On February 11, 2004 a
Letter,Correspondence
was filed
involving a dispute between
Dyer, Craig,
and
Dyer Custom Installation Inc.,
Dyer, Debra,
Dyer, Laurie,
Estate Of Larry Dyer'S,
Geeting, Joseph,
Geeting, Laurie,
Geeting, M Joseph,
Geeting, Richard,
Lambert, Susan,
for OTHER (CIVIL)
in the District Court of Dallas County.
Preview
I
DALLAS COUNTY
4/1/2016 11:53:36 AM
FELICIA PITRE
H J M M DISTRICT CLERK
HowncrenJornson:Mircuett MADDEN. tt?
Montfort Place
13800 Montfort Dr., Suite 160
Dallas, Texas 75240 (972) 484-7780
(972) 484-7743 FAX
MITCHELL MADDEN, J.D., C.P.A. mmadden@hjmmlegal.com
MEMBER: TEXAS AND IDAHO BARS
BOARD CERTIFIED, ADMINISTRATIVE LAW
‘TEXAS BOARD OF LEGAL SPECIALIZATION
April 1, 2016
Via E-filing
Hon. Emily G. Tobolowsky
298" District Court
George L. Allen Sr. Courts Building
600 Commerce Street, Box 822
Dallas, Texas 75202
Re: No. 04-01100-M; 298" Judicial District, Dallas County Texas Craig Dyer v.
Dyer Custom Installation (DCI); Joseph Geeting, Lauri Geeting, Larry Dyer
and Richard Geeting
Dear Judge Tobolowsky:
| have attached two supplemental proposed findings of fact that directly relate to the
testimony of Ms. Shelly Etheridge that we did not have the benefit of at the time that we
drafted the proposal that we submitted yesterday.
Thank you for your attention to these matters.
Very truly yours,
—
Mitchell Madden
MM:ssk
Enclosures
Ce: Chad Baruch (Via Efiling)
Robert Tobey (Via Efiling)
CAUSE NO. DC-04-01100
CRAIG DYER, IN THE DISTRICT COURT
Plaintiff,
Vv.
DYER CUSTOM INSTALLATION, DALLAS COUNTY, TEXAS
INC. (DCI), JOSEPH GEETING,
SUSAN LAMBERT, LARRY DYER
and RICHARD GEETING,
Defendants. 298th JUDICIAL DISTRICT
SUPPLEMENTAL PROPOSED FINDINGS OF FACT
BY CRAIG DYER
In accordance with the Order from the Court of Appeals of the Fifth District of
Texas dated March 16, 2016, following the hearing on March 31, 2016, the Court makes
the following supplemental written findings of fact and finds as follows:
4
Ms. Etheridge discarded her notes and cassette tape recordings of the
trial proceedings on July 6, 7, 8, 2010 in the summer of 2015.
2 Prior to discarding the notes and cassette recordings of the proceedings
on July 6, 7, and 8, 2010, Ms. Etheridge did not notify the court, the official court
teporter for the court (Marcey Poeckes) or the parties or their representatives of her
intent to discard her records.
1|Page
Respectfully submitted,
By: /s/Mitchell Madden
Mitchell Madden
State Bar No. 12789350
Email:mmadden@hjmmlegal.com;
skinney@hjmmlegal.com
Melissa Johnson
State Bar No. 19142900
Email: melissa@hjmmlegal.com
HOLMGREN JOHNSON:
MITCHELL MADDEN, LLP
13800 Montfort Dr., Suite 160
Dallas, Texas 75240
Telephone: 972-484-7780
Facsimile: 972-484-7743
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
| hereby certify that a true and correct copy of this pleading has been forwarded
to counsel of record in accordance with Texas Rules of Civil Procedure 21a on this 1°
day of April, 2016.
/s/ Mitchell Madden
Mitchell Madden
2|Page
Document Filed Date
April 01, 2016
Case Filing Date
February 11, 2004
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I DALLAS COUNTY 4/1/2016 11:53:36 AM FELICIA PITRE H J M M DISTRICT CLERK HowncrenJornson:Mircuett MADDEN. tt? Montfort Place 13800 Montfort Dr., Suite 160 Dallas, Texas 75240 (972) 484-7780 (972) 484-7743 FAX MITCHELL MADDEN, J.D., C.P.A. mmadden@hjmmlegal.com MEMBER: TEXAS AND IDAHO BARS BOARD CERTIFIED, ADMINISTRATIVE LAW ‘TEXAS BOARD OF LEGAL SPECIALIZATION April 1, 2016 Via E-filing Hon. Emily G. Tobolowsky 298" District Court George L. Allen Sr. Courts Building 600 Commerce Street, Box 822 Dallas, Texas 75202 Re: No. 04-01100-M; 298" Judicial District, Dallas County Texas Craig Dyer v. Dyer Custom Installation (DCI); Joseph Geeting, Lauri Geeting, Larry Dyer and Richard Geeting Dear Judge Tobolowsky: | have attached two supplemental proposed findings of fact that directly relate to the testimony of Ms. Shelly Etheridge that we did not have the benefit of at the time that we drafted the proposal that we submitted yesterday. Thank you for your attention to these matters. Very truly yours, — Mitchell Madden MM:ssk Enclosures Ce: Chad Baruch (Via Efiling) Robert Tobey (Via Efiling) CAUSE NO. DC-04-01100 CRAIG DYER, IN THE DISTRICT COURT Plaintiff, Vv. DYER CUSTOM INSTALLATION, DALLAS COUNTY, TEXAS INC. (DCI), JOSEPH GEETING, SUSAN LAMBERT, LARRY DYER and RICHARD GEETING, Defendants. 298th JUDICIAL DISTRICT SUPPLEMENTAL PROPOSED FINDINGS OF FACT BY CRAIG DYER In accordance with the Order from the Court of Appeals of the Fifth District of Texas dated March 16, 2016, following the hearing on March 31, 2016, the Court makes the following supplemental written findings of fact and finds as follows: 4 Ms. Etheridge discarded her notes and cassette tape recordings of the trial proceedings on July 6, 7, 8, 2010 in the summer of 2015. 2 Prior to discarding the notes and cassette recordings of the proceedings on July 6, 7, and 8, 2010, Ms. Etheridge did not notify the court, the official court teporter for the court (Marcey Poeckes) or the parties or their representatives of her intent to discard her records. 1|Page Respectfully submitted, By: /s/Mitchell Madden Mitchell Madden State Bar No. 12789350 Email:mmadden@hjmmlegal.com; skinney@hjmmlegal.com Melissa Johnson State Bar No. 19142900 Email: melissa@hjmmlegal.com HOLMGREN JOHNSON: MITCHELL MADDEN, LLP 13800 Montfort Dr., Suite 160 Dallas, Texas 75240 Telephone: 972-484-7780 Facsimile: 972-484-7743 ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE | hereby certify that a true and correct copy of this pleading has been forwarded to counsel of record in accordance with Texas Rules of Civil Procedure 21a on this 1° day of April, 2016. /s/ Mitchell Madden Mitchell Madden 2|Page