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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
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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
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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.
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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
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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
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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