On June 13, 2022 a
Trial Materials
was filed
involving a dispute between
Hollis, Whittnee,
and
Simms, Kendell,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
FILED
5/22/2023 5:29 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Brandon Keys PUTY
CAUSE . DC-22-06437
WHITTNEE HOLLIS § IN THE DISTRICT COURT
§
V. § 134TH JUDICIAL DISTRICT
§
KENDELL SIMMS § DALLAS COUNTY, TEXAS
DEFENDANT’S EXHIBIT LIST
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Kendell Simms, Defendant herein, and designates the following as
exhibits at the time of trial:
Grant/Denv Description of Eghibit
1. _ _ A11 photographs of vehicles/scene involved in the
accident;
2. _ _ Police Report regarding the incident in question;
3. Defendant’s Counter-Affidavit of Cody Doyle, DC,
Pursuant to Section 18.001 of the Texas Civil
Practices & Remedies Code re: Medical Billing
Affidavits regarding Plaintiff;
4. Defendant’s Counter-Affidavit of Lennard A.
Nadalo, MD, FACR, Pursuant to Section 18.001 of
the Texas Civil Practices & Remedies Code re:
Medical Billing Affidavits regarding Plaintiff;
5. All medical recordsregarding Plaintiff from
Accident & Injury Chiropractic;
6. All medical records regarding Plaintiff from Lone
Star Radiology; and
7. A11 medical records regarding Plaintiff from White
Rock Open Air MRI.
DEFENDANT’S EXHIBIT LIST - PAGE 1
10000. 1296/troby
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 0F CIVIL
PROCEDURE and the TEXAS RULES OF EVIDENCE on the trial of the above cause. Defendant fiIrther
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/9Vtarkfl. ‘I‘eague
MARK A. TEAGUE
State Bar No. 24003039
MARK C. HUMPHREY
State Bar No. 24132191
JOHN W. BREEZE
State Bar No. 00796248
BLAISE S. WILCOTT
State Bar No. 24086481
SELENE DOMINGUEZ PENA
State Bar No. 24106929
MEGAN E. ANDRUS
State Bar No. 24129548
ASHANTI S. BAKER
State Bar No. 24128416
JOHN DAVID “JD” MERRITT
State Bar No. 24128467
ESERVICEGDLECRONELAWCOM
ATTORNEYS FOR DEFENDANT
DEFENDANT’S EXHIBIT LIST - PAGE 2
10000. 1296/ troby
CERTIFICATE OF SERVICE
This is to certify that on May 22nd, 2023, the foregoing instrument was forwarded to the
following counsel of record:
Mr. Camilo Valencia
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 3
10000. 1296/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: 75888307
Filing Code Description: Exhibit List
Filing Description: DEFENDANT'S
Status as of 5/23/2023 2:58 PM CST
Associated Case Party: KENDELL SIMMS
Name BarNumber Email TimestampSubmitted Status
Mark A.Teague eservice@lecronelaw.com 5/22/2023 5:29:49 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Francine Ly fly@dallascourts.org 5/22/2023 5:29:49 PM SENT
CAMILO VALENCIA ESERVICE@BENABBOTT.COM 5/22/2023 5:29:49 PM SENT
Document Filed Date
May 22, 2023
Case Filing Date
June 13, 2022
Category
MOTOR VEHICLE ACCIDENT
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FILED 5/22/2023 5:29 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Brandon Keys PUTY CAUSE . DC-22-06437 WHITTNEE HOLLIS § IN THE DISTRICT COURT § V. § 134TH JUDICIAL DISTRICT § KENDELL SIMMS § DALLAS COUNTY, TEXAS DEFENDANT’S EXHIBIT LIST TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Kendell Simms, Defendant herein, and designates the following as exhibits at the time of trial: Grant/Denv Description of Eghibit 1. _ _ A11 photographs of vehicles/scene involved in the accident; 2. _ _ Police Report regarding the incident in question; 3. Defendant’s Counter-Affidavit of Cody Doyle, DC, Pursuant to Section 18.001 of the Texas Civil Practices & Remedies Code re: Medical Billing Affidavits regarding Plaintiff; 4. Defendant’s Counter-Affidavit of Lennard A. Nadalo, MD, FACR, Pursuant to Section 18.001 of the Texas Civil Practices & Remedies Code re: Medical Billing Affidavits regarding Plaintiff; 5. All medical recordsregarding Plaintiff from Accident & Injury Chiropractic; 6. All medical records regarding Plaintiff from Lone Star Radiology; and 7. A11 medical records regarding Plaintiff from White Rock Open Air MRI. DEFENDANT’S EXHIBIT LIST - PAGE 1 10000. 1296/troby 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 0F CIVIL PROCEDURE and the TEXAS RULES OF EVIDENCE on the trial of the above cause. Defendant fiIrther 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/9Vtarkfl. ‘I‘eague MARK A. TEAGUE State Bar No. 24003039 MARK C. HUMPHREY State Bar No. 24132191 JOHN W. BREEZE State Bar No. 00796248 BLAISE S. WILCOTT State Bar No. 24086481 SELENE DOMINGUEZ PENA State Bar No. 24106929 MEGAN E. ANDRUS State Bar No. 24129548 ASHANTI S. BAKER State Bar No. 24128416 JOHN DAVID “JD” MERRITT State Bar No. 24128467 ESERVICEGDLECRONELAWCOM ATTORNEYS FOR DEFENDANT DEFENDANT’S EXHIBIT LIST - PAGE 2 10000. 1296/ troby CERTIFICATE OF SERVICE This is to certify that on May 22nd, 2023, the foregoing instrument was forwarded to the following counsel of record: Mr. Camilo Valencia 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 3 10000. 1296/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: 75888307 Filing Code Description: Exhibit List Filing Description: DEFENDANT'S Status as of 5/23/2023 2:58 PM CST Associated Case Party: KENDELL SIMMS Name BarNumber Email TimestampSubmitted Status Mark A.Teague eservice@lecronelaw.com 5/22/2023 5:29:49 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Francine Ly fly@dallascourts.org 5/22/2023 5:29:49 PM SENT CAMILO VALENCIA ESERVICE@BENABBOTT.COM 5/22/2023 5:29:49 PM SENT