Trial Materials: JOHN DOE I vs. THE ANDERSON PRIVATE SCHOOL, et al

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                FILED
                                                                                           DALLAS COUNTY
                                                                                        2/17/2017 5:03:56 PM
                                                                                              FELICIA PITRE
                                                                                           DISTRICT CLERK



                                 Cause No. DC-15-07174

John Doe I, Indiviudally and as Next       §         In the District Court
Friend of John Doe II, a Minor,            §
                                           §
     Plaintiffs,                           §
                                           §
v.                                         §
                                           §         Dallas County, Texas
The Anderson Private School,               §
William C. Anderson, Individually,         §
LeVonna C. Anderson, Individually,         §
Alexander A. Anderson,                     §
Individually, Ripley Entertainment,        §
Inc., and Jim Pattison U.S.A., Inc.,       §
                                           §
     Defendants.                           §         44th Judicial District


                   Defendants William Anderson, LeVonna Anderson, and
                     Alexander Anderson’s Supplemental Witness List


     Defendants William Anderson, LeVonna Anderson, and Alexander Anderson file

this Supplemental Witness List to provide correct addresses for witnesses that were

originally identified on Defendants’ Witness List filed on February 16, 2017. This list is

not intended to supersede or change the identification of witnesses as set forth on

Defendants’ Witness List previously filed and served on February 16, 2017.




Defendants William Anderson, LeVonna Anderson, and
Alexander Anderson’s Supplemental Witness List                                      Page 1
                                             Respectfully submitted,

                                             TOUCHSTONE, BERNAYS, JOHNSTON,
                                               BEALL, SMITH & STOLLENWERCK, L.L.P.
                                             4040 Renaissance Tower
                                             1201 Elm Street
                                             Dallas, Texas 75270
                                             (214) 741-1166
                                             (214) 259-8720 (fax)

                                             By: /s/ Rocky Feemster
                                                 Rocky Feemster
                                                 State Bar No. 06873350
                                                 Rocky.Feemster@tbjbs.com
                                                 Trey D. Kampfer
                                                 State Bar No. 24078766
                                                 Trey.Kampfer@tbjbs.com
                                             Counsel for the Anderson Defendants


                                  Certificate of Service

   The undersigned certifies that on February 17, 2017, a true and correct copy of the

foregoing document was served on all known counsel of record in accordance with the

Texas Rules of Civil Procedure.



                                             /s/ Rocky Feemster
                                             Rocky Feemster
                                             Trey D. Kampfer




Defendants William Anderson, LeVonna Anderson, and
Alexander Anderson’s Supplemental Witness List                                   Page 2
                                      Witness List

I. Witnesses who Defendants expect to call to provide live testimony at trial

   6. Minor Child of Mike and Laurie Raulerson
       Laurie Raulerson
       10033 Regent Row Street
       Benbrook Texas 76126
       (972) 342-3221
       and
       Mike Raulerson
       1801 Alston
       Fort Worth, Texas 76110
        (817) 233-3505

       This minor child, whose identity is known to all parties, was a student at the
       Anderson School at the time of the alleged incident and attended the field trip to
       Ripley’s on the day of the alleged incident. Alexander Anderson exchanged text
       messages with this person at or around the time Plaintiffs claim the alleged
       incident took place. Also, Alexander Anderson met this witness, as well as
       another student, shortly after exiting an exhibit with John Doe II. This witness
       may have communicated with John Doe II at that time.

III. Witnesses who Defendants may call to provide live testimony at trial.

   4. Trevor North
      c/o Lance James and Renee North
      204 Ranch House Road
      Willow Park, Texas 76087
      (817) 991-3033

       Trevor North is a former student at the Anderson School who has knowledge
       about statements that John Doe I has made about the alleged incident.




Defendants William Anderson, LeVonna Anderson, and
Alexander Anderson’s Supplemental Witness List                                     Page 3