On July 09, 2018 a
Trial Materials
was filed
involving a dispute between
Merwin, Betty,
Merwin, Lee,
Rushing, Janice,
Rushing, Lige, Jr,
and
Merwin, Betty,
Merwin, Lee,
Rushing, Janice,
Rushing, Lige, Jr.,
for PROPERTY
in the District Court of Dallas County.
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FILED
9/21/2020 4:18 PM
FELICIA PITRE
DISTRICT CLERK
CO., TEXAS
DALLAS
Dorothy Strogen DEPUTY
CAUSE NO. DC'18'08876
LEE MERWIN AND BETTY § IN THE DISTRICT COURT
MERWIN §
§
Plaintiffs, §
§
vs. § 192nd JUDICIAL DISTRICT
§
JANICE RUSHING AND LIGE §
RUSHING JR. §
§
Defendants. § DALLAS COUNTY, TEXAS
§
PLAINTIFFS’ AMENDED TRIAL WITNESS LIST
Plaintiffs, Lee and Betty Merwin (“Merwins” 0r “Plaintiffs”), file this Amended
Trial Witness List in the above-entitled cause. Plaintiffs hereby give notice that they
may present Witness testimony in the form 0f live examination, affidavits, 0r
interrogatory.
Plaintiffs expect t0 present testimony from the following witnessesi
1. Lige Rushing Jr. is expected t0 testify as t0 Defendants’ use and upkeep
0f the Rushings’ Property, and interactions with the Merwins.
2. Janice Rushing is expected t0 testify as t0 Defendants’ use and upkeep
0f the Rushings’ Property, and interactions With the Merwins.
3. Lee Merwin is expected to testify as t0 the various fences that have
separated the Merwin Property and the Rushing Property, his upkeep
0f both the Merwin Property and the Rushing Property, and his
interactions With the Bushings.
AMENDED TRIAL WITNESS LIST PAGE 1
1643982V1 - M1673.00002 200921 Amended Witness List
4. Alex Campbell is expected t0 testify only as t0 the pictures and
measurements that took place at the court'ordered inspection 0f the
Rushing Property 0n February 19, 2020.
Plaintiffs reserve the right to supplement or amend their list of witnesses and
t0 remove Witnesses 0r add witnesses if additional information is discovered.
Plaintiffs reserve the right to call unlisted rebuttal witnesses, the identity 0f
whom cannot be reasonably anticipated at this time.
Plaintiffs reserve the right t0 call any Witnesses listed in any other party’s
Witness List.
Respectfully Submitted,
Underwood Perkins, P.C.
Byi/s/Darrell D. Mn ter
Darrell D. Minter
State Bar N0. 14189400
Alex M. Campbell
State Bar N0. 24095536
Two Lincoln Centre
5420 LBJ Freeway, Suite 1900
Dallas, Texas 75240
Telephone2<972> 661-5114
Facsimile:(972) 661-5691
Emaili dminter@up1awtx.com
acampbell@up1awtx.com
A TTORNEYS FOR PLAINTIFFS
AMENDED TRIAL WITNESS LIST PAGE 2
1643982V1 — M1673.00002 200921 Amended Witness List
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of the above and
foregoing document was served upon all counsel 0f record pursuant to the Texas Rules
0f Civil Procedure 0n September 21, 2020, as followsi
Robert K. Frisch
Attorney at Law
15150 Preston Road, Suite 240
Dallas, Texas 75248
rkfrischlaw@msn.com
Attorney for Defendants
ls/Darrel] D. Mn teI'
Darrell D. Minter
AMENDED TRIAL WITNESS LIST PAGE 3
1643982V1 — M1673.00002 200921 Amended Witness List
Document Filed Date
September 21, 2020
Case Filing Date
July 09, 2018
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FILED 9/21/2020 4:18 PM FELICIA PITRE DISTRICT CLERK CO., TEXAS DALLAS Dorothy Strogen DEPUTY CAUSE NO. DC'18'08876 LEE MERWIN AND BETTY § IN THE DISTRICT COURT MERWIN § § Plaintiffs, § § vs. § 192nd JUDICIAL DISTRICT § JANICE RUSHING AND LIGE § RUSHING JR. § § Defendants. § DALLAS COUNTY, TEXAS § PLAINTIFFS’ AMENDED TRIAL WITNESS LIST Plaintiffs, Lee and Betty Merwin (“Merwins” 0r “Plaintiffs”), file this Amended Trial Witness List in the above-entitled cause. Plaintiffs hereby give notice that they may present Witness testimony in the form 0f live examination, affidavits, 0r interrogatory. Plaintiffs expect t0 present testimony from the following witnessesi 1. Lige Rushing Jr. is expected t0 testify as t0 Defendants’ use and upkeep 0f the Rushings’ Property, and interactions with the Merwins. 2. Janice Rushing is expected t0 testify as t0 Defendants’ use and upkeep 0f the Rushings’ Property, and interactions With the Merwins. 3. Lee Merwin is expected to testify as t0 the various fences that have separated the Merwin Property and the Rushing Property, his upkeep 0f both the Merwin Property and the Rushing Property, and his interactions With the Bushings. AMENDED TRIAL WITNESS LIST PAGE 1 1643982V1 - M1673.00002 200921 Amended Witness List 4. Alex Campbell is expected t0 testify only as t0 the pictures and measurements that took place at the court'ordered inspection 0f the Rushing Property 0n February 19, 2020. Plaintiffs reserve the right to supplement or amend their list of witnesses and t0 remove Witnesses 0r add witnesses if additional information is discovered. Plaintiffs reserve the right to call unlisted rebuttal witnesses, the identity 0f whom cannot be reasonably anticipated at this time. Plaintiffs reserve the right t0 call any Witnesses listed in any other party’s Witness List. Respectfully Submitted, Underwood Perkins, P.C. Byi/s/Darrell D. Mn ter Darrell D. Minter State Bar N0. 14189400 Alex M. Campbell State Bar N0. 24095536 Two Lincoln Centre 5420 LBJ Freeway, Suite 1900 Dallas, Texas 75240 Telephone2<972> 661-5114 Facsimile:(972) 661-5691 Emaili dminter@up1awtx.com acampbell@up1awtx.com A TTORNEYS FOR PLAINTIFFS AMENDED TRIAL WITNESS LIST PAGE 2 1643982V1 — M1673.00002 200921 Amended Witness List CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of the above and foregoing document was served upon all counsel 0f record pursuant to the Texas Rules 0f Civil Procedure 0n September 21, 2020, as followsi Robert K. Frisch Attorney at Law 15150 Preston Road, Suite 240 Dallas, Texas 75248 rkfrischlaw@msn.com Attorney for Defendants ls/Darrel] D. Mn teI' Darrell D. Minter AMENDED TRIAL WITNESS LIST PAGE 3 1643982V1 — M1673.00002 200921 Amended Witness List