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Request For Discovery Deposition Oct09

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23 October 2009 To: Greg Abbott, Texas Attorney General , c/o Mark Steinbach, Assistant Attorney General P.O. Box 12548, Capitol Station, Austin, Texas 78711-2548 Fr: Daniel W. Harbaugh, 8218 Braniff St., Houston, TX 77061

Re: Cause No. 070423

Harbaugh v. TCEQ

FIRST REQUEST FOR DISCOVERY DEPOSITION
Pursuant to the stated mission of and informal procedures afforded in Texas Small Claims Court actions, Plaintiff hereby requests the following: (A)) A statement by the TCEQ/Houston-Galveston Area Council(HGAC) /AirCheckTexas Repair & Replacement Assistance Program, so named as Mr. Ronnie Barnes, Project Coordinator, per official published records, and/or, such person or persons responsible for the issuance of HGAC Voucher Number 41170 on 4/16/2009 12:19:17 PM to Daniel Harbaugh ;stating: (1) How and Why this Voucher was issued as a "Replacement Only" when the Applicant specifically applied for a "Repair" Voucher" valued up to $600.00, and: (2) How and Why the Applicant was not afforded a letter stating he was ineligible for a Repair Voucher, per HGAC official and published information: "Get A Voucher" , "If you are eligible, we'll send your voucher to your mailing address with instructions on how to use it and a list of participating repair facilities and dealers. If you are not eligible, we'll send you a letter describing why you are unable to receive a voucher." , and: (3) How and Why the Applicant's email of 4/23/2009 12:21 PM to HGAC , per: "Get A Voucher ... Direct questions about applications to us at airchecktexas@h-gac.com , with email subject "Request for REPAIR voucher #41170", submitted prior to any repair efforts, was not responded to.. (B) This First Request For Discovery Deposition may be complied with by 'eDiscovery' / email, or by USPS Certified Mail. The information sought must be specific in the response; lacking same, Plaintiff will file for a ‘Supoena For Witness Deposition Pursuant To Texas Rules Of Civil Procedures 176/201’ on Cause No. 070423 pending in the Travis County Small Claims Court. Relevant to Request: Plaintiff's original Small Claims Petition on Cause No. SC210027605 states: "..due to failure of H-GAC to comply with LIRAP provisions Chapter 382.209 TX Health & Safety Code/AirCheckTexas .." , thus identifies H-GAC as a principal party in this Petition and therefore entitles Plaintiff to seek Deposition from same. Sincerely, Daniel W. Harbaugh Copy To: Judge Herb Evans, Justice Of The Peace, Precinct 5 , P.O. Box 1748 , Austin, Texas 78767 , Mr. Ronnie Barnes, AirCheckTexas

Project Coordinator, HGAC , P.O. Box 22777,

Houston, TX 77227-2777


								
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