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FILED
DocuSign Envelope ID: 582C95D4-DA1A-4356-A4 1C-35833CAEE9F4 1/18/2023 10:05 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Rhonda Burks DEPUTY
CAUSE NO. DC-19-10926
VASHONE RHODES
IN THE DISTRICT COURT OF
VS.
DALLAS COUNTY, TEXAS
JAMES GOMEZ; EXCLUSIVE
NATIONWIDE DELIVERY INC.; AND §
GEICO COUNTY MUTUAL INSURANCE 160™ JUDICIAL DISTRICT
COMPANY
DEFENDANT’S VERIFIED ORIGINAL ANSWER
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW Defendant, GEICO County Mutual Insurance Company ("Defendant"),
and files this Verified Original Answer, and would respectfully show as follows:
I. GENERAL DENIAL
As is authorized by Texas Rule of Civil Procedure 92, Defendant generally denies each
and every allegation contained in Plaintiffs Petition, and respectfully requests that Plaintiff be
required to prove same by a preponderance of the evidence as is required by the Constitution and
laws of the State of Texas.
II. CONDITIONS PRECEDENT
Defendant further specifically denies that all conditions precedent necessary for recovery
by Plaintiff under any policy of insurance issued by Defendant have been met. Plaintiff has not
shown Plaintiff is entitled to recover uninsured/underinsured motorist benefits. Plaintiff has no
claim for UM/UIM benefits under the Policy until first establishing Plaintiff is legally entitled to
recover from the tortfeasor(s). The Policy does not require Defendant to pay UM or UIM
benefits before the tortfeasor(s)’ negligence and uninsured/underinsured status is determined. See
Brainard y. Trinity Universal Ins. Co., 216 S.W.3d 809, 818-19 (Tex. 2006); see also State Farm
DEFENDANT’S VERIFIED ORIGINAL ANSWER PAGE 1
DocuSign Envelope ID: 582C95D4-DA1A-4356-A4 1C-35833CAEE9F4
Mut. Auto Ins. Co. v. Norris, 216 S.W.3d 819, 822 (Tex. 2006); see also Henson v. Southern
Farm Bureau Cas. Ins. Co., 17 S.W.3d 652, 653-54 (Tex. 2000).
Ill. COMPARATIVE NEGLIGENCE-RESPONSIBILITY
Defendant would further show that the negligence of the Plaintiff and/or one or more Co-
Defendants and/or one or more third parties was/were the sole, or a partial, proximate cause of
the accident and the injuries and damages alleged by Plaintiff. Pursuant to Texas Civil Practice &
Remedies Code Chapter 33, Defendant invokes the doctrine of comparative responsibility and
would show that Defendant is entitled to an issue submitted to the jury on the comparative
responsibility of Plaintiff and/or any Co-Defendant and/or third party who/which caused,
contributed, or was responsible for this accident and the injuries and damages alleged by
Plaintiff.
IV. SUDDEN ERGENCY/UNAVOIDABLE ACCIDENT
To the extent applicable, Defendant would further show that the tortfeasor was
confronted by an emergency arising suddenly and unexpectedly which was not proximately
caused by any negligence on the tortfeasor’s part and which, to a reasonable person, requires
immediate action without time for deliberation and that the tortfeasor acted as a person of
ordinary prudence would have acted under the same or similar circumstances. Defendant would
further show that the collision with Plaintiff's vehicle was an unavoidable accident without
negligence of the tortfeasor or this Defendant.
V. PRE-EXISTING CONDITION
To the extent applicable, Defendant would further show Plaintiff had a medical condition
which pre-existed this accident or arose following this accident and did not result from this
DEFENDANT’S VERIFIED ORIGINAL ANSWER PAGE 2
DocuSign Envelope ID: 582C95D4-DA1A-4356-A4 1C-35833CAEE9F4
accident. Defendant is not responsible for Plaintiff's medical condition and damages, if any,
attributable to Plaintiff's pre-existing or subsequent condition not caused by this accident.
VI. PROXIMATE CAUSE
To the extent applicable, Defendant would further show that the tortfeasor’s acts or
omissions and/or the accident made the basis of this lawsuit were not the proximate cause of the
occurrence in question and/or Plaintiff's injuries. Further, Defendant disputes that Plaintiff
sustained injury from the occurrence in question.
VII. FAILURE TO MITIGATE DAMAGES
Defendant would further show that Plaintiff failed to act as a person of ordinary prudence
would have done under the same or similar circumstances in caring for and treating the injuries
of Plaintiff, if any, that resulted from this accident and/or in failing to mitigate the damages, if
any, of Plaintiff.
VIII. LOSS OF EARNINGS
To the extent that the Plaintiff is seeking a recovery for loss of earnings, lost wages, loss
of earning capacity and/or loss of contribution of pecuniary value, Defendant further asserts that
evidence of this alleged loss must be presented by the Plaintiff in the form of a net loss after
reduction for income tax payments or unpaid tax liability to any federal income tax law, as
required by Texas Civil Practice & Remedies Code § 18.091.
IX. PAID OR INCURRED MEDICAL EXPENSES LIMITATION
Defendant further specifically contends, in accordance with Texas Civil Practice &
Remedies Code § 41.0105, that recovery by Plaintiff of past medical or health care expenses, if
any, that were incurred as a result of the accident identified in Plaintiffs Petition, and the
relevant evidence of past medical and healthcare expenses, if any, that were incurred as a result
DEFENDANT’S VERIFIED ORIGINAL ANSWER PAGE 3
DocuSign Envelope ID: 582C95D4-DA1A-4356-A4 1C-35833CAEE9F4
of the accident identified in Plaintiff's Petition, is limited to amount(s) actually paid or incurred
by, or on behalf of, the Plaintiff. Haygood v. De Escabedo, 356 S.W.3d 390 (Tex. 2011).
X. POLICY LIMIT
Defendant would further show _ that any recovery made by Plaintiff for
underinsured/uninsured motorist benefits cannot exceed the limits of Plaintiff's insurance policy
applicable to this underinsured/uninsured motorist claim.
XI. CREDIT AND OFFSET
Defendant would further show that it is entitled to offset or credit in the amounts of the
liability insurance amount of any tortfeasor who was responsible for the accident made the basis
of this suit and Plaintiff's alleged injuries and damages, any other uninsured/underinsured policy
of insurance issued by any other insurer to Plaintiff, and any money paid to, or on behalf of,
Plaintiff for any medical payment or personal injury protection benefit.
XII. REQUIRED INITIAL DISCLOSURES
Pursuant to Texas Rule of Civil Procedure 194.2, Plaintiff is required to disclose, within
thirty (30) days of the filing of this Answer, the information or materials described in Rule 194.2.
XII. TEXAS RULE OF CIVIL PROCEDURE 193.7 NOTICE
Pursuant to Texas Rule of Civil Procedure 193.7, Defendant may enter into evidence at
the trial or at any other proceeding during the pendency of this matter all documents produced to
Defendant in response to discovery requests.
XIV. TEXAS RULE OF EVIDENCE 609(f) REQUEST
Defendant requests that Plaintiff, pursuant to Texas Rule of Evidence 609(f), give
Defendant sufficient advanced written notice of Plaintiff's intent to use evidence of a conviction
DEFENDANT’S VERIFIED ORIGINAL ANSWER PAGE 4
DocuSign Envelope ID: 582C95D4-DA1A-4356-A4 1C-35833CAEE9F4
of a crime under Rule 609(f) against any party or witness in this case, with failure to do so
resulting in inadmissibility of the same.
XV. JURY DEMAND
Pursuant to Texas Rule of Civil Procedure 216, Defendant demands a jury trial. The
appropriate jury fee has been or will be paid to the Clerk of the Court within thirty (30) days in
advance of the trial setting.
XVI. PRAYER
WHEREFORE, PREMISES CONSIDERED, Defendant GEICO County Mutual
Insurance Company prays that Plaintiff take nothing by way of this suit, and that this Defendant
have such other and further relief, general or special, at law or in equity, to which this Defendant
may be justly entitled.
Respectfully submitted,
BRITT A. HADLEY & ASSOCIATES
/s/ William Schultz
WILLIAM SCHULTZ
SBN: 00794609
8505 Freeport Parkway, STE 375
Irving, Texas 75063
Telephone: 682-271-6850
Facsimile: 214-277-0518
wschultz@geico.com
ATTORNEY FOR DEFENDANT
DEFENDANT’S VERIFIED ORIGINAL ANSWER PAGE 5
DocuSign Envelope ID: 582C95D4-DA1A-4356-A4 1C-35833CAEE9F4
CERTIFICATE OF SERVICE
Thereby certify that on this the 17th _ day of January, 2023, a true and correct copy of
the foregoing instrument has been sent to all counsel of record pursuant to the Texas Rules of
Civil Procedure:
VIA E-service: paige.eldridge@witheritelaw.com
Paigev Eldrige
Witherite Law Group, PLLC
10440 N. Central Expressway
Suite 400
Dallas, Texas 75231
Attorney for Plaintiff
Randall G. Walters
Nadine K. Weatherall
Walters, Balido & Crain, LLP
Meadow Park Tower, 15" Floor
10440 North Central Expressway
Dallas, Texas 75231
John W. Breeze
Adam B. LeCrone
The LeCrone Law Firm, P.C.
Wall Street Plaza
123 N. Crockett Street, Suite 200
Sherman, Texas 75090
/s/ William Schultz
WILLIAM SCHULTZ
DEFENDANT’S VERIFIED ORIGINAL ANSWER PAGE 6
DocuSign Envelope ID: 582C95D4-DA1A-4356-A4 1C-35833CAEE9F4
VERIFICATION OF ANGELA PIERRE-JACK
STATE OF TEXAS §
§
COUNTY OF §
BEFORE ME, the undersigned Notary Public, on this day personally appeared Angela
Pierre-Jack, who, after having been first by me duly sworn, stated under oath that he/she is an
agent of Defendant duly authorized to execute this verification; that he/she has read the above
Defendant’s Verified Original Answer; and that every statement of fact contained in Paragraph II
thereof is within his/her personal knowledge and is true and correct.
(“Ongele Pierre-facke
DocuBigned by:
27FBFCCIAC2EAZC.
ANGELA PIERRE-JACK
SUBSCRIBED and SWORN TO BEFORE ME, on this the day of
, 2023, to certify which, witness my hand and seal of office.
NOTARY PUBLIC, in and for
The State of TEXAS
VERIFICATION OF ANGELA PIERRE-JACK
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.
Dianne Davis on behalf of William Schultz
Bar No. 794609
diadavis@geico.com
Envelope ID: 71886671
Status as of 1/18/2023 10:57 AM CST
Associated Case Party: VASHONE RHODES
Name BarNumber | Email TimestampSubmitted Status
Amy Witherite 788698 amy.witherite@witheritelaw.com 1/18/2023 10:05:34 AM SENT
Shelly Tomlin Greco | 24008168 shelly.greco@witheritelaw.com 1/18/2023 10:05:34 AM SENT
Paige Eldridge paige.eldridge@ewlawyers.com 1/18/2023 10:05:34 AM SENT
Paige Eldridge paige.eldridge@witheritelaw.com 1/18/2023 10:05:34 AM SENT
Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC
Name BarNumber Email TimestampSubmitted Status
Johnny W. Breeze 796248 eservice@lecronelaw.com 1/18/2023 10:05:34 AM SENT
Randall GWalters waltersedocsnotifications@wbclawfirm.com 1/18/2023 10:05:34 AM SENT
Nadine K Weatherall nadine.weatherall@wbclawfirm.com 1/18/2023 10:05:34 AM SENT
Randall GWalters randy.walters@wbclawfirm.com 1/18/2023 10:05:34 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
V. Paige Eldridge paige.eldridge@witheritelaw.com 1/18/2023 10:05:34 AM SENT
PAIGE VELDRIDGE paige.eldridqe@ewlawyers.com 1/18/2023 10:05:34 AM ERROR
Craig Laird PCL@LAIRD.LAWYER 1/18/2023 10:05:34 AM SENT
Associated Case Party: GEICO COUNTY MUTUAL INSURANCE COMPANY
Name BarNumber Email TimestampSubmitted | Status
William Schultz wschultz@geico.com 1/18/2023 10:05:34 AM | SENT
Melissa Webb mwebb@geico.com 1/18/2023 10:05:34 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.
Dianne Davis on behalf of William Schultz
Bar No. 794609
diadavis@geico.com
Envelope ID: 71886671
Status as of 1/18/2023 10:57 AM CST
Associated Case Party: GEICO COUNTY MUTUAL INSURANCE COMPANY
Dianne Davis diadavis@geico.com 1/18/2023 10:05:34 AM | SENT
Associated Case Party: JAMES GOMEZ
Name BarNumber | Email TimestampSubmitted | Status
Adam LeCrone eservice@lecronelaw.com | 1/18/2023 10:05:34 AM | SENT
Preview
FILED DocuSign Envelope ID: 582C95D4-DA1A-4356-A4 1C-35833CAEE9F4 1/18/2023 10:05 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Rhonda Burks DEPUTY CAUSE NO. DC-19-10926 VASHONE RHODES IN THE DISTRICT COURT OF VS. DALLAS COUNTY, TEXAS JAMES GOMEZ; EXCLUSIVE NATIONWIDE DELIVERY INC.; AND § GEICO COUNTY MUTUAL INSURANCE 160™ JUDICIAL DISTRICT COMPANY DEFENDANT’S VERIFIED ORIGINAL ANSWER TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW Defendant, GEICO County Mutual Insurance Company ("Defendant"), and files this Verified Original Answer, and would respectfully show as follows: I. GENERAL DENIAL As is authorized by Texas Rule of Civil Procedure 92, Defendant generally denies each and every allegation contained in Plaintiffs Petition, and respectfully requests that Plaintiff be required to prove same by a preponderance of the evidence as is required by the Constitution and laws of the State of Texas. II. CONDITIONS PRECEDENT Defendant further specifically denies that all conditions precedent necessary for recovery by Plaintiff under any policy of insurance issued by Defendant have been met. Plaintiff has not shown Plaintiff is entitled to recover uninsured/underinsured motorist benefits. Plaintiff has no claim for UM/UIM benefits under the Policy until first establishing Plaintiff is legally entitled to recover from the tortfeasor(s). The Policy does not require Defendant to pay UM or UIM benefits before the tortfeasor(s)’ negligence and uninsured/underinsured status is determined. See Brainard y. Trinity Universal Ins. Co., 216 S.W.3d 809, 818-19 (Tex. 2006); see also State Farm DEFENDANT’S VERIFIED ORIGINAL ANSWER PAGE 1 DocuSign Envelope ID: 582C95D4-DA1A-4356-A4 1C-35833CAEE9F4 Mut. Auto Ins. Co. v. Norris, 216 S.W.3d 819, 822 (Tex. 2006); see also Henson v. Southern Farm Bureau Cas. Ins. Co., 17 S.W.3d 652, 653-54 (Tex. 2000). Ill. COMPARATIVE NEGLIGENCE-RESPONSIBILITY Defendant would further show that the negligence of the Plaintiff and/or one or more Co- Defendants and/or one or more third parties was/were the sole, or a partial, proximate cause of the accident and the injuries and damages alleged by Plaintiff. Pursuant to Texas Civil Practice & Remedies Code Chapter 33, Defendant invokes the doctrine of comparative responsibility and would show that Defendant is entitled to an issue submitted to the jury on the comparative responsibility of Plaintiff and/or any Co-Defendant and/or third party who/which caused, contributed, or was responsible for this accident and the injuries and damages alleged by Plaintiff. IV. SUDDEN ERGENCY/UNAVOIDABLE ACCIDENT To the extent applicable, Defendant would further show that the tortfeasor was confronted by an emergency arising suddenly and unexpectedly which was not proximately caused by any negligence on the tortfeasor’s part and which, to a reasonable person, requires immediate action without time for deliberation and that the tortfeasor acted as a person of ordinary prudence would have acted under the same or similar circumstances. Defendant would further show that the collision with Plaintiff's vehicle was an unavoidable accident without negligence of the tortfeasor or this Defendant. V. PRE-EXISTING CONDITION To the extent applicable, Defendant would further show Plaintiff had a medical condition which pre-existed this accident or arose following this accident and did not result from this DEFENDANT’S VERIFIED ORIGINAL ANSWER PAGE 2 DocuSign Envelope ID: 582C95D4-DA1A-4356-A4 1C-35833CAEE9F4 accident. Defendant is not responsible for Plaintiff's medical condition and damages, if any, attributable to Plaintiff's pre-existing or subsequent condition not caused by this accident. VI. PROXIMATE CAUSE To the extent applicable, Defendant would further show that the tortfeasor’s acts or omissions and/or the accident made the basis of this lawsuit were not the proximate cause of the occurrence in question and/or Plaintiff's injuries. Further, Defendant disputes that Plaintiff sustained injury from the occurrence in question. VII. FAILURE TO MITIGATE DAMAGES Defendant would further show that Plaintiff failed to act as a person of ordinary prudence would have done under the same or similar circumstances in caring for and treating the injuries of Plaintiff, if any, that resulted from this accident and/or in failing to mitigate the damages, if any, of Plaintiff. VIII. LOSS OF EARNINGS To the extent that the Plaintiff is seeking a recovery for loss of earnings, lost wages, loss of earning capacity and/or loss of contribution of pecuniary value, Defendant further asserts that evidence of this alleged loss must be presented by the Plaintiff in the form of a net loss after reduction for income tax payments or unpaid tax liability to any federal income tax law, as required by Texas Civil Practice & Remedies Code § 18.091. IX. PAID OR INCURRED MEDICAL EXPENSES LIMITATION Defendant further specifically contends, in accordance with Texas Civil Practice & Remedies Code § 41.0105, that recovery by Plaintiff of past medical or health care expenses, if any, that were incurred as a result of the accident identified in Plaintiffs Petition, and the relevant evidence of past medical and healthcare expenses, if any, that were incurred as a result DEFENDANT’S VERIFIED ORIGINAL ANSWER PAGE 3 DocuSign Envelope ID: 582C95D4-DA1A-4356-A4 1C-35833CAEE9F4 of the accident identified in Plaintiff's Petition, is limited to amount(s) actually paid or incurred by, or on behalf of, the Plaintiff. Haygood v. De Escabedo, 356 S.W.3d 390 (Tex. 2011). X. POLICY LIMIT Defendant would further show _ that any recovery made by Plaintiff for underinsured/uninsured motorist benefits cannot exceed the limits of Plaintiff's insurance policy applicable to this underinsured/uninsured motorist claim. XI. CREDIT AND OFFSET Defendant would further show that it is entitled to offset or credit in the amounts of the liability insurance amount of any tortfeasor who was responsible for the accident made the basis of this suit and Plaintiff's alleged injuries and damages, any other uninsured/underinsured policy of insurance issued by any other insurer to Plaintiff, and any money paid to, or on behalf of, Plaintiff for any medical payment or personal injury protection benefit. XII. REQUIRED INITIAL DISCLOSURES Pursuant to Texas Rule of Civil Procedure 194.2, Plaintiff is required to disclose, within thirty (30) days of the filing of this Answer, the information or materials described in Rule 194.2. XII. TEXAS RULE OF CIVIL PROCEDURE 193.7 NOTICE Pursuant to Texas Rule of Civil Procedure 193.7, Defendant may enter into evidence at the trial or at any other proceeding during the pendency of this matter all documents produced to Defendant in response to discovery requests. XIV. TEXAS RULE OF EVIDENCE 609(f) REQUEST Defendant requests that Plaintiff, pursuant to Texas Rule of Evidence 609(f), give Defendant sufficient advanced written notice of Plaintiff's intent to use evidence of a conviction DEFENDANT’S VERIFIED ORIGINAL ANSWER PAGE 4 DocuSign Envelope ID: 582C95D4-DA1A-4356-A4 1C-35833CAEE9F4 of a crime under Rule 609(f) against any party or witness in this case, with failure to do so resulting in inadmissibility of the same. XV. JURY DEMAND Pursuant to Texas Rule of Civil Procedure 216, Defendant demands a jury trial. The appropriate jury fee has been or will be paid to the Clerk of the Court within thirty (30) days in advance of the trial setting. XVI. PRAYER WHEREFORE, PREMISES CONSIDERED, Defendant GEICO County Mutual Insurance Company prays that Plaintiff take nothing by way of this suit, and that this Defendant have such other and further relief, general or special, at law or in equity, to which this Defendant may be justly entitled. Respectfully submitted, BRITT A. HADLEY & ASSOCIATES /s/ William Schultz WILLIAM SCHULTZ SBN: 00794609 8505 Freeport Parkway, STE 375 Irving, Texas 75063 Telephone: 682-271-6850 Facsimile: 214-277-0518 wschultz@geico.com ATTORNEY FOR DEFENDANT DEFENDANT’S VERIFIED ORIGINAL ANSWER PAGE 5 DocuSign Envelope ID: 582C95D4-DA1A-4356-A4 1C-35833CAEE9F4 CERTIFICATE OF SERVICE Thereby certify that on this the 17th _ day of January, 2023, a true and correct copy of the foregoing instrument has been sent to all counsel of record pursuant to the Texas Rules of Civil Procedure: VIA E-service: paige.eldridge@witheritelaw.com Paigev Eldrige Witherite Law Group, PLLC 10440 N. Central Expressway Suite 400 Dallas, Texas 75231 Attorney for Plaintiff Randall G. Walters Nadine K. Weatherall Walters, Balido & Crain, LLP Meadow Park Tower, 15" Floor 10440 North Central Expressway Dallas, Texas 75231 John W. Breeze Adam B. LeCrone The LeCrone Law Firm, P.C. Wall Street Plaza 123 N. Crockett Street, Suite 200 Sherman, Texas 75090 /s/ William Schultz WILLIAM SCHULTZ DEFENDANT’S VERIFIED ORIGINAL ANSWER PAGE 6 DocuSign Envelope ID: 582C95D4-DA1A-4356-A4 1C-35833CAEE9F4 VERIFICATION OF ANGELA PIERRE-JACK STATE OF TEXAS § § COUNTY OF § BEFORE ME, the undersigned Notary Public, on this day personally appeared Angela Pierre-Jack, who, after having been first by me duly sworn, stated under oath that he/she is an agent of Defendant duly authorized to execute this verification; that he/she has read the above Defendant’s Verified Original Answer; and that every statement of fact contained in Paragraph II thereof is within his/her personal knowledge and is true and correct. (“Ongele Pierre-facke DocuBigned by: 27FBFCCIAC2EAZC. ANGELA PIERRE-JACK SUBSCRIBED and SWORN TO BEFORE ME, on this the day of , 2023, to certify which, witness my hand and seal of office. NOTARY PUBLIC, in and for The State of TEXAS VERIFICATION OF ANGELA PIERRE-JACK 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. Dianne Davis on behalf of William Schultz Bar No. 794609 diadavis@geico.com Envelope ID: 71886671 Status as of 1/18/2023 10:57 AM CST Associated Case Party: VASHONE RHODES Name BarNumber | Email TimestampSubmitted Status Amy Witherite 788698 amy.witherite@witheritelaw.com 1/18/2023 10:05:34 AM SENT Shelly Tomlin Greco | 24008168 shelly.greco@witheritelaw.com 1/18/2023 10:05:34 AM SENT Paige Eldridge paige.eldridge@ewlawyers.com 1/18/2023 10:05:34 AM SENT Paige Eldridge paige.eldridge@witheritelaw.com 1/18/2023 10:05:34 AM SENT Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC Name BarNumber Email TimestampSubmitted Status Johnny W. Breeze 796248 eservice@lecronelaw.com 1/18/2023 10:05:34 AM SENT Randall GWalters waltersedocsnotifications@wbclawfirm.com 1/18/2023 10:05:34 AM SENT Nadine K Weatherall nadine.weatherall@wbclawfirm.com 1/18/2023 10:05:34 AM SENT Randall GWalters randy.walters@wbclawfirm.com 1/18/2023 10:05:34 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status V. Paige Eldridge paige.eldridge@witheritelaw.com 1/18/2023 10:05:34 AM SENT PAIGE VELDRIDGE paige.eldridqe@ewlawyers.com 1/18/2023 10:05:34 AM ERROR Craig Laird PCL@LAIRD.LAWYER 1/18/2023 10:05:34 AM SENT Associated Case Party: GEICO COUNTY MUTUAL INSURANCE COMPANY Name BarNumber Email TimestampSubmitted | Status William Schultz wschultz@geico.com 1/18/2023 10:05:34 AM | SENT Melissa Webb mwebb@geico.com 1/18/2023 10:05:34 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. Dianne Davis on behalf of William Schultz Bar No. 794609 diadavis@geico.com Envelope ID: 71886671 Status as of 1/18/2023 10:57 AM CST Associated Case Party: GEICO COUNTY MUTUAL INSURANCE COMPANY Dianne Davis diadavis@geico.com 1/18/2023 10:05:34 AM | SENT Associated Case Party: JAMES GOMEZ Name BarNumber | Email TimestampSubmitted | Status Adam LeCrone eservice@lecronelaw.com | 1/18/2023 10:05:34 AM | SENT