address, business and home telephone number (including
area code), title or position and place of employment.

Cause No. 201716162


DEFENDANT’S SECOND REQUEST FOR PRODUCTION TO PLAINTIFF
2
(b) When used in reference to a governmental or business entity, means to state its
present or last known mailing address, state of incorporation, if any, Employer
Identification Number (EIN) or Taxpayer Identification number (TIN) or both, area
code and telephone number, and names and titles of persons with proper authority
within the entity who may be contacted regarding this cause of action.

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(c) If referring to documents, means to state with respect thereto its date, author or

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signer, addressee, type of document, all other information with sufficient
particularity to enable it to be identified, its present or last known location, its

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custodian or custodians, and all persons to whom the document or a copy thereof

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was distributed. If a document is claimed to be privileged, the privilege claimed and

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the grounds therefore should be stated.

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5. “DOCUMENT” or “RECORD” shall mean writings of every kind, source, and authorship,
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both originals and all non-identical copies thereof, in your possession, custody, or
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control, or known by you to exist, irrespective of whether the writing is one intended for
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or transmitted internally by you, or intended for or transmitted to any other person or


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entity, including without limitation, any government agency, department, administrative


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entity, or personnel. The term shall include handwritten, typewritten, printed,


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photocopied, photographic, or recorded matter. It shall include communications in


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words, symbols, pictures, sound recordings, films, tapes, and information stored in, or
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accessible through, computer or other information storage retrieval systems, together


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with the codes and/or programming instructions and other material necessary to
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understand and use such systems. For purposes of illustration and not limitation, the
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terms shall include: correspondence; transcripts of testimony; letters; notes; reports;


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papers; files; books; records; contracts; agreements; telegrams; teletypes and other
communications sent or received; diaries; calendars; logs; notes or memoranda of
telephonic or face-to-face conversations; drafts; work papers; agendas; bulletins;
notices; circulars; announcements; instructions; schedules, minutes, summaries, and
other records and recordings of any conferences, meetings, visits, statements,

Cause No. 201716162


DEFENDANT’S SECOND REQUEST FOR PRODUCTION TO PLAINTIFF
3
interviews, or telephone conversations; bills, statements, and other records of
obligations and expenditures; canceled checks, vouchers, receipts, and other records of
payments; ledgers, journals, balance sheets, profit and loss statements, and other
sources of financial data; analyses; statements; interviews, affidavits; printed matter
(including published books, articles, speeches, and newspaper clippings); press releases;
charts; drawings; maps; plats; specification manuals; brochures; parts lists; memoranda

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of all kinds to and from any persons, agencies, or entities; technical and engineering

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reports, evaluations, advice, recommendations, commentaries, conclusions, studies,

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test plans, manuals, procedures, data reports, results, and conclusions; records of

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administrative, technical, and financial actions taken or recommended; and all other

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writings the contents of which relate to, discuss, consider, or otherwise refer to the

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subject matter of the particular discovery requested.
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If any document requested to be identified was but is no longer in existence, state whether
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it is:
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1.) Missing or lost,


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2.) Destroyed,
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3.) Transferred voluntarily or involuntarily to others, and if so, to whom or


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4.) Otherwise disposed of; and in each instance explain the circumstances surrounding and
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authorization of such disposition thereof, state the appropriate date thereof and
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describe its contents.


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6. “REFER(S) TO”, “Relate(s) To”, “Relating To”, “Pertaining To” shall mean referring to,
referred to, comprising, comprised of, alluding to, responding to, connected with,
commenting on, in respect of, about, regarding, discussing, showing, deciding,
mentioning, reflecting, analyzing, constituting, evidencing, and all other words of similar
import. These terms include documents, things and information that may support,
sustain, refute and/or contradict an allegation and/or defense in the matter at hand.

Cause No. 201716162


DEFENDANT’S SECOND REQUEST FOR PRODUCTION TO PLAINTIFF
4
7. “INCIDENT(S)” shall mean the events and occurrences comprising, relating or stemming
from your claims and allegations asserted in this lawsuit.

8. “PERSON” includes the plural, as well as the singular, and means any natural person or
individual – when identified as such, or association, business organization, partnership,
corporation (parent, subsidiary or affiliate), governmental organization, or formal or

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informal group, subdivision or affiliate thereof.

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9. Plural words include their singular equivalent; singular words include their plural

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equivalent.

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10. “AND” and “OR” shall be construed either conjunctively or disjunctively as required by

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the context to bring within the scope of these requests any document that might be
deemed outside its scope by another construction.Da
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11. “COMMUNICATION” shall mean and include every manner or means of transmitting,
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disclosure, transfer, or exchange, and every form of transmission, disclosure, transfer or


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exchange of information, whether orally, electronically, or by document and whether


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face-to-face, by telephone, mail, personal delivery, by computer or otherwise.


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12. “STATEMENT” shall mean and include any written or graphic statement or otherwise
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adopted or approved by the user in making it, and stenographic, mechanical, electrical
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or other recording or transcription thereof which is a substantially verbatim recital of an


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oral statement by the person making it and contemporaneously recorded.


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13. “DESCRIBE IN DETAIL” shall mean to give a complete, accurate and full description
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concerning the matter about which inquiry is made, including the full name, address and
telephone number of persons involved, if appropriate, along with dates, times, places,
amounts and other particulars which make the answer to the interrogatory fair and
meaningful.

14. “COMPLAINT” when used refers to your Original Complaint/Petition/Affidavit/Citation


on file with the papers in this lawsuit, and any amendment thereto.
Cause No. 201716162
DEFENDANT’S SECOND REQUEST FOR PRODUCTION TO PLAINTIFF
5
15. “NOTE” when used shall refer to any written promise by one party to pay money to
another party or to bearer which relates to this lawsuit, including but not limited to any:
promissory note, loan agreement, collateral note, joint note, installment note, demand
note, executed note, mortgage note, negotiable note, non-recourse note, recourse
note, renewal note, sale note, secured note, or unsecured note.

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16. Each request for production of documents is to be deemed a continuing one. If, after

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serving an answer to any request for an admission, you obtain or become aware of any
further information pertaining to that requested production of documents, you are

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requested to serve a supplemental answer setting forth such information.

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III. REQUESTS FOR PRODUCTION
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1. In Plaintiff’s Original Petition filed with the Court on March 8, 2017, you allege that
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defamation, “caused special damages to the Plaintiff”. Produce any and all evidence of
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special damages that you allege including the calculation of alleged damages.
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2. In Plaintiff’s Original Petition filed with the Court on March 8, 2017, you allege that the
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Defendant, “published online, in social media, and in written letters, disparaging and
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defamatory statements about the Plaintiff.” Produce the specific evidence of statements
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about you from the Defendant that were published online.


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3. In Plaintiff’s Original Petition filed with the Court on March 8, 2017, you allege that the
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Defendant, “published online, in social media, and in written letters, disparaging and
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defamatory statements about the Plaintiff.” Produce the specific evidence of statements
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about you from the Defendant that were published in social media.

4. In Plaintiff’s Original Petition filed with the Court on March 8, 2017, you allege that the
Defendant, “published online, in social media, and in written letters, disparaging and
defamatory statements about the Plaintiff.” Produce evidence of the methods and chain

Cause No. 201716162


DEFENDANT’S SECOND REQUEST FOR PRODUCTION TO PLAINTIFF
6
of custody of collecting data from the social media you allege contains “disparaging and
defamatory statements about the Plaintiff.”

5. In Plaintiff’s Original Petition filed with the Court on March 8, 2017, you allege that the
Defendant, “published online, in social media, and in written letters, disparaging and
defamatory statements about the Plaintiff.” Produce the specific evidence of statements

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about you from the Defendant that were in written letters.

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6. In Plaintiff’s Original Petition filed with the Court on March 8, 2017, you allege that, “the

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words published by the Defendant were false.” Produce the specific evidence that the

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“words” you allege were published by the Defendant were false about you, the Plaintiff.

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7. In Plaintiff’s Original Petition filed with the Court on March 8, 2017, you allege that the

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Defendant, “has engaged in a cause of conduct intended to harass and startle the
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Plaintiff through the online publication of libelous and defamatory statements.”
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Produce evidence of the “cause of conduct” that you allege the Defendant engaged in.
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8. Produce any and all written or recorded statements, job evaluations, performance
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evaluations, performance reviews, job performance records, performance improvement


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plans, or any other job status/performance related evidence from your employer Cotton
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Ranch Events, a subsidiary of Cotton Holdings that your job was and/or is in jeopardy as
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a result of actions taken by the Defendant.


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9. Produce any and all written or recorded statements, email communication, transcribed
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voicemails, transcribed voice conversations, or any other form of communication as


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defined in this Request from Absolutely! Katy Magazine evidencing that Absolutely! Katy
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Magazine communicated to you that they received letters from the Defendant about
you, the Plaintiff.

10. Produce any and all written or recorded statements, email communication, transcribed
voicemails, transcribed voice conversations, or any other form of communication as
defined in this Request from Cotton Ranch Events, a subsidiary of Cotton Holdings

Cause No. 201716162


DEFENDANT’S SECOND REQUEST FOR PRODUCTION TO PLAINTIFF
7
evidencing that Cotton Ranch Events, a subsidiary of Cotton Holdings communicated to
you that they received letters from the Defendant about you, the Plaintiff.

11. Produce any and all documented evidence and communication between you and Cris
Dishman regarding the Defendant to include text messages, email communication,
social media communication, recorded statements, transcribed telephone voicemails

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transcribed phone conversations and any other form of communication defined in the

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Definitions section of this Request.

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12. Produce any and all documented evidence and communication between you and

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Caroline Dazzio Brown, also known as Caroline Dazzio, regarding the Defendant to

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include text messages, email communication, social media communication, recorded

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statements, transcribed telephone voicemails transcribed phone conversations and any
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other form of communication defined in the Definitions section of this Request.
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13. Produce any and all documented evidence and communication between you and Bubba
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McDowell regarding the Defendant to include text messages, email communication,


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social media communication, recorded statements, transcribed telephone voicemails


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transcribed phone conversations and any other form of communication defined in the
Definitions section of this Request.
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14. Produce any and all documented evidence and communication between you and Floy
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Johnson regarding the Defendant to include text messages, email communication, social
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media communication, recorded statements, transcribed telephone voicemails


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transcribed phone conversations and any other form of communication defined in the
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Definitions section of this Request.


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15. Produce any and all Cease and Desist letters sent to you; or to an agent acting on your
behalf; or to an attorney representing you from the Defendant.

16. Produce any and all Cease and Desist letters sent to you; or to an agent acting on your
behalf; or to an attorney representing you from Cris Dishman.

Cause No. 201716162


DEFENDANT’S SECOND REQUEST FOR PRODUCTION TO PLAINTIFF
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17. Produce any and all police reports you have filed or that you have been recorded in, in
the past five years.

Respectfully submitted,

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Defendant’s Signature

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PO BOX 352

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WACO, TX 76703
832-510-7714

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Cause No. 201716162


DEFENDANT’S SECOND REQUEST FOR PRODUCTION TO PLAINTIFF
9
CERTIFICATE OF SERVICE

I do hereby certify that I have eFiled with the Harris County Courts and mailed a true and
correct copy of DEFENDANT’S SECOND REQUEST FOR PRODUCTION TO PLAINTIFF to the
plaintiff on the 29TH day of March, 2018 at the following address

SEAN A. ROBERTS
2555 NORTH MACGREGOR, SUITE 200 Defendant’s Signature

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HOUSTON, TEXAS 77004

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Cause No. 201716162


DEFENDANT’S SECOND REQUEST FOR PRODUCTION TO PLAINTIFF
10
EXHIBIT L
5/15/2018 4:12 PM
Chris Daniel - District Clerk Harris County
Envelope No. 24617176
By: SASHA PRINCE
Filed: 5/15/2018 4:12 PM

CAUSE NO. 201716162

Julissa Duran § IN THE DISTRICT COURT OF


§
Plaintiff, §
§
§

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HARRIS COUNTY, TEXAS

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VS. §
§

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§

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Jennifer Thibeaux §
§

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Defendant. §
270TH JUDICIAL DISTRICT

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DEFENDANT’S MOTION TO COMPEL DISCOVERY FOR PLAINTIFF TO RESPOND TO
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DEFENDANT’S DISCOVERY REQUESTS AND FOR COSTS AND FEES
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TO THE HONORABLE JUDGE OF SAID COURT:


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NOW COMES Defendant, JENNIFER THIBEAUX, Movant herein, and brings this Motion to
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Compel JULISSA DURAN, Plaintiff, to answer DEFENDANT’S REQUEST FOR DISCLOSURE (EXHIBIT
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A) served on Plaintiff February 26, 2018 pursuant to Rule 194 of the Texas Rules of Civil
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Procedure; DEFENDANT’S REQUEST FOR INERROGATORIES (EXHIBIT B) served on Plaintiff March


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23, 2018 pursuant to Rule 197 of the Texas Rules of Civil Procedure; Movant’s REQUEST TO
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INSPECT PLAINTIFF’S ORIGINAL DOCUMENTS (EXHIBIT C) produced from Movant’s First Request
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for Production pursuant to Rule 196.3 of the Texas Rules of Civil Procedure; and DEFENDANT’S

2ND REQUEST FOR PRODUCTION (EXHIBIT D) served on Plaintiff March 29, 2018 pursuant to

Rule 193 and 196 of the Texas Rules of Civil Procedure; and. In support thereof, Movant would

respectfully show the Court the following:

Cause No. 201716162


DEFENDANT’S MOTION TO COMPEL FURTHER DISCOVERY FOR PLAINTIFF TO RESPOND TO DEFENDANT’S DISCOVERY REQUESTS
AND FOR COSTS AND FEES 1
I. INTRODUCTION

Movant served written request for disclosure on Plaintiff on or about February 26, 2018

[EXHIBIT A]. Thirty (30) days elapsed and the Plaintiff not only failed to serve responses,

through her attorney of record, Sean Alan Roberts, the Plaintiff failed to confer with Movant

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regarding an extension or description of extenuating circumstances.

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Movant served written request for interrogatories on Plaintiff on or about March 23,

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2018 [EXHIBIT B]. Thirty (30) days elapsed and the Plaintiff not only failed to serve responses,

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through her attorney of record, Sean Alan Roberts, the Plaintiff failed to confer with Movant

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regarding an extension or description of extenuating circumstances.

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Due to a lack of Plaintiff cooperation, Movant formally filed a Notice of Intention to
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Inspect Plaintiff’s Production Document Originals (EXHIBIT C). This notice clearly stated the
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request to inspect Plaintiff’s originals including related Rules. The Notice formally summarized
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all seven (7) attempts to request inspection of Plaintiff’s document originals.


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Movant served a second written request for production on Plaintiff on or about March
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29, 2018 [EXHIBIT D]. Thirty (30) days elapsed and the Plaintiff not only failed to serve
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responses, through her attorney of record, Sean Alan Roberts, the Plaintiff failed to confer with
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Movant regarding an extension or description of extenuating circumstances.


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On Thursday, May 1, 2018, Movant attempted conference with the Plaintiff on all four
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discovery request matters (EXHIBIT E) – Movant’s Request for Disclosure, Movant’s Request for

Interrogatories, Movant’s Request to Inspect Plaintiff’s Originals; and Movant’s 2nd Request for

Production through Plaintiff’s attorney of record Sean Alan Roberts and received no response.

Cause No. 201716162


DEFENDANT’S MOTION TO COMPEL FURTHER DISCOVERY FOR PLAINTIFF TO RESPOND TO DEFENDANT’S DISCOVERY REQUESTS
AND FOR COSTS AND FEES 2
In summary, as of the date of this filing, Plaintiff is significantly overdue in her answers

to Movant’s Discovery Requests – Request for Disclosure is Forty-Eight (48) days overdue;

Request for Interrogatories is Twenty-One (21) days overdue; and the 2nd Request for

Production is Fourteen (14) days overdue. Additionally, Plaintiff has failed to allow inspection of

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production originals despite Movant’s numerous requests over a 126-day time period. Finally,

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Plaintiff has failed to communicate with Movant regarding these matter including failing to

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respond to Movant’s request for conference. The Court should determine the Plaintiff has

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failed to cooperate in the Discovery process impacting the process, costing money to the

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Movant, and impacting a fair Trial on Merits.

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II. ARGUMENT & AUTHORITIES
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A. PLAINTIFF SHOULD BE COMPELLED TO PRODUCE DISCOVERY TO MOVANT’S REQUEST
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FOR DISCLOSURE, REQUEST FOR INTERROGATORIES, AND SECOND REQUEST FOR


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PRODUCTION.
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“’[T]he ultimate purpose of discovery is to seek the truth, so that disputes may be
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decided by what the facts reveal, not by what facts are concealed.’” In re Colonial Pipeline Co.,
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968 S.W.2d 938, 941 (Tex. 1998) (quoting Jampole v. Touchy, 673 S.W.2d 569, 573 (Tex. 1984)).
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A party is entitled to obtain discovery about any matter relevant to the subject matter of the
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case. TEX. R. CIV. P. 192.3(a); see Axelson, Inc. v. McIlhany, 798 S.W.2d 550, 553 (Tex. 1990).
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Information is discoverable as long as it appears “reasonably calculated to lead to the discovery


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of admissible evidence.” TEX. R. CIV. P. 192.3(a).

Movant’s requests are reasonably calculated to lead to the discovery of admissible

evidence as required by Rule 192.3. Specifically, Movant seeks answers and documents relating

to (1) Plaintiff’s allegations of defamation made in Plaintiff’s Original Petition (EXHIBIT F) and in

Cause No. 201716162


DEFENDANT’S MOTION TO COMPEL FURTHER DISCOVERY FOR PLAINTIFF TO RESPOND TO DEFENDANT’S DISCOVERY REQUESTS
AND FOR COSTS AND FEES 3
her own Affidavit (EXHIBIT G) filed with the court on September 27, 2017 of which Plaintiff

alleges letters were sent from Movant to two nonparties in this suit, actions and events that

were the subject of the allegedly false statements, and (3) Plaintiff’s asserted damages. Given

that each of these requests is related to the elements of Plaintiff’s asserted claims in her

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original petition, Plaintiff’s own filed Affidavit and Defendant’s defenses, each request is within

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the scope of permissible discovery. As such, Movant respectfully requests that the Court

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compel Plaintiff to respond to Movant’s Request for Disclosure; Movant’s Request for

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Interrogatories, and Movant’s 2nd Request for Production.

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B. PLAINTIFF SHOULD BE COMPELLED TO RESPOND TO MOVANT’S REQUEST FOR
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DISCLOSURE, REQUEST FOR INTERROGATORIES, AND SECOND REQUEST FOR PRODUCTION.
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1. Responding to Written Discovery, Duty to Make Complete Responses


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According to the Texas Rules of Civil Procedure Rule 193.1, “A party must respond to
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written discovery in writing within the time provided by court order or these rules. When
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responding to written discovery, a party must make a complete response, based on all
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information reasonably available to the responding party or its attorney at the time the
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response is made.” Plaintiff failed to serve answers to Movant regarding Movant’s Request for
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Disclosure; Movant’s Request for Interrogatories, and Movant’s 2nd Request for Production.
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Additionally, Plaintiff failed to notify Movant of issues relating to delayed responses. Despite
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Movant’s attempt for conference regarding the matter, Plaintiff’s counsel failed to respond.

2. Failing to Timely Respond – Exclusion of Evidence

Plaintiff has a duty to timely respond to discovery requests and upon notice to resolve

defects in written discovery responses and production. Plaintiff failed to respond entirely to

Cause No. 201716162


DEFENDANT’S MOTION TO COMPEL FURTHER DISCOVERY FOR PLAINTIFF TO RESPOND TO DEFENDANT’S DISCOVERY REQUESTS
AND FOR COSTS AND FEES 4
Movant’s Request for Disclosure, Movant’s Request for Interrogatories, and Movant’s 2nd

Request for Production therefore evidence related to those requests should be excluded from

use in trial. According to the Texas Rules of Civil Procedure, Rule 193.6(a), “A party who fails to

make, amend, or supplement a discovery response in a timely manner may not introduce in

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evidence the material or information that was not timely disclosed, or offer the testimony of a

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witness (other than a named party) who was not timely identified, unless the court finds that:

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(1) there was good cause for the failure to timely make, amend, or supplement the discovery

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response; or (2) the failure to timely make, amend, or supplement the discovery response will

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not unfairly surprise or unfairly prejudice the other parties.” Movant has notified the Plaintiff of

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the missed deadline and need for the answers to be served and received no response regarding
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a status update, extension request, or the actual supplementation of the production requested.
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The Court should find the Plaintiff grossly abused the Discovery Process and exclude discovery
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related to that abuse in accordance with the Rules.


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C. PLAINTIFF SHOULD BE COMPELLED TO ALLOW INSPECTION AND MAKE PRODUCTION


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ORIGINALS AVAILABLE TO MOVANT.


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Pursuant to the Texas Rules of Civil Procedure, Rule 196.3(a), 196.3(b), and 196.3(c):
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196.3 Production (a) Time and place of production. Subject to any objections
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stated in the response, the responding party must produce the requested
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documents or tangible things within the person's possession, custody or control


at either the time and place requested or the time and place stated in the
response, unless otherwise agreed by the parties or ordered by the court, and
must provide the requesting party a reasonable opportunity to inspect them. (b)
Copies. The responding party may produce copies in lieu of originals unless a
question is raised as to the authenticity of the original or in the circumstances it
would be unfair to produce copies in lieu of originals. If originals are produced,
the responding party is entitled to retain the originals while the requesting party
inspects and copies them. (c) Organization. The responding party must either

Cause No. 201716162


DEFENDANT’S MOTION TO COMPEL FURTHER DISCOVERY FOR PLAINTIFF TO RESPOND TO DEFENDANT’S DISCOVERY REQUESTS
AND FOR COSTS AND FEES 5
produce documents and tangible things as they are kept in the usual course of
business or organize and label them to correspond with the categories in the
request.

Defendant has made numerous requests to inspect the originals of production evidence

produced by Plaintiff since January 10, 2018 (EXHIBIT C). On March 29, 2018, Plaintiff’s attorney

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stated the originals were in the possession of the Plaintiff but simply needed to be couriered to

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counsel’s office. Plaintiff’s last communication to Movant regarding this matter was March 29,

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2018. Despite Movant’s numerous requests, Plaintiff has not followed allowed inspection.

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Today marks the 126th day since Movant has requested inspection of Plaintiff’s originals. In

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Movant’s May 1, 2018 communication to Plaintiff regarding outstanding discovery requests,

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Movant included an inquiry about inspection of originals with no response from Plaintiff
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(EXHIBIT E).
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D. MOVANT IS ENTITLED TO COSTS AND FEES.


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Because Plaintiff has failed to comply with the Texas Rules of Civil Procedure, failed to
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timely respond to Movant’s Discovery requests, has improperly withheld relevant discovery,
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and has failed to respond to Movant’s numerous requests for conference, Plaintiff should be
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required to pay Movant’s costs and fees incurred in preparing, filing, and presenting this
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Motion. In granting a motion to compel, a court “shall, after opportunity for hearing, require a
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party whose conduct necessitated the motion or attorney advising such conduct or both of
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them to pay . . . the reasonable expenses incurred in obtaining the order, including attorney

fees,” unless such an award would be unjust. TEX R. CIV. P. 215.1(d) (emphasis added). Because

there are no exigent circumstances to justify Plaintiff’s conduct here, an award of costs and fees

is appropriate.

Cause No. 201716162


DEFENDANT’S MOTION TO COMPEL FURTHER DISCOVERY FOR PLAINTIFF TO RESPOND TO DEFENDANT’S DISCOVERY REQUESTS
AND FOR COSTS AND FEES 6
III. CERTIFICATE OF CONFERENCE

Efforts to resolve these matters without court intervention were attempted as

evidenced by the Certificate of Conference included herein [EXHIBIT E].

IV. CONCLUSION AND PRAYER

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Based on the foregoing, Movant respectfully prays:

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1. That the Court compel Plaintiff to fully respond to Movant’s Request for Disclosure,

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Movant’s Request for Interrogatories, and Movant’s 2nd Request for Production within ten

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(5) days of the date of its order, or by Court order exclude the Discovery;

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2. That the Court compel Plaintiff to fully produce answers and production related to Movant’s

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Request for Disclosure, Movant’s Request or Interrogatories, and Movant’s 2nd Request for
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Production within ten (5) days of the date of its order, or by Court order exclude the
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Discovery;
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3. For an award of reasonable fees and costs for preparation, filing, and presenting of this
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Motion; and
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4. For all other relief to which Movant is entitled.


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5. A Proposed Order granting the motion is attached for the Court’s consideration (EXHIBIT H).
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Respectfully submitted,
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Movant’s Signature

JENNIFER THIBEAUX
PO BOX 352
WACO, TX 76703
713-510-7714
PRO SE

Cause No. 201716162


DEFENDANT’S MOTION TO COMPEL FURTHER DISCOVERY FOR PLAINTIFF TO RESPOND TO DEFENDANT’S DISCOVERY REQUESTS
AND FOR COSTS AND FEES 7
CERTIFICATE OF SERVICE
I do hereby certify that I have eFiled with the Harris County Courts and served a true and
correct copy of the instrument on Plaintiff’s counsel of record in accordance with Tex. R. Civ. P.
21a on the 16th day of March, 2018.

Movant’s Signature

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Cause No. 201716162


DEFENDANT’S MOTION TO COMPEL FURTHER DISCOVERY FOR PLAINTIFF TO RESPOND TO DEFENDANT’S DISCOVERY REQUESTS
AND FOR COSTS AND FEES 8
EXHIBIT M
5/31/2018 Gmail - Cause No. 20171612; Julissa Duran v. Jennifer Thibeaux

Jennifer Thibeaux <jennthibeaux@gmail.com>

Cause No. 20171612; Julissa Duran v. Jennifer Thibeaux


2 messages

Anjali Sharma <as@robertsmarkland.com> Wed, May 16, 2018 at 2:26 PM


To: Jennifer Thibeaux <jennthibeaux@gmail.com>

Ms. Thibeaux,

I hope all is well. I am aware that our discovery responses are late. Ms. Duran recently had intensive surgery and is currently in recovery, however, I plan to have
these responses to you in the very near future. As soon as they are mailed out, I will let you know. Thank you & sincerest apologies for the delay.

Anjali Sharma
Roberts Markland, LLP |2555 N MacGregor Way | Houston, Texas 77004 
( 713 630 0900 | 7 713 630 0991 | * as@robertsmarkland.com
This e-mail is covered by the Electronic Communications Privacy Act, 18 U.S.C. Sections 2510-2521, and is legally privileged. This e-mail and any documents
attached may contain confidential information belonging to the sender that is protected by the attorney-client, work product and/or other privileges. The
information is intended only for the use of the individuals or entities named above. If you have received this e-mail in error, we would appreciate your immediate
notification to us by collect telephone call to arrange for the return of all copies of the e-mail. You should also delete this transmission from your computer and/or
server. The recipient should check any attachments for the presence of viruses. The company and sender accept no liability for any damage caused by any virus transmitted by this email.

Jennifer Thibeaux <jennthibeaux@gmail.com> Wed, May 16, 2018 at 3:09 PM


To: Anjali Sharma <as@robertsmarkland.com>

Ms. Sharma,

I have not heard from your office in 7 weeks. During that time Discovery responses were due and requests/demands for inspection were made. Please be aware
that your office also failed to respond to my outreach. It is my assumption that Duran's counsel did not also undergo "intensive surgery" in the past 7 weeks. I'm
assuming Duran hired an attorney to actually handle this case.

Somehow I consistently get a slew of excuses - all words, absent evidence, or legal authority. I'm going to ask you what I hope The Honorable Judge Gamble will
ask - what's your excuse?

This is clearly a charade to you. I have asked Judge Gamble to intervene in the most recent Motion to Compel. I would encourage you to drum up admissible
evidence to explain the discovery abuse and wish you the best of luck. I'll be ready to respond to your opposition filing if you so choose to do so.

If your client no longer wishes to pursue this case, I would highly recommend you take action quickly.

Regards,
https://mail.google.com/mail/u/1/?ui=2&ik=7445d7d60e&jsver=-dxVNc9Y02g.en.&cbl=gmail_fe_180516.06_p8&view=pt&search=inbox&th=1636a5b93dcf5baf&siml=1636a347321f44b0&siml=1636a5b93dcf5baf
5/31/2018 Gmail - Cause No. 20171612; Julissa Duran v. Jennifer Thibeaux

Jennifer Thibeaux
713-510-7714
[Quoted text hidden]

https://mail.google.com/mail/u/1/?ui=2&ik=7445d7d60e&jsver=-dxVNc9Y02g.en.&cbl=gmail_fe_180516.06_p8&view=pt&search=inbox&th=1636a5b93dcf5baf&siml=1636a347321f44b0&siml=1636a5b93dcf5baf
EXHIBIT N
5/17/2018 Julissa Duran on Instagram: “Happy New Year! #Hello2018”

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Royal Oaks Country Club

justjules2000 Happy New Year! #Hello2018


shawntell.mcwilliams ❤❤
jaybrad 📈

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5/17/2018 Julissa Duran on Instagram: “Back to the grind...#WayTooCold #MakingMoves #Gucci #Sunglasses #EventPlanner”

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justjules2000 Back to the


grind...#WayTooCold #MakingMoves #Gucci
#Sunglasses #EventPlanner
j0rsak 💘💘💘

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5/17/2018 Julissa Duran on Instagram: “Loved me some Pearl time. 💕#Austin #Shopping #SpontaneousDayTrip #KarlLagerfeld”

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justjules2000 Loved me some Pearl time. 💕


#Austin #Shopping #SpontaneousDayTrip
#KarlLagerfeld
dollyssweetsensations You always look so
cool girlie!
justjules2000 @dollyssweetsensations Thank
you Dolly!💋

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5/17/2018 Julissa Duran on Instagram: “❤”

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justjules2000 ❤
dollyssweetsensations Hahahah! Love it!

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5/17/2018 Julissa Duran on Instagram: “Skeet shooting with my new girl! #Beretta #Shotgun #Huntress #GirlsandGuns #SkeetShooting #SundayVi…

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justjules2000 Skeet shooting with my new


girl! #Beretta #Shotgun #Huntress
#GirlsandGuns #SkeetShooting #SundayVibes
darhondaw Next time.... take me! I wanna go
and be a Huntress just like the fabulous Jules!!
-#socool
j0rsak 💘
justjules2000 @darhondaw Definitely! Let’s
go!😀

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5/17/2018 Julissa Duran on Instagram: “#HappySunday ❤”

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justjules2000 #HappySunday ❤
j0rsak ❤
nita.bak 😍
vladan_kn 🙌🙌🙌🙌

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5/17/2018 Julissa Duran on Instagram: “Great evening supporting this AMAZING woman Shawntell McWilliams and the kick-off wine tasting for the …

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AMAZING woman Shawntell McWilliams and
the kick-off wine tasting for the National
Sclerosis Society On The Move Luncheon.
#NationalSclerosis #FriendsSupportFriends
#Luncheon #KickOff
j0rsak 💘
justjules2000 @fitfierce40 Thank you doll!💋

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5/17/2018 Julissa Duran on Instagram: “2018 Houston Chronicle Best Dressed Announcement at #NeimanMarcus. #BestDressed #VelvetNight #Tu…

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justjules2000 2018 Houston Chronicle Best


Dressed Announcement at #NeimanMarcus.
#BestDressed #VelvetNight #TuesdayVibes
j0rsak #alwaysstunning✨ 💕

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5/17/2018 Julissa Duran on Instagram: “And there she goes...#Cruise #CruiseLife #Carnival #Valor #Cozumel”

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Galveston South Jettie

justjules2000 And there she goes...#Cruise


#CruiseLife #Carnival #Valor #Cozumel
tomochoa Nice purse! Have fun.
j0rsak Cruising again?
jpmorganimages Gucci cruise
kngmarketing This is awesome :)
justjules2000 @j0rsak I am...On my way to
Cozumel.

66 likes
FEBRUARY 1

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5/17/2018 Julissa Duran on Instagram: “Sailing away....Totally recommend #Carnival #Valor #CruiseLife”

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Carnival Valor Cruise

justjules2000 Sailing away....Totally


recommend #Carnival #Valor #CruiseLife
j0rsak 💘
jfizzle1970 Looking good Billy Ray!!!
justjules2000 @jfizzle1970 Excuse me! Who’s
Billy Ray! 😂
jfizzle1970 @justjules2000 Trading Places..
You’re supposed to respond “Feeling good
Louis!@

31 likes
FEBRUARY 2

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5/17/2018 Julissa Duran on Instagram: “Fed the fish today...Island Fish Spa. #FishFeetOnFleek #Tickles #CheckedOffBucketList #FishSpa”

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Mr Sancho's Cozumel Beach Club

justjules2000 Fed the fish today...Island Fish


Spa. #FishFeetOnFleek #Tickles
#CheckedOffBucketList #FishSpa
j0rsak Watch your tors😂😂

42 likes
FEBRUARY 3

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5/17/2018 Julissa Duran on Instagram: “We have arrived...#Cozumel #SaturdayVibes #FinallySomeSun”

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Cozumel, Mexico

justjules2000 We have arrived...#Cozumel


#SaturdayVibes #FinallySomeSun
mctmau #Goals
j0rsak #enjoythemoment 💕
inerjon 😍
luxelineorg Hey beautiful! MISS you!
justjules2000 @luxelineorg Miss you too! 💋

41 likes
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5/17/2018 Julissa Duran on Instagram: “Sunset Vibes...#CurrentSituation #CruiseLife #LivingLifeToTheFullest #Sunset #SomewhereOnTheOcean”

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Carnival Valor Cruise

justjules2000 Sunset Vibes...#CurrentSituation


#CruiseLife #LivingLifeToTheFullest #Sunset
#SomewhereOnTheOcean
j0rsak 💕🌹💕🌹
cjt500 Love Entrepreneurs mindsets!

32 likes
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5/17/2018 Julissa Duran on Instagram: “#LaVirgendeGuadalupe #VirgenMary #Cozumel #MrSanchos”

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Cozumel, Mexico

justjules2000 #LaVirgendeGuadalupe
#VirgenMary #Cozumel #MrSanchos
j0rsak 🌈🌹🌈🌹
jerald_jason You are EVERYTHING that is
fabulous!!!!
justjules2000 @jerald_jason Thank you Hun!
💋

38 likes
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5/17/2018 Julissa Duran on Instagram: “Hanging with the birds! #Cozumel #Macaws #BeachesInBlack”

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Mr Sancho's Cozumel Beach Club

justjules2000 Hanging with the birds!


#Cozumel #Macaws #BeachesInBlack
j0rsak 🌈💘🌈💘

30 likes
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5/17/2018 Julissa Duran on Instagram: “Gone With The Wind...Cozumel Style. #Beach #Stroll #Relaxation #Paradise #Cozumel #MrSanchos #Wor…

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Mr Sancho's Cozumel Beach Club

justjules2000 Gone With The Wind...Cozumel


Style. #Beach #Stroll #Relaxation #Paradise
#Cozumel #MrSanchos #WorkHardPlayHard
#Blessed
j0rsak 🌈💘🌈💘
alatostada Beautiful !
justjules2000 @alatostada Thank you doll! 💋
arm2law How's the weather out there?

30 likes
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5/17/2018 Julissa Duran on Instagram: “The strength of a woman is not measured by the impact that all her hardships in life have had on her; but th…

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Cozumel, Quintana Roo, Mexico

justjules2000 The strength of a woman is


not measured by the impact that all her
hardships in life have had on her; but the
strength of a woman is measured by the
extent of her refusal to allow those
hardships to dictate her and who she
becomes. ~ C. JoyBell C. #Quotes
#StrongWomen #Survivor
j0rsak You are like a rock!❤
clevetta Beautiful,Don't look anywhere else
once you see our work, info on my bio for

59 likes
FEBRUARY 5

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5/17/2018 Julissa Duran on Instagram: “Happy Valentine’s Day! ❤ #valentinesday #xoxo #love #everydayisvalentinesday”

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Katy, Texas

justjules2000 Happy Valentine’s Day! ❤


#valentinesday #xoxo #love
#everydayisvalentinesday
darkersidedjs Happy Valentine's Day
amberdavisthrives Have you considered a
side income helping others benefit from your
focus on nutrition and wellness?

66 likes
FEBRUARY 14

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5/17/2018 Julissa Duran on Instagram: “Fabulous luncheon for the Greater Houston Women’s Chamber of Commerce. #ghwcc #luncheon”

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justjules2000 Fabulous luncheon for the


Greater Houston Women’s Chamber of
Commerce. #ghwcc #luncheon
topsy4gold Very nice page 💗
justjules2000 @topsy4gold Thank you! 💋
dizzythecoachh Cool If you ever thought to
be popular, look up the info on my bio 💗

50 likes
FEBRUARY 15

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5/17/2018 Julissa Duran on Instagram: “Honored to be with these amazing women today at the National Multiple Sclerosis Society “On the Move Lu…

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River Oaks Country Club

justjules2000 Honored to be with these


amazing women today at the National
Multiple Sclerosis Society “On the Move
Luncheon.” Fabulous Event
@shawntell.mcwilliams #MS
#MultipleSclerosis #Charity #Luncheon
j0rsak 🌈💘🌈💘
rockwell0618 Pretty...
rockwell0618 Hope it raised a lot of money
for MS! Sure would love a cure! 😊
j0rsak 💘

48 likes
FEBRUARY 28

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5/17/2018 Julissa Duran on Instagram: “Cheers! #HoustonRodeo #Champs #WineGarden”

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RODEOHOUSTON

justjules2000 Cheers! #HoustonRodeo


#Champs #WineGarden
j0rsak 😎💘

63 likes
MARCH 1

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5/17/2018 Julissa Duran on Instagram: “About Last Night: Attended the Mother’s Day Soirée by LCA Houston International Magazine Announceme…

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The Webster

justjules2000 About Last Night: Attended the


Mother’s Day Soirée by LCA Houston
International Magazine Announcement. Loved
running into a friend from junior high. Great
seeing @laurettebveres! #ValleyGirls
#MothersDaySoiree #LCAHouston
j0rsak Another style show I see!❤

39 likes
MARCH 10

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5/17/2018 Julissa Duran on Instagram: “💋#Love #SnapChatFilters”

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justjules2000 💋#Love #SnapChatFilters


darkersidedjs Cute little bunny rabbit
inerjon 😍
brittanyk1611 The Diva is working it!
aguynamedami Damn, Gorgeous is an
understatement 🔥. Your beyond fine 😉
#whosyourdaddy #me loll. How you doin?

39 likes
MARCH 11

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5/17/2018 Julissa Duran on Instagram: “I’ll be having some #StoneCrab claws with my flounders. I have the best guides. #POC #Crabbing #LateNig…

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Port O'Connor, Texas

justjules2000 I’ll be having some #StoneCrab


claws with my flounders. I have the best
guides. #POC #Crabbing #LateNight
#OnTheWater #SaltLife #SpringBreak
handysouthfl Excellent

37 likes
MARCH 14

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5/17/2018 Julissa Duran on Instagram: “I know what my chef will be cooking me this week. Great night of #FlounderGigging! #POC #SpringBreak #…

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Port O'Connor, Texas

justjules2000 I know what my chef will be


cooking me this week. Great night of
#FlounderGigging! #POC #SpringBreak
#Fishing #GirlsThatFish
yolanda.celestine Wow!! Went on my 1st
fishing trip in Corpus a couple of days ago &
loved it!
justjules2000 @yolanda.celestine That’s
awesome!

55 likes
MARCH 14

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5/17/2018 Julissa Duran on Instagram: “Great day at the Houston Chronicle Best Dressed Luncheon. #MarchOfDimes #Charity #Fashion #Show #…

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justjules2000 Great day at the Houston


Chronicle Best Dressed Luncheon.
#MarchOfDimes #Charity #Fashion #Show
#NeimanMarcus
marib311 Gorgeous!
nattyyosiah 😍
thehometownchefcateringco I bet you won
best dressed!!!
j0rsak Hands down #1!❤
forever_cs777 💛💛
your_valentine89 Nice one, look up the link in
my bio ❤

116 likes
MARCH 20

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5/17/2018 Julissa Duran on Instagram: “Gala for the 10 Year Anniversary Elliott Chandler Foundation. #ECFGala2018 #LadyInRed #Charity #RedC…

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Royal Sonesta Houston

justjules2000 Gala for the 10 Year Anniversary


Elliott Chandler Foundation. #ECFGala2018
#LadyInRed #Charity #RedCarpet #Fashion
#EveningDress
pearl_snap Love love dress 💕 ❤
mtduran Stunning! What a dress 👗!
officialtlyons fire 🔥🔥🔥🔥
minamusthave 😍😍😍
j0rsak So nice and elegant! Quite the lady!❤
jonathangradnigo Wow!

75 likes
APRIL 7

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5/17/2018 Julissa Duran on Instagram: “Supporting Pumps & Pearls Scholarships & Awards Luncheon. R.A.R.E. Pearls #Radiant #Authentic #Resil…

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Sugar Land Marriott Town Square

justjules2000 Supporting Pumps & Pearls


Scholarships & Awards Luncheon. R.A.R.E.
Pearls #Radiant #Authentic #Resilient
#Equipped
j0rsak Your a jewel!❤❤❤
nita.bak 💕💕💕

30 likes
APRIL 14

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5/17/2018 Julissa Duran on Instagram: “Great event last night Couture for the Cause benefiting American Cancer Society. #ACS #FashionShow #E…

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Harvest Green by Johnson Development

justjules2000 Great event last night


Couture for the Cause benefiting American
Cancer Society. #ACS #FashionShow
#EndCancer #Mommyanddaughter
#MyRock
j0rsak ❤
sparkle_star_shine ❤❤❤
luxelineorg Looking fab as always! Miss
you. Plan a visit.. 💕👌
justjules2000 @luxelineorg Miss you too!
You know I will Just let me know when it

67 likes
APRIL 15

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5/17/2018 Julissa Duran on Instagram: “Great night supporting one of my favorite charities Couture for the Cause benefiting American Cancer Soci…

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Harvest Green by Johnson Development

justjules2000 Great night supporting one of


my favorite charities Couture for the Cause
benefiting American Cancer Society.
#EndCancer #CancerFree
minamusthave Beautiful!
j0rsak Always the best looking!❤
terri_h85 Hawt !! Love ya girl 😘
darkersidedjs Beautiful!
luxelineorg Hey Gorgeous! Miss you.
justjules2000 @terri_h85 Love you too!💋

55 likes
APRIL 15

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5/17/2018 Julissa Duran on Instagram: “Three years ago this April, I fought the biggest battle of my life and won. I want to give @coutureforthecaus…

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Harvest Green by Johnson Development

justjules2000 Three years ago this April, I


fought the biggest battle of my life and
won. I want to give @coutureforthecause,
@americancancersociety, family and friends
a huge thank you for giving me the
strength and support I needed to fight
breast cancer. 💋 #EndCancer
#CancerSucks #CancerFree
#LiveLifeToTheFullest #NeverGiveUp #Faith
#Survivor #Halston
mtduran Go Juli! Warriors don’t let you
down!!!
j0rsak The one and only elegant you!❤
pelonesmagazine Love from

77 likes
APRIL 17

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5/17/2018 Julissa Duran on Instagram: “Love these two! ❤ Junior Prom! #Prom2018”

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LaCenterra at Cinco Ranch

justjules2000 Love these two! ❤ Junior


Prom! #Prom2018
lunaluver1 Wooooooow!!!
j0rsak 🌹🌹🌹

44 likes
APRIL 20

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5/17/2018 Julissa Duran on Instagram: “Soleil and Austin. Junior Prom #Prom2018 #CuteCouple”

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LaCenterra at Cinco Ranch

justjules2000 Soleil and Austin. Junior Prom


#Prom2018 #CuteCouple
j0rsak 👌💘

41 likes
APRIL 20

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5/17/2018 Julissa Duran on Instagram: “#Selfie at the #PerfectConnection #AustimGalaofLights #AutismAwareness”

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The Health Museum

justjules2000 #Selfie at the


#PerfectConnection #AustimGalaofLights
#AutismAwareness
sol_s_14 My beautiful Jules... I love you

61 likes
APRIL 21

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5/17/2018 Julissa Duran on Instagram: “Give from the heart! Phenomenal event last night #PerfectConnection Inaugural #AutismGalaofLights #Blue…

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The Health Museum

justjules2000 Give from the heart!


Phenomenal event last night
#PerfectConnection Inaugural
#AutismGalaofLights #Blue #Heart
#AutismAwareness #Gala #Charity
#EveningDress
j0rsak ❤
yourfirstblackgirlfriend 😍😍
whosfarai Nice pic, Help Jay by leaving your
thoughts on his last posts, check out the page
on my bio 🙏

45 likes
APRIL 22

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5/17/2018 Julissa Duran on Instagram: “So blessed to be her mommy! I love you Soleil! 💋#HappyMothersDay #MyLove”

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Katy, Texas

justjules2000 So blessed to be her


mommy! I love you Soleil! 💋
#HappyMothersDay #MyLove
dreamphotovideo Happy Mother's day
gorgeous lady
j0rsak 💕💕💕
nita.bak Happy Mother’s Day 🌺
chaz_taylor_713 A lot of beauty in this pic.
🤓
justjules2000 @dreamphotovideo Thank
! 💋H h d f b l M th ’

56 likes
3 DAYS AGO

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5/31/2018 Julissa Duran on Instagram: “Beautiful evening with lovely friends at The Mad Hatters Par-Tea event supporting a Hurricane Harvey Relie…

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Wharton, Texas

justjules2000 Beautiful evening with lovely


friends at The Mad Hatters Par-Tea event
supporting a Hurricane Harvey Relief effort for
Wharton SHARE with a Fabulous Fashion show
by Designer Carter Smith. #Charity #Fashion
#MadHatters #Hats #Sunday
sol_s_14 Classy & beautiful 💋
j0rsak Just stunning!💘
inerjon Love it!😍

49 likes
MAY 20

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5/31/2018 Julissa Duran on Instagram: “Love supporting this amazing woman @shawntell.mcwilliams. The event was Fabulous Darling! #MadHatte…

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Wharton, Texas

justjules2000 Love supporting this amazing


woman @shawntell.mcwilliams. The event was
Fabulous Darling! #MadHatters #Share
#Charity #FashionShow #TeaParty
j0rsak ❤❤❤
inerjon Ohhhhhh!😋

45 likes
MAY 21

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5/31/2018 Julissa Duran on Instagram: “Soleil had her first professional photo shoot today with @jackopatrny and I’m just speechless. #Photo #Pho…

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Bellaire, Texas

justjules2000 Soleil had her first professional


photo shoot today with @jackopatrny and I’m
just speechless. #Photo #Photography
#PhotoShoot #Model #Modeling #Latina
#Studio 💕
jonathangradnigo Omg damn the grow up so
fast!
nataliacastillohouston Gorgeous 😍
sol_s_14 Beautiful, sweet girl 💋👑
etiquetteandstyle Beautiful!

56 likes
6 DAYS AGO

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6/1/2018 Julissa Duran on Instagram: “Enjoyed The Second Annual St. Jude Gold Luncheon. ❤#StJudeChildrensReseachHospital #Charity #Lunc…

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Royal Sonesta Houston

justjules2000 Enjoyed The Second Annual St.


Jude Gold Luncheon. ❤
#StJudeChildrensReseachHospital #Charity
#Luncheon #ThursdayVibes #Fashion #Show
llbailey00 Yessssss

29 likes
1 HOUR AGO

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https://www.instagram.com/p/Bjd1lsbHZQy/?taken-by=justjules2000 1/1
6/1/2018 JustJ💋 (@julissa_duran) | Twitter

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JustJ 
@julissa_duran JustJ   @julissa_duran · 60m
Be A Woman That Other Woman Can Trust #ThereIsACode #TheWomanCode

Behind every successful woman is herself.
 
 Houston, TX JustJ   @julissa_duran · 2h 
 Joined February 2012 Enjoyed The Second Annual St. Jude Gold Luncheon.
#StJudeChildrensResearchHospital #Charity – at Royal Sonesta Hotel
 271 Photos and videos

  2

JustJ   @julissa_duran · May 29


Thank you @ABCNetwork for canceling Roseanne.

  3
https://twitter.com/julissa_duran 1/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter

 JustJ  Retweeted
818 @818Newbie · May 15
People’s trust in you is the best compliment you can get.

 11  367 625

JustJ   @julissa_duran · May 21


You got this Logan! #MissTexas #MissUSA

  2 6

JustJ   @julissa_duran · May 20 


Beautiful evening with lovely friends at The Mad Hatters Par-Tea event supporting
a Hurricane Harvey Relief effort for Wharton SHARE with a Fabulous Fashion show
by Designer Carter Smith. #Charity #Fashion #MadHatters #Hats #Sunday

https://twitter.com/julissa_duran 2/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter

  3

JustJ   @julissa_duran · May 19


There is Power in Love. #RoyalWedding

  1

JustJ   @julissa_duran · May 18


#SantaFeStrong

  3

JustJ   @julissa_duran · May 18


So heartbroken... Praying for #SantaFeHighSchool

  4

JustJ   @julissa_duran · May 15


Thank you so much @journeytohealin! It’s truly an honor. #FaithAward

https://twitter.com/julissa_duran 3/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter

  2

 JustJ  Retweeted
40 
  @40oz_VAN · May 15 
Never let someone with no hustle knock your hustle.

 15  5.5K 7.2K

JustJ   @julissa_duran · May 14


A Strong Woman looks a challenge dead in the eye and gives it a wink. ~ Gina

Carey

  3

JustJ   @julissa_duran · May 13


So blessed to be her mommy! #HappyMothersDay

  3

JustJ   @julissa_duran · May 10


Wishing @CleRendaMcGrady lots of luck on next weeks #WAICV Golf

Tournament. All proceeds will go to Madge Bush Women’s Transitional Center...A
homeless center in Third Ward for women and children. #Charity #Fabregé

https://twitter.com/julissa_duran 4/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter

  4

JustJ   @julissa_duran · May 4


Non stop hustle, even on a Friday. #HappyFriday

 1  6

JustJ   @julissa_duran · May 1


May the month of MAY bring you unlimited blessings in all areas of your life.

  1

JustJ   @julissa_duran · Apr 25


Sometimes you gotta be the beauty and the beast. #BeastMode

https://twitter.com/julissa_duran 5/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter

  3

JustJ   @julissa_duran · Apr 24


Empower the women around you!

  1 2

JustJ   @julissa_duran · Apr 23


Praying for #Toronto!

  1

JustJ   @julissa_duran · Apr 22


Give from the #heart! Phenomenal event last night #PerfectConnection

Inaugural #AutismGalaofLights #Blue #AutismAwareness

  2

JustJ   @julissa_duran · Apr 17 


https://twitter.com/julissa_duran 6/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter
R.I.P. First Lady Barbara Bush. You will truly be missed.

  2

JustJ   @julissa_duran · Apr 14


Great night supporting one of my favorite charities Couture for the Cause

benefiting American Cancer Society. #EndCancer #CancerFree #CancerSucks

  3

JustJ   @julissa_duran · Apr 14 


#Supporting Pumps & Pearls #Scholarships & #Awards #Luncheon. R.A.R.E. Pearls
#Radiant #Authentic #Resilient #Equipped – at The Plaza Suite @ Marriott
Sugarland

https://twitter.com/julissa_duran 7/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter

  2

JustJ   @julissa_duran · Apr 8


Enjoyed the Kick-Off Party for the Perfect Connection Inaugural Autism Gala of

Lights. #Autism #Fabergé #Galleria #Charity #MommyDaughterDuo – at The
Galleria

  2

 JustJ  Retweeted

Diddy   @Diddy · Apr 8 
Your energy introduces you before you even speak.

 979  110K 186K

JustJ   @julissa_duran · Apr 7


Gala for the 10 year Elliott Chandler Foundation. #ECFGala2018 #LadyInRed

#Charity #RedCarpet #Fashion #EveningDress – at Royal Sonesta Hotel Houston

https://twitter.com/julissa_duran 8/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter

  2

 JustJ  Retweeted

Brittney Moses   @Brittney_Moses · Mar 29 
I’m noticing there’s a difference between people who have something to say and
people who have to say something.

 7  80 179

JustJ   @julissa_duran · Mar 20


Great day at the Houston Chronicle Best Dressed Luncheon. #MarchOfDimes

#Charity #Fashion #Show #NeimanMarcus – at The Post Oak Hotel at Uptown
Houston

  4

 JustJ  Retweeted
Billionaire Mindset @IntThings · Mar 8 
I believe in karma, and I believe if you put out positive vibes to everybody, that's
all you're going to get back

 11  819 2.0K

JustJ   @julissa_duran · Mar 14


I know what my chef will be cooking me this week! Great night of

#FlounderGigging #POC #SpringBreak #SaltLife #GirlsThatFish – at Port
O'Connor, TX

https://twitter.com/julissa_duran 9/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter

 1  2

 JustJ  Retweeted

Lecrae   @lecrae · Mar 4 
The difference between a good thing & great thing is the attention to detail.

 25  3.4K 8.7K

JustJ   @julissa_duran · Feb 28


Honored to be with these amazing women today at the National Multiple

Sclerosis Society “On the Move Luncheon.” Fabulous Event @Shawntell_M #MS
#MultipleSclerosis #Charity #Luncheon – at River Oaks Country Club

https://twitter.com/julissa_duran 10/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter

Shawntell McWilliams

  4

JustJ   @julissa_duran · Feb 15


Fabulous luncheon for the Greater Houston Women’s Chamber of Commerce.

Excited to join! – at The Westin Galleria Houston

  1

 JustJ  Retweeted
Cotton Ranch Events @cotton_ranch · Feb 14
Happy Valentine’s Day to all of our lovely clients, followers and vendors.

#Valentines #XOXO #Love

https://twitter.com/julissa_duran 11/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter

Cotton Ranch Events

  1 4

JustJ   @julissa_duran · Feb 14 

  1

JustJ   @julissa_duran · Feb 14 


Heartbroken again...My thoughts and prayers go out to the students and families
that were affected in Florida. #PrayingForParkland

  2

JustJ   @julissa_duran · Feb 13


Congratulations @shaunwhite! You’re AMAZING!!!#GreatestGingerOfAllTime

#Olympics #GoldMedal #USA

 
JustJ   @julissa_duran · Feb 13
Shaun White is insane... #Olympics #PyeongChang2018

  1

JustJ   @julissa_duran · Feb 13 


My tribe of women don’t hate on each other, we salute, we honor, we support, all
that other crap is for the birds.

  1

 JustJ  Retweeted
Boss Chick™ @SexytotheNorth · Feb 11
You can't go up against honesty.

It will win out every single time.

 17  925 1.0K

 JustJ  Retweeted
Michael Chatman @michaelchatman · Feb 10
You know you are winning when people copy you, feel threatened by you, claim

they don't like you but watch your every move.

https://twitter.com/julissa_duran 12/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter

 8  92 205

JustJ   @julissa_duran · Feb 9


Once in awhile blow your own damn mind.

  3

JustJ   @julissa_duran · Feb 3


Sailing away...#CruiseLife #Carnival #Valor #Cozumel

  2

JustJ   @julissa_duran · Jan 30


Congratulations to my beautiful friend Shawntell for making The 2018 Houston

Chronicle Best Dressed. #NeimanMarcus #BestDressed #VelvetNight
#TuesdayVibes

https://twitter.com/julissa_duran 13/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter

  5

JustJ   @julissa_duran · Jan 29


What a beautiful day in H-Town...It’s going to be even more beautiful when I go

on my #cruise Thursday.

  4

JustJ   @julissa_duran · Jan 19


Great evening supporting this AMAZING woman Shawntell McWilliams and the

kick-off wine tasting for the National Sclerosis Society On The Move Luncheon.
#NationalSclerosis #FriendsSupportFriends #Luncheon #KickOff

  1

JustJ   @julissa_duran · Jan 16


It’s an “add to cart” kinda day! #HoustonWeather

 
JustJ   @julissa_duran · Jan 11
It’s only the second week of January and I’m already in need of a full body

massage, 4 days of sleep, and a trip to St. Tropez.

  1

JustJ   @julissa_duran · Jan 9


The best things in life aren’t things.

  1

 JustJ  Retweeted
Cotton Ranch Events @cotton_ranch · Jan 8
J i J 17th f 5 00 P M 7 00 P M f id d t hil i i

https://twitter.com/julissa_duran 14/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter
Join us January 17th from 5:00 P.M. - 7:00 P.M. for a guided tour while sipping on
champagne. Please RSVP to Julissa Duran at julissad@cottonranchevents.com.
#RusticWedding #WeddingPlanning #Katy #WeddingPlanner

  1 2

JustJ   @julissa_duran · Jan 8


Adjusted...Slaying the week! #bossladiesmindset

  2

JustJ 
W i
 @julissa_duran · Jan 7
bl k j hil t hi th #G ld Gl b

https://twitter.com/julissa_duran 15/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter
Wearing black pajamas while watching the #GoldenGlobes.

  2

JustJ   @julissa_duran · Jan 7


#HappySunday

  1

JustJ   @julissa_duran · Jan 6 

  1

https://twitter.com/julissa_duran 16/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter

 JustJ  Retweeted
Cotton Ranch Events @cotton_ranch · Jan 3
To all of the recently engaged couples and brides to be, contact Cotton Ranch

Events TODAY, and book the rustic venue of your dreams!
Contact: julissad@cottonranchevents.com
cottonranchevents.com
#Rustic #WeddingPlanning #Engaged

  1 3

JustJ   @julissa_duran · Jan 1


Happy New Year! No, New Years resolutions here! Just looking forward to another

blessed, fabulous, happy, healthy, peaceful and prosperous year!

#Cheers #2018ImComingToSlay

https://twitter.com/julissa_duran 17/96
6/1/2018 JustJ💋 (@julissa_duran) | Twitter

  2

 JustJ  Retweeted
Michael Chatman @michaelchatman · 30 Dec 2017 
#IPromiseMyself to live each day with joy and enthusiasm, to allow only love and
light to flow through me no matter who or what life sends my way.

  35 55

JustJ   @julissa_duran · Dec 31


Happy New Year! #Hello2018

  3

JustJ   @julissa_duran · 31 Dec 2017


“Alexa, take down the Christmas decorations.”

(It was worth a try)

  1

JustJ   @julissa_duran · 25 Dec 2017 


Wishing everyone a Merry Christmas. May your day be filled with love, peace, joy
and lots of laughter.

https://twitter.com/julissa_duran 18/96
EXHIBIT O
EXHIBIT P
2/20/2018 12:42 PM
Chris Daniel - District Clerk Harris County
Envelope No. 22636772
By: Danielle Gutierrez
Filed: 2/20/2018 12:42 PM

CAUSE NO. 2017-16162

JULISSA DURAN § IN THE DISTRICT COURT OF


§
Plaintiff §
§
v. § HARRIS COUNTY, TEXAS
§
JENNIFER THIBEAUX §

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§
Defendant. § 270TH JUDICIAL DISTRICT

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PLAINTIFF JULISSA DURAN’S RESPONSES TO DEFENDANT’S

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FIRST SET OF REQUESTS FOR PRODUCTION

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To: Defendant, JENNIFER THIBEAUX, P. O. Box 352, Waco, Texas 76703.

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Pursuant to the Texas Rules of Civil Procedure, Plaintiff, Julissa Duran, serves these
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responses to Defendant’s First Set of Request for Production.
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Respectfully submitted,
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ROBERTS MARKLAND LLP


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/s/ Sean A. Roberts


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________________________
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SEAN A. ROBERTS
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State Bar No. 00797328


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ANJALI SHARMA
State Bar No. 24094403
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2555 North MacGregor, Suite 200


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Houston, Texas 77004


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(713) 630-0900 (Telephone)


(713) 630-0991 (Fax)
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Email: sr@robertsmarkland.com
Email: as@robertsmarkland.com

ATTORNEYS FOR PLAINTIFF


CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing instrument has been
forwarded to all known counsel of record on this 20th day of February, 2018.

Via Mail
Jennifer Thibeaux
P.O. Box 352
Waco, Texas 76703

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DEFENDANT

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ist
/s/ Anjali Sharma

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Anjali Sharma

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PLAINTIFF JULISSA DURAN’S RESPONSES TO DEFENDANT’S
FIRST SET OF REQUEST FOR PRODUCTION

REQUEST FOR PRODUCTION NO. 1:

Produce any and all written or recorded statements or reports in the care, custody or control of you
or any of your agents or representatives obtained from any person having knowledge of facts taken
prior to the filing of this lawsuit which will be used as the legal basis for defamation claims under
Texas law to be used in Plaintiff's lawsuit.

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ANSWER:

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Please see Bates Labeled documents DURAN 000001-DURAN 000142.

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REQUEST FOR PRODUCTION NO. 2:

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Produce all writings, drawings, graphs, charts, photographs, or other tangible items of any kind

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intended to be used by you as exhibits at the trial of this case.

ANSWER: Da
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Please see Bates Labeled documents DURAN 000001-DURAN 000142.
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REQUEST FOR PRODUCTION NO. 3:


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Produce all writings, drawings, graphs, charts, photographs, or other tangible items of any kind
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that you intend to admit as evidence at the trial of this case.


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ANSWER:
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Please see Bates Labeled documents DURAN 000001-DURAN 000142.


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REQUEST FOR PRODUCTION NO. 4:


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Produce copies of all letters or correspondence between the Defendant and Plaintiff which will be
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used as the legal basis for defamation claims under Texas law to be used in Plaintiff's lawsuit.
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ANSWER:

None.
REQUEST FOR PRODUCTION NO. 5:

Produce copies of all letters or correspondence from Plaintiff to Defendant prior to filing this
lawsuit which identifies the Plaintiff's complaint of Defendant's defamation.

ANSWER:

None.

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REQUEST FOR PRODUCTION NO. 6:

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Produce a copy of all letters or correspondence between you and any other person or entities
relating to the conduct and incidents which will be used as the legal basis for defamation claims

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under Texas law to be used in Plaintiff's lawsuit.

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ANSWER:

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None at this time. Plaintiff will supplement.

REQUEST FOR PRODUCTION NO. 7: Da


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Produce copies of any and all telephone message slips, notes, or other correspondence reflecting
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oral and/or telephone conversations between you and any other person or entity relating to the
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conduct and incidents which will be used as the legal basis for defamation claims under Texas law
to be used in Plaintiff's lawsuit.
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ANSWER:
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None.
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REQUEST FOR PRODUCTION NO. 8:


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Produce copies of all expert reports which in any way relate to this lawsuit. If such reports are not
in writing, but were given verbally, Defendant requests that the reports be reduced to writing and
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provided to Defendant which will be used as the legal basis for defamation claims under Texas
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law to be used in Plaintiff's lawsuit.


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ANSWER:

None at this time. Plaintiff will supplement.


REQUEST FOR PRODUCTION NO. 9:

Produce copies of all statements and/or admission you contend were made by Defendant or any
past or present employee or agent of Defendant or any other person acting on behalf of Defendant
which will be used as the legal basis for defamation claims under Texas law to be used in Plaintiff's
lawsuit.

ANSWER:

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None.

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REQUEST FOR PRODUCTION NO. 10:

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Produce any and all reports, publications, or other documents evidencing any standards, laws,

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regulations, or industry standards which you contend Defendant violated with respect to the subject

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matter of this lawsuit which will be used as the legal basis for defamation claims under Texas law
to be used in Plaintiff's lawsuit.

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ANSWER:
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Plaintiff will supplement.
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REQUEST FOR PRODUCTION NO. 11:


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Produce all documents which form the basis of your contention that Defendant, or any of her
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representatives, agents, or employees, is/are responsible for the injuries and/or damages allegedly
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sustained by you which will be used as the legal basis for defamation claims under Texas law to
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be used in Plaintiff's lawsuit


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ANSWER:
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Please see Bates Labeled documents DURAN 000001-DURAN 000142.


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REQUEST FOR PRODUCTION NO. 12:


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Produce all documents that reflect, refer or relate to monies received by you from any source which
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relate to the incidents, conduct, injuries or claims involved in this lawsuit.


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ANSWER:

None at this time. Plaintiff will supplement.


REQUEST FOR PRODUCTION NO. 13:

Produce all documents that reflect, refer or relate to monies paid by you to any person or entity
which relates to the incidents, conduct, injuries or claims involved in this lawsuit.

ANSWER:

None at this time. Plaintiff will supplement.

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REQUEST FOR PRODUCTION NO. 14:

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Produce all documents that reflect, refer or relate to your costs associated with your pursuit of this
lawsuit.

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ANSWER:

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Plaintiff will supplement.

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REQUEST FOR PRODUCTION NO. 15:

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Produce all pleadings and other documents reflecting the nature of the claims and defenses, and
the disposition of such claims, at issue any lawsuit or other legal action in which you have been
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involved, either as a plaintiff or as a defendant, other than the above-styled lawsuit.
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ANSWER:
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None.
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REQUEST FOR PRODUCTION NO. 16:


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Produce all correspondence, reports and other records relating to any claim which you have made
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against any person or entity other than Defendant as a result of the incidents and conduct which
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will be used as the legal basis for defamation claims under Texas law to be used in Plaintiff's
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lawsuit.
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ANSWER:
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None.
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REQUEST FOR PRODUCTION NO. 17:

Produce all diaries, calendars or any other lists or notes kept by you which relate to the incidents
or conduct made the basis of this suit or any injuries or damages allegedly sustained by you as a
result of such incidents or conduct which will be used as the legal basis for defamation claims
under Texas law to be used in Plaintiff's lawsuit.
ANSWER:

None.

REQUEST FOR PRODUCTION NO. 18:

Produce any and all records or documents pertaining to any economic losses allegedly sustained
by you as a result, in whole or in part, of the conduct and incident at issue which will be used as
the legal basis for defamation claims under Texas law to be used in Plaintiff's lawsuit.

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ANSWER:

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None.

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REQUEST FOR PRODUCTION NO. 19:

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Produce all documents signed by Defendant or any alleged representative, agent or employee of

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Defendant prior to the institution of this suit which will be used as the legal basis for defamation
claims under Texas law to be used in Plaintiff's lawsuit.
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ANSWER:
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None at this time. Plaintiff will supplement.


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REQUEST FOR PRODUCTION NO. 20:


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Produce copies of any and all documents evidencing any conduct, action, and/or omission
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allegedly committed by Defendant and relevant to your claims which will be used as the legal basis
for defamation claims under Texas law to be used in Plaintiff's lawsuit.
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ANSWER:
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Please see Bates Labeled documents DURAN 000001-DURAN 000142.


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REQUEST FOR PRODUCTION NO. 21:


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Produce all correspondence and unprivileged documents between you and any entity or person
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concerning any of the events, incidents, conduct or alleged damages which form the basis of any
of the claims asserted by you which will be used as the legal basis for defamation claims under
Texas law to be used in Plaintiff's lawsuit.

ANSWER:

Please see Bates Labeled documents DURAN 000001-DURAN 000142.


REQUEST FOR PRODUCTION NO. 22:

Produce all documents you received from or gave to Defendant concerning or relating to any of
the damages, conditions, or events giving rise to or which will be used as the legal basis for
defamation claims under Texas law to be used in Plaintiff's lawsuit.

ANSWER:

Please see Bates Labeled documents DURAN 000001-DURAN 000142.

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REQUEST FOR PRODUCTION NO. 23:

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Produce copies of all documents supporting any claim for damages you contend were caused by

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the actions and/or omission of Defendant which will be used as the legal basis for defamation

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claims under Texas law to be used in Plaintiff's lawsuit.

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ANSWER:

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Please see Bates Labeled documents DURAN 000001-DURAN 000142.
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REQUEST FOR PRODUCTION NO. 24:
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Produce copies of all documents and supporting materials, events, recordings, or any other
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evidence to be used in this lawsuit to support claims made by Plaintiff referenced in paragraph one
(1) in her Affidavit [EXHIBIT A] filed with the 270th Judicial Court on September 27, 2017 in
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which Plaintiff states under oath, "I have been mentality tormented by my ex-boyfriend's
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girlfriend, Jennifer Thibeaux, for the past year." which will be used as the legal basis for
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defamation claims under Texas law to be used in Plaintiff's lawsuit.


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ANSWER:
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Please see Bates Labeled documents DURAN 000001-DURAN 000142.


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REQUEST FOR PRODUCTION NO. 25:


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Produce the identity of Plaintiff's ex-boyfriend Plaintiff references in paragraph one (1) in her
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Affidavit [EXHIBIT A] filed with the 270th Judicial Court on September 27, 2017 in which
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Plaintiff states under oath, "I have been mentality tormented by my ex-boyfriend's girlfriend,
Jennifer Thibeaux, for the past year", including all documents to support the claim of personal
relationships between Plaintiff and Defendant including supporting materials referring to dates
Plaintiff alleges relationships.

ANSWER:

Please see Bates Labeled documents DURAN 000001-DURAN 000142.


REQUEST FOR PRODUCTION NO. 26:

Produce the identity of Plaintiff's employer(s) that are connected to and pertain to the basis of the
claims being made by you in this lawsuit.

ANSWER:

Plaintiff will supplement.

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REQUEST FOR PRODUCTION NO. 27:

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Produce the identity of all Plaintiff employer supervisor(s) that are connected to and pertain to the
basis of the claims being made by you in this lawsuit.

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ANSWER:

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Plaintiff will supplement.

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REQUEST FOR PRODUCTION NO. 28:
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Produce copies of documents and supporting materials Plaintiff references in paragraph two (2) in
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her Affidavit [EXHIBIT A] filed with the 270th Judicial Court on September 27, 2017 in which
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Plaintiff states under oath, "Jennifer Thibeaux has sent letters to my boss of two years at Cotton
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Ranch Events to try to get me fired. She has sent him a couple of letters with false allegations."
which will be used as the legal basis for defamation claims under Texas law to be used in Plaintiff's
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lawsuit.
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ANSWER:
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Please see Bates Labeled documents DURAN 000001-DURAN 000142.


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REQUEST FOR PRODUCTION NO. 29:


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Produce copies of Plaintiff's employment performance records at Cotton Ranch Events to include
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performance evaluations, performance appraisals, performance improvement plans, performance


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related pay docking, and performance bonuses.


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ANSWER:

Plaintiff will supplement.

REQUEST FOR PRODUCTION NO. 30:

Produce copies of Plaintiff's employment attendance, leave of absence, leave with pay, leave
without pay, and disciplinary records at Cotton Ranch Events during her entire tenure of
employment.
ANSWER:

Plaintiff will supplement.

REQUEST FOR PRODUCTION NO. 31:

Produce copies of any documentation from Cotton Ranch Events or the clients if Cotton Ranch
Events that references Plaintiff's job performance, job future, and/or job security during her
employment tenure.

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ANSWER:

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Plaintiff will supplement.

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REQUEST FOR PRODUCTION NO. 32:

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Produce copies of any documentation from Plaintiff's employer Cotton Ranch Events relating to

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salary pay increases, decreases, or bonuses paid during Plaintiff's employment tenure.

ANSWER: Da
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Plaintiff will supplement.
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REQUEST FOR PRODUCTION NO. 33:


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Produce copies of Plaintiff's past two (2) years employment pay stubs from Cotton Ranch Events.
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ANSWER:
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Plaintiff will supplement.


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REQUEST FOR PRODUCTION NO. 34:


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Produce copies of Plaintiff's request for medical leave from Cotton Ranch Events.
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ANSWER:
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Plaintiff will supplement.

REQUEST FOR PRODUCTION NO. 35:

Produce a copy of Plaintiff's job history resume to include company and/or organization name,
place of business, job title, supervisor identifying information, description of Plaintiff's job role,
reason for Plaintiff's employment termination, Plaintiff's education and certificates, and any other
job-related work that comprises Plaintiff's work history as an adult over the past 30 years.
ANSWER:

Plaintiff will supplement.

REQUEST FOR PRODUCTION NO. 36:

Produce copies of the documents Plaintiff references in paragraph three (3) in her Affidavit
[EXHIBIT A] filed with the 270th Judicial Court on September 27, 2017 in which Plaintiff states
under oath, "Jennifer Thibeaux has also sent letters to Absolutely! Katy Magazine in October and

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stated in the letter that I shouldn't have survived cancer." which have made the basis of the claims
being made by you in this lawsuit. Additionally, Plaintiff is requested to produce the original

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documents in this request for inspection by Defendant. Plaintiff is also requested to produce the
evidence of the form of transmission of said documents either physical or electronic for each and

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every document which pertain to or makes the basis of the claims being made by you in this

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lawsuit.

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ANSWER:

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Please see Bates Labeled documents DURAN 000001-DURAN 000142.
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REQUEST FOR PRODUCTION NO. 37:
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Produce copies of documents the Plaintiff alleges were sent from Defendant to any and all
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magazine publications which have made the basis of the claims being made by you in this lawsuit.
Additionally, Plaintiff is requested to produce the original documents in this request for inspection
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by Defendant. Plaintiff is also requested to produce the evidence of the form of transmission of
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said documents either physical or electronic for each and every document which pertain to or
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makes the basis of the claims being made by you in this lawsuit.
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ANSWER:
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Please see Bates Labeled documents DURAN 000001-DURAN 000142.


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REQUEST FOR PRODUCTION NO. 38:


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Produce copies of any and all documents reflecting, evidencing, or comprising any note, letter,
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electronic mail, facsimile transmission, social media posting, live broadcast, recorded broadcast,
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or other form of communication as defined in "COMMUNICATION" within this DEFENDANT'S


FIRST REQUEST FOR PRODUCTION which pertain to or makes the basis of the claims being
made by you in this lawsuit.

ANSWER:

Please see Bates Labeled documents DURAN 000001-DURAN 000142.


REQUEST FOR PRODUCTION NO. 39:

Produce copies of medical documents Plaintiff references in paragraph four (4) in her Affidavit
[EXHIBIT A] filed with the 270th Judicial Court on September 27, 2017 in which Plaintiff states,
"With her sending letters to my work place and to the magazines defaming my character with false
allegations, it has really put me in a bad depression and had to see Dr. Patricia Salvato." which
have made the basis of the claims being made by you in this lawsuit. Defendant requests the
following documents based on Plaintiff's claims in this lawsuit.

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a. Produce the evidence of the date of Plaintiff's original medical diagnosis of depression or
any other illness Plaintiff alleges which pertain to or makes the basis of the claims being

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made by you in this lawsuit.

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b. Produce copies of physician(s) documentation pertaining to the medical diagnosis of

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depression or any other illness Plaintiff alleges which pertain to or makes the basis of the

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claims being made by you in this lawsuit.

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c. Produce copies of physician(s) documentation of Plaintiff's physical symptoms of the
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medical diagnosis of depression or any other illness Plaintiff alleges which pertains to or
makes the basis of the claims being made by you in this lawsuit.
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d. Produce the identity of the treating physician(s) that extended and/or agreed with the
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medical diagnosis of depression or any illness Plaintiff alleges which pertain to or makes
the basis of the claims being made by you in this lawsuit.
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e. Produce the overall dates of treatment by the treating physician(s) that extended or agreed
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with the medical diagnosis of depression or any illness Plaintiff alleges which pertain to or
makes the basis of the claims being made by you in this lawsuit.
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f. Produce copies of the medical treatment records and treatment notes pertaining to
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Plaintiff's medical diagnosis of depression or any illness Plaintiff alleges which pertain to
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or makes the basis of the claims being made by you in this lawsuit.
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g. Produce copies of the medication scripts prescribed by treating physicians to Plaintiff for
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the diagnosis of depression or any illness Plaintiff alleges which pertain to or makes the
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basis of the claims being made by you in this lawsuit.


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h. Produce the identity of the pharmacy or pharmacies in which the Plaintiff filled medicine
prescriptions related to depression or any illness Plaintiff alleges which pertain to or makes
the basis of the claims being made by you in this suit.

i. Produce copies of the prescription records at each and every pharmacy Plaintiff filled
medicine prescriptions related to depression or any illness Plaintiff alleges which pertain
to or makes the basis of the claims being made by you in this lawsuit.
j. Produce copies of the prescription records of all prescription medications Plaintiff has
taken in the past five (5) years from the date of this request.

k. Produce copies of the over-the-counter medications taken by Plaintiff to treat the medical
diagnosis of depression or any other illness Plaintiff alleges which pertain to or makes the
basis of the claims being made by you in this lawsuit.

ANSWER:

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Plaintiff will supplement.

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REQUEST FOR PRODUCTION NO. 40:

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Produce copies of documents and/or evidence to be used in this lawsuit to support claims made by

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Plaintiff referenced in paragraph six (6) in her Affidavit filed with the 270th Judicial Court on

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September 27, 2017 in which Plaintiff states under oath, "It's a horrible feeling having to watch
over my should every time I leave and arrive home. Her ongoing conduct gives me concern for the

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safety of sixteen-year-old daughter and myself. We live in constant fear for our lives." which have
made the basis of the claims being made by you in this lawsuit.
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ANSWER:
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Please see Bates Labeled documents DURAN 000001-DURAN 000142.


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REQUEST FOR PRODUCTION NO. 41:


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If not previously produced in response to the foregoing requests for production, produce copies of
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all documents upon which you rely in support of your contention that Defendant committed any
wrongdoing or improper act or omission that has harmed you in any way.
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ANSWER:
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Please see Bates Labeled documents DURAN 000001-DURAN 000142.


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REQUEST FOR PRODUCTION NO. 42:


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Any other manner of thing that will go to responsively address each and every thing as said to be
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wanting in Defendant's answer not already covered by this request.

ANSWER:

Please see Bates Labeled documents DURAN 000001-DURAN 000142.


EXHIBIT Q
3/26/2018 7:12 AM
Chris Daniel - District Clerk Harris County
Envelope No. 23408340
By: Danielle Gutierrez
Filed: 3/26/2018 7:12 AM

CAUSE NO. 201716162

JULISSA DURAN, § IN THE DISTRICT COURT


§
PLAINTIFF, §
§
VS. § HARRIS COUNTY, TEXAS
§
JENNIFER THIBEAUX, §

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§
DEFENDANT. § 270TH JUDICIAL DISTRICT

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PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION TO COMPEL

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TO THE HONORABLE JUDGE OF SAID COURT:

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COMES NOW, Plaintiff, JULISSA DURAN (hereinafter “Plaintiff” or “Ms. Duran”), and

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files this Response to Jennifer Thibeaux’s Motion to Compel (“Motion”), and in support thereof
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would respectfully show this Honorable Court the following:
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I. FACTUAL BACKGROUND
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1. The defendant is indeed correct that discovery responses were served late,
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however, discovery responses were served without any objections.


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2. Ms. Duran, in good faith, has provided the documents that are in her possession
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and is working diligently to provide the remaining documents that will be supplemented.
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3. Furthermore, the defendant has alleged that the documents provided are
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unresponsive. Ms. Duran made a good-faith effort to provide the discovery responses and
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tendered to the defendant 142 documents, all of which were responsive to the defendant’s
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discovery requests.

II. ARGUMENT AND AUTHORITY

4. The defendant argues that Ms. Duran’s responses to defendant’s discovery

requests are insufficient because of Ms. Duran’s “will supplement” response.


. Texas Rule of Civil Procedure 193.5 (b) provides,

“Time and form of amended or supplemental response. An amended or


supplemental response must be made reasonably promptly after the party
discovers the necessity for such a response. Except as otherwise provided by
these rules, it is presumed that an amended or supplemental response made less
than 30 days before trial was not made reasonably promptly…”

5. The trial in this matter is set for June 18, 2018. Ms. Duran has been and is

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currently working to provide all the documents in response to defendant’s discovery requests.

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She is absolutely not attempting to abuse the discovery process.

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6. The defendant also argues that Ms. Duran’s responses are unresponsive, as the

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response given was to refer to the 142 Bates Labeled documents that were provided.

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Texas Rule of Civil Procedure 196.3 (a) provides,
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“Time and place of production. Subject to any objections stated in the response,
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the responding party must produce the requested documents or tangible things
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within the person's possession, custody or control at either the time and place
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requested or the time and place stated in the response, unless otherwise agreed by
the parties or ordered by the court, and must provide the requesting party a
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reasonable opportunity to inspect them.”


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7. Ms. Duran provided all documents in her possession that answered the
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defendant’s discovery requests.


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III. CONCLUSION
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8. The defendant should not be granted the relief sought in its Motion because Ms.
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Duran has provided the defendant with over a one hundred responsive documents that she has in
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her custody and control. All other documents will be supplemented when Ms. Duran has
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gathered them, as we are still more than two months from our trial date.
PRAYER

WHEREFORE, PREMISES CONSIDERED, Plaintiff, JULISSA DURAN, respectfully

prays that the Court deny defendant’s Motion, and all relief sought therein, and for such other

and further relief, both in law or equity, to which Ms. Duran may be justly entitled.

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Respectfully submitted,

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ROBERTS MARKLAND LLP

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/s/ Sean A. Roberts

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________________________
SEAN A. ROBERTS

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State Bar No. 00797328
ANJALI SHARMA
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State Bar No. 24094403
2555 North MacGregor Way
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Houston, Texas 77004
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(713) 630-0900 (Telephone)


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(713) 630-0991 (Fax)


sr@robertsmarkland.com
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as@robertsmarkland.com
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ATTORNEYS FOR PLAINTIFF


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CERTIFICATE OF SERVICE
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I hereby certify that a true and correct copy of the above and foregoing instrument has
been forwarded to all known persons of record on this day of March, 2018.
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Jennifer Thibeaux
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P.O. Box 352


Waco, Texas 76703
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DEFENDANT

/s/ Anjali Sharma


Anjali Sharma
EXHIBIT R
9/27/2017 10:58 AM
Chris Daniel - District Clerk Harris County
Envelope No. 19697341
By: SASHA PRINCE
Filed: 9/27/2017 10:58 AM

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EXHIBIT S
CAUSE NO. 201716162

Julissa Duran § IN THE DISTRICT COURT OF


§
Plaintiff, §
§
§
VS. §
HARRIS COUNTY, TEXAS
§
§
Jennifer Thibeaux §
§
Defendant. 270TH JUDICIAL DISTRICT
§

ORDER GRANTING DEFENDANT’S MOTION TO STRIKE PLAINTIFF’S DISCOVERY RESPONSES,


MOTION FOR SANCTIONS, AND FOR COSTS AND FEES

After reviewing DEFENDANT’S MOTION TO STRIKE PLAINTIFF’S DISCOVERY RESPONSES,

MOTION FOR SANCTIONS, AND FOR COSTS AND FEES, pleadings, evidence, and arguments of

counsel, if any, the Court is of the opinion that the motion should be GRANTED.

It is so ORDERED that,

1. Plaintiff’s Discovery Responses and Production made outside of the Discovery Period

including Bates labeled DURAN 000143 – 000238 are stricken from all proceedings;

2. All evidence and witness information related to the Defendant’s Request for Disclosures

is barred from Plaintiff’s use in all proceedings;

3. All evidence and witness information related to the production evidence Plaintiff failed

to supplement is barred from Plaintiff’s use in all proceedings;

4. All evidence Bates labeled DURAN 000001 – 000142 Plaintiff failed to allow inspection of

originals is barred from Plaintiff’s use in all proceedings;

1
ORDER GRANTING DEFENDANT’S MOTION TO STRIKE PLAINTIFF’S DISCOVERY RESPONSES, MOTION FOR
SANCTIONS, AND FOR COSTS AND FEES
It is further ORDERED that Plaintiff Julissa Duran must pay Defendant Jennifer Thibeaux

reasonable fees and costs in the amount of $_____________ within two (2) weeks from the date of

this order.

It is further ORDERED that Plaintiff’s counsel, Sean Alan Roberts (Texas Bar: 00797328 )

must pay Defendant Jennifer Thibeaux Sanctions in the amount of $_____________ within two (2)

weeks from the date of this order.

It is further ORDERED that Plaintiff’s counsel, Anjali Sharma (Texas Bar: 24094403) must pay

Defendant Jennifer Thibeaux Sanctions in the amount of $_____________ within two (2) weeks

from the date of this order.

SIGNED this _______ day of _______________, 2018

__________________________________
HONORABLE JUDGE BRENT GAMBLE

2
ORDER GRANTING DEFENDANT’S MOTION TO STRIKE PLAINTIFF’S DISCOVERY RESPONSES, MOTION FOR
SANCTIONS, AND FOR COSTS AND FEES