Preview
Electronically Filed
2/28/2020 5:00 PM
Hidalgo County District Clerks
Reviewed By: Jose Hernandez
CAUSE NO. C-4445-17-G
ALICIA PERALES § IN THE DISTRICT COURT
AS REPRESENTATIVE OF THE §
ESTATE OF MARIO A. PERALES, §
AND AS NEXT OF FRIEND OF §
S.M. PERALES AND
M. PERALES, JR., MINOR CHILDREN §
V. 370™ JUDICIAL DISTRICT
DANIEL SIEGER, INDIVIDUALLY
AND AS AGENT OF DEFENDANT
PEOPLE READY, INC.,
TEXAS SAI, INC., TRUEBLUE
ENTERPRISES, INC. AS AGENT FOR §
ITS SUBSIDIARIES AND AFFILIATES §
PEOPLE READY, INC., DBNK
CONTRACTING, LLC d/b/a BLUE
TEAM RESTORATION, LLC,
WEST TEXAS ROCK RESOURCES,
LLC d/b/a TEXAS RUMBLE STRIP,
HIGHWAY BARRICADES AND
SERVICES, LLC and DUSTROL, INC. § HIDALGO COUNTY, TEXAS
PLAINTIFFS’ DESIGNATION OF EXPERTS
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, ALICIA PERALES, as Representative of the Estate of Mario
Alberto Perales, and as Next Friend of S. M. Perales and M. Perales, Jr., Minor
Children, Plaintiffs in the above styled and numbered cause and file this their
Designation of Expert Witnesses and Filing Reports.
I
Plaintiffs hereby designate the following expert witnesses who may be called to
testify in the trial of this cause:
1) Dusty Arrington
A&M Forensics and Engineering, Inc.
2427 Earl Rudder Frwy S
College Station, Texas 77845
(979) 696-6681
Electronically Filed
2/28/2020 5:00 PM
Hidalgo County District Clerks
Reviewed By: Jose Hernandez
2) DeEstan Ford Turner, Texas DPS Trooper
5160 North Interstate 69-C
Edinburg, Texas
(956) 316-1807
3) Simon Maldonado, Texas DPS Trooper
5160 North Interstate 69-C
Edinburg, Texas
(956) 316-1807
4) Jose Torres, Texas DPS Trooper
500 E. Tom Landry St.
Mission, Texas 78572
(956) 585-3126
5) Rafael De La Torre, Texas DPS Trooper
1414 N. Bicentennial Blvd.
McAllen, Texas 78501
(956) 984-5750
6) Jose Prado, Texas DPS Trooper
410 N. 13" Avenue
Edinburg, Texas 78541
(956) 383-1026
2) Charlie Rivera, Texas DPS Mechanic
2525 N. International Blvd.
Weslaco, Texas 78599
8) Hidalgo County EMS, Medic 4
1415 W. Owassa Road
Edinburg, Texas 78539
(956) 686-5353
9) EMS First Responders, Elite Transportation Services
7608 N. 21* Street
McAllen, Texas 78504
(956) 874-8971
10)Norma Jean Farley, M.D., Coroner, Valley Forensics
3100-A S. Business Hwy 281
Edinburg, Texas 78539
(956) 292-7014
11)Joel Garcia, TXDot Engineer
600 W. Interstate 2
Pharr Texas 78577
(956) 702-6100
As to any favorable testimony elicited from said witness.
Electronically Filed
2/28/2020 5:00 PM
Hidalgo County District Clerks
Reviewed By: Jose Hernandez
12)Martin De La Fuente, TXDot Inspector
Texas Department of Transportation
600 W. Interstate 2
Pharr Texas 78577
(956) 702-6100
As to any favorable testimony elicited from said witness.
13)Rene Garza, TXDot Engineer
as Department of Transportation
600 W. Interstate 2
Pharr Texas 78577
(956) 702-6100
As to any favorable testimony elicited from said witness.
I.
Plaintiffs reserve the right to elicit, by way of cross-examination, opinion
testimony, and adverse testimony, from experts and non-expert witnesses designated
and called by other parties to this suit. Further, Plaintiffs will make available for
depositions in accordance with the Texas Rules of Civil Procedure.
Ul.
Plaintiffs reserve the right to supplement this designation with additional
designation of experts within the time limits imposed by the Court or any alterations of
same by subsequent Court Order or agreement of the parties, or pursuant to the Texas
Rules of Civil Procedure and/or the Texas Rules of Civil Evidence.
IV.
Plaintiffs reserve the right to call un-designated rebuttal expert witnesses whose
testimony cannot reasonably be foreseen until the presentation of the evidence in this
trial. Plaintiffs reserve the right to withdraw the designation of any expert and to aver
positively that any such previously designated expert will not be called as a witness at
trial, and to re-designated the same as a consulting expert, who cannot be called by
opposing counsel. Plaintiffs hereby designate, as adverse parties, potentially adverse
parties, and/or as witnesses associated with adverse parties, all parties to this suit and
all experts designated by any party to this suit, even if the designating party is not a
party to this suit at the time of trial. In the event a present or future party designates an
expert but then is dismissed for any reason from the suit or fails to call any designated
expert, Plaintiffs reserve the right to designate and/or call any such party or any such
Electronically Filed
2/28/2020 5:00 PM
Hidalgo County District Clerks
Reviewed By: J ose Hernandez
experts previously designated by any party. Plaintiffs reserve whatever additional rights
they might have with regard to experts, pursuant to the Texas Rules of Civil Procedure,
the Texas Rules of Civil Evidence, the case law regarding same and the rulings of this
Court. Plaintiff reserves the right to elicit expert, lay or adverse opinions by way of
examinations, cross-examination or other means, whether appropriate, from those
witnesses designated by Plaintiffs or Defendants who may have knowledge of relevant
facts and/or have been designated as expert witnesses by other parties.
Respectfully submitted,
OXFORD & GONZALEZ
ATTORNEYS AT LAW
P.O. DRAWER 630
124 $. 12th
Edinburg, Texas 78540
(956) 54
(956 02 F,
BY:
ardo Gon:
State Bar No. 08131490
ATTORNEY FOR PLAINTIFFS
CERTIFICATE OF SERVICE
| Ricardo Gonzalez, do certify that a true and correct copy of the foregoing
instrument has been forwarded upon all parties and/or counsel of record pursuant to
B
Rules 21 & 21a of the Tex AS les of Civil Procedure via U.S. Mail with postage affixed
and/or facsimile on this the day of February, 2020 to the following:
John R. Griffith
Victoria Olivarez
Griffith Law Group
4228 North McColl, McAllen, Texas 78504
Fax: (956) 971-9451
E-mail: jrg@rgvfirm.com; E-mail: vo@rgvfirm.com
Attorney for Defendant West Texas Rock Resources d/ba West Texas Rumble Strip
Maria Cantu Hexsel
Gregg R. Brown
Germer Beaman and Brown, PLLC
301 Congress Avenue, Suite 1700, Austin, Texas 78701
Fax: (512) 472-0721
E-mail: mhexsel@germer-austin.com; E-mail: grb-svc@germer-austin.com
Attorney for Highway Barricades and Services, LLC
Electronically Filed
2/28/2020 5:00 PM
Hidalgo County District Clerks
Reviewed By: J ose Hernandez
Maria Korzendorfer
Gregg R. Brown
Germer Beaman and Brown, PLLC
301 Congress Avenue, Suite 1700, Austin, Texas 78701
Fax: (512) 472-9260
E-mail: mkorzendorfer@germer-austin.com; E-mail: grb-sve@germer-austin.com
Attorney for Dustrol, Inc.
Mike Mills
Susan Sullivan
Atlas, Hall & Rodriguez
818 Pecan Blvd., McAllen, Texas 78501
Fax: (956) 686-6109
E-mail: mkmills@atlashall.com; ssullivan@atlashall.com
Attorney for DBNK Contracting LLC d/b/a Blue Team Restoration, LLC
Analisa Figueroa
Law Office of Analisa Figueroa, PLLC
514 Paredes Avenue, Suite H, Brownsville, Texas 78521
Fax: (956) 621-1071
E-mail: analisa@afigueroalaw.com
Attorney for Defendant Daniel Sieger
Stephen A. Gibson
Law Office of Stephen A. Gibson
946 W. Nolana Loop, Suite D, Pharr, Texas 78577
Fax: (956) 284-0986,
E-mail: steve@gibson.law
Attorney for Cross-Plaintiff Daniel Sieger
Michael S. Beckelman
Wilson, Elser, Moskowitz, Edelman & Dicker LLP
909 Fannin Street, Suite 3300, Houston, Texas 77010
Fax: (713) 785-7780
E-mail: michael.beckelman@wilsonelser.com
Attorney for Defendant People Ready, Inc.
Javier Gonzalez
Royston, Rayzor, Vickery & Williams, LLP
55 Cove Circle, Brownsville, Texas 78523
Fax: (956) 542-4370
E-mail: javier.gonzalez@roystonlaw.com
Attorney for Defendant Texas SAI, Inc.
di
RICARDO GONZALEZ
_
Preview
Electronically Filed 2/28/2020 5:00 PM Hidalgo County District Clerks Reviewed By: Jose Hernandez CAUSE NO. C-4445-17-G ALICIA PERALES § IN THE DISTRICT COURT AS REPRESENTATIVE OF THE § ESTATE OF MARIO A. PERALES, § AND AS NEXT OF FRIEND OF § S.M. PERALES AND M. PERALES, JR., MINOR CHILDREN § V. 370™ JUDICIAL DISTRICT DANIEL SIEGER, INDIVIDUALLY AND AS AGENT OF DEFENDANT PEOPLE READY, INC., TEXAS SAI, INC., TRUEBLUE ENTERPRISES, INC. AS AGENT FOR § ITS SUBSIDIARIES AND AFFILIATES § PEOPLE READY, INC., DBNK CONTRACTING, LLC d/b/a BLUE TEAM RESTORATION, LLC, WEST TEXAS ROCK RESOURCES, LLC d/b/a TEXAS RUMBLE STRIP, HIGHWAY BARRICADES AND SERVICES, LLC and DUSTROL, INC. § HIDALGO COUNTY, TEXAS PLAINTIFFS’ DESIGNATION OF EXPERTS TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, ALICIA PERALES, as Representative of the Estate of Mario Alberto Perales, and as Next Friend of S. M. Perales and M. Perales, Jr., Minor Children, Plaintiffs in the above styled and numbered cause and file this their Designation of Expert Witnesses and Filing Reports. I Plaintiffs hereby designate the following expert witnesses who may be called to testify in the trial of this cause: 1) Dusty Arrington A&M Forensics and Engineering, Inc. 2427 Earl Rudder Frwy S College Station, Texas 77845 (979) 696-6681 Electronically Filed 2/28/2020 5:00 PM Hidalgo County District Clerks Reviewed By: Jose Hernandez 2) DeEstan Ford Turner, Texas DPS Trooper 5160 North Interstate 69-C Edinburg, Texas (956) 316-1807 3) Simon Maldonado, Texas DPS Trooper 5160 North Interstate 69-C Edinburg, Texas (956) 316-1807 4) Jose Torres, Texas DPS Trooper 500 E. Tom Landry St. Mission, Texas 78572 (956) 585-3126 5) Rafael De La Torre, Texas DPS Trooper 1414 N. Bicentennial Blvd. McAllen, Texas 78501 (956) 984-5750 6) Jose Prado, Texas DPS Trooper 410 N. 13" Avenue Edinburg, Texas 78541 (956) 383-1026 2) Charlie Rivera, Texas DPS Mechanic 2525 N. International Blvd. Weslaco, Texas 78599 8) Hidalgo County EMS, Medic 4 1415 W. Owassa Road Edinburg, Texas 78539 (956) 686-5353 9) EMS First Responders, Elite Transportation Services 7608 N. 21* Street McAllen, Texas 78504 (956) 874-8971 10)Norma Jean Farley, M.D., Coroner, Valley Forensics 3100-A S. Business Hwy 281 Edinburg, Texas 78539 (956) 292-7014 11)Joel Garcia, TXDot Engineer 600 W. Interstate 2 Pharr Texas 78577 (956) 702-6100 As to any favorable testimony elicited from said witness. Electronically Filed 2/28/2020 5:00 PM Hidalgo County District Clerks Reviewed By: Jose Hernandez 12)Martin De La Fuente, TXDot Inspector Texas Department of Transportation 600 W. Interstate 2 Pharr Texas 78577 (956) 702-6100 As to any favorable testimony elicited from said witness. 13)Rene Garza, TXDot Engineer as Department of Transportation 600 W. Interstate 2 Pharr Texas 78577 (956) 702-6100 As to any favorable testimony elicited from said witness. I. Plaintiffs reserve the right to elicit, by way of cross-examination, opinion testimony, and adverse testimony, from experts and non-expert witnesses designated and called by other parties to this suit. Further, Plaintiffs will make available for depositions in accordance with the Texas Rules of Civil Procedure. Ul. Plaintiffs reserve the right to supplement this designation with additional designation of experts within the time limits imposed by the Court or any alterations of same by subsequent Court Order or agreement of the parties, or pursuant to the Texas Rules of Civil Procedure and/or the Texas Rules of Civil Evidence. IV. Plaintiffs reserve the right to call un-designated rebuttal expert witnesses whose testimony cannot reasonably be foreseen until the presentation of the evidence in this trial. Plaintiffs reserve the right to withdraw the designation of any expert and to aver positively that any such previously designated expert will not be called as a witness at trial, and to re-designated the same as a consulting expert, who cannot be called by opposing counsel. Plaintiffs hereby designate, as adverse parties, potentially adverse parties, and/or as witnesses associated with adverse parties, all parties to this suit and all experts designated by any party to this suit, even if the designating party is not a party to this suit at the time of trial. In the event a present or future party designates an expert but then is dismissed for any reason from the suit or fails to call any designated expert, Plaintiffs reserve the right to designate and/or call any such party or any such Electronically Filed 2/28/2020 5:00 PM Hidalgo County District Clerks Reviewed By: J ose Hernandez experts previously designated by any party. Plaintiffs reserve whatever additional rights they might have with regard to experts, pursuant to the Texas Rules of Civil Procedure, the Texas Rules of Civil Evidence, the case law regarding same and the rulings of this Court. Plaintiff reserves the right to elicit expert, lay or adverse opinions by way of examinations, cross-examination or other means, whether appropriate, from those witnesses designated by Plaintiffs or Defendants who may have knowledge of relevant facts and/or have been designated as expert witnesses by other parties. Respectfully submitted, OXFORD & GONZALEZ ATTORNEYS AT LAW P.O. DRAWER 630 124 $. 12th Edinburg, Texas 78540 (956) 54 (956 02 F, BY: ardo Gon: State Bar No. 08131490 ATTORNEY FOR PLAINTIFFS CERTIFICATE OF SERVICE | Ricardo Gonzalez, do certify that a true and correct copy of the foregoing instrument has been forwarded upon all parties and/or counsel of record pursuant to B Rules 21 & 21a of the Tex AS les of Civil Procedure via U.S. Mail with postage affixed and/or facsimile on this the day of February, 2020 to the following: John R. Griffith Victoria Olivarez Griffith Law Group 4228 North McColl, McAllen, Texas 78504 Fax: (956) 971-9451 E-mail: jrg@rgvfirm.com; E-mail: vo@rgvfirm.com Attorney for Defendant West Texas Rock Resources d/ba West Texas Rumble Strip Maria Cantu Hexsel Gregg R. Brown Germer Beaman and Brown, PLLC 301 Congress Avenue, Suite 1700, Austin, Texas 78701 Fax: (512) 472-0721 E-mail: mhexsel@germer-austin.com; E-mail: grb-svc@germer-austin.com Attorney for Highway Barricades and Services, LLC Electronically Filed 2/28/2020 5:00 PM Hidalgo County District Clerks Reviewed By: J ose Hernandez Maria Korzendorfer Gregg R. Brown Germer Beaman and Brown, PLLC 301 Congress Avenue, Suite 1700, Austin, Texas 78701 Fax: (512) 472-9260 E-mail: mkorzendorfer@germer-austin.com; E-mail: grb-sve@germer-austin.com Attorney for Dustrol, Inc. Mike Mills Susan Sullivan Atlas, Hall & Rodriguez 818 Pecan Blvd., McAllen, Texas 78501 Fax: (956) 686-6109 E-mail: mkmills@atlashall.com; ssullivan@atlashall.com Attorney for DBNK Contracting LLC d/b/a Blue Team Restoration, LLC Analisa Figueroa Law Office of Analisa Figueroa, PLLC 514 Paredes Avenue, Suite H, Brownsville, Texas 78521 Fax: (956) 621-1071 E-mail: analisa@afigueroalaw.com Attorney for Defendant Daniel Sieger Stephen A. Gibson Law Office of Stephen A. Gibson 946 W. Nolana Loop, Suite D, Pharr, Texas 78577 Fax: (956) 284-0986, E-mail: steve@gibson.law Attorney for Cross-Plaintiff Daniel Sieger Michael S. Beckelman Wilson, Elser, Moskowitz, Edelman & Dicker LLP 909 Fannin Street, Suite 3300, Houston, Texas 77010 Fax: (713) 785-7780 E-mail: michael.beckelman@wilsonelser.com Attorney for Defendant People Ready, Inc. Javier Gonzalez Royston, Rayzor, Vickery & Williams, LLP 55 Cove Circle, Brownsville, Texas 78523 Fax: (956) 542-4370 E-mail: javier.gonzalez@roystonlaw.com Attorney for Defendant Texas SAI, Inc. di RICARDO GONZALEZ _