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CAUSE NO. 2016-49450
HEMANT GAJARAWALA § IN THE DISTRICT COURT OF
§
VS. § HARRIS COUNTY TEXAS
§
SOMAIAH KURRE § 80" JUDICIAL DISTRICT
DEFENDANT’S DESIGNATION OF EXPERT WITNESSES
TO: HEMANT GAJARAWALA and DEVSJ Concrete, LLC, by and through their attorney of
record, Isaac Villarreal, McCathern, PLLC. by efile / email service at
ivillarreal@mcecathernlaw.com
COMES NOW, Defendant, SOMAIAH KURRE, and in accordance with Rule 194 et.seq. of
the Texas Rules of Civil Procedure and the Docket Control Order, serves the following Designation
of Expert Witnesses and Supplemental Responses to Request for Disclosure.
Respectfully submitted,
KOCHMAN & CHARBONNET, PC
Bye ~
JOHN D. CHARBONNET, JR.
TBA NO. 00785758
12012 Wickchester, Suite 150
Houston, Texas 77079
713-871-2490 — phone
713-871-2495 — fax
jdcharbonnet@kdclaw.com - email
ATTORNEY FOR DEFENDANT
CERTIFICATE OF SERVICE
I do hereby certify that a true and correct copy of the above and foregoing Defendant's
Designation of Expert Witnesses has been forwarded via efiling to all co cord on February
2252017:
JOHN D>GHARBONNET, JR.(f)
DESIGNATION OF EXPERT WITNESSES
For any testifying expert:
(1) the expert’s name, address and telephone number;
(2) the subject matter on which the expert will testify;
(3) _ the general substance of the expert’s mental impressions and opinions and a brief
summary of the basis for them, or if the expert is not retained by, employed by, or
otherwise subject to the control of the responding party, documents reflecting
such information;
(4) _ if the expert is retained by, employed by, or otherwise subject to the control of the
responding party:
(A) all documents, tangible things, reports, models, or data compilations that
have been provided to, reviewed by, or prepared by or for the expert in
anticipation of the expert’s testimony; and
(B) __ the expert’s current resume and bibliography.
. John D. Charbonnet, Jr.
Kochman, Donati & Charbonnet, LLP
12012 Wickchester, Suite 310
Houston, Texas 77079
Phone: 713-871-2490
Fax: 713-871-2495
Mr. Charbonnet is expected to testify concerning reasonable and necessary attorney’s fees
and expenses incurred by the parties in this case and any appeal to the Court of Appeals
and/or the Texas Supreme Court, including with regard to the following areas: his hourly rate
of $185.00 is below market and more than reasonable, the impact of the Promissory Note
made the basis of this lawsuit, including that it is secured by a lien on Mr. Kurre’s ownership
interest in Texas Concrete Enterprise —IV, LLC, the impact of the need to value Mr. Kurre’s
ownership interest in Texas Concrete Enterprise — IV, LLC at the time of his default of the
Promissory Note, the impact of Plaintiffs assuming complete control over Texas Concrete
Enterprise — IV, LLC, the impact of Plaintiff's failure to abide by the governing documents
of Texas Concrete Enterprise — IV, LLC, and impact of the interest rate charged by Plaintiff
in the Memorandum of Understanding regarding Plaintiff's loan of $60,000.00 to Mr. Kurre,
and possible rebuttal opinions for the opinions concerning attorney’s fees given by Plaintiff's
attorney’s fees expert(s). A copy of Mr. Charbonnet’s resume is attached as Exhibit “A”.
Mr. Charbonnet’s opinions regarding reasonable and necessary attorney’s fees will be based
upon Rule 1.04 of the Texas Disciplinary Rules of Professional Conduct and Arthur
Anderson & Co. v. Perry Equipment Corp., 945 S.W.2d 812 (Tex.1997).
Mr. Charbonnet, as attorney of record, has received and reviewed all pleadings and
documents exchanged by the parties. Mr. Charbonnet’s opinions are not yet finalized given
the stage of this case. His opinions will be based upon his time sheets and billing records as
well as those produced by all parties. His billing records will be provided, in redacted form
to protect privileged and confidential information for disclosure, will document the services
provided and time spent. Mr. Charbonnet has not prepared a report. He will be present for
deposition upon request. Mr. Charbonnet will review any additional documents produced by
any party regarding their attorney’s fees.2. Somaiah Kurre
Care of his attorney 1017 Wakefield Drive
John Charbonnet Houston, TX 77018
12012 Wickchester, Suite 150 (832) 283-6818
Houston, Texas 77079
(713) 871-2490
Mr. Kurre is a party in this case. Mr. Kurre will testify regarding the Promissory Note made
the basis of this lawsuit, including that it is secured by a lien on Mr. Kurre’s ownership
interest in Texas Concrete Enterprise — IV, LLC, the valuation of Mr. Kurre’s ownership
interest in Texas Concrete Enterprise — IV, LLC at the time of his default of the Promissory
Note, Plaintiff's assuming complete control over Texas Concrete Enterprise — IV, LLC,
Plaintiff's failure to abide by the governing documents of Texas Concrete Enterprise — IV,
LLC, and the interest rate charged by Plaintiff in the Memorandum of Understanding
regarding Plaintiff’s loan of $60,000.00 to Mr. Kurre.
Mr. Kurre has not provided a report. His opinions are not finalized as Plaintiff has assumed
complete control of the Texas Concrete Enterprise — IV, LLC. Furthermore, Plaintiff has
made absolutely no effort to comply with the requirement to value Mr. Kurre’s ownership
interest in Texas Concrete Enterprise -IV, LLC. Mr. Kurre will be presented for deposition
upon request.
Except for his counsel, Mr. Kurre has not retained any testifying experts.
Mr. Kurre reserves the right to call upon any testimony of other experts designated by any
other party.
Mr. Kurre reserves the right to call rebuttal experts.
Mr. Kurre reserves the right to supplement in accordance with the Texas Rules of Civil
Procedure and any Scheduling Order.
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CAUSE NO. 2016-49450 HEMANT GAJARAWALA § IN THE DISTRICT COURT OF § VS. § HARRIS COUNTY TEXAS § SOMAIAH KURRE § 80" JUDICIAL DISTRICT DEFENDANT’S DESIGNATION OF EXPERT WITNESSES TO: HEMANT GAJARAWALA and DEVSJ Concrete, LLC, by and through their attorney of record, Isaac Villarreal, McCathern, PLLC. by efile / email service at ivillarreal@mcecathernlaw.com COMES NOW, Defendant, SOMAIAH KURRE, and in accordance with Rule 194 et.seq. of the Texas Rules of Civil Procedure and the Docket Control Order, serves the following Designation of Expert Witnesses and Supplemental Responses to Request for Disclosure. Respectfully submitted, KOCHMAN & CHARBONNET, PC Bye ~ JOHN D. CHARBONNET, JR. TBA NO. 00785758 12012 Wickchester, Suite 150 Houston, Texas 77079 713-871-2490 — phone 713-871-2495 — fax jdcharbonnet@kdclaw.com - email ATTORNEY FOR DEFENDANT CERTIFICATE OF SERVICE I do hereby certify that a true and correct copy of the above and foregoing Defendant's Designation of Expert Witnesses has been forwarded via efiling to all co cord on February 2252017: JOHN D>GHARBONNET, JR.(f) DESIGNATION OF EXPERT WITNESSES For any testifying expert: (1) the expert’s name, address and telephone number; (2) the subject matter on which the expert will testify; (3) _ the general substance of the expert’s mental impressions and opinions and a brief summary of the basis for them, or if the expert is not retained by, employed by, or otherwise subject to the control of the responding party, documents reflecting such information; (4) _ if the expert is retained by, employed by, or otherwise subject to the control of the responding party: (A) all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert’s testimony; and (B) __ the expert’s current resume and bibliography. . John D. Charbonnet, Jr. Kochman, Donati & Charbonnet, LLP 12012 Wickchester, Suite 310 Houston, Texas 77079 Phone: 713-871-2490 Fax: 713-871-2495 Mr. Charbonnet is expected to testify concerning reasonable and necessary attorney’s fees and expenses incurred by the parties in this case and any appeal to the Court of Appeals and/or the Texas Supreme Court, including with regard to the following areas: his hourly rate of $185.00 is below market and more than reasonable, the impact of the Promissory Note made the basis of this lawsuit, including that it is secured by a lien on Mr. Kurre’s ownership interest in Texas Concrete Enterprise —IV, LLC, the impact of the need to value Mr. Kurre’s ownership interest in Texas Concrete Enterprise — IV, LLC at the time of his default of the Promissory Note, the impact of Plaintiffs assuming complete control over Texas Concrete Enterprise — IV, LLC, the impact of Plaintiff's failure to abide by the governing documents of Texas Concrete Enterprise — IV, LLC, and impact of the interest rate charged by Plaintiff in the Memorandum of Understanding regarding Plaintiff's loan of $60,000.00 to Mr. Kurre, and possible rebuttal opinions for the opinions concerning attorney’s fees given by Plaintiff's attorney’s fees expert(s). A copy of Mr. Charbonnet’s resume is attached as Exhibit “A”. Mr. Charbonnet’s opinions regarding reasonable and necessary attorney’s fees will be based upon Rule 1.04 of the Texas Disciplinary Rules of Professional Conduct and Arthur Anderson & Co. v. Perry Equipment Corp., 945 S.W.2d 812 (Tex.1997). Mr. Charbonnet, as attorney of record, has received and reviewed all pleadings and documents exchanged by the parties. Mr. Charbonnet’s opinions are not yet finalized given the stage of this case. His opinions will be based upon his time sheets and billing records as well as those produced by all parties. His billing records will be provided, in redacted form to protect privileged and confidential information for disclosure, will document the services provided and time spent. Mr. Charbonnet has not prepared a report. He will be present for deposition upon request. Mr. Charbonnet will review any additional documents produced by any party regarding their attorney’s fees.2. Somaiah Kurre Care of his attorney 1017 Wakefield Drive John Charbonnet Houston, TX 77018 12012 Wickchester, Suite 150 (832) 283-6818 Houston, Texas 77079 (713) 871-2490 Mr. Kurre is a party in this case. Mr. Kurre will testify regarding the Promissory Note made the basis of this lawsuit, including that it is secured by a lien on Mr. Kurre’s ownership interest in Texas Concrete Enterprise — IV, LLC, the valuation of Mr. Kurre’s ownership interest in Texas Concrete Enterprise — IV, LLC at the time of his default of the Promissory Note, Plaintiff's assuming complete control over Texas Concrete Enterprise — IV, LLC, Plaintiff's failure to abide by the governing documents of Texas Concrete Enterprise — IV, LLC, and the interest rate charged by Plaintiff in the Memorandum of Understanding regarding Plaintiff’s loan of $60,000.00 to Mr. Kurre. Mr. Kurre has not provided a report. His opinions are not finalized as Plaintiff has assumed complete control of the Texas Concrete Enterprise — IV, LLC. Furthermore, Plaintiff has made absolutely no effort to comply with the requirement to value Mr. Kurre’s ownership interest in Texas Concrete Enterprise -IV, LLC. Mr. Kurre will be presented for deposition upon request. Except for his counsel, Mr. Kurre has not retained any testifying experts. Mr. Kurre reserves the right to call upon any testimony of other experts designated by any other party. Mr. Kurre reserves the right to call rebuttal experts. Mr. Kurre reserves the right to supplement in accordance with the Texas Rules of Civil Procedure and any Scheduling Order.