On March 15, 2021 a
Trial Materials
was filed
involving a dispute between
Blue Mountain Property Ventures, Llc,
and
Harrison, Bessie,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
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FILED
9/7/2022 2:15 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Jenifer Trujillo DEPUTY
DC-21-03339
BLUE MOUNTAIN PROPERTY * In the District Court
VENTURES LLC *
*
V. * 298th Judicial District
*
BESSIE HARRISON * Dallas County, Texas
DEFENDANT’S WITNESS & EXHIBIT LIST
T0 THE HONORABLE JUDGE 0F SAID COURT:
COMES NOW, Bessie Harrison, in the above-styled and numbered cause and
files this its witness and exhibit list and would respectfully show unto the Court the following:
Witness List. Defendant designates witnesses who may be called to testify at trial as follows:
Bessie Harrison, c/o Robert M. Clark, Eddleman & Clark, 4627 North Central Expressway,
Dallas, Texas 75205-4022, 214.528.2400
Robert M. Clark, Eddleman & Clark, 4627 North Central Expressway, Dallas, Texas 75205-
4022, 214.528.2400, expert on attorney’s fees.
Marc Miller, mmiller@securedtitletex.com, 2805 North Dallas Parkway, Suite 140, Plano, TX
75093, 469.310.0530.
Defendant further reserves the right to call as a witness at trial any person identified by Plaintiff
as persons with knowledge of relevant facts.
Exhibit List. Defendant may introduce the following exhibits:
No. 1 Letter to Blue Mountain dated February 22, 2022
No. 2 TREC License History Brittani Kai Epps
No. 3 2021 Tax Statement
No. 4 Unimproved Property Contract, executed by Bessie Harrison and Blue Mountain
Property Ventures LLC with an Effective Date of November 20, 2020
No. 5 Earnest Money Receipt dated November 30, 2020
No. 6 Demand letter to Bessie Harrison dated January 4, 2021
No. 7 Demand letter to Bessie Harrison dated February 9, 2021
No. 8 Deposition of Bessie Harrison (Excerpts)
Defendant’s Witness and Exhibit List - Page l of 2
Defendant further reserves the right to introduce and use any exhibits identified in Plaintiff’s
exhibit list.
Defendant reserves the right to supplement and/or amend this exhibit and witness list as needed
prior to the beginning of or at trial should the need arise. Defendant further reserves the right, if
the need arises, to use other exhibits or Witnesses not on this list for impeachment, rebuttal, or
demonstrative purposes.
Respectfully submitted,
EDDLEMAN & CLARK
4627 North Central Expressway
Knox Central Place, Suite 2000
Dallas, Texas 75205-4022
Phone 214.528.2400
Fax 214.528.2434
RMC@R0bertMClark.net
WWW
ROBERT M. CLARK
State Bar No. 04298200
Attorney for Defendant
Certificate of Service
I certify that a true copy of the above was served on counsel for Plaintiff Landon H.Thompson at
the Meazell Firm, 1400 Gables Court, Plano, TX 75075, Fax 972.398.8488,
l.thompson@meazellfi1m.com in accordance with Rule 21a of the Texas Rules of Civil Procedure
on the 7th day of September 2022.
Wm. 4M
Robert M. Clark
Defendant’s Witness and Exhibit List - Page 2 of 2
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.
Robert Clark on behalf of Robert Clark
Bar No. 4298200
office@robertmclark.net
Envelope ID: 68026462
Status as of 9/8/2022 10:17 AM CST
Associated Case Party: BLUE MOUNTAIN PROPERTY VENTURES, LLC
Name BarNumber Email TimestampSubmitted Status
John Meazell j.meazell@meazellfirm.com 9/7/2022 2:15:03 PM SENT
Skyler N.Harrigan s.harrigan@meazel|firm.com 9/7/2022 2:15:03 PM SENT
Landon H.Thompson l.thompson@meazellfirm.com 9/7/2022 2:15:03 PM SENT
Ciara Manley c.manley@meazellfirm.com 9/7/2022 2:15:03 PM SENT
Document Filed Date
September 07, 2022
Case Filing Date
March 15, 2021
Category
CNTR CNSMR COM DEBT
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FILED 9/7/2022 2:15 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Jenifer Trujillo DEPUTY DC-21-03339 BLUE MOUNTAIN PROPERTY * In the District Court VENTURES LLC * * V. * 298th Judicial District * BESSIE HARRISON * Dallas County, Texas DEFENDANT’S WITNESS & EXHIBIT LIST T0 THE HONORABLE JUDGE 0F SAID COURT: COMES NOW, Bessie Harrison, in the above-styled and numbered cause and files this its witness and exhibit list and would respectfully show unto the Court the following: Witness List. Defendant designates witnesses who may be called to testify at trial as follows: Bessie Harrison, c/o Robert M. Clark, Eddleman & Clark, 4627 North Central Expressway, Dallas, Texas 75205-4022, 214.528.2400 Robert M. Clark, Eddleman & Clark, 4627 North Central Expressway, Dallas, Texas 75205- 4022, 214.528.2400, expert on attorney’s fees. Marc Miller, mmiller@securedtitletex.com, 2805 North Dallas Parkway, Suite 140, Plano, TX 75093, 469.310.0530. Defendant further reserves the right to call as a witness at trial any person identified by Plaintiff as persons with knowledge of relevant facts. Exhibit List. Defendant may introduce the following exhibits: No. 1 Letter to Blue Mountain dated February 22, 2022 No. 2 TREC License History Brittani Kai Epps No. 3 2021 Tax Statement No. 4 Unimproved Property Contract, executed by Bessie Harrison and Blue Mountain Property Ventures LLC with an Effective Date of November 20, 2020 No. 5 Earnest Money Receipt dated November 30, 2020 No. 6 Demand letter to Bessie Harrison dated January 4, 2021 No. 7 Demand letter to Bessie Harrison dated February 9, 2021 No. 8 Deposition of Bessie Harrison (Excerpts) Defendant’s Witness and Exhibit List - Page l of 2 Defendant further reserves the right to introduce and use any exhibits identified in Plaintiff’s exhibit list. Defendant reserves the right to supplement and/or amend this exhibit and witness list as needed prior to the beginning of or at trial should the need arise. Defendant further reserves the right, if the need arises, to use other exhibits or Witnesses not on this list for impeachment, rebuttal, or demonstrative purposes. Respectfully submitted, EDDLEMAN & CLARK 4627 North Central Expressway Knox Central Place, Suite 2000 Dallas, Texas 75205-4022 Phone 214.528.2400 Fax 214.528.2434 RMC@R0bertMClark.net WWW ROBERT M. CLARK State Bar No. 04298200 Attorney for Defendant Certificate of Service I certify that a true copy of the above was served on counsel for Plaintiff Landon H.Thompson at the Meazell Firm, 1400 Gables Court, Plano, TX 75075, Fax 972.398.8488, l.thompson@meazellfi1m.com in accordance with Rule 21a of the Texas Rules of Civil Procedure on the 7th day of September 2022. Wm. 4M Robert M. Clark Defendant’s Witness and Exhibit List - Page 2 of 2 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. Robert Clark on behalf of Robert Clark Bar No. 4298200 office@robertmclark.net Envelope ID: 68026462 Status as of 9/8/2022 10:17 AM CST Associated Case Party: BLUE MOUNTAIN PROPERTY VENTURES, LLC Name BarNumber Email TimestampSubmitted Status John Meazell j.meazell@meazellfirm.com 9/7/2022 2:15:03 PM SENT Skyler N.Harrigan s.harrigan@meazel|firm.com 9/7/2022 2:15:03 PM SENT Landon H.Thompson l.thompson@meazellfirm.com 9/7/2022 2:15:03 PM SENT Ciara Manley c.manley@meazellfirm.com 9/7/2022 2:15:03 PM SENT