Preview
Filed: 2/14/2022 4:57 PM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 61736170
By: Lisa Kelly
2/15/2022 7:37 AM
CAUSE NO. 21-CV-0332
LISA LESLIE, § IN THE DISTRICT COURT
Plaintiff. §
§
v. §
§ 212th JUDICIAL DISTRICT
EDWIN ALLEN WHEATLEY, JR. §
d/b/a FAST RIGHT REMODELING §
SERVICE §
Defendant. § GALVESTON COUNTY, TEXAS
DEFENDANT’S DESIGNATION OF EXPERT WITNESSESS
TO: Plaintiff, LISA LESLIE, by and through her attorneys of record, Mark S. Byrne and Chris
Lay of Robert D. Clements, Jr, Law Group, LLLP, 1600 East Highway 6, Suite 318 Alvin,
Texas 77511, Tel: (210) 340-9877, Facsimile: (210) 340-9899, Email:
mbyrne@rdclements.com and chris@rdclements.com.
COMES NOW, Defendant, EDWIN ALLEN WHEATLEY, JR d/b/a FAST RIGHT
REMODELING SERVICE and files its Designation of Experts in the above cause number which
will supplement its prior responses to all discovery filed herein.
I. RETAINED EXPERT
Defendant hereby designates the following individual who may be called as retained expert
witness to testify in this cause:
Karalynn Cromeens
The Cromeens Law Firm, PLLC
1345 Campbell Road, Suite 200
Houston, Texas 77055
Phone: 713/715-7334
Fax: 713/715-7335
Ms. Cromeens will offer expert testimony regarding reasonable and necessary attorney’s
fees and costs incurred by Plaintiffs, as well as any fees claimed by the Defendant. The general
Defendant’s Designation of Expert Witnesses
Page 1 of 7
substance of Ms. Cromeens’s mental impressions and opinions will be that $450.00 per hour is a
reasonable and necessary fee in pursuing the claims of/defending Plaintiffs in this case and that
any fees claimed by Defendant were neither reasonable nor necessary under the circumstances.
Ms. Cromeens will also offer testimony as to the reasonableness and necessity of work performed
by associate attorneys and paralegals. Ms. Cromeens may offer expert testimony that the
reasonable and necessary attorney fees if this case should be appealed to the Court of Appeals
would be $15,000.00. Ms. Cromeens may offer expert testimony that the reasonable and necessary
attorney fees if a Motion for Rehearing or a Petition for Review is filed in the Texas Supreme
Court would be $10,500.00. Ms. Cromeens may offer expert testimony that the reasonable and
necessary attorney fees if the Texas Supreme Court granted a Petition for Review would be
$7,000.00. Ms. Cromeens reserves the right to adjust this amount as discovery is completed and
the facts of this case develop. Ms. Cromeens’s opinions are based on her training, education, and
experience as a licensed attorney in the State of Texas in Harris County. Ms. Cromeens’s CV is
attached hereto as Exhibit A – FAST RIGHT 000001-000002. Ms. Cromeens is available for
deposition at the request of Defendant. No report will be produced, and no additional documents
have been reviewed or produced by Ms. Cromeens in anticipation of her testimony. Any invoices
or time sheets reflecting fees are business records and can be provided in response to a proper
request for production.
Ieshia J. Dunmore
Senior Associate Attorney
The Cromeens Law Firm, PLLC
1345 Campbell Road, Suite 200
Houston, Texas 77055
Phone: 713/715-7334
Fax: 713/715-7335
Defendant’s Designation of Expert Witnesses
Page 2 of 7
Ms. Dunmore will offer expert testimony regarding reasonable and necessary attorneys’
fees and costs incurred by Plaintiff, as well as any fees claimed by the Defendant. The general
substance of Ms. Dunmore’s mental impressions and opinions will be that up to $450.00 per hour
is a reasonable and necessary fee in pursuing the claims of Plaintiff in this case and that any fees
claimed by the Defendant were neither reasonable nor necessary under the circumstances. Ms.
Dunmore will also offer testimony as to the reasonableness and necessity of work performed by
associate attorneys and paralegals. Ms. Dunmore may offer expert testimony that the reasonable
and necessary attorneys’ fees of this case should be appealed to the Court of Appeals would be
$15,000.00. Ms. Dunmore may offer expert testimony that that the reasonable and necessary
attorney fees if a Motion for Rehearing or a Petition for Review is filed in the Texas Supreme
Court would be $10,500.00. Ms. Dunmore may offer expert testimony that the reasonable and
necessary attorneys’ fees if the Texas Supreme Court granted a Petition for Review would be
$7,000.00. Ms. Dunmore reserves the right to adjust this amount as discovery is completed and
the facts of this case develop. Ms. Dunmore’s opinions are based on her training, education and
experience as a licensed attorney in the State of Texas. Ms. Dunmore’s CV is attached hereto as
Exhibit B- FAST RIGHT 000003. Ms. Dunmore is available for deposition at the request of
Plaintiff. No report will be produced, and no additional documents have been reviewed or
produced by Ms. Dunmore in anticipation of her testimony. Any invoices or time sheets reflecting
fees are business records and can be provided in response to a proper request for production.
Defendant’s Designation of Expert Witnesses
Page 3 of 7
Kelly N. Stamy
Senior Associate Attorney
The Cromeens Law Firm, PLLC
1345 Campbell Road, Suite 200
Houston, Texas 77055
Phone: 713/715-7334
Fax: 713/715-7335
Ms. Stamy will offer expert testimony regarding reasonable and necessary attorneys’ fees
and costs incurred by Plaintiff, as well as any fees claimed by the Defendant. The general
substance of Ms. Stamy’s mental impressions and opinions will be that up to $450.00 per hour is
a reasonable and necessary fee in pursuing the claims of Plaintiff in this case and that any fees
claimed by the Defendant were neither reasonable nor necessary under the circumstances. Ms.
Dunmore will also offer testimony as to the reasonableness and necessity of work performed by
associate attorneys and paralegals. Ms. Stamy may offer expert testimony that the reasonable and
necessary attorneys’ fees of this case should be appealed to the Court of Appeals would be
$15,000.00. Ms. Stamy may offer expert testimony that that the reasonable and necessary attorney
fees if a Motion for Rehearing or a Petition for Review is filed in the Texas Supreme Court would
be $10,500.00. Ms. Stamy may offer expert testimony that the reasonable and necessary attorneys’
fees if the Texas Supreme Court granted a Petition for Review would be $7,000.00. Ms. Stamy
reserves the right to adjust this amount as discovery is completed and the facts of this case develop.
Ms. Stamy’s opinions are based on her training, education and experience as a licensed attorney
in the State of Texas. Ms. Stamy’s CV is attached hereto as Exhibit B- FAST RIGHT 000004.
Ms. Stamy is available for deposition at the request of Plaintiff. No report will be produced, and
no additional documents have been reviewed or produced by Ms. Stamy in anticipation of her
Defendant’s Designation of Expert Witnesses
Page 4 of 7
testimony. Any invoices or time sheets reflecting fees are business records and can be provided in
response to a proper request for production.
II. NON-RETAINED AND OTHER EXPERTS
Edwin Allen Wheatley, Jr.
Fast Right Remodeling Service
c/o The Cromeens Law Firm, PLLC
1345 Campbell Rd., Ste 200
Houston, Texas 77055
Mr. Wheatley will testify regarding relevant industry customs and practices; including,
but not limited to, those related to general construction and residential remodeling. Mr.
Wheatley will base his opinions on his training, education, and experience as the owner and
operator of Fast Right Remodeling. The general substance of Mr. Wheatley’s mental
impressions and opinions are that Fast Right Remodeling’s customs and practices comply with
all applicable industry standards. Mr. Wheatley has reviewed all the pleadings filed and
discovery produced in this matter. Mr. Wheatley is available for deposition upon reasonable
request and notice as set forth by the Texas Rules of Civil Procedure and no report will be
produced. Mr. Wheatley’s CV is available upon request.
Defendant cross-designates all Plaintiff’s designated trial witnesses and reserves its right
to call any fact witnesses and elicit permissible opinions from any such witness. Fact witnesses
disclosed and identified by either party herein, as of now and hereafter, are designed insofar as
any of them may be called upon to provide an opinion on an issue upon which an opinion from
a lay witness is appropriate and admissible.
Defendant reserves its right to call any rebuttal experts and thus designates any
rebuttal experts that might be called to testify in this matter.
Defendant’s Designation of Expert Witnesses
Page 5 of 7
Defendant hereby designates all custodians of record of any individual and/or entities
from whom records or documents may be obtained in this case.
Defendant expressly reserves the right to amend and/or supplement this designation in
accordance with Texas law, the Court’s orders and/or the parties’ agreements.
III. DE-DESIGNATION OF EXPERTS
Defendant reserves the right to de-designate experts in the future.
WHEREFORE, Defendant files this Designation of Expert Witness.
Respectfully submitted,
THE CROMEENS LAW FIRM, PLLC
BY:
KARALYNN C. CROMEENS
SBN: 24045726
IESHIA J. DUNMORE
SBN: 24083609
1345 Campbell Road, Suite 200
Houston, Texas 77055
713/715-7334 Phone
713/715-7335 Fax
Karalynn@TheCromeensLawFirm.com
IDunmore@TheCromeensLawFirm.com
ATTORNEYS FOR PLAINTIFF
Defendant’s Designation of Expert Witnesses
Page 6 of 7
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was served upon
all parties herein via Tex. R. Civ. P. 21 and 21a on this the 14th day of February, 2022.
VIA E-SERVICE AND/OR FAX
Mark S. Byrne
Chris R. Lay
Robert D. Clements, Jr. Law Group, LLLP
1600 East Highway 6, Suite 318
Alvin, Texas 77511
Telephone: (281) 331-1325
mbyrne@rdclements.com
chris@rdclements.com
ATTORNEYS FOR PLAINTIFF
IESHIA J. DUNMORE
Defendant’s Designation of Expert Witnesses
Page 7 of 7
EXHIBIT A
K AR ALYNN
CROMEENS
OWNER & MANAGING PARTNER
Phone: Email: Website:
(713) 715-7334 karalynn@TheCromeensLawFirm.com TheCromeensLawFirm.com
FAST RIGHT 000001
KARALYNN
CROMEENS 1345 Campbell Rd., Ste 200
Houston, TX 77055, US
OWNER & MANAGING PARTNER
PROFILE
Award Winning Lawyer, Best-Selling Author, & Business Owner.
As a Managing Partner for The Cromeens Law Firm, PLLC, Karalynn holds more than 16 MEMBERSHIPS
years’ experience practicing construction, real estate, lien and business law. Throughout
her professional career, Karalynn has successfully filed more than a thousand lawsuits to
• Texas State Bar Association,
foreclose or remove mechanic’s liens, with 10 to 15 of those cases being tried to a jury. 90
Construction Section
percent of Karalynn’s current practice is comprised of collections, construction and lien
litigation.
• Texas State Bar Association,
Solo Practitioners Section
EDUC ATIO N • Houston Bar Association,
Construction Section
Juris Doctorate B.S. Criminal Justice, Psychology • American Subcontractors
Association,
2004 2001
Houston Chapter
South Texas College of Law Carroll College
Houston, Texas Waukesha, Wisconsin • National Association of
Minority Contractors,
Houston Chapter
• Houston Contractors
WORK EXP E RI E N CE Association
Owner & Managing Partner 2006—Present • Blue Book Network
The Cromeens Law Firm, PLLC / 8431 Katy Freeway, Houston, TX 77024
• Greater Houston Procurement
Forum
Associate Attorney 2004—2006
• Regional Hispanic Contractors
Law Office of J. Tompkins / Example Street, City 5555, State Association
• Hispanic Contractors
Association de San Antonio
P UBLICAT I O N S
• Home Builders Association of
Author 2021 Greater Austin
Quit Getting Screwed: Understand & Negotiating the Subcontract
* Amazon Best Seller
AC C O LAD E S
Author & Contributer 2010-2011
• Houstonian Magazine’s 2016
American Subcontractors Association
Top Lawyer Award for
Contributer 2006—2009 Construction Law
O’Connor’s- Texas Property Code Plus
FAST RIGHT 000002
PHONE: (713) 715-7334 EMAIL: karalynn@thecromeenslawfirm.com WEB: www.thecromeenslawfirm.com
EXHIBIT B
Ieshia J. Dunmore
Senior Associate Attorney
IDunmore@TheCromeensLawFirm.com
Ieshia has practiced civil litigation, personal injury and family law in the San Antonio area for six years. Additionally, she
has practiced real estate, construction, and lien law in the Houston area for two years. 90 percent of Ieshia's current practice
is comprised of construction and lien litigation.
Experience
Associate Attorney 2018 - Present
The Cromeens Law Firm, P.L.L.C.
Founding Partner 2012 - 2018
The Dunmore Law Firm, P.L.L.C.
Education
St. Mary’s School of Law – Juris Doctorate 2012
San Antonio, Texas
University of Texas, S.A. – B.S. Political Science; Minor in Public Speaking 2008
San Antonio, Texas
Licenses
State Bar of Texas 2012 - Present
Admitted to Practice in all state courts
FAST RIGHT 000003
EXHIBIT C
Kelly Stamy
Senior Associate Attorney
KStamy@TheCromeensLawFirm.com
Kelly has practiced civil and administrative law in the Houston area for five years. Kelly has attended over fifty hearings
and has represented clients regarding matters including breach of contract, collections, construction law, and employment
law. She has second chaired several trials and arbitrations, handled briefing on appeal, has experience in taking and
defending depositions, and has experience successfully prosecuting and defending evidentiary hearings.
Experience
Associate Attorney 2019 - Present
The Cromeens Law Firm, P.L.L.C.
Associate Attorney 2015 - 2018
Fiddler & Associates, P.C.
Education
South Texas College of Law – Doctor of Jurisprudence 2015
San Antonio, Texas
Houston Baptist University – Bachelor of Arts, Government and History 2012
Houston, Texas
Licenses
State Bar of Texas 2015 - Present
Admitted to Practice in all state courts and Southern District of Texas
Memberships
Texas State Bar Association
Houston Bar Association
Young Lawyers Committee - Bankruptcy Section of Texas State Bar.
FAST RIGHT 000004
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.
Darcy Horne on behalf of KARALYNN CROMEENS
Bar No. 24045726
paralegal2@thecromeenslawfirm.com
Envelope ID: 61736170
Status as of 2/15/2022 7:37 AM CST
Associated Case Party: Lisa Leslie
Name BarNumber Email TimestampSubmitted Status
Jake Leggett 24117219 jleggett@rdclements.com 2/14/2022 4:57:55 PM SENT
Associated Case Party: EdwinAllenWheatley
Name BarNumber Email TimestampSubmitted Status
Ieshia Dunmore IDunmore@TheCromeensLawFirm.com 2/14/2022 4:57:55 PM SENT
Oriana Torin paralegal@thecromeenslawfirm.com 2/14/2022 4:57:55 PM SENT
Darcy Horne paralegal2@thecromeenslawfirm.com 2/14/2022 4:57:55 PM SENT
Terry Gomez TGomez@TheCromeensLawFirm.com 2/14/2022 4:57:55 PM SENT
Karalynn Cromeens karalynn@thecromeenslawfirm.com 2/14/2022 4:57:55 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Chris Lay Chris@rdclements.com 2/14/2022 4:57:55 PM SENT
Mark S.Byrne mbyrne@rdclements.com 2/14/2022 4:57:55 PM SENT
Rosa ElenaSagredo rosa@rdclements.com 2/14/2022 4:57:55 PM SENT
Preview
Filed: 2/14/2022 4:57 PM JOHN D. KINARD - District Clerk Galveston County, Texas Envelope No. 61736170 By: Lisa Kelly 2/15/2022 7:37 AM CAUSE NO. 21-CV-0332 LISA LESLIE, § IN THE DISTRICT COURT Plaintiff. § § v. § § 212th JUDICIAL DISTRICT EDWIN ALLEN WHEATLEY, JR. § d/b/a FAST RIGHT REMODELING § SERVICE § Defendant. § GALVESTON COUNTY, TEXAS DEFENDANT’S DESIGNATION OF EXPERT WITNESSESS TO: Plaintiff, LISA LESLIE, by and through her attorneys of record, Mark S. Byrne and Chris Lay of Robert D. Clements, Jr, Law Group, LLLP, 1600 East Highway 6, Suite 318 Alvin, Texas 77511, Tel: (210) 340-9877, Facsimile: (210) 340-9899, Email: mbyrne@rdclements.com and chris@rdclements.com. COMES NOW, Defendant, EDWIN ALLEN WHEATLEY, JR d/b/a FAST RIGHT REMODELING SERVICE and files its Designation of Experts in the above cause number which will supplement its prior responses to all discovery filed herein. I. RETAINED EXPERT Defendant hereby designates the following individual who may be called as retained expert witness to testify in this cause: Karalynn Cromeens The Cromeens Law Firm, PLLC 1345 Campbell Road, Suite 200 Houston, Texas 77055 Phone: 713/715-7334 Fax: 713/715-7335 Ms. Cromeens will offer expert testimony regarding reasonable and necessary attorney’s fees and costs incurred by Plaintiffs, as well as any fees claimed by the Defendant. The general Defendant’s Designation of Expert Witnesses Page 1 of 7 substance of Ms. Cromeens’s mental impressions and opinions will be that $450.00 per hour is a reasonable and necessary fee in pursuing the claims of/defending Plaintiffs in this case and that any fees claimed by Defendant were neither reasonable nor necessary under the circumstances. Ms. Cromeens will also offer testimony as to the reasonableness and necessity of work performed by associate attorneys and paralegals. Ms. Cromeens may offer expert testimony that the reasonable and necessary attorney fees if this case should be appealed to the Court of Appeals would be $15,000.00. Ms. Cromeens may offer expert testimony that the reasonable and necessary attorney fees if a Motion for Rehearing or a Petition for Review is filed in the Texas Supreme Court would be $10,500.00. Ms. Cromeens may offer expert testimony that the reasonable and necessary attorney fees if the Texas Supreme Court granted a Petition for Review would be $7,000.00. Ms. Cromeens reserves the right to adjust this amount as discovery is completed and the facts of this case develop. Ms. Cromeens’s opinions are based on her training, education, and experience as a licensed attorney in the State of Texas in Harris County. Ms. Cromeens’s CV is attached hereto as Exhibit A – FAST RIGHT 000001-000002. Ms. Cromeens is available for deposition at the request of Defendant. No report will be produced, and no additional documents have been reviewed or produced by Ms. Cromeens in anticipation of her testimony. Any invoices or time sheets reflecting fees are business records and can be provided in response to a proper request for production. Ieshia J. Dunmore Senior Associate Attorney The Cromeens Law Firm, PLLC 1345 Campbell Road, Suite 200 Houston, Texas 77055 Phone: 713/715-7334 Fax: 713/715-7335 Defendant’s Designation of Expert Witnesses Page 2 of 7 Ms. Dunmore will offer expert testimony regarding reasonable and necessary attorneys’ fees and costs incurred by Plaintiff, as well as any fees claimed by the Defendant. The general substance of Ms. Dunmore’s mental impressions and opinions will be that up to $450.00 per hour is a reasonable and necessary fee in pursuing the claims of Plaintiff in this case and that any fees claimed by the Defendant were neither reasonable nor necessary under the circumstances. Ms. Dunmore will also offer testimony as to the reasonableness and necessity of work performed by associate attorneys and paralegals. Ms. Dunmore may offer expert testimony that the reasonable and necessary attorneys’ fees of this case should be appealed to the Court of Appeals would be $15,000.00. Ms. Dunmore may offer expert testimony that that the reasonable and necessary attorney fees if a Motion for Rehearing or a Petition for Review is filed in the Texas Supreme Court would be $10,500.00. Ms. Dunmore may offer expert testimony that the reasonable and necessary attorneys’ fees if the Texas Supreme Court granted a Petition for Review would be $7,000.00. Ms. Dunmore reserves the right to adjust this amount as discovery is completed and the facts of this case develop. Ms. Dunmore’s opinions are based on her training, education and experience as a licensed attorney in the State of Texas. Ms. Dunmore’s CV is attached hereto as Exhibit B- FAST RIGHT 000003. Ms. Dunmore is available for deposition at the request of Plaintiff. No report will be produced, and no additional documents have been reviewed or produced by Ms. Dunmore in anticipation of her testimony. Any invoices or time sheets reflecting fees are business records and can be provided in response to a proper request for production. Defendant’s Designation of Expert Witnesses Page 3 of 7 Kelly N. Stamy Senior Associate Attorney The Cromeens Law Firm, PLLC 1345 Campbell Road, Suite 200 Houston, Texas 77055 Phone: 713/715-7334 Fax: 713/715-7335 Ms. Stamy will offer expert testimony regarding reasonable and necessary attorneys’ fees and costs incurred by Plaintiff, as well as any fees claimed by the Defendant. The general substance of Ms. Stamy’s mental impressions and opinions will be that up to $450.00 per hour is a reasonable and necessary fee in pursuing the claims of Plaintiff in this case and that any fees claimed by the Defendant were neither reasonable nor necessary under the circumstances. Ms. Dunmore will also offer testimony as to the reasonableness and necessity of work performed by associate attorneys and paralegals. Ms. Stamy may offer expert testimony that the reasonable and necessary attorneys’ fees of this case should be appealed to the Court of Appeals would be $15,000.00. Ms. Stamy may offer expert testimony that that the reasonable and necessary attorney fees if a Motion for Rehearing or a Petition for Review is filed in the Texas Supreme Court would be $10,500.00. Ms. Stamy may offer expert testimony that the reasonable and necessary attorneys’ fees if the Texas Supreme Court granted a Petition for Review would be $7,000.00. Ms. Stamy reserves the right to adjust this amount as discovery is completed and the facts of this case develop. Ms. Stamy’s opinions are based on her training, education and experience as a licensed attorney in the State of Texas. Ms. Stamy’s CV is attached hereto as Exhibit B- FAST RIGHT 000004. Ms. Stamy is available for deposition at the request of Plaintiff. No report will be produced, and no additional documents have been reviewed or produced by Ms. Stamy in anticipation of her Defendant’s Designation of Expert Witnesses Page 4 of 7 testimony. Any invoices or time sheets reflecting fees are business records and can be provided in response to a proper request for production. II. NON-RETAINED AND OTHER EXPERTS Edwin Allen Wheatley, Jr. Fast Right Remodeling Service c/o The Cromeens Law Firm, PLLC 1345 Campbell Rd., Ste 200 Houston, Texas 77055 Mr. Wheatley will testify regarding relevant industry customs and practices; including, but not limited to, those related to general construction and residential remodeling. Mr. Wheatley will base his opinions on his training, education, and experience as the owner and operator of Fast Right Remodeling. The general substance of Mr. Wheatley’s mental impressions and opinions are that Fast Right Remodeling’s customs and practices comply with all applicable industry standards. Mr. Wheatley has reviewed all the pleadings filed and discovery produced in this matter. Mr. Wheatley is available for deposition upon reasonable request and notice as set forth by the Texas Rules of Civil Procedure and no report will be produced. Mr. Wheatley’s CV is available upon request. Defendant cross-designates all Plaintiff’s designated trial witnesses and reserves its right to call any fact witnesses and elicit permissible opinions from any such witness. Fact witnesses disclosed and identified by either party herein, as of now and hereafter, are designed insofar as any of them may be called upon to provide an opinion on an issue upon which an opinion from a lay witness is appropriate and admissible. Defendant reserves its right to call any rebuttal experts and thus designates any rebuttal experts that might be called to testify in this matter. Defendant’s Designation of Expert Witnesses Page 5 of 7 Defendant hereby designates all custodians of record of any individual and/or entities from whom records or documents may be obtained in this case. Defendant expressly reserves the right to amend and/or supplement this designation in accordance with Texas law, the Court’s orders and/or the parties’ agreements. III. DE-DESIGNATION OF EXPERTS Defendant reserves the right to de-designate experts in the future. WHEREFORE, Defendant files this Designation of Expert Witness. Respectfully submitted, THE CROMEENS LAW FIRM, PLLC BY: KARALYNN C. CROMEENS SBN: 24045726 IESHIA J. DUNMORE SBN: 24083609 1345 Campbell Road, Suite 200 Houston, Texas 77055 713/715-7334 Phone 713/715-7335 Fax Karalynn@TheCromeensLawFirm.com IDunmore@TheCromeensLawFirm.com ATTORNEYS FOR PLAINTIFF Defendant’s Designation of Expert Witnesses Page 6 of 7 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served upon all parties herein via Tex. R. Civ. P. 21 and 21a on this the 14th day of February, 2022. VIA E-SERVICE AND/OR FAX Mark S. Byrne Chris R. Lay Robert D. Clements, Jr. Law Group, LLLP 1600 East Highway 6, Suite 318 Alvin, Texas 77511 Telephone: (281) 331-1325 mbyrne@rdclements.com chris@rdclements.com ATTORNEYS FOR PLAINTIFF IESHIA J. DUNMORE Defendant’s Designation of Expert Witnesses Page 7 of 7 EXHIBIT A K AR ALYNN CROMEENS OWNER & MANAGING PARTNER Phone: Email: Website: (713) 715-7334 karalynn@TheCromeensLawFirm.com TheCromeensLawFirm.com FAST RIGHT 000001 KARALYNN CROMEENS 1345 Campbell Rd., Ste 200 Houston, TX 77055, US OWNER & MANAGING PARTNER PROFILE Award Winning Lawyer, Best-Selling Author, & Business Owner. As a Managing Partner for The Cromeens Law Firm, PLLC, Karalynn holds more than 16 MEMBERSHIPS years’ experience practicing construction, real estate, lien and business law. Throughout her professional career, Karalynn has successfully filed more than a thousand lawsuits to • Texas State Bar Association, foreclose or remove mechanic’s liens, with 10 to 15 of those cases being tried to a jury. 90 Construction Section percent of Karalynn’s current practice is comprised of collections, construction and lien litigation. • Texas State Bar Association, Solo Practitioners Section EDUC ATIO N • Houston Bar Association, Construction Section Juris Doctorate B.S. Criminal Justice, Psychology • American Subcontractors Association, 2004 2001 Houston Chapter South Texas College of Law Carroll College Houston, Texas Waukesha, Wisconsin • National Association of Minority Contractors, Houston Chapter • Houston Contractors WORK EXP E RI E N CE Association Owner & Managing Partner 2006—Present • Blue Book Network The Cromeens Law Firm, PLLC / 8431 Katy Freeway, Houston, TX 77024 • Greater Houston Procurement Forum Associate Attorney 2004—2006 • Regional Hispanic Contractors Law Office of J. Tompkins / Example Street, City 5555, State Association • Hispanic Contractors Association de San Antonio P UBLICAT I O N S • Home Builders Association of Author 2021 Greater Austin Quit Getting Screwed: Understand & Negotiating the Subcontract * Amazon Best Seller AC C O LAD E S Author & Contributer 2010-2011 • Houstonian Magazine’s 2016 American Subcontractors Association Top Lawyer Award for Contributer 2006—2009 Construction Law O’Connor’s- Texas Property Code Plus FAST RIGHT 000002 PHONE: (713) 715-7334 EMAIL: karalynn@thecromeenslawfirm.com WEB: www.thecromeenslawfirm.com EXHIBIT B Ieshia J. Dunmore Senior Associate Attorney IDunmore@TheCromeensLawFirm.com Ieshia has practiced civil litigation, personal injury and family law in the San Antonio area for six years. Additionally, she has practiced real estate, construction, and lien law in the Houston area for two years. 90 percent of Ieshia's current practice is comprised of construction and lien litigation. Experience Associate Attorney 2018 - Present The Cromeens Law Firm, P.L.L.C. Founding Partner 2012 - 2018 The Dunmore Law Firm, P.L.L.C. Education St. Mary’s School of Law – Juris Doctorate 2012 San Antonio, Texas University of Texas, S.A. – B.S. Political Science; Minor in Public Speaking 2008 San Antonio, Texas Licenses State Bar of Texas 2012 - Present Admitted to Practice in all state courts FAST RIGHT 000003 EXHIBIT C Kelly Stamy Senior Associate Attorney KStamy@TheCromeensLawFirm.com Kelly has practiced civil and administrative law in the Houston area for five years. Kelly has attended over fifty hearings and has represented clients regarding matters including breach of contract, collections, construction law, and employment law. She has second chaired several trials and arbitrations, handled briefing on appeal, has experience in taking and defending depositions, and has experience successfully prosecuting and defending evidentiary hearings. Experience Associate Attorney 2019 - Present The Cromeens Law Firm, P.L.L.C. Associate Attorney 2015 - 2018 Fiddler & Associates, P.C. Education South Texas College of Law – Doctor of Jurisprudence 2015 San Antonio, Texas Houston Baptist University – Bachelor of Arts, Government and History 2012 Houston, Texas Licenses State Bar of Texas 2015 - Present Admitted to Practice in all state courts and Southern District of Texas Memberships Texas State Bar Association Houston Bar Association Young Lawyers Committee - Bankruptcy Section of Texas State Bar. FAST RIGHT 000004 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. Darcy Horne on behalf of KARALYNN CROMEENS Bar No. 24045726 paralegal2@thecromeenslawfirm.com Envelope ID: 61736170 Status as of 2/15/2022 7:37 AM CST Associated Case Party: Lisa Leslie Name BarNumber Email TimestampSubmitted Status Jake Leggett 24117219 jleggett@rdclements.com 2/14/2022 4:57:55 PM SENT Associated Case Party: EdwinAllenWheatley Name BarNumber Email TimestampSubmitted Status Ieshia Dunmore IDunmore@TheCromeensLawFirm.com 2/14/2022 4:57:55 PM SENT Oriana Torin paralegal@thecromeenslawfirm.com 2/14/2022 4:57:55 PM SENT Darcy Horne paralegal2@thecromeenslawfirm.com 2/14/2022 4:57:55 PM SENT Terry Gomez TGomez@TheCromeensLawFirm.com 2/14/2022 4:57:55 PM SENT Karalynn Cromeens karalynn@thecromeenslawfirm.com 2/14/2022 4:57:55 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Chris Lay Chris@rdclements.com 2/14/2022 4:57:55 PM SENT Mark S.Byrne mbyrne@rdclements.com 2/14/2022 4:57:55 PM SENT Rosa ElenaSagredo rosa@rdclements.com 2/14/2022 4:57:55 PM SENT