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FILED
2/23/2023 4:19 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Jenifer Trujillo DEPUTY
CAUSE NO. DC—19-15328
MINERVA BLANCO, IN THE DISTRICT COURT OF
§§§§§§§§
Plaintiff
VS. DALLAS COUNTY, TEXAS
SUN HOLDINGS, INC. AND FRITZ
MANAGEMENT, LLC,
Defendants. 101“ JUDICIAL DISTRICT
TRIAL BRIEF—STRIKE FOR CAUSE
To THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Plaintiff, who respectfully files this Trial Brief—Strike for Cause.
1. “Voir dire examination protects the right to an impartial jury by exposing possible
improper juror biases that form the basis for statutory disqualification.” Hyundai Motor C0. v.
Vasquez, 189 S.W.3d 743, 749 (Tex. 2006). So, “the primary purpose of VOir dire is to inquire
about specific Views that would prevent or substantially impair jurors from performing their duty
in accordance with their instructions and oath.” Id.
I. EQUIVOCAL V. UNEQUIVOCAL BIAS
2. A prospective juror who admits bias or prejudice is disqualified to serve as a juror.
TEX. GOV’T CODE § 62.105(4). Bias, in its usual meaning, is an inclination toward one side of an
issue; but to disqualify, it must appear that the state of mind of the juror leads to the natural
inference that he will not or did not act with impartiality. Cortez v. HCCI-San Antonio, Inc., 159
S.W.3d 87, 94 (Tex. 2005). Prejudice is prejudgment, which necessarily includes bias. Hyundai
Motor Co. v. Vasquez, 189 S.W.3d 743, 751 (Tex. 2006). Bias or prejudice may apply to parties
but also types of cases. Id.“A juror who is prejudiced against all medical malpractice claims, for
example, is necessarily prejudiced ‘against a party in the case,’ even if they have never met.” Id.
(citing TEX. GOV’T CODE § 62.105(4)).
3. If a veniremember unequivocally expresses bias or prejudice, the veniremember is
disqualified as a matter of law, and the trial court has no discretion to decide whether to strike the
veniremember. Malone v. Foster, 977 S.W.2d 562, 564 (Tex. 1998).
4. A veniremember who is unequivocally biased or prejudiced is disqualified to serve
and cannot revive his eligibility by recanting an earlier expression of bias or prejudice. Shepherd
v. Ledford, 926 S.W.2d 405, 411 (Tex. App—Fort Worth 1996), afl’d 962 S.W.2d 28 (Tex. 1998).
5. In Cortez, the Texas Supreme Court confirms “if the record, taken as a whole,
clearly shows that a veniremember was materially biased, his or her ultimate recantation of that
bias at the prodding of counsel will normally be insufficient to prevent the veniremember’s
disqualification.” Cortez, 159 S.W.3d at 92 (emphasis added). Whether or not the veniremember
is expressing unequivocal bias or apparent bias may depend on factors that would not appear in
the trial court record, such as the veniremember’s tone and demeanor. See z'd. The “relevant
inquiry is not where the jurors start but where they are likely to end.” Id. at 94 (emphasis in
original).
6. There is “no special rule” that applies to rehabilitating a veniremember who
expressed an apparent bias. Id. However, one rule on rehabilitating apparent bias is that the voir
dire examination is largely within the sound discretion of the trial judge. Id. The proper stopping
point in efforts to rehabilitate apparent bias is left to the sound discretion of the trial court. Id.
7. The rule is therefore as follows: If the record, taken as a whole, clearly shows
that a veniremember is materially biased, the veniremember is disqualified as a matter of
law and no rehabilitation is allowed. If, however, the bias is only apparent, then rehabilitation
may be allowed.
8. It is important to note that challenges for cause do not turn on the use of magic
words. In Cortez, the Supreme Court explains that veniremembers may be disqualified even
if they say they can be “fair and impartial,” so long as the rest of the record shows they cannot.
Id. at 93.
9. When determining whether the record shows, as a whole, bias or only an apparent
bias, trial judges are called up to evaluate whether statements of partiality or impartiality were the
“result of inappropriate leading questions, confusion, misunderstanding, ignorance of the law, or
merely ‘loose words spoken in warm debate.”’ Id. at 92 (citing Compton, 364 S.W.2d at 182 (Tex.
1963)).
II. THE LOOP STRIKE FOR CAUSE
10. “Looping” is a well-recognized technique used during voir dire examination that
promotes efficiency. When a venireperson shows unequivocal bias or prejudice (e.g. showing as
a Whole he or she cannot be fair and impartial) the questioning attorney asks the panel to raise their
hand if they feel exactly the same as or agree with specific statements, feelings or beliefs expressed
by the individual venire person previously examined. See e. g., Smith v. Dean, 232 S.W.3d 181,
191—92 (Tex. App—Fort Worth, 2007, pet. denied).1
11. In Shepherd v. Ledford, the Texas Supreme Court affirmed the unequivocal bias
is when a prospective juror replies “I don’t think so” when asked if she “could consider the
facts objectively and in a neutral way.” 962 S.W.2d 28, 34 (Tex. 1998). Moreover, prospective
jurors who “feel the same way” are also struck for cause. Id.
12. During voir dire, defendant’s counsel elicited statements from three consecutive
perspective jurors that none of them could be fair to the defendants because of the result of medical
treatment experienced by family members. Defense counsel asked prospective juror Caudill if she
could consider the facts objectively and in a neutral way. She replied, “I don’t think so.” Next,
counsel asked prospective juror Sommerville: “You feel that based upon your past experience, you
could not be fair and objective in looking at the medical facts as they have been testified to so that
both sides start out evenly in this case; is that correct, ma’am?” In response, Sommerville
responded, “That is true.” Immediately following this exchange, counsel began to ask the
following question of the jury panel and venire person Guerra responded:
COUNSEL: Is there anybody else, after we’ve listened to this—
GUERRA: Ifeel the same way. . . My dad died of a heart attack also. I just don’t like to
.
talk about it because it brings back bad memories. But yeah, I think I would have a—I
would have a problem with that.
COUNSEL: [A]s a result of that, you feel that Mrs. Ledford would be—you would feel for her
and put her—sort of put her ahead of the defense in this case . . .?
GUERRA: I think so. Like I said, my dad was afier that, for a long, he was in a coma, so I
seen [sic] him suffer a lot, and I know what it did to me.
Id.
13. The Supreme Court affirmed the Court of Appeals holding that Guerra, who said
he felt the same way as Sommerville and Caudill, was “disqualified as a matter of law.” Guerra
expressed his bias, and the trial court should have granted defendant’s motion to strike Guerra for
cause. Id.
1
It should be noted that the “loop” strike was not successful in this case because the “block group” merely raised
their hands as if to say “Me too, Me too” in agreement with another venireperson’s apparent bias. Subsequently, the
“block group” was rehabilitated as a group by opposing counsel.
14. In Hafi v. Baker, an opinion delivered two months after Cortez v. HCCI-San
Antonio, Ina, the Texas Supreme Court confirmed its previous holding in Shepherd v. Ledford is
still good law. 164 S.W.3d 383 (Tex. 2005). In Hafi, the trial judge denied plaintiff’s motion to
strike venire person No. 25, a medical malpractice defense lawyer, who felt because of his
background, he could “relate very much to the defendant’s lawyers in the case.” Id. at 384. The
veniremember, however, disagreed with the suggestion that he could not be fair and objective. Id.
In dismissing Plaintiff Baker’s argument that Shepherd v. Ledfora’ required that venire person No.
25 be struck for cause, the Texas Supreme Court explained:
In Shepherd, counsel asked the venire panel whether anyone, based upon your past experience, you
could not be fair and objective. Veniremember Sommerville answered in the affirmative and was
”
struck. Then, veniremember Guerra stated, “Ifeel the same way. We held that the trial court erred
in denying the motion to strike Guerra. As we explained in Cortez, it was Guerra’s agreement with
counsel’s suggestion that he could not be fair and objective that proved his bias. See Cortez 159
S.W.3d at 94. His other comments merely explained the reason behind his bias. Here, the
veniremember disagreed with every suggestion that he could not be fair and objective. His answers
do not reflect a disqualifying bias.
Id. at 385.
15. It is clear that if a venire person expresses unequivocal bias, then other venire
”
persons who “feel the same way are also disqualified. It is not, however, sufficient if other venire
persons simply “agree” with the statements made by the previous venire person. See Smith, 232
S.W.3d at 192 (holding “unlike the juror in Shepherd, the jurors empaneled from the block group
merely raised their hands in agreement with another juror. This is not bias as a matter of law; thus,
the jurors here were able to be rehabilitated”)
16. In Murffv. Pass, the Texas Supreme Court once again showed us how not to loop
strike venirepersons. 249 S.W.3d 407 (Tex. 2008). In this medical malpractice case, venireperson
Ruth stated he would hold the plaintiff to a clear and convincing standard of proof. Several other
venirepersons raised their hands indicating they agreed with venireperson Ruth. Id. at 408. The
problem is not striking several veniremembers at once. The problem is: (a) venireperson Ruth was
confused at the definition of the proper standard of care; and (b) the other veniremembers simply
raised their hand in agreement to a general question. Id. at 412. If, on the other hand, Ruth had
expressed an unequivocal bias or prejudice without being confused and the other veniremembers
raised their hands affirmatively feeling the same bias or prejudice, then all veniremembers would
be struck for cause.
17. The Austin Court of Appeals explains how loop striking is allowed, but only works
when the questions asked of the panel are clear without potential to be misconstrued. Union
Pacific RR C0. v. Legg, 2009 WL 2476636, No. O3-07-00512-CV (Tex. App—Austin, Aug. 12,
2009, no pet.). In this case, a venireperson stated:
I can feel for the family, I really can, but the money is not going to make things
better, you know? I just don’t see how it could. It’s always going to be there, the
pain. How is the money going to help stop the pain?
Id. at 6.
18. When asked if anyone else felt the same way several other veniremembers raised
their hands. While this type of loop striking is allowed, the veniremembers were not struck because
the question may have meant that “money cannot help stop the pain from the loss of a loved one,
or that it could not completely bring about justice.” Id. The possibility of confusion or
misunderstanding in raising their hands prevented those veniremembers from being struck for
cause. Id. The Austin Court noted the attorney did not make a follow-up question on the issue.
Respectfiilly submitted,
D. MILLER & ASSOCIATES, PLLC
By:
Andy Rubenstein
State Bar No. 17360375
Anuj Kapur
State Bar No. 24103706
2610 W. Sam Houston Pkwy S., Suite 200
Houston, Texas 77042
andy@dmillerlaw.com
anuj @dmillerlawcom
713-850-8600 Office
713-366-3463 Facsimile
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
I hereby celtify that a true and correct copy of the above and foregoing instrument has
been forwarded to all counsel in accordance with the Rules of Civil Procedure, this 23th day of
February, 2023.
Via Electronic Service
Byron K. Henry
Josh Wahl
Scheef & Stone, L.L.P.
2600 Network Boulevard, Suite 400
Frisco, Texas 75034
Attorneys for Defendants
Anuj Kapur
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.
Paralegal DMillerLaw on behalf of Anuj Kapur
Bar No. 24103706
paralegal@dmillerlaw.com
Envelope ID: 73062006
Status as of 2/28/2023 9:33 AM CST
Associated Case Party: MINERVA BLANCO
Name BarNumber Email TimestampSubmitted Status
Anuj Kapur anuj@dmillerlaw.com 2/23/2023 4:19:24 PM SENT
Andy Rubenstein andy@dmillerlaw.com 2/23/2023 4:19:24 PM SENT
Elizabeth Elizondo elelizondo@dmillerlaw.com 2/23/2023 4:19:24 PM SENT
Nelly Macias nemacias@dmillerlaw.com 2/23/2023 4:19:24 PM SENT
Ashley Salgado salgado@dmillerlaw.com 2/23/2023 4:19:24 PM SENT
Associated Case Party: SUN HOLDINGS, INC.
Name BarNumber Email TimestampSubmitted Status
Byron K.Henry byron.henry@solidcounsel.com 2/23/2023 4:19:24 PM SENT
Melissa Diaz melissa.diaz@solidcounsel.com 2/23/2023 4:19:24 PM SENT
Josh Wahl josh.wahl@solidcounsel.com 2/23/2023 4:19:24 PM SENT
Case Contacts
Name BarNumber Email Timestam pSubmitted Status
ANDREW ERUBENSTEIN andy@dmillerlaw.com 2/23/2023 4:19:24 PM SENT
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FILED 2/23/2023 4:19 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Jenifer Trujillo DEPUTY CAUSE NO. DC—19-15328 MINERVA BLANCO, IN THE DISTRICT COURT OF §§§§§§§§ Plaintiff VS. DALLAS COUNTY, TEXAS SUN HOLDINGS, INC. AND FRITZ MANAGEMENT, LLC, Defendants. 101“ JUDICIAL DISTRICT TRIAL BRIEF—STRIKE FOR CAUSE To THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Plaintiff, who respectfully files this Trial Brief—Strike for Cause. 1. “Voir dire examination protects the right to an impartial jury by exposing possible improper juror biases that form the basis for statutory disqualification.” Hyundai Motor C0. v. Vasquez, 189 S.W.3d 743, 749 (Tex. 2006). So, “the primary purpose of VOir dire is to inquire about specific Views that would prevent or substantially impair jurors from performing their duty in accordance with their instructions and oath.” Id. I. EQUIVOCAL V. UNEQUIVOCAL BIAS 2. A prospective juror who admits bias or prejudice is disqualified to serve as a juror. TEX. GOV’T CODE § 62.105(4). Bias, in its usual meaning, is an inclination toward one side of an issue; but to disqualify, it must appear that the state of mind of the juror leads to the natural inference that he will not or did not act with impartiality. Cortez v. HCCI-San Antonio, Inc., 159 S.W.3d 87, 94 (Tex. 2005). Prejudice is prejudgment, which necessarily includes bias. Hyundai Motor Co. v. Vasquez, 189 S.W.3d 743, 751 (Tex. 2006). Bias or prejudice may apply to parties but also types of cases. Id.“A juror who is prejudiced against all medical malpractice claims, for example, is necessarily prejudiced ‘against a party in the case,’ even if they have never met.” Id. (citing TEX. GOV’T CODE § 62.105(4)). 3. If a veniremember unequivocally expresses bias or prejudice, the veniremember is disqualified as a matter of law, and the trial court has no discretion to decide whether to strike the veniremember. Malone v. Foster, 977 S.W.2d 562, 564 (Tex. 1998). 4. A veniremember who is unequivocally biased or prejudiced is disqualified to serve and cannot revive his eligibility by recanting an earlier expression of bias or prejudice. Shepherd v. Ledford, 926 S.W.2d 405, 411 (Tex. App—Fort Worth 1996), afl’d 962 S.W.2d 28 (Tex. 1998). 5. In Cortez, the Texas Supreme Court confirms “if the record, taken as a whole, clearly shows that a veniremember was materially biased, his or her ultimate recantation of that bias at the prodding of counsel will normally be insufficient to prevent the veniremember’s disqualification.” Cortez, 159 S.W.3d at 92 (emphasis added). Whether or not the veniremember is expressing unequivocal bias or apparent bias may depend on factors that would not appear in the trial court record, such as the veniremember’s tone and demeanor. See z'd. The “relevant inquiry is not where the jurors start but where they are likely to end.” Id. at 94 (emphasis in original). 6. There is “no special rule” that applies to rehabilitating a veniremember who expressed an apparent bias. Id. However, one rule on rehabilitating apparent bias is that the voir dire examination is largely within the sound discretion of the trial judge. Id. The proper stopping point in efforts to rehabilitate apparent bias is left to the sound discretion of the trial court. Id. 7. The rule is therefore as follows: If the record, taken as a whole, clearly shows that a veniremember is materially biased, the veniremember is disqualified as a matter of law and no rehabilitation is allowed. If, however, the bias is only apparent, then rehabilitation may be allowed. 8. It is important to note that challenges for cause do not turn on the use of magic words. In Cortez, the Supreme Court explains that veniremembers may be disqualified even if they say they can be “fair and impartial,” so long as the rest of the record shows they cannot. Id. at 93. 9. When determining whether the record shows, as a whole, bias or only an apparent bias, trial judges are called up to evaluate whether statements of partiality or impartiality were the “result of inappropriate leading questions, confusion, misunderstanding, ignorance of the law, or merely ‘loose words spoken in warm debate.”’ Id. at 92 (citing Compton, 364 S.W.2d at 182 (Tex. 1963)). II. THE LOOP STRIKE FOR CAUSE 10. “Looping” is a well-recognized technique used during voir dire examination that promotes efficiency. When a venireperson shows unequivocal bias or prejudice (e.g. showing as a Whole he or she cannot be fair and impartial) the questioning attorney asks the panel to raise their hand if they feel exactly the same as or agree with specific statements, feelings or beliefs expressed by the individual venire person previously examined. See e. g., Smith v. Dean, 232 S.W.3d 181, 191—92 (Tex. App—Fort Worth, 2007, pet. denied).1 11. In Shepherd v. Ledford, the Texas Supreme Court affirmed the unequivocal bias is when a prospective juror replies “I don’t think so” when asked if she “could consider the facts objectively and in a neutral way.” 962 S.W.2d 28, 34 (Tex. 1998). Moreover, prospective jurors who “feel the same way” are also struck for cause. Id. 12. During voir dire, defendant’s counsel elicited statements from three consecutive perspective jurors that none of them could be fair to the defendants because of the result of medical treatment experienced by family members. Defense counsel asked prospective juror Caudill if she could consider the facts objectively and in a neutral way. She replied, “I don’t think so.” Next, counsel asked prospective juror Sommerville: “You feel that based upon your past experience, you could not be fair and objective in looking at the medical facts as they have been testified to so that both sides start out evenly in this case; is that correct, ma’am?” In response, Sommerville responded, “That is true.” Immediately following this exchange, counsel began to ask the following question of the jury panel and venire person Guerra responded: COUNSEL: Is there anybody else, after we’ve listened to this— GUERRA: Ifeel the same way. . . My dad died of a heart attack also. I just don’t like to . talk about it because it brings back bad memories. But yeah, I think I would have a—I would have a problem with that. COUNSEL: [A]s a result of that, you feel that Mrs. Ledford would be—you would feel for her and put her—sort of put her ahead of the defense in this case . . .? GUERRA: I think so. Like I said, my dad was afier that, for a long, he was in a coma, so I seen [sic] him suffer a lot, and I know what it did to me. Id. 13. The Supreme Court affirmed the Court of Appeals holding that Guerra, who said he felt the same way as Sommerville and Caudill, was “disqualified as a matter of law.” Guerra expressed his bias, and the trial court should have granted defendant’s motion to strike Guerra for cause. Id. 1 It should be noted that the “loop” strike was not successful in this case because the “block group” merely raised their hands as if to say “Me too, Me too” in agreement with another venireperson’s apparent bias. Subsequently, the “block group” was rehabilitated as a group by opposing counsel. 14. In Hafi v. Baker, an opinion delivered two months after Cortez v. HCCI-San Antonio, Ina, the Texas Supreme Court confirmed its previous holding in Shepherd v. Ledford is still good law. 164 S.W.3d 383 (Tex. 2005). In Hafi, the trial judge denied plaintiff’s motion to strike venire person No. 25, a medical malpractice defense lawyer, who felt because of his background, he could “relate very much to the defendant’s lawyers in the case.” Id. at 384. The veniremember, however, disagreed with the suggestion that he could not be fair and objective. Id. In dismissing Plaintiff Baker’s argument that Shepherd v. Ledfora’ required that venire person No. 25 be struck for cause, the Texas Supreme Court explained: In Shepherd, counsel asked the venire panel whether anyone, based upon your past experience, you could not be fair and objective. Veniremember Sommerville answered in the affirmative and was ” struck. Then, veniremember Guerra stated, “Ifeel the same way. We held that the trial court erred in denying the motion to strike Guerra. As we explained in Cortez, it was Guerra’s agreement with counsel’s suggestion that he could not be fair and objective that proved his bias. See Cortez 159 S.W.3d at 94. His other comments merely explained the reason behind his bias. Here, the veniremember disagreed with every suggestion that he could not be fair and objective. His answers do not reflect a disqualifying bias. Id. at 385. 15. It is clear that if a venire person expresses unequivocal bias, then other venire ” persons who “feel the same way are also disqualified. It is not, however, sufficient if other venire persons simply “agree” with the statements made by the previous venire person. See Smith, 232 S.W.3d at 192 (holding “unlike the juror in Shepherd, the jurors empaneled from the block group merely raised their hands in agreement with another juror. This is not bias as a matter of law; thus, the jurors here were able to be rehabilitated”) 16. In Murffv. Pass, the Texas Supreme Court once again showed us how not to loop strike venirepersons. 249 S.W.3d 407 (Tex. 2008). In this medical malpractice case, venireperson Ruth stated he would hold the plaintiff to a clear and convincing standard of proof. Several other venirepersons raised their hands indicating they agreed with venireperson Ruth. Id. at 408. The problem is not striking several veniremembers at once. The problem is: (a) venireperson Ruth was confused at the definition of the proper standard of care; and (b) the other veniremembers simply raised their hand in agreement to a general question. Id. at 412. If, on the other hand, Ruth had expressed an unequivocal bias or prejudice without being confused and the other veniremembers raised their hands affirmatively feeling the same bias or prejudice, then all veniremembers would be struck for cause. 17. The Austin Court of Appeals explains how loop striking is allowed, but only works when the questions asked of the panel are clear without potential to be misconstrued. Union Pacific RR C0. v. Legg, 2009 WL 2476636, No. O3-07-00512-CV (Tex. App—Austin, Aug. 12, 2009, no pet.). In this case, a venireperson stated: I can feel for the family, I really can, but the money is not going to make things better, you know? I just don’t see how it could. It’s always going to be there, the pain. How is the money going to help stop the pain? Id. at 6. 18. When asked if anyone else felt the same way several other veniremembers raised their hands. While this type of loop striking is allowed, the veniremembers were not struck because the question may have meant that “money cannot help stop the pain from the loss of a loved one, or that it could not completely bring about justice.” Id. The possibility of confusion or misunderstanding in raising their hands prevented those veniremembers from being struck for cause. Id. The Austin Court noted the attorney did not make a follow-up question on the issue. Respectfiilly submitted, D. MILLER & ASSOCIATES, PLLC By: Andy Rubenstein State Bar No. 17360375 Anuj Kapur State Bar No. 24103706 2610 W. Sam Houston Pkwy S., Suite 200 Houston, Texas 77042 andy@dmillerlaw.com anuj @dmillerlawcom 713-850-8600 Office 713-366-3463 Facsimile ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE I hereby celtify that a true and correct copy of the above and foregoing instrument has been forwarded to all counsel in accordance with the Rules of Civil Procedure, this 23th day of February, 2023. Via Electronic Service Byron K. Henry Josh Wahl Scheef & Stone, L.L.P. 2600 Network Boulevard, Suite 400 Frisco, Texas 75034 Attorneys for Defendants Anuj Kapur 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. Paralegal DMillerLaw on behalf of Anuj Kapur Bar No. 24103706 paralegal@dmillerlaw.com Envelope ID: 73062006 Status as of 2/28/2023 9:33 AM CST Associated Case Party: MINERVA BLANCO Name BarNumber Email TimestampSubmitted Status Anuj Kapur anuj@dmillerlaw.com 2/23/2023 4:19:24 PM SENT Andy Rubenstein andy@dmillerlaw.com 2/23/2023 4:19:24 PM SENT Elizabeth Elizondo elelizondo@dmillerlaw.com 2/23/2023 4:19:24 PM SENT Nelly Macias nemacias@dmillerlaw.com 2/23/2023 4:19:24 PM SENT Ashley Salgado salgado@dmillerlaw.com 2/23/2023 4:19:24 PM SENT Associated Case Party: SUN HOLDINGS, INC. Name BarNumber Email TimestampSubmitted Status Byron K.Henry byron.henry@solidcounsel.com 2/23/2023 4:19:24 PM SENT Melissa Diaz melissa.diaz@solidcounsel.com 2/23/2023 4:19:24 PM SENT Josh Wahl josh.wahl@solidcounsel.com 2/23/2023 4:19:24 PM SENT Case Contacts Name BarNumber Email Timestam pSubmitted Status ANDREW ERUBENSTEIN andy@dmillerlaw.com 2/23/2023 4:19:24 PM SENT