On August 20, 2021 a
Trial Materials
was filed
involving a dispute between
Williams, Rosia,
and
Espinoza, Anthony,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
1/19/2023 6:40 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Lafonda Sims DEPUTY
CAUSE NO. DC-21-11276
ROSIA WILLIAMS § IN THE DISTRICT COURT
§
V. § 44TH JUDICIAL DISTRICT
§
ANTHONY ESPINOZA § DALLAS COUNTY, TEXAS
DEFENDANT’S EXHIBIT LIST
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Anthony Espinoza, Defendant herein, and designates the following as
exhibits at the time of trial:
Dft. No. Offer Grant/Denv Description of Eghibit
1. A11 photographs of vehicles/scene involved in the
accident;
2. All medical records regarding Plaintiff from
Accident & Injury Chiropractic, obtained Via
Deposition on Written Questions;
3. Allmedical records regarding Plaintiff from DFW
CT Scan, obtained Via Deposition on Written
Questions;
4. All medical records regarding Plaintiff fi'om
Foundation Pain & Spine, obtained Via Deposition
on Written Questions;
5. All medical records regarding Plaintiff from
Methodist Family Health Center, obtained Via
Deposition on Written Questions;
6. All medical records regarding Plaintiff from MRI
Centers of Texas, obtained Via Deposition on Written
Questions;
DEFENDANT’S EXHIBIT LIST - PAGE 1
10000.1 1 lS/troby
7. Defendant’s Counter-Affidavit of Ryan Robinson,
DC, Pursuant to Section 18.001 of the Texas Civil
Practices & Remedies Code re: Medical Billing
Affidavits regarding Plaintiff;
8. Defendant’s Counter-Affidavit of Jana Schieber,
RN, Pursuant to Section 18.001 of the Texas Civil
Practices & Remedies Code re: Medical Billing
Affidavits regarding Plaintiff;
9. Report dated May 31, 2022, of Steven B. Walton,
MD, regarding Plaintiff, with attached CV;
10. All medical records regarding Plaintiff from
Accident & Injury Pain Center, Inc.;
11. All medical records regarding Plaintiff from ASP
Cares;
12. All medical records regarding Plaintiff from DFW
CT Scan;
13. All medical records regarding Plaintiff from Elevate
Health Clinics;
14. All medical records regarding Plaintiff from Lone
Star Radiology;
15. Allmedical records regarding Plaintiff from
Memorial Care Pharmacy;
16. Allmedical records regarding Plaintiff from
Momentum Spine & Joint;
17. All medical records regarding Plaintiff from MRI
Centers of Texas; and
18. All medical records regarding Plaintiff from Uptown
Radiology Associates.
PLEASE TAKE FURTHER NOTICE that Defendant reserves 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 OF CIVIL
DEFENDANT’S EXHIBIT LIST - PAGE 2
10000.1 1 15/ troby
PROCEDURE and the TEXAS RULES 0F EVIDENCE on the trial of the above cause. Defendant further
reserves the right to use any exhibits designated by Plaintiff.
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/MarEfl. Teague
MARK A. TEAGUE
State Bar No. 24003039
SELENE DOMINGUEZ PENA
State Bar No. 24106929
JOHN W. BREEZE
State Bar No. 00796248
HILLARY LUCKETT CLARK
State Bar No. 24077714
ALEXANDRIA K. CARPENTER
State Bar No. 24101596
RHONDA D. HOLCOMB
State Bar No. 24099024
BLAISE S. WILCOTT
State Bar No. 24086481
eservice@lecronelaw.com
ATTORNEYS FOR DEFENDANT
DEFENDANT’S EXHIBIT LIST - PAGE 3
10000.1 1 15/troby
CERTIFICATE OF SERVICE
This is to certify that on the 19th day of January, 2023, the foregoing instrument was
forwarded to the following counsel of record:
Mr. Rogelio Guerrero
BEN ABBOTT & ASSOCIATES, PLLC
1934 Pendleton Drive
Garland, Texas 75041
TEL: 972.263.5555
FAX: 972.682.7586
eservice@benabbott.com
/s/Markfl. ‘I’egue
MARK A. TEAGUE
DEFENDANT’S EXHIBIT LIST - PAGE 4
10000.1 1 15/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: 71966177
Status as of 1/20/2023 11:18 AM CST
Associated Case Party: ROSIA WILLIAMS
Name BarNumber Email TimestampSubmitted Status
Rogelio Guerrero eservice@benabbott.com 1/19/2023 6:40:11 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Griffin Scheumack 24097168 |ega|@mytexasfirm.com 1/19/2023 6:40:11 PM SENT
Griffin Schemack eservice@benabbott.com 1/19/2023 6:40:11 PM SENT
Selene DominguezPena selene@lecronelaw.com 1/19/2023 6:40:11 PM SENT
Associated Case Party: ANTHONY ESPINOZA
Name BarNumber Email TimestampSubmitted Status
Mark A.Teague eservice@lecronelaw.com 1/19/2023 6:40:11 PM SENT
Document Filed Date
January 19, 2023
Case Filing Date
August 20, 2021
Category
MOTOR VEHICLE ACCIDENT
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED 1/19/2023 6:40 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Lafonda Sims DEPUTY CAUSE NO. DC-21-11276 ROSIA WILLIAMS § IN THE DISTRICT COURT § V. § 44TH JUDICIAL DISTRICT § ANTHONY ESPINOZA § DALLAS COUNTY, TEXAS DEFENDANT’S EXHIBIT LIST TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Anthony Espinoza, Defendant herein, and designates the following as exhibits at the time of trial: Dft. No. Offer Grant/Denv Description of Eghibit 1. A11 photographs of vehicles/scene involved in the accident; 2. All medical records regarding Plaintiff from Accident & Injury Chiropractic, obtained Via Deposition on Written Questions; 3. Allmedical records regarding Plaintiff from DFW CT Scan, obtained Via Deposition on Written Questions; 4. All medical records regarding Plaintiff fi'om Foundation Pain & Spine, obtained Via Deposition on Written Questions; 5. All medical records regarding Plaintiff from Methodist Family Health Center, obtained Via Deposition on Written Questions; 6. All medical records regarding Plaintiff from MRI Centers of Texas, obtained Via Deposition on Written Questions; DEFENDANT’S EXHIBIT LIST - PAGE 1 10000.1 1 lS/troby 7. Defendant’s Counter-Affidavit of Ryan Robinson, DC, Pursuant to Section 18.001 of the Texas Civil Practices & Remedies Code re: Medical Billing Affidavits regarding Plaintiff; 8. Defendant’s Counter-Affidavit of Jana Schieber, RN, Pursuant to Section 18.001 of the Texas Civil Practices & Remedies Code re: Medical Billing Affidavits regarding Plaintiff; 9. Report dated May 31, 2022, of Steven B. Walton, MD, regarding Plaintiff, with attached CV; 10. All medical records regarding Plaintiff from Accident & Injury Pain Center, Inc.; 11. All medical records regarding Plaintiff from ASP Cares; 12. All medical records regarding Plaintiff from DFW CT Scan; 13. All medical records regarding Plaintiff from Elevate Health Clinics; 14. All medical records regarding Plaintiff from Lone Star Radiology; 15. Allmedical records regarding Plaintiff from Memorial Care Pharmacy; 16. Allmedical records regarding Plaintiff from Momentum Spine & Joint; 17. All medical records regarding Plaintiff from MRI Centers of Texas; and 18. All medical records regarding Plaintiff from Uptown Radiology Associates. PLEASE TAKE FURTHER NOTICE that Defendant reserves 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 OF CIVIL DEFENDANT’S EXHIBIT LIST - PAGE 2 10000.1 1 15/ troby PROCEDURE and the TEXAS RULES 0F EVIDENCE on the trial of the above cause. Defendant further reserves the right to use any exhibits designated by Plaintiff. 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/MarEfl. Teague MARK A. TEAGUE State Bar No. 24003039 SELENE DOMINGUEZ PENA State Bar No. 24106929 JOHN W. BREEZE State Bar No. 00796248 HILLARY LUCKETT CLARK State Bar No. 24077714 ALEXANDRIA K. CARPENTER State Bar No. 24101596 RHONDA D. HOLCOMB State Bar No. 24099024 BLAISE S. WILCOTT State Bar No. 24086481 eservice@lecronelaw.com ATTORNEYS FOR DEFENDANT DEFENDANT’S EXHIBIT LIST - PAGE 3 10000.1 1 15/troby CERTIFICATE OF SERVICE This is to certify that on the 19th day of January, 2023, the foregoing instrument was forwarded to the following counsel of record: Mr. Rogelio Guerrero BEN ABBOTT & ASSOCIATES, PLLC 1934 Pendleton Drive Garland, Texas 75041 TEL: 972.263.5555 FAX: 972.682.7586 eservice@benabbott.com /s/Markfl. ‘I’egue MARK A. TEAGUE DEFENDANT’S EXHIBIT LIST - PAGE 4 10000.1 1 15/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: 71966177 Status as of 1/20/2023 11:18 AM CST Associated Case Party: ROSIA WILLIAMS Name BarNumber Email TimestampSubmitted Status Rogelio Guerrero eservice@benabbott.com 1/19/2023 6:40:11 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Griffin Scheumack 24097168 |ega|@mytexasfirm.com 1/19/2023 6:40:11 PM SENT Griffin Schemack eservice@benabbott.com 1/19/2023 6:40:11 PM SENT Selene DominguezPena selene@lecronelaw.com 1/19/2023 6:40:11 PM SENT Associated Case Party: ANTHONY ESPINOZA Name BarNumber Email TimestampSubmitted Status Mark A.Teague eservice@lecronelaw.com 1/19/2023 6:40:11 PM SENT