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.
Preview
FILED
9/29/2022 5:36 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Rhonda Burks DEPUTY
CAUSE NO. DC-19-10926
VASHONE RHODES; THE DISTRICT COURT
§§§§§§§§§§
IN
Plaintiff,
VS. DALLAS COUNTY, TEXAS
JAMES GOMEZ; AND EXCLUSIVE
NATIONWIDE DELIVERY, INC.;
Defendants. 160T” JUDICIAL DISTRICT
PLAINTIFF’S FIRST AMENDED TR|A_L EXHIBIT LIST
PLAINTIFF Vashone Rhodes files Plaintiff’s First Amended Trial Exhibit List as
follows:
EXHIBIT DOCUMENT DESCRIPTION ADMITTED DENIED
NO.
1. Economic Damages Chart
2. Color photograph of Plaintiff’s property
damage
3. Video of Defendant driving away from scene
pulling trailer
4. Google Earth photographs to depict the
area and roadway of the wreck
5. Defendant’s Certified Driving Record
6. Certified copy of Texas Department of
Public Safety, Travis County, Texas
Pertaining to James Gomez
7. Defendant James Gomez’s cell phone
records — AT&T Mobility, LLC
8. Medical records and affidavit of Premier
Injury Clinics of DFW from 11/28/2018 to
01/03/2019
PLAINTIFF'S FIRST AMENDED TRIAL EXHIBIT LIST — Page 1
Billing records and affidavit of Premier Injury
Clinics of DFW from 11/28/2018 to
01/03/2019
10. Medical records and affidavit of MRI
Centers of Texas from 12/04/2018 to
12/18/2018
11. Billing records and affidavit of MRI Centers
of Texas from 12/04/2018 to 12/18/2018
12. Radiology records and affidavit of MRI
Centers of Texas from 12/04/2018 to
12/18/2018
13. Billing records and affidavit of Dallas
Radiology, P.A. from 12/04/2018
14. Billing records and affidavit of Uptown
Radiology Associates from 12/08/2018
15. Medical records and affidavit of MDN Injury
Care, P.A. from 12/26/2018 - 01/18/2019
16. Billing records and affidavit of MDN Injury
Care, P.A. from 12/26/2018 - 01/18/2019
17. Medical records and affidavit of Orthopaedic
& Spine Specialists of Texas, LLC from
02/01/2019 - 01/04/2021
18. Billing records and affidavit of Orthopaedic
& Spine Specialists of Texas, LLC from
02/01/2019 - 01/04/2021
19. Medical records and affidavit of Prime
Imaging Partners from 02/26/2019 -
12/22/2020
20. Billing records and affidavit of Prime
Imaging Partners from 02/26/2019 -
12/22/2020
PLAINTIFF'S FIRST AMENDED TRIAL EXHIBIT LIST — Page 2
21. Radiology records and affidavit of Prime
Imaging Partners from 02/26/2019 -
12/22/2020
22. Medical records and affidavit of Epic Pain &
Orthopedics from 08/06/2019 - 09/16/2019
23. Billing records and affidavit of Epic Pain &
Orthopedics from 08/06/2019 - 09/16/2019
24. Medical records and affidavit of ATl Physical
Therapy - N. Lakeshore from 07/23/2020 -
12/02/2020
25. Billing records and affidavit of ATl Physical
Therapy - N. Lakeshore from 07/23/2020 -
12/02/2020
26. Defendant produced photographs of the
subject Ford F-250
27. Defendant produced photographs of the
Mercedes 8550
Additionally, Plaintiff reserves the right to mark and admit any records or
documents identified on Defendants' Exhibit List and/or produced throughout discovery
by any party. Plaintiff may use other materials not admitted as exhibits as demonstrative
aids such as a Google map, medical demonstratives, photographs, etc.
PLAINTIFF'S FIRST AMENDED TRIAL EXHIBIT LIST — Page 3
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
shel|v.qreco@witheritelaw.com
10440 N. Central Expressway
Suite 400
Dallas, TX 75231-2228
214/378-6665
214/378-6670 (fax)
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
|
hereby certify that a true and correct copy of the foregoing has been fonNarded
to all counsel of record on this 29‘“ day of September, 2022, pursuant to the Texas
Rules of Civil Procedure.
/s/ V. Paige Eldridge
V. Paige Eldridge
Randall G. Walters
Nadine Weatherall
Walters, Balido & Crain, LLP
Meadow Park Tower, 15th Floor
10440 North Central Expressway
Dallas, TX 75231
Adam B. LeCrone
John W. Breeze
The LeCrone Law Firm, P.C.
Wall Street Plaza
123 N. Crockett Street, Suite 200
Sherman,TX 75090
PLAINTIFF'S FIRST AMENDED TRIAL EXHIBIT LIST — Page 4
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.
Alexa Thompson on behalf of Paige Eldridge
Bar No. 24096747
alexa.thompson@witheritelaw.com
Envelope ID: 68762574
Status as of 9/30/2022 8:31 AM CST
Associated Case Party: VASHONE RHODES
Name BarNumber Email TimestampSubmitted Status
Paige Eldridge paige.eldridge@witheritelaw.com 9/29/2022 5:36:10 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.
Alexa Thompson on behalf of Paige Eldridge
Bar No. 24096747
alexa.thompson@witheritelaw.com
Envelope ID: 68762574
Status as of 9/30/2022 8:31 AM CST
Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC
Name BarNumber Email TimestampSubmitted Status
Randall GWalters waltersedocsnotifications@wbclawfirm.com 9/29/2022 5:36:10 PM SENT
Nadine K Weatherall nadine.weatherall@wbclawfirm.com 9/29/2022 5:36:10 PM SENT
Randall GWalters randy.walters@wbclawfirm.com 9/29/2022 5:36:10 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.
Alexa Thompson on behalf of Paige Eldridge
Bar No. 24096747
alexa.thompson@witheritelaw.com
Envelope ID: 68762574
Status as of 9/30/2022 8:31 AM CST
Associated Case Party: JAMES GOMEZ
Name BarNumber Email TimestampSubmitted Status
Adam LeCrone eservice@|ecronelaw.com 9/29/2022 5:36:10 PM SENT
Document Filed Date
September 29, 2022
Case Filing Date
August 02, 2019
Category
MOTOR VEHICLE ACCIDENT
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Preview
FILED 9/29/2022 5:36 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Rhonda Burks DEPUTY CAUSE NO. DC-19-10926 VASHONE RHODES; THE DISTRICT COURT §§§§§§§§§§ IN Plaintiff, VS. DALLAS COUNTY, TEXAS JAMES GOMEZ; AND EXCLUSIVE NATIONWIDE DELIVERY, INC.; Defendants. 160T” JUDICIAL DISTRICT PLAINTIFF’S FIRST AMENDED TR|A_L EXHIBIT LIST PLAINTIFF Vashone Rhodes files Plaintiff’s First Amended Trial Exhibit List as follows: EXHIBIT DOCUMENT DESCRIPTION ADMITTED DENIED NO. 1. Economic Damages Chart 2. Color photograph of Plaintiff’s property damage 3. Video of Defendant driving away from scene pulling trailer 4. Google Earth photographs to depict the area and roadway of the wreck 5. Defendant’s Certified Driving Record 6. Certified copy of Texas Department of Public Safety, Travis County, Texas Pertaining to James Gomez 7. Defendant James Gomez’s cell phone records — AT&T Mobility, LLC 8. Medical records and affidavit of Premier Injury Clinics of DFW from 11/28/2018 to 01/03/2019 PLAINTIFF'S FIRST AMENDED TRIAL EXHIBIT LIST — Page 1 Billing records and affidavit of Premier Injury Clinics of DFW from 11/28/2018 to 01/03/2019 10. Medical records and affidavit of MRI Centers of Texas from 12/04/2018 to 12/18/2018 11. Billing records and affidavit of MRI Centers of Texas from 12/04/2018 to 12/18/2018 12. Radiology records and affidavit of MRI Centers of Texas from 12/04/2018 to 12/18/2018 13. Billing records and affidavit of Dallas Radiology, P.A. from 12/04/2018 14. Billing records and affidavit of Uptown Radiology Associates from 12/08/2018 15. Medical records and affidavit of MDN Injury Care, P.A. from 12/26/2018 - 01/18/2019 16. Billing records and affidavit of MDN Injury Care, P.A. from 12/26/2018 - 01/18/2019 17. Medical records and affidavit of Orthopaedic & Spine Specialists of Texas, LLC from 02/01/2019 - 01/04/2021 18. Billing records and affidavit of Orthopaedic & Spine Specialists of Texas, LLC from 02/01/2019 - 01/04/2021 19. Medical records and affidavit of Prime Imaging Partners from 02/26/2019 - 12/22/2020 20. Billing records and affidavit of Prime Imaging Partners from 02/26/2019 - 12/22/2020 PLAINTIFF'S FIRST AMENDED TRIAL EXHIBIT LIST — Page 2 21. Radiology records and affidavit of Prime Imaging Partners from 02/26/2019 - 12/22/2020 22. Medical records and affidavit of Epic Pain & Orthopedics from 08/06/2019 - 09/16/2019 23. Billing records and affidavit of Epic Pain & Orthopedics from 08/06/2019 - 09/16/2019 24. Medical records and affidavit of ATl Physical Therapy - N. Lakeshore from 07/23/2020 - 12/02/2020 25. Billing records and affidavit of ATl Physical Therapy - N. Lakeshore from 07/23/2020 - 12/02/2020 26. Defendant produced photographs of the subject Ford F-250 27. Defendant produced photographs of the Mercedes 8550 Additionally, Plaintiff reserves the right to mark and admit any records or documents identified on Defendants' Exhibit List and/or produced throughout discovery by any party. Plaintiff may use other materials not admitted as exhibits as demonstrative aids such as a Google map, medical demonstratives, photographs, etc. PLAINTIFF'S FIRST AMENDED TRIAL EXHIBIT LIST — Page 3 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 shel|v.qreco@witheritelaw.com 10440 N. Central Expressway Suite 400 Dallas, TX 75231-2228 214/378-6665 214/378-6670 (fax) ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE | hereby certify that a true and correct copy of the foregoing has been fonNarded to all counsel of record on this 29‘“ day of September, 2022, pursuant to the Texas Rules of Civil Procedure. /s/ V. Paige Eldridge V. Paige Eldridge Randall G. Walters Nadine Weatherall Walters, Balido & Crain, LLP Meadow Park Tower, 15th Floor 10440 North Central Expressway Dallas, TX 75231 Adam B. LeCrone John W. Breeze The LeCrone Law Firm, P.C. Wall Street Plaza 123 N. Crockett Street, Suite 200 Sherman,TX 75090 PLAINTIFF'S FIRST AMENDED TRIAL EXHIBIT LIST — Page 4 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. Alexa Thompson on behalf of Paige Eldridge Bar No. 24096747 alexa.thompson@witheritelaw.com Envelope ID: 68762574 Status as of 9/30/2022 8:31 AM CST Associated Case Party: VASHONE RHODES Name BarNumber Email TimestampSubmitted Status Paige Eldridge paige.eldridge@witheritelaw.com 9/29/2022 5:36:10 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. Alexa Thompson on behalf of Paige Eldridge Bar No. 24096747 alexa.thompson@witheritelaw.com Envelope ID: 68762574 Status as of 9/30/2022 8:31 AM CST Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC Name BarNumber Email TimestampSubmitted Status Randall GWalters waltersedocsnotifications@wbclawfirm.com 9/29/2022 5:36:10 PM SENT Nadine K Weatherall nadine.weatherall@wbclawfirm.com 9/29/2022 5:36:10 PM SENT Randall GWalters randy.walters@wbclawfirm.com 9/29/2022 5:36:10 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. Alexa Thompson on behalf of Paige Eldridge Bar No. 24096747 alexa.thompson@witheritelaw.com Envelope ID: 68762574 Status as of 9/30/2022 8:31 AM CST Associated Case Party: JAMES GOMEZ Name BarNumber Email TimestampSubmitted Status Adam LeCrone eservice@|ecronelaw.com 9/29/2022 5:36:10 PM SENT