CAUSE NO. 22456
DONALD LOUGHRAN AND LINDA § IN THE DISTRICT COURT OF
LOUGHRAN, INDIVIDUALLY AND §
AS NEXT FRIEND TO M.L., A MINOR §
§
Plaintiffs, §
§
V. §
§
JIMMY SANDERS, JR., §
OTMANE BARRE D/B/A § DALLAS COUNTY, TEXAS
COMPLETE AUTO GROUP, §
LKQ AUTO PARTS OF NORTH §
TEXAS, L.P., §
LORENTZ AUTOMOTIVE, INC., AND §
CLASSIC K CARROLLTON LLC §
D/B/A §
CLASSIC KIA OF CARROLLTON, §
§
Defendants. § 51ST JUDICIAL DISTRICT
DEFENDANT JIMMY SANDER’S INITIAL DISCLOSURES
TO: Plaintiffs, Donald Loughran, Linda Loughran, through attorney of record, E. Todd
Tracey, 4701 Bengal St. Dallas, Texas 75235.
Defendant, Jimmy Sanders, Jr. serves these initial disclosures required by Texas Rule of
Civil Procedure 194.2.
1. Disclosure under Rule 194.2(b)(1): The correct names to the parties of the lawsuit are as
follows:
RESPONSE: Jimmy Sanders, Jr. states that his correct name has been used by Plaintiffs in this
lawsuit. Jimmy Sanders, Jr. has no knowledge if the Plaintiffs and Intervenors have been
correctly named.
1
Defendant’s
This study source Responsesby
was downloaded to 100000899606070
Plaintiff’s Requestsfrom
for Disclosure
CourseHero.com on 02-21-2026 21:50:00 GMT -06:00
https://www.coursehero.com/file/206070736/DisclosureAssn3docx/
, 2. Disclosure under Rule 194.2(b)(2): The names, addresses, and telephone numbers of
potential parties are as follows.
RESPONSE: Defendant’s place of business, 14832 Venture Drive, Farmers Branch, Texas
75234.
Phone numbers are unknown.
3. Disclosure under Rule 194.2(b)(3): The legal theories and, in general, the factual bases of
the responding party's claims or defenses (the responding party need not marshal all evidence
that may be offered at trial).
RESPONSE: Defendant had the vehicle examined by Classic Kia after he purchased it and had
Auto Parts of North Texas install a new airbag. The vehicle passed inspection before he sold it.
Sanders was not aware of any other problems.
4. Disclosure under Rule 194.2(b)(4): The amount and any method of calculating economic
damages.
RESPONSE: Defendant seeks no economic damages.
5. Disclosure under Rule 194.2(b)(5): The name, address, and telephone number of persons
having knowledge of relevant facts, and a brief statement of each identified person's connection
with the case.
RESPONSE: No information at the moment. Need to meet with client.
6. Disclosure under Rule 194.2(b)(6): A copy–or a description by category and location–of
all documents, electronically stored information, and tangible things that the responding party
2
Defendant’s
This study source Responsesby
was downloaded to 100000899606070
Plaintiff’s Requestsfrom
for Disclosure
CourseHero.com on 02-21-2026 21:50:00 GMT -06:00
https://www.coursehero.com/file/206070736/DisclosureAssn3docx/
DONALD LOUGHRAN AND LINDA § IN THE DISTRICT COURT OF
LOUGHRAN, INDIVIDUALLY AND §
AS NEXT FRIEND TO M.L., A MINOR §
§
Plaintiffs, §
§
V. §
§
JIMMY SANDERS, JR., §
OTMANE BARRE D/B/A § DALLAS COUNTY, TEXAS
COMPLETE AUTO GROUP, §
LKQ AUTO PARTS OF NORTH §
TEXAS, L.P., §
LORENTZ AUTOMOTIVE, INC., AND §
CLASSIC K CARROLLTON LLC §
D/B/A §
CLASSIC KIA OF CARROLLTON, §
§
Defendants. § 51ST JUDICIAL DISTRICT
DEFENDANT JIMMY SANDER’S INITIAL DISCLOSURES
TO: Plaintiffs, Donald Loughran, Linda Loughran, through attorney of record, E. Todd
Tracey, 4701 Bengal St. Dallas, Texas 75235.
Defendant, Jimmy Sanders, Jr. serves these initial disclosures required by Texas Rule of
Civil Procedure 194.2.
1. Disclosure under Rule 194.2(b)(1): The correct names to the parties of the lawsuit are as
follows:
RESPONSE: Jimmy Sanders, Jr. states that his correct name has been used by Plaintiffs in this
lawsuit. Jimmy Sanders, Jr. has no knowledge if the Plaintiffs and Intervenors have been
correctly named.
1
Defendant’s
This study source Responsesby
was downloaded to 100000899606070
Plaintiff’s Requestsfrom
for Disclosure
CourseHero.com on 02-21-2026 21:50:00 GMT -06:00
https://www.coursehero.com/file/206070736/DisclosureAssn3docx/
, 2. Disclosure under Rule 194.2(b)(2): The names, addresses, and telephone numbers of
potential parties are as follows.
RESPONSE: Defendant’s place of business, 14832 Venture Drive, Farmers Branch, Texas
75234.
Phone numbers are unknown.
3. Disclosure under Rule 194.2(b)(3): The legal theories and, in general, the factual bases of
the responding party's claims or defenses (the responding party need not marshal all evidence
that may be offered at trial).
RESPONSE: Defendant had the vehicle examined by Classic Kia after he purchased it and had
Auto Parts of North Texas install a new airbag. The vehicle passed inspection before he sold it.
Sanders was not aware of any other problems.
4. Disclosure under Rule 194.2(b)(4): The amount and any method of calculating economic
damages.
RESPONSE: Defendant seeks no economic damages.
5. Disclosure under Rule 194.2(b)(5): The name, address, and telephone number of persons
having knowledge of relevant facts, and a brief statement of each identified person's connection
with the case.
RESPONSE: No information at the moment. Need to meet with client.
6. Disclosure under Rule 194.2(b)(6): A copy–or a description by category and location–of
all documents, electronically stored information, and tangible things that the responding party
2
Defendant’s
This study source Responsesby
was downloaded to 100000899606070
Plaintiff’s Requestsfrom
for Disclosure
CourseHero.com on 02-21-2026 21:50:00 GMT -06:00
https://www.coursehero.com/file/206070736/DisclosureAssn3docx/
