BRANDON ROCKETTS INTERROGATORIES TO PLAINTIFF SET ONE

Brandon Rockett

11902 Highland Oaks Trail

Austin, TX 78759

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Defendant in pro per

IN THE COUNTY COURT AT LAW NO. 1

TRAVIS COUNTY, TEXAS

TOM HOSKINS,Plaintiff,vs.BRANDON ROCKETT AND WYATT GILES, D/B/A ROCK SOLID CONSTRUCTION,Defendants Case No.: NumberBRANDON ROCKETT’S INTERROGATORIES TO PLAINTIFF, SET ONE

PROPOUNDING PARTY: Defendant BRANDON ROCKETT

RESPONDING PARTY: Plaintiff TOM HOSKINS

To Tom Hoskins and his attorney:

Defendant Brandon Rockett requests that Tom Hoskins responds to the following interrogatories separately and fully in writing and under oath, pursuant to Tex. R. Civ. P. 197, and that the Response be signed by the person making them and be served on Brandon Rockett, pursuant electronic service already agreed to by the parties, within 30 days from the date of service.

In answering these interrogatories, furnish all information that is available to you. If you cannot answer an interrogatory completely, answer it to the extent possible. If you do not have personal knowledge sufficient to respond fully to an interrogatory, so state, but make a reasonable and good faith effort to obtain the information by inquiry to other natural persons or organizations, unless the information is equally available to the propounding party.

INTERROGATORY NO. 1: What was the age and condition of the existing floor?

INTERROGATORY NO. 2: You told Brandon that your granddaughter caused a great deal of damage to the floors. Please explain how the floors were damaged and where the damage occurred.

INTERROGATORY NO. 3: Brandon repaired the floors several years before and recalled there being extra flooring left from the repair. You had supplied the materials for the repair. Why were these materials or any information regarding these materials not made available to Brandon at the time he started the job?

INTERROGATORY NO. 4: Do you believe the existing floor was a good match compared to the new upgrade that was being done to the house?

INTERROGATORY NO. 5: At any time before or during the job, did you ask to; or did Brandon agree to pay for hotel costs?

INTERROGATORY NO. 6: At any time before or during the job, did you ask to; or did Brandon agree to pay for storage of your personal things?

INTERROGATORY NO. 7: Did you ever discuss a deadline for Brandon to finish the job in order to get paid?

INTERROGATORY NO. 8: Brandon has asked you multiple times to provide any information on the existing flooring, once during the repair and again during the finishing. Have you been able to accommodate that request?

INTERROGATORY NO. 9: You informed Brandon via text message that you had no less than 3 flooring professionals (experts) inspect the floor. Do you have any documentation containing their report or written statement?

INTERROGATORY NO. 10: Did you ask Brandon to attend any meetings you had with anyone in regard to the appearance of the floors?

INTERROGATORY NO. 11: If you did have the floors replaced as you continuously claim, please specify actual flooring purchased and include a receipt of the purchase and invoice for the labor.

INTERROGATORY NO. 12: Do you still believe that the wear layer was compromised during the finishing of the floor?

Dated this 31st day pf January, 2022.

Respectfully Submitted,

___________________________________

Brandon Rockett

Defendant in pro per

DECLARATION OF BRANDON ROCKETT

I, Brandon Rockett declare:

  1. I am a party to this action or proceeding appearing in propria persona.
  2. I am propounding to Plaintiff the attached set of interrogatories.
  3. This is the first set of special interrogatories propounded by Brandon Rockett to Plaintiff.
  4. I am familiar with the issues and the previous discovery conducted by all of the parties in the
  5. case.
  6. I have personally examined each of the questions in this set of interrogatories.
  7. None of the questions in this set of interrogatories is being propounded for any improper
  8. purpose, such as to harass the party, or the attorney for the party, to whom it is directed, or to cause unnecessary delay or needless increase in the cost of litigation.

I declare under penalty of perjury under the laws of Texas that the foregoing is true and correct,

and that this declaration was executed on January 31st, 2022.

Respectfully Submitted,

___________________________________

Brandon Rockett

Defendant in pro per

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