Preview
FILED
12/28/2021 12:00 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Rhonda Burks DEPUTY
CAUSE NO. DC-19-10926
VASHONE RHODES § IN TI-IE DISTRICT COURT
§
V. § 160TH JUDICIAL DISTRICT
§
JAMES GOMEZ and EXCLUSIVE §
NATIONWIDE DELIVERY, INC. § DALLAS COUNTY, TEXAS
DEFENDANT’S OBJECTIONS TO PLAINTIFF’S CROSS-NOTICE OF INTENTION
TO TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D., BY REMOTE
ELECTRONIC MEANS AND REQUEST FOR PRODUCTION OF DOCUMENTS,
AND MOTION FOR PROTECTION
TO TI-IE HONORABLE COURT:
COMES NOW, Defendant and [notwithstanding the previously-filed Suggestion of
Death] files this his Objections to Plaintiff‘s Cross-Notice Of Intention To Take Oral Deposition
Of Rawson L. Wood, M.D. By Remote Electronic Means And Request For Production Of
Documents and Motion for Protection pursuant to Rules 176, 192 and 199, and in support would
show:
1. Attached as Exhibit A is the Notice made the basis of the Motion for Protection
and is incorporated herein.
2. Defendant is not seeking a hearing at this time on the motion, and Dr. Wood will
appear at the noticed deposition in good faith.
SPECIFIC OBJECTIONS
4. Objection is made to Request for Production No. 4 as this request requires the
reproduction and distribution of copy right materials without the express consent of the owner of
said copy right materials, which is an act of copy right infringement under Title 17, US Code.
DEFENDANT ’S OBJECTIONS TO PLAINTIFF’S CROSS-NOTICE OF INTENTION TO
TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D., BY REMOTE ELECTRONIC
MEANS AND REQUEST FOR PRODUCTION OF DOCUMENTS, AND MOTION
FOR PROTECTION PAGE 1
10001.14942/mhugh1ey
5. Objection is made to Request for Production No. 5 as this request requires the
reproduction and distribution of copy right materials Without the express consent of the owner of
said copy right materials, which is an act of copy right infringement under Title l7, US Code.
6. Objection is made to Request for Production No. 6 as this request is overly broad,
vague, unduly burdensome, and not appropriately limited in time, scope, or subject matter.
Defendant objects to this request for the reason that it attempts to force Defendant to “marsha ”
evidence. Further, please see documents produced.
7. Objection is made to Request for Production No. 7 as this request is overly broad,
vague, unduly burdensome, and not appropriately limited in time, scope, or subject matter.
Defendant objects to this request for the reason that it attempts to force Defendant to “marshal”
evidence. Further, please see documents produced.
8. Objection is made to Request for Production No. 8 as this request is overly broad,
vague, unduly burdensome, and not appropriately limited in time, scope, or subject matter.
Defendant objects to this request for the reason that it attempts to force Defendant to “marshal”
evidence. Further, please see documents produced.
9. Objection is made to Request for Production No. 9 as this request is overly broad,
vague, unduly burdensome, and not appropriately limited in time, scope, or subject matter.
Defendant objects to this request for the reason that it attempts to force Defendant to “marshal”
evidence. Further, please see documents produced.
11. Objection is made to Request for Production No. 11 as this request requires the
reproduction and distribution of copy right materials Without the express consent of the owner of
said copy right materials, which is an act of copy right infringement under Title 17, US Code.
DEFENDANT ’S OBJECTIONS TO PLAINTIFF’S CROSS-NOTICE OF INTENTION T0
TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D., BY REMOTE ELECTRONIC
MEANS AND REQUEST FOR PRODUCTION 0F DOCUNIENTS, AND MOTION
FOR PROTECTION PAGE 2
10001.14942/mhugh1ey
12. Objection is made to Request for Production No. 12 as this request is overly broad,
vague, unduly burdensome, and not appropriately limited in time, scope, or subject matter. Subject
to and without waiving the foregoing objection, please see documents produced.
Respectfully submitted,
THE LECRONE LAW FIRM, PC
Wall Street Plaza
123 North Crockett Street, Suite 200
Sherman, TX 75090
TEL: 903.813.1900
FAX: 903.813.1944
By: [9/ Jolin ’W. fireeze
JOHN W. BREEZE
State Bar No. 00796248
RHONDA D. HOLCOMB
State Bar No. 24099024
HILLARY LUCKETT CLARK
State Bar No. 24077714
BLAISE S. WILCOTT
STATE BAR N0. 24086481
MARK A. TEAGUE
State Bar No. 24003039
ALEXANDRIA K. CARPENTER
State Bar No. 24101596
SELENE DOMINGUEZ PENA
State Bar No. 24106929
MOLLY J. KAELIN
State Bar No. 24122949
E SERVICE @LECRONE LAW.COM
ATTORNEYS FOR DEFENDANT
DEFENDANT ’S OBJECTIONS TO PLAINTIFF’S CROSS-NOTICE OF INTENTION TO
TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D., BY REMOTE ELECTRONIC
MEANS AND REQUEST FOR PRODUCTION 0F DOCUMENTS, AND MOTION
FOR PROTECTION PAGE 3
10001.14942/mhugh1ey
CERTIFICATE OF SERVICE
This is to certify that on the 27th day of December 2021, the foregoing instrument was
forwarded to the following counsel of record:
Ms. V. Paige Eldridge Mr. Randall G. Walters SBN: 20819480
Ms. Amy K. Witherite Ms. Nadine K. Weatherall — handling atty
WITHERITE LAw GROUP, PLLC WALTERS, BALIDO & CRAIN L.L.P
10440 N. Central Expressway, Ste. 400 Meadowpark Tower, Suite 1500
10440 North Central Expressway
Dallas, TX 75231-2228
Dallas, TX 75231
/s/ Jofln ‘W. fireeze
John W. Breeze
DEFENDANT ’S OBJECTIONS TO PLAINTIFF’S CROSS-NOTICE OF INTENTION TO
TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D., BY REMOTE ELECTRONIC
MEANS AND REQUEST FOR PRODUCTION 0F DOCUMENTS, AND MOTION
FOR PROTECTION PAGE 4
10001.14942/mhugh1ey
EXHIBIT A
CAUSE NO. DC-19-10926
VASHONE RHODES; THE DISTRICT COURT OF
§§§§§§§§
IN
Plaintiff,
VS. DALLAS COUNTY, TEXAS
JAMES GOMEZ; AND EXCLUSIVE
NATIONWIDE DELIVERY, INC.;
§§
Defendants. 1607” JUDICIAL DISTRICT
PLAINTIFF'S CROSS-NOTICE OF INTENTION TO TAKE ORAL DEPOSITION
OF RAWSON L. WOOD, M.D. BY REMOTE ELECTRONIC MEANS AND
REQUEST FOR PRODUCTION OF DOCUMENTS
TO: Defendant, James Gomez, by and through his attorney of record, Mr.
Adam B. LeCrone, The LeCrone Law Firm, P.C., Wall Street Plaza, 123 N.
Crockett Street, Suite 200, Sherman, TX 75090; and
Defendant, Exclusive Nationwide Delivery |nc., by and through their
attorney of record, Ms. Nadine Weatherall, Walters Balido & Crain, 10440
North Central Expressway, Suite 1500, Dallas, TX 75231.
Please take notice that Plaintiff will take the oral deposition of the
deponent identified below by remote electronic means on the date and at the
time and place specified pursuant to the Texas Rules of Civil Procedure:
Deponent: Rawson L. Wood, M.D.
Date: December 30, 2021
Time: 10:00 a.m.
Location: Via Zoom
PLAINTIFF'S CROSS-NOTICE 0F INTENTION T0 TAKE ORAL DEPOSITION OF RAWSON L.
WOOD, M.D. BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION OF
DOCUMENTS - Page 1
The deposition will be reported and may be videotaped before an officer
authorized by law to take such depositions. The oath will be administered to
Rawson L. Wood, M.D. by the court reporter via videoconferencing. The
deponent is requested to email the documents requested in Exhibit "A" attached
hereto and incorporated herein by reference to paiqe.eldridqe(a)witheritelaw.com
prior to the deposition. Deponent will be at one location, court reporter will be at
another location, and counsel will be at different locations. The oral examination
will continue day-to-day until completed. You are invited to be present at such
time and cross-examine the witness.
Respectfully submitted,
WITHERITE LAW GROUP, PLLC.
By: /s/ V. Paige Eldridge
V. PAIGE ELDRIDGE
State Bar No. 24096747
paiqe.eldridqe©witheritelaw.com
SHELLY GRECO
State Bar No. 24008168
shellv.qreco@witheritelaw.com
10440 N. Central Expressway
Suite 400
Dallas, TX 75231-2228
(214) 378-6665
(214) 378-6670 (fax)
ATTORNEYS FOR PLAINTIFF
PLAINTIFF'S CROSS-NOTICE OF INTENTION TO TAKE ORAL DEPOSITION OF RAWSON L.
WOOD, M.D. BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION OF
DOCUMENTS - Page 2
c_ERTIFICAT§ 0F SERVICE
|
hereby certify that a true and correct copy of the foregoing has been
forwarded to all counsel of record on this 30th day of November, 2021 pursuant to
the Texas Rules of Civil Procedure.
/s/ V. Paige Eldridge
V. Paige Eldridge
Adam B. LeCrone
adam@lecronelaw.com
The LeCrone Law Firm, P.C.
Wall Street Plaza
123 N. Crockett Street, Suite 200
Sherman, TX 75090
Attorney for Defendant James Gomez
Randall G. Walters
randy.walters@wbclawfirm.com
Nadine Weatherall
nadine.weatheralI@wbclawfirm.com
Walters, Balido & Crain, LLP
Meadow Park Tower, 15th Floor
10440 North Central Expressway
Dallas, TX 75231
Attorney for Defendant Exclusive Nationwide Delivery Inc.
PLAINTIFF'S CROSS-NOTICE OF INTENTION TO TAKE ORAL DEPOSITION OF RAWSON L.
WOOD, M.D. BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION OF
DOCUMENTS - Page 3
EXHIBIT "A"
Documents to be produced by email to paige.eldridge@witheritelaw.com:
1. Your entire file in this case, including but not limited to:
a. All documents, correspondence, and other tangible things received
by you from Defendants and/or their attorneys;
b. All e-mails between you and the Defendants and/or their attorneys;
c. All notes that discuss, refer, or relate to any oral or written
communication between you and Defendants and/or their
attorneys;
d. All billing records reflecting your time spent in this case and billing
for or receipt of money for your time spent in this case(including a
copy of any form of payment for your services in this case that has
been made to date);
e. Your final report in this case and all drafts of that report;
f. Any and all notes or documentation created by you in relation to
this matter.
2. All documents reviewed by you in preparation of your report and which
allow you to offer opinions in this case.
3. Your current curriculum vitae or resume.
4. Any and all literature you reviewed and relied upon in connection with this
matter.
5. Any and all literature you contend supports any of your opinions or
conclusions in this matter.
6. Documents concerning each deposition you have given in the past. Note:
this request is not for all documents concerning each deposition given in
the past. Instead, it is for some document(s) that identifies each
deposition you have given in the past.
7. Documents concerning each time you have testified at trial in the past.
Note: this request is not for all documents concerning each trial at which
PLAINTIFF'S CROSS-NOTICE OF INTENTION TO TAKE ORAL DEPOSITION OF RAWSON L.
WOOD, M.D. BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION OF
DOCUMENTS - Page 4
you have testified in the past. Instead, it is for some document(s) that
identifies each trial in which you have given testimony in the past.
8. Documents concerning each case you have been retained to review in the
past. Note: this request is not for all documents concerning each case
you have reviewed in the past. Instead, it is for some document(s) that
identifies each case you have reviewed in the past.
9. Any and all correspondence, literature, notes, letters, brochures, and/or
documents received or sent by you discussing, setting forth, or regarding
your willingness or agreement to act as a consultant on legal matters.
10.All documents and/or tangible things you reviewed to refresh your
recollection prior to your deposition.
11.A copy of all articles, textbook chapters, pamphlets, continuing education
materials or other documents you have authored or contributed to related
to the topics on which you will testify in this case.
12.Copies of all deposition or trial testimony you have given related to the
topics on which you will testify in this case.
PLAINTIFF'S CROSS-NOTICE OF INTENTION TO TAKE ORAL DEPOSITION OF RAWSON L.
WOOD, M.D. BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION OF
DOCUMENTS - 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.
Monica Hughley on behalf of John Breeze
Bar No. 00796248
monica@lecronelaw.com
Envelope ID: 60318985
Status as of 12/28/2021 9:13 AM CST
Associated Case Party: VASHONE RHODES
Name BarNumber Email TimestampSubmitted Status
Amy Witherite 788698 amy.witherite@witheritelaw.com 12/27/2021 4:38:56 PM SENT
Paige Eldridge paige.eldridge@ewlawyers.com 12/27/2021 4:38:56 PM SENT
Associated Case Party: JAMES GOMEZ
Name BarNumber Email TimestampSubmitted Status
Adam LeCrone eservice@lecronelaw.com 12/27/2021 4:38:56 PM SENT
Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC
Name BarNumber Email TimestampSubmitted Status
Randall GWalters waltersedocsnotifications@wbclawfirm.com 12/27/2021 4:38:56 PM SENT
Nadine K Weatherall nadine.weatherall@wbclawfirm.com 12/27/2021 4:38:56 PM SENT
Randall GWalters randy.walters@wbclawfirm.com 12/27/2021 4:38:56 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
V. Paige Eldridge paige.eldridge@witheritelaw.com 12/27/2021 4:38:56 PM SENT
PAIGE VELDRIDGE paiqe.eldridqe@ewlawyers.com 12/27/2021 4:38:56 PM ERROR
Craig Laird PCL@LA|RD.LAWYER 12/27/2021 4:38:56 PM SENT
Preview
FILED 12/28/2021 12:00 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Rhonda Burks DEPUTY CAUSE NO. DC-19-10926 VASHONE RHODES § IN TI-IE DISTRICT COURT § V. § 160TH JUDICIAL DISTRICT § JAMES GOMEZ and EXCLUSIVE § NATIONWIDE DELIVERY, INC. § DALLAS COUNTY, TEXAS DEFENDANT’S OBJECTIONS TO PLAINTIFF’S CROSS-NOTICE OF INTENTION TO TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D., BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION OF DOCUMENTS, AND MOTION FOR PROTECTION TO TI-IE HONORABLE COURT: COMES NOW, Defendant and [notwithstanding the previously-filed Suggestion of Death] files this his Objections to Plaintiff‘s Cross-Notice Of Intention To Take Oral Deposition Of Rawson L. Wood, M.D. By Remote Electronic Means And Request For Production Of Documents and Motion for Protection pursuant to Rules 176, 192 and 199, and in support would show: 1. Attached as Exhibit A is the Notice made the basis of the Motion for Protection and is incorporated herein. 2. Defendant is not seeking a hearing at this time on the motion, and Dr. Wood will appear at the noticed deposition in good faith. SPECIFIC OBJECTIONS 4. Objection is made to Request for Production No. 4 as this request requires the reproduction and distribution of copy right materials without the express consent of the owner of said copy right materials, which is an act of copy right infringement under Title 17, US Code. DEFENDANT ’S OBJECTIONS TO PLAINTIFF’S CROSS-NOTICE OF INTENTION TO TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D., BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION OF DOCUMENTS, AND MOTION FOR PROTECTION PAGE 1 10001.14942/mhugh1ey 5. Objection is made to Request for Production No. 5 as this request requires the reproduction and distribution of copy right materials Without the express consent of the owner of said copy right materials, which is an act of copy right infringement under Title l7, US Code. 6. Objection is made to Request for Production No. 6 as this request is overly broad, vague, unduly burdensome, and not appropriately limited in time, scope, or subject matter. Defendant objects to this request for the reason that it attempts to force Defendant to “marsha ” evidence. Further, please see documents produced. 7. Objection is made to Request for Production No. 7 as this request is overly broad, vague, unduly burdensome, and not appropriately limited in time, scope, or subject matter. Defendant objects to this request for the reason that it attempts to force Defendant to “marshal” evidence. Further, please see documents produced. 8. Objection is made to Request for Production No. 8 as this request is overly broad, vague, unduly burdensome, and not appropriately limited in time, scope, or subject matter. Defendant objects to this request for the reason that it attempts to force Defendant to “marshal” evidence. Further, please see documents produced. 9. Objection is made to Request for Production No. 9 as this request is overly broad, vague, unduly burdensome, and not appropriately limited in time, scope, or subject matter. Defendant objects to this request for the reason that it attempts to force Defendant to “marshal” evidence. Further, please see documents produced. 11. Objection is made to Request for Production No. 11 as this request requires the reproduction and distribution of copy right materials Without the express consent of the owner of said copy right materials, which is an act of copy right infringement under Title 17, US Code. DEFENDANT ’S OBJECTIONS TO PLAINTIFF’S CROSS-NOTICE OF INTENTION T0 TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D., BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION 0F DOCUNIENTS, AND MOTION FOR PROTECTION PAGE 2 10001.14942/mhugh1ey 12. Objection is made to Request for Production No. 12 as this request is overly broad, vague, unduly burdensome, and not appropriately limited in time, scope, or subject matter. Subject to and without waiving the foregoing objection, please see documents produced. Respectfully submitted, THE LECRONE LAW FIRM, PC Wall Street Plaza 123 North Crockett Street, Suite 200 Sherman, TX 75090 TEL: 903.813.1900 FAX: 903.813.1944 By: [9/ Jolin ’W. fireeze JOHN W. BREEZE State Bar No. 00796248 RHONDA D. HOLCOMB State Bar No. 24099024 HILLARY LUCKETT CLARK State Bar No. 24077714 BLAISE S. WILCOTT STATE BAR N0. 24086481 MARK A. TEAGUE State Bar No. 24003039 ALEXANDRIA K. CARPENTER State Bar No. 24101596 SELENE DOMINGUEZ PENA State Bar No. 24106929 MOLLY J. KAELIN State Bar No. 24122949 E SERVICE @LECRONE LAW.COM ATTORNEYS FOR DEFENDANT DEFENDANT ’S OBJECTIONS TO PLAINTIFF’S CROSS-NOTICE OF INTENTION TO TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D., BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION 0F DOCUMENTS, AND MOTION FOR PROTECTION PAGE 3 10001.14942/mhugh1ey CERTIFICATE OF SERVICE This is to certify that on the 27th day of December 2021, the foregoing instrument was forwarded to the following counsel of record: Ms. V. Paige Eldridge Mr. Randall G. Walters SBN: 20819480 Ms. Amy K. Witherite Ms. Nadine K. Weatherall — handling atty WITHERITE LAw GROUP, PLLC WALTERS, BALIDO & CRAIN L.L.P 10440 N. Central Expressway, Ste. 400 Meadowpark Tower, Suite 1500 10440 North Central Expressway Dallas, TX 75231-2228 Dallas, TX 75231 /s/ Jofln ‘W. fireeze John W. Breeze DEFENDANT ’S OBJECTIONS TO PLAINTIFF’S CROSS-NOTICE OF INTENTION TO TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D., BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION 0F DOCUMENTS, AND MOTION FOR PROTECTION PAGE 4 10001.14942/mhugh1ey EXHIBIT A CAUSE NO. DC-19-10926 VASHONE RHODES; THE DISTRICT COURT OF §§§§§§§§ IN Plaintiff, VS. DALLAS COUNTY, TEXAS JAMES GOMEZ; AND EXCLUSIVE NATIONWIDE DELIVERY, INC.; §§ Defendants. 1607” JUDICIAL DISTRICT PLAINTIFF'S CROSS-NOTICE OF INTENTION TO TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D. BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION OF DOCUMENTS TO: Defendant, James Gomez, by and through his attorney of record, Mr. Adam B. LeCrone, The LeCrone Law Firm, P.C., Wall Street Plaza, 123 N. Crockett Street, Suite 200, Sherman, TX 75090; and Defendant, Exclusive Nationwide Delivery |nc., by and through their attorney of record, Ms. Nadine Weatherall, Walters Balido & Crain, 10440 North Central Expressway, Suite 1500, Dallas, TX 75231. Please take notice that Plaintiff will take the oral deposition of the deponent identified below by remote electronic means on the date and at the time and place specified pursuant to the Texas Rules of Civil Procedure: Deponent: Rawson L. Wood, M.D. Date: December 30, 2021 Time: 10:00 a.m. Location: Via Zoom PLAINTIFF'S CROSS-NOTICE 0F INTENTION T0 TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D. BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION OF DOCUMENTS - Page 1 The deposition will be reported and may be videotaped before an officer authorized by law to take such depositions. The oath will be administered to Rawson L. Wood, M.D. by the court reporter via videoconferencing. The deponent is requested to email the documents requested in Exhibit "A" attached hereto and incorporated herein by reference to paiqe.eldridqe(a)witheritelaw.com prior to the deposition. Deponent will be at one location, court reporter will be at another location, and counsel will be at different locations. The oral examination will continue day-to-day until completed. You are invited to be present at such time and cross-examine the witness. Respectfully submitted, WITHERITE LAW GROUP, PLLC. By: /s/ V. Paige Eldridge V. PAIGE ELDRIDGE State Bar No. 24096747 paiqe.eldridqe©witheritelaw.com SHELLY GRECO State Bar No. 24008168 shellv.qreco@witheritelaw.com 10440 N. Central Expressway Suite 400 Dallas, TX 75231-2228 (214) 378-6665 (214) 378-6670 (fax) ATTORNEYS FOR PLAINTIFF PLAINTIFF'S CROSS-NOTICE OF INTENTION TO TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D. BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION OF DOCUMENTS - Page 2 c_ERTIFICAT§ 0F SERVICE | hereby certify that a true and correct copy of the foregoing has been forwarded to all counsel of record on this 30th day of November, 2021 pursuant to the Texas Rules of Civil Procedure. /s/ V. Paige Eldridge V. Paige Eldridge Adam B. LeCrone adam@lecronelaw.com The LeCrone Law Firm, P.C. Wall Street Plaza 123 N. Crockett Street, Suite 200 Sherman, TX 75090 Attorney for Defendant James Gomez Randall G. Walters randy.walters@wbclawfirm.com Nadine Weatherall nadine.weatheralI@wbclawfirm.com Walters, Balido & Crain, LLP Meadow Park Tower, 15th Floor 10440 North Central Expressway Dallas, TX 75231 Attorney for Defendant Exclusive Nationwide Delivery Inc. PLAINTIFF'S CROSS-NOTICE OF INTENTION TO TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D. BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION OF DOCUMENTS - Page 3 EXHIBIT "A" Documents to be produced by email to paige.eldridge@witheritelaw.com: 1. Your entire file in this case, including but not limited to: a. All documents, correspondence, and other tangible things received by you from Defendants and/or their attorneys; b. All e-mails between you and the Defendants and/or their attorneys; c. All notes that discuss, refer, or relate to any oral or written communication between you and Defendants and/or their attorneys; d. All billing records reflecting your time spent in this case and billing for or receipt of money for your time spent in this case(including a copy of any form of payment for your services in this case that has been made to date); e. Your final report in this case and all drafts of that report; f. Any and all notes or documentation created by you in relation to this matter. 2. All documents reviewed by you in preparation of your report and which allow you to offer opinions in this case. 3. Your current curriculum vitae or resume. 4. Any and all literature you reviewed and relied upon in connection with this matter. 5. Any and all literature you contend supports any of your opinions or conclusions in this matter. 6. Documents concerning each deposition you have given in the past. Note: this request is not for all documents concerning each deposition given in the past. Instead, it is for some document(s) that identifies each deposition you have given in the past. 7. Documents concerning each time you have testified at trial in the past. Note: this request is not for all documents concerning each trial at which PLAINTIFF'S CROSS-NOTICE OF INTENTION TO TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D. BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION OF DOCUMENTS - Page 4 you have testified in the past. Instead, it is for some document(s) that identifies each trial in which you have given testimony in the past. 8. Documents concerning each case you have been retained to review in the past. Note: this request is not for all documents concerning each case you have reviewed in the past. Instead, it is for some document(s) that identifies each case you have reviewed in the past. 9. Any and all correspondence, literature, notes, letters, brochures, and/or documents received or sent by you discussing, setting forth, or regarding your willingness or agreement to act as a consultant on legal matters. 10.All documents and/or tangible things you reviewed to refresh your recollection prior to your deposition. 11.A copy of all articles, textbook chapters, pamphlets, continuing education materials or other documents you have authored or contributed to related to the topics on which you will testify in this case. 12.Copies of all deposition or trial testimony you have given related to the topics on which you will testify in this case. PLAINTIFF'S CROSS-NOTICE OF INTENTION TO TAKE ORAL DEPOSITION OF RAWSON L. WOOD, M.D. BY REMOTE ELECTRONIC MEANS AND REQUEST FOR PRODUCTION OF DOCUMENTS - 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. Monica Hughley on behalf of John Breeze Bar No. 00796248 monica@lecronelaw.com Envelope ID: 60318985 Status as of 12/28/2021 9:13 AM CST Associated Case Party: VASHONE RHODES Name BarNumber Email TimestampSubmitted Status Amy Witherite 788698 amy.witherite@witheritelaw.com 12/27/2021 4:38:56 PM SENT Paige Eldridge paige.eldridge@ewlawyers.com 12/27/2021 4:38:56 PM SENT Associated Case Party: JAMES GOMEZ Name BarNumber Email TimestampSubmitted Status Adam LeCrone eservice@lecronelaw.com 12/27/2021 4:38:56 PM SENT Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC Name BarNumber Email TimestampSubmitted Status Randall GWalters waltersedocsnotifications@wbclawfirm.com 12/27/2021 4:38:56 PM SENT Nadine K Weatherall nadine.weatherall@wbclawfirm.com 12/27/2021 4:38:56 PM SENT Randall GWalters randy.walters@wbclawfirm.com 12/27/2021 4:38:56 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status V. Paige Eldridge paige.eldridge@witheritelaw.com 12/27/2021 4:38:56 PM SENT PAIGE VELDRIDGE paiqe.eldridqe@ewlawyers.com 12/27/2021 4:38:56 PM ERROR Craig Laird PCL@LA|RD.LAWYER 12/27/2021 4:38:56 PM SENT