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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 IN LIMINE TO EXCLUDE PLAINTIFF’S EVIDENCE

TO THE HONORABLE JUDGE OF SAID COURT:

Pursuant to Texas Rules of Civil Procedure 166, 190.3(b)(1), 192.5, 193.2, 193.3, 193.4,

193.5 and 193.6, and to Texas Rules of Evidence 103(c), 104(a), 104(c), 105, 401, 402, 403, 702,

801, 802, 1002, and 1007, before jury selection proceedings begin Defendant, JENNIFER THIBEAUX

moves the court, in limine, to order that Plaintiff, JULISSA DURAN, her attorneys of record, and her

witnesses, shall not make any requests or statements, ask any questions, or testify or offer other

evidence about any of these matters, until after the party has made the request or statement,

asked the question, or made an offer of proof outside of the hearing or presence of the jury and

obtained an order from the court permitting the request or statement, or question, or admitting

evidence, relating to these matters:

Cause No. 201716162


DEFENDANT’S MOTION IN LIMINE TO EXCLUDE PLAINTIFF’S EVIDENCE
1
I. INTRODUCTION

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. The Court designated

the Trial Preparation Order on April 26, 2018 and both Plaintiff and Defendant were notified.

While Plaintiff has ignored the evidence exchange as required by the Court’s Trial Preparation

Order and in accordance with TEX. CIV. R. P. 193.7 to date, the Defendant has assumed the

strength of Plaintiff’s evidence exists within the production evidence proffered during discovery.

The Defendant formally notified the Plaintiff of objections to Plaintiff’s production evidence. The

Plaintiff failed to respond to Defendant’s attempt at conference regarding the matter. Again,

Plaintiff never exchanged evidence with Defendant for intended use in trial and per the Court’s

Trial Preparation Order. Based on the discovery production evidence produced from the Plaintiff,

the Defendant objects to the use of said evidence in trial. The deadline for filing a Motion in Limine

is June 4, 2018 in accordance with the Court’s Trial Preparation Order.

II. ARGUMENT

Motion in Limine No. 1: Plaintiff Should Be Precluded from Proffering Social Media Evidence
Which Is Not from the Original Posting, Web Page, or Source; and/or That Fails to Show
Indisputable Ownership of the Account(s); and/or That Fails to Document Evidence of Posting
Within the Period of Recovery for Plaintiff’s Lawsuit.

Cause No. 201716162


DEFENDANT’S MOTION IN LIMINE TO EXCLUDE PLAINTIFF’S EVIDENCE
2
In Plaintiff’s Original Petition, she alleged that Defendant made defamatory statements

against her online and in social media. Defendant made discovery requests related to the social

media and online postings Plaintiff referenced in her original pleading as well as in her sworn

affidavit filed with the court on September 27, 2017. During Discovery, Plaintiff proffered

production evidence within Bates Labeled DURAN 000001 - 000142 in response to Defendant’s

Discovery Requests. Upon review of Plaintiff’s production evidence, it appears that the Plaintiff is

considering an email to herself from an unknown source with .JPG image file type of what

resembles a social media post in the body of the email as her evidence of social media postings

from Defendant. There are many issues with Plaintiff’s evidence. Plaintiff is showing an image

which is unclear as to the authenticity of the image. Plaintiff never allowed inspection of the

original therefore all that Defendant was able to review was a copy, of an email to the Plaintiff,

with an unverified image. The Texas Standard relating to admissibility and authenticating social

media evidence is demonstrated in Tiendo v. State by which case law directs litigants to provide

appropriate extrinsic evidence Tienda v. State, No. 05–09–00553–CR, 2010 WL 5129722. In August

2016, the opinion from Pennsylvania’s 3rd Circuit Court of Appeals on U.S. v. Browne, 834 D.3d

403 (2016) that “Social media evidence is not self-authenticating, even with a certificate from the

site.” The opinion went on to suggest that litigants, “must use extrinsic evidence and the standard

is preponderance.” First Plaintiff has not presented social media evidence to satisfy general

admissibility TRE 401, 402, and 403. Plaintiff has presented an email to herself with a picture

which she is considering a controlling issue of her case TRE 403. Plaintiff testified to social media

posts that the Plaintiff herself cannot produce or authentically evidence. Second, Plaintiff has not

presented any extrinsic evidence such as expert testimony or other testimony to prove content

Cause No. 201716162


DEFENDANT’S MOTION IN LIMINE TO EXCLUDE PLAINTIFF’S EVIDENCE
3
that would satisfy the submission of a preponderance of evidence of social media evidence TRE

702, 1007. Plaintiff failed to make discovery requests during the discovery period therefore the

Plaintiff has not discovered any extrinsic evidence by choice. Plaintiff would ask the Court to admit

an unknown picture sent from an unknown person to herself as Defendant’s social media evidence

and that is not acceptable or admissible. For instance, a Facebook posting webpage would contain

a unique webpage www.facbook.com/123456. Plaintiff cannot show where the image originated.

Plaintiff’s multiple images which are showcased in the same format as being embedded in an

email to herself, she purports to be social media on its face does not show a connection to

Defendant, a date of the posting, or a connection to any individual lacking demographic, meta

data, and identifying information. While Plaintiff has ignored the evidence exchange as required by

the Court’s Trial Preparation Order, the Defendant will assume the strength of Plaintiff’s evidence

exists within the production evidence proffered during discovery.

Motion in Limine No. 2: Plaintiff Should Be Precluded from Proffering Picture Images of Any Kind
Which Fail to Contain Identifying Information About the User, Ownership, Date and Time,
Preservation, Chain of Custody, and Meta Data Information.

In Plaintiff’s production evidence proffered in response to Defendant’s Discovery requests,

Plaintiff offered numerous Joint Photographic Experts Group (commonly referred to as JPGs)

contained in Bates Labeled DURAN 000001 – 000142. Plaintiff has ignored the evidence exchange

as required by the Court’s Trial Preparation Order, the Defendant will assume the strength of

Plaintiff’s evidence exists within the production evidence proffered during discovery. Plaintiff’s JPG

images proffered as evidence to support controlling issues fail to contain identity information such

as meta data, date and time, preservation information, chain of custody, and ownership. Simply

Cause No. 201716162


DEFENDANT’S MOTION IN LIMINE TO EXCLUDE PLAINTIFF’S EVIDENCE
4
showcasing a picture does not make it admissible if it lacks authenticity and, in many cases, lacks

relevance to controlling issues. The Texas Rules of Evidence are very clear on the matter, 401, 402,

and 403. The Plaintiff has failed to meet the minimum standards of relevance according to the

TRE. Additionally, Defendant made several attempts to inspect the originals of Plaintiff’s proffered

evidence with Plaintiff refusing to allow inspection not adhering to the TRE 1002. Defendant

respectfully asks the Court to bar all image evidence from Plaintiff based on the issues herein.

Motion in Limine No. 3: Plaintiff Should Be Precluded from Proffering Third Party Evidence that
Fails to Authenticate Originality, Ownership, Chain of Custody, Evidence of Date, or Witness
Testimony.

In Plaintiff’s Original Petition, she alleged that Defendant made defamatory statements

against her through letters sent to a Third Party – her boss at Cotton Ranch Events and a magazine

– Absolutely Katy Magazine. In Plaintiff’s production evidence proffered during the discovery

period and in response to Defendant’s Discovery Requests, Bates labeled DURAN 000001 –

000142, Plaintiff offered four communications. Two of the communications appeared to be faxed

communications sent from Selena Gourlenia to Pete Bell of Cotton Holdings and to Patti Parish

Kaminski. Plaintiff is not the recipient of those communications which in and of itself establishes

hearsay TRE 801(d), 802. Plaintiff failed to proffer testimony from the stated recipients of the

communication TRE 702, 1007. Plaintiff failed to allow inspection of the originals of the evidence

TRE 1002. Furthermore, the other two of four communications that are connected to controlling

issues in Plaintiff’s lawsuit are both from an unnamed person with signatures as, “A Katy, TX

Native” and “A Disappointed Loyal Reader” to Pete Bell of Cotton Holdings and Patti Parish

Kaminski respectively. The communications on their face do not contain Defendant’s name or

Cause No. 201716162


DEFENDANT’S MOTION IN LIMINE TO EXCLUDE PLAINTIFF’S EVIDENCE
5
identity and they were sent to a Third Party of which Plaintiff has failed to authenticate through

allowing inspection of the original documentation, expert testimony, or other testimony.

Ultimately, there is no proof that these documents exist other than through the creativity of the

Plaintiff. The four letters (two faxes and two letters) lack relevance, admissibility, expert

testimony, other testimony, are hearsay, lack proof of the original, and lack testimony to prove the

content TRE 401, 402, 403, 702, 801, 802, 1002, and 1007.

Motion in Limine No. 4: Plaintiff Should Be Precluded from Calling Witnesses Not Offered,
Identified, or Made Available During Discovery and in Accordance with the Docket Control Order
and the Texas Rules of Civil Procedure.

The Court established a very clear Docket Control Order on November 20, 2017. According

to the Court’s Order, Expert Witnesses and all other experts were to be designated by March 19,

2018. The designation must include the information listed in Rule 194.2(f). Defendant additionally

served a Discovery Request for Disclosures on February 26, 2018, with responses due on March

28, 2018. Finally, as part of the Trial Preparation Order, Plaintiff has failed to proffer a Witness List

as of the date of this filing. The Plaintiff as of the date of this filing has never responded to

Defendant’s Request for Disclosures; and has not communicated or served Expert Witness or

other experts. Failure to communicate an expert testimony or other witness information in a

timely fashion should bar the Plaintiff from using such information in trial as it would not offer a

fair opportunity to Defendant in trial TRE 702.

Secondly on this matter, Plaintiff proffered production evidence during Discovery from an

Internet Protocol Search from the internet – whatismyipadaddress.com contained in Bates Labeled

DURAN 000001 – 000142. Plaintiff is using that evidence in an attempt to establish Defendant’s

whereabouts the day an alleged fax to a Third Party was sent. Unfortunately,

Cause No. 201716162


DEFENDANT’S MOTION IN LIMINE TO EXCLUDE PLAINTIFF’S EVIDENCE
6
whatismyipadaddress.com is not a designated expert or certified by the court as an authority in

location verification. Additionally, Plaintiff’s evidence of IP Address merely showcases where the

fax came from and has no connection to the Defendant. Without serving an expert report or

testimony during the discovery period, this evidence which is borderline irrelevant should be

barred and disqualified from use in trial TRE 401, 402, 702, 1002, and 1007.

Motion in Limine No. 5: Plaintiff Should Be Precluded from Admitting Irrelevant Evidence during
Trial.

It appears the Plaintiff added a significant amount of fluff or filler production evidence

including excessive amounts of duplicate documents that were unrelated to controlling issues of

Plaintiff’s case. While Plaintiff has ignored the evidence exchange as required by the Court’s Trial

Preparation Order, the Defendant will assume the strength of Plaintiff’s evidence exists within the

production evidence proffered during discovery. In Plaintiff’s production evidence Bates Labeled

DURAN 000001 – 000142, there were what appeared to be random social media page screenshots

from unknown accounts with no connections to Defendant’s discovery requests or a controlling

issue in this case. In many of Plaintiff’s production evidence she added handwriting to the

discovery which will create confusion and bias with a jury and are against the TRE 401, 402, 403,

801, 802. It appears the Plaintiff without evidence is attempting to connect irrelevant and

unrelated evidence of a controlling issue to Defendant. Such information would bias a jury and has

no place in the trial proceeding due to a general lack of admissibility and lack of a connection to a

controlling issue.

Motion in Limine No. 6: Plaintiff Should Be Precluded from Proffering Evidence Related to
Damages or Special Damages during Trial.

Cause No. 201716162


DEFENDANT’S MOTION IN LIMINE TO EXCLUDE PLAINTIFF’S EVIDENCE
7
Plaintiff has every right to claim damages in this lawsuit. As a matter of law, damages are a

requisite to meeting the standards or recovery in a Defamation case. While Plaintiff has ignored

the evidence exchange as required by the Court’s Trial Preparation Order, the Defendant will

assume the strength of Plaintiff’s evidence exists within the production evidence and responses

proffered during discovery. Plaintiff in her Original Petition claimed she had special damages. As

previously identified in Defendant’s Motion for No-Evidence Summary Judgment, the Plaintiff

failed to specify the Special Damages as required by the TEX. R. CIV. P. 56. Furthermore, in

Plaintiff’s response to Defendant’s First Request for Production Request 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 a legal basis for

defamation claims under Texas law to be used in Plaintiff’s lawsuit”. Plaintiff served responses on

February 20, 2018 as, “None.”. Plaintiff has indicated she has sustained no losses. Defendant asked

about the calculation of losses and special damages in Defendant’s Request for Interrogatories

filed March 23, 2018 and due April 23, 2018 however Plaintiff failed to serve answers within the

discovery period and within the Rules – lacked Plaintiff’s signature, unsworn, served after the

conclusion of the discovery period. The Plaintiff failing to serve adequate responses in accordance

with the Rules are equivalent to not responding to Defendant’s Discovery Requests. Plaintiff has

not proffered any evidence to showcase losses. Plaintiff has not served production evidence

during discovery or even leading up to the date of this filing that evidenced any loss – economic

and/or special damages. The TEX. R. CIV. P. 193.6(a) is very clear in regard to failing to timely

respond to discovery requests. Plaintiff should be barred from presenting any financial loss

associated with this case.

Cause No. 201716162


DEFENDANT’S MOTION IN LIMINE TO EXCLUDE PLAINTIFF’S EVIDENCE
8
Motion in Limine No. 7: Hearsay Medical Opinions Should be Excluded

Any hearsay statement by an allegedly injured person offered for the purpose of proving the truth

of the declaration concerning any diagnosis or medical opinions by a physician or other health care

provider. Texas Rules of Evidence 802.

III. CERTIFICATE OF CONFERENCE

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

by the Certificate of Conference included herein [EXHIBIT A].

Respectfully submitted,

Defendant’s Signature

JENNIFER THIBEAUX
191 Boulevard Rene-Levesque Est
Montreal, QC, Canada H2X 3Z9
713-510-7714

PRO SE

Cause No. 201716162


DEFENDANT’S MOTION IN LIMINE TO EXCLUDE PLAINTIFF’S EVIDENCE
9
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
4th day of June, 2018.

Defendant’s Signature

Cause No. 201716162


DEFENDANT’S MOTION IN LIMINE TO EXCLUDE PLAINTIFF’S EVIDENCE
10
EXHIBIT A
CAUSE NO. 201716162

§ IN THE DISTRICT COURT OF


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

CERTIFICATE OF CONFERENCE

As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I have

conferred, or made a reasonable attempt to confer, with all other parties which are listed below

about the merits of this motion with the following results:

Sean Alan Roberts, attorney of record for Plaintiff JULISSA DURAN (Cause No. 201716162)

• Email and USPS Priority Mailing Attempt May 15, 2018 – Plaintiff’s
counsel did not return my message

• Email Attempt May 23, 2018 – Plaintiff’s counsel did not return my
message (copied Anjali Sharma on this message with no response from
her on this matter).

______________________________________
Jennifer Thibeaux, pro se
191 Boulevard Rene Levesque, #1022
Montreal, QC, Canada H2X 3Z9
713-510-7714

June 4, 2018
______________________________________
[Date]
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 832-510-7714 • jennthibeaux@gmail.com

May 15, 2018


EMAILED AND MAILED VIA USPS

SEAN A. ROBERTS
2555 NORTH MACGREGOR, SUITE 200
HOUSTON, TEXAS 77004

RE: DURAN v. THIBEAUX, CAUSE: 201716162

Dear Mr. Roberts,

I hope this letter finds you well. I have made numerous requests for the supplementation of evidence of the
Defendant’s First Request for Production. I have not received any further information about the
information your office previously committed to provide. Additionally, I have questioned the authenticity of
evidence and have demanded on numerous occasions to examine the originals of all evidence in Bates
Labeled DURAN 000001 – 000142. You have not cooperated with this process. Is your client still pursuing
this case?

All evidence I have reviewed by copy only, Bates Labeled DURAN 000001 – 000142 fails to meet the
standard of admissibility and authenticity. Your client has several issues related to her evidence:
• Social Media evidence appears to be emails from your client’s inbox and not an original posting.
o Evidence lacks authentication (metadata, chain of custody, user information, time of
preservation, provider information, testimony, etc.)
• Letters to Cotton Ranch and Absolutely Katy Magazine lack authentication (chain of custody, time
of preservation, date of receipt, a connection to Jennifer Thibeaux, etc.)
• Special damages have never been specified in the original petition and evaded to respond to direct
questions about special damages during the discovery period
• Evidence related to depression as alleged in your client’s sworn testimony (August 23, 2017) has no
supporting evidence despite the numerous requests to review evidence in the discovery period
• A majority of evidence in Bates Labeled DURAN 000001 – 000142 appears to be irrelevant to your
petition and allegations of defamation.

Counselor, the bar is very high for defamation and you know this. It is your responsibility to advise your
client regarding the efficacy of her claims. This letter is designed to satisfy the request for Conference
regarding the above referenced matters. If you elect to decline to discuss or ignore this request, I will seek
court intervention for resolution. If your client wishes to discontinue her pursuit of this matter, I highly
recommend you non-suit this cause of action soon.

Regards,

Jennifer Thibeaux
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6/3/2018 Gmail - DURAN v. THIBEAUX, CAUSE: 201716162 (Issues with Duran's Evidence)

Jennifer Thibeaux <jennthibeaux@gmail.com>

DURAN v. THIBEAUX, CAUSE: 201716162 (Issues with Duran's Evidence)


1 message

Jennifer Thibeaux <jennthibeaux@gmail.com> Tue, May 15, 2018 at 5:24 PM


To: sr@therobertsfirm.com

May 15, 2018

SEAN A. ROBERTS
2555 NORTH MACGREGOR, SUITE 200
HOUSTON, TEXAS 77004

RE: DURAN v. THIBEAUX, CAUSE: 201716162

Dear Mr. Roberts,

I hope this le er finds you well. I have made numerous requests for the supplementa on of evidence of the
Defendant’s First Request for Produc on. I have not received any further informa on about the informa on your
office previously commi ed to provide. Addi onally, I have ques oned the authen city of evidence and have
demanded on numerous occasions to examine the originals of all evidence in Bates Labeled DURAN 000001 –
000142. You have not cooperated with this process. Is your client s ll pursuing this case?

All evidence I have reviewed by copy only, Bates Labeled DURAN 000001 – 000142 fails to meet the standard of
admissibility and authen city. Your client has several issues related to her evidence:
· Social Media evidence appears to be emails from your client’s inbox and not an original pos ng.
o Evidence lacks authen ca on (metadata, chain of custody, user informa on, me of preserva on,
provider informa on, tes mony, etc.)
· Le ers to Co on Ranch and Absolutely Katy Magazine lack authen ca on (chain of custody, me of
preserva on, date of receipt, a connec on to Jennifer Thibeaux, etc.)
· Special damages have never been specified in the original pe on and evaded to respond to direct
ques ons about special damages during the discovery period
· Evidence related to depression as alleged in your client’s sworn tes mony (August 23, 2017) has no
suppor ng evidence despite the numerous requests to review evidence in the discovery period
· A majority of evidence in Bates Labeled DURAN 000001 – 000142 appears to be irrelevant to your
pe on and allega ons of defama on.

Counselor, the bar is very high for defama on and you know this. It is your responsibility to advise your client
regarding the efficacy of her claims. This le er is designed to sa sfy the request for Conference regarding the above
referenced ma ers. If you elect to decline to discuss or ignore this request, I will seek court interven on for
resolu on. If your client wishes to discon nue her pursuit of this ma er, I highly recommend you non-suit this cause
of ac on soon.

Regards,

Jennifer Thibeaux

https://mail.google.com/mail/u/1/?ui=2&ik=7445d7d60e&jsver=-dxVNc9Y02g.en.&cbl=gmail_fe_180516.06_p8&view=pt&search=sent&th=16365b050def4e4d&siml=1
6/3/2018 Gmail - DURAN v. THIBEAUX Cause: 201716162 - CONFERENCE ATTEMPT

Jennifer Thibeaux <jennthibeaux@gmail.com>

DURAN v. THIBEAUX Cause: 201716162 - CONFERENCE ATTEMPT


1 message

Jennifer Thibeaux <jennthibeaux@gmail.com> Wed, May 23, 2018 at 12:45 PM


To: sr@therobertsfirm.com
Cc: Anjali Sharma <as@robertsmarkland.com>

Good Afternoon Mr. Roberts,

Attached is a descriptive document which outlines many items related to this matter to be used and/or information
leveraged in upcoming proceedings. I would encourage you to review it carefully and consider the matters I have
addressed/proposed.

Regards,

Jennifer Thibeaux
713-510-7714

May23ndLetterToRoberts_Limine Conf Req_SIGNED.pdf


752K

https://mail.google.com/mail/u/1/?ui=2&ik=7445d7d60e&jsver=-dxVNc9Y02g.en.&cbl=gmail_fe_180516.06_p8&view=pt&search=sent&th=1638de3f7d8b4c9c&siml=1
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

May 23, 2018 EMAILED ON 05-23-18


TO: sr@therobertsfirm.com
SEAN A. ROBERTS
2555 NORTH MACGREGOR, SUITE 200 CC: as@robertsmarkland.com

HOUSTON, TEXAS 77004

RE: DURAN v. THIBEAUX, CAUSE: 201716162

Dear Mr. Roberts,

I hope this letter finds you well. I am writing to attempt conference regarding this matter. On
March 8, 2017, your client filed a Defamation lawsuit against me. Since then, your client has
produced production evidence Bates labeled DURAN 000001 – 000142 (February 20, 2018) and
Bates labeled DURAN 000143 – 000228 (May 21, 2018). There are major issues with the
production evidence your client has submitted. As required by the T.R.C.P., I have a duty to
specify the issues related to discovery. I am including a chart to specify the issues with Plaintiff’s
production documents propounded. It is important to note that the duplicate documents
propounded out-number unique documents. It is not professional to represent 228 unique
Bates labeled documents that contain over 100 duplicates.

I have every intention to file a Motion in Limine to Exclude Plaintiff’s Evidence (Bates labeled
DURAN 000001 – 000228) in all future pre-trial and trial proceedings based on inadmissibility,
relevance, and other evidentiary issues soon. The discovery period is now closed. Your client
not only failed to exercise discovery, she has also failed to propound admissible and relevant
evidence. Your client failed to supplement discovery responses in accordance with her “Plaintiff
will Supplement” statements made in the 1st Request For Production [Requests - 6, 8, 10, 12-14,
19, 26-27, 29-35, 39 (a-k)]. Your client failed to respond to Defendant’s Request for Disclosure,
Request for Interrogatories, and 2nd Request for Production within the discovery period. By
Rule, all evidence must be excluded. Mr. Roberts, it is time to take a serious assessment of this
case and have a pointed talk with your client.

Should you wish to resolve this matter outside of the court’s intervention, please feel free to
contact me. I have made several attempts at phone conference with you and have been unable
to get you on the telephone. Should your client wish to Non-Suit this lawsuit, let’s discuss
drafting a Rule 11 agreement. The clock is obviously ticking on the Summary Judgment motion
to be heard.

Regards,

Jennifer Thibeaux
Page 1 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled Cease and Desist Letter from Brooks Document from 3rd party – lacks
DURAN 000001 Acevedo to Jennifer Thibeaux dated October authentication from 3rd party
7, 2016. Defendant questioned authenticity. No connection to a controlling issue
Defendant requested inspection of original. Allegations absent evidence or specificity
Plaintiff evaded/denied inspection of Hearsay, Rule 801(d), Rule 802
original. Requirement of the Original, Rule 1002
BATES labeled Appears to be page 2 of DURAN – 000001. Document from 3rd party – lacks
DURAN 000002 Defendant questioned authenticity. authentication from 3rd party
Defendant requested inspection of original. No connection to a controlling issue
Plaintiff evaded/denied inspection of Allegations absent evidence or specificity
original. Hearsay, Rule 801(d), Rule 802
Requirement of the Original, Rule 1002
BATES labeled Document that shows an image of Julissa No reference to Jennifer Thibeaux, no date
DURAN 000003 Duran with identifying information and on the document. No metadata. No chain of
reference to Facebook in the text. custody. No authentication.
Defendant questioned authenticity. Test for Relevance, Rule 401(a),(b)
Defendant requested inspection of original. General Admissibility, Rule 402
Plaintiff evaded/denied inspection of Requirement of the Original, Rule 1002
original
BATES labeled Top of Document: IMG_3498.PNG – Julissa This is an email with an image contained
DURAN 000004 Rucker, Date: 11/15/2016, 1:20pm herein. There is no metadata to showcase the
Appearing to be TO Julissa Rucker unique I.P. characteristics of the social media
(Julissarucker@hotmail.com). This posting Plaintiff is alleging to be authentic.
document contains the name Jennifer Lacks testimony to prove content. Lacks date
Thibeaux and references the word of the social media posting to prove
Facebook. Shows page 1/2, File number occurrence within the scope of recovery.
appears to be at the top IMG_3498.PNG. General Admissibility, Rule 402
Defendant questioned authenticity. Requirement of the Original, Rule 1002
Defendant requested inspection of original. Testimony to Prove content, Rule 1007
Plaintiff evaded/denied inspection of
original
BATES labeled Top of Document: IMG_3498.PNG – Julissa This is an email with an image contained
DURAN 000005 Rucker, Date: 11/15/2016 herein. There is no metadata to showcase the
This appears to be a continuation of DURAN unique I.P. characteristics of the social media
- 000004. The top of the document has posting Plaintiff is alleging to be authentic.
Julissa Rucker’s name At the bottom of the Lacks testimony to prove content. Lacks date
page it shows, “Sent from my iPhone” and of the social media posting to prove
Page 2/2. Defendant questioned occurrence within the scope of recovery.
authenticity. Defendant requested General Admissibility, Rule 402
inspection of original. Plaintiff Requirement of the Original, Rule 1002
evaded/denied inspection of original Testimony to Prove content, Rule 1007

Page 2 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled Top of Document: IMG_3496.PNG – Julissa The image displayed has no year date. The
DURAN 000006 Rucker, Date: 11/15/2016 1:20pm document states, “sent from my iPhone”
Appearing to be TO Julissa Rucker This is an email with an image contained
(Julissarucker@hotmail.com). The name herein. There is no metadata to showcase the
Julissa Duran also appears toward the top of unique I.P. characteristics of the social media
the document. This document appears to be posting Plaintiff is alleging to be authentic.
a Comments stream. Jennifer Thibeaux’s Lacks testimony to prove content. Lacks date
name is listed, along with Tiffany M. Hill and of the social media posting to prove
Na Mariah Sargent. At the bottom of the occurrence within the scope of recovery.
page it shows Page 1 of 2. Defendant General Admissibility, Rule 402
questioned authenticity. Defendant Requirement of the Original, Rule 1002
requested inspection of original. Plaintiff Testimony to Prove content, Rule 1007
evaded/denied inspection of original.
BATES labeled Top of Document: IMG_3496.PNG – Julissa There is no origin identified to this document.
DURAN 000007 Rucker, Date: 11/15/2016 1:20pm It appears to be sent to Julissa Rucker with
Appearing to be TO Julissa Rucker Julissa Duran’s name listed on the page,
(Julissarucker@hotmail.com). The name however no connection is identified. The
Julissa Duran also appears toward the top of image does not contain any authenticity of
the document. This document appears to be date. There is no page 2 to this document.
a Comments Replies stream. Jennifer This is an email with an image contained
Thibeaux’s name is listed, along with Tiffany herein. There is no metadata to showcase the
M. Hill, Boyd J. Conerway, and Na Mariah unique I.P. characteristics of the social media
Sargent. At the bottom of the page it shows posting Plaintiff is alleging to be authentic.
Page 1/2. Defendant questioned Lacks testimony to prove content. Lacks date
authenticity. Defendant requested of the social media posting to prove
inspection of original. Plaintiff occurrence within the scope of recovery.
evaded/denied inspection of original General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
BATES labeled Top of the page states, “Comments” and There is no origin identified to this document.
DURAN 000008 “Done” It appears to be sent to Julissa Rucker with
There appears to be an exchange between Julissa Duran’s name listed on the page,
Jennifer Thibeaux and Talva Rutherford. however no connection is identified. The
Defendant questioned authenticity. image does not contain any authenticity of
Defendant requested inspection of original. date. There is no page 2 to this document.
Plaintiff evaded/denied inspection of This is an email with an image contained
original herein. There is no metadata to showcase the
unique I.P. characteristics of the social media
posting Plaintiff is alleging to be authentic.
Lacks testimony to prove content. Lacks date
of the social media posting to prove
occurrence within the scope of recovery.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Page 3 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled Top of Document: IMG_3496.PNG – Julissa No date (month, day, or year) appears in this
DURAN 000009 Rucker, Date: 11/15/2016 document. There is no origin of this
This document appears to be a Comments document indicated.
stream. Jennifer Thibeaux’s name is listed, This is an email with an image contained
along with Boyd J. Conerway. At the bottom herein. There is no metadata to showcase the
of the page it shows, “Sent from my iPhone” unique I.P. characteristics of the social media
and Page 2/2. Defendant questioned posting Plaintiff is alleging to be authentic.
authenticity. Defendant requested Lacks testimony to prove content. Lacks date
inspection of original. Plaintiff of the social media posting to prove
evaded/denied inspection of original occurrence within the scope of recovery.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
BATES labeled DUPLICATE – DURAN - 000003 DUPLICATE – DURAN - 000003
DURAN 000010
BATES labeled DUPLICATE – DURAN - 000004 DUPLICATE – DURAN - 000004
DURAN 000011
BATES labeled DUPLICATE – DURAN - 000005 DUPLICATE – DURAN - 000005
DURAN 000012
BATES labeled DUPLICATE – DURAN - 000006 DUPLICATE – DURAN - 000006
DURAN 000013
BATES labeled DUPLICATE – DURAN - 000007 DUPLICATE – DURAN - 000007
DURAN 000014
BATES labeled DUPLICATE – DURAN - 000008 DUPLICATE – DURAN - 000008
DURAN 000015
BATES labeled DUPLICATE – DURAN - 000009 DUPLICATE – DURAN - 000009
DURAN 000016
BATES labeled This document appears to be a fax To CEO – The authenticity of this document is in
DURAN 000017 Pete Bell, Company: Cotton Holdings, From question as there is writing on the fax page.
Selena Gourlenia email: The fax transmission information is not
sgourlenia@gmail.com – IP Address: legible. Did this writing come from the
12.237.164.219. There is physical writing on original fax or was it altered after it was
the copy. There are highlights. The received? There is no indication as to the
document suggests Julissa Duran was being number of pages contained within the fax to
nominated for prolonged cyber bullying, connect it with certainty to the attachments.
cyber following, and cyber taunting in 2016 General Admissibility, Rule 402
with attachments to follow. At the bottom Requirement of the Original, Rule 1002
of the page there is a reference to 1/1. Testimony to Prove content, Rule 1007
Defendant questioned authenticity. Hearsay, Rule 801(d), 802
Defendant requested inspection of original. Test for Relevance, Rule 401(a),(b)
Plaintiff evaded/denied inspection of
original

Page 4 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document is dated November 10, 2016. Jennifer Thibeaux’s name is not included in
DURAN 000018 It appears to nominate Julissa Duran for this document. There is no connection to
cyber bullying, cyber following, and cyber Jennifer Thibeaux. Noticeably missing is the
taunting in 2016. The document lists Bully chain of custody, evidence ownership. Lacks
Achievements as prolonged cyber bullying, testimony to authenticate the evidence.
cyber following, and cyber taunting in 2016. General Admissibility, Rule 402
The document lists an Instagram and Twitter Requirement of the Original, Rule 1002
public account that seems to be of Julissa Testimony to Prove content, Rule 1007
Duran. The document lists, “Most Notable Hearsay, Rule 801(d), 802
Post” with a unique web address. The Test for Relevance, Rule 401(a),(b)
bottom of the page shows a screen shot of
what appears to be an Instagram Post from
Julissa Duran’s account. Defendant
questioned authenticity. Defendant
requested inspection of original. Plaintiff
evaded/denied inspection of original
BATES labeled There are no dates listed in this document. It Jennifer Thibeaux’s name is not included in
DURAN 000019 appears to be a comment stream from the this document. There is no connection to
Instragram social media account of Julissa Jennifer Thibeaux. The document presented
Duran. There are numerous comments appears to be of Julissa Duran and between
between Julissa Duran and other users. The other social media users.
comments appear to be highly disparaging General Admissibility, Rule 402
in nature, however the subject of the Requirement of the Original, Rule 1002
comments is not spelled out in the Testimony to Prove content, Rule 1007
comments by any user. There are no dates Hearsay, Rule 801(d), 802
listed on this page. Defendant questioned Test for Relevance, Rule 401(a),(b)
authenticity. Defendant requested
inspection of original. Plaintiff
evaded/denied inspection of original
BATES labeled There are no dates listed in this document. It Jennifer Thibeaux’s name is not included in
DURAN 000020 appears to be a comment stream and this document. There is no connection to
perhaps a continuation of DURAN - 000019. Jennifer Thibeaux expressly stated. The
There are numerous comments between document presented appears to be of Julissa
Julissa Duran and user - caraolinedazio. The Duran and between other social media users.
comments appear to be highly disparaging General Admissibility, Rule 402
in nature, however the subject of the Requirement of the Original, Rule 1002
comments is not spelled out in the Testimony to Prove content, Rule 1007
comments by any user. There are no dates Hearsay, Rule 801(d), 802
listed on this page. Julissa Duran appears to Test for Relevance, Rule 401(a),(b)
claim that the target of her comments has a
severe mental disorder. . Defendant
questioned authenticity. Defendant
requested inspection of original. Plaintiff
evaded/denied inspection of original

Page 5 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document appears to be a report from None. This report is connected to an IP
DURAN 000021 the website, “whatismyipadaddress.com”. Address that is not connected to Jennifer
The document appears to be stating the Thibeaux. Whatismyipadaddress.com is not a
iPad address of the person who generated testifying expert or promulgated as an expert
the report. There is no date listed as to report.
when the report generated. Defendant General Admissibility, Rule 402
questioned authenticity. Defendant Requirement of the Original, Rule 1002
requested inspection of original. Plaintiff Testimony to Prove content, Rule 1007
evaded/denied inspection of original. Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

BATES labeled At the top of this image is a designation of This appears to be screen shot of a social
DURAN 000022 “Verizon” and a time of 1:41pm. There is a media post. There is no metadata to
date at the bottom of the page of November showcase the unique I.P. characteristics of
9, 2016. The image appears to be a woman the social media posting Plaintiff is alleging to
with short hair standing next to a sign be authentic. Lacks testimony to prove
“Overtown”. The commentary makes content.
references to a youth film festival. The origin General Admissibility, Rule 402
of this image and post is unknown. Requirement of the Original, Rule 1002
Defendant questioned authenticity. Testimony to Prove content, Rule 1007
Defendant requested inspection of original. Hearsay, Rule 801(d), 802
Plaintiff evaded/denied inspection of Test for Relevance, Rule 401(a),(b)
original. Testimony by Expert Witness, Rule 702

BATES labeled This document appears to be a copy of an There is no return address. There is no
DURAN 000023 envelope to Cotton Holdings, ATTN: Pete connection to Jennifer Thibeaux. Lacks
Bell. The postmark states North Houston. testimony to prove content.
The date of the postmark is November 12, General Admissibility, Rule 402
2016. Defendant questioned authenticity. Requirement of the Original, Rule 1002
Defendant requested inspection of original. Testimony to Prove content, Rule 1007
Plaintiff evaded/denied inspection of Hearsay, Rule 801(d), 802
original. Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 6 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled There is no date to the letter. Salutation is to There is no date on the document. The writer
DURAN 000024 Mr. Bell & Cotton Holdings. In summary the indicates a description of themselves and not
letter states that prospective client of a name – Katy, TX Native. There is no
Cotton Holdings was interested in doing connection to Jennifer Thibeaux being the
business with their company. They wanted author of this document. Lacks testimony to
to connect with General Manager Julissa prove content. Lacks chain of custody. Lacks
Duran on social media and found hate-filled custody of record information.
posts along with posts about Cotton Ranch. General Admissibility, Rule 402
The writer of the letter stated as a result of Requirement of the Original, Rule 1002
seeing those things they have elected to not Testimony to Prove content, Rule 1007
do business with Cotton Holdings. The letter Hearsay, Rule 801(d), 802
was signed, “Katy TX Native”. Defendant Test for Relevance, Rule 401(a),(b)
questioned authenticity. Defendant
requested inspection of original. Plaintiff
evaded/denied inspection of original.
BATES labeled This document appears to be a print out of Jennifer Thibeaux’s name does not appear in
DURAN 000025 Julissa Duran’s Instragram page. It displays 9 this document. There is no connection with
images. There is no date present in the Jennifer Thibeaux. There is no date on this
document. Defendant questioned document. There is no origin information.
authenticity. Defendant requested Lacks chain of custody. Lacks custody of
inspection of original. Plaintiff record information.
evaded/denied inspection of original. General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled This document appears to be a printout of a Jennifer Thibeaux’s name does not appear in
DURAN 000026 particular post from Julissa Duran’s this document. There is no connection with
Instagram page. There is no date anywhere Jennifer Thibeaux. There is no date on this
in the document. Defendant questioned document. There is no origin information.
authenticity. Defendant requested Lacks chain of custody. Lacks custody of
inspection of original. Plaintiff record information.
evaded/denied inspection of original. General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)

Page 7 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document appears to be a printout of a Jennifer Thibeaux’s name does not appear in
DURAN 000027 particular post from Julissa Duran’s this document. There is no connection with
Instagram page. There is no date anywhere Jennifer Thibeaux. There is no date on this
in the document. Defendant questioned document. There is no origin information.
authenticity. Defendant requested Lacks chain of custody. Lacks custody of
inspection of original. Plaintiff record information.
evaded/denied inspection of original. General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled This document appears to be a fax Patti The authenticity of this document is in
DURAN 000028 Parish-Kaminski, Company: Absolutely! Katy question as there is writing on the fax page.
Magazine, From Selena Gourlenia email: Did this writing come from the original fax or
sgourlenia@gmail.com – IP Address: was it altered after it was received? There is
12.237.164.219. There is physical writing on no indication as to the number of pages
the copy. There are highlights that appear contained within the fax to connect it with
on the document. The text claims Julissa certainty to the attachments. Jennifer
Duran committed prolonged cyber bullying, Thibeaux’s name does not appear in this
cyber following, and cyber taunting in 2016 document. There is no connection with
with attachments to follow. Defendant Jennifer Thibeaux. There is no date on this
questioned authenticity. Defendant document. There is no origin information.
requested inspection of original. Plaintiff Lacks chain of custody. Lacks custody of
evaded/denied inspection of original. record information.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled DUPLICATE – DURAN - 000018 DUPLICATE – DURAN - 000018
DURAN 000029
BATES labeled DUPLICATE – DURAN - 000019 DUPLICATE – DURAN - 000019
DURAN 000030
BATES labeled DUPLICATE – DURAN - 000020 DUPLICATE – DURAN - 000020
DURAN 000031
BATES labeled DUPLICATE – DURAN - 000022 DUPLICATE – DURAN - 000022
DURAN 000032
BATES labeled DUPLICATE – DURAN - 000021 DUPLICATE – DURAN - 000021
DURAN 000033

Page 8 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled A letter addressed in the salutation as “Dear There is no connection to Jennifer Thibeaux
DURAN 000034 Absolutely Katy”. There is no date. The in this document. There is no date to indicate
writer identifies themselves as “A when it occurred. There is no evidence of
Disappointed Loyal Reader”. In summary, transmission of this document. There is no
the letter states that the author was inspired testimony to authenticate this document.
by the magazine’s cover story on breast There is no expert testimony to authenticate
cancer. The author states they wanted to this document. There is no origin
follow Julissa Duran and found hate-filled information. Lacks chain of custody. Lacks
messages in her social media. The author custody of record information.
gives the Instragram and twitter addresses General Admissibility, Rule 402
of Julissa Duran and said they were Requirement of the Original, Rule 1002
disappointed in the magazine for choosing Testimony to Prove content, Rule 1007
Julissa Duran as a cover story. Defendant Hearsay, Rule 801(d), 802
questioned authenticity. Defendant Test for Relevance, Rule 401(a),(b)
requested inspection of original. Plaintiff
evaded/denied inspection of original.
BATES labeled This document appears to be an image of There is no connection Jennifer Thibeaux in
DURAN 000035 Julissa Duran’s Instragram post It is credited this document. There is no date on the
to the location: Bellagio, Las Vegas. On the document. There is no connection of this
image it appears to have a date stamp of document to DURAN 000034. Lacks
October 2016. In the image appears to be authenticity of this document being included
Julissa Duran and one other woman. as an attachment to DURAN 000034. Lacks
Defendant questioned authenticity. testimony to authenticate evidence.
Defendant requested inspection of original. General Admissibility, Rule 402
Plaintiff evaded/denied inspection of Requirement of the Original, Rule 1002
original. Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled DUPLICATE – DURAN - 000025 DUPLICATE – DURAN - 000025
DURAN 000036
BATES labeled DUPLICATE – DURAN - 000026 DUPLICATE – DURAN - 000025
DURAN 000037
BATES labeled DUPLICATE – DURAN - 000027 DUPLICATE – DURAN - 000025
DURAN 000038

Page 9 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document appears to be a statement The statements allege concern for harm, but
DURAN 000039 from Julissa Duran. The document is are not connected to the legal definition of
undated. The statement in the document defamation. Jennifer Thibeaux’s name is
alleges that Jennifer Thibeaux “pretended to mentioned repeatedly in this statement.
be a ‘Disappointed Loyal Reader’ of There is no date of this statement. There is
Absolutely Katy Magazine”. The author of no author of this statement. The authenticity
this document is unknown. The evidence is of this statement is in question. Lacks
not sworn testimony. The statement in this testimony to authenticate the statement.
document says that Jennifer Thibeaux General Admissibility, Rule 402
wished death upon her. The statement Requirement of the Original, Rule 1002
alleges that she called the police. Defendant Testimony to Prove content, Rule 1007
questioned authenticity. Defendant Hearsay, Rule 801(d), 802
requested inspection of original. Plaintiff Test for Relevance, Rule 401(a),(b)
evaded/denied inspection of original.
BATES labeled This document appears to be a continuation The statements allege concern for harm, but
DURAN 000040 from Julissa Duran from DURAN - 000039. are not connected to the legal definition of
Defendant questioned authenticity. defamation. Jennifer Thibeaux’s name is
Defendant requested inspection of original. mentioned repeatedly in this statement.
Plaintiff evaded/denied inspection of There is no date of this statement. There is
original. no author of this statement. The authenticity
of this statement is in question. Lacks
testimony to authenticate the statement.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled This document appears to be a phone log of The phone number displaying on this
DURAN 000041 Julissa Rucker Phone: 832-622-0374. Invoice document are not Jennifer Thibeaux’s phone
#, Account Number, and all but 3 calls are number. There is no connection with Jennifer
redacted. NOTE: the 3 calls that are showing Thibeaux and this document. The
are from the same number 650-293-7493. authenticity of this document is in question.
Defendant questioned authenticity. Lacks testimony to authenticate the
Defendant requested inspection of original. document.
Plaintiff evaded/denied inspection of General Admissibility, Rule 402
original. Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)

Page 10 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document appears to be an image of There is no mention of Jennifer Thibeaux in
DURAN 000042 Follow Requests presumably from a Social this document. No Jennifer Thibeaux social
Media account. There is only a time listed as media accounts are listed in the Follow
6:44am. Defendant questioned authenticity. Requests list. It is unknown what social media
Defendant requested inspection of original. account this image is connected to. There is
Plaintiff evaded/denied inspection of no date on this document. The authenticity of
original. this document is in question. Lacks testimony
to authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled This document appears to be an image of There is no mention of Jennifer Thibeaux in
DURAN 000043 Follow Requests presumably from a Social this document. No Jennifer Thibeaux social
Media account. There is only a time listed as media accounts are listed in the Follow
6:44am. Defendant questioned authenticity. Requests list. It is unknown what social media
Defendant requested inspection of original. account this image is connected to. There is
Plaintiff evaded/denied inspection of no date on this document. The authenticity of
original. this document is in question. Lacks testimony
to authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled This document appears to be an image from There is no mention of Jennifer Thibeaux in
DURAN 000044 the Cotton Ranch Events Instagram social this document. There is no connection to
media account. It is an image showing a Jennifer Thibeaux on any level. There is no
woman which appears to be Julissa Duran in date on this document. The authenticity of
a wedding dress by a tree. At the top of the this document is in question. Lacks testimony
document is a time stamp of 3:36pm. to authenticate the document.
Defendant questioned authenticity. General Admissibility, Rule 402
Defendant requested inspection of original. Requirement of the Original, Rule 1002
Plaintiff evaded/denied inspection of Testimony to Prove content, Rule 1007
original. Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)

Page 11 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This appears to be home page of the There is no connection to Jennifer Thibeaux
DURAN 000045 Instragram social media account in this document. There is writing on the
“proudkatylady”. On the top of the account document that adds Jennifer Thibeaux’s
is a time stamp which states 9:21pm. There name to the document. The document has
is writing on this page that states, “Jennifer been altered. There is no date on this
Thibeaux’s fake account”. At the bottom of document. Alarming that Julissa Duran feels
the page displays handwriting, this time she can recognize Jennifer Thibeaux’s
stating, “Jennifer Thibeaux’s nephew”. nephew from the back as an infant. There is
Defendant questioned authenticity. no legal authority to possess the image of the
Defendant requested inspection of original. minor. There is no date on this document.
Plaintiff evaded/denied inspection of The authenticity of this document is in
original. question. Lacks testimony to authenticate the
document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled This document showcases an image of a There is no date of this document. There is
DURAN 000046 baby. In the document there is writing no origin indicated of this document. The
pointing to the image alleging that the only connection to Jennifer Thibeaux is the
image is “Jennifer Thibeaux’s nephew” and writing on the page added. There is no
alleges “sure looks like the same image from metadata regarding the image. There is no
the fake account”. Defendant questioned legal authority to possess the image of the
authenticity. Defendant requested minor. There is no date on this document.
inspection of original. Plaintiff The authenticity of this document is in
evaded/denied inspection of original. question. Lacks testimony to authenticate the
document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)

Page 12 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This image appears to be a Citizens Info There are no names contained in this
DURAN 000047 Card. Case # HC160183426. The report was document of Jennifer Thibeaux. This
filed for “Telephone/Harass”. The Deputy document states, “Telephone/Harass” which
assigned was S. Lopez. Unit # 44E13. is not defamation. There is no date on this
Defendant questioned authenticity. document. The writing on this document is
Defendant requested inspection of original. not authenticated. The authenticity of this
Plaintiff evaded/denied inspection of document is in question. Lacks testimony to
original. authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the cover and There is no defamatory statement contained
DURAN 000048 first page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 13 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled The document appears to be the second and There is no defamatory statement contained
DURAN 000049 third page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the fourth and There is no defamatory statement contained
DURAN 000050 fifth page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 14 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled The document appears to be the sixth and There is no defamatory statement contained
DURAN 000051 seventh page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the eighth and There is no defamatory statement contained
DURAN 000052 ninth page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. . Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 15 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled The document appears to be the 10th and There is no defamatory statement contained
DURAN 000053 11th page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the 12th and There is no defamatory statement contained
DURAN 000054 13th page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. This document is the kindle called out in this book/page. There is no date
version of the book. There is however a to the anecdotal stories in this book/page.
highlight of one of the sentences in the book There are no names, cities, or descriptions of
along with writing. It appears the person persons added to the anecdotal stories in this
adding the handwriting to the page appears book/page. There is no date on this
to be speaking to the author Jennifer “drJ” document. The authenticity of this document
Thibeaux. The person who added the is in question. Lacks testimony to
handwriting is unknown. Defendant authenticate the document.
questioned authenticity. Defendant General Admissibility, Rule 402
requested inspection of original. Plaintiff Requirement of the Original, Rule 1002
evaded/denied inspection of original. Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 16 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled The document appears to be the 14th and This document contains writing added to the
DURAN 000055 15th page of the book “#Bully original work of Jennifer Thibeaux. The writer
#Woman2Woman” written by Jennifer “drJ” is unknown. The writer appears to be talking
Thibeaux. There is no date stamp of the to Jennifer Thibeaux or making commentary
document. This document is the kindle about the book. There is no defamatory
version of the book. There are two statement contained within this document
sentences highlighted on the 15th page. regarding Julissa Duran by the author of the
Additionally, there is handwriting on the book “#Bully #Woman2Woman”. Julissa
page. It appears the person adding the Duran is never called out in this book. There
handwriting to the page appears to be is no date to the anecdotal story. There are
speaking to the author Jennifer “drJ” no names, cities, or descriptions of persons
Thibeaux. The person who added the added to the anecdotal story. The
handwriting is unknown. The handwriting authenticity of this document is in question.
admits that they did what was in the Lacks testimony to authenticate the
anecdote of the book. Defendant document.
questioned authenticity. Defendant General Admissibility, Rule 402
requested inspection of original. Plaintiff Requirement of the Original, Rule 1002
evaded/denied inspection of original. Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 17 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled The document appears to be the 16th and This document contains writing added to the
DURAN 000056 17th page of the book “#Bully original work of Jennifer Thibeaux. The writer
#Woman2Woman” written by Jennifer “drJ” is unknown. The writer appears to be talking
Thibeaux. There is no date stamp of the to Jennifer Thibeaux or making commentary
document. There are four sentences about the book. There is no defamatory
highlighted on the 16th page. Additionally, statement contained within this document
there is handwriting all over the page. It regarding Julissa Duran by the author of the
appears the person adding the handwriting book “#Bully #Woman2Woman”. Julissa
to the page appears to be speaking to the Duran is never called out in this book. There
author Jennifer “drJ” Thibeaux. The person is no date to the anecdotal story. There are
who added the handwriting is unknown. The no names, cities, or descriptions of persons
writing states that the person did what was added to the anecdotal story. There is no
in the anecdote on some parts and defamatory statement contained within this
contended “lie” on other parts of the page. document regarding Julissa Duran by the
Additionally, the handwriting seemingly author of the book “#Bully
justifies the conduct admitted to in the #Woman2Woman”. Julissa Duran is never
handwriting (relating to the book’s called out in this book. There is no date to the
anecdote). Defendant questioned anecdotal story. There are no names, cities,
authenticity. Defendant requested or descriptions of persons added to the
inspection of original. Plaintiff anecdotal story. The authenticity of this
evaded/denied inspection of original. document is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 18 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled The document appears to be the 18th and There is no defamatory statement contained
DURAN 000057 19th page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
Defendant questioned authenticity. book/page. There is no date on this
Defendant requested inspection of original. document. The authenticity of this document
Plaintiff evaded/denied inspection of is in question. Lacks testimony to
original. authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the 20th and There is no defamatory statement contained
DURAN 000058 21st page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 19 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled The document appears to be the 22nd and This document contains writing added to the
DURAN 000059 23rd page of the book “#Bully original work of Jennifer Thibeaux. The writer
#Woman2Woman” written by Jennifer “drJ” of the handwriting is unknown. The writer
Thibeaux. There is no date stamp of the appears to be talking to Jennifer Thibeaux or
document. There are several sentences making commentary about the book. There is
highlighted on the 22nd and 23rd pages. no defamatory statement contained within
Additionally, there is handwriting all over this document regarding Julissa Duran by the
the page It appears the person adding the author of the book “#Bully
handwriting to the page appears to be #Woman2Woman”. Julissa Duran is never
speaking to the author Jennifer “drJ” called out in this book. There is no date to the
Thibeaux. The person who added the anecdotal story. There are no names, cities,
handwriting is unknown. The handwriting or descriptions of persons added to the
seems to share her own stories related to anecdotal story. There is no date on this
the content of the book, “#Bully document. The authenticity of this document
#Woman2Woman” by Jennifer Thibeaux. is in question. Lacks testimony to
Additionally, the person adding the authenticate the document.
handwriting alleges harassment. Defendant General Admissibility, Rule 402
questioned authenticity. Defendant Requirement of the Original, Rule 1002
requested inspection of original. Plaintiff Testimony to Prove content, Rule 1007
evaded/denied inspection of original. Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the 24th and This document contains writing added to the
DURAN 000060 25th page of the book “#Bully original work of Jennifer Thibeaux. The writer
#Woman2Woman” written by Jennifer “drJ” of the handwriting is unknown. The writer
Thibeaux. There is no date stamp of the appears to be talking to Jennifer Thibeaux or
document. There are several sentences making commentary about the book. There is
highlighted on the 24th and 25th pages. no defamatory statement contained within
Additionally, there is handwriting on the 25th this document regarding Julissa Duran by the
page stating “LIE”. It appears the person author of the book “#Bully
adding the handwriting to the page appears #Woman2Woman”. Julissa Duran is never
to be speaking to the author Jennifer “drJ” called out in this book. There is no date to the
Thibeaux. The person who added the anecdotal story. There are no names, cities,
handwriting is unknown. Defendant or descriptions of persons added to the
questioned authenticity. Defendant anecdotal story. There is no date on this
requested inspection of original. Plaintiff document. The authenticity of this document
evaded/denied inspection of original. is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 20 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled The document appears to be the 26th and This document contains highlights added to
DURAN 000061 27th page of the book “#Bully the original work of Jennifer Thibeaux. The
#Woman2Woman” written by Jennifer “drJ” writer of the highlights is unknown. There is
Thibeaux. There is no date stamp of the no defamatory statement contained within
document. There are several sentences this document regarding Julissa Duran by the
highlighted on the 27th page. Defendant author of the book “#Bully
questioned authenticity. Defendant #Woman2Woman”. Julissa Duran is never
requested inspection of original. Plaintiff called out in this book. There is no date to the
evaded/denied inspection of original. anecdotal story. There are no names, cities,
or descriptions of persons added to the
anecdotal story. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the 28th and This document contains writing added to the
DURAN 000062 29th page of the book “#Bully original work of Jennifer Thibeaux. The writer
#Woman2Woman” written by Jennifer “drJ” of the handwriting is unknown. The writer
Thibeaux. There is no date stamp of the appears to be talking to Jennifer Thibeaux or
document. There are several sentences making commentary about the book. There is
highlighted on the 28th and 29th pages. There no defamatory statement contained within
are two areas of handwriting added to this this document regarding Julissa Duran by the
document. It appears the person adding the author of the book “#Bully
handwriting to the page appears to be #Woman2Woman”. Julissa Duran is never
speaking to the author Jennifer “drJ” called out in this book. There is no date to the
Thibeaux. The person who added the anecdotal story. There are no names, cities,
handwriting is unknown. The handwriting or descriptions of persons added to the
seems to share the writer’s own stories anecdotal story. There is no date on this
related to the content of the book, “#Bully document. The authenticity of this document
#Woman2Woman” by Jennifer Thibeaux. is in question. Lacks testimony to
Additionally, the person adding the authenticate the document.
handwriting makes allegations about General Admissibility, Rule 402
Jennifer Thibeaux. Defendant questioned Requirement of the Original, Rule 1002
authenticity. Defendant requested Testimony to Prove content, Rule 1007
inspection of original. Plaintiff Hearsay, Rule 801(d), 802
evaded/denied inspection of original. Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 21 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled The document appears to be the 30th and This document contains writing added to the
DURAN 000063 31st page of the book “#Bully original work of Jennifer Thibeaux. The writer
#Woman2Woman” written by Jennifer “drJ” of the handwriting is unknown. The writer
Thibeaux. There is no date stamp of the appears to be talking to Jennifer Thibeaux or
document. There are several sentences making commentary about the book. There is
highlighted on the 30th and 31st pages. There no defamatory statement contained within
are three areas of handwriting added to this this document regarding Julissa Duran by the
document. It appears the person adding the author of the book “#Bully
handwriting to the page appears to be #Woman2Woman”. Julissa Duran is never
speaking to the author Jennifer “drJ” called out in this book. There is no date to the
Thibeaux. The person who added the anecdotal story. There are no names, cities,
handwriting is unknown. The handwriting or descriptions of persons added to the
seems to be speaking to or about Jennifer anecdotal story. There is no date on this
Thibeaux and shares the handwriter’s own document. The authenticity of this document
stories related to the content of the book, is in question. Lacks testimony to
“#Bully #Woman2Woman” by Jennifer authenticate the document.
Thibeaux. Additionally, the person adding General Admissibility, Rule 402
the handwriting makes allegations about Requirement of the Original, Rule 1002
Jennifer. Defendant questioned authenticity. Testimony to Prove content, Rule 1007
Defendant requested inspection of original. Hearsay, Rule 801(d), 802
Plaintiff evaded/denied inspection of Test for Relevance, Rule 401(a),(b)
original. Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the 32nd and There is no defamatory statement contained
DURAN 000064 33rd page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 22 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
th
BATES labeled The document appears to be the 34 and There is no defamatory statement contained
DURAN 000064 35th page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the 36th and There is no defamatory statement contained
DURAN 000065 37th page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 23 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
th
BATES labeled The document appears to be the 38 and There is no defamatory statement contained
DURAN 000066 39th page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. There are several sentences called out in this book/page. There is no date
highlighted on the 39th page. Defendant to the anecdotal stories in this book/page.
questioned authenticity. Defendant There are no names, cities, or descriptions of
requested inspection of original. Plaintiff persons added to the anecdotal stories in this
evaded/denied inspection of original. book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the 40th and This document contains highlights added to
DURAN 000067 41st page of the book “#Bully the original work of Jennifer Thibeaux. The
#Woman2Woman” written by Jennifer “drJ” writer of the highlights is unknown. There is
Thibeaux. There is no date stamp of the no defamatory statement contained within
document. There are several sentences this document regarding Julissa Duran by the
highlighted on the 40th and 41st pages. There author of the book “#Bully
are five areas of handwriting added to this #Woman2Woman”. Julissa Duran is never
document. It appears the person adding the called out in this book. There is no date to the
handwriting to the page appears to be anecdotal story. There are no names, cities,
speaking to the author Jennifer “drJ” or descriptions of persons added to the
Thibeaux. The person who added the anecdotal story. There is no date on this
handwriting is unknown. The handwriting document. The authenticity of this document
seems to share the writer’s own stories is in question. Lacks testimony to
related to the content of the book, “#Bully authenticate the document.
#Woman2Woman” by Jennifer Thibeaux. General Admissibility, Rule 402
Additionally, the person adding the Requirement of the Original, Rule 1002
handwriting makes allegations about Testimony to Prove content, Rule 1007
Jennifer Thibeaux. Defendant questioned Hearsay, Rule 801(d), 802
authenticity. Defendant requested Test for Relevance, Rule 401(a),(b)
inspection of original. Plaintiff Testimony by Expert Witness, Rule 702
evaded/denied inspection of original.

Page 24 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
nd
BATES labeled The document appears to be the 42 and This document contains writing added to the
DURAN 000068 43rd page of the book “#Bully original work of Jennifer Thibeaux. The writer
#Woman2Woman” written by Jennifer “drJ” of the handwriting is unknown. The writer
Thibeaux. There is no date stamp of the appears to be talking to Jennifer Thibeaux or
document. There are several sentences making commentary about the book. There is
highlighted on the 43rd page. There are five no defamatory statement contained within
areas of handwriting added to this this document regarding Julissa Duran by the
document. It appears the person adding the author of the book “#Bully
handwriting to the page appears to be #Woman2Woman”. Julissa Duran is never
speaking to the author Jennifer “drJ” called out in this book. There is no date to the
Thibeaux. The person who added the anecdotal story. There are no names, cities,
handwriting is unknown. The handwriting or descriptions of persons added to the
seems to share the writer’s own stories anecdotal story. There is no date on this
related to the content of the book, “#Bully document. The authenticity of this document
#Woman2Woman” by Jennifer Thibeaux. is in question. Lacks testimony to
Additionally, the person adding the authenticate the document.
handwriting makes allegations about General Admissibility, Rule 402
Jennifer Thibeaux. Defendant requested Requirement of the Original, Rule 1002
inspection of original. Plaintiff Testimony to Prove content, Rule 1007
evaded/denied inspection of original. Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the 44th and This document contains writing added to the
DURAN 000069 45th page of the book “#Bully original work of Jennifer Thibeaux. The writer
#Woman2Woman” written by Jennifer “drJ” of the handwriting is unknown. The writer
Thibeaux. There is no date stamp of the appears to be talking to Jennifer Thibeaux or
document. There is handwriting added to making commentary about the book. There is
the document which references Jennifer no defamatory statement contained within
Thibeaux. Defendant questioned this document regarding Julissa Duran by the
authenticity. Defendant requested author of the book “#Bully
inspection of original. Plaintiff #Woman2Woman”. Julissa Duran is never
evaded/denied inspection of original. called out in this book. There is no date to the
anecdotal story. There are no names, cities,
or descriptions of persons added to the
anecdotal story. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 25 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
th
BATES labeled The document appears to be the 46 and There is no defamatory statement contained
DURAN 000070 47th page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the 48nd and There is no defamatory statement contained
DURAN 000071 49th page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 26 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
th
BATES labeled The document appears to be the 50 and This document contains writing added to the
DURAN 000072 51st page of the book “#Bully original work of Jennifer Thibeaux. The writer
#Woman2Woman” written by Jennifer “drJ” of the handwriting is unknown. The writer
Thibeaux. There is no date stamp of the appears to be talking to Jennifer Thibeaux or
document. There are several sentences making commentary about the book. There is
highlighted on the 50th and 51st page. There no defamatory statement contained within
are large three areas of handwriting added this document regarding Julissa Duran by the
to this document. It appears the person author of the book “#Bully
adding the handwriting to the page appears #Woman2Woman”. Julissa Duran is never
to be speaking to the author Jennifer “drJ” called out in this book. There is no date to the
Thibeaux. The person who added the anecdotal story. There are no names, cities,
handwriting is unknown. The handwriting or descriptions of persons added to the
seems to share the writer’s own stories anecdotal story. There is no date on this
related to the content of the book, “#Bully document. The authenticity of this document
#Woman2Woman” by Jennifer Thibeaux. is in question. Lacks testimony to
Additionally, the person adding the authenticate the document.
handwriting makes allegations about General Admissibility, Rule 402
Jennifer Thibeaux. Defendant questioned Requirement of the Original, Rule 1002
authenticity. Defendant requested Testimony to Prove content, Rule 1007
inspection of original. Plaintiff Hearsay, Rule 801(d), 802
evaded/denied inspection of original. Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the 52nd and This document contains writing added to the
DURAN 000073 53rd page of the book “#Bully original work of Jennifer Thibeaux. The writer
#Woman2Woman” written by Jennifer “drJ” of the handwriting is unknown. The writer
Thibeaux. There is no date stamp of the appears to be talking to Jennifer Thibeaux or
document. There are several sentences making commentary about the book. There is
highlighted on the 52nd and 53rd page. There no defamatory statement contained within
is handwriting added to this document. It this document regarding Julissa Duran by the
appears the person adding the handwriting author of the book “#Bully
to the page appears to be speaking to the #Woman2Woman”. Julissa Duran is never
author Jennifer “drJ” Thibeaux. The person called out in this book. There is no date to the
who added the handwriting is unknown. The anecdotal story. There are no names, cities,
handwriting seems to share the writer’s own or descriptions of persons added to the
stories related to the content of the book, anecdotal story. There is no date on this
“#Bully #Woman2Woman” by Jennifer document. The authenticity of this document
Thibeaux. Additionally, the person adding is in question. Lacks testimony to
the handwriting makes allegations about authenticate the document.
Jennifer Thibeaux. Defendant questioned General Admissibility, Rule 402
authenticity. Defendant requested Requirement of the Original, Rule 1002
inspection of original. Plaintiff Testimony to Prove content, Rule 1007
evaded/denied inspection of original. Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 27 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
th
BATES labeled The document appears to be the 54 and None. It appears to be a true and correct
DURAN 000074 55th page of the book “#Bully copy of the Kindle version of the book by
#Woman2Woman” written by Jennifer “drJ” Jennifer Thibeaux. There is no defamatory
Thibeaux. There is no date stamp of the statement contained within this document
document. There are several sentences regarding Julissa Duran by the author of the
highlighted. There is handwriting added to book “#Bully #Woman2Woman”. Julissa
this document. It appears the person adding Duran is never called out in this book. There
the handwriting to the page appears to be is no date to the anecdotal story. There are
speaking to the author Jennifer “drJ” no names, cities, or descriptions of persons
Thibeaux. The person who added the added to the anecdotal story. There is no
handwriting is unknown. The handwriting date on this document. The authenticity of
seems to share the writer’s own stories this document is in question. Lacks testimony
related to the content of the book, “#Bully to authenticate the document.
#Woman2Woman” by Jennifer Thibeaux. General Admissibility, Rule 402
Additionally, the person adding the Requirement of the Original, Rule 1002
handwriting makes allegations about Testimony to Prove content, Rule 1007
Jennifer Thibeaux. Defendant questioned Hearsay, Rule 801(d), 802
authenticity. Defendant requested Test for Relevance, Rule 401(a),(b)
inspection of original. Plaintiff Testimony by Expert Witness, Rule 702
evaded/denied inspection of original.
BATES labeled The document appears to be the 56th and There is no defamatory statement contained
DURAN 000075 57th page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 28 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
th
BATES labeled The document appears to be the 58 and None. It appears to be a true and correct
DURAN 000076 59th page of the book “#Bully copy of the Kindle version of the book by
#Woman2Woman” written by Jennifer “drJ” Jennifer Thibeaux. There is no defamatory
Thibeaux. There is no date stamp of the statement contained within this document
document. There are a few sentences regarding Julissa Duran by the author of the
highlighted on the 58th page. There are book “#Bully #Woman2Woman”. Julissa
several sentences highlighted. There is Duran is never called out in this book. There
handwriting added to this document. It is no date to the anecdotal story. There are
appears the person adding the handwriting no names, cities, or descriptions of persons
to the page appears to be speaking to the added to the anecdotal story. There is no
author Jennifer “drJ” Thibeaux. The person date on this document. The authenticity of
who added the handwriting is unknown. The this document is in question. Lacks testimony
handwriting seems to share the writer’s own to authenticate the document.
stories related to the content of the book, General Admissibility, Rule 402
“#Bully #Woman2Woman” by Jennifer Requirement of the Original, Rule 1002
Thibeaux. Additionally, the person adding Testimony to Prove content, Rule 1007
the handwriting makes allegations about Hearsay, Rule 801(d), 802
Jennifer Thibeaux. Defendant questioned Test for Relevance, Rule 401(a),(b)
authenticity. Defendant requested Testimony by Expert Witness, Rule 702
inspection of original. Plaintiff
evaded/denied inspection of original.
BATES labeled The document appears to be the 60th and This document contains highlights added to
DURAN 000077 61st page of the book “#Bully the original work of Jennifer Thibeaux. The
#Woman2Woman” written by Jennifer “drJ” writer of the highlights is unknown. There is
Thibeaux. There is no date stamp of the no defamatory statement contained within
document. There are several sentences this document regarding Julissa Duran by the
highlighted on the 60th page. Defendant author of the book “#Bully
questioned authenticity. Defendant #Woman2Woman”. Julissa Duran is never
requested inspection of original. Plaintiff called out in this book. There is no date to the
evaded/denied inspection of original. anecdotal story. There are no names, cities,
or descriptions of persons added to the
anecdotal story. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 29 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
nd
BATES labeled The document appears to be the 62 and This document contains writing added to the
DURAN 000078 63rd page of the book “#Bully original work of Jennifer Thibeaux. The writer
#Woman2Woman” written by Jennifer “drJ” of the handwriting is unknown. The writer
Thibeaux. There is no date stamp of the appears to be talking to Jennifer Thibeaux or
document. There are several sentences making commentary about the book. There is
highlighted on the 50th and 51st page. There no defamatory statement contained within
are large three areas of handwriting added this document regarding Julissa Duran by the
to this document. It appears the person author of the book “#Bully
adding the handwriting to the page appears #Woman2Woman”. Julissa Duran is never
to be speaking to the author Jennifer “drJ” called out in this book. There is no date to the
Thibeaux. The person who added the anecdotal story. There are no names, cities,
handwriting is unknown. The handwriting or descriptions of persons added to the
seems to share the writer’s own stories anecdotal story. There is no date on this
related to the content of the book, “#Bully document. The authenticity of this document
#Woman2Woman” by Jennifer Thibeaux. is in question. Lacks testimony to
Additionally, the person adding the authenticate the document.
handwriting makes allegations about General Admissibility, Rule 402
Jennifer Thibeaux. Defendant questioned Requirement of the Original, Rule 1002
authenticity. Defendant requested Testimony to Prove content, Rule 1007
inspection of original. Plaintiff Hearsay, Rule 801(d), 802
evaded/denied inspection of original. Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the 64th and This document contains highlights added to
DURAN 000079 65th page of the book “#Bully the original work of Jennifer Thibeaux. The
#Woman2Woman” written by Jennifer “drJ” writer of the highlights is unknown. There is
Thibeaux. There is no date stamp of the no defamatory statement contained within
document. There are a few sentences this document regarding Julissa Duran by the
highlighted on the 64th and 65th page. There author of the book “#Bully
is no date stamp of the document. #Woman2Woman”. Julissa Duran is never
Defendant questioned authenticity. called out in this book. There is no date to the
Defendant requested inspection of original. anecdotal story. There are no names, cities,
Plaintiff evaded/denied inspection of or descriptions of persons added to the
original. anecdotal story. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 30 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
th
BATES labeled The document appears to be the 66 and This document contains highlights added to
DURAN 000080 67th page of the book “#Bully the original work of Jennifer Thibeaux. The
#Woman2Woman” written by Jennifer “drJ” writer of the highlights is unknown. There is
Thibeaux. There is no date stamp of the no defamatory statement contained within
document. There are a few sentences this document regarding Julissa Duran by the
highlighted on the 66th page. There is no author of the book “#Bully
date stamp of the document. Defendant #Woman2Woman”. Julissa Duran is never
questioned authenticity. Defendant called out in this book. There is no date to the
requested inspection of original. Plaintiff anecdotal story. There are no names, cities,
evaded/denied inspection of original. or descriptions of persons added to the
anecdotal story. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the 68th and This document contains highlights added to
DURAN 000081 69th page of the book “#Bully the original work of Jennifer Thibeaux. The
#Woman2Woman” written by Jennifer “drJ” writer of the highlights is unknown. There is
Thibeaux. There is no date stamp of the no defamatory statement contained within
document. There are a few sentences this document regarding Julissa Duran by the
highlighted on the 68th and 69th page. There author of the book “#Bully
is no date stamp of the document. #Woman2Woman”. Julissa Duran is never
Defendant questioned authenticity. called out in this book. There is no date to the
Defendant requested inspection of original. anecdotal story. There are no names, cities,
Plaintiff evaded/denied inspection of or descriptions of persons added to the
original. anecdotal story. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 31 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
th
BATES labeled The document appears to be the 70 and There is no defamatory statement contained
DURAN 000082 71st page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled The document appears to be the 72nd and There is no defamatory statement contained
DURAN 000083 73rd page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Defendant questioned called out in this book/page. There is no date
authenticity. Defendant requested to the anecdotal stories in this book/page.
inspection of original. Plaintiff There are no names, cities, or descriptions of
evaded/denied inspection of original. persons added to the anecdotal stories in this
book/page. There is no date on this
document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 32 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
th
BATES labeled The document appears to be the 74 and There is no defamatory statement contained
DURAN 000084 75th page of the book “#Bully within this document regarding Julissa Duran
#Woman2Woman” written by Jennifer “drJ” by the author of the book “#Bully
Thibeaux. There is no date stamp of the #Woman2Woman”. Julissa Duran is never
document. Several sentences in Jennifer called out in this book/page. There is no date
Thibeaux’s bio are highlighted on the 72nd to the anecdotal stories in this book/page.
page. Defendant questioned authenticity. There are no names, cities, or descriptions of
Defendant requested inspection of original. persons added to the anecdotal stories in this
Plaintiff evaded/denied inspection of book/page. There is no date on this
original. document. The authenticity of this document
is in question. Lacks testimony to
authenticate the document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled This document appears to be a screen shot This document appears to originate from
DURAN 000085 or image of Julissa Duran’s own Twitter Julissa Duran. There is no mention or
social media page. There is no date on the connection to Jennifer Thibeaux. .
account other than Julissa Duran’s Date of Additionally, there is no connection to
Birth: September 19, 1969. There appears to defamatory behavior or statements from
be a post showing 02/18/17 at the bottom Jennifer Thibeaux to or about Julissa Duran.
of the page. Defendant questioned There is no date on this document. There is
authenticity. Defendant requested no metadata to support the image or web
inspection of original. Plaintiff page. The authenticity of this document is in
evaded/denied inspection of original. question. Lacks testimony to authenticate the
document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 33 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document appears to be a screen shot This document appears to originate from
DURAN 000086 or image of Julissa Duran’s own Twitter Julissa Duran. There is no mention or
social media page. There is no date on the connection to Jennifer Thibeaux. .
account other than Julissa Duran’s Date of Additionally, there is no connection to
Birth: September 19, 1969. There appears to defamatory behavior or statements from
be a post showing 02/18/17 at the bottom Jennifer Thibeaux to or about Julissa Duran.
of the page. Defendant questioned There is no date on this document. There is
authenticity. Defendant requested no metadata to support the image or web
inspection of original. Plaintiff page. The authenticity of this document is in
evaded/denied inspection of original. question. Lacks testimony to authenticate the
document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled This document appears to be a screen shot There is no mention or connection to Jennifer
DURAN 000087 of a conversation between Twitter and Thibeaux. There is no date on the document
Julissa Rucker. In this document, Twitter to authenticate it. . Additionally, there is no
explains to Julissa Rucker that they do not connection to defamatory behavior or
release information about Twitter users statements from Jennifer Thibeaux to or
except during a valid legal process. There is about Julissa Duran. There is no date on this
no date on the document. Defendant document. There is no metadata to support
questioned authenticity. Defendant the image or web page or email. The
requested inspection of original. Plaintiff authenticity of this document is in question.
evaded/denied inspection of original. Lacks testimony to authenticate the
document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 34 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document appears to be a printout There is no mention or connection to Jennifer
DURAN 000088 from Julissa Duran of an email exchange Thibeaux. . Additionally, there is no
between her and Cris Dishman. The date of connection to defamatory behavior or
the document is March 24, 2017 at statements from Jennifer Thibeaux to or
10:50am. The message is from Cris Dishman about Julissa Duran. There is no metadata to
to Julissa Duran. Defendant questioned support the image or web page or email. The
authenticity. Defendant requested authenticity of this document is in question.
inspection of original. Plaintiff Lacks testimony to authenticate the
evaded/denied inspection of original. document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled This document appears to be a printout There is no mention or connection to Jennifer
DURAN 000089 from Julissa Duran of an email exchange Thibeaux. . Additionally, there is no
between her and Cris Dishman. The date of connection to defamatory behavior or
the document is March 24, 2017 at statements from Jennifer Thibeaux to or
10:54am. Defendant questioned about Julissa Duran. There is no metadata to
authenticity. Defendant requested support the image or web page or email. The
inspection of original. Plaintiff authenticity of this document is in question.
evaded/denied inspection of original. Lacks testimony to authenticate the
document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled This document appears to be a printout There is no mention or connection to Jennifer
DURAN 000090 from Julissa Duran of an email exchange Thibeaux. . Additionally, there is no
between her and Cris Dishman. The date of connection to defamatory behavior or
the document is March 31, 2017 at 6:32am. statements from Jennifer Thibeaux to or
Defendant questioned authenticity. about Julissa Duran. There is no metadata to
Defendant requested inspection of original. support the image or web page or email. The
Plaintiff evaded/denied inspection of authenticity of this document is in question.
original. Lacks testimony to authenticate the
document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
Page 35 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document appears to be a highly There is no mention or connection to Jennifer
DURAN 000091 redacted telephone statement of Julissa D. Thibeaux. . Additionally, there is no
Rucker (832-622-0374). Date of the connection to defamatory behavior or
statement is unknown. Bill Cycle is 03/19/17 statements from Jennifer Thibeaux to or
– 04/18/17. There appears to be a highlight, about Julissa Duran. There is no metadata to
however the document is ILLEGIBLE. support the image or web page or email. The
Defendant questioned authenticity. authenticity of this document is in question.
Defendant requested inspection of original. Lacks testimony to authenticate the
Plaintiff evaded/denied inspection of document.
original. General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled This document appears to be a Cease and This document appears to have originated
DURAN 000092 Desist Demand Letter sent from Cris from Cris Dishman to Julissa Duran. There is
Dishman to Luis Acevedo as the attorney for no connection to defamatory behavior from
Julissa Duran on July 11, 2017. In this Jennifer Thibeaux to or about Julissa Duran.
document Cris Dishman demands Julissa There is no metadata to support the image or
Duran immediately discontinue all contact web page or email. The authenticity of this
with him. Jennifer Thibeaux’s name is document is in question. Lacks testimony to
mentioned in the document as Cris Dishman authenticate the document.
was demanding Julissa Duran cease contact General Admissibility, Rule 402
with them both. Defendant questioned Requirement of the Original, Rule 1002
authenticity. Defendant requested Testimony to Prove content, Rule 1007
inspection of original. Plaintiff Hearsay, Rule 801(d), 802
evaded/denied inspection of original. Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled This document appears to be a screen shot There is no mention or connection to Jennifer
DURAN 000093 of an email from Julissa Duran to Cris Thibeaux. . Additionally, there is no
Dishman. There is a time stamp on the connection to defamatory behavior or
document of 9:24am, but no date stamp. statements from Jennifer Thibeaux to or
Defendant questioned authenticity. about Julissa Duran. There is no metadata to
Defendant requested inspection of original. support the image or web page or email. The
Plaintiff evaded/denied inspection of authenticity of this document is in question.
original. Lacks testimony to authenticate the
document.
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 36 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document appears to be a social media There is no mention or connection to Jennifer
DURAN 000094 account that shows an image of Julissa Thibeaux other than the handwriting alleging
Duran at the top of the image. It is time a “Jennifer Thibeaux fake account”. There is
stamped as 10:17am. There is no date no proof or connection as to why the Plaintiff
stamp. It showcases a title of “Notifications” feels Jennifer Thibeaux is connected.
at the top. It showcases 3 social media Additionally, there is no connection to
accounts that appear to be Twitter that liked defamatory behavior or statements from
tweets that originated by Julissa Duran. Jennifer Thibeaux to or about Julissa Duran.
There are highlights and writing added to There is no metadata to support the image or
the document. It is unknown the identity of web page or email. The authenticity of this
the person who added the handwriting. document is in question. Lacks testimony to
Jennifer Thibeaux’s name is on this authenticate the document.
document as the author of the handwriting General Admissibility, Rule 402
wrote, “Jennifer Thibeaux fake account”. Requirement of the Original, Rule 1002
The highlights are on the words, “Missus Testimony to Prove content, Rule 1007
Dishman liked your tweet”. Defendant Hearsay, Rule 801(d), 802
questioned authenticity. Defendant Test for Relevance, Rule 401(a),(b)
requested inspection of original. Plaintiff Testimony by Expert Witness, Rule 702
evaded/denied inspection of original.
BATES labeled This document shows an image of Julissa There is no mention or connection to Jennifer
DURAN 000095 Duran at the top of the image. It is time Thibeaux . Additionally, there is no
stamped as 10:42pm. There is no date connection to defamatory behavior or
stamp. The image appears to be of Julissa statements from Jennifer Thibeaux to or
Duran and another person. This image about Julissa Duran. There is no metadata to
appears to be taken from Twitter. support the image or web page or email. The
Defendant questioned authenticity. authenticity of this document is in question.
Defendant requested inspection of original. Lacks testimony to authenticate the
Plaintiff evaded/denied inspection of document.
original. General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 37 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document is time stamped on 4:55pm. There is no mention or connection to Jennifer
DURAN 000096 There is no date stamp. The document Thibeaux other than the handwriting alleging
appears to originate from twimagepro.com. a “Jennifer Thibeaux fake account”. There is
There is a large image of a heart with the no proof or connection as to why the Plaintiff
text “Mrs. Dishman 2017”. There is feels Jennifer Thibeaux is connected.
handwriting on the document which states, Additionally, there is no connection to
“Jennifer Thibeaux Fake account”. There are defamatory behavior or statements from
words that appear to be a user account Jennifer Thibeaux to or about Julissa Duran.
“Missus Dishman @MissusDishman). Julissa There is no metadata to support the image or
Duran’s name does not appear in this web page or email. The authenticity of this
document. Defendant questioned document is in question. Lacks testimony to
authenticity. Defendant requested authenticate the document.
inspection of original. Plaintiff General Admissibility, Rule 402
evaded/denied inspection of original. Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled This document is time stamped at 10:20am. There is no mention or connection to Jennifer
DURAN 000097 There is no date stamp on the document Thibeaux . Additionally, there is no
however there is a date of 07/03/17 on one connection to defamatory behavior or
of the posts. The posts come from Missus statements from Jennifer Thibeaux to or
Dishman. Julissa Duran’s name is not about Julissa Duran. There is no metadata to
contained anywhere in this document. support the image or web page or email. The
Jennifer Thibeaux’s name is not contained authenticity of this document is in question.
anywhere in this document. Defendant Lacks testimony to authenticate the
questioned authenticity. Defendant document.
requested inspection of original. Plaintiff General Admissibility, Rule 402
evaded/denied inspection of original. Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702

Page 38 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document is time stamped at 4:54pm. There is no mention or connection to Jennifer
DURAN 000098 There is no date stamp on the document. Thibeaux . Additionally, there is no
There are three posts showing in this connection to defamatory behavior or
document. The 2nd post is highlighted. The statements from Jennifer Thibeaux to or
posts come from Missus Dishman. Julissa about Julissa Duran. There is no metadata to
Duran’s name is not contained anywhere in support the image or web page or email. The
this document. Jennifer Thibeaux’s name is authenticity of this document is in question.
not contained anywhere in this document. Lacks testimony to authenticate the
Defendant questioned authenticity. document.
Defendant requested inspection of original. General Admissibility, Rule 402
Plaintiff evaded/denied inspection of Requirement of the Original, Rule 1002
original. Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled This appears to be a duplicate image of There is no mention or connection to Jennifer
DURAN 000099 DURAN - 000096 with the exception there is Thibeaux . Additionally, there is no
no handwriting on the page. Julissa Duran’s connection to defamatory behavior or
name is not contained anywhere in this statements from Jennifer Thibeaux to or
document. Jennifer Thibeaux’s name is not about Julissa Duran. There is no metadata to
contained anywhere in this document. support the image or web page or email. The
Defendant questioned authenticity. authenticity of this document is in question.
Defendant requested inspection of original. Lacks testimony to authenticate the
Plaintiff evaded/denied inspection of document.
original. General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled This document is time stamped at 10:32pm. There is no mention or connection to Jennifer
DURAN 000100 The document appears to originate from Thibeaux . Additionally, there is no
twimagepro.com. There is no date stamp on connection to defamatory behavior or
the document. There are two posts showing statements from Jennifer Thibeaux to or
in this document. The posts come from about Julissa Duran. There is no metadata to
Missus Dishman. Julissa Duran’s name is not support the image or web page or email. The
contained anywhere in this document. authenticity of this document is in question.
Jennifer Thibeaux’s name is not contained Lacks testimony to authenticate the
anywhere in this document. Defendant document.
questioned authenticity. Defendant General Admissibility, Rule 402
requested inspection of original. Plaintiff Requirement of the Original, Rule 1002
evaded/denied inspection of original. Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
Page 39 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document is time stamped at 10:32pm. There is no mention or connection to Jennifer
DURAN 000101 The document appears to originate from Thibeaux . Additionally, there is no
twimagepro.com. There is no date stamp on connection to defamatory behavior or
the document. There are two posts showing statements from Jennifer Thibeaux to or
in this document. The posts come from about Julissa Duran. There is no metadata to
Missus Dishman. Julissa Duran’s name is not support the image or web page or email. The
contained anywhere in this document. authenticity of this document is in question.
Jennifer Thibeaux’s name is not contained Lacks testimony to authenticate the
anywhere in this document. Defendant document.
questioned authenticity. Defendant General Admissibility, Rule 402
requested inspection of original. Plaintiff Requirement of the Original, Rule 1002
evaded/denied inspection of original. Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled This document is time stamped at 10:32pm. There is no mention or connection to Jennifer
DURAN 000102 The document appears to originate from Thibeaux . Additionally, there is no
twimagepro.com. There is no date stamp on connection to defamatory behavior or
the document. There are three posts statements from Jennifer Thibeaux to or
showing in this document. The posts come about Julissa Duran. There is no metadata to
from Missus Dishman. Julissa Duran’s name support the image or web page or email. The
is not contained anywhere in this document. authenticity of this document is in question.
Jennifer Thibeaux’s name is not contained Lacks testimony to authenticate the
anywhere in this document. Defendant document.
questioned authenticity. Defendant General Admissibility, Rule 402
requested inspection of original. Plaintiff Requirement of the Original, Rule 1002
evaded/denied inspection of original. Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled This document is time stamped at 10:33pm. There is no mention or connection to Jennifer
DURAN 000103 The document appears to originate from Thibeaux . Additionally, there is no
twimagepro.com. There is no date stamp on connection to defamatory behavior or
the document. There are two posts showing statements from Jennifer Thibeaux to or
in this document. The posts come from about Julissa Duran. There is no metadata to
Missus Dishman. Julissa Duran’s name is not support the image or web page or email. The
contained anywhere in this document. authenticity of this document is in question.
Jennifer Thibeaux’s name is not contained Lacks testimony to authenticate the
anywhere in this document. Defendant document.
questioned authenticity. Defendant General Admissibility, Rule 402
requested inspection of original. Plaintiff Requirement of the Original, Rule 1002
evaded/denied inspection of original. Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
Page 40 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document is time stamped at 10:33pm. There is no mention or connection to Jennifer
DURAN 000104 The document appears to originate from Thibeaux . Additionally, there is no
twimagepro.com. There is no date stamp on connection to defamatory behavior or
the document. There are three posts statements from Jennifer Thibeaux to or
showing in this document. The posts come about Julissa Duran. There is no metadata to
from Missus Dishman. Julissa Duran’s name support the image or web page or email. The
is not contained anywhere in this document. authenticity of this document is in question.
Jennifer Thibeaux’s name is not contained Lacks testimony to authenticate the
anywhere in this document. Defendant document.
questioned authenticity. Defendant General Admissibility, Rule 402
requested inspection of original. Plaintiff Requirement of the Original, Rule 1002
evaded/denied inspection of original. Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled This document is time stamped at 10:33pm. There is no mention or connection to Jennifer
DURAN 000105 The document appears to originate from Thibeaux . Additionally, there is no
twimagepro.com. There is no date stamp on connection to defamatory behavior or
the document. There are three posts statements from Jennifer Thibeaux to or
showing in this document. The posts come about Julissa Duran. There is no metadata to
from Missus Dishman. Julissa Duran’s name support the image or web page or email. The
is not contained anywhere in this document. authenticity of this document is in question.
Jennifer Thibeaux’s name is not contained Lacks testimony to authenticate the
anywhere in this document. Defendant document.
questioned authenticity. Defendant General Admissibility, Rule 402
requested inspection of original. Plaintiff Requirement of the Original, Rule 1002
evaded/denied inspection of original. Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled This document is time stamped at 10:33pm. There is no mention or connection to Jennifer
DURAN 000106 The document appears to originate from Thibeaux . Additionally, there is no
twimagepro.com. There is no date stamp on connection to defamatory behavior or
the document. There are two posts showing statements from Jennifer Thibeaux to or
in this document. The posts come from about Julissa Duran. There is no metadata to
Missus Dishman. Julissa Duran’s name is not support the image or web page or email. The
contained anywhere in this document. authenticity of this document is in question.
Jennifer Thibeaux’s name is not contained Lacks testimony to authenticate the
anywhere in this document. Defendant document.
questioned authenticity. Defendant General Admissibility, Rule 402
requested inspection of original. Plaintiff Requirement of the Original, Rule 1002
evaded/denied inspection of original. Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
Page 41 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document is time stamped at 4:54pm. There is no mention or connection to Jennifer
DURAN 000107 The document appears to originate from Thibeaux . Additionally, there is no
twimagepro.com. There is no date stamp on connection to defamatory behavior or
the document. There are two posts showing statements from Jennifer Thibeaux to or
in this document. The posts come from about Julissa Duran. There is no metadata to
Missus Dishman. There is handwriting on support the image or web page or email. The
the post stating, “Jennifer Thibeaux is very authenticity of this document is in question.
unstable”. The author of the writing is Lacks testimony to authenticate the
unknown. Julissa Duran’s name is not document.
contained anywhere in this document. General Admissibility, Rule 402
Defendant questioned authenticity. Requirement of the Original, Rule 1002
Defendant requested inspection of original. Testimony to Prove content, Rule 1007
Plaintiff evaded/denied inspection of Hearsay, Rule 801(d), 802
original. Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
BATES labeled This document is time stamped at 4:55pm. There is no mention or connection to Jennifer
DURAN 000108 The document appears to originate from Thibeaux . Additionally, there is no
twimagepro.com. There is no date stamp on connection to defamatory behavior or
the document. There are three posts statements from Jennifer Thibeaux to or
showing in this document. The posts come about Julissa Duran. There is no metadata to
from Missus Dishman. There is handwriting support the image or web page or email. The
on the post stating, “Sane women do not do authenticity of this document is in question.
this period”. There are arrows pointing to Lacks testimony to authenticate the
each of the 3 posts on the page. The author document.
of the handwriting is unknown. Julissa General Admissibility, Rule 402
Duran’s name is not contained anywhere in Requirement of the Original, Rule 1002
this document. Defendant questioned Testimony to Prove content, Rule 1007
authenticity. Defendant requested Hearsay, Rule 801(d), 802
inspection of original. Plaintiff Test for Relevance, Rule 401(a),(b)
evaded/denied inspection of original. Testimony by Expert Witness, Rule 702
BATES labeled This document is time stamped at 4:55pm. There is no mention or connection to Jennifer
DURAN 000109 The document appears to originate from Thibeaux . Additionally, there is no
twimagepro.com. There is no date stamp on connection to defamatory behavior or
the document. There are two posts showing statements from Jennifer Thibeaux to or
in this document. The posts come from about Julissa Duran. There is no metadata to
Missus Dishman. There is one post support the image or web page or email. The
highlighted. Julissa Duran’s name is not authenticity of this document is in question.
contained anywhere in this document. Lacks testimony to authenticate the
Jennifer Thibeaux’s name is not contained document.
anywhere in this document. Defendant General Admissibility, Rule 402
questioned authenticity. Defendant Requirement of the Original, Rule 1002
requested inspection of original. Plaintiff Testimony to Prove content, Rule 1007
evaded/denied inspection of original. Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
Testimony by Expert Witness, Rule 702
Page 42 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document is time stamped at 10:42pm. There is no mention or connection to Jennifer
DURAN 000110 There is no date stamped on this document. Thibeaux other than what was handwritten
This document shows what looks like a on the document. Additionally, there is no
screen capture taken from Julissa Duran’s connection to defamatory behavior or
Instagram account. At the top of the statements from Jennifer Thibeaux to or
document it shows “sosososohappyy”. about Julissa Duran. There is no metadata to
There is an image showing an unidentified support the image or web page or email. The
woman. The name “Missus Dishman” authenticity of this document is in question.
appears under the image. The location Lacks testimony to authenticate the
Houston, TX displays underneath. The document.
account is private. There is writing on the General Admissibility, Rule 402
paper stating, “Jennifer Thibeaux” with an Requirement of the Original, Rule 1002
arrow to the image. There is a date Testimony to Prove content, Rule 1007
handwritten on the page July 12, 2017. Hearsay, Rule 801(d), 802
Julissa Duran’s name is not contained Test for Relevance, Rule 401(a),(b)
anywhere in this document. Defendant Testimony by Expert Witness, Rule 702
questioned authenticity. Defendant
requested inspection of original. Plaintiff
evaded/denied inspection of original.
BATES labeled This document is time stamped at 4:26pm. There is no mention or connection to Jennifer
DURAN 000111 There is no date stamped on this document. Thibeaux other than what was handwritten
This document shows what looks like a on the document. Additionally, there is no
screen capture taken from Cotton Ranch’s connection to defamatory behavior or
Instagram account. At the top of the statements from Jennifer Thibeaux to or
document it shows “sosososohappyy”. about Julissa Duran. There is no metadata to
There is an image showing a heart with what support the image or web page or email. The
appears to say Mrs. Dishman on the inside. authenticity of this document is in question.
The name states “Mrs. Dishman” appears Lacks testimony to authenticate the
under the image. Displayed underneath it document.
states, “it’s official” with an image of a ring General Admissibility, Rule 402
and a baby. The account is private. There is Requirement of the Original, Rule 1002
writing on the paper stating, “Jennifer Testimony to Prove content, Rule 1007
changed picture” with an arrow to the Hearsay, Rule 801(d), 802
image. There is additional handwriting Test for Relevance, Rule 401(a),(b)
stating, “the one on Twitter”. There is a date Testimony by Expert Witness, Rule 702
handwritten on the page July 12, 2017. The
author of the handwriting is unknown.
Julissa Duran’s name is not contained
anywhere in this document. Defendant
questioned authenticity. Defendant
requested inspection of original. Plaintiff
evaded/denied inspection of original.
BATES labeled DUPLICATE – DURAN - 000017 DUPLICATE – DURAN - 000017
DURAN 000112

Page 43 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled DUPLICATE – DURAN - 000018 DUPLICATE – DURAN - 000018
DURAN 000113
BATES labeled DUPLICATE – DURAN - 000019 DUPLICATE – DURAN - 000019
DURAN 000114
BATES labeled DUPLICATE – DURAN - 000021 DUPLICATE – DURAN - 000021
DURAN 000115
BATES labeled DUPLICATE – DURAN - 000022 DUPLICATE – DURAN - 000022
DURAN 000116
BATES labeled This document appears to be a This is a first and third person statement. The
DURAN 000117 statement/journal entry/diary entry author of the statement is unknown. The
presumably made by Julissa Duran about statement is unsigned, unsworn, and lacks
Jennifer Thibeaux. There is no date or time identity. There is no metadata to support the
stamp on the document. The document image or web page or email. The authenticity
alleges activity committed by Julissa Duran of this document is in question. Lacks
toward Jennifer Thibeaux. The document testimony to authenticate the document.
appears to be a summary of events Plaintiff General Admissibility, Rule 402
alleges happened to her related to her Requirement of the Original, Rule 1002
feeling of being stalked by Jennifer Testimony to Prove content, Rule 1007
Thibeaux. Defendant questioned Hearsay, Rule 801(d), 802
authenticity. Defendant requested Test for Relevance, Rule 401(a),(b)
inspection of original. Plaintiff Testimony by Expert Witness, Rule 702
evaded/denied inspection of original.
BATES labeled This document appears to be a This is a first and third person statement. The
DURAN 000118 statement/journal entry/diary entry author of the statement is unknown. The
presumably made by Julissa Duran about statement is unsigned, unsworn, and lacks
Jennifer Thibeaux. There is no date or time identity. There is no metadata to support the
stamp on the document. The document image or web page or email. The authenticity
alleges activity committed by Julissa Duran of this document is in question. Lacks
toward Jennifer Thibeaux. The document testimony to authenticate the document.
appears to be a summary of events Plaintiff General Admissibility, Rule 402
alleges happened to her related to her Requirement of the Original, Rule 1002
feeling of being stalked by Jennifer Testimony to Prove content, Rule 1007
Thibeaux. Defendant questioned Hearsay, Rule 801(d), 802
authenticity. Defendant requested Test for Relevance, Rule 401(a),(b)
inspection of original. Plaintiff Testimony by Expert Witness, Rule 702
evaded/denied inspection of original.
BATES labeled DUPLICATE – DURAN - 000023 DUPLICATE – DURAN - 000023
DURAN 000119
BATES labeled DUPLICATE – DURAN - 000024 DUPLICATE – DURAN - 000024
DURAN 000120
BATES labeled DUPLICATE – DURAN - 000025 DUPLICATE – DURAN - 000025
DURAN 000121
BATES labeled DUPLICATE – DURAN - 000026 DUPLICATE – DURAN - 000026
DURAN 000122

Page 44 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled DUPLICATE – DURAN - 000027 DUPLICATE – DURAN - 000027
DURAN 000123
BATES labeled There is no date or time stamp on this This is a first and third person statement. The
DURAN 000124 document. This document appears to be a author of the statement is unknown. The
statement/journal entry/diary entry statement is unsigned, unsworn, and lacks
presumably made by Julissa Duran about identity. There is no metadata to support the
Jennifer Thibeaux. There is no date or time image or web page or email. The authenticity
stamp on the document. Plaintiff alleges a of this document is in question. Lacks
connection between the letters sent about testimony to authenticate the document.
her as coning from Jennifer Thibeaux but General Admissibility, Rule 402
does not point to evidence that Requirement of the Original, Rule 1002
corroborates those allegations. Defendant Testimony to Prove content, Rule 1007
questioned authenticity. Defendant Hearsay, Rule 801(d), 802
requested inspection of original. Plaintiff Test for Relevance, Rule 401(a),(b)
evaded/denied inspection of original. Testimony by Expert Witness, Rule 702
BATES labeled DUPLICATE – DURAN - 000034 DUPLICATE – DURAN - 000034
DURAN 000125
BATES labeled DUPLICATE – DURAN - 000035 DUPLICATE – DURAN - 000035
DURAN 000126
BATES labeled DUPLICATE – DURAN - 000025 DUPLICATE – DURAN - 000025
DURAN 000127
BATES labeled DUPLICATE – DURAN - 000026 DUPLICATE – DURAN - 000026
DURAN 000128
BATES labeled DUPLICATE – DURAN - 000027 DUPLICATE – DURAN - 000027
DURAN 000129
BATES labeled DUPLICATE – DURAN - 000028 DUPLICATE – DURAN - 000028
DURAN 000130
BATES labeled DUPLICATE – DURAN - 000018 DUPLICATE – DURAN - 000018
DURAN 000131
BATES labeled DUPLICATE – DURAN - 000027 DUPLICATE – DURAN - 000027
DURAN 000132
BATES labeled DUPLICATE – DURAN - 000020 DUPLICATE – DURAN - 000020
DURAN 000133
BATES labeled DUPLICATE – DURAN - 000022 DUPLICATE – DURAN - 000022
DURAN 000134
BATES labeled DUPLICATE – DURAN - 000021 DUPLICATE – DURAN - 000021
DURAN 000135
BATES labeled DUPLICATE – DURAN - 000034 DUPLICATE – DURAN - 000034
DURAN 000136
BATES labeled DUPLICATE – DURAN - 000035 DUPLICATE – DURAN - 000035
DURAN 000137
BATES labeled DUPLICATE – DURAN - 000025 DUPLICATE – DURAN - 000025
DURAN 000138

Page 45 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled DUPLICATE – DURAN - 000026 DUPLICATE – DURAN - 000026
DURAN 000139
BATES labeled DUPLICATE – DURAN - 000027 DUPLICATE – DURAN - 000027
DURAN 000140
BATES labeled DUPLICATE – DURAN - 000039 DUPLICATE – DURAN - 000039
DURAN 000141
BATES labeled DUPLICATE – DURAN - 000040 DUPLICATE – DURAN - 000040
DURAN 000142
BATES labeled Fax to Luis Acevedo from Jennifer Thibeaux. Plaintiff failed to produce this document
DURAN 000143 Fax # 713-777-7326. Phone # 713-777-7332. during the Discovery period despite
Subject, “RE: Thibeaux Response to Acevedo Defendant’s numerous requests to Plaintiff
C&D”. Pages, “10”. CC, “Cris Dishman” This and 2 expired Request For Production served
is the Fax Cover page. Dated November 21, on Plaintiff with plenty of time to respond
2016. Checked, “For Review”. Added text, within the Rules and within the discovery
“See attached”. Noticeably missing is the Fax period.
Transmission metadata on the page if this is
in fact a fax transmission. Objection:
Plaintiff Failed to adhere to
Supplementation/Amendments of Discovery
Responses, T.R.C.P. 193.5(b); AND
Mandatory Exclusion of Evidence in
accordance with T.R.C.P. 193.6(a)

Additionally:
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)

Page 46 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled Letter to Luis Acevedo from Jennifer Plaintiff failed to produce this document
DURAN 000144 Thibeaux dated November 21, 2016. “RE: during the Discovery period despite
THIBEAUX RESPONSE TO ACEVEDO Defendant’s numerous requests to Plaintiff
NOVEMBER 8, 2016 CEASE AND DESIST and 2 expired Request For Production served
LETTER”. Noticeably missing is the Fax on Plaintiff with plenty of time to respond
Transmission metadata on the page. In this within the Rules and within the discovery
document Defendant alleges the Plaintiff period.
has been harassing the Defendant.
Defendant Jennifer Thibeaux describes the Objection:
precautions she took to block the Plaintiff in Plaintiff Failed to adhere to
June 2016 from all social media accounts. Supplementation/Amendments of Discovery
Thibeaux describes the harassing behavior Responses, T.R.C.P. 193.5(b); AND
experienced as a result of Plaintiff Duran’s Mandatory Exclusion of Evidence in
actions. Noticeably missing is the Fax accordance with T.R.C.P. 193.6(a)
Transmission metadata on the page if this is
in fact a fax transmission. “Enclosures” is Additionally:
indicated however the number is not General Admissibility, Rule 402
indicated. Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled Letter to Luis Acevedo from Jennifer Plaintiff failed to produce this document
DURAN 000145 Thibeaux dated November 21, 2016. “RE: during the Discovery period despite
THIBEAUX RESPONSE TO ACEVEDO Defendant’s numerous requests to Plaintiff
NOVEMBER 8, 2016 CEASE AND DESIST and 2 expired Request For Production served
LETTER”. Noticeably missing is the Fax on Plaintiff with plenty of time to respond
Transmission metadata on the page. In this within the Rules and within the discovery
document Defendant alleges the Plaintiff period.
has been harassing the Defendant.
Defendant Jennifer Thibeaux describes the Objection:
precautions she took to block the Plaintiff in Plaintiff Failed to adhere to
June 2016 from all social media accounts. Supplementation/Amendments of Discovery
Thibeaux describes the harassing behavior Responses, T.R.C.P. 193.5(b); AND
experienced as a result of Plaintiff Duran’s Mandatory Exclusion of Evidence in
actions. Noticeably missing is the Fax accordance with T.R.C.P. 193.6(a)
Transmission metadata on the page if this is
in fact a fax transmission. “Enclosures” is Additionally:
indicated however the number is not General Admissibility, Rule 402
indicated. Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)

Page 47 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled A document showcasing Defendant’s social Plaintiff failed to produce this document
DURAN 000146 media inbox whereby Plaintiff Duran during the Discovery period despite
attempted contact on June 28, 2016. Defendant’s numerous requests to Plaintiff
Plaintiff Duran left her contact phone and 2 expired Request For Production served
number and requested a call back. There is on Plaintiff with plenty of time to respond
no response from Defendant on the page. within the Rules and within the discovery
Noticeably missing is the Fax Transmission period.
metadata on the page if this is in fact a fax
transmission. Objection:
Plaintiff Failed to adhere to
Supplementation/Amendments of Discovery
Responses, T.R.C.P. 193.5(b); AND
Mandatory Exclusion of Evidence in
accordance with T.R.C.P. 193.6(a)

Additionally:
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled A document showcasing an email from Plaintiff failed to produce this document
DURAN 000147 “Julissa Duran (via Twitter)” during the Discovery period despite
<notify@twitter.com>”. to Defendant, Defendant’s numerous requests to Plaintiff
“Jennifer Thibeaux Jennifer@thibeaux.net. and 2 expired Request For Production served
Document showcased, “Julissa Duran on Plaintiff with plenty of time to respond
mentioned you.” In a post dated June 28 within the Rules and within the discovery
with no date listed in the post, there is a period.
tagged post on twitter from the user
account, “Julissa Duran @julissa_duran” Objection:
stating, “@JennThibeaux, Can you please Plaintiff Failed to adhere to
call me? I left you my number on FB Supplementation/Amendments of Discovery
Messenger. Thanks.” At the bottom there is Responses, T.R.C.P. 193.5(b); AND
handwriting stating, “Twitter Contact, Mandatory Exclusion of Evidence in
06/28/16 7:15am”. Noticeably missing is the accordance with T.R.C.P. 193.6(a)
Fax Transmission metadata on the page if
this is in fact a fax transmission. Additionally:
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)

Page 48 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document appears to be a printout Plaintiff failed to produce this document
DURAN 000148 from Plaintiff Duran’s social media during the Discovery period despite
Instagram.com/justjules2000 account. At Defendant’s numerous requests to Plaintiff
the top left of the page showcases and 2 expired Request For Production served
handwriting, “pg 1”.There is handwriting on on Plaintiff with plenty of time to respond
the top right of the page which specifies, within the Rules and within the discovery
“Julissa Duran Instagram Public Account on period.
November 7, 2016. There is additional
writing on the page that says, “Now Objection:
@Redscarlett007”. Noticeably missing is the Plaintiff Failed to adhere to
Fax Transmission metadata on the page if Supplementation/Amendments of Discovery
this is in fact a fax transmission. Responses, T.R.C.P. 193.5(b); AND
Mandatory Exclusion of Evidence in
accordance with T.R.C.P. 193.6(a)

Additionally:
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled This document appears to be a printout Plaintiff failed to produce this document
DURAN 000149 from Plaintiff Duran’s social media during the Discovery period despite
Instagram.com/justjules2000 account. At Defendant’s numerous requests to Plaintiff
the top left of the page showcases and 2 expired Request For Production served
handwriting, “pg 2”.There is handwriting on on Plaintiff with plenty of time to respond
the top right of the page which specifies, within the Rules and within the discovery
“Julissa Duran Instagram Public Account on period.
November 7, 2016. There is additional
writing on the page that says, “Now Objection:
@Redscarlett007”. Noticeably missing is the Plaintiff Failed to adhere to
Fax Transmission metadata on the page if Supplementation/Amendments of Discovery
this is in fact a fax transmission. Responses, T.R.C.P. 193.5(b); AND
Mandatory Exclusion of Evidence in
accordance with T.R.C.P. 193.6(a)

Additionally:
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)

Page 49 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document appears to be a printout Plaintiff failed to produce this document
DURAN 000150 from Plaintiff Duran’s social media during the Discovery period despite
Instagram.com/justjules2000 account – a Defendant’s numerous requests to Plaintiff
specific post. There is handwriting in the and 2 expired Request For Production served
middle top of the page which specifies, on Plaintiff with plenty of time to respond
“Julissa Duran Instagram Public Posting – within the Rules and within the discovery
End of October 2016. There appears to be period.
dialogue between Plaintiff Duran and otdher
users. Plaintiff Duran notes the she’s Objection:
“#FeelingFabulous” “#LoveMyLife” Plaintiff Failed to adhere to
“#KillingIt”. Noticeably missing is the Fax Supplementation/Amendments of Discovery
Transmission metadata on the page if this is Responses, T.R.C.P. 193.5(b); AND
in fact a fax transmission. Mandatory Exclusion of Evidence in
accordance with T.R.C.P. 193.6(a)

Additionally:
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled This document appears to be a printout Plaintiff failed to produce this document
DURAN 000151 from Plaintiff Duran’s social media during the Discovery period despite
Instagram.com/justjules2000 account – a Defendant’s numerous requests to Plaintiff
specific post. There is no date on the page. and 2 expired Request For Production served
There is no time stamp on the page. There is on Plaintiff with plenty of time to respond
handwriting in the middle top of the page within the Rules and within the discovery
which specifies, “Julissa Duran Instagram period.
Details of ‘Even on my Worst day’ posting
Public Posts”. There are arrows pointing to Objection:
the Plaintiff’s comments below her post. Plaintiff Failed to adhere to
There appears to be dialogue between Supplementation/Amendments of Discovery
Plaintiff Duran and other users. Plaintiff Responses, T.R.C.P. 193.5(b); AND
Duran notes the she’s “in the hospital and Mandatory Exclusion of Evidence in
working and closing deals”. Noticeably accordance with T.R.C.P. 193.6(a)
missing is the Fax Transmission metadata on
the page if this is in fact a fax transmission. Additionally:
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)

Page 50 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document appears to be a printout Plaintiff failed to produce this document
DURAN 000152 from Plaintiff Duran’s social media during the Discovery period despite
Instagram.com/justjules2000 account – a Defendant’s numerous requests to Plaintiff
specific post. There is no date on the page. and 2 expired Request For Production served
There is no time stamp on the page. There is on Plaintiff with plenty of time to respond
handwriting in the middle top of the page within the Rules and within the discovery
which specifies, “Julissa Duran Instagram period.
Public Post pulled Early November 2016”.
There appears to be dialogue between Objection:
Plaintiff Duran and other users. Text appears Plaintiff Failed to adhere to
at the bottom of the page, “Photo with Supplementation/Amendments of Discovery
Instagram User @CarolineDazzio. Noticeably Responses, T.R.C.P. 193.5(b); AND
missing is the Fax Transmission metadata on Mandatory Exclusion of Evidence in
the page if this is in fact a fax transmission. accordance with T.R.C.P. 193.6(a)

Additionally:
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled DUPLICATE – DURAN - 000143 DUPLICATE – DURAN - 000143
DURAN 000153
BATES labeled DUPLICATE – DURAN - 000144 DUPLICATE – DURAN - 000144
DURAN 000154
BATES labeled DUPLICATE – DURAN - 000145 DUPLICATE – DURAN - 000145
DURAN 000155
BATES labeled DUPLICATE – DURAN - 000146 DUPLICATE – DURAN - 000146
DURAN 000156
BATES labeled DUPLICATE – DURAN - 000147 DUPLICATE – DURAN - 000147
DURAN 000157
BATES labeled DUPLICATE – DURAN - 000148 DUPLICATE – DURAN - 000148
DURAN 000158
BATES labeled DUPLICATE – DURAN - 000149 DUPLICATE – DURAN - 000149
DURAN 000159
BATES labeled DUPLICATE – DURAN - 000150 DUPLICATE – DURAN - 000150
DURAN 000160
BATES labeled DUPLICATE – DURAN - 000151 DUPLICATE – DURAN - 000151
DURAN 000161
BATES labeled DUPLICATE – DURAN - 000152 DUPLICATE – DURAN - 000152
DURAN 000162
BATES labeled DUPLICATE – DURAN - 000143 DUPLICATE – DURAN - 000143
DURAN 000163

Page 51 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled DUPLICATE – DURAN - 000144 DUPLICATE – DURAN - 000144
DURAN 000164
BATES labeled DUPLICATE – DURAN - 000145 DUPLICATE – DURAN - 000145
DURAN 000165
BATES labeled DUPLICATE – DURAN - 000146 DUPLICATE – DURAN - 000146
DURAN 000166
BATES labeled DUPLICATE – DURAN - 000147 DUPLICATE – DURAN - 000147
DURAN 000167
BATES labeled DUPLICATE – DURAN - 000148 DUPLICATE – DURAN - 000148
DURAN 000168
BATES labeled DUPLICATE – DURAN - 000149 DUPLICATE – DURAN - 000149
DURAN 000169
BATES labeled DUPLICATE – DURAN - 000150 DUPLICATE – DURAN - 000150
DURAN 000170
BATES labeled DUPLICATE – DURAN - 000151 DUPLICATE – DURAN - 000151
DURAN 000171
BATES labeled DUPLICATE – DURAN - 000152 DUPLICATE – DURAN - 000152
DURAN 000172
BATES labeled DUPLICATE – DURAN - 000143 DUPLICATE – DURAN - 000143
DURAN 000173
BATES labeled DUPLICATE – DURAN - 000144 DUPLICATE – DURAN - 000144
DURAN 000174
BATES labeled DUPLICATE – DURAN - 000145 DUPLICATE – DURAN - 000145
DURAN 000175
BATES labeled DUPLICATE – DURAN - 000146 DUPLICATE – DURAN - 000146
DURAN 000176
BATES labeled DUPLICATE – DURAN - 000147 DUPLICATE – DURAN - 000147
DURAN 000177
BATES labeled DUPLICATE – DURAN - 000148 DUPLICATE – DURAN - 000148
DURAN 000178
BATES labeled DUPLICATE – DURAN - 000149 DUPLICATE – DURAN - 000149
DURAN 000179
BATES labeled DUPLICATE – DURAN - 000150 DUPLICATE – DURAN - 000150
DURAN 000180
BATES labeled DUPLICATE – DURAN - 000151 DUPLICATE – DURAN - 000151
DURAN 000181
BATES labeled DUPLICATE – DURAN - 000152 DUPLICATE – DURAN - 000152
DURAN 000182

Page 52 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled Fax to Luis Acevedo from Cris Dishman & Plaintiff failed to produce this document
DURAN 000183 Jennifer Thibeaux. Fax # 713-777-7326. during the Discovery period despite
Phone # 713-777-7332. Subject, “Joint Defendant’s numerous requests to Plaintiff
Statement – Cease & Desist”. Pages, “2”. and 2 expired Request For Production served
This is the Fax Cover page. Dated November on Plaintiff with plenty of time to respond
21, 2016. Checked, “For Review”. Added within the Rules and within the discovery
text, “Julissa Duran Cease and Desist period.
Demand Enclosed”. Noticeably missing is the
Fax Transmission metadata on the page if Objection:
this is in fact a fax transmission. Plaintiff Failed to adhere to
Supplementation/Amendments of Discovery
Responses, T.R.C.P. 193.5(b); AND
Mandatory Exclusion of Evidence in
accordance with T.R.C.P. 193.6(a)

Additionally:
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled This document appears to be a joint Plaintiff failed to produce this document
DURAN 000184 statement from Cris Dishman and Jennifer during the Discovery period despite
Thibeaux. Document dated November 21, Defendant’s numerous requests to Plaintiff
2016. In this letter a demand that Julissa and 2 expired Request For Production served
Duran stop cyber following, making false on Plaintiff with plenty of time to respond
accusation, making false statement, bullying, within the Rules and within the discovery
harassment, or any other defamatory, period.
slanderous, libelous statement made against
Cris Dishman and Jennifer Thibeaux. The Objection:
document appears to be signed by both Plaintiff Failed to adhere to
Jennifer Thibeaux and Cris Dishman. Supplementation/Amendments of Discovery
Noticeably missing is the Fax Transmission Responses, T.R.C.P. 193.5(b); AND
metadata on the page if this is in fact a fax Mandatory Exclusion of Evidence in
transmission. accordance with T.R.C.P. 193.6(a)

Additionally:
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)

Page 53 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document appears to be a letter from Plaintiff failed to produce this document
DURAN 000185 an unknown person to “Julissa”. It is during the Discovery period despite
uncertain if this document is an email or Defendant’s numerous requests to Plaintiff
physical letter. The document showcases and 2 expired Request For Production served
what appears to be an email forward from on Plaintiff with plenty of time to respond
lara@absolutelyfocusmedia.com to Lara bell within the Rules and within the discovery
lara@absolutelyfocusmedia.com date and period.
time stamped November 21, 2016 at
12:21:07 PM CST. In this letter the author Objection:
states a letter regarding Julissa was received Plaintiff Failed to adhere to
from a girl named “Selena”. The author of Supplementation/Amendments of Discovery
this letter to Julissa states, she does not Responses, T.R.C.P. 193.5(b); AND
know who the author of the anonymous fax Mandatory Exclusion of Evidence in
is. The author of the letter to Julissa cautions accordance with T.R.C.P. 193.6(a)
and recommends to Plaintiff Julissa Duran to
limit her social media posts to positivity only Additionally:
seemingly verifying the information General Admissibility, Rule 402
contained in the anonymous fax Lara Bell Requirement of the Original, Rule 1002
received about the Plaintiff Julissa Duran. Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled DUPLICATE – DURAN – 000034 DUPLICATE – DURAN – 000034
DURAN 000186
BATES labeled DUPLICATE – DURAN – 000037 DUPLICATE – DURAN – 000037
DURAN 000187
BATES labeled DUPLICATE – DURAN – 000038 DUPLICATE – DURAN – 000038
DURAN 000188
BATES labeled DUPLICATE – DURAN – 000028 DUPLICATE – DURAN – 000028
DURAN 000189
BATES labeled DUPLICATE – DURAN – 000029 DUPLICATE – DURAN – 000029
DURAN 000190
BATES labeled DUPLICATE – DURAN – 000030 DUPLICATE – DURAN – 000030
DURAN 000191

Page 54 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled DUPLICATE – DURAN – 000031 with the Plaintiff failed to produce this document
DURAN 000192 exception at the bottom of the page is an during the Discovery period despite
indication of the name, “Lara Bell Publisher, Defendant’s numerous requests to Plaintiff
Absolutely Memorial Magazine Publisher, and 2 expired Request For Production served
Absolutely Katy Magazine @larabell on Plaintiff with plenty of time to respond
www.absolutelymemorial.com within the Rules and within the discovery
www.absolutelykaty.com” period.

Objection:
Plaintiff Failed to adhere to
Supplementation/Amendments of Discovery
Responses, T.R.C.P. 193.5(b); AND
Mandatory Exclusion of Evidence in
accordance with T.R.C.P. 193.6(a)

Additionally:
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled DUPLICATE – DURAN – 000024 Xx
DURAN 000193 General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled DUPLICATE – DURAN – 000025 DUPLICATE – DURAN – 000025
DURAN 000194
BATES labeled DUPLICATE – DURAN – 000026 DUPLICATE – DURAN – 000026
DURAN 000195
BATES labeled DUPLICATE – DURAN – 000027 DUPLICATE – DURAN – 000027
DURAN 000196
BATES labeled DUPLICATE – DURAN – 000185 DUPLICATE – DURAN – 000185
DURAN 000197
BATES labeled DUPLICATE – DURAN – 000034 DUPLICATE – DURAN – 000034
DURAN 000198
BATES labeled DUPLICATE – DURAN – 000037 DUPLICATE – DURAN – 000037
DURAN 000199
BATES labeled DUPLICATE – DURAN – 000038 DUPLICATE – DURAN – 000038
DURAN 000200
BATES labeled DUPLICATE – DURAN – 000028 DUPLICATE – DURAN – 000028
DURAN 000201

Page 55 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled DUPLICATE – DURAN – 000029 DUPLICATE – DURAN – 000029
DURAN 000202
BATES labeled DUPLICATE – DURAN – 000030 DUPLICATE – DURAN – 000030
DURAN 000203
BATES labeled DUPLICATE – DURAN – 000031 DUPLICATE – DURAN – 000031
DURAN 000204
BATES labeled DUPLICATE – DURAN – 000185 DUPLICATE – DURAN – 000185
DURAN 000197 *Repeated in the pages with the Bates label, *Repeated in the pages with the Bates label,
“DURAN 000197” “DURAN 000197”
BATES labeled DUPLICATE – DURAN – 000038 DUPLICATE – DURAN – 000038
DURAN 000200 *Repeated in the pages with the Bates label, *Repeated in the pages with the Bates label,
“DURAN 000200” “DURAN 000200”
BATES labeled DUPLICATE – DURAN – 000028 DUPLICATE – DURAN – 000028
DURAN 000201 *Repeated in the pages with the Bates label, *Repeated in the pages with the Bates label,
“DURAN 000201” “DURAN 000201”
BATES labeled DUPLICATE – DURAN – 000029 DUPLICATE – DURAN – 000029
DURAN 000202 *Repeated in the pages with the Bates label, *Repeated in the pages with the Bates label,
“DURAN 000202” “DURAN 000202”
BATES labeled DUPLICATE – DURAN – 000030 DUPLICATE – DURAN – 000030
DURAN 000203 *Repeated in the pages with the Bates label, *Repeated in the pages with the Bates label,
“DURAN 000203” “DURAN 000203”
BATES labeled DUPLICATE – DURAN – 000192 DUPLICATE – DURAN – 000192
DURAN 000204 *Repeated in the pages with the Bates label, *Repeated in the pages with the Bates label,
“DURAN 000204” “DURAN 000204”
BATES labeled DUPLICATE – DURAN – 000024 DUPLICATE – DURAN – 000024
DURAN 000205
BATES labeled DUPLICATE – DURAN – 000025 DUPLICATE – DURAN – 000025
DURAN 000206
BATES labeled DUPLICATE – DURAN – 000026 DUPLICATE – DURAN – 000026
DURAN 000207
BATES labeled DUPLICATE – DURAN – 000027 DUPLICATE – DURAN – 000027
DURAN 000208

Page 56 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document appears to be a screen shot Plaintiff failed to produce this document
DURAN 000209 taken at 5:57pm on October 26, 2016 with during the Discovery period despite
another time stamp time of 6:26pm. This Defendant’s numerous requests to Plaintiff
document showcase the word “Tweets” and 2 expired Request For Production served
with a posting from user “@JennThibeaux” on Plaintiff with plenty of time to respond
with a time stamp of “12h”. The post from within the Rules and within the discovery
the user shows a screen shot of a LinkedIn period.
Premium tool, “Who Viewed My Profile”;
according to the post from “2 weeks ago”. Objection:
There are names that appear within the post Plaintiff Failed to adhere to
however none are the Plaintiff Julissa Duran. Supplementation/Amendments of Discovery
Responses, T.R.C.P. 193.5(b); AND
Mandatory Exclusion of Evidence in
accordance with T.R.C.P. 193.6(a)

Additionally:
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)
BATES labeled DUPLICATE – DURAN – 000004 DUPLICATE – DURAN – 000004
DURAN 000210
BATES labeled DUPLICATE – DURAN – 000005 DUPLICATE – DURAN – 000005
DURAN 000211
BATES labeled DUPLICATE – DURAN – 000024 DUPLICATE – DURAN – 000024
DURAN 000212 *with the exception that several sentences *with the exception that several sentences
now contain a highlight. now contain a highlight.
BATES labeled DUPLICATE – DURAN – 000034 DUPLICATE – DURAN – 000034
DURAN 000213 *with the exception that several sentences *with the exception that several sentences
now contain a highlight. now contain a highlight.
BATES labeled DUPLICATE – DURAN – 000017 DUPLICATE – DURAN – 000017
DURAN 000214 *with the exception that several sentences *with the exception that several sentences
now contain a highlight. now contain a highlight.
BATES labeled DUPLICATE – DURAN – 000018 DUPLICATE – DURAN – 000018
DURAN 000215 *with the exception that several sentences *with the exception that several sentences
now contain a highlight. now contain a highlight.
BATES labeled DUPLICATE – DURAN – 000028 DUPLICATE – DURAN – 000028
DURAN 000216 *with the exception that several sentences *with the exception that several sentences
now contain a highlights; there is no now contain a highlights; there is no
handwriting on the document. handwriting on the document.
BATES labeled DUPLICATE – DURAN – 000018 DUPLICATE – DURAN – 000018
DURAN 000217 *with the exception that several sentences *with the exception that several sentences
now contain a highlights now contain a highlights

Page 57 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled DUPLICATE – DURAN – 000004 DUPLICATE – DURAN – 000004
DURAN 000218 *with the exception that several sentences *with the exception that several sentences
now contain a highlights now contain a highlights
BATES labeled DUPLICATE – DURAN – 000005 DUPLICATE – DURAN – 000005
DURAN 000219 *with the exception that several sentences *with the exception that several sentences
now contain a highlights; handwriting is on now contain a highlights; handwriting is on
the document in the same highlight yellow the document in the same highlight yellow
color. color.
BATES labeled DUPLICATE – DURAN – 000004 DUPLICATE – DURAN – 000004
DURAN 000220
BATES labeled DUPLICATE – DURAN – 000005 DUPLICATE – DURAN – 000005
DURAN 000221
BATES labeled DUPLICATE – DURAN – 000009 DUPLICATE – DURAN – 000009
DURAN 000222
BATES labeled DUPLICATE – DURAN – 000006 DUPLICATE – DURAN – 000006
DURAN 000223
BATES labeled DUPLICATE – DURAN 000024 DUPLICATE – DURAN 000024
DURAN 000224
BATES labeled DUPLICATE – DURAN 000034 DUPLICATE – DURAN 000034
DURAN 000225
BATES labeled DUPLICATE – DURAN – 000028 DUPLICATE – DURAN – 000028
DURAN 000226 *with the exception that there is no *with the exception that there is no
handwriting or highlight on the document. handwriting or highlight on the document.
BATES labeled DUPLICATE – DURAN – 000017 DUPLICATE – DURAN – 000017
DURAN 000227 *with the exception that there is no *with the exception that there is no
handwriting or highlight on the document. handwriting or highlight on the document.

Page 58 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S ANALYSIS AND COMMENT REGARDING PLAINTIFF’S EVIDENCE


[DURAN 000001 – 000228]
Document Label Info/Issue(s) Objection(s)
BATES labeled This document appears to be a Linked In There is no date or time stamp on this
DURAN 000228 posting – perhaps a screen shot of Plaintiff document. It is unclear if the document is a
Julissa Duran’s profile. Duran’s profile has screen shot or print out from a post. There is
been viewed “7” times. On the page shows 3 no metadata associated with this
pictures of people with a +4 on the page. image/document. The origin is unknown. The
There are no names. There is arrows author of the handwriting is unknown.
pointing to an image with handwriting
stating, “Stalker Scary Eyes My LinkedIn Plaintiff failed to produce this document
account”. There is no date or time stamp on during the Discovery period despite
this document. It is unclear if the document Defendant’s numerous requests to Plaintiff
is a screen shot or print out from a post. and 2 expired Request For Production served
on Plaintiff with plenty of time to respond
within the Rules and within the discovery
period.

Objection:
Plaintiff Failed to adhere to
Supplementation/Amendments of Discovery
Responses, T.R.C.P. 193.5(b); AND
Mandatory Exclusion of Evidence in
accordance with T.R.C.P. 193.6(a)

Additionally:
General Admissibility, Rule 402
Requirement of the Original, Rule 1002
Testimony to Prove content, Rule 1007
Hearsay, Rule 801(d), 802
Test for Relevance, Rule 401(a),(b)

Page 59 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S FIRST REQEUST FOR PRODUCTION


PLAINTIFF
PLAINTIFF JULISSA DURAN’S RESPONSES Did Plaintiff Did
RESPONDED
REQUEST Due: February 10, 2018 Produce Plaintiff
WITHIN THE
# Responses Served Late - February 20, what was Allow
DISCOVERY
2018 Requested? Inspection?
PERIOD?
Please see Bates Labeled documents
1 YES YES NO
DURAN 000001 – 000142.
Please see Bates Labeled documents
2 YES YES NO
DURAN 000001 – 000142.
Please see Bates Labeled documents
3 YES YES NO
DURAN 000001 – 000142.
PLAINTIFF
4 None. YES RESPONDED N/A
NONE
PLAINTIFF
5 None. YES RESPONDED N/A
NONE
None at this time. Plaintiff will
6 NO NO NO
supplement.
PLAINTIFF
7 None. YES RESPONDED N/A
NONE
None at this time. Plaintiff will
8 NO NO NO
supplement.
PLAINTIFF
9 None. YES RESPONDED N/A
NONE
10 Plaintiff will supplement. NO NO NO
Please see Bates Labeled documents
11 YES NO NO
DURAN 000001 – 000142.
None at this time. Plaintiff will
12 NO NO NO
supplement.
None at this time. Plaintiff will
13 NO NO NO
supplement.
14 Plaintiff will supplement. NO NO NO
PLAINTIFF
15 None. YES RESPONDED N/A
NONE
PLAINTIFF
16 None. YES RESPONDED N/A
NONE

Page 60 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S FIRST REQEUST FOR PRODUCTION


PLAINTIFF
PLAINTIFF JULISSA DURAN’S RESPONSES Did Plaintiff Did
RESPONDED
REQUEST Due: February 10, 2018 Produce Plaintiff
WITHIN THE
# Responses Served Late - February 20, what was Allow
DISCOVERY
2018 Requested? Inspection?
PERIOD?
PLAINTIFF
17 None. YES RESPONDED N/A
NONE
PLAINTIFF
18 None. YES RESPONDED N/A
NONE
None at this time. Plaintiff will
19 NO NO NO
supplement.
Please see Bates Labeled documents
20 YES TES NO
DURAN 000001 – 000142.
Please see Bates Labeled documents
21 YES NO NO
DURAN 000001 – 000142.
Please see Bates Labeled documents
22 YES NO NO
DURAN 000001 – 000142.
Please see Bates Labeled documents
23 YES NO NO
DURAN 000001 – 000142.
Please see Bates Labeled documents
24 YES NO NO
DURAN 000001 – 000142.
Please see Bates Labeled documents
25 YES NO NO
DURAN 000001 – 000142.
26 Plaintiff will supplement. NO NO NO
27 Plaintiff will supplement. NO NO NO
Please see Bates Labeled documents
28 YES NO NO
DURAN 000001 – 000142.
29 Plaintiff will supplement. NO NO NO
30 Plaintiff will supplement. NO NO NO
31 Plaintiff will supplement. NO NO NO
32 Plaintiff will supplement. NO NO NO
33 Plaintiff will supplement. NO NO NO
34 Plaintiff will supplement. NO NO NO
35 Plaintiff will supplement. NO NO NO
Please see Bates Labeled documents
36 YES NO NO
DURAN 000001 – 000142.
Please see Bates Labeled documents
37 YES NO NO
DURAN 000001 – 000142.
Please see Bates Labeled documents
38 YES YES NO
DURAN 000001 – 000142.
39 (a-k) Plaintiff will supplement. NO NO NO

Page 61 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S FIRST REQEUST FOR PRODUCTION


PLAINTIFF
PLAINTIFF JULISSA DURAN’S RESPONSES Did Plaintiff Did
RESPONDED
REQUEST Due: February 10, 2018 Produce Plaintiff
WITHIN THE
# Responses Served Late - February 20, what was Allow
DISCOVERY
2018 Requested? Inspection?
PERIOD?
Please see Bates Labeled documents
40 YES NO NO
DURAN 000001 – 000142.
Please see Bates Labeled documents
41 YES NO NO
DURAN 000001 – 000142.
Please see Bates Labeled documents
42 YES NO NO
DURAN 000001 – 000142.

Page 62 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S SECOND REQEUST FOR PRODUCTION


PLAINTIFF JULISSA DURAN’S RESPONSES PLAINTIFF
Did Plaintiff
REQUEST Due: April 30, 2018 RESPONDED WITHIN
Produce what was
# Reponses Served LATE – May 21, 2018 THE DISCOVERY
Requested?
(After End of Discovery Period) PERIOD?
1 Plaintiff will supplement NO NO
Please see Bates Labeled documents DURAN
2 NO NO
000143 – 000228.
Please see Bates Labeled documents DURAN
3 NO NO
000143 – 000228.
Please see Bates Labeled documents DURAN
4 NO NO
000143 – 000228.
Please see Bates Labeled documents DURAN
5 NO NO
000143 – 000228.
6 Plaintiff will supplement NO NO
Please see Bates Labeled documents DURAN
7 NO NO
000143 – 000228.
PLAINTIFF
8 None NO RESPONDED
NONE
Please see Bates Labeled documents DURAN
9 NO NO
000143 – 000228.
PLAINTIFF
10 None NO RESPONDED
NONE
11 Plaintiff will supplement NO NO
Please see Bates Labeled documents DURAN
12 NO YES
000143 – 000228.
Please see Bates Labeled documents DURAN
13 NO NO
000143 – 000228.
PLAINTIFF
14 None. NO RESPONDED
NONE
Please see Bates Labeled documents DURAN
15 NO YES
000143 – 000228.
Please see Bates Labeled documents DURAN
16 NO YES
000143 – 000228.
17 Plaintiff will supplement NO NO

Page 63 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S FIRST REQEUST FOR INTERROGATORIES


PLAINTIFF JULISSA DURAN’S RESPONSES PLAINTIFF
Plaintiff’s
REQUEST Due: April 23, 2018 RESPONDED WITHIN
Responses
# Reponses Served LATE & IMPROPER – May 21, 2018 THE DISCOVERY
Admissible?
(After End of Discovery Period) PERIOD?
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
1 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
2 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
3 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
4 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
5 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
6 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
7 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
8 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
9 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
10 NO NO
responses due to the deficiency of the form and
responses.
Page 64 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S FIRST REQEUST FOR INTERROGATORIES


PLAINTIFF JULISSA DURAN’S RESPONSES PLAINTIFF
Plaintiff’s
REQUEST Due: April 23, 2018 RESPONDED WITHIN
Responses
# Reponses Served LATE & IMPROPER – May 21, 2018 THE DISCOVERY
Admissible?
(After End of Discovery Period) PERIOD?
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
11 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
12 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
13 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
14 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
15 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
16 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
17 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
18 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
19 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
20 NO NO
responses due to the deficiency of the form and
responses.

Page 65 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S FIRST REQEUST FOR INTERROGATORIES


PLAINTIFF JULISSA DURAN’S RESPONSES PLAINTIFF
Plaintiff’s
REQUEST Due: April 23, 2018 RESPONDED WITHIN
Responses
# Reponses Served LATE & IMPROPER – May 21, 2018 THE DISCOVERY
Admissible?
(After End of Discovery Period) PERIOD?
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
21 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
22 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
23 NO NO
responses due to the deficiency of the form and
responses.
Plaintiff failed to sign Interrogatories; document was
not sworn under oath. Cannot evaluate Plaintiff’s
24 NO NO
responses due to the deficiency of the form and
responses.

Page 66 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S REQEUST FOR DISCLOSURE


PLAINTIFF JULISSA DURAN’S RESPONSES
PLAINTIFF RESPONDED
REQUEST Due: March 28, 2018
WITHIN THE DISCOVERY
# Reponses NEVER Served to Date
PERIOD?
Discovery Period has ENDED
Plaintiff failed to respond; failed to request additional time to
respond; failed to address lateness of response; failed to address
194.2 (a) NO – NEVER RESPONDED
any objections to this request; failed respond to Plaintiff upon
inquiry of missed deadline.
Plaintiff failed to respond; failed to request additional time to
respond; failed to address lateness of response; failed to address
194.2 (b) NO – NEVER RESPONDED
any objections to this request; failed respond to Plaintiff upon
inquiry of missed deadline.
Plaintiff failed to respond; failed to request additional time to
respond; failed to address lateness of response; failed to address
194.2 (c) NO – NEVER RESPONDED
any objections to this request; failed respond to Plaintiff upon
inquiry of missed deadline.
Plaintiff failed to respond; failed to request additional time to
respond; failed to address lateness of response; failed to address
194.2 (d) NO – NEVER RESPONDED
any objections to this request; failed respond to Plaintiff upon
inquiry of missed deadline.
Plaintiff failed to respond; failed to request additional time to
respond; failed to address lateness of response; failed to address
194.2 (e) NO – NEVER RESPONDED
any objections to this request; failed respond to Plaintiff upon
inquiry of missed deadline.
Plaintiff failed to respond; failed to request additional time to
respond; failed to address lateness of response; failed to address
194.2 (f) NO – NEVER RESPONDED
any objections to this request; failed respond to Plaintiff upon
inquiry of missed deadline.
Plaintiff failed to respond; failed to request additional time to
respond; failed to address lateness of response; failed to address
194.2 (g) NO – NEVER RESPONDED
any objections to this request; failed respond to Plaintiff upon
inquiry of missed deadline.
Plaintiff failed to respond; failed to request additional time to
respond; failed to address lateness of response; failed to address
194.2 (h) NO – NEVER RESPONDED
any objections to this request; failed respond to Plaintiff upon
inquiry of missed deadline.
Plaintiff failed to respond; failed to request additional time to
respond; failed to address lateness of response; failed to address
194.2 (i) NO – NEVER RESPONDED
any objections to this request; failed respond to Plaintiff upon
inquiry of missed deadline.
Plaintiff failed to respond; failed to request additional time to
respond; failed to address lateness of response; failed to address
194.2 (j) NO – NEVER RESPONDED
any objections to this request; failed respond to Plaintiff upon
inquiry of missed deadline.
Page 67 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

DEFENDANT’S REQEUST FOR DISCLOSURE


PLAINTIFF JULISSA DURAN’S RESPONSES
PLAINTIFF RESPONDED
REQUEST Due: March 28, 2018
WITHIN THE DISCOVERY
# Reponses NEVER Served to Date
PERIOD?
Discovery Period has ENDED
Plaintiff failed to respond; failed to request additional time to
respond; failed to address lateness of response; failed to address
194.2 (k) NO – NEVER RESPONDED
any objections to this request; failed respond to Plaintiff upon
inquiry of missed deadline.
Plaintiff failed to respond; failed to request additional time to
respond; failed to address lateness of response; failed to address
194.2 (l) NO – NEVER RESPONDED
any objections to this request; failed respond to Plaintiff upon
inquiry of missed deadline.

Page 68 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

CASE COMMUNICATION BETWEEN PLAINTIFF AND DEFENDANT


Date & Time Form FROM TO Content
10/26/2017 eFile & DEFENDANT PLAINTIFF Defendant’s Original Answer
19:38 CDT Serve; Jennifer Sean A.
USPS Mail Thibeaux Roberts
01/10/2018 eFile & DEFENDANT PLAINTIFF Defendant’s First Request for Production
20:51 CST Serve; Jennifer Sean A.
USPS Mail Thibeaux Roberts
02/13/2018 Email; DEFENDANT PLAINTIFF Defendant’s Attempt at Conference RE:
23:07 CST USPS Mail Jennifer Sean A. Deadline missed, late responses.
Thibeaux Roberts
NOTE: Plaintiff’s Counsel did not reply in any
form.
02/20/2018 eFile & DEFENDANT PLAINTIFF Defendant’s Motion to Compel Discovery
10:24 CDT Serve; Jennifer Sean A.
USPS Mail Thibeaux Roberts
02/20/2018 eFile & DEFENDANT PLAINTIFF Notice of Submission for Defendant’s Motion
09:09 CST Serve; Jennifer Sean A. to Compel Discovery
USPS Mail Thibeaux Roberts
Hearing date – March 5, 2018 08:00 –
Submission Docket
02/20/2018 eFile PLAINTIFF DEFENDANT Plaintiff’s Responses to Defendant’s First
12:42 CST Sean A. Jennifer Request for Production
Roberts Thibeaux
02/20/2018 Email; DEFENDANT PLAINTIFF Defendant’s Attempt at Conference RE:
20:17 CST USPS Mail Jennifer Sean A. Deficient responses; request inspection of
Thibeaux Roberts originals; inquiry as to when inspection would
occur.

NOTE: Plaintiff’s Counsel did not reply in any


form.
02/24/2018 USPS Mail PLAINTIFF DEFENDANT Plaintiff’s Production Evidence in Response to
12:42 CST Sean A. Jennifer Defendant’s First Request for Production
Roberts Thibeaux
02/26/2018 eFile & DEFENDANT PLAINTIFF Defendant’s Request for Disclosure and
06:46 CST Serve; Jennifer Sean A. Preservation to Plaintiff
USPS Mail Thibeaux Roberts
02/26/2018 eFile PLAINTIFF DEFENDANT Plaintiff’s Notice of Intention to Take the Oral
15:58 CST Sean A. Jennifer Deposition of Defendant Jennifer Thibeaux
Roberts Thibeaux
02/27/2018 eFile & DEFENDANT PLAINTIFF Defendant’s Motion to Quash & Motion for
23:09 CST Serve; Jennifer Sean A. Protective Order to Plaintiff
USPS Mail Thibeaux Roberts
Page 69 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

CASE COMMUNICATION BETWEEN PLAINTIFF AND DEFENDANT


Date & Time Form FROM TO Content
02/28/2018 Email; DEFENDANT PLAINTIFF Defendant’s Attempt at Conference RE:
01:19 CST USPS Mail Jennifer Sean A. Deficient responses; request inspection of
Thibeaux Roberts originals; inquiry as to when inspection would
occur.

NOTE: Plaintiff’s Counsel did not reply in any


form.
02/28/2018 eFile & DEFENDANT PLAINTIFF Notice of Submission for Defendant’s Motion
10:06 CST Serve; Jennifer Sean A. to Quash & Motion for Protective Order to
USPS Mail Thibeaux Roberts Plaintiff

Hearing date – March 12, 2018 08:00 –


Submission Docket
02/28/2018 eFile & DEFENDANT PLAINTIFF Defendant’s First Request for Admission to
15:50 CST Serve; Jennifer Sean A. Plaintiff
USPS Mail Thibeaux Roberts
02/28/2018 Email PLAINTIFF DEFENDANT Acknowledgement of receiving Defendant’s
15:58 CST Anjali Jennifer Motion to Quash Oral Deposition & Motion
Sharma Thibeaux for Protective Order. Plaintiff’s counsel asked
for dates in March for deposition.
02/28/2018 eFile & DEFENDANT PLAINTIFF Amended Notice of Submission for
16:06 CST Serve; Jennifer Sean A. Defendant’s Motion to Quash & Motion for
USPS Mail Thibeaux Roberts Protective Order to Plaintiff

Hearing date – March 12, 2018 08:00 –


Submission Docket
03/05/2018 Email PLAINTIFF DEFENDANT Follow-up email to Defendant regarding
11:05 CST Anjali Jennifer identifying Deposition availability dates in
Sharma Thibeaux March.
03/06/2018 Email DEFENDANT PLAINTIFF Defendant reply to Plaintiff’s Counsel Sharma
10:32 CST Jennifer Anjali RE: Deposing Plaintiff; Defendant’s travel
Thibeaux Sharma considerations; Defendant’s desire to depose
other witnesses at the same time as the
deposition of Plaintiff Duran; and requesting
Plaintiff’s counsel Sharma refrain from casual
language in addressing Defendant.

Page 70 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

CASE COMMUNICATION BETWEEN PLAINTIFF AND DEFENDANT


Date & Time Form FROM TO Content
03/13/2018 Email; DEFENDANT PLAINTIFF Defendant’s Attempt at Conference RE: Final
08:42 CDT USPS Mail Jennifer Sean A. Attempt prior to Filing Motion to Compel RE:
Thibeaux Roberts Deficient responses; request inspection of
originals; inquiry as to when inspection would
occur.

NOTE: Plaintiff’s Counsel did not reply in any


form.
03/13/2018 Email PLAINTIFF DEFENDANT Plaintiff’s Counsel Sharma requesting a phone
16:53 CDT Anjali Jennifer conference for the next day (03/14/2018)
Sharma Thibeaux
03/14/2018 Phone DEFENDANT PLAINTIFF Defendant attempted phone conference. Left
07:48 CDT Jennifer Anjali message with Cynthia at Plaintiff’s Counsel’s
Thibeaux Sharma’s office for Plaintiff’s Counsel Sharma. Intended
Admin - to discuss Deposition dates, Plaintiff’s
Cynthia availability; and additional discovery issues.
03/14/2018 Email DEFENDANT PLAINTIFF Defendant’s email to reiterate phone message
07:52 CDT Jennifer Anjali left with Cynthia at Plaintiff’s Counsel’s office
Thibeaux Sharma for Plaintiff’s Counsel Sharma
03/14/2018 Email PLAINTIFF DEFENDANT Plaintiff’s Counsel Sharma provided dates of
12:53 CDT Anjali Jennifer availability for the upcoming week. Plaintiff’s
Sharma Thibeaux Counsel Sharma refused to discuss discovery
issues
03/15/2018 eFile & DEFENDANT PLAINTIFF Defendant’s Motion to Compel Further
17:25 CDT Serve; Jennifer Sean A. Discovery for Plaintiff to Respond to
USPS Mail Thibeaux Roberts Defendant’s Discovery Requests and for Costs
and Fees
03/16/2018 eFile & DEFENDANT PLAINTIFF Notice of Submission for Defendant’s Motion
00:51 CST Serve; Jennifer Sean A. to Compel Further Discovery for Plaintiff to
USPS Mail Thibeaux Roberts Respond to Defendant’s Discovery Requests
and for Costs and Fees

Hearing date – March 26, 2018 08:00 –


Submission Docket
03/20/2018 Email DEFENDANT PLAINTIFF Defendant’s email to Plaintiff’s Counsel
12:33 CDT Jennifer Anjali Sharma offered up dates for phone
Thibeaux Sharma conference. Defendant additionally offered to
conference via email.
03/20/2018 Email PLAINTIFF DEFENDANT Plaintiff’s Counsel Sharma asked for
14:58 CDT Anjali Jennifer Defendant to provide dates for availability for
Sharma Thibeaux deposition.

Page 71 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

CASE COMMUNICATION BETWEEN PLAINTIFF AND DEFENDANT


Date & Time Form FROM TO Content
03/20/2018 Email DEFENDANT PLAINTIFF Defendant’s email to Plaintiff’s Counsel
16:56 CDT Jennifer Anjali Sharma offered up dates for deposition.
Thibeaux Sharma Defendant requested 5 dates for availability
for Plaintiff’s Deposition. Defendant notified
Plaintiff’s Counsel Sharma of the names of
other witnesses Defendant indents to depose.
Defendant outlined 5 Notices - #1 Plaintiff’s
Production Responses deficient; #2 Inquiry as
to when supplementation will occur; #3
Plaintiff’s actual production was defective; #4
demand for inspection of Plaintiff’s original
production evidence; and #5 Caution to
Plaintiff’s Counsel regarding the efficacy of
Plaintiff’s claims.
03/23/2018 eFile & DEFENDANT PLAINTIFF Defendant’s First Set of Interrogatories to
07:59 CST Serve; Jennifer Sean A. Plaintiff
USPS Mail Thibeaux Roberts
03/26/2018 eFile PLAINTIFF DEFENDANT Plaintiff’s Response to Defendant’s Motion to
07:12 CST Sean A. Jennifer Compel
Roberts Thibeaux
NOTE: Responses Motions are due no less
than 3 days prior to a hearing on the matter.
Plaintiff filed the response 48 minutes prior to
the Submission Docket Hearing. Additionally,
Plaintiff failed to serve responses to
Defendant.
03/27/2018 eFile & DEFENDANT PLAINTIFF Defendant’s Notice of Intention to Use
12:56 CST Serve; Jennifer Sean A. Plaintiff’s Production Documents in Pre-Trial
USPS Mail Thibeaux Roberts Proceedings and Trial
03/28/2018 Email PLAINTIFF DEFENDANT Plaintiff’s Counsel Sharma asked for
09:36 CDT Anjali Jennifer Defendant to provide dates for availability for
Sharma Thibeaux deposition at the end of May 2018. Plaintiff’s
Counsel Sharma advised that Plaintiff was
gathering supplemented information and
would be sure to get inspection scheduled as
soon as Plaintiff completed gathering the
information.

Page 72 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

CASE COMMUNICATION BETWEEN PLAINTIFF AND DEFENDANT


Date & Time Form FROM TO Content
03/28/2018 Email DEFENDANT PLAINTIFF Defendant makes a final demand to inspect
10:14 CDT Jennifer Anjali Plaintiff’s production evidence originals.
Thibeaux Sharma Defendant reiterates the issues related to
discovery avoidance and discovery abuse.
Defendant gives Plaintiff’s Counsel Sharma 24
hours to get inspection scheduled.
03/28/2018 Email PLAINTIFF DEFENDANT Plaintiff’s Counsel Sharma now states the
10:24 CDT Anjali Jennifer Plaintiff is in possession of all originals and
Sharma Thibeaux merely needs to get the documents couriered
over to Plaintiff’s Counsel’s office. Plaintiff’s
Counsel Sharma asks for dates over the next
two weeks for inspection.
03/28/2018 Email DEFENDANT PLAINTIFF Defendant reiterates final demand for
10:30 CDT Jennifer Anjali inspection and provided a date of 10:00am
Thibeaux Sharma CDT March 29, 2018.

NOTE: There was no further communication


from Plaintiff’s Counsel on this matter. No
inspection ever scheduled despite
Defendant’s numerous requests.
03/28/2018 eFile & DEFENDANT PLAINTIFF Defendant’s Notice of Intention to Inspect
11:52 CST Serve; Jennifer Sean A. Plaintiff’s Production Document Originals
USPS Mail Thibeaux Roberts
03/29/2018 eFile & DEFENDANT PLAINTIFF Defendant’s Second Request for Production to
01:29 CST Serve; Jennifer Sean A. Plaintiff
USPS Mail Thibeaux Roberts
03/29/2018 eFile & DEFENDANT PLAINTIFF Order Granting Defendant’s Motion to Quash
02:46 CST Serve; Jennifer Sean A. & Motion for Protective Order
USPS Mail Thibeaux Roberts
03/29/2018 eFile & DEFENDANT PLAINTIFF Order Granting Defendant’s Motion to to
03:07 CST Serve; Jennifer Sean A. Compel Further Discovery, For Plaintiff to
USPS Mail Thibeaux Roberts Respond to Defendant’s Discovery Requests,
and for Costs and Fees

Page 73 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

CASE COMMUNICATION BETWEEN PLAINTIFF AND DEFENDANT


Date & Time Form FROM TO Content
05/01/2018 Email; DEFENDANT PLAINTIFF Defendant’s Attempt at Conference RE: #1 –
08:42 CDT USPS Mail Jennifer Sean A. Inspection of Originals has still not been
Thibeaux Roberts allowed; #2 – Plaintiff has failed to
supplement evidence; #3 – Answers for
Request for Disclosure overdue by 35 days; #4
– Answers for Request for Interrogatories
overdue by 8 days; #5 – Answers for
Defendant’s 2nd Request for Production
overdue by 1 day; #6 – Plaintiff’s lack of
participation and cooperation in discovery.

NOTE: Plaintiff’s Counsel did not reply in any


form.
05/15/2018 eFile & DEFENDANT PLAINTIFF Defendant’s Motion to Compel Discovery for
16:12 CDT Serve; Jennifer Sean A. Plaintiff to Respond to Defendant’s Discovery
USPS Mail Thibeaux Roberts Requests and for Costs and Fees
05/15/2018 eFile & DEFENDANT PLAINTIFF Notice of Submission for Defendant’s Motion
16:36 CDT Serve; Jennifer Sean A. to Compel Discovery for Plaintiff to Respond to
USPS Mail Thibeaux Roberts Defendant’s Discovery Requests and for Costs
and Fees

Hearing date – June 4, 2018 08:00 –


Submission Docket
05/15/2018 Email; DEFENDANT PLAINTIFF Defendant’s Attempt at Conference RE:
16:21 CDT USPS Mail Jennifer Sean A. Evidence List; Plaintiff’s production evidence
Thibeaux Roberts and behavior concerns; Defendant’s advising
of upcoming evidence.

NOTE: Plaintiff’s Counsel did not reply in any


form.
05/15/2018 Email; DEFENDANT PLAINTIFF Defendant’s Attempt at Conference RE:
16:24 CDT USPS Mail Jennifer Sean A. Issues with Duran’s evidence; a lack of special
Thibeaux Roberts damages evidence; relevancy issues with a
majority of Plaintiff’s evidence; a general
concern regarding the efficacy of Plaintiff’s
claims/case.

NOTE: Plaintiff’s Counsel did not reply in any


form.

Page 74 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

CASE COMMUNICATION BETWEEN PLAINTIFF AND DEFENDANT


Date & Time Form FROM TO Content
05/15/2018 Email; DEFENDANT PLAINTIFF Defendant’s Attempt at Conference RE:
16:25 CDT USPS Mail Jennifer Sean A. Defendant’s Upcoming Summary Judgment
Thibeaux Roberts filing. Inquired to Plaintiff’s Counsel Roberts if
he would unoppose a motion on the matter
based on the lack of evidence; lack of
participation; and general lack of claims in this
matter.

NOTE: Plaintiff’s Counsel did not reply in any


form.
05/15/2018 Email PLAINTIFF DEFENDANT Plaintiff’s Counsel Sharma emailed to advise
13:26 CDT Anjali Jennifer that she is aware that discovery responses are
Sharma Thibeaux late. Plaintiff’s Counsel advised that the
Plaintiff recently had “intensive surgery” and
was currently in recovery. Plaintiff’s Counsel
advised that as soon as the information was
prepared and mailed Plaintiff’s Counsel
Sharma would alert Defendant.
05/15/2018 Email DEFENDANT PLAINTIFF Defendant replied to Plaintiff’s Counsel
14:09 CDT Jennifer Anjali Sharma regarding the disbelief in the excuses
Thibeaux Sharma over the discovery period. Defendant advised
that discovery abuse will not be tolerated and
advised that the pending Motion to Compel
will provide an opportunity to address issues
related to this matter.

NOTE: Plaintiff’s Counsel did not reply in any


form.
05/18/2018 eFile & DEFENDANT PLAINTIFF Defendant’s Motion for No-Evidence Summary
08:57 CDT Serve; Jennifer Sean A. Judgment
USPS Mail Thibeaux Roberts
05/18/2018 eFile & DEFENDANT PLAINTIFF Notice of Submission for Defendant’s Motion
09:09 CDT Serve; Jennifer Sean A. for No-Evidence Summary Judgment
USPS Mail Thibeaux Roberts
Hearing date – June 11, 2018 08:00 –
Submission Docket

Page 75 of 76
Jennifer Thibeaux
PO Box 352, Waco, TX 76703 • 713-510-7714 • jennthibeaux@gmail.com

CASE COMMUNICATION BETWEEN PLAINTIFF AND DEFENDANT


Date & Time Form FROM TO Content
05/21/2018 Email PLAINTIFF DEFENDANT Plaintiff’s Counsel Sharma emailed to forward
16:45 CDT Anjali Jennifer two PDF documents - #1 Plaintiff’s Answers to
Sharma Thibeaux Defendant’s 2nd Request for Production and
Defendant’s Request for Interrogatories; #2
Additional Production Evidence Bates labeled
DURAN 000143 – 000228.

NOTE: Plaintiff’s responses were served after


the close of the discovery period and are not
allowable to be used in trial. Additionally,
Plaintiff’s Interrogatories were not signed by
Plaintiff or taken under oath per T.R.C.P. Rule
197.2(d). Plaintiff’s production evidence
contained 91 total pages with 76 duplicated
documents (only 15 unique documents)
05/23/2018 Email DEFENDANT PLAINTIFF Defendant replied to Plaintiff’s Counsel
11:45 CDT Jennifer Anjali Sharma with this document outlining issues
Thibeaux Sharma throughout the entire case.

NOTE: Plaintiff’s Counsel did not reply in any


form.

Page 76 of 76