MTN:OTHER MOTION

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                          Filed

09 December 14 A11:42
Amalia Rodriguez-Mendoza
District Clerk
Travis District
CAUSE NO. D-1-GN-08-004283
BARBARA ALLEN, § IN THE DISTRICT COURT OF

§
Plaintiff, §
§ TRAVIS COUNTY, TEXAS
v. §
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MOSTER & WYNNE, P.C. d/b/a §
MOSTERWYNNE 8 98" JUDICIAL DISTRICT
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Defendant. §

PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S DESIGNATION OF
EXPERT WITNESS THOMAS H. WATKINS

TO THE HONORABLE JUDGE OF SAID COURT:

Plaintiff Barbara Allen (“Allen”) moves to strike Defendant Moster & Wynne
P.C.’s Designation of Expert Witness Thomas H. Watkins due to a substantial conflict of
interest. In fact, Watkins’ law firm, Brown McCarroll, L.L.P., represented Allen in the
underlying litigation that led to the claims in this lawsuit and now seeks to testify as a
hired expert against her. In support of this motion, Allen would respectfully show the
following:

INTRODUCTION

Background

This suit is the result of MosterWynne’s representation of Allen in her divorce
during a seven-week period in late 2006.…