Party Discovery: VASHONE RHODES vs. JAMES GOMEZ, et al

On August 02, 2019 a Party Discovery 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
9/28/2022 10:06 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Rhonda Burks DEPUTY

CAUSE NO. DC-l9-10926

VASHONE RHODES § 1N THE DISTRICT COURT 0F
Plaintifﬂ §
§
vs. § DALLAS COUNTY, TEXAS
§
JAMES GOMEZ AND EXCLUSIVE §
NATIONWIDE DELIVERY INC. §
Defendants. § 160TH IUDICLAL DISTRICT

DEFENDANT EXCLUSIVE NATIONWIDE DELIVERY INC.’S PAGE/LINE
DESIGNATIONS OF DEPOSITION TESTIMONY

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW, Exclusive Nationwide Delivery Inc., Defendant in the above-entitled and

numbered cause, and hereby submits the following deposition testimony to be used at trial:

Oral and Videotaped Deposition of Rawson Wood, MD

START END
6:5 Starting with “Dr. Wood . . .” 6:7
6:19 6:25
7:2 Starting with “you submitted . . .” 8:17
9:10 11:4 Ending at“. . . illness or injury.”
1 1:8 Starting with “I want to . . .” 12:14
12:19 14:11 Ending a “. . . experienced.”
14:15 14:25
15: 13 Starting with “Dr. Wood . . .” 15:17
16:1 16:16
16: 18 Startig with “someone from . . .” 16:25 Ending at“. . . That’s correct.”
17:4 18:5 Ending at“. . . right-quarter panel”
18:6 Starting with “demonstrated minor . . .” 18:19
18:22 19:16
20:8 21 :20
21:23 Starting with “your report . . .” 24:22 Ending at“. . . Yes.”
25:8 25:13
25:21 Starting with “it’d be about . . .” 25:23
26:2 Starting With “Is it your . . .” 26:4
26:12 Starting with “In this . . .” 27:3 Ending at “Sure . . .”
27:9 30:7
30:14 Starting with “Playing basketball . . .” 32:7
33:1 33: 15
33:16 Starting with “Is that still . . .” 33:19

DEFENDANT EXCLUSIVE NATIONWIDE DELIVERY INC.’S
PAGE/LINE DESIGNATIONS OF DEPOSITION TESTIMONY PAGE l
84:7 Starting with “I’m going to...” 85:10
85:12 Starting with “I know actually . . .” 87:16
87: 18 Starting with “not only...” 91 :7
91:8 Starting with “I’m going to . . .” 95:25 Ending at “Finally, Dr. Wood . . .”
96:1 Starting with “you’ve looked at. . 96: 13
102:3 102:20

Oral Deposition of James Gomez

START END
6:24 7:10
12:3 Starting with “Do you remember . . .” 12:24
13:8 13:21
14:9 14:13
14:20 14:22
15:12 15:19
16:3 16:6
20:10 20:14
20:25 21:2
24:10 25:20
26:4 Starting with “I said . . .” 26:9
26:14 26:19
27:7 27:13

Respectfully submitted,

WALTERS, BALIDO & CRAIN, L.L.P.
BY: /s/ Randall G. Walters
RANDALL G. WALTERS — 20819480
randy.walters@wbclawﬁrm.com
NADINE K. WEATHERALL — 24073060
nadine.weatherall@wbclawﬁrm.com
Service of Documents:
WaltersEDocsNotiﬁcations@wbclawﬁrmcom
Meadow Park Tower, Suite 1500
10440 North Central Expressway
Dallas, Texas 75231
214/347-8381 — FAX
214/347-8380 — DIRECT
214/749-4805 — MAIN

ATTORNEYS FOR DEFENDANT
EXCLUSIVE NATIONWIDE DELIVERY INC.

DEFENDANT EXCLUSIVE NATIONWIDE DELIVERY INC.’S
PAGE/LINE DESIGNATIONS OF DEPOSITION TESTIMONY PAGE 2
CERTIFICATE OF SERVICE
This is to certify that on this the 28th day of September, 2022, a true and correct copy of
the above document has been forwarded to all known counsel of record.

/s/ Randall G. Walters
RANDALL G. WALTERS

DEFENDANT EXCLUSIVE NATIONWIDE DELIVERY INC.’S
PAGE/LINE DESIGNATIONS OF DEPOSITION TESTIMONY PAGE 3
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.

Olasubomi Koiki on behalf of Randall Walters
Bar No. 20819480
olasubomi.koiki@wbclawfirm.com
Envelope ID: 68684272
Status as of 9/28/2022 10:15 AM CST
Associated Case Party: VASHONE RHODES
Name BarNumber Email TimestampSubmitted Status
Amy Witherite 788698 amy.witherite@witheritelaw.com 9/28/2022 10:06:03 AM SENT
Shelly Tomlin Greco 24008168 shelly.greco@witheritelaw.com 9/28/2022 10:06:03 AM SENT
Paige Eldridge paige.eldridge@witheritelaw.com 9/28/2022 10:06:03 AM SENT
Paige Eldridge paige.eldridge@ewlawyers.com 9/28/2022 10:06:03 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.

Olasubomi Koiki on behalf of Randall Walters
Bar No. 20819480
olasubomi.koiki@wbclawfirm.com
Envelope ID: 68684272
Status as of 9/28/2022 10:15 AM CST
Associated Case Party: JAMES GOMEZ
Name BarNumber Email TimestampSubmitted Status
Adam LeCrone eservice@lecronelaw.com 9/28/2022 10:06:03 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.

Olasubomi Koiki on behalf of Randall Walters
Bar No. 20819480
olasubomi.koiki@wbclawfirm.com
Envelope ID: 68684272
Status as of 9/28/2022 10:15 AM CST
Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC
Name BarNumber Email TimestampSubmitted Status
Randall GWalters waltersedocsnotiﬁcations@wbclawﬁrm.com 9/28/2022 10:06:03 AM SENT
Nadine K Weatherall nadine.weatherall@wbclawﬁrm.com 9/28/2022 10:06:03 AM SENT
Randall GWalters randy.walters@wbclawﬁrm.com 9/28/2022 10:06:03 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.

Olasubomi Koiki on behalf of Randall Walters
Bar No. 20819480
olasubomi.koiki@wbclawfirm.com
Envelope ID: 68684272
Status as of 9/28/2022 10:15 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
V. Paige Eldridge paige.eldridge@witheritelaw.com 9/28/2022 10:06:03 AM SENT
Craig Laird PCL@LA|RD.LAWYER 9/28/2022 10:06:03 AM SENT
PAIGE VELDRIDGE paiqe.eldridqe@ewlawyers.com 9/28/2022 10:06:03 AM ERROR

Case Info

Judge

REDMOND, AIESHA Track Judge’s New Case

Case No.

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Document Filed Date

September 28, 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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