On August 02, 2010 a
Motion-Secondary
was filed
involving a dispute between
Gpm Houston Properties Ltd,
Gpm Houston Properties, Ltd,
Sjm Realty Ltd,
Sjm Realty, Ltd.,
Triyar Companies Llc,
Triyar Companies, Llc,
and
Fireman'S Fund Insurance Company,
for DAMAGES (OTH)
in the District Court of Harris County.
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07/16/2013 04:27:59 PM 713-755-1451 Page 2/3
CAUSE NO. 2010-47654
GPM HOUSTON PROPERTIES, LTD., IN THE DISTRICT COURT OF
TRIY AR COMPANIES, LLC, and
SJM REALTY, LTD.
V. HARRIS COUNTY, TEXAS
FIREMAN’S FUND INSURANCE
COMPANY §5" JUDICIAL DISTRICT
DEFENDANT’S OBJECTIONS TO
PLAINTIFFS’ DESIGNATION OF EXCERPTS FROM DEPOSITION OF
KEN GRAEBER TAKEN ON AUGUST 14, 2012
Defendant Fireman’s Fund Insurance Company (“FFIC”) objects to Plaintiffs’
Designation of Excerpts from Deposition of Ken Graeber taken on August 14, 2012, as the
proposed excerpts relate to issues to be tried in cause number 2010-47654-B, to wit: the
quantification of and extra contractual damages. Because these issues are not addressed in the
trial of the above styled matter and are irrelevant to the issues being tried in this case, FFIC
objects to their inclusion at this time.
Respectfully submitted,
MARTIN, DISIERE, JEFFERSON & WISDOM, L.L.P.
By: if Molly L. Pela
Christopher W. Martin
State Bar No. 13057620
martin@mdjwaw.com
David D. Disiere
State Bar No. 00785356
disiere@mdjwlaw.com
Molly L. Pela
State Bar No. 24046606
pela@mdjwlaw.com
808 Travis Street, 20th Floor
Houston, TX 77002
Ph: (713) 632-1700 Fax: (713) 222-0101
— AND-
07/16/2013 04:27:59 PM 713-755-1451 Page 3/3
GARDERE WYNNE SEWELL LLP
Robert M. Hoffman
State Bar No. 09788200
thottman@gardere.com
Jordan La Raia
State Bar No. 24069970
jlaraia@gardere.com
Thanksgiving Tower, Suite 3000
1601 Elm Street
Dallas, TX 75201
Ph: (214) 999-4707 — Fax: (214) 999-3707
ATTORNEYS FOR DEFENDANT
FIREMAN’S FUND INSURANCE COMPANY
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing document was
electronically filed on this the 16th day of July, 2013. Notice of this filing will be sent to all
parties via operation of the Court’s electronic filing system. For those parties whose counsel is
not registered with the Court's electronic filing system, service will be made by either facsimile,
hand delivery, or via certified mail, return receipt requested.
Mr. James L. Cornell Via CM/ECF and Facsimile
CORNELL & PARDUE
2727 Allen Parkway, Suite 1675
Houston, Texas 77019
Mr. Gene F. Creely, IT Via CMECF and Facsimile
‘THE CREELY LAW FIRM PLLC
701 Richmond Avenue, Suite 250
Houston, TX 77006
i MollyL. Pela
Molly L. Pela
Document Filed Date
July 16, 2013
Case Filing Date
August 02, 2010
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07/16/2013 04:27:59 PM 713-755-1451 Page 2/3 CAUSE NO. 2010-47654 GPM HOUSTON PROPERTIES, LTD., IN THE DISTRICT COURT OF TRIY AR COMPANIES, LLC, and SJM REALTY, LTD. V. HARRIS COUNTY, TEXAS FIREMAN’S FUND INSURANCE COMPANY §5" JUDICIAL DISTRICT DEFENDANT’S OBJECTIONS TO PLAINTIFFS’ DESIGNATION OF EXCERPTS FROM DEPOSITION OF KEN GRAEBER TAKEN ON AUGUST 14, 2012 Defendant Fireman’s Fund Insurance Company (“FFIC”) objects to Plaintiffs’ Designation of Excerpts from Deposition of Ken Graeber taken on August 14, 2012, as the proposed excerpts relate to issues to be tried in cause number 2010-47654-B, to wit: the quantification of and extra contractual damages. Because these issues are not addressed in the trial of the above styled matter and are irrelevant to the issues being tried in this case, FFIC objects to their inclusion at this time. Respectfully submitted, MARTIN, DISIERE, JEFFERSON & WISDOM, L.L.P. By: if Molly L. Pela Christopher W. Martin State Bar No. 13057620 martin@mdjwaw.com David D. Disiere State Bar No. 00785356 disiere@mdjwlaw.com Molly L. Pela State Bar No. 24046606 pela@mdjwlaw.com 808 Travis Street, 20th Floor Houston, TX 77002 Ph: (713) 632-1700 Fax: (713) 222-0101 — AND- 07/16/2013 04:27:59 PM 713-755-1451 Page 3/3 GARDERE WYNNE SEWELL LLP Robert M. Hoffman State Bar No. 09788200 thottman@gardere.com Jordan La Raia State Bar No. 24069970 jlaraia@gardere.com Thanksgiving Tower, Suite 3000 1601 Elm Street Dallas, TX 75201 Ph: (214) 999-4707 — Fax: (214) 999-3707 ATTORNEYS FOR DEFENDANT FIREMAN’S FUND INSURANCE COMPANY CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing document was electronically filed on this the 16th day of July, 2013. Notice of this filing will be sent to all parties via operation of the Court’s electronic filing system. For those parties whose counsel is not registered with the Court's electronic filing system, service will be made by either facsimile, hand delivery, or via certified mail, return receipt requested. Mr. James L. Cornell Via CM/ECF and Facsimile CORNELL & PARDUE 2727 Allen Parkway, Suite 1675 Houston, Texas 77019 Mr. Gene F. Creely, IT Via CMECF and Facsimile ‘THE CREELY LAW FIRM PLLC 701 Richmond Avenue, Suite 250 Houston, TX 77006 i MollyL. Pela Molly L. Pela