Preview
FILED
3/17/2023 5:07 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Rosa Delacerda DEPUTY
CAUSE NO. DC-20-02088
JACQUELINE MOBLEY IN THE DISTRICT COURT
Plaintiff,
V. 14TH JUDICIAL DISTRICT
MARM ORTIZ
Defendant. DALLAS COUNTY, TEXAS
DEFENDANT’S SECOND AMENDED MOTION IN LIMINE
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES MARIA ORTIZ, hereinafier referred to as "Defendant," and before any
proceedings before the jury, makes and files this SECOND AMENDED MOTION IN LIMINE,
and respectfully moves the Court to instruct Plaintiff and Plaintiff s counsel to refrain from either
directly or indirectly, upon voir dire examination, opening statement, interrogation of witnesses,
introduction of any evidence, argument, objections before the jury, reading of any portion of the
pleadings, or by any other means or in any other manner, informing the jury, or bringing to the
jury's attention, any of the matters set forth in the numbered paragraphs below, unless and until
such matters have been first called to the attention of the Court, out of the presence and/or hearing
of the jury, and a favorable ruling has been obtained from the Court as to the admissibility and
relevance of any such matters:
1. Insurance. Unless an insurance company is a named Defendant, that the Defendant is
or is not protected, in whole or in part, by liability insurance, or that defense counsel
was retained by, or all or any part of the costs of defense, or of any resulting judgment,
are or will be paid by an insurance company, or any other matter suggesting an
involvement of any insurance company with the defense of the case.
2. J_urors' Connection with Insurance Industry. Inquiring of potential jurors as to their
present or past employment or connection with the insurance industry, or present or
past connection of any family member with the insurance industry, except that:
a) If a potential juror's juror information card discloses employment in the insurance
industry, such potential juror may be questioned concerning same.
Mobley vs. Ortiz PAGE 1
DEFENDANT’S SECOND AMENDED MOTION IN LIMINE
b) Inquiry may be made of potential jurors concerning their experience (or that of
members of their family), if any, reviewing, adjusting or allowing/disallowing
claims, as long as no express reference is made to "insurance."
3. Liability or Non-Liabilitv for Judgment. That the named Defendant(s) may or may
not have to pay any resulting judgment.
4. Attorneys' Fees. That any party will have to pay attorneys' fees, or any reference to
the amount or basis of any attorneys' fees, unless a claim for recovery of attorneys' fees
in the case will be submitted to the jury.
5. Criminal Offenses. That any party or Witness has been suspected of, arrested for,
charged with or convicted of any criminal offense unless there is evidence of a specific
conviction that the Court has previously ruled is admissible in the case.
6. Alcohol or Drug Use. That any party or witness uses or abuses alcohol, tobacco, or
any controlled substance, unless and until such alleged use or abuse is shown to be
specifically relevant to the matters in controversy. Amoco Chemicals Corp. vs.
Stafford, 663 S.W.2d 147 (Tex. App—Houston [1“ Dist.] 1983, no writ).; TRCE
801(d); TRCE 403.
7. Settlement Negotiations or Mediation. Any negotiations, offers or demands with
respect to any attempted settlement or mediation. TRCE 408; Beutel vs. Paul, 741
S.W.2d 510 (Tex. AppiHouston [14th Dist.] 1987, no writ).
8. Discovery Disputes. Any reference to discovery disputes that arose during the
preparation of the case for trial, any position taken by any party with respect thereto,
or to the Court's rulings thereon.
9. Hearsay Medical Opinions. Any hearsay statement offered for the truth of the
statement by an allegedly injured person concerning any diagnosis or medical opinions
communicated to such person by a physician or other health care provider. Such would
be an attempt to introduce before the jury expert testimony without a proper predicate
concerning the expert’s qualifications and abilities to give such testimony. Defendant
would note that TRE 803(4) specifically excepts statements made to a medical
provider for diagnosis or treatment from the hearsay rule. This does not apply to
statements by a medical provider to the patient. The idea is that an individual is
unlikely to lie to a medical provider since they want an accurate diagnosis and
appropriate treatment. Conversely, there is not the same reassurance of truthfulness
when it comes to an individual stating what the doctor told them in the middle of a
personal injury jury trial for money damages.
10. Requests for Stipulations. Any request or demand in the presence of the jury for a
stipulation to any fact, or that counsel admit or deny any fact.
11. Reguests for Files. Any request or demand in the presence of the jury that opposing
counsel produce any document or thing, or that opposing counselor any party or witness
Mobley vs. Ortiz PAGE 2
DEFENDANT’S SECOND AMENDED MOTION IN LIMINE
exhibit, turn over or allow examination of the contents of any file or briefcase (except
that a party may demand to see a document used by a witness on the stand to refresh
his/her recollection, or that a witness testifies that he/she has used previously to refresh
his/her recollection).
12. Discrimination. Any argument that a party should be treated more or less favorably
because of such party's race, gender, national origin, nationality, religion, marital
status, occupation, or financial status (except in the second phase of a bifiircated trial).
13. Hardship or Privation. Any argument or suggestion that a failure to award damages
will cause a Plaintiff privation or financial hardship except that Plaintiff s counsel may
certainly argue that Plaintiff has a particular amount of money outstanding for past
medical bills.
14. Golden Rule. Any argument or suggestion that the jurors should put themselves in the
position of a party. World Wide Tire C0. vs. Brown, 644 S.W.2d 144 (Tex. App.-
Houston [14m Dist.] 1982, writ refd n.r.e.).
15. Effect of Answers to Jury Questions. Any argument that any finding or failure to
find in response to a particular jury question will or will not result in a judgment
favorable to any party. This provision does not bar argument by counsel that a
particular jury question should be answered in a particular way. Cooper vs. Argonaut
Insurance Co., 430 S.W. 2d. 35 (Tex. Civ. App—Dallas 1968, writ refd n.r.e.). Such
argument is improper under the Texas special verdict system because it advises the jury
of the effect of its answers.
16. Obi ections to Evidence Not Produced in Discovery. Any objection based on failure
to disclose evidence in pre-trial discovery. Any party desiring to urge any such
objection shall request to approach the bench and urge such objection outside the
hearing of the jury. To the extent possible or predictable, such matters should be
addressed and a ruling sought at pretrial once the case is assigned for trial, although the
objection may be urged for the record outside the hearing of the jury at the time such
evidence is offered in the event the Court has overruled the objection at pretrial.
17. Qualifying Exnert Witness. Calling any witness to testify as an expert without having
first been qualified as an expert for those matters which were disclosed in response to
Request for Disclosure. In addition, prior to the expert stating any opinion he must be
required to disclose the underlying facts or data which forms his “expert” opinion
pursuant to Rule 705 of the Texas Rules of Evidence.
18. Available Assets. Any inquiry into or reference to the assets Defendant has available
for investigating, preparing and defending this cause. First Nat’l Bank ofMarshall vs.
Beavers, 619 S.W.2d 288 (Tex. Civ. App.—Texarkana 1981, writ ref’ d n.r.e.); Wimoth
vs. Limestone Prods. Co., 255 S.W.2d 532, 534 (Tex. App—Waco 1953, writ ref’ d
n.r.e.).
19. Superseded Pleadings. The contents of any pleadings which have been superseded
by the current pleadings on file in this case. Zock vs. Bank of the Southwest National
Mobley vs. Ortiz PAGE 3
DEFENDANT’S SECOND AMENDED MOTION IN LIMINE
Association, Houston, 464 S.W.2d 375 (Tex. Civ. App—Houston [14th Dist] 1971, no
writ).
20. Voir Dire — Pre-testing Evidence / Previewing Verdict. Any inquiry attempting to
determine the weight jurors will give to the evidence. If a question does not seek to
discover a disqualifying bias or prejudice but seeks to determine the weight jurors will
give to the evidence, such question is an improper attempt to pre-test the evidence and
preview the verdict and therefore objectionable. Hvundai Motor Co. v. Vasquez, 189
S.W.3d 743 (Tex. 2006).
21. Prior Automobile Accidents. Any inquiry into or disclosing that the Defendant(s)
has/have been involved in any prior or subsequent automobile accident. Any testimony
regarding previous or subsequent accidents is irrelevant and far too prejudicial to
discuss before the jury.
22. Prior Speeding Tickets. Any inquiry into or disclosing that the Defendant has ever
been issued any speeding tickets prior to or subsequent to this accident. As the Texas
Supreme Court wrote in Missouri-Kansas-Texas Railroad Co. vs. May, 600 S.W.2d.
755 (Tex. 1980), “as a general rule, evidence of similar acts is inadmissible on the issue
of whether someone was a negligent in doing or not doing a particular act.”
23. Investigative Officer’s Opinion. Any inquiry or reference to the fact that the
investigative officer has formed an opinion or determined a cause of the accident or
that one of the drivers was at fault until the qualifications of the officer has been
established. Pilgrim’s Pride Corp. vs. Smoak, 134 S.W. 3rd 880, (Tex. App.—
Texarkana, 2004, pet. denied) (investigating officer's testimony on accident causation
was required to be given by a qualified person in science of accident reconstruction.)
See also DeLarue vs. State, 102 S.W.3d 388, Tex. App—Houston, [14th Dist] 2003;
and Ter— Vartanyan vs. R&R Freight, Ina, 111 S.W. 3rd 779, Tex. App—Dallas, 2003,
pet. denied).
24. Issuance of any traffic ticket. Any inquiry or reference to the fact that Defendant was
issued a ticket for a traffic Violation arising out of the alleged negligence giving rise to
the charge, absent proof of a “guilty plea in open court”. Texas Rules of Evidence,
Rule 410; Cox v. Bohman, 683 S.W.2d 757, (Tex.App. — Corpus Christi 1984, writ
refused n.r.e.); Switzer v. Johnson, 432 S.W.2d 164 (Tex.App. — Houston, 1968 no
writ).
25. Defendant’s Medical Treatment. Any inquiry or reference to whether or not
Defendant was injured in this motor vehicle collision and/or sought medical treatment
as a result of this motor vehicle collision as Defendant’s medical conditions and
treatments are not relevant to Plaintiffs claims, any inquiries or references would be
an invasion of Defendant’s privacy, and Defendant would argue that any probative
value would be outweighed by the confusion caused to the jury over this issue.
26. Photographs. Showing any photographs to the jury until the same has been tendered
to opposing counsel and admitted into evidence.
Mobley vs. Ortiz PAGE 4
DEFENDANT’S SECOND AMENDED MOTION IN LIMINE
27. Comments on “sending a message.” Plaintiff be prohibited fiom making any
argument, comment or inference during any phase of this trial that Defendant should
be held accountable or responsible for the purpose of sending a message on behalf of
society as a whole or sending a message that a particular behavior Will not be
tolerated. This is because it appeals to a juror’s fear and plays upon bias, prejudice or
sympathy rather than a principled weighing of What the credible evidence shows.
Respectfiilly submitted,
LISA CHASTAIN & ASSOCIATES
(MM
JENNIFER MOK
TBN: 24130743
P.O. Box 655441
Dallas, TX 75265
E-Service Only: DallasLegal@allstate.com
(469) 428-1016
(877) 678-4763 (fax)
ATTORNEY FOR DEFENDANT(S)
MARIA ORTIZ
Mobley vs. Ortiz PAGE 5
DEFENDANT’S SECOND AMENDED MOTION IN LIMINE
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been served in compliance
with Rules 21 and 21a of the Texas Rules of Civil Procedure on March 17, 2023, to:
ROLLE LAW
Heather V. Banahan Nease
State Bar No. 24090959
2030 Main Street, Suite 200
Dallas, Texas 75201
heathern@rbrl.com
Tel: (214) 742-8897
Fax: (214) 637-6872
ATTORNEY FOR PLAINTIFF
(MM
JENNIFER MOK
Mobley vs. Ortiz PAGE 6
DEFENDANT’S SECOND AMENDED MOTION IN LIMINE
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.
Young Jenkins on behalf of Jennifer Mok
Bar No. 24130743
yjena@allstate.com
Envelope ID: 73784576
Filing Code Description: Witness List
Filing Description: SECOND AMENDED - DEFENDANT
Status as of 3/20/2023 8:51 AM CST
Associated Case Party: MARIA ORTIZ
Name BarNumber Email TimestampSubmitted Status
LARRY ROLLE Iarryr@rbrl.com 3/17/2023 5:07:23 PM SENT
Associated Case Party: JACQUELINE MOBLEY
Name BarNumber Email TimestampSubmitted Status
Heather V.Banahan Nease heathern@rbrl.com 3/17/2023 5:07:23 PM SENT
Carol Mathews carolm@rbrl.com 3/17/2023 5:07:23 PM SENT
Preview
FILED 3/17/2023 5:07 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Rosa Delacerda DEPUTY CAUSE NO. DC-20-02088 JACQUELINE MOBLEY IN THE DISTRICT COURT Plaintiff, V. 14TH JUDICIAL DISTRICT MARM ORTIZ Defendant. DALLAS COUNTY, TEXAS DEFENDANT’S SECOND AMENDED MOTION IN LIMINE TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES MARIA ORTIZ, hereinafier referred to as "Defendant," and before any proceedings before the jury, makes and files this SECOND AMENDED MOTION IN LIMINE, and respectfully moves the Court to instruct Plaintiff and Plaintiff s counsel to refrain from either directly or indirectly, upon voir dire examination, opening statement, interrogation of witnesses, introduction of any evidence, argument, objections before the jury, reading of any portion of the pleadings, or by any other means or in any other manner, informing the jury, or bringing to the jury's attention, any of the matters set forth in the numbered paragraphs below, unless and until such matters have been first called to the attention of the Court, out of the presence and/or hearing of the jury, and a favorable ruling has been obtained from the Court as to the admissibility and relevance of any such matters: 1. Insurance. Unless an insurance company is a named Defendant, that the Defendant is or is not protected, in whole or in part, by liability insurance, or that defense counsel was retained by, or all or any part of the costs of defense, or of any resulting judgment, are or will be paid by an insurance company, or any other matter suggesting an involvement of any insurance company with the defense of the case. 2. J_urors' Connection with Insurance Industry. Inquiring of potential jurors as to their present or past employment or connection with the insurance industry, or present or past connection of any family member with the insurance industry, except that: a) If a potential juror's juror information card discloses employment in the insurance industry, such potential juror may be questioned concerning same. Mobley vs. Ortiz PAGE 1 DEFENDANT’S SECOND AMENDED MOTION IN LIMINE b) Inquiry may be made of potential jurors concerning their experience (or that of members of their family), if any, reviewing, adjusting or allowing/disallowing claims, as long as no express reference is made to "insurance." 3. Liability or Non-Liabilitv for Judgment. That the named Defendant(s) may or may not have to pay any resulting judgment. 4. Attorneys' Fees. That any party will have to pay attorneys' fees, or any reference to the amount or basis of any attorneys' fees, unless a claim for recovery of attorneys' fees in the case will be submitted to the jury. 5. Criminal Offenses. That any party or Witness has been suspected of, arrested for, charged with or convicted of any criminal offense unless there is evidence of a specific conviction that the Court has previously ruled is admissible in the case. 6. Alcohol or Drug Use. That any party or witness uses or abuses alcohol, tobacco, or any controlled substance, unless and until such alleged use or abuse is shown to be specifically relevant to the matters in controversy. Amoco Chemicals Corp. vs. Stafford, 663 S.W.2d 147 (Tex. App—Houston [1“ Dist.] 1983, no writ).; TRCE 801(d); TRCE 403. 7. Settlement Negotiations or Mediation. Any negotiations, offers or demands with respect to any attempted settlement or mediation. TRCE 408; Beutel vs. Paul, 741 S.W.2d 510 (Tex. AppiHouston [14th Dist.] 1987, no writ). 8. Discovery Disputes. Any reference to discovery disputes that arose during the preparation of the case for trial, any position taken by any party with respect thereto, or to the Court's rulings thereon. 9. Hearsay Medical Opinions. Any hearsay statement offered for the truth of the statement by an allegedly injured person concerning any diagnosis or medical opinions communicated to such person by a physician or other health care provider. Such would be an attempt to introduce before the jury expert testimony without a proper predicate concerning the expert’s qualifications and abilities to give such testimony. Defendant would note that TRE 803(4) specifically excepts statements made to a medical provider for diagnosis or treatment from the hearsay rule. This does not apply to statements by a medical provider to the patient. The idea is that an individual is unlikely to lie to a medical provider since they want an accurate diagnosis and appropriate treatment. Conversely, there is not the same reassurance of truthfulness when it comes to an individual stating what the doctor told them in the middle of a personal injury jury trial for money damages. 10. Requests for Stipulations. Any request or demand in the presence of the jury for a stipulation to any fact, or that counsel admit or deny any fact. 11. Reguests for Files. Any request or demand in the presence of the jury that opposing counsel produce any document or thing, or that opposing counselor any party or witness Mobley vs. Ortiz PAGE 2 DEFENDANT’S SECOND AMENDED MOTION IN LIMINE exhibit, turn over or allow examination of the contents of any file or briefcase (except that a party may demand to see a document used by a witness on the stand to refresh his/her recollection, or that a witness testifies that he/she has used previously to refresh his/her recollection). 12. Discrimination. Any argument that a party should be treated more or less favorably because of such party's race, gender, national origin, nationality, religion, marital status, occupation, or financial status (except in the second phase of a bifiircated trial). 13. Hardship or Privation. Any argument or suggestion that a failure to award damages will cause a Plaintiff privation or financial hardship except that Plaintiff s counsel may certainly argue that Plaintiff has a particular amount of money outstanding for past medical bills. 14. Golden Rule. Any argument or suggestion that the jurors should put themselves in the position of a party. World Wide Tire C0. vs. Brown, 644 S.W.2d 144 (Tex. App.- Houston [14m Dist.] 1982, writ refd n.r.e.). 15. Effect of Answers to Jury Questions. Any argument that any finding or failure to find in response to a particular jury question will or will not result in a judgment favorable to any party. This provision does not bar argument by counsel that a particular jury question should be answered in a particular way. Cooper vs. Argonaut Insurance Co., 430 S.W. 2d. 35 (Tex. Civ. App—Dallas 1968, writ refd n.r.e.). Such argument is improper under the Texas special verdict system because it advises the jury of the effect of its answers. 16. Obi ections to Evidence Not Produced in Discovery. Any objection based on failure to disclose evidence in pre-trial discovery. Any party desiring to urge any such objection shall request to approach the bench and urge such objection outside the hearing of the jury. To the extent possible or predictable, such matters should be addressed and a ruling sought at pretrial once the case is assigned for trial, although the objection may be urged for the record outside the hearing of the jury at the time such evidence is offered in the event the Court has overruled the objection at pretrial. 17. Qualifying Exnert Witness. Calling any witness to testify as an expert without having first been qualified as an expert for those matters which were disclosed in response to Request for Disclosure. In addition, prior to the expert stating any opinion he must be required to disclose the underlying facts or data which forms his “expert” opinion pursuant to Rule 705 of the Texas Rules of Evidence. 18. Available Assets. Any inquiry into or reference to the assets Defendant has available for investigating, preparing and defending this cause. First Nat’l Bank ofMarshall vs. Beavers, 619 S.W.2d 288 (Tex. Civ. App.—Texarkana 1981, writ ref’ d n.r.e.); Wimoth vs. Limestone Prods. Co., 255 S.W.2d 532, 534 (Tex. App—Waco 1953, writ ref’ d n.r.e.). 19. Superseded Pleadings. The contents of any pleadings which have been superseded by the current pleadings on file in this case. Zock vs. Bank of the Southwest National Mobley vs. Ortiz PAGE 3 DEFENDANT’S SECOND AMENDED MOTION IN LIMINE Association, Houston, 464 S.W.2d 375 (Tex. Civ. App—Houston [14th Dist] 1971, no writ). 20. Voir Dire — Pre-testing Evidence / Previewing Verdict. Any inquiry attempting to determine the weight jurors will give to the evidence. If a question does not seek to discover a disqualifying bias or prejudice but seeks to determine the weight jurors will give to the evidence, such question is an improper attempt to pre-test the evidence and preview the verdict and therefore objectionable. Hvundai Motor Co. v. Vasquez, 189 S.W.3d 743 (Tex. 2006). 21. Prior Automobile Accidents. Any inquiry into or disclosing that the Defendant(s) has/have been involved in any prior or subsequent automobile accident. Any testimony regarding previous or subsequent accidents is irrelevant and far too prejudicial to discuss before the jury. 22. Prior Speeding Tickets. Any inquiry into or disclosing that the Defendant has ever been issued any speeding tickets prior to or subsequent to this accident. As the Texas Supreme Court wrote in Missouri-Kansas-Texas Railroad Co. vs. May, 600 S.W.2d. 755 (Tex. 1980), “as a general rule, evidence of similar acts is inadmissible on the issue of whether someone was a negligent in doing or not doing a particular act.” 23. Investigative Officer’s Opinion. Any inquiry or reference to the fact that the investigative officer has formed an opinion or determined a cause of the accident or that one of the drivers was at fault until the qualifications of the officer has been established. Pilgrim’s Pride Corp. vs. Smoak, 134 S.W. 3rd 880, (Tex. App.— Texarkana, 2004, pet. denied) (investigating officer's testimony on accident causation was required to be given by a qualified person in science of accident reconstruction.) See also DeLarue vs. State, 102 S.W.3d 388, Tex. App—Houston, [14th Dist] 2003; and Ter— Vartanyan vs. R&R Freight, Ina, 111 S.W. 3rd 779, Tex. App—Dallas, 2003, pet. denied). 24. Issuance of any traffic ticket. Any inquiry or reference to the fact that Defendant was issued a ticket for a traffic Violation arising out of the alleged negligence giving rise to the charge, absent proof of a “guilty plea in open court”. Texas Rules of Evidence, Rule 410; Cox v. Bohman, 683 S.W.2d 757, (Tex.App. — Corpus Christi 1984, writ refused n.r.e.); Switzer v. Johnson, 432 S.W.2d 164 (Tex.App. — Houston, 1968 no writ). 25. Defendant’s Medical Treatment. Any inquiry or reference to whether or not Defendant was injured in this motor vehicle collision and/or sought medical treatment as a result of this motor vehicle collision as Defendant’s medical conditions and treatments are not relevant to Plaintiffs claims, any inquiries or references would be an invasion of Defendant’s privacy, and Defendant would argue that any probative value would be outweighed by the confusion caused to the jury over this issue. 26. Photographs. Showing any photographs to the jury until the same has been tendered to opposing counsel and admitted into evidence. Mobley vs. Ortiz PAGE 4 DEFENDANT’S SECOND AMENDED MOTION IN LIMINE 27. Comments on “sending a message.” Plaintiff be prohibited fiom making any argument, comment or inference during any phase of this trial that Defendant should be held accountable or responsible for the purpose of sending a message on behalf of society as a whole or sending a message that a particular behavior Will not be tolerated. This is because it appeals to a juror’s fear and plays upon bias, prejudice or sympathy rather than a principled weighing of What the credible evidence shows. Respectfiilly submitted, LISA CHASTAIN & ASSOCIATES (MM JENNIFER MOK TBN: 24130743 P.O. Box 655441 Dallas, TX 75265 E-Service Only: DallasLegal@allstate.com (469) 428-1016 (877) 678-4763 (fax) ATTORNEY FOR DEFENDANT(S) MARIA ORTIZ Mobley vs. Ortiz PAGE 5 DEFENDANT’S SECOND AMENDED MOTION IN LIMINE CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been served in compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on March 17, 2023, to: ROLLE LAW Heather V. Banahan Nease State Bar No. 24090959 2030 Main Street, Suite 200 Dallas, Texas 75201 heathern@rbrl.com Tel: (214) 742-8897 Fax: (214) 637-6872 ATTORNEY FOR PLAINTIFF (MM JENNIFER MOK Mobley vs. Ortiz PAGE 6 DEFENDANT’S SECOND AMENDED MOTION IN LIMINE 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. Young Jenkins on behalf of Jennifer Mok Bar No. 24130743 yjena@allstate.com Envelope ID: 73784576 Filing Code Description: Witness List Filing Description: SECOND AMENDED - DEFENDANT Status as of 3/20/2023 8:51 AM CST Associated Case Party: MARIA ORTIZ Name BarNumber Email TimestampSubmitted Status LARRY ROLLE Iarryr@rbrl.com 3/17/2023 5:07:23 PM SENT Associated Case Party: JACQUELINE MOBLEY Name BarNumber Email TimestampSubmitted Status Heather V.Banahan Nease heathern@rbrl.com 3/17/2023 5:07:23 PM SENT Carol Mathews carolm@rbrl.com 3/17/2023 5:07:23 PM SENT