Case No. ______________
WILLIAM KITCHEN,
Plaintiff
vs.
TRACY JOSEPH,
Defendant
IN THE DISTRICT COURT OF
_______________ COUNTY, TX
_________ JUDICIAL DISTRICT
MOTION FOR DISCOVERY
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES WILLIAM KITCHEN, the Plaintiff in the above cause, under the
authority of Rule 190.4 of the Texas Rules of Civil Procedure, and makes his Motion for
Discovery, and in support thereof would show the Court as follows:
The Defendant moves the Court to order the Defendant to produce and permit the
inspection of and the copying and/or photographing of, by or on behalf of the Plaintiff, the
following designated items:
1. Any and all documents, statements, reports, notes, or any other documents that support or
dispute the substance of the evidence the Defendant intends to offer at trial. The
documents must include, without limitation:
i. The sublease agreement
ii. The lease agreement between Defendant and the Landlord of the property
iii. Other relevant records and/or documents relating to Defendant’s lease of the
property
2. All documents maintained by Defendant regarding Plaintiff’s sublease.
3. All bills, invoices, or proof of any payments made by Plaintiff to Defendant regarding the
sublease.
4. All documents Defendant intends to introduce as evidence at the trial in this action.
5. All written reports of all potential witnesses with whom Defendant or Defendant’s
attorneys have consulted.
6. All notes, correspondence, bills, invoices, or other documents prepared or reviewed by
each person whom Defendant expects to call as a witness at trial.
7. Any document prepared during the regular course of business as a result of the wrongful
eviction and the harassment complained of in the Plaintiff’s Complaint.
8. Copies of any treaties, standards in the industry, legal authority, rule, case, statute, or
code that will be relied upon in the case.
9. All written communications, applications, correspondence or records thereof relating to
the sublease.
10. All accounts, ledgers, records or other documents including payment receipts, notes, and
memoranda in which the Defendant has recorded any debits and credits made to the
Defendant’s account.
WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully prays that this
Honorable Court will grant Plaintiff’s Motion for Discovery or in the alternative, that this Court
will set this matter down for a hearing prior to trial on the merits and that at such hearing this
Motion will be in all things granted.
Respectfully submitted,
Dated: __________
______________________________
WILLIAM KITCHEN
7650 S. McClintock Dr. #103-300
Tempe, AZ 85286
Plaintiff Pro se
Case No. ______________
WILLIAM KITCHEN,
Plaintiff
vs.
TRACY JOSEPH,
Defendant
IN THE DISTRICT COURT OF
_______________ COUNTY, TX
_________ JUDICIAL DISTRICT
PROPOSED ORDER ON PLAINTIFF’S MOTION FOR DISCOVERY
Upon the foregoing Plaintiff’s Motion for Discovery, it is hereby ORDERED that such
Motion be, and hereby is, GRANTED.
It is further ORDERED that the Defendant furnish Plaintiff with access to those items
granted hereby, on or before days after the date this order is signed, at such other time
and place as the parties may agree.
SIGNED this ______ day of __________________, 2023.
_________________________________
JUDGE PRESIDING
CERTIFICATE OF SERVICE
I hereby certify on the ____________day of _______________, 2023, that a true and correct
copy of the foregoing Motion were served by placing a copy in the United States Postal Service,
with postage prepaid, addressed upon the following:
SERVICE ON:
Tracy Joseph
11655 Briar Forest Dr.
Phase 1, Building 5, Apartment 61
Houston, TX 77077
______________________________
WILLIAM KITCHEN
7650 S. McClintock Dr. #103-300
Tempe, AZ 85286
Plaintiff Pro se
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