Preview
FILED
7/23/2021 12:33 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Jeremy Jones DEPUTY
CAUSE N0. DC-20-12709
ASHANTI BOYD § IN THE DISTRICT COURT
Plainufl/Counter-Defendant §
§
Vs. § 192““ JUDICIAL DISTRICT
§
MARIA ZUNIGA HERRERA §
Defendant/Counter-Plaintifi" § DALLAS COUNTY, TEXAS
PLAINTIFF’S SUPPLEIVIENTAL DISCLOSURES AND
EXPERT WITNESS DESIGNATION
COMES NOW Plaintiff Ashanti Boyd and files this, her Supplemental Disclosures and
Expert Witness Designation, and designates the following persons as expert witnesses who might
be called by Plaintiff to testify at the time of trial in this case:
Plaintiff incorporates herein by reference Plaintiff’s Response to Defendant’s Request for
Disclosure (and all amendments and supplements thereto) together with all other discovery
responses previously served on Defendant and designates her expert witnesses as follows:
NON-RETAINED EXPERTS:
Plaintiff’s Treating Physicians and Other Persons with Knowledge of Relevant
Facts That May Qualify as Experts but Have Not Been Specially Retained
(Fact Experts - TEX. R. CIV. P. 194.2(1))
The following person(s), or their custodian(s) of records, have not been retained by and
are not employed by, or are otherwise subject to the control of Plaintiff (hereinafter referred to as
"non-retained" experts), but are hereby designated as testifying experts by Plaintiff and the
following information is provided in accordance with Texas Rule of Civil Procedure 194.2.
Although these witnesses have not been specifically retained as expert witnesses by
Plaintiff and while Plaintiff cannot vouch for the expertise or credibility of such witnesses at this
time, it is believed that they may have knowledge, training or expertise which may qualify them
as experts. Accordingly, Plaintiff will designate these witnesses as persons who may be called
upon to give testimony that would be considered expert testimony.
The following healthcare providers, and/or the custodian(s) of their records, may testify
regarding the injuries sustained by Plaintiff in the incident made the subject of this suit, their
Plaintiff’s Supp. Responses to RFD and Designation of Expert Witnesses Page 1of 8
medical diaglosis, prognosis and the reasonable and necessary cost of hospital, doctor and
medical bills for treatment of Plaintiff’s injuries in the past and in the fiiture.
Please refer to the healthcare providers’ records for their mental impressions, opinions,
conclusions, and the factual basis for each opinion.
NON-RETAINED MEDICAL EXPERTS.
THE FOLLOWING INDIVIDUALS AND ENTITIES AND THEIR CURRENT AND
FORMER OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SERVANTS,
PHYSICIANS, NURSES, PARAMEDICS, EMTs, ATTENDANTS, STAFF,
HEALTHCARE PROVIDERS, AND CUSTODIANS OF RECORDS:
Chicoine Chiropractic Health Centers
Mary Barron, Custodian of Records
6805 Main Street Suite 410
The Colony, TX 75056
Plaintifl’s health care provider
Texas Medicine Resources
Jasmine Gonzales, Custodian of Records
PO Box 8549
Fort Worth, TX 76124
Plaintif’s health care provider
Texas Health Presbyterian
Yamiziana Parks, Custodian of Records
Sharon Nichols, Custodian of Records
6200 W. Parker Road
Plano, TX 75093
Plaintifl’s health care provider
Texas Health Plano
Dr. William Stanley Peterson
Adayat Aminu, Custodian of Records
6200 West Park Rd.
Plano, TX 75093
Plaintiff’s health care provider
Texas Radiology Associates, LLP
Dr. Catherine Fusilier
Amy Glatz, Custodian of Records
1820 Preston Park Blvd #2400
Plano, TX 75093
Plaintifi"’s health care provider
Plaintiffs Supp. Responses to RFD and Designation of Expert Witnesses Page 2 of 8
1. Subject Matters of Non-Retained Medical Experts. The subject matters on which said
non-retained non-controlled medical experts will testify are as follows:
a. the existence, nature and/or extent of the injuries sustained by Plaintiff as a result
of the Subject collision;
the examination and treatment of the injuries sustained by Plaintiff as a result of
the subject collision;
the type, purpose, extent, results, evaluations and/or interpretations of
examinations, treatments and tests regarding Plaintiff;
recommendations, diagnosis and prognosis with regard to the injuries of Plaintiff,
including the need for future medical care and the cost of filture medical care;
the existence, nature and/or extent of the injuries and/or incapacities sustained by
Plaintiff in the past as a result of the subject collision, and the reasonable
probability and extent of the injuries and/or incapacities which Plaintiff may
suffer from in the future as a result of the subject collision;
the reasonableness and the necessity of the medical services, medical care,
surgeries, rehabilitation and medications rendered to Plaintiff in the past and those
medical interventions recommended for the future;
the medical care, treatment, surgeries, rehabilitation and medications that have
been required by Plaintiff in the past for the treatment of injuries sustained by
Plaintiff in the subject collision;
the medical care, treatment, surgeries, rehabilitation and medications that will be
required by Plaintiff in the fixture for the treatment of the injuries Plaintiff
sustained in the subject collision;
the cause of the injuries sustained by Plaintiff to a reasonable degree of medical
probability;
all those subject matters contained, discussed or disclosed in:
(l) the medical records of Plaintiff which have been, and which may hereafter
be, produced in this cause;
(2) any and all medical records affidavits and/or medical billing affidavits
which have been filed, and which may hereafter be filed, in this cause, and
all exhibits thereto;
Plaintiffs Supp. Responses to RFD and Designation of Expert Witnesses Page 3 of 8
(3) the depositions on written questions of Plaintiffs health care providers
which have been taken, and which may hereafier be taken, in this cause,
and all exhibits thereto; and
(4) all written reports of healthcare providers produced during the course of
discovery in this cause.
All of said documents are incorporated herein by reference as though set out at length for
all purposes.
2. Impressions and Opinions of Non-Retained Medical Experts. The general substance of
said non-retained/non—controlled medical experts' mental impressions and opinions are expected
to be, and a brief summary of the basis for them are, as follows:
a. the nature, extent and severity of Plaintiff’s injuries;
b. that Plaintiff’s injuries (described in Plaintiff’s medical records), including but not
limited to, head, back and left arm injuries, are the proximate result in whole fi'om
the incident made the subject of this suit;
the medical care and treatment (including diagnoses, surgeries and rehabilitation)
rendered to Plaintiff was reasonable and/or necessary;
the subject incident did, based on reasonable medical probability, cause all of the
complaints, injuries, and/or incapacities complained of by Plaintiff;
that all medical intervention for treatment/diagnosis (including surgeries,
diagnoses and rehabilitation) of Plaintiff’s injuries was necessitated and
proximately caused by the incident made the subject of this lawsuit;
that the medical expenses of Plaintiff were reasonable and necessitated by the
incident which is the subject of this lawsuit;
that Plaintiff will likely need future medical care, and the details of the same, as a
result of this incident;
all other impressions and/or opinions that are contained, discussed, and/or
disclosed in the following:
(1) the medical records of Plaintiff which have been, and which may hereafier
be, produced in this cause;
(2) the medical records affidavits and medical billing affidavits which have
been filed, and which may hereafter be filed, in this cause and all exhibits
thereto;
Plaintiffs Supp. Responses to RFD and Designation of Expert Witnesses Page 4 of 8
(3) the depositions on written questions of Plaintiff’s health care providers
which have been taken, and which may hereafter be taken, in this cause,
and all exhibits thereto; and
(4) all written reports of healthcare providers produced during the course of
discovery in this cause.
All of said documents are incorporated herein by reference as though set out at length for
all purposes.
3. Brief Summgg of Basis for Immeslions and Qpi-nions. The basis for the foregoing
impressions and opinions of the above named and/or designated expert witnesses are all of the
facts shown by and/or contained in:
a. Physical examinations and medical diagnoses of Plaintiff;
b. All of the medical records (including medical imaging) of Plaintiff produced in
this cause;
c. All depositions taken, and hereafter taken, in this cause, either by written
questions or orally, and all exhibits thereto;
d. The expert reports herein above expressly referred to;
e. All witness statements which may be produced in this cause;
f. All of the photographs and videotape recordings produced in this cause;
g. The Responses to Requests For Disclosure, Responses to Requests For
Production, Answers to Interrogatories, and the Amendments and Supplements
thereto which have been filed by each of the parties in this cause of action;
h. The Pleadings on file in this cause of action; and
i. All documents and tangible things produced in this cause.
NON-RETAINED EXPERTS, OTHER THAN MEDICAL EXPERTS:
Officer Nick Sham #1569
City of Farmers Branch Police Department
Its current and former chief, officers, investigators, detectives, employees, and custodian(s) of
records
3723 Valley View Lane
Farmers Branch, TX 75244
Investigating Officer
Plaintiff‘s Supp. Responses to RFD and Designation of Expert Witnesses Page 5 of 8
The officer is expected to testify regarding his investigation of the subject incident and
the statements made by the parties to the lawsuit.
Plaintiff also incorporates herein by reference all depositions; depositions on written
questions; documents and exhibits attached to or referenced in all depositions; and all documents
produced by any party hereto in disclosures and/or discovery. Any opinions and bases for
opinions discussed in deposition(s) are incorporated herein.
Plaintiff further refers the Defendant to Plaintiff’ s retained and non-retained experts’
files, reports and supplemental reports; initial and supplemental disclosures; pleadings of all
parties; discovery of all parties; depositions and exhibits thereto; medical and billing records;
rebuttal opinions, factual observations, opinions, deposition testimony and/or trial testimony and
deposition exhibits of non-retained experts.
Plaintiff further reserves the right through cross-examination or deposition, to call any
expert witness identified herein by the Defendant.
Plaintiff reserves the right to withdraw the designation of any expert witness and to aver
positively that such previously designated expert will not be called as an expert witness at trial
and to redesignate same as a consulting expert, who cannot be called by opposing counsel.
Plaintiff reserves the right to elicit any expert testimony and/or lay opinion testimony that
would assist the jury in determining material issues of fact and that would not violate the Texas
Rules of Civil Procedure.
Plaintiff reserves all additional rights they may have with regard to expert witnesses and
testimony under the Texas Rules of Civil Procedure, case law and rulings of this Honorable
Court.
Plaintiff reserves the right to elicit expert opinion from any of the desigiated fact
witnesses within any area as to which such person has expertise.
To the extent necessary, this expert designation should be considered a supplement to any
outstanding or fiiture discovery requests served on Plaintiff.
This designation shall serve to supplement Plaintiff’s disclosures, including fact witness
designations, answers to interrogatories, pretrial disclosures, expert witness designations, and
responses to requests for production propounded to Plaintiff by any party inquiring as to expert
witnesses.
Discovery in this matter is still ongoing and Plaintiff reserves the right to supplement this
designation if further discovery reveals the need for additional testimony.
This designation shall serve to supplement Plaintiffs Responses to Defendant’s Request
for Disclosure, including the identification of individuals likely to have discoverable information
Plaintiffs Supp. Responses to RFD and Designation of Expert Witnesses Page 6 of 8
regarding Plaintiffs claims or defenses, Answers to Interrogatories, and Responses to Requests
for Production propounded to Plaintiff by any party inquiring as to expert witnesses.
DATED this 1'5 _
day of July 2021
Respectfully submitted,
SLOAN, HATCHER, PERRY, RUNGE,
ROBERTSON, SMITH & JONES
8mm *1
CARSON R. RUNGE
m
State Bar No. 24059262
crunge@sloanfirm.com
SAVANNAH M. JUDKINS
State Bar No. 24121694
sjudkins@sloanfirm.com
101 East Whaley Street
Longview, Texas 75601
Telephone 903-757-7000
Facsimile 903-757-7574
ATTORNEYS FOR PLAINTIFF
Plaintiffs Supp. Responses to RFD and Designation of Expert Witnesses Page 7 of 8
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document been
forwarded Via efile in accordance with the Texas Rules of Civil Procedure on this Z?)Esday of
July 2021 to the following attorney of record:
Fernando Martinez
Meynier, Reese, Liber & Matte
Preston Plaza
17950 Preston Road Suite 410
Dallas, TX 75252
ATTORNEY FOR DEFENDANT MARIA ZUNIGA HERRERA, As DEFENDANT
Geoffrey E. Schorr
A. Jared Aldinger
Hutton W. Sentell
Schorr Law Firm, P.C.
328 W. Interstate 30, Suite 2
Garland, TX 75043
ATTORNEYS FOR DEFENDANT MARIA ZUNIGA HERRERA, As COUNTER-PLAINTIFF
Richard J. Byrne
Ekvall & Byrne, LLP
4450 Sigma Road, Suite 100
Dallas, TX 75244
ATTORNEY FOR PLAINTIFF ASHANTI BOYD, As COUNTER-DEFENDANT
SAVANNAH M. JUDKINS
Plaintiffs Supp. Responses to RFD and Designation of Expert Witnesses Page 8 of 8
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Donna Rountree on behalf of Savannah Judkins
Bar No. 24121694
drountree@sloanfirm.com
Envelope ID: 55646675
Status as of 7/26/2021 4:00 PM CST
Associated Case Party: ASHANTI BOYD
Name BarNumber Email TimestampSubmitted Status
Geoffrey E.Schorr geoff@schorrfirm.com 7/23/2021 12:33:22 PM SENT
Hutton W.Sentell hutton@schorrfirm.com 7/23/2021 12:33:22 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Carson R.Runge crunge@sloanfirm.com 7/23/2021 12:33:22 PM SENT
Donna Rountree drountree@sloanfirm.com 7/23/2021 12:33:22 PM SENT
Richard J.Byrne rbyrne@ekvallbyrne.com 7/23/2021 12:33:22 PM SENT
Stefan Allen sallen@ekvallbyrne.com 7/23/2021 12:33:22 PM SENT
Savannah Judkins sjudkins@sloanfirm.com 7/23/2021 12:33:22 PM SENT
Lori Sarathy lsarathy@ekvallbyrne.com 7/23/2021 12:33:22 PM SENT
Lillie E.Sanchez lsanchez@ekvallbyrne.com 7/23/2021 12:33:22 PM SENT
Associated Case Party: MARIAZUNIGAHERRERA
Name BarNumber Email TimestampSubmitted Status
Fernando Martinez DALLASHC@PROGRESSIVE.COM 7/23/2021 12:33:22 PM SENT
Preview
FILED 7/23/2021 12:33 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Jeremy Jones DEPUTY CAUSE N0. DC-20-12709 ASHANTI BOYD § IN THE DISTRICT COURT Plainufl/Counter-Defendant § § Vs. § 192““ JUDICIAL DISTRICT § MARIA ZUNIGA HERRERA § Defendant/Counter-Plaintifi" § DALLAS COUNTY, TEXAS PLAINTIFF’S SUPPLEIVIENTAL DISCLOSURES AND EXPERT WITNESS DESIGNATION COMES NOW Plaintiff Ashanti Boyd and files this, her Supplemental Disclosures and Expert Witness Designation, and designates the following persons as expert witnesses who might be called by Plaintiff to testify at the time of trial in this case: Plaintiff incorporates herein by reference Plaintiff’s Response to Defendant’s Request for Disclosure (and all amendments and supplements thereto) together with all other discovery responses previously served on Defendant and designates her expert witnesses as follows: NON-RETAINED EXPERTS: Plaintiff’s Treating Physicians and Other Persons with Knowledge of Relevant Facts That May Qualify as Experts but Have Not Been Specially Retained (Fact Experts - TEX. R. CIV. P. 194.2(1)) The following person(s), or their custodian(s) of records, have not been retained by and are not employed by, or are otherwise subject to the control of Plaintiff (hereinafter referred to as "non-retained" experts), but are hereby designated as testifying experts by Plaintiff and the following information is provided in accordance with Texas Rule of Civil Procedure 194.2. Although these witnesses have not been specifically retained as expert witnesses by Plaintiff and while Plaintiff cannot vouch for the expertise or credibility of such witnesses at this time, it is believed that they may have knowledge, training or expertise which may qualify them as experts. Accordingly, Plaintiff will designate these witnesses as persons who may be called upon to give testimony that would be considered expert testimony. The following healthcare providers, and/or the custodian(s) of their records, may testify regarding the injuries sustained by Plaintiff in the incident made the subject of this suit, their Plaintiff’s Supp. Responses to RFD and Designation of Expert Witnesses Page 1of 8 medical diaglosis, prognosis and the reasonable and necessary cost of hospital, doctor and medical bills for treatment of Plaintiff’s injuries in the past and in the fiiture. Please refer to the healthcare providers’ records for their mental impressions, opinions, conclusions, and the factual basis for each opinion. NON-RETAINED MEDICAL EXPERTS. THE FOLLOWING INDIVIDUALS AND ENTITIES AND THEIR CURRENT AND FORMER OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SERVANTS, PHYSICIANS, NURSES, PARAMEDICS, EMTs, ATTENDANTS, STAFF, HEALTHCARE PROVIDERS, AND CUSTODIANS OF RECORDS: Chicoine Chiropractic Health Centers Mary Barron, Custodian of Records 6805 Main Street Suite 410 The Colony, TX 75056 Plaintifl’s health care provider Texas Medicine Resources Jasmine Gonzales, Custodian of Records PO Box 8549 Fort Worth, TX 76124 Plaintif’s health care provider Texas Health Presbyterian Yamiziana Parks, Custodian of Records Sharon Nichols, Custodian of Records 6200 W. Parker Road Plano, TX 75093 Plaintifl’s health care provider Texas Health Plano Dr. William Stanley Peterson Adayat Aminu, Custodian of Records 6200 West Park Rd. Plano, TX 75093 Plaintiff’s health care provider Texas Radiology Associates, LLP Dr. Catherine Fusilier Amy Glatz, Custodian of Records 1820 Preston Park Blvd #2400 Plano, TX 75093 Plaintifi"’s health care provider Plaintiffs Supp. Responses to RFD and Designation of Expert Witnesses Page 2 of 8 1. Subject Matters of Non-Retained Medical Experts. The subject matters on which said non-retained non-controlled medical experts will testify are as follows: a. the existence, nature and/or extent of the injuries sustained by Plaintiff as a result of the Subject collision; the examination and treatment of the injuries sustained by Plaintiff as a result of the subject collision; the type, purpose, extent, results, evaluations and/or interpretations of examinations, treatments and tests regarding Plaintiff; recommendations, diagnosis and prognosis with regard to the injuries of Plaintiff, including the need for future medical care and the cost of filture medical care; the existence, nature and/or extent of the injuries and/or incapacities sustained by Plaintiff in the past as a result of the subject collision, and the reasonable probability and extent of the injuries and/or incapacities which Plaintiff may suffer from in the future as a result of the subject collision; the reasonableness and the necessity of the medical services, medical care, surgeries, rehabilitation and medications rendered to Plaintiff in the past and those medical interventions recommended for the future; the medical care, treatment, surgeries, rehabilitation and medications that have been required by Plaintiff in the past for the treatment of injuries sustained by Plaintiff in the subject collision; the medical care, treatment, surgeries, rehabilitation and medications that will be required by Plaintiff in the fixture for the treatment of the injuries Plaintiff sustained in the subject collision; the cause of the injuries sustained by Plaintiff to a reasonable degree of medical probability; all those subject matters contained, discussed or disclosed in: (l) the medical records of Plaintiff which have been, and which may hereafter be, produced in this cause; (2) any and all medical records affidavits and/or medical billing affidavits which have been filed, and which may hereafter be filed, in this cause, and all exhibits thereto; Plaintiffs Supp. Responses to RFD and Designation of Expert Witnesses Page 3 of 8 (3) the depositions on written questions of Plaintiffs health care providers which have been taken, and which may hereafier be taken, in this cause, and all exhibits thereto; and (4) all written reports of healthcare providers produced during the course of discovery in this cause. All of said documents are incorporated herein by reference as though set out at length for all purposes. 2. Impressions and Opinions of Non-Retained Medical Experts. The general substance of said non-retained/non—controlled medical experts' mental impressions and opinions are expected to be, and a brief summary of the basis for them are, as follows: a. the nature, extent and severity of Plaintiff’s injuries; b. that Plaintiff’s injuries (described in Plaintiff’s medical records), including but not limited to, head, back and left arm injuries, are the proximate result in whole fi'om the incident made the subject of this suit; the medical care and treatment (including diagnoses, surgeries and rehabilitation) rendered to Plaintiff was reasonable and/or necessary; the subject incident did, based on reasonable medical probability, cause all of the complaints, injuries, and/or incapacities complained of by Plaintiff; that all medical intervention for treatment/diagnosis (including surgeries, diagnoses and rehabilitation) of Plaintiff’s injuries was necessitated and proximately caused by the incident made the subject of this lawsuit; that the medical expenses of Plaintiff were reasonable and necessitated by the incident which is the subject of this lawsuit; that Plaintiff will likely need future medical care, and the details of the same, as a result of this incident; all other impressions and/or opinions that are contained, discussed, and/or disclosed in the following: (1) the medical records of Plaintiff which have been, and which may hereafier be, produced in this cause; (2) the medical records affidavits and medical billing affidavits which have been filed, and which may hereafter be filed, in this cause and all exhibits thereto; Plaintiffs Supp. Responses to RFD and Designation of Expert Witnesses Page 4 of 8 (3) the depositions on written questions of Plaintiff’s health care providers which have been taken, and which may hereafter be taken, in this cause, and all exhibits thereto; and (4) all written reports of healthcare providers produced during the course of discovery in this cause. All of said documents are incorporated herein by reference as though set out at length for all purposes. 3. Brief Summgg of Basis for Immeslions and Qpi-nions. The basis for the foregoing impressions and opinions of the above named and/or designated expert witnesses are all of the facts shown by and/or contained in: a. Physical examinations and medical diagnoses of Plaintiff; b. All of the medical records (including medical imaging) of Plaintiff produced in this cause; c. All depositions taken, and hereafter taken, in this cause, either by written questions or orally, and all exhibits thereto; d. The expert reports herein above expressly referred to; e. All witness statements which may be produced in this cause; f. All of the photographs and videotape recordings produced in this cause; g. The Responses to Requests For Disclosure, Responses to Requests For Production, Answers to Interrogatories, and the Amendments and Supplements thereto which have been filed by each of the parties in this cause of action; h. The Pleadings on file in this cause of action; and i. All documents and tangible things produced in this cause. NON-RETAINED EXPERTS, OTHER THAN MEDICAL EXPERTS: Officer Nick Sham #1569 City of Farmers Branch Police Department Its current and former chief, officers, investigators, detectives, employees, and custodian(s) of records 3723 Valley View Lane Farmers Branch, TX 75244 Investigating Officer Plaintiff‘s Supp. Responses to RFD and Designation of Expert Witnesses Page 5 of 8 The officer is expected to testify regarding his investigation of the subject incident and the statements made by the parties to the lawsuit. Plaintiff also incorporates herein by reference all depositions; depositions on written questions; documents and exhibits attached to or referenced in all depositions; and all documents produced by any party hereto in disclosures and/or discovery. Any opinions and bases for opinions discussed in deposition(s) are incorporated herein. Plaintiff further refers the Defendant to Plaintiff’ s retained and non-retained experts’ files, reports and supplemental reports; initial and supplemental disclosures; pleadings of all parties; discovery of all parties; depositions and exhibits thereto; medical and billing records; rebuttal opinions, factual observations, opinions, deposition testimony and/or trial testimony and deposition exhibits of non-retained experts. Plaintiff further reserves the right through cross-examination or deposition, to call any expert witness identified herein by the Defendant. Plaintiff reserves the right to withdraw the designation of any expert witness and to aver positively that such previously designated expert will not be called as an expert witness at trial and to redesignate same as a consulting expert, who cannot be called by opposing counsel. Plaintiff reserves the right to elicit any expert testimony and/or lay opinion testimony that would assist the jury in determining material issues of fact and that would not violate the Texas Rules of Civil Procedure. Plaintiff reserves all additional rights they may have with regard to expert witnesses and testimony under the Texas Rules of Civil Procedure, case law and rulings of this Honorable Court. Plaintiff reserves the right to elicit expert opinion from any of the desigiated fact witnesses within any area as to which such person has expertise. To the extent necessary, this expert designation should be considered a supplement to any outstanding or fiiture discovery requests served on Plaintiff. This designation shall serve to supplement Plaintiff’s disclosures, including fact witness designations, answers to interrogatories, pretrial disclosures, expert witness designations, and responses to requests for production propounded to Plaintiff by any party inquiring as to expert witnesses. Discovery in this matter is still ongoing and Plaintiff reserves the right to supplement this designation if further discovery reveals the need for additional testimony. This designation shall serve to supplement Plaintiffs Responses to Defendant’s Request for Disclosure, including the identification of individuals likely to have discoverable information Plaintiffs Supp. Responses to RFD and Designation of Expert Witnesses Page 6 of 8 regarding Plaintiffs claims or defenses, Answers to Interrogatories, and Responses to Requests for Production propounded to Plaintiff by any party inquiring as to expert witnesses. DATED this 1'5 _ day of July 2021 Respectfully submitted, SLOAN, HATCHER, PERRY, RUNGE, ROBERTSON, SMITH & JONES 8mm *1 CARSON R. RUNGE m State Bar No. 24059262 crunge@sloanfirm.com SAVANNAH M. JUDKINS State Bar No. 24121694 sjudkins@sloanfirm.com 101 East Whaley Street Longview, Texas 75601 Telephone 903-757-7000 Facsimile 903-757-7574 ATTORNEYS FOR PLAINTIFF Plaintiffs Supp. Responses to RFD and Designation of Expert Witnesses Page 7 of 8 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document been forwarded Via efile in accordance with the Texas Rules of Civil Procedure on this Z?)Esday of July 2021 to the following attorney of record: Fernando Martinez Meynier, Reese, Liber & Matte Preston Plaza 17950 Preston Road Suite 410 Dallas, TX 75252 ATTORNEY FOR DEFENDANT MARIA ZUNIGA HERRERA, As DEFENDANT Geoffrey E. Schorr A. Jared Aldinger Hutton W. Sentell Schorr Law Firm, P.C. 328 W. Interstate 30, Suite 2 Garland, TX 75043 ATTORNEYS FOR DEFENDANT MARIA ZUNIGA HERRERA, As COUNTER-PLAINTIFF Richard J. Byrne Ekvall & Byrne, LLP 4450 Sigma Road, Suite 100 Dallas, TX 75244 ATTORNEY FOR PLAINTIFF ASHANTI BOYD, As COUNTER-DEFENDANT SAVANNAH M. JUDKINS Plaintiffs Supp. Responses to RFD and Designation of Expert Witnesses Page 8 of 8 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Donna Rountree on behalf of Savannah Judkins Bar No. 24121694 drountree@sloanfirm.com Envelope ID: 55646675 Status as of 7/26/2021 4:00 PM CST Associated Case Party: ASHANTI BOYD Name BarNumber Email TimestampSubmitted Status Geoffrey E.Schorr geoff@schorrfirm.com 7/23/2021 12:33:22 PM SENT Hutton W.Sentell hutton@schorrfirm.com 7/23/2021 12:33:22 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Carson R.Runge crunge@sloanfirm.com 7/23/2021 12:33:22 PM SENT Donna Rountree drountree@sloanfirm.com 7/23/2021 12:33:22 PM SENT Richard J.Byrne rbyrne@ekvallbyrne.com 7/23/2021 12:33:22 PM SENT Stefan Allen sallen@ekvallbyrne.com 7/23/2021 12:33:22 PM SENT Savannah Judkins sjudkins@sloanfirm.com 7/23/2021 12:33:22 PM SENT Lori Sarathy lsarathy@ekvallbyrne.com 7/23/2021 12:33:22 PM SENT Lillie E.Sanchez lsanchez@ekvallbyrne.com 7/23/2021 12:33:22 PM SENT Associated Case Party: MARIAZUNIGAHERRERA Name BarNumber Email TimestampSubmitted Status Fernando Martinez DALLASHC@PROGRESSIVE.COM 7/23/2021 12:33:22 PM SENT