Motion in Limine Evidentiary in MARCUS THOMAS vs. NOAH L. HAMRICK, et al| Trellis.Law

On January 19, 2022 a PROPOSED ORDER IN LIMINE - NON-SIGNED PROPOSED ORDER/JUDGMENT was filed involving a dispute between Thomas, Marcus, and Dallas Movers South Llc, Hamrick, Noah L., Pioneer Truck Leasing, Sia Transportation Inc., Sia Transportation Inc. Dba Two Men And A Truck, for MOTOR VEHICLE ACCIDENT in the District Court of Dallas County.

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CAUSE NO. DC-22-00781

MARCUS THOMAS IN THE DISTRICT COURT

§§§§§§§§§§§§§
PLAINTIFF,
VS.
IOISTJUDICIAL DISTRICT
NOAH HAMRICK, SIA
TRANSPORTATION INC. DBA TWO
MEN AND A TRUCK, PIONEER TRUCK
LEASING, AND DALLAS MOVERS
SOUTH LLC

DEFENDAN TS. DALLAS COUNTY, TEXAS
ORDER ON DEFENDANTS’ MOTION IN LIMINE

Defendants Noah Hamrick and SLA Transportation Inc. d/b/a Two Men and a Truck (“Defendants”)

Motion in Limine was duly and timely presented to the Court before the beginning of voir dire

examination, and the Court made the following ruling as to the particular numbered paragraphs:

1. Insurance Coverage

Any matter related to insurance, existence of insurance, failure to pay insurance, coverage
under any insurance company, the fact that these Defendants were or were not covered by some form
of liability insurance with respect to the incident in question because such fact is entirely immaterial
to any issue in this cause, and any mention or inference thereof, directly or indirectly, would be
extremely harmful and prejudicial to Defendants. TEX. R. EVID. 411.

Sustained Denied Modiﬁed

2. Connection With Insurance Industry

From inquiring of any member of the venire as to any connection with the insurance industry,
and in this connection would point out to the Court that if Plaintiff” s counsel is sincerely interested in
determining whether or not there is any such connection for purposes of exercising jury strikes, he or
she can do so by asking each individual juror their occupation, past occupations and that of those in
their household, which will provide relevant information and avoid harming Defendants by
interjecting insurance into the case and implying that an insurance policy will pay any adverse
judgment against Defendants. TEX. R. EVID. 401-403; Brockett v. Tice, 445 S.W.2d 20 (Tex. Civ.
App. — Houston [lSt Dist.] 1969, writ refd n.r.e.); Green v. Ligon, 190 S.W.2d 742 (Tex. Civ. App. —
Fort Worth 1945, writ ref'd n.r.e.).

ORDER ON DEFENDANTS’ MOTION IN LIMINE - Page 1
Sustained Denied Modiﬁed

3. Answer Damage Issue “Regardless of Who Pavs”

From interrogating any member of the venire as to whether they would answer an issue on
damages in accordance with the evidence, regardless of who pays the damages or when they will be
paid, 0r whether they will ever be paid, or any similar version of such inquiry, for the reason that the
same improperly injects the implication of insurance and wealth into the suit and because the issue of
“who pays” damages that are awarded is not relevant to the issues being decided by the jury. TEX. R.
EVID. 401, 403 ; TEX. R. EVID. 411. Similarly, that counsel is not permitted to say, argue, or imply that
Defendants are not responsible for damages that may be awarded or that they are not obligated to pay
damages that are awarded because such statements misstate the law of Vicarious liability and is
irrelevant to the issues submitted to the jury. See E.B. Kendrix v. Southern Pacific Transp. C0., 907
S.W.2d 111 (Tex. App. — Beaumont 1995, no writ).

Sustained Denied Modiﬁed

4. Nature of Defendants’ Counsel's Practice

Any reference to the circumstances surrounding the employment of Defendants’ counsel, any
reference to Defendants’ counsel as “its regular lawyer” or any other reference or term or phrase that
would indicate that counsel for Defendants, or the ﬁrm of Chamblee Ryan, P.C. regularly serves as
counsel for Defendants or parties like the Defendants, such as “trucking companies” or any similar
characterization. TEX. R. EVID. 401-403.

Sustained Denied Modiﬁed

5. Defendants’ Financial Statlg

From mentioning, referring to, or asking questions regarding Defendants’ ﬁnancial status; or
regarding the assets, property, liabilities, or wealth of Defendants because such collateral ﬁnancial
matters are irrelevant to any material issue in this lawsuit and would be brought up solely for the
purposes of prejudice and inﬂammation of the jury. Any reference to Defendants’ ﬁnances, ability to
pay, or other matters relating to their ﬁnancial status would constitute an effort to “compare the
wealt ” of the parties and can only serve the purpose of creating prejudice against Defendants, thereby
causing the jury to reach a verdict based on emotion, rather than fact, and would, in all probability,
have such effect. TEX. R. EVID. 401-403; Transportation Ins. Co. v. Moriel, 879 S.W.2d 10 (Tex.
1994).

Sustained Denied Modiﬁed

ORDER 0N DEFENDANTS’ MOTION IN LIMINE - Page 2
6. Damages Received

Any reference to the fact that Plaintiff may not receive the ﬁ111 amount awarded because of
attorneys’ fees, expenses, taxes, liens, etc. Such information is irrelevant and unnecessary to
determine the existence or extent of liability, injury, or damage in this case. Therefore, such
information is inadmissible under TEX. R. EVID. 401-403. Chicago R.I. & G. RY. C0. v. Johnson, 111
S.W. 758 (Tex. Civ. App. 1908) (holding comment regarding attorneys’ fees improper, but not
reversible error).

Sustained Denied Modiﬁed

7. Testimony of Absent Witness

Any reference, mention or statement to the jury of the probable testimony of a witness who is
absent, unavailable or not called to testify in this cause and tendering, referring to, reading from,
offering or exhibiting any ex parte statements or reports from any witness who is not present in the
court to testify and be examined by Defendants’ counsel. Texas Power & Light Co. v. Walker, 559
S.W.2d 403 (Tex. Civ. App.—Texarkana 1977, no writ); Sanders v. St. Paul Fire & Marine Ins. Co.,
429 S.W.2d 516 (Tex. Civ. App.—Texarkana 1968, writ ref'd n.r.e.). TEX. R. EVID. 802-804.

Sustained Denied Modiﬁed

8. Personal Beliefs of Plaintiffs’ Counsel

That Plaintiff’s counsel not mention or state to the jury his or her personal beliefs (as opposed
to stating what the facts will show or arguing the facts in evidence) concerning the justice of their
client’s cases, and/or their client’s right to recover damages in this case, such being clearly improper
as held in Wallace v. Liberty Mutual Inc. Co., 413 S.W.2d 787 (Tex. Civ. AppiHouston 1967, writ
refd, n.r.e.). See Huﬂv. State, 660 S.W.2d 635 (Tex. App—Corpus Christi 1983, pet. ref’d.) and
TEX. R. EVID. 401-403 (such statements are unfair, irrelevant, and highly prejudicial). See also TEX.
DISCIPLINARY R. PROF. CONDUCT 304(c)(3), which speciﬁcally prohibits such statements.

Sustained Denied Modiﬁed

9. Expenses of Plaintiff

From offering evidence or referencing the costs, expenses or fees incurred by Plaintiff in
connection with the actual bringing and prosecuting of this lawsuit because such is not an element of
damage in this case, and as such is irrelevant, immaterial, and more prejudicial than probative. TEX.
R. EVID. 401-403.

Sustained Denied Modiﬁed

ORDER 0N DEFENDANTS’ MOTION IN LIMINE - Page 3
10. Using the Verdict to Send a Message

From suggesting or implying that the jury use its verdict as a mechanism through which to
effect social change or send a message to other members of the community. See Westbrook v. General
Tire and Rubber C0., 754 F.2d 1233 (5th Cir. 1985).

Sustained Denied Modiﬁed

1 1. Pre-Trial Remedies

From referencing the availability of pre-trial procedural remedies for the dismissal of frivolous
or non-meritorious lawsuits through Motions for Summary Judgment, Motions to Dismiss, or
otherwise, because such would be an attempt to mislead the jury as to the merits of Plaintiffs claims
based upon procedural issues that have no relationship to the jury’s role as the ﬁnder of fact.

Sustained Denied Modiﬁed

12. Failure to Call EulLallv Available Witnesses

Any reference that Defendants have failed to call to testify any witness equally available to
the Plaintiff in this cause. In this regard, Defendants move that opposing counsel further be instructed
not to tender, read from or refer to any ex parte statement or report, not previously admitted into
evidence by the Court, of any person not then and there present in Court to testify and to be
cross-examined by counsel for Defendants, and that opposing counsels be instructed not to suggest to
the jury, by argument or otherwise, what would have been the testimony of any witness not actually
called. Texas Power & Light Co. v. Walker, 55 9 S.W.2d 403 (Tex. App. — Texarkana 1977, no writ);
Sanders v. St. Paul Fire & Marine Ins. Co., 429 S.W.2d 516 (Tex. Civ. App—Texarkana 1968, writ
ref. n.r.e.); Jarbet v. Hengst, 260 S.W.2d 88 (Tex. App. — Austin 1953, no writ).

Sustained Denied Modiﬁed

13. Qpinions as to the Truth or Falsitv of Testimony of Others

From eliciting any statements or opinions from any witness or expert Witness as to the truth or
falsity of the testimony of any other witness or person. Such questioning is improper as it invades the
province of the jury. Cain v. Pruett, 938 S.W.2d 152 (Tex. App. — Dallas 1996, no writ); United
States Fire Ins. Co. v. Biggs, 614 S.W.2d 496 (Tex. Civ. App—Amarillo 1981, no writ); Southwestern
Bell Telephone Co. v. Griﬂith, 575 S.W.2d 92 (Tex. Civ. App—Corpus Christi 1979, writ refd n.r.e.);
Neuhaus v. Kain, 557 S.W.2d 125 (Tex. Civ. App—Corpus Christi 1977, writ refd n.r.e.); Ryan v.
Morgan Spear Associates, Inc., 546 S.W.2d 678 (Tex. Civ. App—Corpus Christi 1977, writ refd
n.r.e.).

Sustained Denied Modiﬁed

ORDER 0N DEFENDANTS’ MOTION IN LIMINE - Page 4
14. Demand Item_s from Attornev's Files

That Plaintiff and her counsel be instructed not to make demands or requests before the jury
for matters found or contained in Defendants’ or Defendants’ attorney’s ﬁles. Such matters are
privileged or potentially privileged from disclosure to opposing parties. Further, such demands or
requests serve only to improperly imply that Defendants are withholding information or evidence in
this matter. TEX. R. EVID. 501, 503.

Sustained Denied Modiﬁed

15. Quest for Stipulation in Jurv Presence
Requesting Defendants or Defendants’ attorney to stipulate to either the admissibility of any
evidence or stipulate to any facts or matters in front of the jury. TEX. R. EVID. 401-403.

Sustained Denied Modiﬁed

16. mlestioning Defendants’ Attorney

Asking questions to Defendants’ counsel in front of the jury. TEX. R. EVID. 401-403.

Sustained Denied Modiﬁed

17. Unrelated or Prior Suits, Claims or Settlements

That these Defendants and/or their agents, employees, or servants that have been involved in
any lawsuit or has settled any claim, or the amount of any such settlement, as all such matters are
unrelated to the subject of the present action. To refrain from mentioning, suggesting, implying or
inquiring about any lawsuits or other types of claims, accusations, charges, inquiries, or investigations
which have in the past been ﬁled or made or conducted or are presently pending, against Defendants
herein or any employees, agent, or representative of Defendants herein for the reason that such matters
are wholly irrelevant to the issues in the case, and would be mentioned solely for the purpose of
prejudicing the jury with collateral matters, the merits of which could not possibly be litigated in this
suit. TEX. R. EVID. 401-403; Group Hosp. Services, Inc. v. Daniel, 704 S.W.2d 870 (TeX.App.—
Corpus Christi 1985, no writ).

Sustained Denied Modiﬁed

18. Test_imonv of Experts Not Partﬂlarlv Ident_iﬁed
The offering of any expert testimony of any kind or character of any expert witness regarding
an ultimate issue applicable to these or a similar case that was not properly and timely designated as
an expert witness regarding any issue in this matter. Further, the offering by Plaintiff, of any expert
or opinion testimony of any kind or character of any witness whose identity, opinions, and conclusions

ORDER ON DEFENDANTS’ MOTION IN LIMINE - Page 5
have not been fully, properly, and timely disclosed pursuant to Texas Rule of Civil Procedure 194,
outstanding discovery requests, and the Court’s Scheduling Order in this matter is improper and would
constitute surprise and prejudice against Defendants, particularly if the opinions and conclusions
addressed any ultimate issue of fact or law applicable to this or a similar case. Further, any attempt to
elicit any testimony from any person not properly and timely disclosed or designated by the Plaintiff
should be wholly excluded. TEX. R. EVID. 401-403; TEX. R. CIV. P. 166a, 166b, 168, 194, 195 and
215; Yeldell v. Holiday Hills Retirement and Nursing Center, Inc., 701 S.W.2d 243 (Tex. 1985);
Morrow v. HEB, Inc., 714 S.W.2d 297 (Tex. 1986).

Sustained Denied Modiﬁed

19. Evidence of Treatment bv Undisclosed Provider

The offering of any evidence or testimony of any kind or character of any medical or healthcare
treatment by a medical or healthcare treatment provider not properly and seasonably identiﬁed as a
person with knowledge of relevant facts by Plaintiff in his Answers to Defendants’ Interrogatories
and Requests for Disclosure under Texas Rule of Civil Procedure 194. TEX. R. EVID. 401-403; TEX.
R. CIV. P. 166b, 168, 193, 194 and 215; Yeldell v. Holiday Hills Retirement and Nursing Center, Ina,
701 S.W.2d 243 (Tex. 1985); Morrow v. HEB, Inc., 714 S.W.2d 297 (Tex. 1986).

Sustained Denied Modiﬁed

20. Expenses

Any evidence or documentation of Plaintiffs expenses, including but not limited to attorney’s
fees and expenses and expert testimony regarding same, which are not relevant to the issues properly
before the jury. TEX. R. EVID. 401-403.

Sustained Denied Modiﬁed

21. Afﬁdavits of Medical Bills/Records

A11 afﬁdavits regarding medical bills and/or medical records which were not timely ﬁled
and/or timely served upon Defendants.

Sustained Denied Modiﬁed

22. Onlv Evidence of Medical Expenses Actdallv Paid or Incdrred

Any reference to or Evidence of medical bills not actually paid or incurred. TEX. CIV. PRAC.
& REM. CODE § 41.0105; Haygood v. De Escabedo, 356 S.W.3d 390, 392 (Tex. 2011); Daughters 0f
Charity Health Services of Waco v. Linnstaedter, 226 S.W.3d 409 (Tex. 2007); Mills v. Fletcher, 229
ORDER ON DEFENDANTS’ MOTION IN LIMINE - Page 6
S.W.3d 765 (Tex. App.—San Antonio 2007, no pet); Bituminous Casualty Corporation v. Cleveland,
223 S.W.3d 485 (Tex.App—Amarillo 2006, no pet). Submitting the total amount of the gross medical
bills of Plaintiff where those bills have not been paid in full and will never be paid in full, would
constitute an unjust enrichment of Plaintiff to the extent the jury award exceeds the amounts actually
paid by or on behalf of Plaintiff. See Mills, 229 S.W.3d at 767. Plaintiff’s claimed medical expenses
include charges that have never been paid and never will be paid by Plaintiff or any third party. Neither
Plaintiff nor any third party will remain responsible for those medical expenses. As such, Plaintiff’ s
claimed medical expenses would represent wholly illusory charges, which, if allowed, would result
in a windfall to Plaintiff and unreasonably serve to punish Defendants. Additionally, in Texas,
personal injury claimants are entitled to recover only “reasonable and necessary” medical expenses.
Rivas v. Gariby, 974 S.W.2d 93 (Tex. App—San Antonio 1998, pet. denied).

Sustained Denied Modiﬁed

23. Referring t0 Motion in Limine

Reference to the ﬁling of this Motion in Limine or to any ruling by the Court in response this
Motion, since references are inherently prejudicial and that they suggest or infer that the movant has
sought to prohibit proof or that the Court has excluded proof of matters damaging to a movant’s case.
TEX. R. EVID. 401-403; Texas Employers Ins. Assn. v. Phillips, 255 S.W.2d 364 (Tex. Civ. App.—
Eastland 1953, writ refd n.r.e.); Burdick v. York Oil Co., 364 S.W.2d 766 (Tex. Civ. App.—San
Antonio 1963, writ refd n.r.e.).

Sustained Denied Modiﬁed

24. Informal Conversations and Agreements Between Counsel

Any reference or allusion to any informal conversations of agreements between counsel in this
matter during the course of this litigation as such could prove to be prejudicial to one side or the other.
TEX. R. EVID. 401-403.

Sustained Denied Modiﬁed

25. Legal Defenses & Other Legal Matters

From mentioning, directly or indirectly, any reference to matters of law plead in Defendants’
most recently amended answer, as those are matters of law solely for the Court’s consideration and
determination. References such as the foregoing are argumentative and misleading and would be
offered solely for the purpose of confusing and misleading the jury. TEX. R. EVID. 401-403; Sisk v.
Glen Falls Indemnity Co., 310 S.W.2d 118 (Tex. Civ. App—Houston 1958, writ ref’d n.r.e.); TEX.
R. CIV. P. 269(b).

ORDER ON DEFENDANTS’ MOTION IN LIMINE - Page 7
Sustained Denied Modiﬁed

24. Use 0f Photographs 0r Motion Pictures

Any and all photographs, motion pictures or picture depictions not previously identiﬁed and
produced by Plaintiff prior to this Motion be excluded and that should one of these parties wish to
introduce any photographs, pictorial depictions, or motion picture ﬁlm evidence, the same be tendered
to the Court and opposing counsel outside the presence of the jury and shown or exhibited to determine
its relevance and suitability for introduction into evidence prior to and before informing the Jury as to
its existence or its tender into evidence. TEX. R. EVID. 401-403; TEX. R. CIV. P. 193.

Sustained Denied Modiﬁed

27. Comment on Discovery

Any reference to the fact that Defendants or their attorney sought to prevent discovery of any
documentation, information, or evidence during the pre-trial discovery, or after the trial began,
through the assertion of objections, motions for protection, motions in limine, instructions from
counsel, or privileges. TEX. R. EVID. 401-403.

Sustained Denied Modiﬁed

28. Opinion Testimony bv Lav Witnesses

That Plaintiff and his witnesses providing opinion testimony requiring specialized knowledge
where such witness has not been established to be qualiﬁed to render such opinions for the reason that
the existence of such opinions or the substance of such opinions would be wholly inadmissible and
would relate testimony about matters which require expertise. TEX. R. EVID. 701-703.

Sustained Denied Modiﬁed

29. Other Verdicts in Unrelated Litigatm

Any reference or inference that Defendants or any partner, agent, or employee of the
Defendants has been unsuccessful in any civil litigation, including but not limited to any jury verdict.
TEX. R. EVID. 401-404.

Sustained Denied Modiﬁed

ORDER 0N DEFENDANTS’ MOTION IN LIMINE - Page 8
30. Medical Testimony Limited to Records

Any statement, reference, comment, or question not identiﬁed or disclosed by the Witnesses’
medical records in the medical records generated by his or her observation and treatment of Plaintiff.

Sustained Denied Modiﬁed

31. Hearsay Statements of a Probable Witness Not Called to Testify

Any mention or statement to the jury of the probable testimony of a witness who is absent,
unavailable, or not called to testify in this cause. Such matters are clearly hearsay and inadmissible.
TEX. R. EVID. 801-804; Texas Power & Light C0. v. Walker, 559 S.W.2d 403 (Tex. App.—Texarkana
1977, no writ).

Sustained Denied Modiﬁed

32. Ju uestions

Any statement by opposing counsel calculated to inform the jury of the effect of their answer
to Jury Questions. HE. Butt Grocery C0. v. Bilotto, 985 S.W.2d 22 (Tex. 1998); Cavnar v. Quality
Control Parking, Inc, 678 S.W.2d 548 (Tex. App—Houston [14th Dist.] 1984), reversed in part on
other grounds by 696 S.W.2d 549 (Tex. 1985); Cooper v. Argonaut, 430 S.W.2d 35 (Tex. CiV. App.—
Dallas 1968, writ refd n.r.e.).

Sustained Denied Modiﬁed

33. Proof of Lost Wages/Lost Earning Capacity Must be Presented as Net Loss

Any reference to loss of earnings, earning capacity, loss of contributions of a pecuniary value,
or loss of inheritance presented to the jury Without reduction for income tax payments or unpaid tax
liability pursuant to any federal income tax law. TEX. CIV. P. & REM. CODE §18.09 1 (a).

Sustained Denied Modiﬁed

34. Testimony of Police Report

The offering of any evidence or testimony of any kind relating to or concerning the police
reports and any conclusions made therein, such as opinions pertaining to the party at fault. The
offering of such evidence is more prejudicial than probative, particularly if the opinions and
conclusions addressed any ultimate issue of fact or law applicable to this or a similar case. TEX. R.
EVID. 401-403. Additionally, any testimony or opinion by an investigating ofﬁcer as to Defendant
being a proximate cause of the accident should be excluded because such testimony involves a legal
deﬁnition and a conclusion based on that deﬁnition, which is not the province of opinion evidence in

ORDER ON DEFENDANTS’ MOTION IN LIMINE - Page 9
a tort case. See DeLeon v. Louder, 743 S.W.2d 357, 361-362 (Tex.App.—Amarillo, 1987, rehr’g
denied), citing Carr v. Radkey, 393 S.W.2d 806, 812 (Tex. 1965); Danaho Refining C0. v. Pan
American Petroleum Corp, 383 S.W.2d 941, 946 (Tex.CiV.App.—Waco 1964, writ refd n.r.e.).

Sustained Denied Modiﬁed

35. Unauthenticategl Evidence

Any evidence not properly authenticated under the Texas Rules of Evidence.

Sustained Denied Modiﬁed

36. Segregation of Medical Exnenses

Any form of discussion of medical billing records from the past that do not segregate out the
medical expenses that would have ordinarily been incurred without the alleged negligence of the
Defendant from those that would have been incurred due to the alleged negligence of Defendant. Such
segregation is required to make evidence of medical expenses admissible, and the segregation must
occur through expert testimony. Texarkana Mem ’l Hosp. v. Murdock, 946 S.W.2d 836 (Tex. 1997).
Without segregation, evidence of billing records is inadmissible, irrelevant, unduly prejudicial, and
misleading. TEX. R. EVID. 401-403.

Sustained Denied Modiﬁed

37. Referring t0 or Questioning Witnesses Regarding Meetings with Defense Counsel

Reference to or questions of witnesses alluding that meetings between treating physicians and
defense counsel were in any way improper, unethical, or violated the physician/patient privilege. TEX.
R. EVID. 509; Durst v. Hill Country Memorial Hospital, No. 04-00-00540-CV, 2001 S.W. 1631839
(Tex. App—San Antonio 2001, no writ); Rios v. Texas Dept. or Mental Health and Retardation, 58
S.W.3d 167 (Tex.App.—San Antonio 2001); Hogue v. Kroger Store # 107, et. al., 875 S.W.2d 477
(Tex.App.—Houston [1st Dist.] 1994, writ denied).

Sustained Denied Modiﬁed

38. Photographs of Other Vehicles Not of the Model and Make at Issue

Any reference or showing to the jury any photographs of other trucks that are not of this make
and model for the purpose of showing that Defendants could have added additional mirrors or made
modiﬁcations to the vehicle in some way to avoid or minimize any blind spots inherent on the vehicle
at issue. Such evidence is irrelevant to the matter at hand and would mislead the jury and be prejudicial
to Defendants. See TEX. R. EVID. 402, 403; see also Lovelace v. Sabine Console, Ina, 733 S.W.2d

ORDER ON DEFENDANTS’ MOTION IN LIMINE - Page 10
648, 654 (Tex.App.—Houston [14th Dist] 1987, writ denied (evidence of defendant’s negligence on
one occasion was not admissible to prove negligence on the occasion in question).

Sustained Denied Modiﬁed

39. Prior 0r Subsequent Accidents

Any reference to prior or subsequent accidents of Defendants to show or suggest in any way,
that on this particular occasion in question, Defendants acted accordingly. TEX. R. EVID. 404(b)(1).
Such evidence is irrelevant to the matter at hand and would mislead the jury and be prejudicial to
Defendants. See TEX. R. EVID. 402, 403; see also Lovelace v. Sabine Console, Ina, 733 S.W.2d 648,
654 (Tex.App.—Houston [14th Dist.] 1987, writ denied (evidence of defendant’s negligence on one
occasion was not admissible to prove negligence on the occasion in question).

Sustained Denied Modiﬁed

40. Evidence 0r Statements Regarding any Lost Wages/Lost Earning Capacig Damages by
Plaintiff

Any reference to or argument that Plaintiff has lost wages or earning capacity as a result of
the Incident and/or is entitled to damages for lost wages or earning capacity as a result of the Incident
as Plaintiff has not disclosed such economic damages in his disclosures.

Sustained Denied Modiﬁed

IT IS SO ORDERED.
SIGNED THIS DAY OF , 2023.

JUDGE PRESIDING

ORDER ON DEFENDANTS’ MOTION IN LIMINE - Page 11
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Karen Wiley on behalf of Kelley Cash
Bar No. 24001852
kwiley@cr.law
Envelope ID: 74778759
Filing Code Description: Motion - In Limine
Filing Description: d
Status as of 4/19/2023 3:08 PM CST

Associated Case Party: NOAHL. HAMRICK

Name BarNumber Email TimestampSubmitted Status
William HChamblee wchamblee@cr.law 4/18/2023 4:39:14 PM SENT
Karen Wiley kwiley@cr.law 4/18/2023 4:39:14 PM SENT
Kelley Cash kcash@cr.law 4/18/2023 4:39:14 PM SENT
Yecenia Estrada yestrada@cr.law 4/18/2023 4:39:14 PM SENT

Associated Case Party: MARCUS THOMAS

Name BarNumber Email TimestampSubmitted Status

Felipe B.Link flink@linklawpc.com 4/18/2023 4:39:14 PM SENT
Monica Isaac monica@linklawpc.com 4/18/2023 4:39:14 PM SENT
Oscar Rodriguez Oscar@LinkLawPC.com 4/18/2023 4:39:14 PM SENT
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Case Contacts

Name BarNumber Email TimestampSubmitted Status
JASON MCGILBERRY JMCGILBERRY@LINKLAWPC.COM 4/18/2023 4:39:14 PM SENT
JASON MCGILBERRY service@linklawpc.com 4/18/2023 4:39:14 PM SENT

Case Info

Judge

WILLIAMS, STACI Track Judge’s New Case

Case No.

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Document Filed Date

April 18, 2023

Case Filing Date

January 19, 2022

County

Parties

CASH, KELLEY E Attorney for the Defendant
CHAMBLEE, WILLIAM H Attorney for the Defendant
DALLAS MOVERS SOUTH LLC Defendant
Hamrick, Noah L. Defendant
MCGILBERRY, JASON Attorney for the Plaintiff
PIONEER TRUCK LEASING Defendant
SIA TRANSPORTATION INC. Defendant
SIA Transportation Inc. DBA Two Men and A Truck Defendant
THOMAS, MARCUS Plaintiff
Felipe Link Attorney
Amos Pettis Attorneys for Defendants
William Newman Attorney

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