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Litigate the matter as aggressively as possible in order to show that he is not responsible for the claims raised by plaintiff.
Reviewed the file and am noticing some gaps in the plaintiff's fact pattern.
Request for production
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Prepare all necessary discovery responses and notices for the Diaz matter

Diaz_RFP_Responses.docx
DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST REQUESTS FOR PRODUCTION
Defendant Anthony Diaz serves these responses and objections to Plaintiff's First Requests for Production pursuant to Rule 196 of the Texas Rules of Civil Procedure, as follows:
REQUEST FOR PRODUCTION NO. 1: All documents concerning the claims and allegations asserted in Plaintiff's Original Petition.
RESPONSE: Defendant will produce all non-privileged, responsive documents in his possession, custody, or control.
REQUEST FOR PRODUCTION NO. 2: All communications between Defendant and any third party regarding the transactions made the basis of this suit.
RESPONSE: Defendant objects that this request is overbroad and unduly burdensome. Subject to that objection, responsive non-privileged communications will be produced.
REQUEST FOR PRODUCTION NO. 3: All documents Defendant intends to offer as evidence at the trial of this cause.
RESPONSE: Defendant has not yet determined its trial exhibits and will supplement this response as discovery continues.
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