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FILED
8/17/2023 4:22 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Margaret Thomas DEPUTY
PIC.26467
CAUSE NO. DC-22-01700
RONDA COBB, IN THE DISTRICT COURT
§§§§§§§§§§§§
Plaintiff,
VS.
RIVERSIDE CCF/CB PARTNERS, L.P. DALLAS COUNTY, TEXAS
D/B/A THE PARK AT CLIFF CREEK
APARTMENTS; CESAR CHAVEZ
FOUNDATION; REYNALDO
RODRIGUEZ D/B/A RODRIGUEZ
PAINTING,
Defendants. 298TH JUDICIAL DISTRICT
DEFENDANTS RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A THE PARK AT CLIFF
CREEK APARTMENTS AND CESAR CHAVEZ FOUNDATION’S WITNESS LIST
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A THE PARK AT
CLIFF CREEK APARTMENTS AND CESAR CHAVEZ FOUNDATION, Defendants in the
above-entitled and numbered cause, and file this, their Witness List, pursuant to the instruction
of the Court and the Texas Rules of Civil Procedure, as follows:
Defendants filrther reserve the right to call as Witnesses on direct examination any
witness identified by Plaintiff or Co-Defendant to this case. Defendants reserve the right to
question on cross-examination any witness called by Plaintiff or Co-Defendant to this case.
DEFENDANTS RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A THE PARK AT CLIFF CREEK APARTMENTS AND CESAR
CHAVEZ FOUNDATION’S WITNESS LIST Page 1
Respectfully submitted,
FLETCHER, FARLEY, SHIPMAN
& SALINAS, L.L.P.
/s/ Joseph J. Harrison
DOUGLAS D. FLETCHER
State Bar No. 07139500
Email: doug.fletcher@fletcherfarlev.com
JULIA L. SINOR
State Bar No. 24032540
Email: iulia.sinor@fletcherfarlev.com
JOSEPH J. HARRISON
State Bar No. 24083143
Email: ioe.harrison@fletcherfarlev.com
9201 N. Central Expressway, Suite 600
Dallas, Texas 75231
(214) 987-9600 (office)
(214) 987-9866 (telecopier)
ATTORNEYS FOR DEFENDANT RIVERSIDE
CCF/CB PARTNERS, L.P. D/B/A THE PARK
AT CLIFF CREEK APARTMENTS AND
CESAR CHAVEZ FOUNDATION
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing instrument has been mailed,
telecopied, electronically served or hand delivered to all attorneys of record, in compliance with
Rule 21a. of the Texas Rules of Civil Procedure, on this the 17th day of August, 2023.
/s/ Joseph J. Harrison
JOSEPH J. HARRISON
DEFENDANTS RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A THE PARK AT CLIFF CREEK APARTMENTS AND CESAR
CHAVEZ FOUNDATION’S WITNESS LIST Page 2
Defendants designate the following Witnesses, who will be called to offer testimony at the
trial of this case:
l Ms. Ronda Cobb
. Ms. Felicia Graves, Manager
Corporate Representative of Riverside CCF/CB Partners, L.P. d/b/a The Park at Cliff
Creek Apartments and Cesar Chavez Foundation
Mr. Reynaldo Rodriguez
Ms. Patrice T. Morin-Resch, BA, CPC, CPMA, CMRS
Defendants may call the following witnesses if the need arises:
L2.3.4.
Frances Larry
Sylvester Larry
Daja Bernard
Elvis Home Healthcare LLC, including all employees, agents, representatives and
custodians.
Social Security Administration, including all employees, agents, representatives and
custodians.
Social Security Administration, including all employees, agents, representatives and
custodians.
Plaintiff’s Medical Providers, and its employees and custodian(s) of records, including but
not limited to:
1. Dallas County Hospital dba Parkland Health & Hospital System, including all employees,
agents, representatives and custodians.
2. UT Southwestern Medical Center, including all employees, agents, representatives and
custodians.
Methodist Charlton Medical Center, including all employees, agents, representatives and
custodians.
Texas Physicians Resources, including all employees, agents, representatives and
custodians.
Radiology Associates of North Texas, including all employees, agents, representatives
and custodians.
6. MRI Centers of Texas, including all employees, agents, representatives and custodians
Premier Injury Clinics of DFW, including all employees, agents, representatives and
custodians.
8. MDN, PA, including all employees, agents, representatives and custodians.
9. Dallas Radiology, PA, including all employees, agents, representatives and custodians.
l 0. Comprehensive Spine Center, including all employees, agents, representatives and
custodians.
11. DFW Prescriptions, including all employees, agents, representatives and custodians.
12. Uzochi L. Obioha, including all employees, agents, representatives and custodians.
DEFENDANTS RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A THE PARK AT CLIFF CREEK APARTMENTS AND CESAR
CHAVEZ FOUNDATION’S WITNESS LIST Page 3
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.
lsra Bheda on behalf of Julie Sinor
Bar No. 24032540
isra.bheda@fletcherfarley.com
Envelope ID: 78656823
Filing Code Description: Witness List
Filing Description: DEFENDANT
Status as of 8/18/2023 6:08 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Patricia McCulloch pmcculloch@tureklawfirm.com 8/17/2023 4:22:08 PM SENT
Douglas DFletcher sheila.landua@f|etcherfarley.com 8/17/2023 4:22:08 PM SENT
Douglas Turek dturek@tureklawfirm.com 8/17/2023 4:22:08 PM SENT
Deborah Stick deborah.stick@fletcherfarley.com 8/17/2023 4:22:08 PM SENT
Julia Sinor julia.sinor@fletcherfarley.com 8/17/2023 4:22:08 PM SENT
Joe J.Harrison joe.harrison@fletcherfarley.com 8/17/2023 4:22:08 PM SENT
lsra DBheda isra.bheda@fletcherfarley.com 8/17/2023 4:22:08 PM SENT
Associated Case Party: RONDA COBB
Name BarNumber Email TimestampSubmitted Status
Walker M. Duke wduke@dukeseth.com 8/17/2023 4:22:08 PM SENT
Maureen Gehring mgehring@dukeseth.com 8/17/2023 4:22:08 PM SENT
GAGANDEEP KSETH gkseth@dukeseth.com 8/17/2023 4:22:08 PM SENT
Associated Case Party: REYNALDO RODRIGUEZ
Name BarNumber Email TimestampSubmitted Status
E-Service Resnick & Louis mail@rlattorneys.com 8/17/2023 4:22:08 PM SENT
Kelley Kessler kkessler@rlattorneys.com 8/17/2023 4:22:08 PM SENT
Stacy Thompson sthompson@rlattorneys.com 8/17/2023 4:22:08 PM SENT
Jennifer Ernst jernst@rlattorneys.com 8/17/2023 4:22:08 PM SENT
Preview
FILED 8/17/2023 4:22 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Margaret Thomas DEPUTY PIC.26467 CAUSE NO. DC-22-01700 RONDA COBB, IN THE DISTRICT COURT §§§§§§§§§§§§ Plaintiff, VS. RIVERSIDE CCF/CB PARTNERS, L.P. DALLAS COUNTY, TEXAS D/B/A THE PARK AT CLIFF CREEK APARTMENTS; CESAR CHAVEZ FOUNDATION; REYNALDO RODRIGUEZ D/B/A RODRIGUEZ PAINTING, Defendants. 298TH JUDICIAL DISTRICT DEFENDANTS RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A THE PARK AT CLIFF CREEK APARTMENTS AND CESAR CHAVEZ FOUNDATION’S WITNESS LIST TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A THE PARK AT CLIFF CREEK APARTMENTS AND CESAR CHAVEZ FOUNDATION, Defendants in the above-entitled and numbered cause, and file this, their Witness List, pursuant to the instruction of the Court and the Texas Rules of Civil Procedure, as follows: Defendants filrther reserve the right to call as Witnesses on direct examination any witness identified by Plaintiff or Co-Defendant to this case. Defendants reserve the right to question on cross-examination any witness called by Plaintiff or Co-Defendant to this case. DEFENDANTS RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A THE PARK AT CLIFF CREEK APARTMENTS AND CESAR CHAVEZ FOUNDATION’S WITNESS LIST Page 1 Respectfully submitted, FLETCHER, FARLEY, SHIPMAN & SALINAS, L.L.P. /s/ Joseph J. Harrison DOUGLAS D. FLETCHER State Bar No. 07139500 Email: doug.fletcher@fletcherfarlev.com JULIA L. SINOR State Bar No. 24032540 Email: iulia.sinor@fletcherfarlev.com JOSEPH J. HARRISON State Bar No. 24083143 Email: ioe.harrison@fletcherfarlev.com 9201 N. Central Expressway, Suite 600 Dallas, Texas 75231 (214) 987-9600 (office) (214) 987-9866 (telecopier) ATTORNEYS FOR DEFENDANT RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A THE PARK AT CLIFF CREEK APARTMENTS AND CESAR CHAVEZ FOUNDATION CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing instrument has been mailed, telecopied, electronically served or hand delivered to all attorneys of record, in compliance with Rule 21a. of the Texas Rules of Civil Procedure, on this the 17th day of August, 2023. /s/ Joseph J. Harrison JOSEPH J. HARRISON DEFENDANTS RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A THE PARK AT CLIFF CREEK APARTMENTS AND CESAR CHAVEZ FOUNDATION’S WITNESS LIST Page 2 Defendants designate the following Witnesses, who will be called to offer testimony at the trial of this case: l Ms. Ronda Cobb . Ms. Felicia Graves, Manager Corporate Representative of Riverside CCF/CB Partners, L.P. d/b/a The Park at Cliff Creek Apartments and Cesar Chavez Foundation Mr. Reynaldo Rodriguez Ms. Patrice T. Morin-Resch, BA, CPC, CPMA, CMRS Defendants may call the following witnesses if the need arises: L2.3.4. Frances Larry Sylvester Larry Daja Bernard Elvis Home Healthcare LLC, including all employees, agents, representatives and custodians. Social Security Administration, including all employees, agents, representatives and custodians. Social Security Administration, including all employees, agents, representatives and custodians. Plaintiff’s Medical Providers, and its employees and custodian(s) of records, including but not limited to: 1. Dallas County Hospital dba Parkland Health & Hospital System, including all employees, agents, representatives and custodians. 2. UT Southwestern Medical Center, including all employees, agents, representatives and custodians. Methodist Charlton Medical Center, including all employees, agents, representatives and custodians. Texas Physicians Resources, including all employees, agents, representatives and custodians. Radiology Associates of North Texas, including all employees, agents, representatives and custodians. 6. MRI Centers of Texas, including all employees, agents, representatives and custodians Premier Injury Clinics of DFW, including all employees, agents, representatives and custodians. 8. MDN, PA, including all employees, agents, representatives and custodians. 9. Dallas Radiology, PA, including all employees, agents, representatives and custodians. l 0. Comprehensive Spine Center, including all employees, agents, representatives and custodians. 11. DFW Prescriptions, including all employees, agents, representatives and custodians. 12. Uzochi L. Obioha, including all employees, agents, representatives and custodians. DEFENDANTS RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A THE PARK AT CLIFF CREEK APARTMENTS AND CESAR CHAVEZ FOUNDATION’S WITNESS LIST Page 3 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. lsra Bheda on behalf of Julie Sinor Bar No. 24032540 isra.bheda@fletcherfarley.com Envelope ID: 78656823 Filing Code Description: Witness List Filing Description: DEFENDANT Status as of 8/18/2023 6:08 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Patricia McCulloch pmcculloch@tureklawfirm.com 8/17/2023 4:22:08 PM SENT Douglas DFletcher sheila.landua@f|etcherfarley.com 8/17/2023 4:22:08 PM SENT Douglas Turek dturek@tureklawfirm.com 8/17/2023 4:22:08 PM SENT Deborah Stick deborah.stick@fletcherfarley.com 8/17/2023 4:22:08 PM SENT Julia Sinor julia.sinor@fletcherfarley.com 8/17/2023 4:22:08 PM SENT Joe J.Harrison joe.harrison@fletcherfarley.com 8/17/2023 4:22:08 PM SENT lsra DBheda isra.bheda@fletcherfarley.com 8/17/2023 4:22:08 PM SENT Associated Case Party: RONDA COBB Name BarNumber Email TimestampSubmitted Status Walker M. Duke wduke@dukeseth.com 8/17/2023 4:22:08 PM SENT Maureen Gehring mgehring@dukeseth.com 8/17/2023 4:22:08 PM SENT GAGANDEEP KSETH gkseth@dukeseth.com 8/17/2023 4:22:08 PM SENT Associated Case Party: REYNALDO RODRIGUEZ Name BarNumber Email TimestampSubmitted Status E-Service Resnick & Louis mail@rlattorneys.com 8/17/2023 4:22:08 PM SENT Kelley Kessler kkessler@rlattorneys.com 8/17/2023 4:22:08 PM SENT Stacy Thompson sthompson@rlattorneys.com 8/17/2023 4:22:08 PM SENT Jennifer Ernst jernst@rlattorneys.com 8/17/2023 4:22:08 PM SENT