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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 FIRST SUPPLEMENTAL
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 follows:
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.
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Ms. Jackson’s opinion is that the attorney’s fees incurred by Respondent are reasonable in
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 or
settlement, consultation, inspection of documents, discovery produced by any party to this suit,
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including bank statements, pension and retirement statements, withdrawals and transfers between
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 is 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 Jack Grimm’s Curriculum vitae is attached hereto as Bated Label
0023.
IV.
Molly Sewell
(321) 303
Ms. Sewell is not retained at this time but if necessary she is anticipated to testify to the
appraised value of the parties’ horses. The basis for her testimony is the individual s experience as
Equine Broker. Ms. Sewell’s mental impressions and opinions of the valuation of the horses,
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being a part of the community property. The facts will be acquired through her personal
knowledge, experience, and education dealing with high end or performances horses.
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.
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 First Supplemental Designation of Expert
Witnesses was served in accordance with rule 21a of the Texas Rules of Civil Procedure on the
following on April 15, 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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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 FIRST SUPPLEMENTAL 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 follows: 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. Page Ms. Jackson’s opinion is that the attorney’s fees incurred by Respondent are reasonable in 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 or settlement, consultation, inspection of documents, discovery produced by any party to this suit, Page including bank statements, pension and retirement statements, withdrawals and transfers between 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 is 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 Jack Grimm’s Curriculum vitae is attached hereto as Bated Label 0023. IV. Molly Sewell (321) 303 Ms. Sewell is not retained at this time but if necessary she is anticipated to testify to the appraised value of the parties’ horses. The basis for her testimony is the individual s experience as Equine Broker. Ms. Sewell’s mental impressions and opinions of the valuation of the horses, Page being a part of the community property. The facts will be acquired through her personal knowledge, experience, and education dealing with high end or performances horses. 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. 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 First Supplemental Designation of Expert Witnesses was served in accordance with rule 21a of the Texas Rules of Civil Procedure on the following on April 15, 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