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  • In the Matter of the Marriage of Katie Elizabeth Lomness and Phillip John Lomness, II and In the Interest of Cooper John LomnessDivorce with Children document preview
  • In the Matter of the Marriage of Katie Elizabeth Lomness and Phillip John Lomness, II and In the Interest of Cooper John LomnessDivorce with Children document preview
  • In the Matter of the Marriage of Katie Elizabeth Lomness and Phillip John Lomness, II and In the Interest of Cooper John LomnessDivorce with Children document preview
  • In the Matter of the Marriage of Katie Elizabeth Lomness and Phillip John Lomness, II and In the Interest of Cooper John LomnessDivorce with Children document preview
  • In the Matter of the Marriage of Katie Elizabeth Lomness and Phillip John Lomness, II and In the Interest of Cooper John LomnessDivorce with Children document preview
  • In the Matter of the Marriage of Katie Elizabeth Lomness and Phillip John Lomness, II and In the Interest of Cooper John LomnessDivorce with Children document preview
  • In the Matter of the Marriage of Katie Elizabeth Lomness and Phillip John Lomness, II and In the Interest of Cooper John LomnessDivorce with Children document preview
  • In the Matter of the Marriage of Katie Elizabeth Lomness and Phillip John Lomness, II and In the Interest of Cooper John LomnessDivorce with Children document preview
						
                                

Preview

NO. 23-11-17622 IN THE MATTER OF IN THE DISTRICT COURT THE MARRIAGE OF KATIE ELIZABETH LOMNESS 410th JUDICIAL DISTRICT PHILLIP JOHN LOMNESS II AND IN THE INTEREST OF COOPER JOHN LOMNESS, A MONTGOMERY COUNTY, TEXAS CHILD RESPONDENT DESIGNATION OF EXPERT WITNESSES Respondent, Phillip John Lomness, II Respondent") files this Designation of Expert Witnesses, and reserves the right to call and use expert witnesses and elicit expert testimony in this cause, either through live testimony, by deposition, through Custodian of Records, affidavit, or as otherwise allowed in accordance with the Rules of this Court and the Texas Rules of Civil Procedure, as follow Erica Jackson Erica Jackson Law, P.L.L.C. 307 N. San Jacinto Conroe, Texas 77301 Ms. Jacksonis expected to testify, as and to the extent the allocation of attorney’s fees is an issue in this case, to reasonable and necessary attorneys’ fees based on her training, experience, education and review of the documents in this matter. Ms. Jackson is anticipated to testify regarding the reasonableness and necessity of attorneys’ fees and costs, and normal and customary charges in Texas for legal services rendered in similar cases. Ms. Jackson’s opinion is that the attorney’s fees incurred by Respondent are reasonable in Page light of the type, complexity and proceedings in this case. Respondent shall supplement regarding opinions as to fees presented by Respondent upon receipt of sufficient information to formulate such an opinion. Jackson is not a retained expert, however, she may rely upon and/or review any pleadings and/or discovery generated in this case; as well as any records and/or documents that have been obtained through written discovery, depositions on written questions and/or subpoena duces tecum. Ms. Jackson will also testify as a rebuttal witness to other attorneys fees requested if necessary. A copy of Erica Jackson’s Representation Contract, redacted invoices and Ms. Jackson’s Curriculum vitae are attached hereto as Bated Label 0001 Jaclyn Franks, ASA, CFE Valuation Fraud & Forensics, LLC 114 West Lewis Street Conroe, Texas 77301 3923 Ms. Franks is a retained expertas well as a rebuttal expert and is anticipated to testify to the fair market value of any separate/community property interest and claims of the parties including but not limited to retirement accounts and reimbursement claims. Ms. Franks’ mental impressions and opinions will include the community property and Respondent’s separate property interestsShe will also testify to the value of the parties’ business and testify as a rebuttal witness to the valuation presented by Petitioner’s expert. The basis for her testimony is the individual expert’s education as a certified fraud examiner, background, and experience in forensics, valuation, and litigation support services, asset valuation and optimization of business value for sale, distribution o settlement, consultation, inspection of documents, discovery produced by any party to this suit, including bank statements, pension and retirement statements, withdrawals and transfers between Page accounts and/or any other relevant documents. Any reports or evaluation produced by this expert witness in connection with this case will be filed with the Court and served on each attorney of record or party in accordance with the Texas Rules of Civil Procedure. A copy of Jaclyn Franks Curriculum vitae attached hereto as Bated Label 0020 Mr. Jack Grimm Jack Grimm and Associates 805 Stone Mountain Drive Conroe, Texas 77302 (936) 321 . Grimm is a retained expert and is anticipated to testify to the appraised value of real property owned by the parties. The basis for his testimony is the individual expert’s education as a certified General Real Estate Appraiser. Mr. Grimm’s mental impressions and opinions are the valuation of the community residential and commercial real property. The facts will be acquired through his inspection of the property and the conducting of a comprehensive comparison with other properties in the area, as well as through his personal knowledge, experience, and education. Any reports or evaluation produced by this expert witness in connection with this case will be filed with the Court and served on each attorney of record or party in accordance with the Texas Rules of Civil Procedure. A copy of Jac k Grimm Curriculum vitae attached hereto as Bated Label 0023. Page RESPECTFULLY UBMITTED Erica Jackson Law, P.L.L.C. 307 N. San Jacinto Conroe, Texas 77301 Tel: (832) 653-9372 By: /s/Erica Jackson Erica Jackson State Bar No. 24055722 erica@ericajacksonlaw.com Attorney for Respondent Page Certificate of Service I certify that a true copy of this Respondent Designation of Expert Witnesses was served in accordance with rule 21a of the Texas Rules of Civil Procedure on the following on April 2024: Maliah I. Wilsonby electronic filing manager at eservice@walke-wilsonlaw.com Walke Wilson Firm, PLLC Maliah I. Wilson 2219 Sawdust Road, Suite 401 The Woodlands, Texas 77380 (281) 942-4052 Attorney for Petitioner /s/Erica Jackson Erica Jackson Attorney for Respondent Page PL - 0001 PL - 0002 PL - 0003 PL - 0004 PL - 0005 Erica Jackson Law, PLLC Erica Jackson Law, PLLC 307 N. San Jacinto Conroe, TX 77301 United States 832-653-9372 Phillip J Lomness Balance $0.00 3600 FM 1488 Rd Ste 120-166 Invoice # 01027 Conroe, TX 77384 Invoice Date December 15, 2023 Payment Terms Due Date Due Date December 15, 2023 Lomness, Phillip Time Entries Date EE Activity Description Rate Hours Line Total Receipt and review petition; forward same to client; 11/29/2023 EJ Billing $315.00 0.1 $31.50 correspond with OC regarding conference call Review documents from client; email client 11/30/2023 EJ Billing regarding ; telephone conference with client $315.00 0.5 $157.50 regarding Draft and file answer; start drafting counterpetition; 12/01/2023 EJ Billing receipt and respond to email from client; telephone $315.00 0.9 $283.50 conference with client 12/06/2023 EJ Billing Receipt and review emails from client $315.00 0.1 $31.50 Telephone conference with client; finalize draft of counterpetition; forward same to client for review; 12/08/2023 EJ Billing $315.00 0.8 $252.00 email OC regarding agreements to alcohol injunctions Review client revisions to petition; correspond with 12/12/2023 EJ Billing client r edit petition; forward to client for $315.00 0.9 $283.50 review 12/15/2023 EJ Billing Correspond with client and OC regarding case $315.00 0.1 $31.50 Totals: 3.4 $1,071.00 Time Entry Sub-Total: $1,071.00 Sub-Total: $1,071.00 Total: $1,071.00 Amount Paid: $1,071.00 Balance Due: $0.00 PL - 0006 Payment History Activity Date Payment Method Amount Responsible User Deposited Into Payment Dec 15, Trust $1,071.00 Erica Jackson Operating Received 2023 (Attorney) Account Summary Phillip J Lomness's Trust History Balance As Of 12/15/2023: $2,929.00 Date Related To Details Amount Balance 12/15/2023 01027 Payment from trust -$1,071.00 $2,929.00 11/29/2023 -- Trust deposit $4,000.00 $4,000.00 PL - 0007 Erica Jackson Law, PLLC Erica Jackson Law, PLLC 307 N. San Jacinto Conroe, TX 77301 United States 832-653-9372 Phillip J Lomness Balance $0.00 3600 FM 1488 Rd Ste 120-166 Invoice # 01048 Conroe, TX 77384 Invoice Date January 15, 2024 Payment Terms Due Date Due Date January 15, 2024 Lomness, Phillip Time Entries Date EE Activity Description Rate Hours Line Total Receipt and review rule 11; telephone conference 12/18/2023 EJ Billing $315.00 0.4 $126.00 with client regarding 12/19/2023 Receipt revised rule 11; telephone conference with EJ Billing $315.00 0.2 $63.00 client Totals: 0.6 $189.00 Time Entry Sub-Total: $189.00 Sub-Total: $189.00 Total: $189.00 Amount Paid: $189.00 Balance Due: $0.00 Payment History Activity Date Payment Method Amount Responsible User Deposited Into Payment Jan 15, Trust $189.00 Erica Jackson Operating Received 2024 (Attorney) PL - 0008 Account Summary Phillip J Lomness's Trust History Balance As Of 01/15/2024: $2,740.00 Date Related To Details Amount Balance 01/15/2024 01048 Payment from trust -$189.00 $2,740.00 12/15/2023 01027 Payment from trust -$1,071.00 $2,929.00 11/29/2023 -- Trust deposit $4,000.00 $4,000.00 Phillip J Lomness's Credit History Balance As Of 01/15/2024: $0.00 Date Related To Details Amount Balance PL - 0009 Erica Jackson Law, PLLC Erica Jackson Law, PLLC 307 N. San Jacinto Conroe, TX 77301 United States 832-653-9372 Phillip J Lomness Balance $0.00 3600 FM 1488 Rd Ste 120-166 Invoice # 01072 Conroe, TX 77384 Invoice Date February 19, 2024 Payment Terms Due Date Due Date February 19, 2024 Lomness, Phillip Time Entries Date EE Activity Description Rate Hours Line Total 01/17/2024 EJ Billing Receipt and respond to emails from client $315.00 0.3 $94.50 Receipt and respond to email from client and 01/22/2024 EJ Billing $315.00 0.2 $63.00 opposing counsel Telephone conference with client; call various 02/12/2024 EJ Billing appraisers; telephone conference with Jack Grimm; $315.00 0.8 $252.00 email OC regarding injunctions Totals: 1.3 $409.50 Time Entry Sub-Total: $409.50 Sub-Total: $409.50 Total: $409.50 Amount Paid: $409.50 Balance Due: $0.00 Payment History Activity Date Payment Method Amount Responsible User Deposited Into Payment Feb 19, Trust $409.50 Erica Jackson Operating Received 2024 (Attorney) PL - 0010 Account Summary Phillip J Lomness's Trust History Balance As Of 02/19/2024: $2,330.50 Date Related To Details Amount Balance 02/19/2024 01072 Payment from trust -$409.50 $2,330.50 01/15/2024 01048 Payment from trust -$189.00 $2,740.00 12/15/2023 01027 Payment from trust -$1,071.00 $2,929.00 11/29/2023 -- Trust deposit $4,000.00 $4,000.00 Phillip J Lomness's Credit History Balance As Of 02/19/2024: $0.00 Date Related To Details Amount Balance PL - 0011 Erica Jackson Law, PLLC Erica Jackson Law, PLLC 307 N. San Jacinto Conroe, TX 77301 United States 832-653-9372 Phillip J Lomness Balance $0.00 3600 FM 1488 Rd Ste 120-166 Invoice # 01102 Conroe, TX 77384 Invoice Date April 2, 2024 Payment Terms Due Date Due Date April 02, 2024 Lomness, Phillip Time Entries Date EE Activity Description Rate Hours Line Total Execute and file rule 11; telephone conference with 02/23/2024 EJ Billing client; email J. Franks respond to $315.00 0.8 $252.00 J. Grimm Correspond with client regarding 03/04/2024 EJ Billing ; review tracing contract; forward same to $315.00 0.1 $31.50 client Receipt and respond to email from client regarding 03/06/2024 EJ Billing $315.00 0.1 $31.50 Rescheduled mediation for 5/9/24; spoke with 03/14/2024 KC Billing $165.00 0.3 $41.25 client, mediators office and opposing counsel. Receipt and respond to email from ; email 03/21/2024 EJ Billing $315.00 0.1 $31.50 client; review Rule 11; forward same to client Telephone conference with client; revise property rule 11; execute same; forward same to client for 03/22/2024 EJ Billing $315.00 0.8 $252.00 execution; email OC regarding rule 11 and forms for business valuation Totals: 2.2 $639.75 Time Entry Sub-Total: $639.75 Sub-Total: $639.75 Total: $639.75 Amount Paid: $639.75 Balance Due: $0.00 PL - 0012 Payment History Activity Date Payment Method Amount Responsible User Deposited Into Payment Apr 2, 2024 Trust $639.75 Erica Jackson Operating Received (Attorney) Account Summary Phillip J Lomness's Trust History Balance As Of 04/02/2024: $1,690.75 Date Related To Details Amount Balance 04/02/2024 01102 Payment from trust -$639.75 $1,690.75 02/19/2024 01072 Payment from trust -$409.50 $2,330.50 01/15/2024 01048 Payment from trust -$189.00 $2,740.00 12/15/2023 01027 Payment from trust -$1,071.00 $2,929.00 11/29/2023 -- Trust deposit $4,000.00 $4,000.00 PL - 0013 ica Bar Memberships State Bar of Texas, November 2006 Montgomery County Bar Association 2013 Education Texas Tech University School of Law Lubbock, TX 2006 Texas A&M University College Station, TX Bachelor of Arts in International Studies & Political Sciencecum laude 2001 Academic Excellence Award Universidad De Granada Granada, Spain Hispanic Studies and Spanish Language Certificate 2001 & 2004 Texas A&M Study Abroad Program Stetson University College of Law - International Law Study Abroad Program Dispute Resolution Center of Lubbock County Lubbock, TX 2005 Experience Erica Jackson Law, P.L.L.C. Conroe, Attorney February resent Family Law Cordell Cordell The Woodlands, TX Associate Attorney October 2014 February 2018 Family Law Vernier & Associates, P.L.L.C. The Woodlands, TX Associate Attorney July 2013September, 2014 Family Law Whisenant & Associates The Woodlands, TX Associate Attorney October 2011 June 2013 Family Law Nichols Law, P.L.L.C. Houston, TX Associate Attorney April 2011 October 2011 Family Law Harris County Attorney’s Office Houston, TX Assistant County Attorney Oct. 2007 March 2011 Exhibit “A” PL - 0014 PL - 0015 PL - 0016 PL - 0017 PL - 0018 PL - 0019 PL - 0020 PL - 0021 PL - 0022 PL - 0023