On February 20, 2018 a
Expert Witness Designation of Petitioner - Designation
was filed
involving a dispute between
Delagarza, Hector,
Delagarza, Hector Jaime,
and
Delagarza, Lisbett K,
Mota, Lisbett Kimara,
for (Title IV-D OAG Use Only) Enforcement
in the District Court of Montgomery County.
Preview
IN THE MATTER OF IN THE DISTRICT COURT
THE MARRIAGE OF
HECTOR DELAGARZA
418TH JUDICIAL DISTRICT
LISBETT DELAGARZA
AND IN THE INTEREST OF
EMANUEL DELAGARZA, A CHILD MONTGOMERY COUNTY,
TEXAS
EXPERT WITNESS DESIGNATION OF PETITIONER
TO THE HONORABLE JUDGE OF THIS COURT:
NOW COMES, Hector Delagarza Petitioner herein, pursuant to the Texas Rules of Civil
Procedure for Discovery Control Plan 2, designates the following expert witness(es) for purposes
of the trial in this matter:
Justin A. Rasch
William E. Harrison
THE HARRISON FIRM, PLLC
215 Simonton Street
Conroe, Texas 77301
Tel: (936) 828
Expert will testify to the amount of attorney’s fees and expenses expended and that those fees
and expenses were costs that are reasonable, customary for handling a suit of this nature and
complexity in Montgomery County, Texas.
Insofar as this request for disclosure requires the above anticipation of litigation by such expert,
Petitioner would assert privilege as a defense to production as the delivery of all such
information would violate the attorney client privilege and all of the information responsive to
the request for disclosure is being withheld by Petitioner’s attorney.
Custodian of Records
THE HARRISON FIRM, PLLC
215 Simonton Street
Conroe, Texas 773
Tel: (936) 828
Expert Witness Designation
Page
Expert will testify to the possession, custody, and control of documents pertaining to court costs,
attorney fees, and expenses in this case.
Respectfully submitted,
THE HARRISON FIRM, PLLC
215 Simonton Street
Conroe, TX 77301
Tel: (936) 828-3898
Fax: (936) 828-3965
By:
Justin A. Rasch
State Bar No. 24101140
justin@harrisonfirm.net
Attorney for Petitioner
CERTIFICATE OF SERVICE
I certify that a true copy of the above was served on each attorney of record or party in
accordance with the Texas Rules of Civil Procedure on September 7, 2018.
Justin A. Rasch
Expert Witness Designation – Burns, Alton
Page 2
Document Filed Date
September 07, 2018
Case Filing Date
February 20, 2018
Category
(Title IV-D OAG Use Only) Enforcement
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IN THE MATTER OF IN THE DISTRICT COURT THE MARRIAGE OF HECTOR DELAGARZA 418TH JUDICIAL DISTRICT LISBETT DELAGARZA AND IN THE INTEREST OF EMANUEL DELAGARZA, A CHILD MONTGOMERY COUNTY, TEXAS EXPERT WITNESS DESIGNATION OF PETITIONER TO THE HONORABLE JUDGE OF THIS COURT: NOW COMES, Hector Delagarza Petitioner herein, pursuant to the Texas Rules of Civil Procedure for Discovery Control Plan 2, designates the following expert witness(es) for purposes of the trial in this matter: Justin A. Rasch William E. Harrison THE HARRISON FIRM, PLLC 215 Simonton Street Conroe, Texas 77301 Tel: (936) 828 Expert will testify to the amount of attorney’s fees and expenses expended and that those fees and expenses were costs that are reasonable, customary for handling a suit of this nature and complexity in Montgomery County, Texas. Insofar as this request for disclosure requires the above anticipation of litigation by such expert, Petitioner would assert privilege as a defense to production as the delivery of all such information would violate the attorney client privilege and all of the information responsive to the request for disclosure is being withheld by Petitioner’s attorney. Custodian of Records THE HARRISON FIRM, PLLC 215 Simonton Street Conroe, Texas 773 Tel: (936) 828 Expert Witness Designation Page Expert will testify to the possession, custody, and control of documents pertaining to court costs, attorney fees, and expenses in this case. Respectfully submitted, THE HARRISON FIRM, PLLC 215 Simonton Street Conroe, TX 77301 Tel: (936) 828-3898 Fax: (936) 828-3965 By: Justin A. Rasch State Bar No. 24101140 justin@harrisonfirm.net Attorney for Petitioner CERTIFICATE OF SERVICE I certify that a true copy of the above was served on each attorney of record or party in accordance with the Texas Rules of Civil Procedure on September 7, 2018. Justin A. Rasch Expert Witness Designation – Burns, Alton Page 2