Preview
Electronically Submitted
4/3/2024 4:33 PM
Hidalgo County Clerk
Accepted by: Alejandra Lara
CAUSE NO. CL-22-2373-B
PATRICIA FLORES BALLI and § IN THE COUNTY COURT
ANGEL JESUS DELGADO, JR. §
§
VS. § AT LAW NO. 2
§
MARIA OLIVIA ESPARZA § HIDALGO COUNTY, TEXAS
DEFENDANT’S OBJECTIONS TO PLAINTIFFS’ SUBPOENA DUCES TECUM
ATTACHED TO THE THIRD AMENDED NOTICE OF DEPOSITION OF
GREGORY S. GOLDSMITH, M.D.
TO: Plaintiffs, by and through their attorney of record:
Juan H. Gonzalez
VILLARREAL & BEGUM
2401 Wildflower, Suite B
Brownsville, Texas 78526
COMES MARIA OLIVIA ESPARZA, Defendant in the above-styled and numbered cause,
and makes these objections to the subpoena duces tecum propounded by Plaintiffs in their Third
Amended Notice of Intention to Take Oral and Videotaped Deposition of Gregory S. Goldsmith,
M.D. noticed on March 4, 2024, pursuant to the Texas Rules of Civil Procedure.
Respectfully submitted,
LAW OFFICE OF RALPH M. RODRIGUEZ, PLLC
1410 W. Dove Avenue
McAllen, Texas 78504
(956) 758-0300
Email: gtj-service@tdlawtx.com
By: __/s/ Guillermo Tijerina, Jr._______
GUILLERMO TIJERINA, JR.
Of Counsel
State Bar No. 24092339
ATTORNEY FOR DEFENDANT
1
Electronically Submitted
4/3/2024 4:33 PM
Hidalgo County Clerk
Accepted by: Alejandra Lara
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 3rd day of April, 2024, a true and correct copy of the
foregoing document has been sent to all counsel of record as follows:
Via E-Service
Juan H. Gonzalez
Villarreal & Begum
2401 Wildflower, Suite B
Brownsville, Texas 78526
_/s/ Guillermo Tijerina, Jr. /s/_____
Guillermo Tijerina, Jr.
2
Electronically Submitted
4/3/2024 4:33 PM
Hidalgo County Clerk
Accepted by: Alejandra Lara
DEFENDANT’S OBJECTIONS TO PLAINTIFFS’ SUBPOENA DUCES TECUM
ATTACHED TO THE THIRD AMENDED NOTICE OF DEPOSITION OF
GREGORY S. GOLDSMITH, M.D.
1. The witness’ most current professional resume or curriculum vitae.
REPSONSE:
Please see Dr. Goldsmith’s curriculum vitae that was previously produced at the following
link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
2. A list of all litigation-related matters in which the witness has been engaged, including a list of
all depositions and trial engagements participated in by the witness, including dates, courts, and
attorneys who have engaged the witness.
RESPONSE:
Defendant objects to this request on the grounds that it is overly broad and requests
information not relevant to any issue in this lawsuit, constitutes an impermissible "fishing
expedition” and/or invasion of privacy, and is not reasonably calculated to lead to the
discovery of admissible evidence.
Subject to such objection, please see Dr. Goldsmith’s testifying history that was previously
produced at the following link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
3. Any papers, articles, or textbooks authored, written, or presented by the witness in any field in
which the witness has an opinion in this matter.
RESPONSE:
Defendant objects to this request on the basis that it is overly broad and unduly
burdensome. A party is required to produce only those documents or tangible things within
its possession, custody, or control. Tex. R. Civ. P. 192.3(b). Moreover, a party is not
required to produce information that, at the time the response is made, is not reasonably
available to the party or its attorney. Tex. R. Civ. P. 193.1.
4. The amount of income or other consideration received by the witness or any entity with which
the witness has been associated in the preceding ten (10) years for services rendered as an expert
witness in connection with any claim or litigation.
3
Electronically Submitted
4/3/2024 4:33 PM
Hidalgo County Clerk
Accepted by: Alejandra Lara
RESPONSE:
Defendant objects to this request on the grounds that it is overly broad and requests
information not relevant to any issue in this lawsuit, constitutes an impermissible "fishing
expedition” and/or invasion of privacy, and is not reasonably calculated to lead to the
discovery of admissible evidence.
Subject to such objection, please see Dr. Goldsmith’s testifying history that was previously
produced at the following link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
5. A copy of every report prepared by the witness, or at the witness’ direction, as an expert witness
in connection with any claim or lawsuit.
RESPONSE:
Defendant objects to this request on the grounds that it is overly broad and requests
information not relevant to any issue in this lawsuit, constitutes an impermissible "fishing
expedition” and/or invasion of privacy, and is not reasonably calculated to lead to the
discovery of admissible evidence.
Subject to such objection, please see Dr. Goldsmith’s report and counter-affidavit that were
previously produced at the following link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
6. All photographs taken or relied upon by the witness.
RESPONSE:
Please see the police report, plaintiff’s medical and radiology records that were previously
produced at the following link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
7. All notes, calculations, reports, and other similar documents authored by or caused to be
authored by the witness concerning this case.
RESPONSE:
Please refer to plaintiffs’ medical bills and records sent to Dr. Goldsmith that were
previously produced at the following link:
4
Electronically Submitted
4/3/2024 4:33 PM
Hidalgo County Clerk
Accepted by: Alejandra Lara
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
8. All treaties, scholarly journals, professional studies, professional literature, and other similar
documents consulted by the witness and relied upon by the witness in expressing any of the
opinions and conclusions in this matter.
RESPONSE:
Defendant objects to this request on the basis that it is overly broad and unduly
burdensome.
Subject to such objections, besides the medical training he received as an orthopedic
surgeon licensed to practice in the State of Texas, and his years of experience practicing
in this specialty.
9. All promotional, advertising, or other literature or documents which makes known or offers or
purports to offer the witness as an expert witness available for consultation in the review of claims
or litigation.
RESPONSE:
Defendant objects to this request on the basis that it is overly broad and unduly
burdensome.
Subject to such objection, Dr. Goldsmith does not advertise his services for personal injury
cases.
10. All contracts or agreements between the witness and any other party or organization concerning
the witness’ ability to review claims or litigation as an expert witness.
RESPONSE:
Defendant objects to this request on the grounds that it is overly broad and requests
information not relevant to any issue in this lawsuit, constitutes an impermissible "fishing
expedition” and/or invasion of privacy, and is not reasonably calculated to lead to the
discovery of admissible evidence.
Defendant objects to this request on the grounds that the discovery sought is obtainable
from other sources that are more convenient, less burdensome, or less expensive.
Subject to such objections, please see Dr. Goldsmith’s invoices generated relating to this
case that were previously produced at the following link:
5
Electronically Submitted
4/3/2024 4:33 PM
Hidalgo County Clerk
Accepted by: Alejandra Lara
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
11. All correspondence, telephone message slips, email, and any and all other records reflecting
any and all communications between the witness and the Defendants or their counsel.
RESPONSE:
Please see correspondence generated in this case at the following link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
12. All pleadings, depositions, or discovery materials given by the witness as a party in a lawsuit.
RESPONSE:
Defendant objects to this request on the basis that it is overly broad and unduly
burdensome.
Defendant objects to this request on the grounds that it is overly broad and requests
information not relevant to any issue in this lawsuit, constitutes an impermissible "fishing
expedition” and/or invasion of privacy, and is not reasonably calculated to lead to the
discovery of admissible evidence.
Subject to such objections, please see the documents reviewed by Dr. Goldsmith that was
previously produced at the following link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
13. All invoices and bills for professional services sent by the witness to Defendant or her counsel
in this matter.
RESPONSE:
Please see Dr. Goldsmith’s invoices generated relating to this case that were previously
produced at the following link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
14. All records of professional time spent by the witness with respect to the engagement made the
basis of this suit.
RESPONSE:
6
Electronically Submitted
4/3/2024 4:33 PM
Hidalgo County Clerk
Accepted by: Alejandra Lara
Please see Dr. Goldsmith’s invoices generated relating to this case that were previously
produced at the following link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
15. All documents provided to the witness by the Defendant or her counsel with respect to the
witness’ engagement in this matter, and upon which the witness has reviewed in expressing any
opinions in this case.
RESPONSE:
Please see the documents reviewed by Dr. Goldsmith that was previously produced at the
following link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
16. All documents which the witness has read, reviewed, or used to refresh his/her recollection
with prior to the deposition.
RESPONSE:
None other than the documents reviewed by Dr. Goldsmith that was previously produced
at the following link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
17. The most current list of any professional publications authored or edited to any extent by the
witness which relate in any way to the subject matter of the witness’ testimony.
RESPONSE:
Please see Dr. Goldsmith’s curriculum vitae that was previously produced at the following
link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
18. Any professional license held by the witness.
RESPONSE:
7
Electronically Submitted
4/3/2024 4:33 PM
Hidalgo County Clerk
Accepted by: Alejandra Lara
Please see Dr. Goldsmith’s curriculum vitae that was previously produced and licenses at
the following link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
19. Any board certifications of the witness.
RESPONSE:
Please see Dr. Goldsmith’s curriculum vitae that was previously produced and licenses at
the following link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
20. Any and all documents and/or tangible items reviewed by the witness in connection with this
case.
RESPONSE:
Please see the documents reviewed by Dr. Goldsmith that was previously produced at the
following link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
21. Any and all documents or tangible items sent to or provided to the witness in connection with
this case.
RESPONSE:
Please see the documents reviewed by Dr. Goldsmith that was previously produced at the
following link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
22. A list of all the cases Guillermo Tijerina, Jr. and/or his firm of Law Office of Ralph M.
Rodriguez, PLLC has hired you as an expert.
RESPONSE:
Defendant objects to this request on the grounds that it is grossly overly broad and requests
information not relevant to any issue in this lawsuit, constitutes an impermissible "fishing
8
Electronically Submitted
4/3/2024 4:33 PM
Hidalgo County Clerk
Accepted by: Alejandra Lara
expedition” and/or invasion of privacy, and is not reasonably calculated to lead to the
discovery of admissible evidence.
Subject to such objection, please see Dr. Goldsmith’s testifying history that was previously
produced at the following link:
https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7
bqasibb3x9r9&dl=0
23. A copy of all 1099’s issued to you by Guillermo Tijerina, Jr. and/or his firm of Law Office of
Ralph M. Rodriguez, PLLC has hired you as an expert.
RESPONSE:
Defendant objects to this request as vague and ambiguous. Defendant objects to this request
on the basis that it is overly broad and unduly burdensome. Defendant objects to this
request on the grounds that it requests information not relevant to any issue in this lawsuit,
constitutes an impermissible "fishing expedition” and/or invasion of privacy, and is not
reasonably calculated to lead to the discovery of admissible evidence. Defendant would
object to this request insofar as it requires information regarding expert witnesses which is
outside of the scope of discovery allowed as to experts by Texas Rules of Civil Procedure
195.1.
24. Produce billing master schedule for all CPT codes opinions given in this matter.
RESPONSE:
Defendant would also object to this request as unintelligible and it is not clear from the
request the specific information being sought.
Defendant would therefore also object to this request insofar as the information requested
is vague, unlimited in scope, and overly broad.
9
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.
Miriam Contreras on behalf of Guillermo Tijerina
Bar No. 24056437
mcontreras@tdlawtx.com
Envelope ID: 86265589
Filing Code Description: Notice
Filing Description: Obj to 3rd Amd Dr. Goldsmith SDT
Status as of 4/3/2024 4:53 PM CST
Associated Case Party: MariaOliviaEsparza
Name BarNumber Email TimestampSubmitted Status
Jaclyn Palomo jpalomo@tdlawtx.com 4/3/2024 4:33:27 PM SENT
Guillermo Tijerina Jr. gtj-service@tdlawtx.com 4/3/2024 4:33:27 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
JUAN GONZALEZ brownsvillelegal@begumlawgroup.com 4/3/2024 4:33:27 PM SENT
Preview
Electronically Submitted 4/3/2024 4:33 PM Hidalgo County Clerk Accepted by: Alejandra Lara CAUSE NO. CL-22-2373-B PATRICIA FLORES BALLI and § IN THE COUNTY COURT ANGEL JESUS DELGADO, JR. § § VS. § AT LAW NO. 2 § MARIA OLIVIA ESPARZA § HIDALGO COUNTY, TEXAS DEFENDANT’S OBJECTIONS TO PLAINTIFFS’ SUBPOENA DUCES TECUM ATTACHED TO THE THIRD AMENDED NOTICE OF DEPOSITION OF GREGORY S. GOLDSMITH, M.D. TO: Plaintiffs, by and through their attorney of record: Juan H. Gonzalez VILLARREAL & BEGUM 2401 Wildflower, Suite B Brownsville, Texas 78526 COMES MARIA OLIVIA ESPARZA, Defendant in the above-styled and numbered cause, and makes these objections to the subpoena duces tecum propounded by Plaintiffs in their Third Amended Notice of Intention to Take Oral and Videotaped Deposition of Gregory S. Goldsmith, M.D. noticed on March 4, 2024, pursuant to the Texas Rules of Civil Procedure. Respectfully submitted, LAW OFFICE OF RALPH M. RODRIGUEZ, PLLC 1410 W. Dove Avenue McAllen, Texas 78504 (956) 758-0300 Email: gtj-service@tdlawtx.com By: __/s/ Guillermo Tijerina, Jr._______ GUILLERMO TIJERINA, JR. Of Counsel State Bar No. 24092339 ATTORNEY FOR DEFENDANT 1 Electronically Submitted 4/3/2024 4:33 PM Hidalgo County Clerk Accepted by: Alejandra Lara CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 3rd day of April, 2024, a true and correct copy of the foregoing document has been sent to all counsel of record as follows: Via E-Service Juan H. Gonzalez Villarreal & Begum 2401 Wildflower, Suite B Brownsville, Texas 78526 _/s/ Guillermo Tijerina, Jr. /s/_____ Guillermo Tijerina, Jr. 2 Electronically Submitted 4/3/2024 4:33 PM Hidalgo County Clerk Accepted by: Alejandra Lara DEFENDANT’S OBJECTIONS TO PLAINTIFFS’ SUBPOENA DUCES TECUM ATTACHED TO THE THIRD AMENDED NOTICE OF DEPOSITION OF GREGORY S. GOLDSMITH, M.D. 1. The witness’ most current professional resume or curriculum vitae. REPSONSE: Please see Dr. Goldsmith’s curriculum vitae that was previously produced at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 2. A list of all litigation-related matters in which the witness has been engaged, including a list of all depositions and trial engagements participated in by the witness, including dates, courts, and attorneys who have engaged the witness. RESPONSE: Defendant objects to this request on the grounds that it is overly broad and requests information not relevant to any issue in this lawsuit, constitutes an impermissible "fishing expedition” and/or invasion of privacy, and is not reasonably calculated to lead to the discovery of admissible evidence. Subject to such objection, please see Dr. Goldsmith’s testifying history that was previously produced at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 3. Any papers, articles, or textbooks authored, written, or presented by the witness in any field in which the witness has an opinion in this matter. RESPONSE: Defendant objects to this request on the basis that it is overly broad and unduly burdensome. A party is required to produce only those documents or tangible things within its possession, custody, or control. Tex. R. Civ. P. 192.3(b). Moreover, a party is not required to produce information that, at the time the response is made, is not reasonably available to the party or its attorney. Tex. R. Civ. P. 193.1. 4. The amount of income or other consideration received by the witness or any entity with which the witness has been associated in the preceding ten (10) years for services rendered as an expert witness in connection with any claim or litigation. 3 Electronically Submitted 4/3/2024 4:33 PM Hidalgo County Clerk Accepted by: Alejandra Lara RESPONSE: Defendant objects to this request on the grounds that it is overly broad and requests information not relevant to any issue in this lawsuit, constitutes an impermissible "fishing expedition” and/or invasion of privacy, and is not reasonably calculated to lead to the discovery of admissible evidence. Subject to such objection, please see Dr. Goldsmith’s testifying history that was previously produced at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 5. A copy of every report prepared by the witness, or at the witness’ direction, as an expert witness in connection with any claim or lawsuit. RESPONSE: Defendant objects to this request on the grounds that it is overly broad and requests information not relevant to any issue in this lawsuit, constitutes an impermissible "fishing expedition” and/or invasion of privacy, and is not reasonably calculated to lead to the discovery of admissible evidence. Subject to such objection, please see Dr. Goldsmith’s report and counter-affidavit that were previously produced at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 6. All photographs taken or relied upon by the witness. RESPONSE: Please see the police report, plaintiff’s medical and radiology records that were previously produced at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 7. All notes, calculations, reports, and other similar documents authored by or caused to be authored by the witness concerning this case. RESPONSE: Please refer to plaintiffs’ medical bills and records sent to Dr. Goldsmith that were previously produced at the following link: 4 Electronically Submitted 4/3/2024 4:33 PM Hidalgo County Clerk Accepted by: Alejandra Lara https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 8. All treaties, scholarly journals, professional studies, professional literature, and other similar documents consulted by the witness and relied upon by the witness in expressing any of the opinions and conclusions in this matter. RESPONSE: Defendant objects to this request on the basis that it is overly broad and unduly burdensome. Subject to such objections, besides the medical training he received as an orthopedic surgeon licensed to practice in the State of Texas, and his years of experience practicing in this specialty. 9. All promotional, advertising, or other literature or documents which makes known or offers or purports to offer the witness as an expert witness available for consultation in the review of claims or litigation. RESPONSE: Defendant objects to this request on the basis that it is overly broad and unduly burdensome. Subject to such objection, Dr. Goldsmith does not advertise his services for personal injury cases. 10. All contracts or agreements between the witness and any other party or organization concerning the witness’ ability to review claims or litigation as an expert witness. RESPONSE: Defendant objects to this request on the grounds that it is overly broad and requests information not relevant to any issue in this lawsuit, constitutes an impermissible "fishing expedition” and/or invasion of privacy, and is not reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to this request on the grounds that the discovery sought is obtainable from other sources that are more convenient, less burdensome, or less expensive. Subject to such objections, please see Dr. Goldsmith’s invoices generated relating to this case that were previously produced at the following link: 5 Electronically Submitted 4/3/2024 4:33 PM Hidalgo County Clerk Accepted by: Alejandra Lara https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 11. All correspondence, telephone message slips, email, and any and all other records reflecting any and all communications between the witness and the Defendants or their counsel. RESPONSE: Please see correspondence generated in this case at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 12. All pleadings, depositions, or discovery materials given by the witness as a party in a lawsuit. RESPONSE: Defendant objects to this request on the basis that it is overly broad and unduly burdensome. Defendant objects to this request on the grounds that it is overly broad and requests information not relevant to any issue in this lawsuit, constitutes an impermissible "fishing expedition” and/or invasion of privacy, and is not reasonably calculated to lead to the discovery of admissible evidence. Subject to such objections, please see the documents reviewed by Dr. Goldsmith that was previously produced at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 13. All invoices and bills for professional services sent by the witness to Defendant or her counsel in this matter. RESPONSE: Please see Dr. Goldsmith’s invoices generated relating to this case that were previously produced at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 14. All records of professional time spent by the witness with respect to the engagement made the basis of this suit. RESPONSE: 6 Electronically Submitted 4/3/2024 4:33 PM Hidalgo County Clerk Accepted by: Alejandra Lara Please see Dr. Goldsmith’s invoices generated relating to this case that were previously produced at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 15. All documents provided to the witness by the Defendant or her counsel with respect to the witness’ engagement in this matter, and upon which the witness has reviewed in expressing any opinions in this case. RESPONSE: Please see the documents reviewed by Dr. Goldsmith that was previously produced at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 16. All documents which the witness has read, reviewed, or used to refresh his/her recollection with prior to the deposition. RESPONSE: None other than the documents reviewed by Dr. Goldsmith that was previously produced at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 17. The most current list of any professional publications authored or edited to any extent by the witness which relate in any way to the subject matter of the witness’ testimony. RESPONSE: Please see Dr. Goldsmith’s curriculum vitae that was previously produced at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 18. Any professional license held by the witness. RESPONSE: 7 Electronically Submitted 4/3/2024 4:33 PM Hidalgo County Clerk Accepted by: Alejandra Lara Please see Dr. Goldsmith’s curriculum vitae that was previously produced and licenses at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 19. Any board certifications of the witness. RESPONSE: Please see Dr. Goldsmith’s curriculum vitae that was previously produced and licenses at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 20. Any and all documents and/or tangible items reviewed by the witness in connection with this case. RESPONSE: Please see the documents reviewed by Dr. Goldsmith that was previously produced at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 21. Any and all documents or tangible items sent to or provided to the witness in connection with this case. RESPONSE: Please see the documents reviewed by Dr. Goldsmith that was previously produced at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 22. A list of all the cases Guillermo Tijerina, Jr. and/or his firm of Law Office of Ralph M. Rodriguez, PLLC has hired you as an expert. RESPONSE: Defendant objects to this request on the grounds that it is grossly overly broad and requests information not relevant to any issue in this lawsuit, constitutes an impermissible "fishing 8 Electronically Submitted 4/3/2024 4:33 PM Hidalgo County Clerk Accepted by: Alejandra Lara expedition” and/or invasion of privacy, and is not reasonably calculated to lead to the discovery of admissible evidence. Subject to such objection, please see Dr. Goldsmith’s testifying history that was previously produced at the following link: https://www.dropbox.com/scl/fo/sdzmq5dvl0phzjmv8gae6/h?rlkey=uptn97mrm72q7 bqasibb3x9r9&dl=0 23. A copy of all 1099’s issued to you by Guillermo Tijerina, Jr. and/or his firm of Law Office of Ralph M. Rodriguez, PLLC has hired you as an expert. RESPONSE: Defendant objects to this request as vague and ambiguous. Defendant objects to this request on the basis that it is overly broad and unduly burdensome. Defendant objects to this request on the grounds that it requests information not relevant to any issue in this lawsuit, constitutes an impermissible "fishing expedition” and/or invasion of privacy, and is not reasonably calculated to lead to the discovery of admissible evidence. Defendant would object to this request insofar as it requires information regarding expert witnesses which is outside of the scope of discovery allowed as to experts by Texas Rules of Civil Procedure 195.1. 24. Produce billing master schedule for all CPT codes opinions given in this matter. RESPONSE: Defendant would also object to this request as unintelligible and it is not clear from the request the specific information being sought. Defendant would therefore also object to this request insofar as the information requested is vague, unlimited in scope, and overly broad. 9 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. Miriam Contreras on behalf of Guillermo Tijerina Bar No. 24056437 mcontreras@tdlawtx.com Envelope ID: 86265589 Filing Code Description: Notice Filing Description: Obj to 3rd Amd Dr. Goldsmith SDT Status as of 4/3/2024 4:53 PM CST Associated Case Party: MariaOliviaEsparza Name BarNumber Email TimestampSubmitted Status Jaclyn Palomo jpalomo@tdlawtx.com 4/3/2024 4:33:27 PM SENT Guillermo Tijerina Jr. gtj-service@tdlawtx.com 4/3/2024 4:33:27 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status JUAN GONZALEZ brownsvillelegal@begumlawgroup.com 4/3/2024 4:33:27 PM SENT