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.
Preview
FILED
9/6/2023 5:15 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Jenifer Trujillo DEPUTY
CAUSE NO. DC-19-10926
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 FIRST AMENDED
PAGE/LINE DESIGNATIONS 0F DEPOSITION TESTIMONY AND CROSS-
DESIGNATIONS
TO THE HONORABLE IUDGE 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 Startinwith “you submitted . . .” 8:17
9:10 11:4 Ending at“. . . illness or injury.”
11:8 Starting with “I want to . . .” 12:14
12:19 14:11 Ending at“. . . experienced.”
14:15 14:25
15: 13 Starting with “Dr. Wood . . .” 15:17
16:1 16:16
16:18 Starting with “someone from . . .” 16:25 Ending at“. . . That’s correct.”
17:4 17:25
18:9 Starting with “from your . . .” 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 FIRST AMENDED
PAGE/LINE DESIGNATIONS OF DEPOSITION TESTIMONY AND CROSS-DESIGNATIONS 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 Startigwith “you’ve looked at...” 96:13
102:3 102:20
Cross-Designations of Oral and Videotaped Deposition of Rawson Wood. MD
START END
38:1 38:3
41:21 Starting with “butI . . .” 41:23
43:5 Starting with “It may or may not . . .” 43:7
46:5 46: 14 Ending at “line is,”
47:15 Starting with “because it’s not . . .” 47:18
49:2 Starting with “That would not . . .” 49:3
54:22 Starting with “but my exemplar” 54:23
55: 15 Starting with “I know that his . . .” 55:17
57:22 Starting with “This is me . . .” 57:24
60: 18 Starting wit “. . . but it transitioned , , .” 60: 19
61 :3 Starting with “The majority of the . . .” 61:10
61:18 61 :24
63:7 Starting with “it’s a sideswipe . . .” 63:13 Ending at“ . . .as a sideswipe.”
71:11 Starting with “You asked at what . . .” 71:17
72:25 Starting with “You have to do . . .” 73:1
74:3 Starting with “I did it as part of . . .” 74:7 Ending at “this type of collision.”
74:8 Starting with “I did not do . . .” 74:10
80:17 Starting with “I know that he has . . .” 80:20
83:8 Starting with “for the whole . . .” 83:8
101 :2 Starting with “that’s not true at all.” 101:1 l
101:17 Starting with “I didn’t . . .” 101 :20
103:11 103:20 Ending at “I just — I .”
104: 10 Starting with “this level . . .” 104:20
Ora_l 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
DEFENDANT EXCLUSIVE NATIONWIDE DELIVERY INC.’S FIRST AMENDED
PAGE/LINE DESIGNATIONS OF DEPOSITION TESTIMONY AND CROSS-DESIGNATIONS PAGE 2
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
Cross-Designations of Ora_l and Videotaml Deposition 0f Francisco S. Gomez
START END
10:16 10:21
10:25 Starting with “So who else . . .” 11:1
11:3 Starting with “I don’t know who else . . .” 11:5
1 1:18 11:21
22:20 23:3
23:11 23:20 Ending at “Both.”
24:6 24:8
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@wbclawfirm.com
Meadow Park Tower, Suite 1500
10440 North Central Expressway
Dallas, Texas 75231
(214) 204-2400 — DIRECT
(214) 204-2100 — MAIN
(214) 204-2101 — FAX
ATTORNEYS FOR DEFENDANT
EXCLUSIVE NATIONWIDE DELIVERY INC.
DEFENDANT EXCLUSIVE NATIONWIDE DELIVERY INC.’S FIRST AMENDED
PAGE/LINE DESIGNATIONS 0F DEPOSITION TESTIMONY AND CROSS-DESIGNATIONS PAGE 3
CERTIFICATE OF SERVICE
This is to certify that on this the 6th day of September, 2023, 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 FIRST AMENDED
PAGE/LINE DESIGNATIONS 0F DEPOSITION TESTIMONY AND CROSS-DESIGNATIONS 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.
Araceli Guajardo on behalf of Randall Walters
Bar No. 20819480
aguajardo@wbclawfirm.com
Envelope ID: 79281629
Filing Code Description: Designation Of Deposition
Filing Description: DEFENDANTS 1ST AMENDED & CROSS
DESIGNATIONS
Status as of 9/7/2023 8:23 AM CST
Associated Case Party: VASHONE RHODES
Name BarNumber Email TimestampSubmitted Status
Amy Witherite 788698 amy.witherite@witheritelaw.com 9/6/2023 5:15:08 PM SENT
Shelly Tomlin Greco 24008168 shelly@greco.net 9/6/2023 5:15:08 PM SENT
V. Paige Eldridge paige.eldridge@witheritelaw.com 9/6/2023 5:15:08 PM SENT
Paige Eldridge paige.eldridge@ewlawyers.com 9/6/2023 5:15:08 PM SENT
Paige Eldridge paige.eldridge@witheritelaw.com 9/6/2023 5:15:08 PM SENT
Associated Case Party: JAMES GOMEZ
Name BarNumber Email TimestampSubmitted Status
Adam LeCrone eservice@lecronelaw.com 9/6/2023 5:15:08 PM SENT
John W.Breeze eservice@lecronelaw.com 9/6/2023 5:15:08 PM SENT
Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC
Name BarNumber Email TimestampSubmitted Status
Johnny W. Breeze 796248 eservice@lecronelaw.com 9/6/2023 5:15:08 PM SENT
Randall GWalters waltersedocsnotifications@wbclawfirm.com 9/6/2023 5:15:08 PM SENT
Nadine K Weatherall nadine.weatherall@wbclawfirm.com 9/6/2023 5:15:08 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
William Schultz wschultz@geico.com 9/6/2023 5:15:08 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.
Araceli Guajardo on behalf of Randall Walters
Bar No. 20819480
aguajardo@wbclawfirm.com
Envelope ID: 79281629
Filing Code Description: Designation Of Deposition
Filing Description: DEFENDANTS 1ST AMENDED & CROSS
DESIGNATIONS
Status as of 9/7/2023 8:23 AM CST
Case Contacts
PAIGE VELDRIDGE paiqe.eldridqe@ewlawyers.com 9/6/2023 5:15:08 PM SENT
Craig Laird PCL@LAIRD.LAWYER 9/6/2023 5:15:08 PM SENT
Melissa Webb mwebb@geico.com 9/6/2023 5:15:08 PM SENT
Dianne Davis diadavis@geico.com 9/6/2023 5:15:08 PM SENT
Document Filed Date
September 06, 2023
Case Filing Date
August 02, 2019
Category
MOTOR VEHICLE ACCIDENT
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FILED 9/6/2023 5:15 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Jenifer Trujillo DEPUTY CAUSE NO. DC-19-10926 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 FIRST AMENDED PAGE/LINE DESIGNATIONS 0F DEPOSITION TESTIMONY AND CROSS- DESIGNATIONS TO THE HONORABLE IUDGE 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 Startinwith “you submitted . . .” 8:17 9:10 11:4 Ending at“. . . illness or injury.” 11:8 Starting with “I want to . . .” 12:14 12:19 14:11 Ending at“. . . experienced.” 14:15 14:25 15: 13 Starting with “Dr. Wood . . .” 15:17 16:1 16:16 16:18 Starting with “someone from . . .” 16:25 Ending at“. . . That’s correct.” 17:4 17:25 18:9 Starting with “from your . . .” 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 FIRST AMENDED PAGE/LINE DESIGNATIONS OF DEPOSITION TESTIMONY AND CROSS-DESIGNATIONS 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 Startigwith “you’ve looked at...” 96:13 102:3 102:20 Cross-Designations of Oral and Videotaped Deposition of Rawson Wood. MD START END 38:1 38:3 41:21 Starting with “butI . . .” 41:23 43:5 Starting with “It may or may not . . .” 43:7 46:5 46: 14 Ending at “line is,” 47:15 Starting with “because it’s not . . .” 47:18 49:2 Starting with “That would not . . .” 49:3 54:22 Starting with “but my exemplar” 54:23 55: 15 Starting with “I know that his . . .” 55:17 57:22 Starting with “This is me . . .” 57:24 60: 18 Starting wit “. . . but it transitioned , , .” 60: 19 61 :3 Starting with “The majority of the . . .” 61:10 61:18 61 :24 63:7 Starting with “it’s a sideswipe . . .” 63:13 Ending at“ . . .as a sideswipe.” 71:11 Starting with “You asked at what . . .” 71:17 72:25 Starting with “You have to do . . .” 73:1 74:3 Starting with “I did it as part of . . .” 74:7 Ending at “this type of collision.” 74:8 Starting with “I did not do . . .” 74:10 80:17 Starting with “I know that he has . . .” 80:20 83:8 Starting with “for the whole . . .” 83:8 101 :2 Starting with “that’s not true at all.” 101:1 l 101:17 Starting with “I didn’t . . .” 101 :20 103:11 103:20 Ending at “I just — I .” 104: 10 Starting with “this level . . .” 104:20 Ora_l 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 DEFENDANT EXCLUSIVE NATIONWIDE DELIVERY INC.’S FIRST AMENDED PAGE/LINE DESIGNATIONS OF DEPOSITION TESTIMONY AND CROSS-DESIGNATIONS PAGE 2 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 Cross-Designations of Ora_l and Videotaml Deposition 0f Francisco S. Gomez START END 10:16 10:21 10:25 Starting with “So who else . . .” 11:1 11:3 Starting with “I don’t know who else . . .” 11:5 1 1:18 11:21 22:20 23:3 23:11 23:20 Ending at “Both.” 24:6 24:8 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@wbclawfirm.com Meadow Park Tower, Suite 1500 10440 North Central Expressway Dallas, Texas 75231 (214) 204-2400 — DIRECT (214) 204-2100 — MAIN (214) 204-2101 — FAX ATTORNEYS FOR DEFENDANT EXCLUSIVE NATIONWIDE DELIVERY INC. DEFENDANT EXCLUSIVE NATIONWIDE DELIVERY INC.’S FIRST AMENDED PAGE/LINE DESIGNATIONS 0F DEPOSITION TESTIMONY AND CROSS-DESIGNATIONS PAGE 3 CERTIFICATE OF SERVICE This is to certify that on this the 6th day of September, 2023, 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 FIRST AMENDED PAGE/LINE DESIGNATIONS 0F DEPOSITION TESTIMONY AND CROSS-DESIGNATIONS 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. Araceli Guajardo on behalf of Randall Walters Bar No. 20819480 aguajardo@wbclawfirm.com Envelope ID: 79281629 Filing Code Description: Designation Of Deposition Filing Description: DEFENDANTS 1ST AMENDED & CROSS DESIGNATIONS Status as of 9/7/2023 8:23 AM CST Associated Case Party: VASHONE RHODES Name BarNumber Email TimestampSubmitted Status Amy Witherite 788698 amy.witherite@witheritelaw.com 9/6/2023 5:15:08 PM SENT Shelly Tomlin Greco 24008168 shelly@greco.net 9/6/2023 5:15:08 PM SENT V. Paige Eldridge paige.eldridge@witheritelaw.com 9/6/2023 5:15:08 PM SENT Paige Eldridge paige.eldridge@ewlawyers.com 9/6/2023 5:15:08 PM SENT Paige Eldridge paige.eldridge@witheritelaw.com 9/6/2023 5:15:08 PM SENT Associated Case Party: JAMES GOMEZ Name BarNumber Email TimestampSubmitted Status Adam LeCrone eservice@lecronelaw.com 9/6/2023 5:15:08 PM SENT John W.Breeze eservice@lecronelaw.com 9/6/2023 5:15:08 PM SENT Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC Name BarNumber Email TimestampSubmitted Status Johnny W. Breeze 796248 eservice@lecronelaw.com 9/6/2023 5:15:08 PM SENT Randall GWalters waltersedocsnotifications@wbclawfirm.com 9/6/2023 5:15:08 PM SENT Nadine K Weatherall nadine.weatherall@wbclawfirm.com 9/6/2023 5:15:08 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status William Schultz wschultz@geico.com 9/6/2023 5:15:08 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. Araceli Guajardo on behalf of Randall Walters Bar No. 20819480 aguajardo@wbclawfirm.com Envelope ID: 79281629 Filing Code Description: Designation Of Deposition Filing Description: DEFENDANTS 1ST AMENDED & CROSS DESIGNATIONS Status as of 9/7/2023 8:23 AM CST Case Contacts PAIGE VELDRIDGE paiqe.eldridqe@ewlawyers.com 9/6/2023 5:15:08 PM SENT Craig Laird PCL@LAIRD.LAWYER 9/6/2023 5:15:08 PM SENT Melissa Webb mwebb@geico.com 9/6/2023 5:15:08 PM SENT Dianne Davis diadavis@geico.com 9/6/2023 5:15:08 PM SENT