initial disclosure as defense counsel for the following allegations:

NO.1202840

IPFS CORPORATION				IN THE COUNTY CIVIL COURT
VS.				AT LAW NO.2
BREAKTIME CORNER MARKET
KANSAS, LLC also known as
BREAKTIME CORNER
MARKET 6, LLC				HARRIS COUNTY TEXAS

PLAINTIFF'S INITIAL DISCLOSURE RESPONSES

TO: BREAKTIME CORNER MARKET KANSAS, LLC also known as BREAKTIME CORNER MARKET 6, LLC, Defendant, by and through Defendant's attorney of record, Sara Richey, 11777 Katy Freeway, Suite 335 Houston, TX 77079; Email:

COMES NOW IPFS Corporation, Plaintiff, and serves herewith its Initial Disclosure Responses to Defendant pursuant to Rule 194.2.

1. the correct names of the parties to the lawsuit [if different than as sued] Response: As sued.
2. the name, address, and telephone number of any potential parties:

Response: None at this time.

1. the legal theories and, in general, the factual bases of our claims or defenses:

Response: Plaintiff's action is founded upon the note made a part of Exhibit "A" hereto, all incorporated herein by reference, all hereafter the "Instrument" or "Instruments". Defendant requested and received the premium financing therein described at the agreed prices charged or at the reasonable market value. Defendant or its authorized agent signed the premium finance agreement and promised to pay Plaintiff, a lender, on the note according to its specified terms, but the note remains unpaid, damaging Plaintiff with interest at law or as agreed in each Instrument, and for attorneys' fees.

Plaintiff's cause of action is founded upon the account that has arisen from the breach of the note and all attachments in said Exhibit "A". Plaintiff is the payee and the owner and holder of each Instrument. Defendant or its authorized agent signed each Instrument. Plaintiff is the party entitled to sue on all the Instruments.Each instrument matured and remain unpaid.

Defendant has not fully paid on any Instrument. That after this account was presented to Defendant, Defendant acknowledged the amount demanded as justly due and owing. Plaintiff's damages for its unpaid account are $14,585.47.

In the alternative, Plaintiff's cause of action is founded upon each note made Exhibit "A", hereto, incorporated herein by reference, all hereafter the "Instrument" or "Instruments". Each Defendant or its authorized representative made and executed each Instrument. Each Instrument is payable to Plaintiff.

Plaintiff is the payee, owner, and holder of each Instrument. Plaintiff is the party for whose benefit each Instrument was drawn. Plaintiff is the party entitled to sue on all the Instruments. Each note matured or was accelerated and remain unpaid.Defendant or its authorized agent signed the premium finance agreement . The Defendant has not fully paid on any Instrument. The Defendant promised to pay Plaintiff but Plaintiff's debt remains unpaid, damaging Plaintiff with interest as agreed in each Instrument. Plaintiff's damages for its unpaid account are $14,585.47.

1. the amount and any method of calculating the Money sued for - or any other economic damages;

Response: Plaintiff's damages for its unpaid account are $14,585.47plus interest as agreed upon, court costs and reasonable attorneys' fees.

1. the name, address, and telephone number of EVERY person with knowledge of ANY relevant facts, and a brief statement of each identified person's connection with and knowledge of the case;

Response:

Jack Young.Central Region Operations Manager.(816) 412-6424. &..g@ipfs.comMr. Young is the Central Region Operation Manager which includes the Houston TX branch office. Mr. Young is responsible for the branch operations and managing agency relationships.

Diana Boyer.Regional Cancellations Manager.(816) 410-5132. &..r@ipfs.com Ms. Boyer is the Collections Manager for the central region which includes the Houston TX branch office. Ms Boyer supervises the collections group in its work with carriers, general agents, agents for the return of unearned premium on cancelled accounts.

Melissa Waal.Litigation Recovery Manager.(201) 631-5442. &..l@ipfs.com Ms. Waal is the custodian of business records.

1. a copy-or a description by category and location-of all documents, electronically stored information, and tangible things that the responding party has in its possession, custody, or control, and may use to support its claims or defenses, unless the use would be solely for impeachment

Response: See Exhibit Documents.

1. any indemnity and insuring agreements described in Rule 192.3(f):

Response: NA.

1. any settlement agreements described in Rule 192.3(g):

Response: NA.

1. all witness statements:

Response: NA.

1. in a suit alleging physical or mental injury and damages from the occurrence that is the subject of the case, all medical records and bills that are reasonably related to the injuries or damages asserted or, in lieu thereof, an authorization permitting the disclosure of such medical records and bills:

Response: NA.

1. in a suit alleging physical or mental injury and damages from the occurrence that is the subject of the case, all medical records and bills obtained by the responding party by virtue of an authorization furnished by the requesting party:

Response: NA.

1. the name, address, and telephone number of any person who may be designated as a responsible third party:

Response: NA.

194.3 Testifying Expert Disclosures.

In addition to the disclosures required by Rule 194.2, a party must disclose to the other parties testifying expert information as provided by Rule 195

Response: Stephen E. Price, J. Javier Anziani, Richard Castillo

1102 West Avenue, Suite 200

Austin, Texas 78701

512.687.0900 Fax: 512.687.0795

(2) the subject matter on which the expert will testify:

Response: Attorneys' Fees.

NO.1202840

IPFS CORPORATION				IN THE COUNTY CIVIL COURT
VS.				AT LAW NO.2
BREAKTIME CORNER MARKET
KANSAS, LLC also known as
BREAKTIME CORNER
MARKET 6, LLC				HARRIS COUNTY TEXAS

CERTIFICATE OF SERVICE

I hereby certify that on October 17, 2023 , a true and correct copy of Plaintiff's Initial

Disclosure Responses were served via email and/or e-filing on all counsel of record at:

s..a@thericheylawfirm.com

/S/ Javier Anziani

An Attorney for Plaintiff

NO.1202840

IPFS CORPORATION				IN THE COUNTY CIVIL COURT
VS.				AT LAW NO.2
BREAKTIME CORNER MARKET
KANSAS, LLC also known as
BREAKTIME CORNER
MARKET 6, LLC				HARRIS COUNTY TEXAS

CERTIFICATE OF WRITTEN DISCOVERY

I hereby certify that I have served Plaintiff's Initial Disclosure Response on Defendant's attorney by email and/or e-filing on: October 17, 2023.

Respectfully submitted,

FREEDMAN, PRICE & ANZIANI, P.C.

Attorneys for Plaintiff

/S/ Javier Anziani

By:_______________________

J. JAVIER ANZIANI

1102 West Avenue, Suite 200

Austin, Texas 78701

512.687.0900 713.349.0088

Fax: 512.687.0795

State Bar No. 24053076

&..i@freedmanprice.com