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FILED
10/9/2023 12:30 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Kellie Juricek DEPUTY
CAUSE NO. DC-21-15846
MARIA SANCHEZ, INDIVIDUALLY AND § IN THE DISTRICT COURT
A/N/F FOR 0.8, and A.S., MINORS, AND §
TATSIANA MARTINEZ AM/F FOR §
J.M., A MINOR AND JOSHUA SANCHEZ §
§
Plaintlffs, §
§
VS. § 0F DALLAS COUNTY, TEXAS
§
TAMARA LAMEKIA GEORGE §
§
Defendant, § 162““ JUDICIAL DISTRICT
PLAINTIFFS’ REPLY TO DEFENDANT’S OBJECTION TO MOTION TO STRIKE
ACCIDENT REPORT AND OFFICER TESTIMONY
TO THE HONORABLE JUDGE 0F SAID COURT:
Plaintiffs’ file this Reply to Defendant’s Response to Plaintiffs’ Motion to Strike Accident
Report and Officer Alejando Kuenzle’s deposition testimony and exclusion as a witness.
1. Texas law is clear that the Accident Report in this case cannot overcome the hearsay
exception because (1) Officer Kuenzle who prepared the report possesses NO training in accident
reconstruction and NEVER participated in accident reconstruction beforelg and (2) Plaintiffs
demonstrated that the source of information or other circumstances indicate that the Accident Report
and Officer Kuenzle’s statements and propositions lack trustworthiness as set forth in Plaintiffs
Motion. See TH Transportation v. Hughes, 224 S.W.3d 870, 889-890 (Tex. App. Fort Worth, 2007,
no writ); Tex. R. Evid. 803(8).
2. The older case law cited by Defendant does not contradict or overrule Plaintiffs’
arguments of trustworthiness, foundation and admissibility, but rather make it clear it is this Court’s
ultimate determination of admissibility upon review of the circumstances in this case that are unlike
l See, Exhibit B: Deposition of Officer Kuenzle (14: 7-19, 20: 18-20).
PLAINTIFFS’ REPLY TO DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION TO STRIKE AND EXCLUDE 7 Page 1
those cited by Defendant in the following case law:
a. In Sciarrilla, the Court found no error in the trial court determining the police
officer was an expert with sufficient training under Rule 702 because he had advanced,
specialized training at accident reconstruction school, and that appellant merely made a
generic hearsay challenge but did not further object to the officer’s opinions on other
grounds like relevancy under Tex. R. CiV. Evid. 402 or unfair prejudice, confusion or
misleading the jury under Tex. R. CiV. EVid. 403. Sciarrilla v. Osborne, 946 S.W.2d 919,
923-24 (Tex. App. 1997). Here, Officer Kuenzle is not an expert as a matter of law and
Plaintiffs DO challenge his report and lay opinions based on other evidentiary challenges.
b. In Carter, the Court acknowledged exceptions for Tex. R. Evid. 803(8) but
could not address the issue because the appellant failed to include the accident report in the
appellate record. Carter v. Steere Tank Lines, Inc., 835 S.W.2d 176, 181 (Tex. App. 1992).
c. In Clement, the Court acknowledged that an affidavit provided by a police
officer that outlined all his personal observations of the criminal defendant’s conduct was
otherwise admissible and thus not double hearsay when incorporated into the police report.
Clement v. Texas Dept. 0fPublic Safety, 726 S.W.2d 579, 5 81 (Tex. App. 1986). The Court
also found the officer’s affidavit probative and trustworthy because the criminal defendant’s
own testimony confirmed probable cause existed thus rendering the police report
trustworthy. Id. Here, Officer Kuenzle did not personally observe any evidence in the
accidentz, but claims to incorporate the body camera footage of only one Officer Tooley who
is no longer with the Garland Police Department? Unlike Clement, Officer Tooley did not
personally provide a written affidavit or otherwise testify under oath in this case. Moreover,
2 Exhibit B: Deposition of Officer Kuenzle (21-32, 54-57).
PLAINTIFFS’ REPLY TO DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION TO STRIKE AND EXCLUDE 7 Page 2
both Plaintiff and Defendant’s deposition testimony do not corroborate but are rather in
conflict with Officer Kuenzle’s Accident Report statements and testimony4 thereto thus
rendering it untrustworthy.
d. In Porter, the Court did not address authenticity because it was not raised and
found the mere complaint of how long it took for the officer to write the report was not
sufficient to challenge its trustworthiness. Porter v. Texas Dept. of Public Safety, 712
S.W.2d 263, 265 (Tex. App. 1986). Here, Plaintiffs do challenge authenticity among other
evidentiary challenges to challenge trustworthiness, delay not being one of them.
e. In McRaw, the appellant provided no evidence to show that the officer’s
accident report lacked trustworthiness, and the Court found it wasn’t an abuse of discretion
to admit the officer’s “lay opinion” through the form of a contributing factor of “failing to
pass to left safely” when the physical evidence provided in the handwritten drawing proved
the same conclusion, the car passing on the left failed to pass safely because it hit the other
car. Id. Here, Plaintiffs have provided ample evidence that the Accident Report lacks
trustworthiness and Officer Kuenzle’s opinions that Plaintiff only had a green light is n_ot
proven bv anv other evidence. Rather, Officer Kuenzle testified the opposite, upon review of
body cam footage, that Plaintiff stated she had a green arrow and NOT a green or red lights
Officer Kuenzle amended the Accident Report but is still of the opinion that Plaintiff had a
green light with no other corroborating physical evidence.6 Officer Kuenzle testified at his
deposition that he didn’t follow proper procedure7 and would have probably found fault on
3 See, Exhibit B: Deposition of Officer Kuenzle (18: 15-16, 19: 6-9; 40: 10-12).
4 See, Exhibit B: Deposition of Officer Kuenzle (24, 32, 62-64); See, Exhibit C: Deposition of Defendant Tamara
Lamekia George (29, 1-15); See, Exhibit D: Deposition of Plaintiff Maria Sanchez (34: 13-16).
5 See, Exhibit B: Deposition of Officer Kuenzle (l9: 6-12, 24: 8-20, 32).
6 See, Exhibit B: Deposition of Officer Kuenzle (65: 9-10).
7 See, Exhibit B: Deposition of Officer Kuenzle (48: 18-25, 65: 6-8).
PLAINTIFFS’ REPLY T0 DEFENDANT’S RESPONSE To PLAINTIFFS’ MOTION TO STRIKE AND EXCLUDE 7 Page 3
Defendant’s part if he had heard her testimony.8 Thus, his “lay opinion” is untrustworthy
under the standard provided by McRaw.
f. In Beech, the Supreme Court found that the Rules of Evidence provide
safeguards to the admissibility of evidence, including (1) the requirement that reports contain
factual findings bars the admission of statements not based on factual investigation; (2) the
trustworthiness provision requires the court to make a determination as to whether the report,
or any portion thereof, is sufficiently trustworthy to be admitted; (3) experts can testify in the
form of an opinion, without any exclusion of opinions on “ultimate issues”; and (4) a lay
witness permits even a lay witness to testify in the form of opinions or inferences drawn
from her observations when testimony in that form will be helpful to the trier of fact . Beech
Aircraft Corporation v. Rainey Beech Aerospace Services, Inc 488 U.S. 153, 162 (1988).
Here, the Accident Report and Officer Kuenzle’s testimony provide no factual findings that
could corroborate his opinions. Rather, his opinions and computer-generated drawing in the
Accident Report9 are inconsistent with physical evidence and what Plaintiff said that night at
the accident.” Officer Kuenzle confirmed upon review of body warn camera that Plaintiff
NEVER said she had a red light.” He agreed Plaintiff stated she had a green arrow (not
12
green light). He also confirmed that he incorrectly reported where the damage occurred to
Plaintiff s vehicle.” And the drawing is still incorrect with Plaintiff and Defendant’s
testimony and wrongly identifies where the accident occurred in the intersection.”
8 See,Exhibit B: Deposition of Officer Kuenzle (61-63, 64: 1-13).
9 See,Exhibit B: Deposition of Officer Kuenzle (22-23).
lO See, Exhibit B: Deposition of Officer Kuenzle (l9: 6-12, 24: 8-20, 32).
ll Id.
l2 Id.
l3 See, Exhibit B: Deposition of Officer Kuenzle (31).
l4 See, Exhibit C: Deposition of Defendant Tamara Lamekia George (29, 1-15); See, Exhibit E: Deposition of
Plaintiff Maria Sanchez (34: 13-16).
PLAINTIFFS’ REPLY TO DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION TO STRIKE AND EXCLUDE 7 Page 4
3. Officer Kuenzle’ s observations of the accident, even Via review of inadmissible body
worn camera recording of Officer Tooley, did NOT include any observations of physical evidence”
that both Plaintiff and Defendant cannot otherwise testify to. Thus, Officer Kuenzle’s Accident
Report and “lay” testimony will NOT “add” or otherwise “help” the jury determine who was at fault
but rather prejudice the jury.
4. Opposing Counsel is incorrect in her statement that Plaintiffs’ Counsel is attempting
to be the “gatekeeper”. The Court “is the gatekeeper” and determines issues of admissibility and
trustworthiness on a case-by-case, not the jury or Plaintiffs’ counsel.
5. No mischaracterizations of opposing counsel’s opinions occurred. She confirmed on
the record that Officer Kuenzle is not qualified to testify as to what factors like speed could or could
not have caused a car to flip over upon impact.”
6. Last, Opposing Counsel tries to mischaracterize a timely pretrial motion regarding the
admissibility of evidence as an untimely “dispositive” motion. Plaintiffs’ Motion to Strike is not
“dispositive” because it does not seek to dispose of all or part of Defendant’s claims like a motion to
dismiss, summary judgment, new trial or a judgment on the pleadings or as a matter of law.
7. Plaintiffs have adequately and timely challenged the admissibility of the Accident
Report and Officer Kuenzle’ s testimony on several grounds including lack of trustworthiness, lack of
foundation: authenticity, hearsay and lack of factual findings, and probative value is substantially
outweighed.
WHEREFORE, PREMISES CONSIDERED, Plaintiffs requests that this Honorable Court
grant this Motion to Strike the Accident Report, Officer Kuenzle’s testimony and exclude Officer
Kuenzle as a witness.
15 Exhibit B: Deposition of Officer Kuenzle (21-32, 54-57).
PLAINTIFFS’ REPLY TO DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION TO STRIKE AND EXCLUDE 7 Page 5
Respectfully submitted,
The LIDJI Firm
/s/ K. Gracie Everz'tt
I. SCOTT LIDJI
Texas Bar No. 24000336
scott@thelidjifirm.com
MARY J 0 R. BETZEN
Texas Bar No. 24089054
marvio@thelidiifirm.com
K. GRACIE EVERITT
Texas Bar No. 24057842
gracie@thelidjifirm.com
Meadow Park Tower
10440 N. Central Exprswy, Suite 1240
Dallas, Texas 75204
(972) 223-7455 (Tel)
(214) 753-4751 (Fax)
ATTORNEYS FOR PLAIN TIFFS
CERTIFICATE OF SERVICE
I hereby certify that a true and conect copy of the foregoing instrument has been forwarded
to all counsel of record Via e-serve on this 9th of October, 2023.
/s/ K. Gracie Everitt
K. GRACIE EVERITT
l6 Exhibit B: Deposition 0f Officer Kuenzle (l9: 20-25).
PLAINTIFFS’ REPLY TO DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION TO STRIKE AND EXCLUDE 7 Page 6
Automated Certificate of eService
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The filer served this document via email generated by the efiling system
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|. Lidji
Bar No. 24000336
scott@thelidjifirm.com
Envelope ID: 80382964
Filing Code Description: Response
Filing Description: PLTF/REPLY TO DEF/OBJECTION TO MOTION
STRIKE
Status as of 10/10/2023 9:11 AM CST
Associated Case Party: JOSHUA SANCHEZ
Name BarNumber Email TimestampSubmitted Status
Legal Lidji legal@thelidjifirm.com 10/9/2023 12:30:46 PM SENT
I. Scott Lidji scott@thelidjifirm.com 10/9/2023 12:30:46 PM SENT
K GracieEveritt gracie@thelidjifirm.com 10/9/2023 12:30:46 PM SENT
Associated Case Party: TAMARALAMEKIAGEORGE
Name BarNumber Email TimestampSubmitted Status
Melanie Clark meclark@geico.com 10/9/2023 12:30:46 PM SENT
Dawn Savino dsavino@geico.com 10/9/2023 12:30:46 PM SENT
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FILED 10/9/2023 12:30 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Kellie Juricek DEPUTY CAUSE NO. DC-21-15846 MARIA SANCHEZ, INDIVIDUALLY AND § IN THE DISTRICT COURT A/N/F FOR 0.8, and A.S., MINORS, AND § TATSIANA MARTINEZ AM/F FOR § J.M., A MINOR AND JOSHUA SANCHEZ § § Plaintlffs, § § VS. § 0F DALLAS COUNTY, TEXAS § TAMARA LAMEKIA GEORGE § § Defendant, § 162““ JUDICIAL DISTRICT PLAINTIFFS’ REPLY TO DEFENDANT’S OBJECTION TO MOTION TO STRIKE ACCIDENT REPORT AND OFFICER TESTIMONY TO THE HONORABLE JUDGE 0F SAID COURT: Plaintiffs’ file this Reply to Defendant’s Response to Plaintiffs’ Motion to Strike Accident Report and Officer Alejando Kuenzle’s deposition testimony and exclusion as a witness. 1. Texas law is clear that the Accident Report in this case cannot overcome the hearsay exception because (1) Officer Kuenzle who prepared the report possesses NO training in accident reconstruction and NEVER participated in accident reconstruction beforelg and (2) Plaintiffs demonstrated that the source of information or other circumstances indicate that the Accident Report and Officer Kuenzle’s statements and propositions lack trustworthiness as set forth in Plaintiffs Motion. See TH Transportation v. Hughes, 224 S.W.3d 870, 889-890 (Tex. App. Fort Worth, 2007, no writ); Tex. R. Evid. 803(8). 2. The older case law cited by Defendant does not contradict or overrule Plaintiffs’ arguments of trustworthiness, foundation and admissibility, but rather make it clear it is this Court’s ultimate determination of admissibility upon review of the circumstances in this case that are unlike l See, Exhibit B: Deposition of Officer Kuenzle (14: 7-19, 20: 18-20). PLAINTIFFS’ REPLY TO DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION TO STRIKE AND EXCLUDE 7 Page 1 those cited by Defendant in the following case law: a. In Sciarrilla, the Court found no error in the trial court determining the police officer was an expert with sufficient training under Rule 702 because he had advanced, specialized training at accident reconstruction school, and that appellant merely made a generic hearsay challenge but did not further object to the officer’s opinions on other grounds like relevancy under Tex. R. CiV. Evid. 402 or unfair prejudice, confusion or misleading the jury under Tex. R. CiV. EVid. 403. Sciarrilla v. Osborne, 946 S.W.2d 919, 923-24 (Tex. App. 1997). Here, Officer Kuenzle is not an expert as a matter of law and Plaintiffs DO challenge his report and lay opinions based on other evidentiary challenges. b. In Carter, the Court acknowledged exceptions for Tex. R. Evid. 803(8) but could not address the issue because the appellant failed to include the accident report in the appellate record. Carter v. Steere Tank Lines, Inc., 835 S.W.2d 176, 181 (Tex. App. 1992). c. In Clement, the Court acknowledged that an affidavit provided by a police officer that outlined all his personal observations of the criminal defendant’s conduct was otherwise admissible and thus not double hearsay when incorporated into the police report. Clement v. Texas Dept. 0fPublic Safety, 726 S.W.2d 579, 5 81 (Tex. App. 1986). The Court also found the officer’s affidavit probative and trustworthy because the criminal defendant’s own testimony confirmed probable cause existed thus rendering the police report trustworthy. Id. Here, Officer Kuenzle did not personally observe any evidence in the accidentz, but claims to incorporate the body camera footage of only one Officer Tooley who is no longer with the Garland Police Department? Unlike Clement, Officer Tooley did not personally provide a written affidavit or otherwise testify under oath in this case. Moreover, 2 Exhibit B: Deposition of Officer Kuenzle (21-32, 54-57). PLAINTIFFS’ REPLY TO DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION TO STRIKE AND EXCLUDE 7 Page 2 both Plaintiff and Defendant’s deposition testimony do not corroborate but are rather in conflict with Officer Kuenzle’s Accident Report statements and testimony4 thereto thus rendering it untrustworthy. d. In Porter, the Court did not address authenticity because it was not raised and found the mere complaint of how long it took for the officer to write the report was not sufficient to challenge its trustworthiness. Porter v. Texas Dept. of Public Safety, 712 S.W.2d 263, 265 (Tex. App. 1986). Here, Plaintiffs do challenge authenticity among other evidentiary challenges to challenge trustworthiness, delay not being one of them. e. In McRaw, the appellant provided no evidence to show that the officer’s accident report lacked trustworthiness, and the Court found it wasn’t an abuse of discretion to admit the officer’s “lay opinion” through the form of a contributing factor of “failing to pass to left safely” when the physical evidence provided in the handwritten drawing proved the same conclusion, the car passing on the left failed to pass safely because it hit the other car. Id. Here, Plaintiffs have provided ample evidence that the Accident Report lacks trustworthiness and Officer Kuenzle’s opinions that Plaintiff only had a green light is n_ot proven bv anv other evidence. Rather, Officer Kuenzle testified the opposite, upon review of body cam footage, that Plaintiff stated she had a green arrow and NOT a green or red lights Officer Kuenzle amended the Accident Report but is still of the opinion that Plaintiff had a green light with no other corroborating physical evidence.6 Officer Kuenzle testified at his deposition that he didn’t follow proper procedure7 and would have probably found fault on 3 See, Exhibit B: Deposition of Officer Kuenzle (18: 15-16, 19: 6-9; 40: 10-12). 4 See, Exhibit B: Deposition of Officer Kuenzle (24, 32, 62-64); See, Exhibit C: Deposition of Defendant Tamara Lamekia George (29, 1-15); See, Exhibit D: Deposition of Plaintiff Maria Sanchez (34: 13-16). 5 See, Exhibit B: Deposition of Officer Kuenzle (l9: 6-12, 24: 8-20, 32). 6 See, Exhibit B: Deposition of Officer Kuenzle (65: 9-10). 7 See, Exhibit B: Deposition of Officer Kuenzle (48: 18-25, 65: 6-8). PLAINTIFFS’ REPLY T0 DEFENDANT’S RESPONSE To PLAINTIFFS’ MOTION TO STRIKE AND EXCLUDE 7 Page 3 Defendant’s part if he had heard her testimony.8 Thus, his “lay opinion” is untrustworthy under the standard provided by McRaw. f. In Beech, the Supreme Court found that the Rules of Evidence provide safeguards to the admissibility of evidence, including (1) the requirement that reports contain factual findings bars the admission of statements not based on factual investigation; (2) the trustworthiness provision requires the court to make a determination as to whether the report, or any portion thereof, is sufficiently trustworthy to be admitted; (3) experts can testify in the form of an opinion, without any exclusion of opinions on “ultimate issues”; and (4) a lay witness permits even a lay witness to testify in the form of opinions or inferences drawn from her observations when testimony in that form will be helpful to the trier of fact . Beech Aircraft Corporation v. Rainey Beech Aerospace Services, Inc 488 U.S. 153, 162 (1988). Here, the Accident Report and Officer Kuenzle’s testimony provide no factual findings that could corroborate his opinions. Rather, his opinions and computer-generated drawing in the Accident Report9 are inconsistent with physical evidence and what Plaintiff said that night at the accident.” Officer Kuenzle confirmed upon review of body warn camera that Plaintiff NEVER said she had a red light.” He agreed Plaintiff stated she had a green arrow (not 12 green light). He also confirmed that he incorrectly reported where the damage occurred to Plaintiff s vehicle.” And the drawing is still incorrect with Plaintiff and Defendant’s testimony and wrongly identifies where the accident occurred in the intersection.” 8 See,Exhibit B: Deposition of Officer Kuenzle (61-63, 64: 1-13). 9 See,Exhibit B: Deposition of Officer Kuenzle (22-23). lO See, Exhibit B: Deposition of Officer Kuenzle (l9: 6-12, 24: 8-20, 32). ll Id. l2 Id. l3 See, Exhibit B: Deposition of Officer Kuenzle (31). l4 See, Exhibit C: Deposition of Defendant Tamara Lamekia George (29, 1-15); See, Exhibit E: Deposition of Plaintiff Maria Sanchez (34: 13-16). PLAINTIFFS’ REPLY TO DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION TO STRIKE AND EXCLUDE 7 Page 4 3. Officer Kuenzle’ s observations of the accident, even Via review of inadmissible body worn camera recording of Officer Tooley, did NOT include any observations of physical evidence” that both Plaintiff and Defendant cannot otherwise testify to. Thus, Officer Kuenzle’s Accident Report and “lay” testimony will NOT “add” or otherwise “help” the jury determine who was at fault but rather prejudice the jury. 4. Opposing Counsel is incorrect in her statement that Plaintiffs’ Counsel is attempting to be the “gatekeeper”. The Court “is the gatekeeper” and determines issues of admissibility and trustworthiness on a case-by-case, not the jury or Plaintiffs’ counsel. 5. No mischaracterizations of opposing counsel’s opinions occurred. She confirmed on the record that Officer Kuenzle is not qualified to testify as to what factors like speed could or could not have caused a car to flip over upon impact.” 6. Last, Opposing Counsel tries to mischaracterize a timely pretrial motion regarding the admissibility of evidence as an untimely “dispositive” motion. Plaintiffs’ Motion to Strike is not “dispositive” because it does not seek to dispose of all or part of Defendant’s claims like a motion to dismiss, summary judgment, new trial or a judgment on the pleadings or as a matter of law. 7. Plaintiffs have adequately and timely challenged the admissibility of the Accident Report and Officer Kuenzle’ s testimony on several grounds including lack of trustworthiness, lack of foundation: authenticity, hearsay and lack of factual findings, and probative value is substantially outweighed. WHEREFORE, PREMISES CONSIDERED, Plaintiffs requests that this Honorable Court grant this Motion to Strike the Accident Report, Officer Kuenzle’s testimony and exclude Officer Kuenzle as a witness. 15 Exhibit B: Deposition of Officer Kuenzle (21-32, 54-57). PLAINTIFFS’ REPLY TO DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION TO STRIKE AND EXCLUDE 7 Page 5 Respectfully submitted, The LIDJI Firm /s/ K. Gracie Everz'tt I. SCOTT LIDJI Texas Bar No. 24000336 scott@thelidjifirm.com MARY J 0 R. BETZEN Texas Bar No. 24089054 marvio@thelidiifirm.com K. GRACIE EVERITT Texas Bar No. 24057842 gracie@thelidjifirm.com Meadow Park Tower 10440 N. Central Exprswy, Suite 1240 Dallas, Texas 75204 (972) 223-7455 (Tel) (214) 753-4751 (Fax) ATTORNEYS FOR PLAIN TIFFS CERTIFICATE OF SERVICE I hereby certify that a true and conect copy of the foregoing instrument has been forwarded to all counsel of record Via e-serve on this 9th of October, 2023. /s/ K. Gracie Everitt K. GRACIE EVERITT l6 Exhibit B: Deposition 0f Officer Kuenzle (l9: 20-25). PLAINTIFFS’ REPLY TO DEFENDANT’S RESPONSE TO PLAINTIFFS’ MOTION TO STRIKE AND EXCLUDE 7 Page 6 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. |. Lidji Bar No. 24000336 scott@thelidjifirm.com Envelope ID: 80382964 Filing Code Description: Response Filing Description: PLTF/REPLY TO DEF/OBJECTION TO MOTION STRIKE Status as of 10/10/2023 9:11 AM CST Associated Case Party: JOSHUA SANCHEZ Name BarNumber Email TimestampSubmitted Status Legal Lidji legal@thelidjifirm.com 10/9/2023 12:30:46 PM SENT I. Scott Lidji scott@thelidjifirm.com 10/9/2023 12:30:46 PM SENT K GracieEveritt gracie@thelidjifirm.com 10/9/2023 12:30:46 PM SENT Associated Case Party: TAMARALAMEKIAGEORGE Name BarNumber Email TimestampSubmitted Status Melanie Clark meclark@geico.com 10/9/2023 12:30:46 PM SENT Dawn Savino dsavino@geico.com 10/9/2023 12:30:46 PM SENT