On May 07, 2018 a
Trial Materials
was filed
involving a dispute between
Holbert, Ashley,
Holbert, Donna,
and
Catapult Energy Services Group, Llc,
Catapult Energy Services Group Llc,
Cretic Energy Services, Llc,
Cretic Energy Services Llc,
Ngp Energy Capital Management, Llc,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
Preview
FILED
9/6/2022 12:00 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Cassandra Walker DEPUTY
CAUSE NO. DC-18-05978
ASHLEY HOLBERT, INDIVIDUALLY, IN THE DISTRICT COURT
§§§§§§§§§§§§§§§§§§§§§
AND AS NEXT FRIEND OF K.H., A MINOR
AND AS REPRESENTATIVE OF THE
ESTATE OF ROWDY LEE HOLBERT,
DECEASED AND DONNA HOLBERT
Plaintiffs,
and
BIG B CRANE, LLC AND
INTERNATIONAL INSURANCE
COMPANY OF HANOVER S.E. 101“ JUDICIAL DISTRICT
Intervenors,
V.
CRETIC ENERGY SERVICES, LLC;
CATAPULT ENERGY SERVICES
GROUP, LLC; and N GP CAPITAL
MANAGEMENT, LLC.
Defendants. DALLAS COUNTY, TEXAS
PLAINTIFFS’ AND INTERVENORS’ AMENDED EXHIBIT LIST
Pursuant to the Texas Rules of Civil Procedure and the scheduling order herein, Plaintiffs
and Intervenors hereby designates the following trial exhibits:
N0. Description Offered Admitted Modified
1 Reagan County Sheriff Incident Report with
Pictures
2 Photographs - January 12, 2018 scene
3 Photographs - January 17, 2018 inspection
4 Photographs - Aerial Scene INTSOO683-684
5 Medical records from AirMed 1 (Rowdy)
6 Medical records from Reagan County Fire
Department (Rowdy)
PLAINTIFFS’AND INTERVENORS’ AMENDED EXHIBIT LIST PAGE 1
7 Funeral records from Clayton Kay Vaughan
Funeral Home
8 Autopsy Records from South Plains Forensic
Pathology
9 Cretic preliminary report CRETIC00632
10 Incident Witness Statements CRETIC
0000 l -00007
11 Affidavit of Stacey, Wall
12 Affidavit of Thompson, Ryan
l3 Affidavit of Giese, Anthony
l4 Affidavit of Kilgore, Denton
15 Affidavit of Flores, Tyler
l6 Affidavit of Horton, Monty
l7 Affidavit of Maglaris, Daniel
l8 Affidavit of Sanchez, Adan (A.J.)
l9 Affidavit of Hines, Dexter
20 Sign in and Check List (J SA)
CRETIC00628-631
21 Standard Crane Hand Sigials
22 Wind Speed Data
23 Sunrise and Sunset Data
24 Animation - Demonstrative
25 Hook Latch Inspection Video
26 Cretic Prior Accident photographs
CRETIC00798-00806
27 Christie Orson 2017 Report
CRETIC00845-00846
28 Rowe Welding Invoices CRETIC00680-683
29 Cretic Policies CRETIC 00516-533
3O Application for Employment
NTS00978-INTSOO987
PLAINTIFFS’AND INTERVENORS’ AMENDED EXHIBIT LIST PAGE 2
31 Big B Crane's Facebook post - Rowdy
32 Obituary of Rowdy Holbert
33 Photograph family
34 Medical records from Cook Children's Med Ctr
(K.H.)
35 Medical records from First Step Pediatric Assoc
(K.H.)
36 Medical records from Texas Health Physicians
Group - Ray, DO (Ashley)
37 Medical records from Hillside Counseling
(Ashley)
38 Medical records from Mesa Springs (Ashley)
39 Expert.Liebkemann, Fred.CV
40 ExpertLiebkemann, Fred.Report
41 ExpertDancilla, Dragos Stefan.CV
42 ExpertDancilla, Dragos Stefan.Report
43 ExpertDancilla, Dragos Stefan.Certificate of
Merit
44 Expert.Lusi, Anthony J. Jr.CV
45 Expert.Lusi, Anthony J. Jr.Report
46 Expert.Peerwani. Nizam.CV
47 Expert.Shipp, Shannon.CV
48 Expert.Shipp, Shannon.Report and worksheets
49 Duct Tape Article Ex. 1 to Depo.Gray, James
Wendell
50 Hook and Latch Demonstrative
51 Hydra-Rig-BOP-Handler Demonstrative
52 Drawing from Liebkemann
53 Miller Certification for Signalmann Rigger
CRETIC005 15
54 TEREX Load Charts INTSOOSOO
PLAINTIFFS’AND INTERVENORS’ AMENDED EXHIBIT LIST PAGE 3
55 Invoice for Replacement Crane INTSOO768-769
56 2014 Profit & Loss Statement INTSO3118 -
INTSO3119
57 2015 Profit & Loss Statement INTSO3116 -
1NTSO31 17
58 2016 Profit & Loss Statement [NTSO3120 -
INTS03121
59 2017 Profit & Loss Statement [NTSO3122 -
INTSO3123
60 ASME Standards - B30.5-2018
61 Coleman Supervisor Accident Report
INTSOOSS2
62 Cretic Field Ticket CRETIC00649
63 Cretic Photo Lower Cab CRETIC00784
64 Cretic Photo of Crane CRETIC00787
65 Cretic Photos Coil Tube Spool Unit
CRETIC00791-792
66 2017 Inspection of TEREX Crane
INT800554-562
67 AC140 Operating Instructions Superstructure
Plaintiffs and Intervenors reserve the right to utilize and refer to any exhibits designated by
Defendants herein. Plaintiffs and Intervenors further reserve the right to utilize and refer to all
documents produced by the parties in discovery and all exhibits attached to depositions taken in this
case. Plaintiffs and Intervenors may also introduce additional exhibits to be used as rebuttal
evidence.
PLAINTIFFS’AND INTERVENORS’ AMENDED EXHIBIT LIST PAGE 4
Respectfully submitted,
/s/ Brian W. Butcher
Charles M. Noteboom
State Bar No. 15116875
Brian W. Butcher
State Bar No. 24029928
NOTEBOOM - The Law Firm
669 Airport Freeway
Hurst, Texas 76053
817.282.9700 Phone
817.282.8073 Fax
butcher@noteboom.com
ATTORNEYS FOR PLAINTIFFS
CERTIFICATE OF SERVICE
I hereby certify that on September 5, 2022 the foregoing instrument was served on all
counsel of record in accordance with the Texas Rules of Civil Procedure.
/s/ Brian W. Butcher
Brian W. Butcher
PLAINTIFFS’AND INTERVENORS’ AMENDED EXHIBIT LIST PAGE 5
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.
Glenda Joyner on behalf of Brian Butcher
Bar No. 24029928
joyner@noteboom.com
Envelope ID: 67956511
Status as of 9/7/2022 11:37 AM CST
Associated Case Party: Big B Crane LLC
Name BarNumber Email TimestampSubmitted Status
John HolmanBarr jbarr@bbarr.com 9/5/2022 9:25:00 PM SENT
John HolmanBarr jbarr@bbarr.com 9/5/2022 9:25:00 PM SENT
Michael ForestNelson fnelson@bbarr.com 9/5/2022 9:25:00 PM SENT
Mary ChristianBarr mcbarr@bbarr.com 9/5/2022 9:25:00 PM SENT
Eliza Montez emontez@bbarr.com 9/5/2022 9:25:00 PM SENT
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.
Glenda Joyner on behalf of Brian Butcher
Bar No. 24029928
joyner@noteboom.com
Envelope ID: 67956511
Status as of 9/7/2022 11:37 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Shawn SHinkle shinkle@pf-lawfirm.com 9/5/2022 9:25:00 PM SENT
Chris DParker cparker@pf—|awfirm.com 9/5/2022 9:25:00 PM SENT
Tom DFarris tfarris@pf—lawfirm.com 9/5/2022 9:25:00 PM SENT
Ruth Fields rfields@bbarr.com 9/5/2022 9:25:00 PM SENT
Teresa Jones Teresa.Jones@dallascounty.org 9/5/2022 9:25:00 PM SENT
Jeri LMorgan jlmorgan@dgclaw.com 9/5/2022 9:25:00 PM ERROR
Jorge Sanchez 101 court@dallascounty.org 9/5/2022 9:25:00 PM SENT
Natasha Taylor taylor@wrightclosebarger.com 9/5/2022 9:25:00 PM SENT
Eric Boettcher boettcher@wrightclosebarger.com 9/5/2022 9:25:00 PM SENT
Becky Grooms bgrooms@pf-lawfirm.com 9/5/2022 9:25:00 PM SENT
Amber DGriffith agriffith@pf-Iawfirm.com 9/5/2022 9:25:00 PM SENT
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.
Glenda Joyner on behalf of Brian Butcher
Bar No. 24029928
joyner@noteboom.com
Envelope ID: 67956511
Status as of 9/7/2022 11:37 AM CST
Associated Case Party: LAREDO PETROLEUM INC
Name BarNumber Email TimestampSubmitted Status
Jill Christine Pennington 24007825 jcpennington@permian.law 9/5/2022 9:25:00 PM SENT
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.
Glenda Joyner on behalf of Brian Butcher
Bar No. 24029928
joyner@noteboom.com
Envelope ID: 67956511
Status as of 9/7/2022 11:37 AM CST
Associated Case Party: International Insurance Company of Hanover S.E.
Name BarNumber Email TimestampSubmitted Status
John HBarr jbarr@bbarr.com 9/5/2022 9:25:00 PM SENT
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.
Glenda Joyner on behalf of Brian Butcher
Bar No. 24029928
joyner@noteboom.com
Envelope ID: 67956511
Status as of 9/7/2022 11:37 AM CST
Associated Case Party: Ashley Holbert
Name BarNumber Email TimestampSubmitted Status
Brian W.Butcher butcher@noteboom.com 9/5/2022 9:25:00 PM SENT
Charles M.Noteboom noteboom@noteboom.com 9/5/2022 9:25:00 PM SENT
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.
Glenda Joyner on behalf of Brian Butcher
Bar No. 24029928
joyner@noteboom.com
Envelope ID: 67956511
Status as of 9/7/2022 11:37 AM CST
Associated Case Party: Donna Holbert
Name BarNumber Email TimestampSubmitted Status
Brian W.Butcher butcher@noteboom.com 9/5/2022 9:25:00 PM SENT
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.
Glenda Joyner on behalf of Brian Butcher
Bar No. 24029928
joyner@noteboom.com
Envelope ID: 67956511
Status as of 9/7/2022 11:37 AM CST
Associated Case Party: Cretic Energy Services, LLC
Name BarNumber Email TimestampSubmitted Status
Chris D.Parker cparker@pf—lawfirm.com 9/5/2022 9:25:00 PM SENT
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.
Glenda Joyner on behalf of Brian Butcher
Bar No. 24029928
joyner@noteboom.com
Envelope ID: 67956511
Status as of 9/7/2022 11:37 AM CST
Associated Case Party: Catapult Energy Services Group, LLC
Name BarNumber Email TimestampSubmitted Status
Chris Parker cparker@pf—lawfirm.com 9/5/2022 9:25:00 PM SENT
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.
Glenda Joyner on behalf of Brian Butcher
Bar No. 24029928
joyner@noteboom.com
Envelope ID: 67956511
Status as of 9/7/2022 11:37 AM CST
Associated Case Party: NGP ENERGY CAPITAL MANAGEMENT, LLC
Name BarNumber Email TimestampSubmitted Status
Chris Parker cparker@pf—lawfirm.com 9/5/2022 9:25:00 PM SENT
Document Filed Date
September 06, 2022
Case Filing Date
May 07, 2018
Category
OTHER PERSONAL INJURY
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