Trial Materials: VASHONE RHODES vs. JAMES GOMEZ, et al

On August 02, 2019 a Trial Materials was filed involving a dispute between Rhodes, Vashone, and Exclusive Nationwide Delivery, Inc, Gomez, James, for MOTOR VEHICLE ACCIDENT in the District Court of Dallas County.

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FILED
9/27/2022 11:31 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Madison McCarrier DEPUTY

CAUSE NO. DC-19-10926
VASHONE RHODES IN THE DISTRICT COURT

§§§§§§
V. 160TH JUDICIAL DISTRICT
JAMES GOMEZ AND EXCLUSIVE
NATIONWIDE DELIVERY, INC. DALLAS COUNTY, TEXAS

DEFENDANT JAMES GOMEZ’ EXHIBIT LIST

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW, James Gomez, Defendant herein, and designates the following as exhibits

at the time of trial:

Dft. N0. Offer Grant/Denv Description of Exhibit

1. Exhibit Nos. 1 attached to oral deposition of Rawson
L. Wood, MD, MPH;

A11 photographs of vehicles/scene involved in the
accident;

Google Earth Maps of the accident scene;

All radiology records regarding Plaintiff from MRI
Centers of Texas obtained Via Deposition by Written
Questions;

All radiology records regarding Plaintiff from
Orthopedic & Spine Specialists of Texas obtained
Via Deposition by Written Questions;

All radiology records regarding Plaintiff from Prime
Diagnostic Imaging obtained Via Deposition by
Written Questions;

A11 TWC records regarding Plaintiff from Texas
Workforce Commission obtained Via Deposition by
Written Questions;

DEFENDANT’S EXHIBIT LIST - PAGE 1
10001 . 14942/troby
A11 employment and payroll records regarding
Plaintiff from Datamax, Inc., obtained Via
Deposition by Written Questions;

All employment and payroll records regarding
Plaintiff from UBEO obtained Via Deposition by
Written Questions;

10. A11 insurance records regarding Plaintiff from
GEICO Insurance Company — Claim
#0290332900101052; DOL 11.09.2017, obtained Via
Deposition by Written Questions;

11. A11 insurance records regarding Plaintiff from
GEICO Insurance Company — Claim
#0290332900101078; DOL 05.07.2018, obtained Via
Deposition by Written Questions;

12. All insurance records regarding Plaintiff from
Liberty Mutual Insurance Company — Claim
#035565138; DOL 05.19.2017, obtained Via
Deposition by Written Questions;

13. All insurance records regarding Plaintiff from
Repwest Insurance Company — Claim #
009276592017EXP1; DOL 1 1.09.2017, obtained via
Deposition by Written Questions;

14. Defendant Gomez’ Counter-Afﬁdavit of Roger
Clifford, DC, DACNB, Pursuant to Section 18.001
of the Texas Civil Practices & Remedies Code re:
Medical Billing Afﬁdavits regarding Plaintiff;

15. Defendant Gomez’ Counter-Afﬁdavit of Lennard A.
Nadalo, MD, FACR, Pursuant to Section 18.001 of
the Texas Civil Practices & Remedies Code re:
Medical Billing Aﬁidavits regarding Plaintiff;

16. Defendant Gomez’ Second Counter-Afﬁdavit of
Lennard A. Nadalo, MD, FACR, Pursuant to Section
18.001 of the Texas Civil Practices & Remedies
Code re: Medical Billing Affidavits regarding
Plaintiff;

17. Reread report of Lennard A. Nadalo, MD, FACR,
dated December 11, 2019, regarding Plaintiff;

DEFENDANT’S EXHIBIT LIST - PAGE 2
10001 . 14942/troby
18. Second Reread report of Lennard A. Nadalo, MD,
FACR, dated March 20, 2020, regarding Plaintiff;
19. Report of Defendant Gomez’ expert witness,
Rawson L. Wood, MD, MPH, dated June 3, 2021,
regarding Plaintiff;

20. A11 medical records regarding Plaintiff from ATI
Physical Therapy;

21. All medical records regarding Plaintiff from Dallas
Radiology;

22. All medical records regarding Plaintiff from Epic
Pain & Orthopedics;

23. All medical records regarding Plaintiff from MDN
Dallas/MDN PA;

24. All medical records regarding Plaintiff from MRI
Centers of Texas;

25. All medical records regarding Plaintiff from
Orthopedic & Spine Specialist of Texas, LLC;

26. All medical records regarding Plaintiff from Premier
Injury Clinics of DFW;

27. All medical records regarding Plaintiff from Prime
Diagnostic Imaging Partners d/b/a Prime Diagnostic
Imaging; and

28. All medical records regarding Plaintiff from Uptown
Radiology.

PLEASE TAKE FURTHER NOTICE that Defendant reserves the right to supplement

this exhibit list and to offer other rebuttal evidence and use demonstrative evidence and

demonstrative exhibits in addition to testimony by Witnesses listed in response to Request for

Disclosure and to call rebuttal witnesses allowed by the Court and the TEXAS RULES 0F CIVIL

PROCEDURE and the TEXAS RULES 0F EVIDENCE on the trial of the above cause. Defendant ﬁIrther

reserves the right to use any exhibits designated by Plaintiff and/or Co-Defendant.

DEFENDANT’S EXHIBIT LIST - PAGE 3
10001 . l4942/troby
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: /s/]oﬁn ’W. Qreeze
JOHN W. BREEZE
State Bar No. 00796248
RHONDA D. HOLCOMB
State Bar No. 24099024
MARK A. TEAGUE
State Bar No. 24003039
HILLARY LUCKETT CLARK
State Bar No. 24077714
ALEXANDRIA K. CARPENTER
State Bar No. 24101596
BLAISE S. WILCOTT
State Bar No. 24086481
SELENE DOMINGUEZ PENA
State Bar No. 24106929
MOLLY J. KAELIN
State Bar NO. 24122949
ESERVICE@LECRONELAW.COM

ATTORNEYS FOR DEFENDANT
JAMES GOMEZ

DEFENDANT’S EXHIBIT LIST - PAGE 4
10001 . 14942/troby
CERTIFICATE OF SERVICE
This is to certify that on the 27th day of September, 2022, the foregoing instrument was
forwarded to the following counsel of record:

Ms. V. Paige Eldridge
WITHERITE LAW GROUP, PLLC
10440 North Central Expressway, Suite 400
Dallas, Texas 75231-2228
TEL: 214.378.6665
FAX: 214.378.6670
Paige.eldridge@witheritelaw.com

Mr. Randall G. Walters
Ms. Nadine K. Weatherall
WALTERS, BALIDo & CRAIN, LLP
Meadowpark Tower, Suite 1500
10440 North Central Expressway
Dallas, Texas 75231
TEL: 214.749.4805
FAX: 214.347.8381
Randy.walters@wbclawﬁrm.com
Nadine.weatherall@wbclawﬁrm.com

/s/]olin ’W. Qreeze
JOHN W. BREEZE

DEFENDANT’S EXHIBIT LIST - PAGE 5
10001 . 14942/troby
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.

Terri Roby on behalf of John Breeze
Bar No. 00796248
terri@lecronelaw.com
Envelope ID: 68677547
Status as of 9/28/2022 8:21 AM CST
Associated Case Party: VASHONE RHODES
Name BarNumber Email TimestampSubmitted Status
Amy Witherite 788698 amy.witherite@witheritelaw.com 9/27/2022 11:31 :19 PM SENT
Paige Eldridge paige.eldridge@ewlawyers.com 9/27/2022 11:31:19 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.

Terri Roby on behalf of John Breeze
Bar No. 00796248
terri@lecronelaw.com
Envelope ID: 68677547
Status as of 9/28/2022 8:21 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
V. Paige Eldridge paige.eldridge@witheritelaw.com 9/27/2022 11:31:19 PM SENT
PAIGE VELDRIDGE paiqe.eldridqe@ewlawyers.com 9/27/2022 11:31 :1 9 PM SENT
Craig Laird PCL@LA|RD.LAWYER 9/27/2022 11:31:19 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.

Terri Roby on behalf of John Breeze
Bar No. 00796248
terri@lecronelaw.com
Envelope ID: 68677547
Status as of 9/28/2022 8:21 AM CST
Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC
Name BarNumber Email TimestampSubmitted Status
Randall GWalters waltersedocsnotiﬁcations@wbclawﬁrm.com 9/27/2022 11:31:19 PM SENT
Nadine K Weatherall nadine.weatherall@wbclawﬁrm.com 9/27/2022 11:31:19 PM SENT
Randall GWalters randy.walters@wbclawﬁrm.com 9/27/2022 11:31:19 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.

Terri Roby on behalf of John Breeze
Bar No. 00796248
terri@lecronelaw.com
Envelope ID: 68677547
Status as of 9/28/2022 8:21 AM CST
Associated Case Party: JAMES GOMEZ
Name BarNumber Email TimestampSubmitted Status
Adam LeCrone eservice@lecronelaw.com 9/27/2022 11:31 :19 PM SENT

Case Info

Judge

REDMOND, AIESHA Track Judge’s New Case

Case No.

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Document Filed Date

September 27, 2022

Case Filing Date

August 02, 2019

County

Parties

BREEZE, JOHNNY W Attorney for the Defendant
ELDRIDGE, V. PAIGE Attorney for the Plaintiff
EXCLUSIVE NATIONWIDE DELIVERY, INC Defendant
GOMEZ, JAMES Defendant
HOLCOMB, RHONDA D Attorney for the Defendant
LAIRD, PAUL CRAIG Attorney for the Defendant
LECRONE, ADAM B Attorney for the Defendant
RHODES, VASHONE Plaintiff
WALTERS, RANDALL G Attorney for the Defendant
WEATHERALL, NADINE K Attorney for the Defendant
William Schultz Attorneys for Plaintiffs
Vivian Eldridge Attorneys for Plaintiffs
Shelly Greco Attorneys for Plaintiffs
David Kennedy Attorney
Amy Witherite Attorneys for Plaintiffs
Mark Teague Attorneys for Defendants
Hillary Clark Attorneys for Defendants
Alexandria Carpenter Attorneys for Defendants
Blaise Wilcott Attorneys for Defendants
Michael Kelly Attorneys for Defendants
Trevor Beaty Attorneys for Defendants
Selene Peña Attorneys for Defendants
Molly Kaelin Attorneys for Defendants
Mark Humphrey Attorneys for Defendants
Ashanti Baker Attorneys for Defendants
John Merritt Attorneys for Defendants
Rhonda Denton Attorney
Megan Andrus Attorneys for Defendants

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