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FILED
9/29/2022 5:20 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Rhonda Burks DEPUTY
CAUSE N0. DC-l9—10926
VASHONE RHODES § IN THE DISTRICT COURT
§
V. § 160TH JUDICIAL DISTRICT
§
JAMES GOMEZ AND EXCLUSIVE §
NATIONWIDE DELIVERY INC. § DALLAS COUNTY, TEXAS
DEFENDANT JAMES GOMEZ PAGE/LINE DESIGNATION OF DEPOSITION
TESTIMONY
COMES NOW, Defendant, James Gomez, and files this Designation of Excerpts as
follows:
I.
Oral and Video Deposition ofRawson Wood, MD
Pg. 6, line 5 staIting with “Dr. Wood...” to pg. 6 line 25
Pg. 7, line 2 starting with “you submitted...” to pg. 8 line 17
Pg. 9, line 10 to pg. 11 line 4 ending at“... illness or injury.”
Pg. 11, line 8 starting with “I want to...” to pg. 12 line 14
Pg. 12, line 19 to pg. 14 line 11 ending a “... experienced.”
Pg. 14, line 15 to pg. 14 line 25
Pg. 15, line 13 starting with “Dr Wood...” to pg. 15 line 17
Pg. 16, line 1 to pg. l6 line 16
Pg. 16, line 18 starting with “someone from...” to pg. 16 line 25 ending at “... that’s
correct”
Pg. 17, line 4 to pg. l8 line 5 ending a “. .. right-quarter panel”
Pg. 18, line 6 starting with “demonstration minor...” to pg. 18 line 19
DEFENDANT JAMES GOMEZ PAGE/LINE DESIGNATION OF
DEPOSITION TESTIMONY PAGE 1
10001 . 14942/mhughley
Pg. 18, line 22 to pg. 21 line 20
Pg . 21, line 23 starting with “your report...” to pg. 25 line 13
Pg. 25, line 21 starting with “it’d be about...” to pg. 25 line 23
“ Is it
Pg. 26, line 2 starting with your...” to pg. 26 line 4
Pg . 26, line 12 starting with “in this...” to pg. 27 line 3 ending at “sure ...”
Pg. 27, line 9 to pg. 30 line 7
Pg. 30, line 14 starting with “playing basketball ...” to pg. 32 line 7
Pg . 33, line l to pg. 33 line 15
Pg. 36, line 16 starting with “is that still...” to pg. 33 line 19
Pg. 96, line 22 to pg. 96 line 23 ending with “previously...”
Pg . 97, line 3 to pg. 99 line 1
II.
Oral Deposition of James Gomez
Pg. 6, line 24 to pg. 7 line 10
Pg. 12, line 3 starting with “do you remember...” to pg. 12 line 24
Pg. 13, line 8 to pg. 13 line 21
Pg. 14, line 9 to pg. 14 line 13
Pg. 14, line 20 to pg. l4 line 22
Pg. 15, line l2 to pg. l6 line 6
Pg. 20, line 10 to pg. 20 line 14
Pg. 20, line 25 to pg. 21 line 2
Pg. 24, line 10 to pg. 25 line 20
Pg. 26, line 4 starting with “I said...” to pg. 26 line 9
Pg. 26, line l4 to pg. 26 line 19
DEFENDANT JAMES GOMEZ PAGE/LINE DESIGNATION OF
DEPOSITION TESTIMONY PAGE 2
10001 . 14942/mhughley
Pg. 27, line 7 to pg. 27 line 13
Defendant further reserves the right to use any testimony designated by Plaintiff and Co-
Defendant in this case.
WHEREFORE, PREMISES CONSIDERED, Defendant James Gomez prays that the
Court and counsel take notice of this designations.
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/ 70511 ’W. @reeze
JOHN W. BREEZE
State Bar No. 00796248
MARK A. TEAGUE
State Bar No. 24003039
HILLARY LUCKETT CLARK
State Bar No. 24077714
ALEXANDRIA K. CARPENTER
State Bar No. 24101596
RHONDA D. HOLCOMB
State Bar No. 24099024
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
DEFENDANT JAMES GOMEZ PAGE/LINE DESIGNATION OF
DEPOSITION TESTIMONY PAGE 3
10001 . 14942/mhughley
CERTIFICATE OF SERVICE
This is to certify that on the 29th day of September, 2022, the foregoing instrument was
forwarded to the following counsel of record:
Ms. V. Paige Eldridge
Ms. Amy K. Witherite
WITHERITE LAw GROUP, PLLC
10440 N. Central Expressway, Ste. 400
Dallas, TX 75231-2228
TEL: 214.378.6665
FAX: 214.378.6670
Email: paige.eldfidge@witheritelaw.com
Mr. Randall G. Walters
Ms. Nadine K. Weatherall
WALTERS, BALIDo & CRAIN L.L.P
Meadowpark Tower, Suite 1500
10440 North Central Expressway
Dallas, TX 75231
TEL: 214.749.4805
FAX: 214.347.8381
Email: randy.walters@wbclawfirm.com
Email: Nadine.Weatherall@wbclawfirm.com
/s/ Jolin ’W. Qreeze
JOHN W. BREEZE
DEFENDANT JAMES GOMEZ PAGE/LINE DESIGNATION OF
DEPOSITION TESTIMONY PAGE 4
10001 . 14942/mhughley
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: 68761959
Status as of 9/30/2022 8:28 AM CST
Associated Case Party: VASHONE RHODES
Name BarNumber Email TimestampSubmitted Status
Amy Witherite 788698 amy.witherite@witheritelaw.com 9/29/2022 5:20:21 PM SENT
Shelly Tomlin Greco 24008168 shelly.greco@witheritelaw.com 9/29/2022 5:20:21 PM SENT
Paige Eldridge paige.eldridge@ewlawyers.com 9/29/2022 5:20:21 PM SENT
Paige Eldridge paige.eldridge@witheritelaw.com 9/29/2022 5:20:21 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.
Monica Hughley on behalf of John Breeze
Bar No. 00796248
monica@lecronelaw.com
Envelope ID: 68761959
Status as of 9/30/2022 8:28 AM CST
Associated Case Party: JAMES GOMEZ
Name BarNumber Email TimestampSubmitted Status
Adam LeCrone eservice@|ecronelaw.com 9/29/2022 5:20:21 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.
Monica Hughley on behalf of John Breeze
Bar No. 00796248
monica@lecronelaw.com
Envelope ID: 68761959
Status as of 9/30/2022 8:28 AM CST
Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC
Name BarNumber Email TimestampSubmitted Status
Randall GWalters waltersedocsnotifications@wbclawfirm.com 9/29/2022 5:20:21 PM SENT
Nadine K Weatherall nadine.weatherall@wbclawfirm.oom 9/29/2022 5:20:21 PM SENT
Randall GWalters randy.walters@wbclawfirm.com 9/29/2022 5:20:21 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.
Monica Hughley on behalf of John Breeze
Bar No. 00796248
monica@lecronelaw.com
Envelope ID: 68761959
Status as of 9/30/2022 8:28 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
V. Paige Eldridge paige.eldridge@witheritelaw.com 9/29/2022 5:20:21 PM SENT
PAIGE VELDRIDGE paiqe.eldridqe@ewlawyers.com 9/29/2022 5:20:21 PM ERROR
Craig Laird PCL@LA|RD.LAWYER 9/29/2022 5:20:21 PM SENT
Preview
FILED 9/29/2022 5:20 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Rhonda Burks DEPUTY CAUSE N0. DC-l9—10926 VASHONE RHODES § IN THE DISTRICT COURT § V. § 160TH JUDICIAL DISTRICT § JAMES GOMEZ AND EXCLUSIVE § NATIONWIDE DELIVERY INC. § DALLAS COUNTY, TEXAS DEFENDANT JAMES GOMEZ PAGE/LINE DESIGNATION OF DEPOSITION TESTIMONY COMES NOW, Defendant, James Gomez, and files this Designation of Excerpts as follows: I. Oral and Video Deposition ofRawson Wood, MD Pg. 6, line 5 staIting with “Dr. Wood...” to pg. 6 line 25 Pg. 7, line 2 starting with “you submitted...” to pg. 8 line 17 Pg. 9, line 10 to pg. 11 line 4 ending at“... illness or injury.” Pg. 11, line 8 starting with “I want to...” to pg. 12 line 14 Pg. 12, line 19 to pg. 14 line 11 ending a “... experienced.” Pg. 14, line 15 to pg. 14 line 25 Pg. 15, line 13 starting with “Dr Wood...” to pg. 15 line 17 Pg. 16, line 1 to pg. l6 line 16 Pg. 16, line 18 starting with “someone from...” to pg. 16 line 25 ending at “... that’s correct” Pg. 17, line 4 to pg. l8 line 5 ending a “. .. right-quarter panel” Pg. 18, line 6 starting with “demonstration minor...” to pg. 18 line 19 DEFENDANT JAMES GOMEZ PAGE/LINE DESIGNATION OF DEPOSITION TESTIMONY PAGE 1 10001 . 14942/mhughley Pg. 18, line 22 to pg. 21 line 20 Pg . 21, line 23 starting with “your report...” to pg. 25 line 13 Pg. 25, line 21 starting with “it’d be about...” to pg. 25 line 23 “ Is it Pg. 26, line 2 starting with your...” to pg. 26 line 4 Pg . 26, line 12 starting with “in this...” to pg. 27 line 3 ending at “sure ...” Pg. 27, line 9 to pg. 30 line 7 Pg. 30, line 14 starting with “playing basketball ...” to pg. 32 line 7 Pg . 33, line l to pg. 33 line 15 Pg. 36, line 16 starting with “is that still...” to pg. 33 line 19 Pg. 96, line 22 to pg. 96 line 23 ending with “previously...” Pg . 97, line 3 to pg. 99 line 1 II. Oral Deposition of James Gomez Pg. 6, line 24 to pg. 7 line 10 Pg. 12, line 3 starting with “do you remember...” to pg. 12 line 24 Pg. 13, line 8 to pg. 13 line 21 Pg. 14, line 9 to pg. 14 line 13 Pg. 14, line 20 to pg. l4 line 22 Pg. 15, line l2 to pg. l6 line 6 Pg. 20, line 10 to pg. 20 line 14 Pg. 20, line 25 to pg. 21 line 2 Pg. 24, line 10 to pg. 25 line 20 Pg. 26, line 4 starting with “I said...” to pg. 26 line 9 Pg. 26, line l4 to pg. 26 line 19 DEFENDANT JAMES GOMEZ PAGE/LINE DESIGNATION OF DEPOSITION TESTIMONY PAGE 2 10001 . 14942/mhughley Pg. 27, line 7 to pg. 27 line 13 Defendant further reserves the right to use any testimony designated by Plaintiff and Co- Defendant in this case. WHEREFORE, PREMISES CONSIDERED, Defendant James Gomez prays that the Court and counsel take notice of this designations. 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/ 70511 ’W. @reeze JOHN W. BREEZE State Bar No. 00796248 MARK A. TEAGUE State Bar No. 24003039 HILLARY LUCKETT CLARK State Bar No. 24077714 ALEXANDRIA K. CARPENTER State Bar No. 24101596 RHONDA D. HOLCOMB State Bar No. 24099024 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 DEFENDANT JAMES GOMEZ PAGE/LINE DESIGNATION OF DEPOSITION TESTIMONY PAGE 3 10001 . 14942/mhughley CERTIFICATE OF SERVICE This is to certify that on the 29th day of September, 2022, the foregoing instrument was forwarded to the following counsel of record: Ms. V. Paige Eldridge Ms. Amy K. Witherite WITHERITE LAw GROUP, PLLC 10440 N. Central Expressway, Ste. 400 Dallas, TX 75231-2228 TEL: 214.378.6665 FAX: 214.378.6670 Email: paige.eldfidge@witheritelaw.com Mr. Randall G. Walters Ms. Nadine K. Weatherall WALTERS, BALIDo & CRAIN L.L.P Meadowpark Tower, Suite 1500 10440 North Central Expressway Dallas, TX 75231 TEL: 214.749.4805 FAX: 214.347.8381 Email: randy.walters@wbclawfirm.com Email: Nadine.Weatherall@wbclawfirm.com /s/ Jolin ’W. Qreeze JOHN W. BREEZE DEFENDANT JAMES GOMEZ PAGE/LINE DESIGNATION OF DEPOSITION TESTIMONY PAGE 4 10001 . 14942/mhughley 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: 68761959 Status as of 9/30/2022 8:28 AM CST Associated Case Party: VASHONE RHODES Name BarNumber Email TimestampSubmitted Status Amy Witherite 788698 amy.witherite@witheritelaw.com 9/29/2022 5:20:21 PM SENT Shelly Tomlin Greco 24008168 shelly.greco@witheritelaw.com 9/29/2022 5:20:21 PM SENT Paige Eldridge paige.eldridge@ewlawyers.com 9/29/2022 5:20:21 PM SENT Paige Eldridge paige.eldridge@witheritelaw.com 9/29/2022 5:20:21 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. Monica Hughley on behalf of John Breeze Bar No. 00796248 monica@lecronelaw.com Envelope ID: 68761959 Status as of 9/30/2022 8:28 AM CST Associated Case Party: JAMES GOMEZ Name BarNumber Email TimestampSubmitted Status Adam LeCrone eservice@|ecronelaw.com 9/29/2022 5:20:21 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. Monica Hughley on behalf of John Breeze Bar No. 00796248 monica@lecronelaw.com Envelope ID: 68761959 Status as of 9/30/2022 8:28 AM CST Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC Name BarNumber Email TimestampSubmitted Status Randall GWalters waltersedocsnotifications@wbclawfirm.com 9/29/2022 5:20:21 PM SENT Nadine K Weatherall nadine.weatherall@wbclawfirm.oom 9/29/2022 5:20:21 PM SENT Randall GWalters randy.walters@wbclawfirm.com 9/29/2022 5:20:21 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. Monica Hughley on behalf of John Breeze Bar No. 00796248 monica@lecronelaw.com Envelope ID: 68761959 Status as of 9/30/2022 8:28 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status V. Paige Eldridge paige.eldridge@witheritelaw.com 9/29/2022 5:20:21 PM SENT PAIGE VELDRIDGE paiqe.eldridqe@ewlawyers.com 9/29/2022 5:20:21 PM ERROR Craig Laird PCL@LA|RD.LAWYER 9/29/2022 5:20:21 PM SENT