Complaint,Petition: Chad Frank and Kerri Frank, Individually and as Next Friend for their Minor Child, Rowan Frank VS. Amber Tawse

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                                CAUSE NO. 20         14219

CHAD FRANK AND KERRI FRANK                                      IN THE DISTRICT COURT OF
INDIVIDUALLY AND AS NEXT
FRIEND FOR THEIR MINOR CHILD,
 OWAN FRANK
                                                          MONTGOMERY COUNTY, TEXAS


AMBER TAWSE                                                                 JUDICIAL DISTRICT


              DEFENDANTAMBER TAWSE AMENDED EXHI BIT LIST

TO THE HONORABLE JUDGE OF THIS COURT:

       COMES NOW, AMBER TAWSE, Defendant in the above-styled and numbered cause,

and files this Amended Exhibit List, and would respectfully show unto the Court the following:

       Defendant hereby lists the following Exhibits to be used at trial:

                           EXHIBIT                        OFFERED           ADMITTED     REF’D
          HCA Houston Healthcare Northwest
          Medical Records [Kerri 13Kerri 493]
          Memorial Hermann The Woodlands
          Hospital
          Medical Records [Kerri 501 Kerri 725]
          Sterling R dge Orthopedics
            edical Records [Kerri 801 Kerri 979]
          Ciar vino Total Beauty
             dical Records [Kerri 3]
          Cypress Fairfield Emergency
          Department /First Choice Emergency
          Room
          MedicaRecords [Kerri 67 Kerri 119]
          Elite Diagnostics
          Medical Records [Kerri 54]
          Cotton Feray, MD (PCP) Lance Feray,
             (PCP)
            edical Records [Kerri 4 - Kerri 51]
Spring MRI
Medical Records [Kerri 767 Kerri
Next Generation Orthopedic and Spine
Institute
   dical Records [Kerri 1Ker
Next Generation Orthopedic and Spine
Institute(June July
   dical Records [Kerri 1319Kerri
Quest Diagnostics
   dicalRecords [Kerri 738Kerri
   al Time Neuromonitoring Associates
Sigma
   dical Records
Tomball MRI / Tomball Medical Imaging
   dical Records [Kerri 1285 Kerri
        , PLLC
   dical Records [Kerri 1253 Kerri
Zimmer Biomet / EB
   dical Record [Kerri 994 Kerri
River Oaks Imaging
Medical Records [Kerri 13Kerri
Southeast Texas Cardiology
Medical Records [Kerri 761Kerri
Mohammad Etminan, MD, CV
Malik Kutty, MD, CV
Photos of Vehicle Plaintiff s Truck
Photos of Vehicle Defendant s SU
Repair Estimate of Plaintiff s truck
Produced by Plaintiff
Google Maps
   ogle Maps    closer view
Google Maps     closest vies
       In additio to       exhibits identified above, Defendant reserves       e right to rely on any

document identified by any other party n that party s exhibit list, the right to introduce such

document for purposes of impeachment and/or rebuttal, and the right to amend and/o

  lement th      exhibit list prior to trial, as pe   itted by the Court. Further, Defendant reserves

the right to create a summary of other documentary evidence, in conjunction with witness

testimony, in accordance with Texas Rule of Evidence, as well             the ight         use as an

exhibit any ofthe items dentified on this list.

         efendant reserve the right to          end and/or supplement this List, as well as cross

designateexhibits as lawfully or equi tably allowed

                                                Respectfully submitted,


                                                GERMER PLL


                                                By:
                                                      DALE M. “RETT” HOLI
                                                      State Bar No. 00792937
                                                      holidyefile@germer.com
                                                      America Tower
                                                      2929 Allen P rkway, Suite 2900
                                                      Houston, Texas 77019
                                                      (713) 650       Telephon
                                                                       Facsi

                                                ATTORNEY FOR DEFENDANT
                                                AMBERTAWSE
                                CERTIFICATE OF SERVICE

        I hereby certify that a true and correct copy of the foreoing in   rument has been served
on allcounsel of record on this January 6

Mark A. Rubal                                       IA EFILE/ESERVICE
Waldron & Schneider,PLLC                          mrubal@ws law.com
15150 Middlebrook Dr.                             colette@ws law.co
Houston, Texas

 ttorneys for Plaintiff




                                             DALE M. “RETT” HOLI