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CAUSE NO. 18-6796-393
JOHN T. THORNGRFN,
5
IN THE DISTRICT COURT OF
§
Plaintiff,
5
§
v.
§
DENTON COUNTY, TEXAS
§
DENTON COUNTY APPRAISAL
DISTRICT,
§
Defendant.
393ko JUDICIAL DISTRICT
DEFENDANT'S RESPONSES TO
PLAINTIFF'S REQUESTS FOR ADMISSIONS
TO
Plaintiff. John T. Thorngren, pre se, (" Plaintiff") P O. Box 718, Lake Dallas, Texas
75016; I.E. \ A Nr)c, tE,chartvr.n.21.
in accordance with Rule 19R of the Texas Rifles of Civil Proceilu rt., Denton Central
Appraisal District ("Denton CAD" or "Defendant") cuhmiLc the folkAving oblections and
responses to the 'discovery requests- that appear to have been submitted pursuant to
Rule t9S confined within "Plaintiff's Amended Re-Plead Petition for St tutor Basis"
filed with the Court on Novemb•.,_r
14. 201H and served tin counsel for Defendant on
November 14, 201ti
RESPONSES TO REQUESTS FOR ADMISSION
REQUEST FOR ADMISSION CONTAIN ED. WITHIN 5.4:
Plain ti ti seeks a separate rule of discovery as to an Admission pursuant to
19K.1
regarding the +idler party to admit the truth of any matter within the scope of discovery
for 5.2
ftEs roN S F.:
Defendant objects to this request as vague. contusing and misleading as phrased.
It is not clear to Defendant exactly what it is being asked to admit because of Plaintiff's
use of the phrase, "a separate rule of discovery as to an Admission pursuant to I98.1"
and Plaintiff's undefined reference to 52. Defendant further objects to this request to the
RE5PONSEi TO P .11 NTI fT'S
FON MMUS'S:10%S
il;F
extent that it seeks an admission for admissions) regarding anything that is not relevant,
01- regarding anything that is not reasonably calculated to lead to the discovery of
admissible evidence
%bled thereto and without waiving same, this request for
admission is denied.
REQUEST FOR ADMISSION CONTAINED WITHIN 5.5:
Plaintiff seeks a separate rule of discovery as to an Admission pursuant to
198,1.
regarding the other part,, to admit the truth of any matter within the scope of discovery
for 5.3.
RESPONSE:
Defendant objects to this request as vague, confusing and misleading as phrased.
It is not clear to Defendant exactly what it is being asked to admit because of Plaintiffs
use of the phrase. "a separate rule of discovery as to an Admission pursuant to
198.1"
and Plaintiff's undefined reference to 5-3. Defendant further objects to this request to the
extent that it seeks an admission (or admissions) regarding anything that is not relevant,
or regarding anything that is not reasonably calculated to lead to the discovery of
admissible evidence. Subject thereto and without waiving same, this request for
admission is denied.
REQUEST FOR ADMISSION CONTAINED WITHIN 5.6.:
Plaintiff seeks a separate rule of discover,. as to an Admission pursuant to I98.2(c)
regarding a response must fairly meet the substance of the request for 5.2.
RESPONSE;
Defendant objects to this request as vague, confusing and misleading as phrased.
it is not clear to Defendant exactly what it is being asked to admit because of Plaintiff's
LL4i2 of the phrase. "a separate rule of discovery as to an Admission pursuant to
198.2
(c)
regarding a respose must fairly meet the substance of the request for 5_2" and Plaintiff's
undefined reference to 5.2. Defendant further obiects to this request to the extent that it
seeks an admission (or admissions) regarding anything that is not relevant, or regarding
anything that is not reasonably calculated to lead to the discovery of admissible evidence.
Subject thereto and without waiving same, this request for admission is denied.
REQUEST FOR ADMISSION CONTAINED WITHIN 5.7i
Plaintiff seeks a separate rule of discovery as to an Admission pursuant to 198.2(c)
regarding a response must fairly meet the substance of the request for 5.3
RESPONSE:
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Defendant objects to this request as vague, confusing and misleading as phrased.
It is not clear to Defendant exactly what it is being asked to admit because of Plaintiff's
use of the phrase, "a separate rule of discovery as to an Admission pursuant to 198.2(c)
regarding a response must fairly meet the substance I )t the request for 5,3'r and Plaintiff's
undefined reference to 5.3. Defendant further objects to this request to the extent that it
seeks an admission (or admissions) regarding anything that is not relevant, or regarding
anything that isnot reasonably calculated to lead to the discovery of admissible evidence.
Subject thereto and without waiving same, this request for admission is denied.
Respectfully submitted,
SH ;CKELFORD, BO WEN. MCI [NIIA 45.t
NORTON. LLP
By: Ai David i Tabor
_
David H. -Fabor
State Bar No. 24037577
9201 N. Central Expressway
Fourth Floor
Dallas, Texas 73231
(214) 780-1400
(214)780-1401
[Fax'
d ta bor0; s h ac ke I ford law.net
oRNE-ys FL'K DEFEN DANC DEVION CENTRAL
APPRAISAL DISTRICT
CERTIFICATE OF SERVICE
I hereby certify that on this 17'1' day of December 2018 the foregoing document
has been served on the following parties in accordance with Rule 21 of the 11-A(B Rules of
Procrituri. via eservice through eFlieTexas.gol.. on:
John T. Thorrigren, Pro Se
P. O. Box 718
Lake Dallas. Texas 75076
TEA ANN.{ }r p r.Charter.net
is Darild B. Tabor
David B. Tabor
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