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FILED
8/24/2022 9:02 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Debra Clark DEPUTY
l
SLOAN FIRME
Sloan, Hatchcr, Perry, Range,
Robertson & Smith
WWI mum III VIII! MI!!!“ la ['5
August 22, 2022
VIA EMAIL:
rramirez@thebassettfinn.com
Richard Ramirez
The Bassett Firm
3838 Oak Lawn Ave, Suite 1300
Dallas, TX 75219
Horton r. Alv a a be One
Cause No. DC-19-20410; Antho
.
Re: Texas
[n the 191‘31 Judicial District Court, Dallas County,
Dear Mr. Ramirez:
the depositions on written questions-
Please allow this letter to serve as an agreement regarding
Defendants’ counsel previously served on State
Farm Insurance Company, on August 1, 2022, that will
nced matter pertaining to Plaintiff Anthony Horto
n.
be obtained in connection with the above refere
amend Defendants’ depositions on written
We agree that Defendants’ counsel will immediately
to ce, in every instance, the following language:
questions and any accompanying subpoenas repla
ds to the insurance and claim file of Anthony
“any and all documents and recor pertaining
all payments, policy information, listing of providers,
Horton, including, but not limited to, to
declaration of coverage, color photographs pertaining
correspondence, all log notes, date
with SS# XXX-XX-8283 claimtt 1823H370Q,
Anthony Horton, DOB: April 27, 1994,
of loss: 08/12/2021”
with the following language:
and medical
“all color photographs, recorded statements, property damage estimates,
date of loss: 08/12/2021, pertaining to
records from the file for claimtl 1823H370Q,
with SS# XXX-XX-8283”
Anthony Horton, DOB: April 27, 1994,
the Plaintiff,
Further, we agree that when Defen
dants’ records service obtains records pertaining to
the records have been
the above refere nce DWQ , the following agreement will be in place: Once
per to Plaintiff:
record service will send the records directly
received by Defendants’ record service, the matter.
counsel at his office, so that he may revie
w them for possible privileges or other objectionable
issues
Defendants’ counsel any of the records until any
Defendants’ record service shall not provide
been completely resolved.
resulting from the review have
Principal Office 101 East Whalcy
|
Street | IMMTexas 75601
Phone 903.757.7000 Facsimile 903.757.7574
|
.
www.sloanflrrn.com
Longview Houston I Santa Fe] Albuquerque
|
ROBERTSON & SMITH
SLOAN, HATCHER, PERRY, RUNGE,
August 22, 2022
Page 2
or
1) Upon receipt of the records,
Plaintiff’s counsel will forward any photographs (color otherwise),
and property damage estim ates withi n 5 days of
written statements, recorded statements, Plaintiffs counsel
ds be received within 5 days of our current trial setting,
receipt. Should the recor e the first day of trial.
will forward them within 2 days, but in any event befor ents
ds that are produced and with regard to any docum
2) With regard to any medical recor will have
the agreed upon scope of our DWQ, Plaintiff‘s couns
el
incidentally produced outside rs, begin ning the
or other objectionable matte
five (5) days to review those records for privileges
those records from the record servic e.
day Plaintiff’s counsel receives the
the records to Defendanls’ counsel one day following
3) The record service may release the withheld records
conclusion of this five (5) day review period unles objections identifying
s
and reasons for withholding the same are made
within the five (5) day review period.
date Plaintiff’s counsel receives the records, ifPlaintiff
’s counsel does
4) Within five (5) days of the
the records, Plaintiff's counsel will provide
have objections to the contents of some or all
Defendants’ counsel with a privilege log setting out
Plaintiff‘s objections.
and documents incidentally produced outside the agreed upon scope
5) Should any medical records n 5 days of our current trial setting.
of Defendants’ DWQ be received by Plaintiff’s counsel withi
of the medical records and incidentally produced
within 2 days Plaintiff's counsel will produce any
to. With regard to any medical records and
records which Plaintiff's counsel does not object counsel will
which Plaintiff‘s counsel does object to, Plaintifi’s
incidentally produced records within 2 days.
el with a privilege log setting out Plaintiff's objections
provide Defendants’ couns records which Plaintiff's counsel does
In any event, the medical records and incidentally produced
not object will be produced before the first day
of trial. Further, as to those medical and incidentally
el will provide
produced records to
which Plaintiff‘s counsel does object, Plaintiff's couns
out Plaintiff's objections befor e the first day of
Defendants’ counsel with a privilege log setting
trial.
to Rule 11 of the Texas Rules
If this accurately reflects our agreement, please sign below pursuant matter
wish to discuss this further, please do not
of Civil Procedure and return the copy to me. If you
hesitate to contact me.
Yours truly
an, PERRY, RUNGE, ROBERTSON &
SMITH
NR
ég iro 2' ['7W i‘ n
{W. . 5..
E .'
RICHAmMIR EZ
_
éfiw K. by”
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.
Donna Rountree on behalf of Carson Runge
Bar No. 24059262
drountree@sloanfirm.com
Envelope ID: 67597652
Status as of 8/24/2022 10:31 AM CST
Associated Case Party: ANTHONY HORTON
Name BarNumber Email TimestampSubmitted Status
Carson R.Runge crunge@sloanfirm.com 8/24/2022 9:02:03 AM SENT
Donna Rountree drountree@sloanfirm.com 8/24/2022 9:02:03 AM SENT
Savannah Judkins sjudkins@sloanfirm.com 8/24/2022 9:02:03 AM 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.
Donna Rountree on behalf of Carson Runge
Bar No. 24059262
drountree@sloanfirm.com
Envelope ID: 67597652
Status as of 8/24/2022 10:31 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
The BassettFirm efile@thebassettfirm.com 8/24/2022 9:02:03 AM SENT
The Bassett Firm eservice@thebassettfirm.com 8/24/2022 9:02:03 AM 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.
Donna Rountree on behalf of Carson Runge
Bar No. 24059262
drountree@sloanfirm.com
Envelope ID: 67597652
Status as of 8/24/2022 10:31 AM CST
Associated Case Party: MARQUISKBROWN
Name BarNumber Email TimestampSubmitted Status
Jennifer Horrell jhorrell@ekvallbyrne.com 8/24/2022 9:02:03 AM SENT
Gerry Xagoraris gxagoraris@ekvallbyrne.com 8/24/2022 9:02:03 AM SENT
Catina Lorenzo clorenzo@ekvallbyrne.com 8/24/2022 9:02:03 AM SENT
Preview
FILED 8/24/2022 9:02 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Debra Clark DEPUTY l SLOAN FIRME Sloan, Hatchcr, Perry, Range, Robertson & Smith WWI mum III VIII! MI!!!“ la ['5 August 22, 2022 VIA EMAIL: rramirez@thebassettfinn.com Richard Ramirez The Bassett Firm 3838 Oak Lawn Ave, Suite 1300 Dallas, TX 75219 Horton r. Alv a a be One Cause No. DC-19-20410; Antho . Re: Texas [n the 191‘31 Judicial District Court, Dallas County, Dear Mr. Ramirez: the depositions on written questions- Please allow this letter to serve as an agreement regarding Defendants’ counsel previously served on State Farm Insurance Company, on August 1, 2022, that will nced matter pertaining to Plaintiff Anthony Horto n. be obtained in connection with the above refere amend Defendants’ depositions on written We agree that Defendants’ counsel will immediately to ce, in every instance, the following language: questions and any accompanying subpoenas repla ds to the insurance and claim file of Anthony “any and all documents and recor pertaining all payments, policy information, listing of providers, Horton, including, but not limited to, to declaration of coverage, color photographs pertaining correspondence, all log notes, date with SS# XXX-XX-8283 claimtt 1823H370Q, Anthony Horton, DOB: April 27, 1994, of loss: 08/12/2021” with the following language: and medical “all color photographs, recorded statements, property damage estimates, date of loss: 08/12/2021, pertaining to records from the file for claimtl 1823H370Q, with SS# XXX-XX-8283” Anthony Horton, DOB: April 27, 1994, the Plaintiff, Further, we agree that when Defen dants’ records service obtains records pertaining to the records have been the above refere nce DWQ , the following agreement will be in place: Once per to Plaintiff: record service will send the records directly received by Defendants’ record service, the matter. counsel at his office, so that he may revie w them for possible privileges or other objectionable issues Defendants’ counsel any of the records until any Defendants’ record service shall not provide been completely resolved. resulting from the review have Principal Office 101 East Whalcy | Street | IMMTexas 75601 Phone 903.757.7000 Facsimile 903.757.7574 | . www.sloanflrrn.com Longview Houston I Santa Fe] Albuquerque | ROBERTSON & SMITH SLOAN, HATCHER, PERRY, RUNGE, August 22, 2022 Page 2 or 1) Upon receipt of the records, Plaintiff’s counsel will forward any photographs (color otherwise), and property damage estim ates withi n 5 days of written statements, recorded statements, Plaintiffs counsel ds be received within 5 days of our current trial setting, receipt. Should the recor e the first day of trial. will forward them within 2 days, but in any event befor ents ds that are produced and with regard to any docum 2) With regard to any medical recor will have the agreed upon scope of our DWQ, Plaintiff‘s couns el incidentally produced outside rs, begin ning the or other objectionable matte five (5) days to review those records for privileges those records from the record servic e. day Plaintiff’s counsel receives the the records to Defendanls’ counsel one day following 3) The record service may release the withheld records conclusion of this five (5) day review period unles objections identifying s and reasons for withholding the same are made within the five (5) day review period. date Plaintiff’s counsel receives the records, ifPlaintiff ’s counsel does 4) Within five (5) days of the the records, Plaintiff's counsel will provide have objections to the contents of some or all Defendants’ counsel with a privilege log setting out Plaintiff‘s objections. and documents incidentally produced outside the agreed upon scope 5) Should any medical records n 5 days of our current trial setting. of Defendants’ DWQ be received by Plaintiff’s counsel withi of the medical records and incidentally produced within 2 days Plaintiff's counsel will produce any to. With regard to any medical records and records which Plaintiff's counsel does not object counsel will which Plaintiff‘s counsel does object to, Plaintifi’s incidentally produced records within 2 days. el with a privilege log setting out Plaintiff's objections provide Defendants’ couns records which Plaintiff's counsel does In any event, the medical records and incidentally produced not object will be produced before the first day of trial. Further, as to those medical and incidentally el will provide produced records to which Plaintiff‘s counsel does object, Plaintiff's couns out Plaintiff's objections befor e the first day of Defendants’ counsel with a privilege log setting trial. to Rule 11 of the Texas Rules If this accurately reflects our agreement, please sign below pursuant matter wish to discuss this further, please do not of Civil Procedure and return the copy to me. If you hesitate to contact me. Yours truly an, PERRY, RUNGE, ROBERTSON & SMITH NR ég iro 2' ['7W i‘ n {W. . 5.. E .' RICHAmMIR EZ _ éfiw K. by” 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. Donna Rountree on behalf of Carson Runge Bar No. 24059262 drountree@sloanfirm.com Envelope ID: 67597652 Status as of 8/24/2022 10:31 AM CST Associated Case Party: ANTHONY HORTON Name BarNumber Email TimestampSubmitted Status Carson R.Runge crunge@sloanfirm.com 8/24/2022 9:02:03 AM SENT Donna Rountree drountree@sloanfirm.com 8/24/2022 9:02:03 AM SENT Savannah Judkins sjudkins@sloanfirm.com 8/24/2022 9:02:03 AM 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. Donna Rountree on behalf of Carson Runge Bar No. 24059262 drountree@sloanfirm.com Envelope ID: 67597652 Status as of 8/24/2022 10:31 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status The BassettFirm efile@thebassettfirm.com 8/24/2022 9:02:03 AM SENT The Bassett Firm eservice@thebassettfirm.com 8/24/2022 9:02:03 AM 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. Donna Rountree on behalf of Carson Runge Bar No. 24059262 drountree@sloanfirm.com Envelope ID: 67597652 Status as of 8/24/2022 10:31 AM CST Associated Case Party: MARQUISKBROWN Name BarNumber Email TimestampSubmitted Status Jennifer Horrell jhorrell@ekvallbyrne.com 8/24/2022 9:02:03 AM SENT Gerry Xagoraris gxagoraris@ekvallbyrne.com 8/24/2022 9:02:03 AM SENT Catina Lorenzo clorenzo@ekvallbyrne.com 8/24/2022 9:02:03 AM SENT