Document for Gayla Smith Individually and as Executor of the estate Joyce Faye Dacke, Melissa Snider, Jeff Roberts, and Harold Roberts VS. Susan Weinzettle Fryfogle, Sterling Fryfogle, Cameron Paul Weinzettle, and Matthew Weinzettle

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                                CAUSE NO. 23-03-04432

GAYLA SMITHTHE ESATE                         §
OF JOYCE FAYE DACKE                          §       IN THE DISTRICT COURT OF
                                             §
       Plaintiff                             §
                                             §
                                             §       MONTGOMERY COUNTY, TEXAS
                                             §
SUSAN WEINZETTLE FRYFOGLE                    §
AND STERLING FRYFOGLE                        §
     Defendants                              §       457 JUDICIAL DISTRICT COURT



                       PLAINTIFFS’ DESIGNATION OF EXPERTS

To the Honorable Judge of Said Court:

Gayla Smith, individually, and as Executor of the Estate of Joyce Faye Dacke files this
Designation of Experts:

               Travis Owens. 414 W. Phillips, Suite 105, Conroe, Texas 77301. 832-312-
           3013. Mr. Owens will testify as to the amount of attorney’s fees that were incurred
           Plaintiff The Plaintiff’s attorney’s fees are reasonable and necessary taking into
           consideration: 1. The time and labor required, the novelty and difficulty of the
           questions involved, and the skill required to perform the legal service properly; 2. The
           likelihood that the acceptance of the particular employment prevented other
           employment by the attorney; 3. The fee customarily charged in the locality for similar
           legal services; 4.The amount involved and the results obtained; 5. The time
           limitations imposed by the client or by the circumstances; 6. The nature and length
           of the professional relationship with the client; 7. The experience, reputation, and
           ability of the attorney performing the services; 8. Whether the fee is fixed or
           contingent on results obtained or the uncertainty of collection before the legal
           services have been rendered. The amount of reasonable and necessary fees shall be
           $10,000 for trial and preparation, $5,000 for an appeal to the court of Appeals and
           $5,000 for an appeal to the Supreme Court of Texas.

              Maribeth Moore, DO: 800 Riverwood Ct. Suit 105, Conroe Texas 77304. 936-
           788-3710. Dr. Moore will testify to medical recordsfor Joyce Faye Dacke. Dacke
           was a long term patient in Dr. Moore’s care. Dr. Moore will further testify to Dacke’s
           mental health and mental status, and Dr. Moore’s observations of Dacke and with
           Dacke as a patient.

              Benny Wang, MD1020 Riverwood Ct., Conroe Texas 77304, 832-510-6553. Dr.
           Wang may testify to medical records for Joyce Faye Dackewhile she was in care as a
           neurology patient.
                                             Respectfully submitted,

                                             ________/s Conner Bree Tichota
                                             Travis Owens
                                             Texas Bar Number 24065859
                                             Conner Tichota
                                             Texas Bar Number 24103245

                                             Owens Law Group, P.L.L.C.
                                             P.O. Box 8605
                                             The Woodlands, TX 77387
                                             Tel. (
                                             Fax. (832) 327
                                             travis@owens lawgroup.com
                                             conner@owens lawgroup.com

                                             Attorney for Plaintiff

                                CERTIFICATE OF SERVICE

     I certify that June 23,a true and correct copy of the foregoing was served to each
party viacertified mailpursuant to Texas Rules of Civil Procedure 21 and 21a.


                                                       Conner Bree Tichota
                                             Conner Tichota