Preview
141-321588-20 FILED
TARRANT COUNTY
6/15/2022 6:17 PM
THOMAS A. WILDER
CAUSE NO. 141-321588-20 DISTRICT CLERK
VIVIAN UPSHAW IN THE DISTRICT COURT
Plaintiff,
141ST JUDICIAL DISTRICT
VS.
CLINT BURGESS TARRANT COUNTY, TEXAS
Defendant.
DEFENDANT’S MOTION IN LIMINE
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES CLINT BURGESS, hereinafter referred to as "Defendant," and before
any proceedings before the jury, makes and files this MOTION IN LIMINE, and respectfully
moves the Court to instruct Plaintiff(s) and Plaintiff(s)' counsel to refrain from either directly or
indirectly, upon voir dire examination, opening statement, interrogation of witnesses,
introduction of any evidence, argument, objections before the jury, reading of any portion of the
pleadings, or by any other means or in any other manner, informing the jury, or bringing to the
jury's attention, any of the matters set forth in the numbered paragraphs below, unless and until
such matters have been first called to the attention of the Court, out of the presence and/or
hearing of the jury, and a favorable ruling has been obtained from the Court as to the
admissibility and relevance of any such matters.
Defendant would also note that due to the current pandemic climate and the premium
being placed on getting a live jury to show up for jury selection, that these matters be strictly
enforced. A mistrial in this atmosphere is no more or less justified based upon violation of the
parties’ motions in limine, but it may be more costly to all parties involved and the community
and courts as a whole.
Upshaw vs. Burgess PAGE 1
DEFENDANT’S MOTION IN LIMINE
1. Insurance. Unless an insurance company is a named Defendant, that the Defendant
is or is not protected, in whole or in part, by liability insurance, or that defense
counsel was retained by, or all or any part of the costs of defense, or of any resulting
judgment, are or will be paid by an insurance company, or any other matter
suggesting an involvement of any insurance company with the defense of the case.
2. Jurors' Connection with Insurance Industry. Inquiring of potential jurors as to
their present or past employment or connection with the insurance industry, or present
or past connection of any family member with the insurance industry, except that:
a) If a potential juror's juror information card discloses employment in the insurance
industry, such potential juror may be questioned concerning same.
b) Inquiry may be made of potential jurors concerning their experience (or that of
members of their family), if any, reviewing, adjusting or allowing/disallowing
claims, as long as no express reference is made to "insurance."
3. Liability or Non-Liabilitv for Judgment. That the named Defendant(s) may or may
not have to pay any resulting judgment.
4. Attorneys' Fees. That any party will have to pay attorneys' fees, or any reference to
the amount or basis of any attorneys' fees, unless a claim for recovery of attorneys'
fees in the case will be submitted to the jury.
5. Criminal Offenses. That any party or witness has been suspected of, arrested for,
charged with or convicted of any criminal offense unless there is evidence of a
specific conviction that the Court has previously ruled is admissible in the case.
6. Alcohol or Drug Use. That any party or witness uses or abuses alcohol, tobacco, or
any controlled substance, unless and until such alleged use or abuse is shown to be
specifically relevant to the matters in controversy. Amoco Chemicals Corp. vs.
Stafford, 663 S.W.2d 147 (Tex. App.—Houston [1st Dist.] 1983, no writ).; TRCE
801(d); TRCE 403.
7. Settlement Negotiations or Mediation. Any negotiations, offers or demands with
respect to any attempted settlement or mediation. TRCE 408; Beutel vs. Paul, 741
S.W.2d 510 (Tex. App.—Houston [14th Dist.] 1987, no writ).
8. Discovery Disputes. Any reference to discovery disputes that arose during the
preparation of the case for trial, any position taken by any party with respect thereto,
or to the Court's rulings thereon.
Upshaw vs. Burgess PAGE 2
DEFENDANT’S MOTION IN LIMINE
9. Hearsay Medical Opinions. Any hearsay statement offered for the truth of the
statement by an allegedly injured person concerning any diagnosis or medical
opinions communicated to such person by a physician or other health care provider.
Such would be an attempt to introduce before the jury expert testimony without a
proper predicate concerning the expert’s qualifications and abilities to give such
testimony. Defendant would note that TRE 803(4) specifically excepts statements
made to a medical provider for diagnosis or treatment from the hearsay rule. This
does not apply to statements by a medical provider to the patient. The idea is that an
individual is unlikely to lie to a medical provider since they want an accurate
diagnosis and appropriate treatment. Conversely, there is not the same reassurance of
truthfulness when itcomes to an individual stating what the doctor told them in the
middle of a personal injury jury trial for money damages.
10. Requests for Stipulations. Any request or demand in the presence of the jury for a
stipulation to any fact, or that counsel admit or deny any fact.
11. Requests for Files. Any request or demand in the presence of the jury that opposing
counsel produce any document or thing, or that opposing counselor any party or
witness exhibit, turn over or allow examination of the contents of any file or briefcase
(except that a party may demand to see a document used by a witness on the stand to
refresh his/her recollection, or that a witness testifies that he/she has used previously
to refresh his/her recollection).
12. Discrimination. Any argument that a party should be treated more or less favorably
because of such party's race, gender, national origin, nationality, religion, marital
status, occupation, or financial status (except in the second phase of a bifurcated
trial).
13. Hardship or Privation. Any argument or suggestion that a failure to award damages
will cause a Plaintiff privation or financial hardship except that Plaintiff’s counsel
may certainly argue that Plaintiff has a particular amount of money outstanding for
past medical bills.
14. Golden Rule. Any argument or suggestion that the jurors should put themselves in
the position of a party. World Wide Tire Co. vs. Brown, 644 S.W.2d 144 (Tex. App.-
Houston [14th Dist.] 1982, writ ref’d n.r.e.).
15. Effect of Answers to Jury Questions. Any argument that any finding or failure to
find in response to a particular jury question will or will not result in a judgment
favorable to any party. This provision does not bar argument by counsel that a
particular jury question should be answered in a particular way. Cooper vs. Argonaut
Insurance Co., 430 S.W. 2d. 35 (Tex. Civ. App.—Dallas 1968, writ ref’d n.r.e.).
Such argument is improper under the Texas special verdict system because it advises
the jury of the effect of its answers.
Upshaw vs. Burgess PAGE 3
DEFENDANT’S MOTION IN LIMINE
16. Objections to Evidence Not Produced in Discovery. Any objection based on failure
to disclose evidence in pre-trial discovery. Any party desiring to urge any such
objection shall request to approach the bench and urge such objection outside the
hearing of the jury. To the extent possible or predictable, such matters should be
addressed and a ruling sought at pretrial once the case is assigned for trial, although
the objection may be urged for the record outside the hearing of the jury at the time
such evidence is offered in the event the Court has overruled the objection at pretrial.
17. Qualifying Expert Witness. Calling any witness to testify as an expert without
having first been qualified as an expert for those matters which were disclosed in
response to Request for Disclosure. In addition, prior to the expert stating any
opinion he must be required to disclose the underlying facts or data which forms his
“expert” opinion pursuant to Rule 705 of the Texas Rules of Evidence.
18. Available Assets. Any inquiry into or reference to the assets Defendant has available
for investigating, preparing and defending this cause. First Nat’l Bank of Marshall
vs. Beavers, 619 S.W.2d 288 (Tex. Civ. App.—Texarkana 1981, writ ref’d n.r.e.);
Wimoth vs. Limestone Prods. Co., 255 S.W.2d 532, 534 (Tex. App.—Waco 1953,
writ ref’d n.r.e.).
19. Voir Dire – Pre-testing Evidence / Previewing Verdict. Any inquiry attempting to
determine the weight jurors will give to the evidence. If a question does not seek to
discover a disqualifying bias or prejudice but seeks to determine the weight jurors
will give to the evidence, such question is an improper attempt to pre-test the
evidence and preview the verdict and therefore objectionable. Hyundai Motor Co. v.
Vasquez, 189 S.W.3d 743 (Tex. 2006).
20. Prior Automobile Accidents. Any inquiry into or disclosing that the Defendant(s)
has/have been involved in any prior or subsequent automobile accident. Any
testimony regarding previous or subsequent accidents is irrelevant and far too
prejudicial to discuss before the jury.
21. Prior Speeding Tickets. Any inquiry into or disclosing that the Defendant has ever
been issued any speeding tickets prior to or subsequent to this accident. As the Texas
Supreme Court wrote in Missouri-Kansas-Texas Railroad Co. vs. May, 600 S.W.2d.
755 (Tex. 1980), “as a general rule, evidence of similar acts is inadmissible on the
issue of whether someone was a negligent in doing or not doing a particular act.”
22. Investigative Officer’s Opinion. Any inquiry or reference to the fact that the
investigative officer has formed an opinion or determined a cause of the accident or
that one of the drivers was at fault until the qualifications of the officer has been
established. Pilgrim’s Pride Corp. vs. Smoak, 134 S.W. 3 rd
880, (Tex. App.—
Texarkana, 2004, pet. denied) (investigating officer's testimony on accident causation
was required to be given by a qualified person in science of accident reconstruction.)
See also DeLarue vs. State, 102 S.W.3d 388, Tex. App.—Houston, [14th Dist.] 2003;
and Ter-Vartanyan vs. R&R Freight, Inc., 111 S.W. 3rd 779, Tex. App.—Dallas,
2003, pet. denied).
Upshaw vs. Burgess PAGE 4
DEFENDANT’S MOTION IN LIMINE
23. Photographs. Showing any photographs to the jury until the same has been tendered
to opposing counsel and admitted into evidence.
24. Comments on “sending a message.” Plaintiff be prohibited from making any
argument, comment or inference during any phase of this trial that Defendant should
be held accountable or responsible for the purpose of sending a message on behalf of
society as a whole or sending a message that a particular behavior will not be
tolerated. This is because it appeals to a juror’s fear and plays upon bias, prejudice or
sympathy rather than a principled weighing of what the credible evidence shows.
25. Lost Wage Earning Capacity in the Future. Any inquiry or reference to whether
Plaintiff wage earning capacity in the future is impacted by this motor vehicle
accident. This is being requested since Plaintiff has not timely enumerated any lost
wage earning capacity in the future calculations in response to Defendant(s) Request
for Disclosure (D).
26. Future Medical Expenses. Any testimony, documentary evidence, argument,
inquiry, or reference as to Plaintiff’s future medical that is not itemized and calculated
in Plaintiff(s)’ disclosure responses (i.e. – any amount greater than $15,703.00). This
is being requested as future medical damages are a form of economic damages that
must be itemized and calculated in Plaintiff(s)’ initial disclosures or in response to
Defendant(s) Request for Disclosure (D). Defendant is not agreeing that Plaintiff’s
evidence supports this amount; just that Plaintiff cannot claim an amount greater than
this figure due to representations in her disclosure responses.
27. Service of Process on Defendant in this Lawsuit. Any testimony, documentary
evidence, argument, inquiry, or reference as to details surrounding how Defendant
was served with process in this lawsuit as that topic is not relevant to the issues before
the jury: (1) Negligence; and (2) Damages.
Upshaw vs. Burgess PAGE 5
DEFENDANT’S MOTION IN LIMINE
Respectfully submitted,
LISA CHASTAIN & ASSOCIATES
YOUNG C. JENKINS
TBN: 24034505
P.O. Box 655441
Dallas, TX 75265
E-Service Only: DallasLegal@allstate.com
(214) 659-4346
(877) 678-4763 (fax)
ATTORNEY FOR DEFENDANT(S)
CLINT BURGESS
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been served in
compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on June 15, 2022 to:
KRIS HEALD & JAMES RICHARDSON
THE HEALD LAW FIRM, PLLC
12222 Merit Drive, Suite 1200
Dallas, TX 75251
469/598-1900
469/598-1910
kris.heald@healdlawfirm.com
james.richardson@healdlawfirm.com
ATTORNEYS FOR PLAINTIFF
YOUNG C. JENKINS
Upshaw vs. Burgess PAGE 6
DEFENDANT’S MOTION IN LIMINE
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.
Young Jenkins
Bar No. 24034505
yjena@allstate.com
Envelope ID: 65488781
Status as of 6/16/2022 8:18 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Sharon Williams sharon.williams@healdlawfirm.com 6/15/2022 6:17:15 PM SENT
Kris Heald kris.heald@healdlawfirm.com 6/15/2022 6:17:15 PM SENT
James Richardson james.richardson@healdlawfirm.com 6/15/2022 6:17:15 PM SENT
Elizabeth Flores elizabeth.flores@healdlawfirm.com 6/15/2022 6:17:15 PM SENT
Associated Case Party: VIVIANUPSHAW
Name BarNumber Email TimestampSubmitted Status
Devin Brown Devin.Brown@healdlawfirm.com 6/15/2022 6:17:15 PM SENT
Preview
141-321588-20 FILED TARRANT COUNTY 6/15/2022 6:17 PM THOMAS A. WILDER CAUSE NO. 141-321588-20 DISTRICT CLERK VIVIAN UPSHAW IN THE DISTRICT COURT Plaintiff, 141ST JUDICIAL DISTRICT VS. CLINT BURGESS TARRANT COUNTY, TEXAS Defendant. DEFENDANT’S MOTION IN LIMINE TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES CLINT BURGESS, hereinafter referred to as "Defendant," and before any proceedings before the jury, makes and files this MOTION IN LIMINE, and respectfully moves the Court to instruct Plaintiff(s) and Plaintiff(s)' counsel to refrain from either directly or indirectly, upon voir dire examination, opening statement, interrogation of witnesses, introduction of any evidence, argument, objections before the jury, reading of any portion of the pleadings, or by any other means or in any other manner, informing the jury, or bringing to the jury's attention, any of the matters set forth in the numbered paragraphs below, unless and until such matters have been first called to the attention of the Court, out of the presence and/or hearing of the jury, and a favorable ruling has been obtained from the Court as to the admissibility and relevance of any such matters. Defendant would also note that due to the current pandemic climate and the premium being placed on getting a live jury to show up for jury selection, that these matters be strictly enforced. A mistrial in this atmosphere is no more or less justified based upon violation of the parties’ motions in limine, but it may be more costly to all parties involved and the community and courts as a whole. Upshaw vs. Burgess PAGE 1 DEFENDANT’S MOTION IN LIMINE 1. Insurance. Unless an insurance company is a named Defendant, that the Defendant is or is not protected, in whole or in part, by liability insurance, or that defense counsel was retained by, or all or any part of the costs of defense, or of any resulting judgment, are or will be paid by an insurance company, or any other matter suggesting an involvement of any insurance company with the defense of the case. 2. Jurors' Connection with Insurance Industry. Inquiring of potential jurors as to their present or past employment or connection with the insurance industry, or present or past connection of any family member with the insurance industry, except that: a) If a potential juror's juror information card discloses employment in the insurance industry, such potential juror may be questioned concerning same. b) Inquiry may be made of potential jurors concerning their experience (or that of members of their family), if any, reviewing, adjusting or allowing/disallowing claims, as long as no express reference is made to "insurance." 3. Liability or Non-Liabilitv for Judgment. That the named Defendant(s) may or may not have to pay any resulting judgment. 4. Attorneys' Fees. That any party will have to pay attorneys' fees, or any reference to the amount or basis of any attorneys' fees, unless a claim for recovery of attorneys' fees in the case will be submitted to the jury. 5. Criminal Offenses. That any party or witness has been suspected of, arrested for, charged with or convicted of any criminal offense unless there is evidence of a specific conviction that the Court has previously ruled is admissible in the case. 6. Alcohol or Drug Use. That any party or witness uses or abuses alcohol, tobacco, or any controlled substance, unless and until such alleged use or abuse is shown to be specifically relevant to the matters in controversy. Amoco Chemicals Corp. vs. Stafford, 663 S.W.2d 147 (Tex. App.—Houston [1st Dist.] 1983, no writ).; TRCE 801(d); TRCE 403. 7. Settlement Negotiations or Mediation. Any negotiations, offers or demands with respect to any attempted settlement or mediation. TRCE 408; Beutel vs. Paul, 741 S.W.2d 510 (Tex. App.—Houston [14th Dist.] 1987, no writ). 8. Discovery Disputes. Any reference to discovery disputes that arose during the preparation of the case for trial, any position taken by any party with respect thereto, or to the Court's rulings thereon. Upshaw vs. Burgess PAGE 2 DEFENDANT’S MOTION IN LIMINE 9. Hearsay Medical Opinions. Any hearsay statement offered for the truth of the statement by an allegedly injured person concerning any diagnosis or medical opinions communicated to such person by a physician or other health care provider. Such would be an attempt to introduce before the jury expert testimony without a proper predicate concerning the expert’s qualifications and abilities to give such testimony. Defendant would note that TRE 803(4) specifically excepts statements made to a medical provider for diagnosis or treatment from the hearsay rule. This does not apply to statements by a medical provider to the patient. The idea is that an individual is unlikely to lie to a medical provider since they want an accurate diagnosis and appropriate treatment. Conversely, there is not the same reassurance of truthfulness when itcomes to an individual stating what the doctor told them in the middle of a personal injury jury trial for money damages. 10. Requests for Stipulations. Any request or demand in the presence of the jury for a stipulation to any fact, or that counsel admit or deny any fact. 11. Requests for Files. Any request or demand in the presence of the jury that opposing counsel produce any document or thing, or that opposing counselor any party or witness exhibit, turn over or allow examination of the contents of any file or briefcase (except that a party may demand to see a document used by a witness on the stand to refresh his/her recollection, or that a witness testifies that he/she has used previously to refresh his/her recollection). 12. Discrimination. Any argument that a party should be treated more or less favorably because of such party's race, gender, national origin, nationality, religion, marital status, occupation, or financial status (except in the second phase of a bifurcated trial). 13. Hardship or Privation. Any argument or suggestion that a failure to award damages will cause a Plaintiff privation or financial hardship except that Plaintiff’s counsel may certainly argue that Plaintiff has a particular amount of money outstanding for past medical bills. 14. Golden Rule. Any argument or suggestion that the jurors should put themselves in the position of a party. World Wide Tire Co. vs. Brown, 644 S.W.2d 144 (Tex. App.- Houston [14th Dist.] 1982, writ ref’d n.r.e.). 15. Effect of Answers to Jury Questions. Any argument that any finding or failure to find in response to a particular jury question will or will not result in a judgment favorable to any party. This provision does not bar argument by counsel that a particular jury question should be answered in a particular way. Cooper vs. Argonaut Insurance Co., 430 S.W. 2d. 35 (Tex. Civ. App.—Dallas 1968, writ ref’d n.r.e.). Such argument is improper under the Texas special verdict system because it advises the jury of the effect of its answers. Upshaw vs. Burgess PAGE 3 DEFENDANT’S MOTION IN LIMINE 16. Objections to Evidence Not Produced in Discovery. Any objection based on failure to disclose evidence in pre-trial discovery. Any party desiring to urge any such objection shall request to approach the bench and urge such objection outside the hearing of the jury. To the extent possible or predictable, such matters should be addressed and a ruling sought at pretrial once the case is assigned for trial, although the objection may be urged for the record outside the hearing of the jury at the time such evidence is offered in the event the Court has overruled the objection at pretrial. 17. Qualifying Expert Witness. Calling any witness to testify as an expert without having first been qualified as an expert for those matters which were disclosed in response to Request for Disclosure. In addition, prior to the expert stating any opinion he must be required to disclose the underlying facts or data which forms his “expert” opinion pursuant to Rule 705 of the Texas Rules of Evidence. 18. Available Assets. Any inquiry into or reference to the assets Defendant has available for investigating, preparing and defending this cause. First Nat’l Bank of Marshall vs. Beavers, 619 S.W.2d 288 (Tex. Civ. App.—Texarkana 1981, writ ref’d n.r.e.); Wimoth vs. Limestone Prods. Co., 255 S.W.2d 532, 534 (Tex. App.—Waco 1953, writ ref’d n.r.e.). 19. Voir Dire – Pre-testing Evidence / Previewing Verdict. Any inquiry attempting to determine the weight jurors will give to the evidence. If a question does not seek to discover a disqualifying bias or prejudice but seeks to determine the weight jurors will give to the evidence, such question is an improper attempt to pre-test the evidence and preview the verdict and therefore objectionable. Hyundai Motor Co. v. Vasquez, 189 S.W.3d 743 (Tex. 2006). 20. Prior Automobile Accidents. Any inquiry into or disclosing that the Defendant(s) has/have been involved in any prior or subsequent automobile accident. Any testimony regarding previous or subsequent accidents is irrelevant and far too prejudicial to discuss before the jury. 21. Prior Speeding Tickets. Any inquiry into or disclosing that the Defendant has ever been issued any speeding tickets prior to or subsequent to this accident. As the Texas Supreme Court wrote in Missouri-Kansas-Texas Railroad Co. vs. May, 600 S.W.2d. 755 (Tex. 1980), “as a general rule, evidence of similar acts is inadmissible on the issue of whether someone was a negligent in doing or not doing a particular act.” 22. Investigative Officer’s Opinion. Any inquiry or reference to the fact that the investigative officer has formed an opinion or determined a cause of the accident or that one of the drivers was at fault until the qualifications of the officer has been established. Pilgrim’s Pride Corp. vs. Smoak, 134 S.W. 3 rd 880, (Tex. App.— Texarkana, 2004, pet. denied) (investigating officer's testimony on accident causation was required to be given by a qualified person in science of accident reconstruction.) See also DeLarue vs. State, 102 S.W.3d 388, Tex. App.—Houston, [14th Dist.] 2003; and Ter-Vartanyan vs. R&R Freight, Inc., 111 S.W. 3rd 779, Tex. App.—Dallas, 2003, pet. denied). Upshaw vs. Burgess PAGE 4 DEFENDANT’S MOTION IN LIMINE 23. Photographs. Showing any photographs to the jury until the same has been tendered to opposing counsel and admitted into evidence. 24. Comments on “sending a message.” Plaintiff be prohibited from making any argument, comment or inference during any phase of this trial that Defendant should be held accountable or responsible for the purpose of sending a message on behalf of society as a whole or sending a message that a particular behavior will not be tolerated. This is because it appeals to a juror’s fear and plays upon bias, prejudice or sympathy rather than a principled weighing of what the credible evidence shows. 25. Lost Wage Earning Capacity in the Future. Any inquiry or reference to whether Plaintiff wage earning capacity in the future is impacted by this motor vehicle accident. This is being requested since Plaintiff has not timely enumerated any lost wage earning capacity in the future calculations in response to Defendant(s) Request for Disclosure (D). 26. Future Medical Expenses. Any testimony, documentary evidence, argument, inquiry, or reference as to Plaintiff’s future medical that is not itemized and calculated in Plaintiff(s)’ disclosure responses (i.e. – any amount greater than $15,703.00). This is being requested as future medical damages are a form of economic damages that must be itemized and calculated in Plaintiff(s)’ initial disclosures or in response to Defendant(s) Request for Disclosure (D). Defendant is not agreeing that Plaintiff’s evidence supports this amount; just that Plaintiff cannot claim an amount greater than this figure due to representations in her disclosure responses. 27. Service of Process on Defendant in this Lawsuit. Any testimony, documentary evidence, argument, inquiry, or reference as to details surrounding how Defendant was served with process in this lawsuit as that topic is not relevant to the issues before the jury: (1) Negligence; and (2) Damages. Upshaw vs. Burgess PAGE 5 DEFENDANT’S MOTION IN LIMINE Respectfully submitted, LISA CHASTAIN & ASSOCIATES YOUNG C. JENKINS TBN: 24034505 P.O. Box 655441 Dallas, TX 75265 E-Service Only: DallasLegal@allstate.com (214) 659-4346 (877) 678-4763 (fax) ATTORNEY FOR DEFENDANT(S) CLINT BURGESS CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been served in compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on June 15, 2022 to: KRIS HEALD & JAMES RICHARDSON THE HEALD LAW FIRM, PLLC 12222 Merit Drive, Suite 1200 Dallas, TX 75251 469/598-1900 469/598-1910 kris.heald@healdlawfirm.com james.richardson@healdlawfirm.com ATTORNEYS FOR PLAINTIFF YOUNG C. JENKINS Upshaw vs. Burgess PAGE 6 DEFENDANT’S MOTION IN LIMINE 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. Young Jenkins Bar No. 24034505 yjena@allstate.com Envelope ID: 65488781 Status as of 6/16/2022 8:18 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Sharon Williams sharon.williams@healdlawfirm.com 6/15/2022 6:17:15 PM SENT Kris Heald kris.heald@healdlawfirm.com 6/15/2022 6:17:15 PM SENT James Richardson james.richardson@healdlawfirm.com 6/15/2022 6:17:15 PM SENT Elizabeth Flores elizabeth.flores@healdlawfirm.com 6/15/2022 6:17:15 PM SENT Associated Case Party: VIVIANUPSHAW Name BarNumber Email TimestampSubmitted Status Devin Brown Devin.Brown@healdlawfirm.com 6/15/2022 6:17:15 PM SENT