On August 12, 2020 a
DEFS LIST OF EXHIBITS - EXHIBIT LIST
was filed
involving a dispute between
Williams, Michael,
and
Martin Marietta,
Martin Marietta Materials, Inc.,
Martin Marietta Materials Southwest, L.L.C.,
Texas Industries, Inc.,
Txi Operations, Inc.,
for PROPERTY
in the District Court of Dallas County.
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FILED
11/6/2023 6:59 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Debra Clark DEPUTY
CAUSE NO. DC-20-11175
MICHAEL WILLIAMS, § IN THE 134m JUDICIAL
Plaintiffs, §
§
v. §
§
TXI OPERATIONS, LP, TEXAS INDUSTRIES, § DISTRICT COURT OF
INC., MARTIN MARIETTA, MARTIN §
MARIETTA MATERIALS, INC. and §
MARTIN MARIETTA MATERIALS §
SOUTHWEST, L.L.C., §
Defendants. § DALLAS COUNTY, TEXAS
DEFENDANTS’ PRELIMINARY LIST OF EXHIBITS
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW, TXI OPERATIONS, LP, TEXAS INDUSTRIES, INC., MARTIN
MARIETTA, MARTIN MARIETTA MATERIALS, INC. and MARTIN MARIETTA
MATERIALS SOUTHWEST, L.L.C., Defendants in the above entitled and numbered cause, and
file this their Preliminary List of Exhibits, and in support thereof would respectfully show onto this
Honorable Court the following:
I.
LIST OF POTENTIAL EXHIBITS
Defendants may offer the following exhibits at trial:
1. Plaintiff’s employment records from 3B Dozer (DWQ subpoenaed from 3B Dozer)
2. SLAM form, Sep. 28, 2018
3. Plaintiff’s medical expense billing affidavits and records (Dell Seton Med Ctr x2;
U. S. Anesthesia; Seton Doctors; CVS Pharmacy; American Medical Response; Austin
Radiology; Clinical Pathology; W. Texas Rehab; Integrated Pain; Texas Specialty Clinic)
Exhibits to Patterson deposition (Ex. 2 and Ex. 9)
3B Dozer Services Agreement
Exhibits to Nance deposition (Ex. 8, 11, 20)
Exhibits to Smith deposition (Ex. 1 and 2)
Exhibits to Dr. Sutton deposition (Ex. 1, including LOP Intake separately)
Any of Plaintiff‘s medical record affidavits W/ records not offered by Plaintiff
0. Any documents listed on Plaintiff” s Exhibit List, but not offered by Plaintiff
1. Miscellaneous exhibits used for impeachment, not yet known to Defendants
DEFENDANTS’ PRELIMINARY LIST OF EXHIBITS - PAGE 1
WHEREFORE, PREMISES CONSIDERED, Defendants respectfully prays that this List
of Exhibits be filed with this court, that Defendants be noted to be in compliance of all outstanding
pretrial orders of this court; and that Plaintiff takes nothing, with Defendants recovering their costs
of court, and for such other relief to which Defendants may show themselves justly entitled and for
which they shall ever pray.
Respectfully submitted,
THE STRADLEY LAW FIRM
9330 LBJ Freeway, Suite 1185
Dallas, Texas 75243
(972) 231-6001
(972) 231-7004 (Fax)
Mark@Stradleylawfirm.com
/ S/ - Mark Stradley
By:
MARK E. STRADLEY
State Bar No. 19352500
ATTORNEY FOR DEFENDAN TS
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the above and foregoing instrument has been
sent to all counsel of record by E-file and/or E-mail on this 6TH day of November, 2022.
/S/ - Mark Stradley
MARK E. STRADLEY
DEFENDANTS’ PRELIMINARY LIST OF EXHIBITS - PAGE 2
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.
Christy Schmitz on behalf of Mark Stradley
Bar No. 19352500
christy@stradleylawfirm.com
Envelope ID: 81361481
Filing Code Description: Exhibit List
Filing Description: DEFS PRELIMINARY
Status as of 11/7/2023 3:45 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Carlos Rodriguez crodriguez@carlsonattorneys.com 11/6/2023 6:59:06 PM SENT
Schmitz Christy christy@stradleylawfirm.com 11/6/2023 6:59:06 PM SENT
Mark Stradley Mark@Stradleylawfirm.com 11/6/2023 6:59:06 PM SENT
Francine Ly fly@dallascourts.org 11/6/2023 6:59:06 PM SENT
William Rossick WRossick@carlsonattorneys.com 11/6/2023 6:59:06 PM SENT
Rachael Rubio rrubio@carlsonattorneys.com 11/6/2023 6:59:06 PM SENT
Associated Case Party: MICHAEL WILLIAMS
Name BarNumber Email TimestampSubmitted Status
William Rossick BillRossickEfile@carlsonattorneys.com 11/6/2023 6:59:06 PM SENT
Karla Rodriguez KRodriguez@carlsonattorneys.com 11/6/2023 6:59:06 PM SENT
Luke Porche LPorche@carlsonattorneys.com 11/6/2023 6:59:06 PM SENT
Document Filed Date
November 06, 2023
Case Filing Date
August 12, 2020
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FILED 11/6/2023 6:59 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Debra Clark DEPUTY CAUSE NO. DC-20-11175 MICHAEL WILLIAMS, § IN THE 134m JUDICIAL Plaintiffs, § § v. § § TXI OPERATIONS, LP, TEXAS INDUSTRIES, § DISTRICT COURT OF INC., MARTIN MARIETTA, MARTIN § MARIETTA MATERIALS, INC. and § MARTIN MARIETTA MATERIALS § SOUTHWEST, L.L.C., § Defendants. § DALLAS COUNTY, TEXAS DEFENDANTS’ PRELIMINARY LIST OF EXHIBITS TO THE HONORABLE JUDGE OF SAID COURT: COME NOW, TXI OPERATIONS, LP, TEXAS INDUSTRIES, INC., MARTIN MARIETTA, MARTIN MARIETTA MATERIALS, INC. and MARTIN MARIETTA MATERIALS SOUTHWEST, L.L.C., Defendants in the above entitled and numbered cause, and file this their Preliminary List of Exhibits, and in support thereof would respectfully show onto this Honorable Court the following: I. LIST OF POTENTIAL EXHIBITS Defendants may offer the following exhibits at trial: 1. Plaintiff’s employment records from 3B Dozer (DWQ subpoenaed from 3B Dozer) 2. SLAM form, Sep. 28, 2018 3. Plaintiff’s medical expense billing affidavits and records (Dell Seton Med Ctr x2; U. S. Anesthesia; Seton Doctors; CVS Pharmacy; American Medical Response; Austin Radiology; Clinical Pathology; W. Texas Rehab; Integrated Pain; Texas Specialty Clinic) Exhibits to Patterson deposition (Ex. 2 and Ex. 9) 3B Dozer Services Agreement Exhibits to Nance deposition (Ex. 8, 11, 20) Exhibits to Smith deposition (Ex. 1 and 2) Exhibits to Dr. Sutton deposition (Ex. 1, including LOP Intake separately) Any of Plaintiff‘s medical record affidavits W/ records not offered by Plaintiff 0. Any documents listed on Plaintiff” s Exhibit List, but not offered by Plaintiff 1. Miscellaneous exhibits used for impeachment, not yet known to Defendants DEFENDANTS’ PRELIMINARY LIST OF EXHIBITS - PAGE 1 WHEREFORE, PREMISES CONSIDERED, Defendants respectfully prays that this List of Exhibits be filed with this court, that Defendants be noted to be in compliance of all outstanding pretrial orders of this court; and that Plaintiff takes nothing, with Defendants recovering their costs of court, and for such other relief to which Defendants may show themselves justly entitled and for which they shall ever pray. Respectfully submitted, THE STRADLEY LAW FIRM 9330 LBJ Freeway, Suite 1185 Dallas, Texas 75243 (972) 231-6001 (972) 231-7004 (Fax) Mark@Stradleylawfirm.com / S/ - Mark Stradley By: MARK E. STRADLEY State Bar No. 19352500 ATTORNEY FOR DEFENDAN TS CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the above and foregoing instrument has been sent to all counsel of record by E-file and/or E-mail on this 6TH day of November, 2022. /S/ - Mark Stradley MARK E. STRADLEY DEFENDANTS’ PRELIMINARY LIST OF EXHIBITS - PAGE 2 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. Christy Schmitz on behalf of Mark Stradley Bar No. 19352500 christy@stradleylawfirm.com Envelope ID: 81361481 Filing Code Description: Exhibit List Filing Description: DEFS PRELIMINARY Status as of 11/7/2023 3:45 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Carlos Rodriguez crodriguez@carlsonattorneys.com 11/6/2023 6:59:06 PM SENT Schmitz Christy christy@stradleylawfirm.com 11/6/2023 6:59:06 PM SENT Mark Stradley Mark@Stradleylawfirm.com 11/6/2023 6:59:06 PM SENT Francine Ly fly@dallascourts.org 11/6/2023 6:59:06 PM SENT William Rossick WRossick@carlsonattorneys.com 11/6/2023 6:59:06 PM SENT Rachael Rubio rrubio@carlsonattorneys.com 11/6/2023 6:59:06 PM SENT Associated Case Party: MICHAEL WILLIAMS Name BarNumber Email TimestampSubmitted Status William Rossick BillRossickEfile@carlsonattorneys.com 11/6/2023 6:59:06 PM SENT Karla Rodriguez KRodriguez@carlsonattorneys.com 11/6/2023 6:59:06 PM SENT Luke Porche LPorche@carlsonattorneys.com 11/6/2023 6:59:06 PM SENT