On September 22, 2005 a
PLTFS DESIGNATION OF REBUTTAL EXPERTS
was filed
involving a dispute between
and
for OTHER CIVIL, TEMP RESTRAINING ORDER/INJUNCTION
in the District Court of Tarrant County.
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CAUSE NO. 352-214202-05
RAYMOND SPOTH, GEORGE RAY, INC., § IN THE DISTRICT COURT
PSI PARTNERS, LTD., AND PSI GP, LLC §
AS THE GENERAL PARTNER OF PSI §
PARTNERS, LTD., §
§
PLAINTIFFS, §
§
v. § OFTARRANTCOUNTY,TEXAS
§
PAUL PEEBLES, AND FIRST OLD §
CAPITAL, INC., §
§
DEFENDANTS. § 352N° JUDICIAL DISTRICT
PLAINTIFFS' DESIGNATION OF REBUTTAL EXPERTS
TO THE HONORABLE JUDGE OF SAID COURT:
Raymond Spoth, George Ray, Inc., PSI Partners, Ltd., and PSI GP, LLC as the General
Partner of PSI Partners, Ltd. (collectively "Plaintiffs"), Plaintiffs in the above entitled and
numbered cause and files this their Designation of Rebuttal Experts as required by the Agreed
Discovery Control Order dated April 10, 2006, and subsequent Rule II agreements, and
identifies the following experts to testify at the time of trial:
I.
Plaintiffs' designate the following experts who may testify at the time of trial:
1. David R. Seidler
Hughes & Luce
301 Commerce Street ::;g
Suite3000 ~
Fort Worth, Texas 76102 ·- f::::
(81 7) 347-5275 ~
(817) 347-5299 (Fax) ~
Messr. Seidler will offer rebuttal testimony as to the opinions and mental impi~ions~'
r':J:, ':.:;:,
Defendants' expert witness concerning the reasonableness and necessity of attomeysZkes ~d -,(
PLAINTIFFS' DESIGNATION OF REBUTTAL EXPERTS
Page 1
expenses incurred by Defendants in connection with Defendants' defense against Plaintiffs'
claims and prosecution of Defendants' claims in this case.
2. Nelson Thibodaux
Publisher I Editor
Local News Only
POBox 332
Colleyville, Texas 76034
Mr. Thibodaux is the editor I publisher of the online newspaper localnewsonly.com. Mr.
Thibodaux will present subject matter with regards to web hosting, registration, web design,
ownership, and copyright. Mr. Thibodaux may also present evidence showing registration
designation and web site design and functionality showing the site created by Spoth was more
than a one dimensional website or brochure.
II.
Plaintiffs reserve the right to supplement: (I) the aforementioned designations; and (2)
the experts' reports should Defendants fail to comply with discovery requests.
III.
Plaintiffs designate all of the experts, whether retained or not, that have been designated
by Defendants. Plaintiffs reserve the right to examine or cross-examine and elicit testimony
from each of Defendants' experts whether that testimony is considered "expert" or not.
IV.
Plaintiffs request that this Court take notice of this designation and allow such experts to
testifY at trial.
PLAINTIFFS' DESIGNATION OF REBUTTAL EXPERTS Page2
~~~er·.CB-------
WINSTEAD SECHREST & MINICK P.C.
William Frank Carroll
State Bar No. 03892500
Jennifer L. Murphy
State Bar No. 24027560
Thomas B. Alleman
State Bar No. 01017485
5400 Renaissance Tower
1201 Elm Street
Dallas, Texas 75270-2199
(214) 754-5400 Telephone
(214) 745-5390 Facsimile
ATTORNEYS FOR RAYMOND SPOTH,
GEORGE RAY, INC., PSI PARTNERS, LTD.,
AND PSI GP, LLC AS THE GENERAL
PARTNER OF PSI PARTNERS, LTD.,
CERTIFICATE OF SERVICE
The undersigned counsel affirms that the above document was served pursuant to the
Te= Rul" of Civil Proo
Document Filed Date
July 10, 2006
Case Filing Date
September 22, 2005
Category
OTHER CIVIL, TEMP RESTRAINING ORDER/INJUNCTION
Status
DISMISSED OR NON-SUITED
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CAUSE NO. 352-214202-05 RAYMOND SPOTH, GEORGE RAY, INC., § IN THE DISTRICT COURT PSI PARTNERS, LTD., AND PSI GP, LLC § AS THE GENERAL PARTNER OF PSI § PARTNERS, LTD., § § PLAINTIFFS, § § v. § OFTARRANTCOUNTY,TEXAS § PAUL PEEBLES, AND FIRST OLD § CAPITAL, INC., § § DEFENDANTS. § 352N° JUDICIAL DISTRICT PLAINTIFFS' DESIGNATION OF REBUTTAL EXPERTS TO THE HONORABLE JUDGE OF SAID COURT: Raymond Spoth, George Ray, Inc., PSI Partners, Ltd., and PSI GP, LLC as the General Partner of PSI Partners, Ltd. (collectively "Plaintiffs"), Plaintiffs in the above entitled and numbered cause and files this their Designation of Rebuttal Experts as required by the Agreed Discovery Control Order dated April 10, 2006, and subsequent Rule II agreements, and identifies the following experts to testify at the time of trial: I. Plaintiffs' designate the following experts who may testify at the time of trial: 1. David R. Seidler Hughes & Luce 301 Commerce Street ::;g Suite3000 ~ Fort Worth, Texas 76102 ·- f:::: (81 7) 347-5275 ~ (817) 347-5299 (Fax) ~ Messr. Seidler will offer rebuttal testimony as to the opinions and mental impi~ions~' r':J:, ':.:;:, Defendants' expert witness concerning the reasonableness and necessity of attomeysZkes ~d -,( PLAINTIFFS' DESIGNATION OF REBUTTAL EXPERTS Page 1 expenses incurred by Defendants in connection with Defendants' defense against Plaintiffs' claims and prosecution of Defendants' claims in this case. 2. Nelson Thibodaux Publisher I Editor Local News Only POBox 332 Colleyville, Texas 76034 Mr. Thibodaux is the editor I publisher of the online newspaper localnewsonly.com. Mr. Thibodaux will present subject matter with regards to web hosting, registration, web design, ownership, and copyright. Mr. Thibodaux may also present evidence showing registration designation and web site design and functionality showing the site created by Spoth was more than a one dimensional website or brochure. II. Plaintiffs reserve the right to supplement: (I) the aforementioned designations; and (2) the experts' reports should Defendants fail to comply with discovery requests. III. Plaintiffs designate all of the experts, whether retained or not, that have been designated by Defendants. Plaintiffs reserve the right to examine or cross-examine and elicit testimony from each of Defendants' experts whether that testimony is considered "expert" or not. IV. Plaintiffs request that this Court take notice of this designation and allow such experts to testifY at trial. PLAINTIFFS' DESIGNATION OF REBUTTAL EXPERTS Page2 ~~~er·.CB------- WINSTEAD SECHREST & MINICK P.C. William Frank Carroll State Bar No. 03892500 Jennifer L. Murphy State Bar No. 24027560 Thomas B. Alleman State Bar No. 01017485 5400 Renaissance Tower 1201 Elm Street Dallas, Texas 75270-2199 (214) 754-5400 Telephone (214) 745-5390 Facsimile ATTORNEYS FOR RAYMOND SPOTH, GEORGE RAY, INC., PSI PARTNERS, LTD., AND PSI GP, LLC AS THE GENERAL PARTNER OF PSI PARTNERS, LTD., CERTIFICATE OF SERVICE The undersigned counsel affirms that the above document was served pursuant to the Te= Rul" of Civil Proo