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CAUSE NO. 2006-02596 &
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DISTRICT 215TH JUDICIAL DIST %
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COME NOW, Alief independent School District, Dan Tumer and Henry Bonaparte,
Defendants in the above numbered and entitled cause of action, and pursuant to Texas
Rules of Civil Procedure file this their Designation of Experts:
L. DEFENDANTS’ EXPERTS
Defendants, pursuant to the Texas Rules of Civil Procedure and this Court’s Order,
designate the following expert witnesses:
1 Dr. Francisco |. Perez, Ph.D.
Francisco |. Perez, Ph.D. and Associates, P.C.
6560 Fannin, Suite 1810
Houston, Texas 77030
713/790-1225
Dr. Perez is a clinical psychologist whose CV is attached hereto. Dr. Perez may
testify regarding Plaintiff's claim of mental anguish and any corresponding damages. Dr.
Perez will respond to the testimony of Plaintiffs expert, Dr. Benjamin May, and any other
experts called by Plaintiff to testify as to Plaintiff's mental state, alleged mental anguish, or
mental anguish damages. Dr. Perez will testify as to his own findings, if any, and opinions
as to Plaintiffs mental state.
J. Erik Nichols
Henslee, Fowler, Hepworth & Schwartz, LLP
3200 Southwest Freeway, Suite 1200
Houston, Texas 77027
713/552/1693
RECORDER'S MEMORANDUM
This instrument is ofPoor quitlity.
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at the time of imaging
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Mr. Nichols is the lead attomey assigned to the Perry v. Alief 1.S.D. case with
Henslee, Fowler, Hepworth & Schwartz, LLP. Mr. Nichols will testify regarding attomeys
fees in general as well as specifically to this litigation. Mr. Nichols may also testify with
regard to the reasonableness and necessity of any said attorneys fees.
2 Other Fact Witnesses
Certain other fact witnesses may give expert testimony; however, they have not
been retained as experts by Defendants. These other fact witnesses include, but are not
limited to, those employees of Alief !.S.D., who were disclosed in Defendants’ disclosures.
I oO E E:
Defendants designate any expert designated by Plaintiff.
a | TNE:
Defendants reserve the right to call expert witnesses in rebuttal, whose identities and
testimony cannot reasonably be foreseen until Plaintiff, and/or Defendants have presented
evidence at trial.
VV. TIONS
Defendants reserve the right to elicit expert testimony from any expert designated
or identified by any other party to this lawsuit.
Defendants reserve the right to elicit by cross-examination the opinion testimony of
experts designated and/or called by other parties to this lawsuit.
Defendants reserve 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 same as a consulting expert who cannot be called by
Opposing counsel.
Defendants reserve the right to supplement this designation further within time
limitations imposed by the Court and/or by alterations of same by subsequent court order
2
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and/or by agreement of the parties pursuant to the Texas Rules of Civil Procedure and/or
Texas Rules of Evidence.
Defendants specifically note that discovery in this case is ongoing. As discovery is
completed, it is possible that the designation of additional expert witnesses may be
required. All counsel will be immediately notified of any additional experts that Defendants
may call. The necessity of this reservation is that the need for such testimony cannot be
reasonably anticipated until the foregoing discovery is obtained.
Defendants reserve any and all additional rights they may have with regard to expert
witnesses and testimony under the Texas Rules of Civil Procedure, the Texas Rules of
Evidence and case law and rulings of this Court.
Defendants may also elicit opinion testimony from any other physician who has
provided care or treatment to Plaintiff, which Plaintiff has not disclosed as of this time.
Respectfully submitted,
HENSLEE, FOWLER, HEPWORTH &
SCHWARTZ, L.L.P.
|p
. Erik Nichols
BN 00788119
Kristen Z. Foster
SBN 24040018
3200 Southwest Freeway, Suite 1200
Houston, Texas 77027-7526
(713) 552-1693 - Phone
(743) 552-1697 - Fax
ATTORNEYS FOR DEFENDANTS
CE 1FI TE OF SERVIC!
| certify that a copy of the foregoing was served under Rules 21 ind 21a, Texas
Rules of Civil Procedure, by Facsimile and/or Certified Mail, on this day of March,
2007, upon the following counsel of record:
James L. Reed
Michael A. Ackal, Ill
Looper, Reed & McGraw
1300 Post Oak Blvd., Suite 2000
Houston, Texas 77056
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Kfisten Zingaro Fostér
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Nik Henslee Fowler
Hepworth & Schwartzur AUSTIN DALLAS. FORT WORTH HOUSTON MEALLEN ing THR
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Kristen Zingaro Foster
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March 14, 2007
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Mr. Charles Bacarisse
Harris County District Clerk
201 Caroline
Houston, Texas 77002
Re Cause No. 2006-02596; Troy Perry vs. Alief Independent School District, In
the. 215" Judicial District Court of Harris County, Texas
Dear Mr. Bacarisse:
Enclosed for filing in the above-entitled and numbered cause please find an original
and one copy of the following
. Defendants’ Supplemental Designation of Expert Witnesses
Please file-stamp the enclosed copy and return it to us in the self-addressed
stamped envelope
Thank you for your assistance in this matter. If you have any questions, please do
not hesitate to contact me.
Sincerely,
Dusan
Susan valli,
Legal Assistant to Kristen Zingaro Foster
KAZ/sd
Enclosures
3200S.W. Freeway Suite 1200 Houston, Texas 77027 { 713.552.1693 713.552.1697
fax 877.552.1693 | www.bthslaw.com
wee
“Charles Bacarisse
March 14, 2007
Page 2
cc’ (w/enclosures)
Via Facsimile (713) 986-7100
James L. Reed
Michael A. Ackal, Ill
Looper, Reed & McGraw
1300 Post Oak Bivd., Suite 2000
Houston, Texas 77056
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Preview
. £T Ox, CAUSE NO. 2006-02596 & TROY PERRY, IN THE pistricg GeyGX +REF —“~ 8o>;beBe % % Sy ce Vs. HARRIS COUNT ve vy ALIEF INDEPENDENT SCHOOL ‘ 2DL SS, “ ae s S> DISTRICT 215TH JUDICIAL DIST % Oo oD D, * SU EMENTAL DESIGNATION OF EXPE! WITNESS S COME NOW, Alief independent School District, Dan Tumer and Henry Bonaparte, Defendants in the above numbered and entitled cause of action, and pursuant to Texas Rules of Civil Procedure file this their Designation of Experts: L. DEFENDANTS’ EXPERTS Defendants, pursuant to the Texas Rules of Civil Procedure and this Court’s Order, designate the following expert witnesses: 1 Dr. Francisco |. Perez, Ph.D. Francisco |. Perez, Ph.D. and Associates, P.C. 6560 Fannin, Suite 1810 Houston, Texas 77030 713/790-1225 Dr. Perez is a clinical psychologist whose CV is attached hereto. Dr. Perez may testify regarding Plaintiff's claim of mental anguish and any corresponding damages. Dr. Perez will respond to the testimony of Plaintiffs expert, Dr. Benjamin May, and any other experts called by Plaintiff to testify as to Plaintiff's mental state, alleged mental anguish, or mental anguish damages. Dr. Perez will testify as to his own findings, if any, and opinions as to Plaintiffs mental state. J. Erik Nichols Henslee, Fowler, Hepworth & Schwartz, LLP 3200 Southwest Freeway, Suite 1200 Houston, Texas 77027 713/552/1693 RECORDER'S MEMORANDUM This instrument is ofPoor quitlity. I at the time of imaging a ZN Mr. Nichols is the lead attomey assigned to the Perry v. Alief 1.S.D. case with Henslee, Fowler, Hepworth & Schwartz, LLP. Mr. Nichols will testify regarding attomeys fees in general as well as specifically to this litigation. Mr. Nichols may also testify with regard to the reasonableness and necessity of any said attorneys fees. 2 Other Fact Witnesses Certain other fact witnesses may give expert testimony; however, they have not been retained as experts by Defendants. These other fact witnesses include, but are not limited to, those employees of Alief !.S.D., who were disclosed in Defendants’ disclosures. I oO E E: Defendants designate any expert designated by Plaintiff. a | TNE: Defendants reserve the right to call expert witnesses in rebuttal, whose identities and testimony cannot reasonably be foreseen until Plaintiff, and/or Defendants have presented evidence at trial. VV. TIONS Defendants reserve the right to elicit expert testimony from any expert designated or identified by any other party to this lawsuit. Defendants reserve the right to elicit by cross-examination the opinion testimony of experts designated and/or called by other parties to this lawsuit. Defendants reserve 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 same as a consulting expert who cannot be called by Opposing counsel. Defendants reserve the right to supplement this designation further within time limitations imposed by the Court and/or by alterations of same by subsequent court order 2 an ‘ and/or by agreement of the parties pursuant to the Texas Rules of Civil Procedure and/or Texas Rules of Evidence. Defendants specifically note that discovery in this case is ongoing. As discovery is completed, it is possible that the designation of additional expert witnesses may be required. All counsel will be immediately notified of any additional experts that Defendants may call. The necessity of this reservation is that the need for such testimony cannot be reasonably anticipated until the foregoing discovery is obtained. Defendants reserve any and all additional rights they may have with regard to expert witnesses and testimony under the Texas Rules of Civil Procedure, the Texas Rules of Evidence and case law and rulings of this Court. Defendants may also elicit opinion testimony from any other physician who has provided care or treatment to Plaintiff, which Plaintiff has not disclosed as of this time. Respectfully submitted, HENSLEE, FOWLER, HEPWORTH & SCHWARTZ, L.L.P. |p . Erik Nichols BN 00788119 Kristen Z. Foster SBN 24040018 3200 Southwest Freeway, Suite 1200 Houston, Texas 77027-7526 (713) 552-1693 - Phone (743) 552-1697 - Fax ATTORNEYS FOR DEFENDANTS CE 1FI TE OF SERVIC! | certify that a copy of the foregoing was served under Rules 21 ind 21a, Texas Rules of Civil Procedure, by Facsimile and/or Certified Mail, on this day of March, 2007, upon the following counsel of record: James L. Reed Michael A. Ackal, Ill Looper, Reed & McGraw 1300 Post Oak Blvd., Suite 2000 Houston, Texas 77056 ‘dll Sy foster Kfisten Zingaro Fostér ~ + -* aN Bie RB Nik Henslee Fowler Hepworth & Schwartzur AUSTIN DALLAS. FORT WORTH HOUSTON MEALLEN ing THR ws i NY Kristen Zingaro Foster C hingephoeaty % byMy wy March 14, 2007 ys % vy wy. Ye LON Mr. Charles Bacarisse Harris County District Clerk 201 Caroline Houston, Texas 77002 Re Cause No. 2006-02596; Troy Perry vs. Alief Independent School District, In the. 215" Judicial District Court of Harris County, Texas Dear Mr. Bacarisse: Enclosed for filing in the above-entitled and numbered cause please find an original and one copy of the following . Defendants’ Supplemental Designation of Expert Witnesses Please file-stamp the enclosed copy and return it to us in the self-addressed stamped envelope Thank you for your assistance in this matter. If you have any questions, please do not hesitate to contact me. Sincerely, Dusan Susan valli, Legal Assistant to Kristen Zingaro Foster KAZ/sd Enclosures 3200S.W. Freeway Suite 1200 Houston, Texas 77027 { 713.552.1693 713.552.1697 fax 877.552.1693 | www.bthslaw.com wee “Charles Bacarisse March 14, 2007 Page 2 cc’ (w/enclosures) Via Facsimile (713) 986-7100 James L. Reed Michael A. Ackal, Ill Looper, Reed & McGraw 1300 Post Oak Bivd., Suite 2000 Houston, Texas 77056 == ao aan eo ee z- Fry z= Be & oO