4/5/2023 10:11 PM
Marilyn Burgess - District Clerk Harris County
Envelope No. 74388666
By: MARCELLA WILES
Filed: 4/5/2023 10:11 PM
CAUSE NO. 2022-67181
JANE DOE § IN THE DISTRICT COURT OF
§
Plaintiff, §
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VS § HARRIS COUNTY, TEXAS
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DESHAUN WATSON §
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Defendant. § 113TH JUDICIAL DISTRICT
PLAINTIFF’S SECOND AMENDED NOTICE OF INTENT TO TAKE
THE ORAL DEPOSITION OF DEFENDANT DESHAUN WATSON
TO: DESHAUN WATSON, Defendant, by and through his attorney of record, RUSTY
HARDIN, 1401 McKinney Street, Suite 2250, Houston, Texas 77010.
Please take notice that pursuant to Texas Rules of Civil Procedure 199.2, Plaintiff will take
the oral deposition of Defendant, DESHAUN WATSON, on Monday, April 10, 2023, at 10:00
A.M. CST at 1401 McKinney Street, Suite 2250, Houston, Texas 77010. The deposition will
continue from day to day until completed. Said deposition, when so taken and returned according
to law, may be used in evidence upon the trial of said cause. The deposition will be recorded
stenographically and will likely be videotaped pursuant to Rule 199.1(c) of the Texas Rules of
Civil Procedure.
Pursuant to Texas Rules of Civil Procedure 199.2(b)(5), 193, and 196, Defendant,
DESHAUN WATSON, is commanded to produce the following documents at the time and place
of the oral deposition:
1. Cell phone records reflecting all telephone calls Defendant made to Plaintiff in
December 2020 and January 2021;
2. Cell phone records reflecting all text messages Defendant sent to Plaintiff in
December 2020 and January 2021;
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3. Text messages sent from (347) 996-0866 to Plaintiff from December 2020 to
January 2021;
4. Text messages sent from Defendant to Plaintiff from December 2020 to January
2021;
5. Direct Messages sent from the Instagram Account @deshaunwatson to Plaintiff
from December 2020 to January 2021;
6. Direct Messages received from the Instagram Account @htxmink in December
2020 and January 2021;
7. All correspondence from Defendant to a third party from December 2020 through
December 2021 regarding or relating to Defendant’s meeting with Plaintiff at the
Houstonian on December 18, 2020;
8. All correspondence from Defendant to a third party regarding or relating to the
Plaintiff from December 2020 through December 2021;
9. All receipts, invoices, booking confirmation text messages, and booking
confirmation e-mails related to or reflecting the hotel room used by Defendant at
the Houstonian on December 18, 2020;
10. Documents or records reflecting the person or entity who paid for the hotel room
used by Defendant at the Houstonian on December 18, 2020; and
11. Documents or records reflecting the person or entity who booked the hotel room
used by Defendant at the Houstonian on December 18, 2020.
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Respectfully submitted,
UNIVERSAL LAW GROUP, PLLC
Anissah M. Nguyen
State Bar No. 24072895
Email: anguyen@ulg.law
10350 Richmond Avenue, Suite 450
Houston, Texas 77042
Telephone: (832) 767-0339
Fax: (832) 767-0669
service@ulg.law
COUNSEL FOR PLAINTIFF
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CERTIFICATE OF SERVICE
I certify that on April 5, 2023, a true and correct copy of the foregoing document was
served to each person listed below by the method indicated.
Via E-Service:
RUSTY HARDIN & ASSOCIATES, LLP
Rusty Hardin
rhardin@rustyhardin.com
John MacVane
jmacvane@rustyhardin.com
1401 McKinney Street, Suite 2250
Houston, Texas 77010
Telephone: (713) 652-9000
Facsimile: (713) 652-9800
Anissah M. Nguyen
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Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Sheree Harper on behalf of Anissah Nguyen
Bar No. 24072895
sharper@nguyen-chen.com
Envelope ID: 74388666
Filing Code Description: No Fee Documents
Filing Description: Plaintiffs Second Amended Notice of Intent to take the
Oral Deposition of Defendant Deshaun Watson
Status as of 4/6/2023 9:03 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Universal Law Group service@ulg.law 4/5/2023 10:11:11 PM SENT
Sheree Harper sharper@ulg.law 4/5/2023 10:11:11 PM SENT
Anissah Nguyen anguyen@ulg.law 4/5/2023 10:11:11 PM SENT
Caridad Tanner ctanner@ulg.law 4/5/2023 10:11:11 PM SENT
Ryan K.Higgins rhiggins@rustyhardin.com 4/5/2023 10:11:11 PM SENT
Lara Hollingsworth lhollingsworth@rustyhardin.com 4/5/2023 10:11:11 PM SENT
Leah MGraham lgraham@rustyhardin.com 4/5/2023 10:11:11 PM SENT
John MacVane jmacvane@rustyhardin.com 4/5/2023 10:11:11 PM SENT
Rusty Hardin rhardin@rustyhardin.com 4/5/2023 10:11:11 PM SENT
Letitia Quinones lquinones@rustyhardin.com 4/5/2023 10:11:11 PM SENT
Armstead Lewis alewis@rustyhardin.com 4/5/2023 10:11:11 PM SENT
Julie Ayers jayers@rustyhardin.com 4/5/2023 10:11:11 PM SENT
Sandra Dominguez sdominguez@rustyhardin.com 4/5/2023 10:11:11 PM SENT
Cathy Gibson cgibson@rustyhardin.com 4/5/2023 10:11:11 PM SENT
Stella Jares sjares@rustyhardin.com 4/5/2023 10:11:11 PM SENT
Shannon Campbell scampbell@rustyhardin.com 4/5/2023 10:11:11 PM SENT
