On April 02, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Offen, Todd,
and
Kenyon, Carla,
Kenyon, John,
Progressive Casualty Insurance Company,
Statefarm Mutual Automobile Insurance Company,
for OTHER (CIVIL)
in the District Court of Dallas County.
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FILED
8/18/2022 3:53 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Marissa Gomez DEPUTY
CAUSE NO. DC-20-05169
TODD OFFEN, IN THE DISTRICT COURT
§§§§§§§§§§§
Plaintifi’,
V.
DALLAS COUNTY, TEXAS
CARLA KENYON, JOHN KENYON,
PROGRESSIVE COUNTY MUTUAL
INSURANCE COMPANY, and STATE
FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY
Defendants. 134TH JUDICIAL DISTRICT
DEFENDANT PROGRESSIVE COUNTY MUTUAL INSURANCE COMPANY’S
MOTION FOR LEAVE TO FILE APPENDIX IN EXCESS OF 25 PAGES IN SUPPORT
OF PROGRESSIVE’S BRIEF IN SUPORT OF MOTION TO QUASH CORPORATE
REPRESENTATIVE DEPOSITION AND MOTION FOR PROTECTIVE ORDER
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Progressive County Mutual Insurance Company (“Progressive”), one of
the Defendants, in the above styled and numbered cause, and files this Motion for Leave to File
Appendix in Excess of 25 Pages in Support of Progressive’s Brief in Support of Motion to Quash
Corporate Representative’s Deposition and Motion for Protective Order, and in support thereof
would respectfully represent and show unto the Court the following:
Concurrently herewith, Progressive has filed Progressive’s Brief in Support of Motion to
Quash and Motion for Protective Order of Plaintiff’s Third Amended Notice of Oral and
Videotaped Deposition of a Corporate Representative for Progressive (“Brief”). Pursuant to the
Amended Local Rule of the Civil District Courts of Dallas County, Texas, adopted by some of the
Dallas courts, Progressive requests leave to file the evidentiary appendix in support of
Progressive’s Brief, which exceeds 25 pages. In spite of Progressive’s best efforts to cull
unnecessary materials and pages, the evidence necessary to support the Brief exceeds 25 pages.
As it was necessary for Progressive to support their Motion to Quash and Motion for Protective
Defendant Progressive’s Motion for Leave to File Appendix in Excess of 25 Pages Page l of 2
90401
Order with evidence, Progressive has a compelling need to be permitted to submit an appendix in
excess of 25 pages. Accordingly, Progressive respectfully requests leave to file an appendix in
excess of 25 pages to the Brief in Support of the Motion to Quash Plaintiff’ s Third Amended
Notice of Oral and Videotaped Deposition of Progressive and Motion for Protective Order.
Respectfully submitted,
WALTERS, BALIDO & CRAIN, L.L.P.
BY: /s/ Randall G. Walters
RANDALL G. WALTERS — 20819480
randy.walters@Wbclawfirmcom
Service of Documents:
WaltersEDocsNotifications@wbclawfirm.com
Meadow Park Tower, Suite 1500
10440 North Central Expressway
Dallas, Texas 75231
214/760-1670 — FAX
214/749-4805 MAIN
ATTORNEY FOR DEFENDANT
PROGRESSIVE COUNTY MUTUAL
INSURANCE COMPANY
CERTIFICATE OF SERVICE
This is to certify that on this the 18th day of August, 2022, a true and correct copy of the
above document has been forwarded to all known counsel of record.
/s/ Randall G. Walters
RANDALL G. WALTERS
Defendant Progressive’s Motion for Leave to File Appendix in Excess of 25 Pages Page 2 of 2
90401
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.
Kimberly Childs on behalf of Randall Walters
Bar No. 20819480
Kimberly.Childs@wbclawfirm.com
Envelope ID: 67445976
Status as of 8/18/2022 4:09 PM CST
Associated Case Party: TODD OFFEN
Name BarNumber Email TimestampSubmitted Status
Collen AClark eservice@cvpalaw.com 8/18/2022 3:53:20 PM SENT
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.
Kimberly Childs on behalf of Randall Walters
Bar No. 20819480
Kimberly.Childs@wbclawfirm.com
Envelope ID: 67445976
Status as of 8/18/2022 4:09 PM CST
Associated Case Party: PROGRESSIVE CASUALTY INSURANCE COMPANY
Name BarNumber Email TimestampSubmitted Status
Randall GWalters waltersedocsnotifications@wbclawfirm.com 8/18/2022 3:53:20 PM SENT
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.
Kimberly Childs on behalf of Randall Walters
Bar No. 20819480
Kimberly.Childs@wbclawfirm.com
Envelope ID: 67445976
Status as of 8/18/2022 4:09 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Francine Ly fly@dallascourts.org 8/18/2022 3:53:20 PM SENT
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.
Kimberly Childs on behalf of Randall Walters
Bar No. 20819480
Kimberly.Childs@wbclawfirm.com
Envelope ID: 67445976
Status as of 8/18/2022 4:09 PM CST
Associated Case Party: STATEFARM MUTUAL AUTOMOBILE INSURANCE COMPANY
Name BarNumber Email TimestampSubmitted Status
Diane TWeisman dweisman@harrisonhull.com 8/18/2022 3:53:20 PM SENT
Michael P.Gross mgross@harrisonhull.com 8/18/2022 3:53:20 PM SENT
Document Filed Date
August 18, 2022
Case Filing Date
April 02, 2020
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FILED 8/18/2022 3:53 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Marissa Gomez DEPUTY CAUSE NO. DC-20-05169 TODD OFFEN, IN THE DISTRICT COURT §§§§§§§§§§§ Plaintifi’, V. DALLAS COUNTY, TEXAS CARLA KENYON, JOHN KENYON, PROGRESSIVE COUNTY MUTUAL INSURANCE COMPANY, and STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY Defendants. 134TH JUDICIAL DISTRICT DEFENDANT PROGRESSIVE COUNTY MUTUAL INSURANCE COMPANY’S MOTION FOR LEAVE TO FILE APPENDIX IN EXCESS OF 25 PAGES IN SUPPORT OF PROGRESSIVE’S BRIEF IN SUPORT OF MOTION TO QUASH CORPORATE REPRESENTATIVE DEPOSITION AND MOTION FOR PROTECTIVE ORDER TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Progressive County Mutual Insurance Company (“Progressive”), one of the Defendants, in the above styled and numbered cause, and files this Motion for Leave to File Appendix in Excess of 25 Pages in Support of Progressive’s Brief in Support of Motion to Quash Corporate Representative’s Deposition and Motion for Protective Order, and in support thereof would respectfully represent and show unto the Court the following: Concurrently herewith, Progressive has filed Progressive’s Brief in Support of Motion to Quash and Motion for Protective Order of Plaintiff’s Third Amended Notice of Oral and Videotaped Deposition of a Corporate Representative for Progressive (“Brief”). Pursuant to the Amended Local Rule of the Civil District Courts of Dallas County, Texas, adopted by some of the Dallas courts, Progressive requests leave to file the evidentiary appendix in support of Progressive’s Brief, which exceeds 25 pages. In spite of Progressive’s best efforts to cull unnecessary materials and pages, the evidence necessary to support the Brief exceeds 25 pages. As it was necessary for Progressive to support their Motion to Quash and Motion for Protective Defendant Progressive’s Motion for Leave to File Appendix in Excess of 25 Pages Page l of 2 90401 Order with evidence, Progressive has a compelling need to be permitted to submit an appendix in excess of 25 pages. Accordingly, Progressive respectfully requests leave to file an appendix in excess of 25 pages to the Brief in Support of the Motion to Quash Plaintiff’ s Third Amended Notice of Oral and Videotaped Deposition of Progressive and Motion for Protective Order. Respectfully submitted, WALTERS, BALIDO & CRAIN, L.L.P. BY: /s/ Randall G. Walters RANDALL G. WALTERS — 20819480 randy.walters@Wbclawfirmcom Service of Documents: WaltersEDocsNotifications@wbclawfirm.com Meadow Park Tower, Suite 1500 10440 North Central Expressway Dallas, Texas 75231 214/760-1670 — FAX 214/749-4805 MAIN ATTORNEY FOR DEFENDANT PROGRESSIVE COUNTY MUTUAL INSURANCE COMPANY CERTIFICATE OF SERVICE This is to certify that on this the 18th day of August, 2022, a true and correct copy of the above document has been forwarded to all known counsel of record. /s/ Randall G. Walters RANDALL G. WALTERS Defendant Progressive’s Motion for Leave to File Appendix in Excess of 25 Pages Page 2 of 2 90401 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. Kimberly Childs on behalf of Randall Walters Bar No. 20819480 Kimberly.Childs@wbclawfirm.com Envelope ID: 67445976 Status as of 8/18/2022 4:09 PM CST Associated Case Party: TODD OFFEN Name BarNumber Email TimestampSubmitted Status Collen AClark eservice@cvpalaw.com 8/18/2022 3:53:20 PM SENT 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. Kimberly Childs on behalf of Randall Walters Bar No. 20819480 Kimberly.Childs@wbclawfirm.com Envelope ID: 67445976 Status as of 8/18/2022 4:09 PM CST Associated Case Party: PROGRESSIVE CASUALTY INSURANCE COMPANY Name BarNumber Email TimestampSubmitted Status Randall GWalters waltersedocsnotifications@wbclawfirm.com 8/18/2022 3:53:20 PM SENT 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. Kimberly Childs on behalf of Randall Walters Bar No. 20819480 Kimberly.Childs@wbclawfirm.com Envelope ID: 67445976 Status as of 8/18/2022 4:09 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Francine Ly fly@dallascourts.org 8/18/2022 3:53:20 PM SENT 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. Kimberly Childs on behalf of Randall Walters Bar No. 20819480 Kimberly.Childs@wbclawfirm.com Envelope ID: 67445976 Status as of 8/18/2022 4:09 PM CST Associated Case Party: STATEFARM MUTUAL AUTOMOBILE INSURANCE COMPANY Name BarNumber Email TimestampSubmitted Status Diane TWeisman dweisman@harrisonhull.com 8/18/2022 3:53:20 PM SENT Michael P.Gross mgross@harrisonhull.com 8/18/2022 3:53:20 PM SENT