On April 11, 2023 a
Party Discovery
was filed
involving a dispute between
Abell, Joseph D,
and
Kroger Texas L.P. D B A Kroger Store No. K034 East Houston,
Reddy Ice, Llc,
for Other Injury or Damage - Over $250,000
in the District Court of Montgomery County.
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CAUSE NO. 23-04-05276
JOSEPH D. ABELL IN THE DISTRICT COURT OF
VS.
MONTGOMERY COUNTY, TEXAS
KROGER TEXAS L.P. D/B/A
KROGER STORE NO. K034
EAST/HOUSTON JUDICIAL DISTRICT
PLAINTIFF SECOND NOTICE OF FILING OF AFFIDAVITS AND RECORDS
Pursuant to Rule 902(10) of the Texas Rules of Evidence, JOSEPH D. ABELL, hereby
gives notice of the filing of the following Records and Affidavits:
Affidavit of Houston Methodist The Woodlands Hospital, Jul, 2023; Billing Records
for Joseph D. Abell consisting of a total of 8 pages.
These records will be offered into evidence at the trial of the captioned cause.
Please be advised that the original documents will be retained in Plaintiff s file until
time of trial, unless objected to in writing. Copies of the Affidavits and all medical and/or
billing records are being provided to opposing counsel.
Respectfully submitted,
HOPE & CAUSEY, P. C.
/s/ Dustin Causey
Dustin. Causey
State Bar No. 24078325
P. O. Box 3188
Conroe, Texas 77305-3188
(936) 441-4673 - Metro
(936) 441-4674 - Telecopier
hcdocket@hope-causey.com
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
Pursuant to Rules 21, and 21. of the Texas Rules of Civil Procedure, I hereby certify
that the original of Plaintiff Notice of Filing of Affidavits has been filed with the clerk of the
court in writing, and true and correct copies have been delivered to all interested parties on July
, correctly addressed as follows:
VIA E FILE
Brock C. Akers
The Akers Firm, PLLC
The Clocktower Building
3401 Allen Parkway, Suite 101
Houston, TX 77019
VIA E FILE
Lindsay G. Gorbach
Mayer LLP
750 North Saint Paul Street
Suite 700
Dallas, TX 75201
/s/ ustin Causey
DustinCausey
Page
Document Filed Date
July 31, 2023
Case Filing Date
April 11, 2023
Category
Other Injury or Damage - Over $250,000
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CAUSE NO. 23-04-05276 JOSEPH D. ABELL IN THE DISTRICT COURT OF VS. MONTGOMERY COUNTY, TEXAS KROGER TEXAS L.P. D/B/A KROGER STORE NO. K034 EAST/HOUSTON JUDICIAL DISTRICT PLAINTIFF SECOND NOTICE OF FILING OF AFFIDAVITS AND RECORDS Pursuant to Rule 902(10) of the Texas Rules of Evidence, JOSEPH D. ABELL, hereby gives notice of the filing of the following Records and Affidavits: Affidavit of Houston Methodist The Woodlands Hospital, Jul, 2023; Billing Records for Joseph D. Abell consisting of a total of 8 pages. These records will be offered into evidence at the trial of the captioned cause. Please be advised that the original documents will be retained in Plaintiff s file until time of trial, unless objected to in writing. Copies of the Affidavits and all medical and/or billing records are being provided to opposing counsel. Respectfully submitted, HOPE & CAUSEY, P. C. /s/ Dustin Causey Dustin. Causey State Bar No. 24078325 P. O. Box 3188 Conroe, Texas 77305-3188 (936) 441-4673 - Metro (936) 441-4674 - Telecopier hcdocket@hope-causey.com ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE Pursuant to Rules 21, and 21. of the Texas Rules of Civil Procedure, I hereby certify that the original of Plaintiff Notice of Filing of Affidavits has been filed with the clerk of the court in writing, and true and correct copies have been delivered to all interested parties on July , correctly addressed as follows: VIA E FILE Brock C. Akers The Akers Firm, PLLC The Clocktower Building 3401 Allen Parkway, Suite 101 Houston, TX 77019 VIA E FILE Lindsay G. Gorbach Mayer LLP 750 North Saint Paul Street Suite 700 Dallas, TX 75201 /s/ ustin Causey DustinCausey Page