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048-323719-21 FILED
TARRANT COUNTY
11/2/2021 11:06 AM
CAUSE NO. 048-323719-21 THOMAS A. WILDER
DISTRICT CLERK
SHRADESH SHRESTHA § IN THE DISTRICT COURT
§
Vs. § TARRANT COUNTY, TEXAS
§
TAD WILLIAMS AND §
CRETE CARRIER CORPORATION § 48TH JUDICIAL DISTRICT
PLAINTIFF’S DESIGNATION OF EXPERT WITNESSES
AND SUPPLEMENTAL RULE 194.2 DISCLOSURES
Plaintiff, Shradesh Shrestha, in accordance with the Texas Rules of Civil Procedure,
serves his Designation of Expert Witnesses and supplements his disclosures as follows:
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, of 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;
(C) the expert’s qualifications, including a list of all publications
authored in the previous 10 years;
(D) a list of all other cases in which, during the previous four years,
the expert testified as an expert at trial or by deposition;
(E) a statement of the compensation to be paid for the expert’s
study and testimony in the case.
RESPONSE:
Plaintiff’s Treating Physicians
and Other Persons with Knowledge of Relevant Facts
Who May Qualify as Experts but Have Not
Been Specially Retained
(Fact Experts – TEX. R. CIV. P. 194.2(f))
The following person(s), or the 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.
I. NON-RETAINED MEDICAL EXPERTS.
The following healthcare providers, and/or the custodian of their records, may testify
regarding the injuries sustained by Plaintiff in the incident made the subject of this suit, their
medical diagnosis, 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 future.
Please refer to the healthcare providers’ records for their mental impressions, opinions,
conclusions, and the factual basis for each opinion.
I.1. Identity of Non-Retained Medical Experts.
The names of the non-retained, non-controlled medical experts and their addresses and
telephone numbers are as follows:
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:
Chadha Medical Clinic
Jagjit Chadha, MD
140 W. 4th Street,
Dequincy, LA 70633
I.2. 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;
b. the examination, diagnostics and treatment of the injuries sustained by Plaintiff;
c. pre-existing injuries, if any, to, and/or pre-existing medical conditions, if any, of
Plaintiff;
d. the type, purpose, extent, results, evaluations and/or interpretations of
examinations, treatments, x-rays, diagnostics, and tests regarding Plaintiff;
e. recommendations, diagnosis and prognosis with regard to the injuries of Plaintiff;
f. the existence, nature and/or extent of the disabilities and/or incapacities of
Plaintiff in the past, and the reasonable probability and extent of the disabilities
and/or incapacities which Plaintiff may suffer from in the future;
g. the cause and/or causes of Plaintiff’s condition(s), injuries, disabilities and/or
capacities;
h. medical care and treatment and medications that have been required by Plaintiff in
the past for the treatment of the injuries sustained by Plaintiff in the subject
incident and for rehabilitation from such injuries;
i. medical care and treatment and medications that will be required by Plaintiff in
the future, if any, for the treatment of the injuries sustained by Plaintiff in the
subject incident and for rehabilitation from such injuries;
j. the reasonableness and the necessity of the medical services and medical care and
medications rendered to Plaintiff in the past, and that Plaintiff will in reasonable
probability receive in the future, for the injuries sustained by Plaintiff in the
subject incident;
k. all those subject matters contained, discussed or disclosed in:
(1) the medical records, diagnostic records, of Plaintiff which have been and
which may hereafter be produced in this cause;
(2) all medical records affidavits and/or medical billing affidavits which have
been served and which may hereafter be served in this cause, and all
exhibits thereto;
(3) the oral depositions and 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.
I.3. 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 alleged injuries, incapacities, and
disabilities;
b. Plaintiff’s injuries, incapacities, and/or disabilities are the result in whole or in
part of the injuries received by Plaintiff as a result of the subject incident and
made the subject of this suit;
c. the medical care and treatment rendered to Plaintiff was reasonable and
necessary;
d. the subject incident did, based on reasonable medical probability, cause all of the
complaints, disabilities, injuries, and/or incapacities of Plaintiff;
e. that any surgical intervention for treatment of Plaintiff’s injuries and/or symptoms
was necessitated and proximately caused by the incident made the subject of this
lawsuit;
f. that the medical treatment and expenses of Plaintiff were necessitated by the
incident which is the subject of this lawsuit;
g. that Plaintiff will, in reasonable probability, require medical care in the future to
treat the injuries and/or symptoms proximately caused by the incident made the
subject of this lawsuit, and the reasonable cost of that care;
g. all other impressions and/or opinions that are contained, discussed, and/or
disclosed in the following:
(1) the medical records of Plaintiff which has been and which may hereafter
be produced in this cause;
(2) the medical records affidavits and medical billing affidavits which have
been served and which may hereafter be served in this cause and all
exhibits thereto;
(3) the oral depositions and 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.
I.4. Brief Summary of Basis for Impressions and Opinions.
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. All of the medical records of Plaintiff produced in this cause;
b. All depositions taken and hereafter taken in this cause, either by written questions
or orally, and all exhibits thereto;
c. The expert reports, if any, herein above expressly referred to;
d. All witness statements which may be produced in this cause;
e. All of the photographs and videotape recordings produced in this cause;
f. The Responses to Disclosure, Responses to Requests for Production, Answers to
Interrogatories, and the Amendments and Supplements thereto which have been
served by each of the parties in this cause of action;
g. The Pleadings on file in this cause of action; and
h. All documents and tangible things produced in this cause.
II. NON-RETAINED PEACE OFFICER EXPERTS: The following peace officers,
and/or the custodian of their records, may testify regarding the facts of the wreck made the
subject matter of this case, the causation of the wreck, and statement made by the persons
involved in the wreck, or witnesses thereto. Please refer to the Texas Peace Officer’s Crash
Report for their mental impressions, opinions, conclusions, and the factual basis for each
opinion.
II.1 Identify of Non-Retained Peace Officers. The names of the non-retained/non-
controlled Peace Officer expert and his address and telephone number are as follows:
Trooper Mark Cooke
ID No. 15436
Texas Department of Public Safety
Service/Region DA – HP2B12
Lukfin, Texas
II.2. Subject Matters of Non-Retained Peace Officer. The subject matters on which said
non-retained non-controlled peace officer will testify are as follows:
a. the facts surrounding the wreck;
b. the cause of the wreck;
c. the results of his accident investigation/recreation of the wreck;
d. the facts obtained during his investigation of this wreck;
e. any observations made by him at the scene of the wreck or during the
course of his investigation;
f. the substance of any witness statements taken during the course of his
investigation;
g. any analysis of the vehicles involved in this collision; and
h. all those subject matters contained, discussed or disclosed in:
(1) the Texas Peace Officer’s Report of the wreck made the subject of
this suit;
(2) the depositions taken in this cause, orally and on written questions;
(3) all written reports produced during the course of discovery in this
cause;
(4) any and all accident reports created by any governmental agency
and all attachments thereto;
(5) any and all pictures taken of the wreck, the vehicles involved in the
wreck, or the injuries received in the wreck, including all
photographs produced during the course of discovery in this cause;
(6) all statements produced during the course of discovery in this
cause;
(7) any deposition testimony given in this cause by any of the above-
designated individuals or any individual who also investigated this
wreck but who is not specifically identified above.
All of which documents are incorporated herein by reference as though set out at length
for all purposes.
II.3. Impressions and Opinions of Non-Retained Peace Officer. The general substance of
said non-retained / non-controlled Peace Officer’s expert mental impressions and opinions are
expected to be, and a brief summary of the basis for them are, as follows:
a. the facts of the wreck made the subject of this suit;
b. the identity of the drivers involved in the wreck made the subject of this
suit;
c. the causative factors regarding the wreck made the subject of this suit;
d. the extent of the damage to the vehicles involved in the wreck made the
subject of this suit;
e. the traffic conditions, terrain, and weather conditions at the time of the
wreck made the subject of this suit;
f. all other impressions and opinions that are contained, discussed or
disclosed in:
(1) the Texas Peace Officer’s Report of the wreck made the subject of
this suit;
(2) the depositions taken in this cause, orally and on written questions;
(3) all written reports produced during the course of discovery in this
cause;
(4) any and all accident reports created by any governmental agency
and all attachments thereto;
(5) any and all pictures taken of the wreck, the vehicles involved in the
wreck, or the injuries received in the wreck, including all
photographs produced during the course of discovery in this cause;
(6) all statements produced during the course of discovery in this
cause;
(7) any deposition testimony given in this cause by any of the above-
designated individuals or any individual who also investigated this
wreck but who is not specifically identified above.
All of which documents are incorporated herein by reference as though set out at length
for all purposes.
II.4. Brief Summary of Basis For Impressions And Opinions. The basis for the foregoing
impressions and opinions of the above named and/or designated expert witness are all of the
facts shown by and/or contained in:
a. the Peace Officer’s investigation of the wreck including the scene of the
wreck, the vehicles involved, the statements of the drivers and passengers
in the vehicles, statements of witnesses to the wreck, and emergency
medical care rendered to the parties;
b. the Peace Officer’s report and notes pertaining to the wreck made the
subject of this suit;
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 or
obtained by the designated individuals during the course of their
investigation;
g. Disclosures, Responses to Requests for Production, Answers to Interrogatories,
and the Amendments and Supplements thereto which have been filed by each of
the parties to this cause;
h. the Pleadings on file in this cause;
i. all documents and tangible things produced in this cause;
j. All depositions taken and hereafter taken in this cause, either by written
questions or orally, and all exhibits thereto;
k. Any and all accident reports created by any governmental agency and all
attachments thereto;
l. the education, knowledge and experience of the investigating officer along
with any specialized training received by him and his observations,
deductions and calculations performed during his investigation of this
wreck.
All of which records, reports, documents, depositions, photographs and videotape
recordings are incorporated herein by reference and made a part hereof for all purposes as if set
out at length herein.
III. NON-RETAINED NON-MEDICAL EXPERT: The following person and/or the
custodian of records, may testify regarding the facts of the damage to Plaintiff’s vehicle as a
result of the collision.
III.1 Identify of Non-Medical Expert. The names of the non-retained/non-controlled expert
and his/her address and telephone number are as follows:
Becky Laughlin
Briley’s Paint and Body, Inc.
4003 Broad Street
Lake Charles, Louisiana 70615
(337) 491-9481
III.2. Subject Matters of Non-Retained Non-Medical Expert. The subject matters on which
said non-retained non-medical expert will testify are as follows:
a. the damages to Plaintiff’s vehicle;
b. the cost to repair Plaintiff’s vehicle;
c. the Preliminary Estimate and any supplemental estimate;
d. loss of use of the vehicle while the repairs are made;
e. allotted time for the repairs;
f. damage related to the motor vehicle collision; and
g. any and all pictures taken of the wreck, the vehicles involved in the wreck, including all
photographs produced during the course of discovery in this cause;
All of which documents are incorporated herein by reference as though set out at length
for all purposes.
III.3. Impressions and Opinions of Non-Retained Non-Medical Expert. The general
substance of said non-retained non-medical expert mental impressions and opinions are expected
to be, and a brief summary of the basis for them are, as follows:
a. the damages to Plaintiff’s vehicle;
b. all other impressions and opinions that are contained, discussed or
disclosed in:
1) the Preliminary Estimate and any supplemental estimate that may be
obtained;
2) the cost of all repairs in the preliminary estimate and any supplemental
estimate that may be obtained;
3) all repairs reflected in the estimate to the stripes and mouldings and any
repairs that may be required to the stripes and mouldings in any
supplemental estimate, if any;
4) all repairs reflected in the estimate to the front doors and any repairs that
may be required to the front doors in any supplemental estimate, if any;
5) all repairs reflected in the estimate to the rear doors and any repairs that
may be required to the rear doors in a supplemental estimate, if any;
6) all repairs reflected in the estimate to the quarter and rocker panel and
any repairs that may be required to the quarter and rocker panel in any
supplemental estimate, if any;
7) all repairs reflected in the estimate to the inner quarter and panels and
any repairs that may be required to the inner quarter and panels in any
supplemental estimate, if any;
8) all repairs reflected in the estimate to the rear bumper and any repairs
that may be required to the rear bumper in any supplemental estimate, if
any;
9) all repairs reflected in the estimate to the rear body, lamps and floor plan
and any repairs that may be required to the rear body, lamps and floor
plan in any supplemental estimate, if any;
10) all repairs reflected in the estimate for manual entries and any repairs
that may be required as manual entries in any supplemental estimate, if
any;
11) the value of all parts, materials, paints, labor, including taxes, to repair
the vehicle reflected in the estimate, including any supplemental
estimate;
12) the depositions taken in this cause, orally and on written questions;
13) all written reports produced during the course of discovery in this
cause;
14) any and all pictures taken of the wreck, the vehicles involved in the
wreck, or the injuries received in the wreck, including all photographs
produced during the course of discovery in this cause; and
15) any deposition testimony given in this cause by any of the above-
designated individuals or any individual who also investigated this
wreck but who is not specifically identified above.
All of which documents are incorporated herein by reference as though set out at length
for all purposes.
III.4. Brief Summary of Basis For Impressions And Opinions. The basis for the foregoing
impressions and opinions of the above named and/or designated expert witness are all of the
facts shown by and/or contained in:
a. the repair man/woman’s investigation vehicle including the photographs of the
wreck, the vehicles involved, the statements of the drivers and passengers
in the vehicles, statements of witnesses to the wreck;
b. the Peace Officer’s report and notes pertaining to the wreck made the
subject of this suit;
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 or
obtained by the designated individuals during the course of their
investigation;
g. Disclosures, Responses to Requests for Production, Answers to Interrogatories,
and the Amendments and Supplements thereto which have been filed by each of
the parties to this cause;
h. the Pleadings on file in this cause;
i. all documents and tangible things produced in this cause;
j. All depositions taken and hereafter taken in this cause, either by written
questions or orally, and all exhibits thereto;
k. Any and all accident reports created by any governmental agency and all
attachments thereto; and
l. the education, knowledge and experience of repair man/woman along
with any specialized training received by him and his observations,
deductions and calculations performed during his investigation of this
wreck.
All of which records, reports, documents, depositions, photographs and videotape
recordings are incorporated herein by reference and made a part hereof for all purposes as if set
out at length herein.
IV. ADDITIONAL DISCLOSURES
All records, reports, documents, depositions, photographs and videotape recordings taken
or obtained in this matter and produced by any party or non-party in this matter are incorporated
herein by reference and made a part hereof for all purposes as if set out at length herein.
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 Defendant to Plaintiff’s retained and non-retained experts’ files,
reports and supplemental reports; written discovery responses of all parties; pleadings of all
parties; depositions and exhibits thereto; medical and billing records; rebuttal opinions; factual
observations and opinions.
Plaintiff further reserves the right through cross-examination or deposition, to call any
expert witness identified herein by any 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 that Plaintiff may have regarding 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 designated fact
witnesses within any area as to which such person has expertise.
Respectfully submitted,
SLOAN, HATCHER, PERRY, RUNGE, ROBERTSON & SMITH
/s/ J. Kendon Womack
J. KENDON WOMACK
State Bar No. 24117620
kwomack@sloanfirm.com
JUSTIN A. SMITH
State Bar No. 24068415
jsmith@sloanfirm.com
101 East Whaley Street
Longview, Texas 75601
Telephone: (903) 757-7000
Facsimile: (903) 757-7574
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document has been
forwarded via efile in accordance with the Texas Rules of Civil Procedure on this 02 day
of November 2021, to the following attorney of record:
Lindsay G. Gorbach
Laura E. Calloway
Cox PLLC
8144 Walnut Hill Lane, Suite 1090
Dallas, Texas 75230
lgorbach@cloxpllc.com
lcalloway@coxpllc.com
/s/ J. Kendon Womack
J. KENDON WOMACK
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.
Lida Vega on behalf of J. Womack
Bar No. 24117620
lvega@sloanfirm.com
Envelope ID: 58757336
Status as of 11/2/2021 11:27 AM CST
Associated Case Party: TADWILLIAMS
Name BarNumber Email TimestampSubmitted Status
Lindsay G.Gorbach lgorbach@coxpllc.com 11/2/2021 11:06:31 AM SENT
Greg Brenner gbrenner@coxpllc.com 11/2/2021 11:06:31 AM SENT
Laura Calloway lcalloway@coxpllc.com 11/2/2021 11:06:31 AM SENT
Cindy Lewis clewis@coxpllc.com 11/2/2021 11:06:31 AM SENT
Associated Case Party: THECRETE CARRIER CORPORATION
Name BarNumber Email TimestampSubmitted Status
Lindsay G.Gorbach lgorbach@coxpllc.com 11/2/2021 11:06:31 AM SENT
Laura Atherstone latherstone@coxpllc.com 11/2/2021 11:06:31 AM SENT
Cindy Lewis clewis@coxpllc.com 11/2/2021 11:06:31 AM SENT
Associated Case Party: SHRADESHSHRESTHA
Name BarNumber Email TimestampSubmitted Status
J. KendonWomack kwomack@sloanfirm.com 11/2/2021 11:06:31 AM SENT
Justin A.Smith jsmith@sloanfirm.com 11/2/2021 11:06:31 AM SENT
Lida Vega lvega@sloanfirm.com 11/2/2021 11:06:31 AM SENT
Preview
048-323719-21 FILED TARRANT COUNTY 11/2/2021 11:06 AM CAUSE NO. 048-323719-21 THOMAS A. WILDER DISTRICT CLERK SHRADESH SHRESTHA § IN THE DISTRICT COURT § Vs. § TARRANT COUNTY, TEXAS § TAD WILLIAMS AND § CRETE CARRIER CORPORATION § 48TH JUDICIAL DISTRICT PLAINTIFF’S DESIGNATION OF EXPERT WITNESSES AND SUPPLEMENTAL RULE 194.2 DISCLOSURES Plaintiff, Shradesh Shrestha, in accordance with the Texas Rules of Civil Procedure, serves his Designation of Expert Witnesses and supplements his disclosures as follows: 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, of 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; (C) the expert’s qualifications, including a list of all publications authored in the previous 10 years; (D) a list of all other cases in which, during the previous four years, the expert testified as an expert at trial or by deposition; (E) a statement of the compensation to be paid for the expert’s study and testimony in the case. RESPONSE: Plaintiff’s Treating Physicians and Other Persons with Knowledge of Relevant Facts Who May Qualify as Experts but Have Not Been Specially Retained (Fact Experts – TEX. R. CIV. P. 194.2(f)) The following person(s), or the 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. I. NON-RETAINED MEDICAL EXPERTS. The following healthcare providers, and/or the custodian of their records, may testify regarding the injuries sustained by Plaintiff in the incident made the subject of this suit, their medical diagnosis, 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 future. Please refer to the healthcare providers’ records for their mental impressions, opinions, conclusions, and the factual basis for each opinion. I.1. Identity of Non-Retained Medical Experts. The names of the non-retained, non-controlled medical experts and their addresses and telephone numbers are as follows: 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: Chadha Medical Clinic Jagjit Chadha, MD 140 W. 4th Street, Dequincy, LA 70633 I.2. 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; b. the examination, diagnostics and treatment of the injuries sustained by Plaintiff; c. pre-existing injuries, if any, to, and/or pre-existing medical conditions, if any, of Plaintiff; d. the type, purpose, extent, results, evaluations and/or interpretations of examinations, treatments, x-rays, diagnostics, and tests regarding Plaintiff; e. recommendations, diagnosis and prognosis with regard to the injuries of Plaintiff; f. the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in the past, and the reasonable probability and extent of the disabilities and/or incapacities which Plaintiff may suffer from in the future; g. the cause and/or causes of Plaintiff’s condition(s), injuries, disabilities and/or capacities; h. medical care and treatment and medications that have been required by Plaintiff in the past for the treatment of the injuries sustained by Plaintiff in the subject incident and for rehabilitation from such injuries; i. medical care and treatment and medications that will be required by Plaintiff in the future, if any, for the treatment of the injuries sustained by Plaintiff in the subject incident and for rehabilitation from such injuries; j. the reasonableness and the necessity of the medical services and medical care and medications rendered to Plaintiff in the past, and that Plaintiff will in reasonable probability receive in the future, for the injuries sustained by Plaintiff in the subject incident; k. all those subject matters contained, discussed or disclosed in: (1) the medical records, diagnostic records, of Plaintiff which have been and which may hereafter be produced in this cause; (2) all medical records affidavits and/or medical billing affidavits which have been served and which may hereafter be served in this cause, and all exhibits thereto; (3) the oral depositions and 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. I.3. 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 alleged injuries, incapacities, and disabilities; b. Plaintiff’s injuries, incapacities, and/or disabilities are the result in whole or in part of the injuries received by Plaintiff as a result of the subject incident and made the subject of this suit; c. the medical care and treatment rendered to Plaintiff was reasonable and necessary; d. the subject incident did, based on reasonable medical probability, cause all of the complaints, disabilities, injuries, and/or incapacities of Plaintiff; e. that any surgical intervention for treatment of Plaintiff’s injuries and/or symptoms was necessitated and proximately caused by the incident made the subject of this lawsuit; f. that the medical treatment and expenses of Plaintiff were necessitated by the incident which is the subject of this lawsuit; g. that Plaintiff will, in reasonable probability, require medical care in the future to treat the injuries and/or symptoms proximately caused by the incident made the subject of this lawsuit, and the reasonable cost of that care; g. all other impressions and/or opinions that are contained, discussed, and/or disclosed in the following: (1) the medical records of Plaintiff which has been and which may hereafter be produced in this cause; (2) the medical records affidavits and medical billing affidavits which have been served and which may hereafter be served in this cause and all exhibits thereto; (3) the oral depositions and 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. I.4. Brief Summary of Basis for Impressions and Opinions. 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. All of the medical records of Plaintiff produced in this cause; b. All depositions taken and hereafter taken in this cause, either by written questions or orally, and all exhibits thereto; c. The expert reports, if any, herein above expressly referred to; d. All witness statements which may be produced in this cause; e. All of the photographs and videotape recordings produced in this cause; f. The Responses to Disclosure, Responses to Requests for Production, Answers to Interrogatories, and the Amendments and Supplements thereto which have been served by each of the parties in this cause of action; g. The Pleadings on file in this cause of action; and h. All documents and tangible things produced in this cause. II. NON-RETAINED PEACE OFFICER EXPERTS: The following peace officers, and/or the custodian of their records, may testify regarding the facts of the wreck made the subject matter of this case, the causation of the wreck, and statement made by the persons involved in the wreck, or witnesses thereto. Please refer to the Texas Peace Officer’s Crash Report for their mental impressions, opinions, conclusions, and the factual basis for each opinion. II.1 Identify of Non-Retained Peace Officers. The names of the non-retained/non- controlled Peace Officer expert and his address and telephone number are as follows: Trooper Mark Cooke ID No. 15436 Texas Department of Public Safety Service/Region DA – HP2B12 Lukfin, Texas II.2. Subject Matters of Non-Retained Peace Officer. The subject matters on which said non-retained non-controlled peace officer will testify are as follows: a. the facts surrounding the wreck; b. the cause of the wreck; c. the results of his accident investigation/recreation of the wreck; d. the facts obtained during his investigation of this wreck; e. any observations made by him at the scene of the wreck or during the course of his investigation; f. the substance of any witness statements taken during the course of his investigation; g. any analysis of the vehicles involved in this collision; and h. all those subject matters contained, discussed or disclosed in: (1) the Texas Peace Officer’s Report of the wreck made the subject of this suit; (2) the depositions taken in this cause, orally and on written questions; (3) all written reports produced during the course of discovery in this cause; (4) any and all accident reports created by any governmental agency and all attachments thereto; (5) any and all pictures taken of the wreck, the vehicles involved in the wreck, or the injuries received in the wreck, including all photographs produced during the course of discovery in this cause; (6) all statements produced during the course of discovery in this cause; (7) any deposition testimony given in this cause by any of the above- designated individuals or any individual who also investigated this wreck but who is not specifically identified above. All of which documents are incorporated herein by reference as though set out at length for all purposes. II.3. Impressions and Opinions of Non-Retained Peace Officer. The general substance of said non-retained / non-controlled Peace Officer’s expert mental impressions and opinions are expected to be, and a brief summary of the basis for them are, as follows: a. the facts of the wreck made the subject of this suit; b. the identity of the drivers involved in the wreck made the subject of this suit; c. the causative factors regarding the wreck made the subject of this suit; d. the extent of the damage to the vehicles involved in the wreck made the subject of this suit; e. the traffic conditions, terrain, and weather conditions at the time of the wreck made the subject of this suit; f. all other impressions and opinions that are contained, discussed or disclosed in: (1) the Texas Peace Officer’s Report of the wreck made the subject of this suit; (2) the depositions taken in this cause, orally and on written questions; (3) all written reports produced during the course of discovery in this cause; (4) any and all accident reports created by any governmental agency and all attachments thereto; (5) any and all pictures taken of the wreck, the vehicles involved in the wreck, or the injuries received in the wreck, including all photographs produced during the course of discovery in this cause; (6) all statements produced during the course of discovery in this cause; (7) any deposition testimony given in this cause by any of the above- designated individuals or any individual who also investigated this wreck but who is not specifically identified above. All of which documents are incorporated herein by reference as though set out at length for all purposes. II.4. Brief Summary of Basis For Impressions And Opinions. The basis for the foregoing impressions and opinions of the above named and/or designated expert witness are all of the facts shown by and/or contained in: a. the Peace Officer’s investigation of the wreck including the scene of the wreck, the vehicles involved, the statements of the drivers and passengers in the vehicles, statements of witnesses to the wreck, and emergency medical care rendered to the parties; b. the Peace Officer’s report and notes pertaining to the wreck made the subject of this suit; 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 or obtained by the designated individuals during the course of their investigation; g. Disclosures, Responses to Requests for Production, Answers to Interrogatories, and the Amendments and Supplements thereto which have been filed by each of the parties to this cause; h. the Pleadings on file in this cause; i. all documents and tangible things produced in this cause; j. All depositions taken and hereafter taken in this cause, either by written questions or orally, and all exhibits thereto; k. Any and all accident reports created by any governmental agency and all attachments thereto; l. the education, knowledge and experience of the investigating officer along with any specialized training received by him and his observations, deductions and calculations performed during his investigation of this wreck. All of which records, reports, documents, depositions, photographs and videotape recordings are incorporated herein by reference and made a part hereof for all purposes as if set out at length herein. III. NON-RETAINED NON-MEDICAL EXPERT: The following person and/or the custodian of records, may testify regarding the facts of the damage to Plaintiff’s vehicle as a result of the collision. III.1 Identify of Non-Medical Expert. The names of the non-retained/non-controlled expert and his/her address and telephone number are as follows: Becky Laughlin Briley’s Paint and Body, Inc. 4003 Broad Street Lake Charles, Louisiana 70615 (337) 491-9481 III.2. Subject Matters of Non-Retained Non-Medical Expert. The subject matters on which said non-retained non-medical expert will testify are as follows: a. the damages to Plaintiff’s vehicle; b. the cost to repair Plaintiff’s vehicle; c. the Preliminary Estimate and any supplemental estimate; d. loss of use of the vehicle while the repairs are made; e. allotted time for the repairs; f. damage related to the motor vehicle collision; and g. any and all pictures taken of the wreck, the vehicles involved in the wreck, including all photographs produced during the course of discovery in this cause; All of which documents are incorporated herein by reference as though set out at length for all purposes. III.3. Impressions and Opinions of Non-Retained Non-Medical Expert. The general substance of said non-retained non-medical expert mental impressions and opinions are expected to be, and a brief summary of the basis for them are, as follows: a. the damages to Plaintiff’s vehicle; b. all other impressions and opinions that are contained, discussed or disclosed in: 1) the Preliminary Estimate and any supplemental estimate that may be obtained; 2) the cost of all repairs in the preliminary estimate and any supplemental estimate that may be obtained; 3) all repairs reflected in the estimate to the stripes and mouldings and any repairs that may be required to the stripes and mouldings in any supplemental estimate, if any; 4) all repairs reflected in the estimate to the front doors and any repairs that may be required to the front doors in any supplemental estimate, if any; 5) all repairs reflected in the estimate to the rear doors and any repairs that may be required to the rear doors in a supplemental estimate, if any; 6) all repairs reflected in the estimate to the quarter and rocker panel and any repairs that may be required to the quarter and rocker panel in any supplemental estimate, if any; 7) all repairs reflected in the estimate to the inner quarter and panels and any repairs that may be required to the inner quarter and panels in any supplemental estimate, if any; 8) all repairs reflected in the estimate to the rear bumper and any repairs that may be required to the rear bumper in any supplemental estimate, if any; 9) all repairs reflected in the estimate to the rear body, lamps and floor plan and any repairs that may be required to the rear body, lamps and floor plan in any supplemental estimate, if any; 10) all repairs reflected in the estimate for manual entries and any repairs that may be required as manual entries in any supplemental estimate, if any; 11) the value of all parts, materials, paints, labor, including taxes, to repair the vehicle reflected in the estimate, including any supplemental estimate; 12) the depositions taken in this cause, orally and on written questions; 13) all written reports produced during the course of discovery in this cause; 14) any and all pictures taken of the wreck, the vehicles involved in the wreck, or the injuries received in the wreck, including all photographs produced during the course of discovery in this cause; and 15) any deposition testimony given in this cause by any of the above- designated individuals or any individual who also investigated this wreck but who is not specifically identified above. All of which documents are incorporated herein by reference as though set out at length for all purposes. III.4. Brief Summary of Basis For Impressions And Opinions. The basis for the foregoing impressions and opinions of the above named and/or designated expert witness are all of the facts shown by and/or contained in: a. the repair man/woman’s investigation vehicle including the photographs of the wreck, the vehicles involved, the statements of the drivers and passengers in the vehicles, statements of witnesses to the wreck; b. the Peace Officer’s report and notes pertaining to the wreck made the subject of this suit; 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 or obtained by the designated individuals during the course of their investigation; g. Disclosures, Responses to Requests for Production, Answers to Interrogatories, and the Amendments and Supplements thereto which have been filed by each of the parties to this cause; h. the Pleadings on file in this cause; i. all documents and tangible things produced in this cause; j. All depositions taken and hereafter taken in this cause, either by written questions or orally, and all exhibits thereto; k. Any and all accident reports created by any governmental agency and all attachments thereto; and l. the education, knowledge and experience of repair man/woman along with any specialized training received by him and his observations, deductions and calculations performed during his investigation of this wreck. All of which records, reports, documents, depositions, photographs and videotape recordings are incorporated herein by reference and made a part hereof for all purposes as if set out at length herein. IV. ADDITIONAL DISCLOSURES All records, reports, documents, depositions, photographs and videotape recordings taken or obtained in this matter and produced by any party or non-party in this matter are incorporated herein by reference and made a part hereof for all purposes as if set out at length herein. 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 Defendant to Plaintiff’s retained and non-retained experts’ files, reports and supplemental reports; written discovery responses of all parties; pleadings of all parties; depositions and exhibits thereto; medical and billing records; rebuttal opinions; factual observations and opinions. Plaintiff further reserves the right through cross-examination or deposition, to call any expert witness identified herein by any 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 that Plaintiff may have regarding 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 designated fact witnesses within any area as to which such person has expertise. Respectfully submitted, SLOAN, HATCHER, PERRY, RUNGE, ROBERTSON & SMITH /s/ J. Kendon Womack J. KENDON WOMACK State Bar No. 24117620 kwomack@sloanfirm.com JUSTIN A. SMITH State Bar No. 24068415 jsmith@sloanfirm.com 101 East Whaley Street Longview, Texas 75601 Telephone: (903) 757-7000 Facsimile: (903) 757-7574 ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has been forwarded via efile in accordance with the Texas Rules of Civil Procedure on this 02 day of November 2021, to the following attorney of record: Lindsay G. Gorbach Laura E. Calloway Cox PLLC 8144 Walnut Hill Lane, Suite 1090 Dallas, Texas 75230 lgorbach@cloxpllc.com lcalloway@coxpllc.com /s/ J. Kendon Womack J. KENDON WOMACK 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. Lida Vega on behalf of J. Womack Bar No. 24117620 lvega@sloanfirm.com Envelope ID: 58757336 Status as of 11/2/2021 11:27 AM CST Associated Case Party: TADWILLIAMS Name BarNumber Email TimestampSubmitted Status Lindsay G.Gorbach lgorbach@coxpllc.com 11/2/2021 11:06:31 AM SENT Greg Brenner gbrenner@coxpllc.com 11/2/2021 11:06:31 AM SENT Laura Calloway lcalloway@coxpllc.com 11/2/2021 11:06:31 AM SENT Cindy Lewis clewis@coxpllc.com 11/2/2021 11:06:31 AM SENT Associated Case Party: THECRETE CARRIER CORPORATION Name BarNumber Email TimestampSubmitted Status Lindsay G.Gorbach lgorbach@coxpllc.com 11/2/2021 11:06:31 AM SENT Laura Atherstone latherstone@coxpllc.com 11/2/2021 11:06:31 AM SENT Cindy Lewis clewis@coxpllc.com 11/2/2021 11:06:31 AM SENT Associated Case Party: SHRADESHSHRESTHA Name BarNumber Email TimestampSubmitted Status J. KendonWomack kwomack@sloanfirm.com 11/2/2021 11:06:31 AM SENT Justin A.Smith jsmith@sloanfirm.com 11/2/2021 11:06:31 AM SENT Lida Vega lvega@sloanfirm.com 11/2/2021 11:06:31 AM SENT