On September 20, 2021 a
Exhibit,Appendix
was filed
involving a dispute between
Rapalo, Delmy,
and
Escobar, Ana Daysi,
Escobar, Noe,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
Preview
FILED
8/19/2022 3:38 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Marissa Gomez DEPUTY
CAUSE NO. DC-21-14009
DELMY RAPALO, INDIVIDUALLY § IN THE DISTRICT COURT
AND AS NEXT FRIEND OF A.A.R., A
MINOR §
§
V. § 134TH JUDICIAL DISTRICT
§
ANA DAYSI ESCOBAR AND NOE §
ESCOBAR § DALLAS COUNTY, TEXAS
DEFENDANTS’ FIRST AMENDED EXHIBIT LIST
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW, Ana Daysi Escobar and Noe Escobar, Defendants herein, and designates
the following as exhibits at the time of trial:
Dft. N0. Offer Grant/Denv Description of Exhibit
1. All photographs of vehicles/scene involved in the
accident;
Property damage estimates regarding the vehicles
involved in the accident;
Police Report regarding the incident in question;
All medical records regarding Minor Plaintiff,
A.A.R., from Children’s Medical Center of
Dallas/Children’s Health;
All medical records regarding Minor Plaintiff,
A.A.R., from City of Dallas;
All medical records regarding Minor Plaintiff,
A.A.R., from Esposito Chiropractic; and
All medical records regarding Minor Plaintiff,
A.A.R., from UT Southwestern Medical Center.
DEFENDANTS’ FIRST AMENDED EHIIBIT LIST - PAGE 1
10000.1 135/ troby
PLEASE TAKE FURTHER NOTICE that Defendants reserve the right to supplement
this exhibit list and to offer other rebuttal evidence and use demonstrative evidence and
demonstrative exhibits in addition to testimony by Witnesses listed in response to Request for
Disclosure and to call rebuttal witnesses allowed by the Court and the TEXAS RULES 0F CIVIL
PROCEDURE and the TEXAS RULES 0F EVIDENCE on the trial of the above cause. Defendants fiirther
reserve the right to use any exhibits designated by Plaintiffs.
Respectfully submitted,
THE LECRONE LAW FIRM, PC
Wall Street Plaza
123 North Crockett Street, Suite 200
Sherman, TX 75090
Tel: 903.813.1900
Fax: 903.813.1944
By: /s/9vtarkfl. ‘I‘eague
MARK A. TEAGUE
State Bar No. 24003039
ALEXANDRIA K. CARPENTER
State Bar No. 24101596
JOHN W. BREEZE
State Bar No. 00796248
HILLARY LUCKETT CLARK
State Bar No. 24077714
RHONDA D. HOLCOMB
State Bar No. 24099024
BLAISE S. WILCOTT
State Bar No. 24086481
SELENE DOMINGUEZ PENA
State Bar No. 24106929
MOLLY J. KAELIN
State Bar No. 24122949
ESERVICEGDLECRONELAWCOM
ATTORNEYS FOR DEFENDANTS
DEFENDANTS’ FIRST AMENDED EXHIBIT LIST - PAGE 2
10000.1 135/ troby
CERTIFICATE OF SERVICE
This is to certify that on the 19th day of August, 2022, the foregoing instrument was
forwarded to the following counsel of record:
Mr. Eric D. Nielsen
THE NIELSEN LAW FIRM, PC
9800 Northwest Freeway, Suite 314
Houston, Texas 77092
TEL: 713.524.4800
FAX: 888.587.9443
eric@nielsentriallaw.com
/s/Markfl. ‘I’egue
MARK A. TEAGUE
DEFENDAN TS’ FIRST AMENDED EHIIBIT LIST - PAGE 3
10000.1 135/ troby
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.
Terri Roby on behalf of Mark Teague
Bar No. 24003039
terri@lecronelaw.com
Envelope ID: 67488533
Status as of 8/22/2022 9:19 AM CST
Associated Case Party: DELMY RAPALO
Name BarNumber Email TimestampSubmitted Status
Eric Nielsen eric@nielsentriallaw.com 8/19/2022 3:38:57 PM SENT
Service TNLF service@nielsentriallaw.com 8/19/2022 3:38:57 PM SENT
Elizabeth Moran liz@nielsentriallaw.com 8/19/2022 3:38:57 PM SENT
Daniela Rodriguez daniela@nielsentriallaw.com 8/19/2022 3:38:57 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.
Terri Roby on behalf of Mark Teague
Bar No. 24003039
terri@lecronelaw.com
Envelope ID: 67488533
Status as of 8/22/2022 9:19 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Francine Ly fly@dallascourts.org 8/19/2022 3:38:57 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.
Terri Roby on behalf of Mark Teague
Bar No. 24003039
terri@lecronelaw.com
Envelope ID: 67488533
Status as of 8/22/2022 9:19 AM CST
Associated Case Party: ANADAYSIESCOBAR
Name BarNumber Email TimestampSubmitted Status
Mark A.Teague eservice@lecronelaw.com 8/19/2022 3:38:57 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.
Terri Roby on behalf of Mark Teague
Bar No. 24003039
terri@lecronelaw.com
Envelope ID: 67488533
Status as of 8/22/2022 9:19 AM CST
Associated Case Party: NOE ESCOBAR
Name BarNumber Email TimestampSubmitted Status
Mark A.Teague eservice@lecronelaw.com 8/19/2022 3:38:57 PM SENT
Document Filed Date
August 19, 2022
Case Filing Date
September 20, 2021
Category
OTHER PERSONAL INJURY
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Preview
FILED 8/19/2022 3:38 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Marissa Gomez DEPUTY CAUSE NO. DC-21-14009 DELMY RAPALO, INDIVIDUALLY § IN THE DISTRICT COURT AND AS NEXT FRIEND OF A.A.R., A MINOR § § V. § 134TH JUDICIAL DISTRICT § ANA DAYSI ESCOBAR AND NOE § ESCOBAR § DALLAS COUNTY, TEXAS DEFENDANTS’ FIRST AMENDED EXHIBIT LIST TO THE HONORABLE JUDGE OF SAID COURT: COME NOW, Ana Daysi Escobar and Noe Escobar, Defendants herein, and designates the following as exhibits at the time of trial: Dft. N0. Offer Grant/Denv Description of Exhibit 1. All photographs of vehicles/scene involved in the accident; Property damage estimates regarding the vehicles involved in the accident; Police Report regarding the incident in question; All medical records regarding Minor Plaintiff, A.A.R., from Children’s Medical Center of Dallas/Children’s Health; All medical records regarding Minor Plaintiff, A.A.R., from City of Dallas; All medical records regarding Minor Plaintiff, A.A.R., from Esposito Chiropractic; and All medical records regarding Minor Plaintiff, A.A.R., from UT Southwestern Medical Center. DEFENDANTS’ FIRST AMENDED EHIIBIT LIST - PAGE 1 10000.1 135/ troby PLEASE TAKE FURTHER NOTICE that Defendants reserve the right to supplement this exhibit list and to offer other rebuttal evidence and use demonstrative evidence and demonstrative exhibits in addition to testimony by Witnesses listed in response to Request for Disclosure and to call rebuttal witnesses allowed by the Court and the TEXAS RULES 0F CIVIL PROCEDURE and the TEXAS RULES 0F EVIDENCE on the trial of the above cause. Defendants fiirther reserve the right to use any exhibits designated by Plaintiffs. Respectfully submitted, THE LECRONE LAW FIRM, PC Wall Street Plaza 123 North Crockett Street, Suite 200 Sherman, TX 75090 Tel: 903.813.1900 Fax: 903.813.1944 By: /s/9vtarkfl. ‘I‘eague MARK A. TEAGUE State Bar No. 24003039 ALEXANDRIA K. CARPENTER State Bar No. 24101596 JOHN W. BREEZE State Bar No. 00796248 HILLARY LUCKETT CLARK State Bar No. 24077714 RHONDA D. HOLCOMB State Bar No. 24099024 BLAISE S. WILCOTT State Bar No. 24086481 SELENE DOMINGUEZ PENA State Bar No. 24106929 MOLLY J. KAELIN State Bar No. 24122949 ESERVICEGDLECRONELAWCOM ATTORNEYS FOR DEFENDANTS DEFENDANTS’ FIRST AMENDED EXHIBIT LIST - PAGE 2 10000.1 135/ troby CERTIFICATE OF SERVICE This is to certify that on the 19th day of August, 2022, the foregoing instrument was forwarded to the following counsel of record: Mr. Eric D. Nielsen THE NIELSEN LAW FIRM, PC 9800 Northwest Freeway, Suite 314 Houston, Texas 77092 TEL: 713.524.4800 FAX: 888.587.9443 eric@nielsentriallaw.com /s/Markfl. ‘I’egue MARK A. TEAGUE DEFENDAN TS’ FIRST AMENDED EHIIBIT LIST - PAGE 3 10000.1 135/ troby 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. Terri Roby on behalf of Mark Teague Bar No. 24003039 terri@lecronelaw.com Envelope ID: 67488533 Status as of 8/22/2022 9:19 AM CST Associated Case Party: DELMY RAPALO Name BarNumber Email TimestampSubmitted Status Eric Nielsen eric@nielsentriallaw.com 8/19/2022 3:38:57 PM SENT Service TNLF service@nielsentriallaw.com 8/19/2022 3:38:57 PM SENT Elizabeth Moran liz@nielsentriallaw.com 8/19/2022 3:38:57 PM SENT Daniela Rodriguez daniela@nielsentriallaw.com 8/19/2022 3:38:57 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. Terri Roby on behalf of Mark Teague Bar No. 24003039 terri@lecronelaw.com Envelope ID: 67488533 Status as of 8/22/2022 9:19 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Francine Ly fly@dallascourts.org 8/19/2022 3:38:57 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. Terri Roby on behalf of Mark Teague Bar No. 24003039 terri@lecronelaw.com Envelope ID: 67488533 Status as of 8/22/2022 9:19 AM CST Associated Case Party: ANADAYSIESCOBAR Name BarNumber Email TimestampSubmitted Status Mark A.Teague eservice@lecronelaw.com 8/19/2022 3:38:57 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. Terri Roby on behalf of Mark Teague Bar No. 24003039 terri@lecronelaw.com Envelope ID: 67488533 Status as of 8/22/2022 9:19 AM CST Associated Case Party: NOE ESCOBAR Name BarNumber Email TimestampSubmitted Status Mark A.Teague eservice@lecronelaw.com 8/19/2022 3:38:57 PM SENT