Preview
ye
we
Cause No. 2007-14670 Se Sy.
X
FRANK'S CASING CREW & § IN THE DISTRICT COURT of %
RENTAL TOOLS, INC. § <<,
§ &
VS. § HARRIS COUNTY, TEXAS
%
SUNDANCE RESOURCES, INC. § 333 JUDICIAL DISTRICT
PLAINTIFF FRANK'S CASING CREW & RENTAL TOOLS, INC.'S
DESIGNATION OF EXPERT WITNESSES
TO THE HONORABLE JAMES HALBACH, JR.:
COMES NOW Frank's Casing Crew & Rental Tools, Inc.., Plaintiff in the above-styled
and numbered cause, without waiving its right to name additional expert witnesses and/or
provide supplemental information and designates the following as expert witnesses for the trial
of this cause:
I
RETAINED EXPERTS
Charles R. Dunn
Godwin Pappas Ronquillo L.L.P.
1401 McKinney Street, Suite 2700
Houston, Texas 77010
(713) 425-7400
Kevin T, Dossett
Chamberlain, Hrdlicka, White, Williams & Martin, PC
1200 Smith Street, Suite 1400
Houston, Texas 77002
(713) 654-9662
Mr. Dunn is Of Counsel to the law firm Godwin Pappas Ronquillo, and Mr. Dossett is a
Shareholder of Chamberlain, Hrdlicka, White, Williams, & Martin. The general substance of
Messrs. Dunn's and Dossett's opinions concerns the reasonableness and necessity of the
attorneys’ fees incurred by Frank's Casing Crew & Rental Tools, Inc., in the prosecution of this
action, including hourly charges and the number of hours expended. Messrs. Dunn and Dossett
are expected to testify that $225 per hour for the work up to and including December 31, 2007,
and $250 per hour thereafter is an appropriate hourly charge for a matter of the size and
complexity of the captioned matter. They are further expected to testify that the aggregate
attorneys’ fees accumulated by Frank's Casing Crew & Rental Tools, Inc., at the time of trial
were reasonable and necessary to collect on the open account that Defendant refused to satisfy.
The facts known to Messrs. Dunn and Dossett have been or will be derived from their review of
the pleadings on file or to be filed and all correspondence between the Parties. Frank's Casing
Crew & Rental Tools, Inc., anticipates that Messrs. Dunn and Dossett will review its entire file
as it exists at the time of trial, including, in Mr. Dossett's case, privileged materials, in
preparation for testifying on the reasonableness and necessity of attorneys’ fees.
Messrs. Dunn's and Dossett's resumes and bibliographies are attached as Exhibit "A" and
Exhibit "B", respectively. Neither Mr. Dunn nor Mr. Dossett have prepared a report. They are,
however, available for deposition.
I.
NON-RETAINED EXPERTS
FRANK'S CASING CREW _& RENTAL TOOLS, INC., PERSONNEL
Thomas Bosquez.
Frank's Casing Crew & Rental Tools, Inc.
3735 Hwy. 6 East
Alvin, TX 77511
281-331-1501
Daniel Rodriguez
Frank's Casing Crew & Rental Tools, Inc.
3735 Hwy. 6 East
Alvin, TX 77511
281-331-1501
Jeremiah Leach
Frank's Casing Crew & Rental Tools, Inc.
3735 Hwy. 6 East
Alvin, TX 77511
281-331-1501
Mike Ezell
Frank's Casing Crew & Rental Tools, Inc.
3735 Hwy. 6 East
Alvin, TX 77511
281-331-1501
Jason Waggoner
Frank's Casing Crew & Rental Tools, Inc
3735 Hwy. 6 East
Alvin, TX 77511
281-331-1501
Michael J. Andrepont
Frank's Casing Crew & Rental Tools, Inc.
P.O. Box 51729
Lafayette, LA 70505
337-233-0303
Joan Craft
Frank's Casing Crew & Rental Tools, Inc.
P.O. Box 51729
Lafayette, LA 70505
337-233-0303
Pattie Courcier
Frank's Casing Crew & Rental Tools, Inc.
P.O. Box 51729
Lafayette, LA 70505
337-233-0303
The above individual(s) have has/knowledge of the facts surrounding the contracts and
the events giving rise to this litigation. This/these individual(s) may be called to testify and to
provide lay opinions which are rationally based upon the witness'(es’) perception(s) and helpful
to the fact finder for an understanding of the facts in issue. This/these witness'(es’) opinion(s)
can be obtained through his/their depositions. Frank's Casing Crew & Rental Tools, Inc.,
reserves the right to elicit opinion testimony from all lay witnesses.
Il.
CROSS-EXAMINATION OF DEFENDANT'S EXPERTS
Frank's Casing Crew & Rental Tools, Inc., reserves the right to elicit, by way of cross-
examination, opinion testimony from experts designated and called by the Defendant in this
matter, if any.
Iv.
RIGHT TO CALL REBUTTAL WITNESSES
Frank's Casing Crew & Rental Tools, Inc., reserves the right to call at the trial of this
cause any witness, either fact or expert, designated by any other party to this litigation, who will
testify in rebuttal, and whose identities cannot be known until the presentation of the evidence
against Frank's Casing Crew & Rental Tools, Inc.
Vv.
RIGHT TO WITHDRAW THE DESIGNATION OF ANY EXPERT
Frank's Casing Crew & Rental Tools, Inc., reserves the right to withdraw the designation
of any expert witness and to aver positively that such previously-designated expert will not be
called as an expert witness at trial and to re-designate the same as a consulting expert, who
cannot be called by opposing counsel absent a showing of exceptional circumstances such that it
is impracticable to obtain facts or opinions on the same subject by other means.
VI.
RIGHT TO ELICIT ANY EXPERT OPINION OR LAY OPINION TESTIMONY
Frank's Casing Crew & Rental Tools, Inc., reserves the right to elicit any expert
testimony and/or lay opinion testimony at the time of trial that would assist the jury in
determining material issues of fact.
VII.
RIGHT TO SUPPLEMENT DESIGNATION
Frank's Casing Crew & Rental Tools, Inc., reserves the right to supplement this
designation of experts further within the limitations imposed by the Court or any alterations of
the same by subsequent Court Order and/or by agreement of the parties or pursuant to the Texas
Rules of Civil Procedure and/or the Texas Rules of Evidence.
Vill.
RESERVATION OF ADDITIONAL RIGHTS
Frank's Casing Crew & Rental Tools, Inc., reserves whatever additional rights it may
have with regard to experts, pursuant to the Texas Rules of Civil Procedure, the Texas Rules of
Evidence, the case law construing same, and the rulings of this Honorable Court.
Respectfully submitted,
CHAMBERLAIN, HRDLICKA, WHITE
WILLIAMS & MARTIN
~
ees
KEVIN T. DOSSETT
State Bar No. 24004623
1200 Smith Street, Suite 1400
Houston, Texas 77002
(713) 654-9662—Telephone
(713) 356-1062—Facsimile
ATTORNEY FOR PLAINTIFF
FRANK'S CASING CREW & RENTAL TOOLS, INC.
CERTIFICATE OF SERVICE
Pursuant to the Texas Rules of Civil Procedure, I hereby certify that a true and correct
copy of the foregoing instrument has been furnished to all counsel of record via facsimile, hand
delivery, and/or certified mail-return receipt requested on the 725 Tay of February, 2008, as
indicated:
Charles W. Gameros, Jr., P.C. Via Certified Mail, RRR
Hoge & Gameros, L.L.P.
4311 Oak Lawn Ave., Suite 600
Dallas, Texas 75219 OT
KEVIN T. DOSSE
Lawyer Detail Page | of 1
.
ee:
Gi dwin| Pappas [Ronquillow cs
EHOU
eniSlanessedeh
yj
CHARLES R. DUNN
Of Counsel - Houston
AREAS OF PRACTICE
ra
Commercial Litigation Mass Tort Litigation =
Estate Planning and Probate Personal Injury Trial Law ri
Energy Product Liability wee
od
Labor and Employment
BIOGRAPHY 4
Charles R. “Bob” Dunn practices commercial, estate, employment, mass torts, personal
injury and product liability litigation. He is a successful litigator with more than 100 cases
tried in more than 40 years of practice. Additionally, he began a successful mediation
practice 10 years ago, and served as president of both the Houston Bar Association and Direct Line: n 3.425.7403
Toll Free: 800.662.8393
the State Bar of Texas. He served six years on the Texas State Commission on Judicial Fax: 713.425.7552
Conduct and was Chair of that Commission for two of those years. Download Veard
cdunn@godwinpappas.com
Bob received a J.D. from South Texas College of Law in 1965 and a B.S. in Geological
Engineering from Texas A&M University in 1952. —@ LexisNexis:
tetera
Martindale-Hubbell”
Peer Review Rated
Btanderde
wad Lagal Ablity
Chatles Re (Bob) Bunn
Back. Paint
Le) PAI meToT| LtediTt ea
EXHIBIT
Pas
http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008
Lawyer Detail / Page 1 of 1
win |Pappas|Ronquillou
er i
CHARLES R. DUNN
Of Counsel - Houston
AREAS OF PRACTICE
Commercial Litigation Mass Tort Litigation i
Estate Planning and Probate Personal Injury Trial Law
Energy Product Liability
Labor and Employment
EDUCATION
AV rated Martindale-Hubbell
South Texas College of Law (J.D., 1965}
Direct Line: 713.425.7403
Texas A&M University (B.S., Geological Engineering. 1952) Toll Free: 800.662.8393
Fax: 713.425.7552
Download Veard
cdunn@godwinpappas.com
_@ LexiNeis
Martindale-Hubbell”
Peer Review Rated
For Ete Bandera
aad Langa Abdty
Charles B. (Bob} Dunn
Back Print
ORC GE ii TFACCLe ZL Ela Saat
http:/Awww.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008
Lawyer Detail Page 1 of 1
.
“ Godw Pappas Ronquillow veh
a 5 | HOUSTO!
Es eine,
es 65
CHARLES R. DUNN i.ee
Of Counsel - Houston
AREAS OF PRACTICE
i
Commercial Litigation Mass Tort Litigation
Estate Planning and Probate Personal injury Trai Law
Energy Product Liability
Labor and Employment
REPRESENTATIVE EXPERIENCE i
Commercial Litigation #
Successfully represented the defendant in the case of Rudy Tomjanovich v. Los
Angeles Angeles Lakers, which was tried in federal court in Houston; Tomjanovich
was awarded a substantial verdict; the case was appealed and settled a few days Direct Line: 713.425.7403
Toll Free: 800.662.8393
prior to the scheduled argument before the U.S. Fifth Circuit Court of Appeals Fax: 713.425.7552
Download Veard
Estate Planning, Probate, and Estate Litigation cdunn@godwinpappas.com
Lead counsel in the Guardian of the Estate of Ugo di Portanova (grandson to Hugh
Roy Cullen and Lillie Cullen) v. Quintana Oil and the Co-Executrices of the Estate of —@ LexisNexis
Hugh Roy Cullen and Lillie Cullen, for breach of fiduciary duty growing out of the
Martindale-Hubbell”
administration of those estates Peer Review Rated
For Einvel Beandarde nad Lagu! AbUity
Energy Law
Charles R. (Bob) Dunn
Lead counsel for Manitowac Engineering Company in a series of North Sea cases
involving injury and death to Scottish crane drivers in the North Sea; one of which
was tried to verdict, judgment and ultimate settlement in Federal District Court in
Houston; and, in a related case, appeared as co-counsel to a Scottish Barrister
Back Print
involving an inquest in Aberdeen, Scotland that was tried to conclusion with the court
ruling, "No foul play"
Products Liability
Served as co-counsel in Parker & Parsley v. Baker Hughes and Dresser Industries in
a case growing out of the field operations of Cardinal Chemical, Dresser Industries,
and Baker Hughes over a period of seven years in the West Texas/Midland area;
tried to conclusion with a verdict of hundreds of millions against Dresser and Baker
Hughes: the case was appealed to the U.S. Fifth Circuit Court of Appeals, reversed,
dismissed, then refilled in state court and ultimately settled during the course of the
third mediation for a confidential amount
In related litigation to the Parker & Parsley v. Baker Hughes and Dresser, provided
co-counseled in a case against Lloyd's Insurance for failure to provide a defense and
indemnity for the original lawsuit; that case was settled very favorably for Dresser for
a confidential amount
fo) is ie eV RacTeeSR CL Lene a
http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008
Lawyer Detail Page 1 of |
in| ppas [Ronquillow
a3 ms :
eh oc
AS f
CHARLES R. DUNN
Of Counsel - Houston
keLs
es
AREAS OF PRACTICE
Commercial Litigation Mass Tort Litigation
Estate Planning and Probate Persona! Injury Trial Law te
Energy Product Liability
Labor and Employment
HONORS AND AWARDS
Selected as one of Houston's "Top Lawyers for the People" by H Texas magazine,
2008
Selected as one of "Houston's Top Lawyers” by H Texas magazine, 2006 - 2007 Direct Line: 713.425.7403
Toll Free: 800.662.8393
American Bar Foundation, Fellow Fax: 713.425.7552
Download Veard
Houston Association of Legal Secretaries, Boss of the Year, 1981 cdunn@godwinpappas.com
South Texas College of Law Distinguished Alumnus, 1980 .
LexisNexis"
Texas Aggie Bar Association, President, 1988-89
uN
Martindale-Hubbell”
Peer Review Rated
For Ethel Standards
and Logl Abs
Charles R. {Bob} Dunn
Back Print ;
a) NateLn eratFae NCL DESMO] ma
http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008
Lawyer Detail / Page | of |
in|Pappas|Ronquillow ee
FHOUSTO
CHARLES R. DUNN
Of Counsel - Houston
AREAS OF PRACTICE
ti
Commercial Litigation
Estate Planning and Probate
Energy
Mass Tort Litgation
Personal Injury Trai Law
Product Liability
i
Labor and Employment ae
ADMITTED TO PRACTICE
State Courts of Texas
U.S. Court of Appeais, Fifth Circuit
Direct Line: 713.425.7403
U.S. District Courts for the Northern, Southern, Eastern and Western Districts of Toll Free: 800.662.8393
Texas Fax: 713.425.7552
Download Veard
U.S. Supreme Court cdunn@godwinpappas.com
LexisNexis
@ Martindale-Hubbell”
Peer Review Rated
Fo Eile! Standards
aad Legal Anaity
Charles R. (Bob) Dunn
Back ‘Print
By itd
oom oe cont] ne
http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008
Lawyer Detail Page lofl
ses
a ae=
Godwin Pappas Ronquillo. esme
Hf
basse
CHARLES R. DUNN
Of Counsel - Houston
ee
AREAS OF PRACTICE
i; bs r
Commercial Litigation Mass Tort Litigation
Estate Planning and Probate Personal Injury Trial Law
Energy Product Liability
a
Labor and Employment
Fi
PRESENTATIONS AND PUBLICATIONS
Tribute to Fred Parks, 2003
The Institute for Responsible Dispute Resolution: Designing New ADR System for
Fast, Efficient, and Effective Resolution of Business Disputes, 2002 Direct Line: 713.425.7403
Toll Free; 800.662.8393
The Tort of Bad Faith, 1998 Fax: 713.425.7552
Download Veard
Alternative Sources of Discovery, 1996 cdunn@godwinpappas.com
Cross-Examination of Experts, 1994
LexisNexis"
—
The Ultimate Trial Notebook, 1993 Martindale-Hubbell”
Peer Review Rated
Chemically Induced Immune Dysfunctions, 1989
For Enelandar wt Age ADU
The Lawyer as a Target: Problems Facing Defendant's Counsel, 1989
Charles B. Bob} Dunn
Expert Witnesses and Attorneys: An Interdisciplinary Team, 1987
Psychic Injury, 1987
Back Print.
Selection, Preparation & Presentation of Expert Witnesses, 1987
Use of Experts in Litigation, 1987
Use of a Psychiatrist as an Expert Witness, 1987
mM Lis Faces msg1 Lite] ea
http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008
Lawyer Detail Page | of 2
ie
Go in ppas |Ronquillow fe
a i GLAS 3
rage
i
CHARLES R. DUNN
A
Of Counsel - Houston
AREAS OF PRACTICE
Commercial Litigation Mass fort Litigation Md
Estate Pianning and Probate
Energy
Personal Injury Trial Law
Product Liability
a
Labor and Employment
MEMBER
American Bar Association
House of Delegates, 1992-1997
Direct Line: 713.425.7403
Toll Free: 800.662.8393
American Board of Trial Advocates, 1990 to present Fax: 713.425.7552
Association of Trial Lawyers of America, 1994 to present
Download Veard
cdunn@godwinpappas.com
Houston Bar Association
President, 1979-1980
LexisN
Martindale-I ul
Houston Bar Foundation Peer Review Rated
For Etlcal Bhandaris
wed Lege Abby
Life Fellow, 1983 to present Charles R. «{Bob} Dunn
International Association of Defense Counsel, 1993 to present
International Centers for Arbitration (ICA), Certified Panelist
Back Print
State Bar of Texas
President, 1991
Board of Directors, 1984-1987, 1990-1993
Chairman, Long-Range Planning Committee, 1989-1990
Chairman, Legal Issues Sub-Committee, Sunset Committee, 1989-1990
Texas Association of Defense Counsel, 1970 to present
Texas Bar Foundation
Sustaining Life Fellow, 1977 to present
Chair, Fellows of the Texas Bar Foundation, 1998-1999
Texas Commission on Judicial Conduct, Commissioner, 1990-1996
Chair, 1994 - 1996
Texas Young Lawyers Association, Board of Directors, Honorary Young Lawyer,
http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008
Lawyer Detail Page 2 of 2
1985
OMG Nae ecuPmmerele ni mses) O Tt Le ma
http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008
Lawyer Detail Page | of 1
Godwin | Pappas (Ronquillow
Te
ae ical
Hi STON:
oe
CHARLES R. DUNN
Of Counsel - Houston
AREAS OF PRACTICE
eu
Commercial Litigation Mass Tort Litigation Sey
Estate Planning and Probate Personal Injury Thal Law
Energy Product Liability
Labor and Employment
COMMUNITY
Board of Directors, South Texas College of Law, 1980 to present
Executive Committee, South Texas College of Law, 1998 to present
Direct Line: 713.425.7403
Mr. Dunn served on active duty with the United States Army, seeing action in Korea Tolt Free: 800.662.8393
as an Artillery Forward Observer on Heartbreak Ridge and later as Commanding Fax: 713.425.7552
Officer of “A" Battery of the 158th Field Artillery Battalion of the 45th Infantry Division Download Veard
cdunn@godwinpappas.com
LexisNexis" _
jindale-Hubbell”
Peer Review Rated
For ct Standart
aa Lager Ay
Charles R. (Bob? Bunn
Back Print
ten Hg PA Umer El One ead
http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008
Kevin T. Dossett
1639 Sage Street, Houston, Texas 77009
Pho! : 713/412-7764
Em rma mucglobal nt
EMPLOYMENT:
Chamberlain, Hrdlicka, White, Williams & Martin, P.C., Houston, Texas (Shareholder)
Full-service general civil trial practice with a focus on admiralty and energy-related matters.
Primary representation includes international and domestic drilling contractors, exploration
and production companies, offshore construction and diving contractors, dredging contractors,
both insured and self-insured local, national and international concerns.
Admissions:
*State Bar of Texas
United States District Court, Southern District of Texas
«United States District Court, Eastern District of Texas
*United States District Court, Northern District of Texas
«United States Court of Appeals for the Fifth Federal Circuit
Associations:
«Texas State Bar Association
* Houston Bar Association
Bar Association of the Fifth Federal Circuit
Maritime Law Association (Personnel and Young Lawyers Committees)
Federalist Society for Law and Public Policy
EDUCATION:
Tulane University School of Law, New Orleans, Louisiana
Master of Laws (admiralty), May 1997
Scholarships/Awards:
Graduate Fellowship in Maritime Law: Awarded by the Maritime Law Center. Carries an award covering
tuition and fees, as well as a stipend for living expenses. Duties include assisting Professor Robert Force, Director
of the Maritime Law Center, with research and writing of books and articles on maritime law, the development of
teaching materials, and the preparation of seminars in maritime law.
University of Mississippi School of Law, Oxford, Mississippi
Juris Doctorate, May 1996
Primary Extracurricular Activities:
Executive & Managing Editor, Journal of National Security Law (1995-96): Served as a founding member and
officer of the Board of Student Editors of JNSL, a periodical dedicated to giving exclusive focus to national
security legal issues, and produced through the combined efforts of the University of Mississippi School of Law,
EXHIBIT
}3 XB “
the Center for National Security Law at the University of Virginia School of Law, and the Center for Law, Ethics
and National Security at the Duke University School of Law. Managed the day-to-day administrative, editorial
and business operations of the journal, overseeing a staff of 25; Served as liaison to the national security
community through attendance at various conferences and seminars.
Member, Mississippi Law Journal (1994-96): Served as a staff member of the University’s flagship journal, a
student-run and student-edited legal periodical committed to publishing practical and scholarly articles, comments,
and casenotes on a variety of legal topics of interest to the practicing Bar. Responsible for editorial research, as
well as writing briefs of recent Mississippi Supreme Court Opinions for the journal’s commercial briefing service.
Research Assistant, Prof. Ronald Rychlak (1994-96): Assisted professor Rychlak with research/editorial
development for various law review articles (primarily in the areas of environmental and criminal law), as well as
a treatise on the law of evidence (REAL AND DEMONSTRATIVE EVIDENCE: APPLICATIONS AND THEORY (Michie
1995)); assisted with research and preparation of materials for consultations on criminal and environmental cases.
Additional Extracurricular Activities:
«Member, The William C. Keady American Inn of Court
«Vice-President, The Ole Miss Federalist Society
¢Member, The International Law Society
Nicholls State University, Thibodaux, Louisiana
Bachelor of Arts (magna cum laude), History, 1992
Honors:
Phi Kappa Phi
Phi Alpha Theta
National Dean's List
NSU President's List, 1989-92
*The German Award
CHAMBERLAIN, HRDLICKA, WHITE, WILLIAMS & MARTIN
A PARTNERSHIP OF PROFESSIONAL CORPORATIONS, 2M
re
Sr vcs Y
ATTORNEYS AT LAW
1200 SMITH STREET, SUITE 1400,
tQTLANTA,
KEVIN T. DOSSETT
HOUSTON, TEXAS 77002 Ss port pin
ATTORNEY AT LAW (713) 658-1818 (800) 342-5829 ae or
DIRECT DIAL NO. (713) 654-9662
DIRECT FAX NO, (713) 356-1062 (713) 658-2553 (FAX) Be.
Ae? @
%
E-MAIL: kevin dossett@chamberlainiaw.com, oo
www.chamberlainiaw.com,
February 25, 2008
@
Honorable Charles Bacarisse Via Certified Mail
Harris County District Clerk
201 Caroline
Houston, Texas 77002
Re: Cause No. 2007-14670; Frank's Casing Crew & Rental Tools, Inc. vs. Sundance
Resources, Inc.; In the 333rd Judicial District Court of Harris County, Texas.
CH File No.: 6542.4
Dear Sir:
Enclosed are the original and one copy of the following for filing among the papers of the
above-captioned cause:
1 Plaintiff Frank's Casing Crew & Rental Tools, Inc.'s Designation of Expert
Witnesses.
Please place your file-stamp mark on the extra copy of the enclosed pleading, and return
the extra copy to me for my file in the enclosed self-addressed, postage-paid envelope. By copy
of this correspondence, all known counsel of record have been served with a copy of this
document. Thank you for your assistance.
Yours truly,
to ee
Kevin T. Dossett
KTD:jmh
Enclosures
0616390.01
006542-000004:2/25/2008
cc: Charles W. Gameros, Jr., P.C. Via Certified Mail, RRR
THF meRITAS Law Fins WORLDWIDE
Preview
ye we Cause No. 2007-14670 Se Sy. X FRANK'S CASING CREW & § IN THE DISTRICT COURT of % RENTAL TOOLS, INC. § <<, § & VS. § HARRIS COUNTY, TEXAS % SUNDANCE RESOURCES, INC. § 333 JUDICIAL DISTRICT PLAINTIFF FRANK'S CASING CREW & RENTAL TOOLS, INC.'S DESIGNATION OF EXPERT WITNESSES TO THE HONORABLE JAMES HALBACH, JR.: COMES NOW Frank's Casing Crew & Rental Tools, Inc.., Plaintiff in the above-styled and numbered cause, without waiving its right to name additional expert witnesses and/or provide supplemental information and designates the following as expert witnesses for the trial of this cause: I RETAINED EXPERTS Charles R. Dunn Godwin Pappas Ronquillo L.L.P. 1401 McKinney Street, Suite 2700 Houston, Texas 77010 (713) 425-7400 Kevin T, Dossett Chamberlain, Hrdlicka, White, Williams & Martin, PC 1200 Smith Street, Suite 1400 Houston, Texas 77002 (713) 654-9662 Mr. Dunn is Of Counsel to the law firm Godwin Pappas Ronquillo, and Mr. Dossett is a Shareholder of Chamberlain, Hrdlicka, White, Williams, & Martin. The general substance of Messrs. Dunn's and Dossett's opinions concerns the reasonableness and necessity of the attorneys’ fees incurred by Frank's Casing Crew & Rental Tools, Inc., in the prosecution of this action, including hourly charges and the number of hours expended. Messrs. Dunn and Dossett are expected to testify that $225 per hour for the work up to and including December 31, 2007, and $250 per hour thereafter is an appropriate hourly charge for a matter of the size and complexity of the captioned matter. They are further expected to testify that the aggregate attorneys’ fees accumulated by Frank's Casing Crew & Rental Tools, Inc., at the time of trial were reasonable and necessary to collect on the open account that Defendant refused to satisfy. The facts known to Messrs. Dunn and Dossett have been or will be derived from their review of the pleadings on file or to be filed and all correspondence between the Parties. Frank's Casing Crew & Rental Tools, Inc., anticipates that Messrs. Dunn and Dossett will review its entire file as it exists at the time of trial, including, in Mr. Dossett's case, privileged materials, in preparation for testifying on the reasonableness and necessity of attorneys’ fees. Messrs. Dunn's and Dossett's resumes and bibliographies are attached as Exhibit "A" and Exhibit "B", respectively. Neither Mr. Dunn nor Mr. Dossett have prepared a report. They are, however, available for deposition. I. NON-RETAINED EXPERTS FRANK'S CASING CREW _& RENTAL TOOLS, INC., PERSONNEL Thomas Bosquez. Frank's Casing Crew & Rental Tools, Inc. 3735 Hwy. 6 East Alvin, TX 77511 281-331-1501 Daniel Rodriguez Frank's Casing Crew & Rental Tools, Inc. 3735 Hwy. 6 East Alvin, TX 77511 281-331-1501 Jeremiah Leach Frank's Casing Crew & Rental Tools, Inc. 3735 Hwy. 6 East Alvin, TX 77511 281-331-1501 Mike Ezell Frank's Casing Crew & Rental Tools, Inc. 3735 Hwy. 6 East Alvin, TX 77511 281-331-1501 Jason Waggoner Frank's Casing Crew & Rental Tools, Inc 3735 Hwy. 6 East Alvin, TX 77511 281-331-1501 Michael J. Andrepont Frank's Casing Crew & Rental Tools, Inc. P.O. Box 51729 Lafayette, LA 70505 337-233-0303 Joan Craft Frank's Casing Crew & Rental Tools, Inc. P.O. Box 51729 Lafayette, LA 70505 337-233-0303 Pattie Courcier Frank's Casing Crew & Rental Tools, Inc. P.O. Box 51729 Lafayette, LA 70505 337-233-0303 The above individual(s) have has/knowledge of the facts surrounding the contracts and the events giving rise to this litigation. This/these individual(s) may be called to testify and to provide lay opinions which are rationally based upon the witness'(es’) perception(s) and helpful to the fact finder for an understanding of the facts in issue. This/these witness'(es’) opinion(s) can be obtained through his/their depositions. Frank's Casing Crew & Rental Tools, Inc., reserves the right to elicit opinion testimony from all lay witnesses. Il. CROSS-EXAMINATION OF DEFENDANT'S EXPERTS Frank's Casing Crew & Rental Tools, Inc., reserves the right to elicit, by way of cross- examination, opinion testimony from experts designated and called by the Defendant in this matter, if any. Iv. RIGHT TO CALL REBUTTAL WITNESSES Frank's Casing Crew & Rental Tools, Inc., reserves the right to call at the trial of this cause any witness, either fact or expert, designated by any other party to this litigation, who will testify in rebuttal, and whose identities cannot be known until the presentation of the evidence against Frank's Casing Crew & Rental Tools, Inc. Vv. RIGHT TO WITHDRAW THE DESIGNATION OF ANY EXPERT Frank's Casing Crew & Rental Tools, Inc., reserves the right to withdraw the designation of any expert witness and to aver positively that such previously-designated expert will not be called as an expert witness at trial and to re-designate the same as a consulting expert, who cannot be called by opposing counsel absent a showing of exceptional circumstances such that it is impracticable to obtain facts or opinions on the same subject by other means. VI. RIGHT TO ELICIT ANY EXPERT OPINION OR LAY OPINION TESTIMONY Frank's Casing Crew & Rental Tools, Inc., reserves the right to elicit any expert testimony and/or lay opinion testimony at the time of trial that would assist the jury in determining material issues of fact. VII. RIGHT TO SUPPLEMENT DESIGNATION Frank's Casing Crew & Rental Tools, Inc., reserves the right to supplement this designation of experts further within the limitations imposed by the Court or any alterations of the same by subsequent Court Order and/or by agreement of the parties or pursuant to the Texas Rules of Civil Procedure and/or the Texas Rules of Evidence. Vill. RESERVATION OF ADDITIONAL RIGHTS Frank's Casing Crew & Rental Tools, Inc., reserves whatever additional rights it may have with regard to experts, pursuant to the Texas Rules of Civil Procedure, the Texas Rules of Evidence, the case law construing same, and the rulings of this Honorable Court. Respectfully submitted, CHAMBERLAIN, HRDLICKA, WHITE WILLIAMS & MARTIN ~ ees KEVIN T. DOSSETT State Bar No. 24004623 1200 Smith Street, Suite 1400 Houston, Texas 77002 (713) 654-9662—Telephone (713) 356-1062—Facsimile ATTORNEY FOR PLAINTIFF FRANK'S CASING CREW & RENTAL TOOLS, INC. CERTIFICATE OF SERVICE Pursuant to the Texas Rules of Civil Procedure, I hereby certify that a true and correct copy of the foregoing instrument has been furnished to all counsel of record via facsimile, hand delivery, and/or certified mail-return receipt requested on the 725 Tay of February, 2008, as indicated: Charles W. Gameros, Jr., P.C. Via Certified Mail, RRR Hoge & Gameros, L.L.P. 4311 Oak Lawn Ave., Suite 600 Dallas, Texas 75219 OT KEVIN T. DOSSE Lawyer Detail Page | of 1 . ee: Gi dwin| Pappas [Ronquillow cs EHOU eniSlanessedeh yj CHARLES R. DUNN Of Counsel - Houston AREAS OF PRACTICE ra Commercial Litigation Mass Tort Litigation = Estate Planning and Probate Personal Injury Trial Law ri Energy Product Liability wee od Labor and Employment BIOGRAPHY 4 Charles R. “Bob” Dunn practices commercial, estate, employment, mass torts, personal injury and product liability litigation. He is a successful litigator with more than 100 cases tried in more than 40 years of practice. Additionally, he began a successful mediation practice 10 years ago, and served as president of both the Houston Bar Association and Direct Line: n 3.425.7403 Toll Free: 800.662.8393 the State Bar of Texas. He served six years on the Texas State Commission on Judicial Fax: 713.425.7552 Conduct and was Chair of that Commission for two of those years. Download Veard cdunn@godwinpappas.com Bob received a J.D. from South Texas College of Law in 1965 and a B.S. in Geological Engineering from Texas A&M University in 1952. —@ LexisNexis: tetera Martindale-Hubbell” Peer Review Rated Btanderde wad Lagal Ablity Chatles Re (Bob) Bunn Back. Paint Le) PAI meToT| LtediTt ea EXHIBIT Pas http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008 Lawyer Detail / Page 1 of 1 win |Pappas|Ronquillou er i CHARLES R. DUNN Of Counsel - Houston AREAS OF PRACTICE Commercial Litigation Mass Tort Litigation i Estate Planning and Probate Personal Injury Trial Law Energy Product Liability Labor and Employment EDUCATION AV rated Martindale-Hubbell South Texas College of Law (J.D., 1965} Direct Line: 713.425.7403 Texas A&M University (B.S., Geological Engineering. 1952) Toll Free: 800.662.8393 Fax: 713.425.7552 Download Veard cdunn@godwinpappas.com _@ LexiNeis Martindale-Hubbell” Peer Review Rated For Ete Bandera aad Langa Abdty Charles B. (Bob} Dunn Back Print ORC GE ii TFACCLe ZL Ela Saat http:/Awww.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008 Lawyer Detail Page 1 of 1 . “ Godw Pappas Ronquillow veh a 5 | HOUSTO! Es eine, es 65 CHARLES R. DUNN i.ee Of Counsel - Houston AREAS OF PRACTICE i Commercial Litigation Mass Tort Litigation Estate Planning and Probate Personal injury Trai Law Energy Product Liability Labor and Employment REPRESENTATIVE EXPERIENCE i Commercial Litigation # Successfully represented the defendant in the case of Rudy Tomjanovich v. Los Angeles Angeles Lakers, which was tried in federal court in Houston; Tomjanovich was awarded a substantial verdict; the case was appealed and settled a few days Direct Line: 713.425.7403 Toll Free: 800.662.8393 prior to the scheduled argument before the U.S. Fifth Circuit Court of Appeals Fax: 713.425.7552 Download Veard Estate Planning, Probate, and Estate Litigation cdunn@godwinpappas.com Lead counsel in the Guardian of the Estate of Ugo di Portanova (grandson to Hugh Roy Cullen and Lillie Cullen) v. Quintana Oil and the Co-Executrices of the Estate of —@ LexisNexis Hugh Roy Cullen and Lillie Cullen, for breach of fiduciary duty growing out of the Martindale-Hubbell” administration of those estates Peer Review Rated For Einvel Beandarde nad Lagu! AbUity Energy Law Charles R. (Bob) Dunn Lead counsel for Manitowac Engineering Company in a series of North Sea cases involving injury and death to Scottish crane drivers in the North Sea; one of which was tried to verdict, judgment and ultimate settlement in Federal District Court in Houston; and, in a related case, appeared as co-counsel to a Scottish Barrister Back Print involving an inquest in Aberdeen, Scotland that was tried to conclusion with the court ruling, "No foul play" Products Liability Served as co-counsel in Parker & Parsley v. Baker Hughes and Dresser Industries in a case growing out of the field operations of Cardinal Chemical, Dresser Industries, and Baker Hughes over a period of seven years in the West Texas/Midland area; tried to conclusion with a verdict of hundreds of millions against Dresser and Baker Hughes: the case was appealed to the U.S. Fifth Circuit Court of Appeals, reversed, dismissed, then refilled in state court and ultimately settled during the course of the third mediation for a confidential amount In related litigation to the Parker & Parsley v. Baker Hughes and Dresser, provided co-counseled in a case against Lloyd's Insurance for failure to provide a defense and indemnity for the original lawsuit; that case was settled very favorably for Dresser for a confidential amount fo) is ie eV RacTeeSR CL Lene a http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008 Lawyer Detail Page 1 of | in| ppas [Ronquillow a3 ms : eh oc AS f CHARLES R. DUNN Of Counsel - Houston keLs es AREAS OF PRACTICE Commercial Litigation Mass Tort Litigation Estate Planning and Probate Persona! Injury Trial Law te Energy Product Liability Labor and Employment HONORS AND AWARDS Selected as one of Houston's "Top Lawyers for the People" by H Texas magazine, 2008 Selected as one of "Houston's Top Lawyers” by H Texas magazine, 2006 - 2007 Direct Line: 713.425.7403 Toll Free: 800.662.8393 American Bar Foundation, Fellow Fax: 713.425.7552 Download Veard Houston Association of Legal Secretaries, Boss of the Year, 1981 cdunn@godwinpappas.com South Texas College of Law Distinguished Alumnus, 1980 . LexisNexis" Texas Aggie Bar Association, President, 1988-89 uN Martindale-Hubbell” Peer Review Rated For Ethel Standards and Logl Abs Charles R. {Bob} Dunn Back Print ; a) NateLn eratFae NCL DESMO] ma http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008 Lawyer Detail / Page | of | in|Pappas|Ronquillow ee FHOUSTO CHARLES R. DUNN Of Counsel - Houston AREAS OF PRACTICE ti Commercial Litigation Estate Planning and Probate Energy Mass Tort Litgation Personal Injury Trai Law Product Liability i Labor and Employment ae ADMITTED TO PRACTICE State Courts of Texas U.S. Court of Appeais, Fifth Circuit Direct Line: 713.425.7403 U.S. District Courts for the Northern, Southern, Eastern and Western Districts of Toll Free: 800.662.8393 Texas Fax: 713.425.7552 Download Veard U.S. Supreme Court cdunn@godwinpappas.com LexisNexis @ Martindale-Hubbell” Peer Review Rated Fo Eile! Standards aad Legal Anaity Charles R. (Bob) Dunn Back ‘Print By itd oom oe cont] ne http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008 Lawyer Detail Page lofl ses a ae= Godwin Pappas Ronquillo. esme Hf basse CHARLES R. DUNN Of Counsel - Houston ee AREAS OF PRACTICE i; bs r Commercial Litigation Mass Tort Litigation Estate Planning and Probate Personal Injury Trial Law Energy Product Liability a Labor and Employment Fi PRESENTATIONS AND PUBLICATIONS Tribute to Fred Parks, 2003 The Institute for Responsible Dispute Resolution: Designing New ADR System for Fast, Efficient, and Effective Resolution of Business Disputes, 2002 Direct Line: 713.425.7403 Toll Free; 800.662.8393 The Tort of Bad Faith, 1998 Fax: 713.425.7552 Download Veard Alternative Sources of Discovery, 1996 cdunn@godwinpappas.com Cross-Examination of Experts, 1994 LexisNexis" — The Ultimate Trial Notebook, 1993 Martindale-Hubbell” Peer Review Rated Chemically Induced Immune Dysfunctions, 1989 For Enelandar wt Age ADU The Lawyer as a Target: Problems Facing Defendant's Counsel, 1989 Charles B. Bob} Dunn Expert Witnesses and Attorneys: An Interdisciplinary Team, 1987 Psychic Injury, 1987 Back Print. Selection, Preparation & Presentation of Expert Witnesses, 1987 Use of Experts in Litigation, 1987 Use of a Psychiatrist as an Expert Witness, 1987 mM Lis Faces msg1 Lite] ea http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008 Lawyer Detail Page | of 2 ie Go in ppas |Ronquillow fe a i GLAS 3 rage i CHARLES R. DUNN A Of Counsel - Houston AREAS OF PRACTICE Commercial Litigation Mass fort Litigation Md Estate Pianning and Probate Energy Personal Injury Trial Law Product Liability a Labor and Employment MEMBER American Bar Association House of Delegates, 1992-1997 Direct Line: 713.425.7403 Toll Free: 800.662.8393 American Board of Trial Advocates, 1990 to present Fax: 713.425.7552 Association of Trial Lawyers of America, 1994 to present Download Veard cdunn@godwinpappas.com Houston Bar Association President, 1979-1980 LexisN Martindale-I ul Houston Bar Foundation Peer Review Rated For Etlcal Bhandaris wed Lege Abby Life Fellow, 1983 to present Charles R. «{Bob} Dunn International Association of Defense Counsel, 1993 to present International Centers for Arbitration (ICA), Certified Panelist Back Print State Bar of Texas President, 1991 Board of Directors, 1984-1987, 1990-1993 Chairman, Long-Range Planning Committee, 1989-1990 Chairman, Legal Issues Sub-Committee, Sunset Committee, 1989-1990 Texas Association of Defense Counsel, 1970 to present Texas Bar Foundation Sustaining Life Fellow, 1977 to present Chair, Fellows of the Texas Bar Foundation, 1998-1999 Texas Commission on Judicial Conduct, Commissioner, 1990-1996 Chair, 1994 - 1996 Texas Young Lawyers Association, Board of Directors, Honorary Young Lawyer, http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008 Lawyer Detail Page 2 of 2 1985 OMG Nae ecuPmmerele ni mses) O Tt Le ma http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008 Lawyer Detail Page | of 1 Godwin | Pappas (Ronquillow Te ae ical Hi STON: oe CHARLES R. DUNN Of Counsel - Houston AREAS OF PRACTICE eu Commercial Litigation Mass Tort Litigation Sey Estate Planning and Probate Personal Injury Thal Law Energy Product Liability Labor and Employment COMMUNITY Board of Directors, South Texas College of Law, 1980 to present Executive Committee, South Texas College of Law, 1998 to present Direct Line: 713.425.7403 Mr. Dunn served on active duty with the United States Army, seeing action in Korea Tolt Free: 800.662.8393 as an Artillery Forward Observer on Heartbreak Ridge and later as Commanding Fax: 713.425.7552 Officer of “A" Battery of the 158th Field Artillery Battalion of the 45th Infantry Division Download Veard cdunn@godwinpappas.com LexisNexis" _ jindale-Hubbell” Peer Review Rated For ct Standart aa Lager Ay Charles R. (Bob? Bunn Back Print ten Hg PA Umer El One ead http://www.godwinpappas.com/Lawyers/lawyer.aspx?id=246 2/25/2008 Kevin T. Dossett 1639 Sage Street, Houston, Texas 77009 Pho! : 713/412-7764 Em rma mucglobal nt EMPLOYMENT: Chamberlain, Hrdlicka, White, Williams & Martin, P.C., Houston, Texas (Shareholder) Full-service general civil trial practice with a focus on admiralty and energy-related matters. Primary representation includes international and domestic drilling contractors, exploration and production companies, offshore construction and diving contractors, dredging contractors, both insured and self-insured local, national and international concerns. Admissions: *State Bar of Texas United States District Court, Southern District of Texas «United States District Court, Eastern District of Texas *United States District Court, Northern District of Texas «United States Court of Appeals for the Fifth Federal Circuit Associations: «Texas State Bar Association * Houston Bar Association Bar Association of the Fifth Federal Circuit Maritime Law Association (Personnel and Young Lawyers Committees) Federalist Society for Law and Public Policy EDUCATION: Tulane University School of Law, New Orleans, Louisiana Master of Laws (admiralty), May 1997 Scholarships/Awards: Graduate Fellowship in Maritime Law: Awarded by the Maritime Law Center. Carries an award covering tuition and fees, as well as a stipend for living expenses. Duties include assisting Professor Robert Force, Director of the Maritime Law Center, with research and writing of books and articles on maritime law, the development of teaching materials, and the preparation of seminars in maritime law. University of Mississippi School of Law, Oxford, Mississippi Juris Doctorate, May 1996 Primary Extracurricular Activities: Executive & Managing Editor, Journal of National Security Law (1995-96): Served as a founding member and officer of the Board of Student Editors of JNSL, a periodical dedicated to giving exclusive focus to national security legal issues, and produced through the combined efforts of the University of Mississippi School of Law, EXHIBIT }3 XB “ the Center for National Security Law at the University of Virginia School of Law, and the Center for Law, Ethics and National Security at the Duke University School of Law. Managed the day-to-day administrative, editorial and business operations of the journal, overseeing a staff of 25; Served as liaison to the national security community through attendance at various conferences and seminars. Member, Mississippi Law Journal (1994-96): Served as a staff member of the University’s flagship journal, a student-run and student-edited legal periodical committed to publishing practical and scholarly articles, comments, and casenotes on a variety of legal topics of interest to the practicing Bar. Responsible for editorial research, as well as writing briefs of recent Mississippi Supreme Court Opinions for the journal’s commercial briefing service. Research Assistant, Prof. Ronald Rychlak (1994-96): Assisted professor Rychlak with research/editorial development for various law review articles (primarily in the areas of environmental and criminal law), as well as a treatise on the law of evidence (REAL AND DEMONSTRATIVE EVIDENCE: APPLICATIONS AND THEORY (Michie 1995)); assisted with research and preparation of materials for consultations on criminal and environmental cases. Additional Extracurricular Activities: «Member, The William C. Keady American Inn of Court «Vice-President, The Ole Miss Federalist Society ¢Member, The International Law Society Nicholls State University, Thibodaux, Louisiana Bachelor of Arts (magna cum laude), History, 1992 Honors: Phi Kappa Phi Phi Alpha Theta National Dean's List NSU President's List, 1989-92 *The German Award CHAMBERLAIN, HRDLICKA, WHITE, WILLIAMS & MARTIN A PARTNERSHIP OF PROFESSIONAL CORPORATIONS, 2M re Sr vcs Y ATTORNEYS AT LAW 1200 SMITH STREET, SUITE 1400, tQTLANTA, KEVIN T. DOSSETT HOUSTON, TEXAS 77002 Ss port pin ATTORNEY AT LAW (713) 658-1818 (800) 342-5829 ae or DIRECT DIAL NO. (713) 654-9662 DIRECT FAX NO, (713) 356-1062 (713) 658-2553 (FAX) Be. Ae? @ % E-MAIL: kevin dossett@chamberlainiaw.com, oo www.chamberlainiaw.com, February 25, 2008 @ Honorable Charles Bacarisse Via Certified Mail Harris County District Clerk 201 Caroline Houston, Texas 77002 Re: Cause No. 2007-14670; Frank's Casing Crew & Rental Tools, Inc. vs. Sundance Resources, Inc.; In the 333rd Judicial District Court of Harris County, Texas. CH File No.: 6542.4 Dear Sir: Enclosed are the original and one copy of the following for filing among the papers of the above-captioned cause: 1 Plaintiff Frank's Casing Crew & Rental Tools, Inc.'s Designation of Expert Witnesses. Please place your file-stamp mark on the extra copy of the enclosed pleading, and return the extra copy to me for my file in the enclosed self-addressed, postage-paid envelope. By copy of this correspondence, all known counsel of record have been served with a copy of this document. Thank you for your assistance. Yours truly, to ee Kevin T. Dossett KTD:jmh Enclosures 0616390.01 006542-000004:2/25/2008 cc: Charles W. Gameros, Jr., P.C. Via Certified Mail, RRR THF meRITAS Law Fins WORLDWIDE