On May 24, 2017 a
Plaintiff's Designation of Experts
was filed
involving a dispute between
Tejas Tubular Products, Inc.,
and
Command Drilling Products Usa, Ltd.,
for Debt/Contract - Debt/Contract
in the District Court of Harris County.
Preview
Cause No. 2017 35132
TEJAS TUBULAR PRODUCTS, INC. § IN THE DISTRICT COURT OF
Plaintiff
§
V. § HARRIS COUNTY, TEXAS
COMMAND DRILLING PRODUCTS §
USA, Ltd. §
§
Defendant § 164th JUDICIAL DISTRICT
PLAINTIFF'S ESIGNATION OF EXPERTS
PLEASE TAKE NOTICE that, pursuant to the provisions of the Texas
Rules of Civil Procedure, Plaintiff TEJAS TUBULAR PRODUCTS, INC. b
and through its undersigned counsel designates the following experts:
1. Andrew M. Caplan
Murphy Klasing
Weycer, Kaplan, Pulaski & Zuber, P.C.
11 Greenway Plaza, Suite 1400
Houston, Texas 77046
(713) 9619045
(713) 9619045
Mr. Caplan and/or Mr. Klasing may testify regarding the reasonable
and necessary attorneys’ fees incurred and permitted in this case and
in similar cases. All documents reviewed by Mr. Caplan and Mr.
Klasing will be produced at a mutually convenient time with
appropriate redactions to preserve the attorney client and work product
privileges which are hereby asserted for all purposes. Andrew M.
Caplan and/or Murphy Klasing’s opinions will relate to the reasonable
hourly rates for attorneys practicing in Harris County, Texas, and the
necessary work done in this case. may also provide expert
rebuttal testimony to claims for attorneys' fees potentially proffered on
behalf of the Defendant. Their qualifications are available at
www.wkpz.com.
{TEJ000/00024/1519968.DOC;1/LKO }
Plaintiff reserve the right to depose, call, examine and/or cross
examine any expert(s) designated by any other party.
Plaintiff the right to qualify any lay witness, as an expert
witness and to depose, call, examine or crossexamine any such
witness(s).
Due to the fact that discovery has not been completed, Plaintiff
reserves the right to amend or supplement this designation as the case
develops with additional designation(s) of expert witnesses and/or
expert opinions within the time limits imposed by the Court or any
alterations of same by subsequent Court Order or agreement between
the parties, or pursuant to the Texas Rules of Civil Procedure.
Plaintiff reserves the right to amend or supplement this designation
upon being advised by the Defendant to the opinions of Defendant's
expert witnesses.
Plaintiff reserves the right to call rebuttal expert witnesses, whos
testimony cannot reasonably be foreseen until the presentation of the
evidence at trial or designation of the Defendantexpert(s).
8. Plaintiff reserves the right to dedesignate any expert witness and to
assert that any such previously designated expert will not be called as
a witness at trial, and to re designate same as a consulting expert, who
cannot be called by opposing counsel.
9. Plaintiff incorporates herein by reference each and every expert
witness designated by the Plaintiff/Defendant
10 This designation serves as a supplement to any prior designation or
disclosure response.
{TEJ000/00024/1519968.DOC;1/LKO }
Respectfully submitted,
WEYCER, KAPLAN, PULASKI & ZUBER,
P.C.
:__/S/ ANDREW M. CAPLAN___________
ANDREW M. CAPLAN
State Bar No. 03776700
acaplan@wkpz.com
11 Greenway Plaza, Suite 1400
Houston, Texas 77046
Telephone: (713) 961 9045
Facsimile: (713) 961 5341
ATTORNEYS FOR PLAINTIFF
TEJAS TUBULAR PRODUCTS, INC.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing instrument
was served upon the parties listed below by the method(s) indicated on
December 21, 2018
Rusty D. Sewell
Winstead PC
24 Waterway Avenue, Suite 500
The Woodlands, Texas 77380
krwatson@winstead.com
ll@winstead.com
:__/S/ ANDREW M. CAPLAN
Andrew M. Caplan
{TEJ000/00024/1519968.DOC;1/LKO }
Document Filed Date
December 21, 2018
Case Filing Date
May 24, 2017
Category
Debt/Contract - Debt/Contract
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Cause No. 2017 35132 TEJAS TUBULAR PRODUCTS, INC. § IN THE DISTRICT COURT OF Plaintiff § V. § HARRIS COUNTY, TEXAS COMMAND DRILLING PRODUCTS § USA, Ltd. § § Defendant § 164th JUDICIAL DISTRICT PLAINTIFF'S ESIGNATION OF EXPERTS PLEASE TAKE NOTICE that, pursuant to the provisions of the Texas Rules of Civil Procedure, Plaintiff TEJAS TUBULAR PRODUCTS, INC. b and through its undersigned counsel designates the following experts: 1. Andrew M. Caplan Murphy Klasing Weycer, Kaplan, Pulaski & Zuber, P.C. 11 Greenway Plaza, Suite 1400 Houston, Texas 77046 (713) 9619045 (713) 9619045 Mr. Caplan and/or Mr. Klasing may testify regarding the reasonable and necessary attorneys’ fees incurred and permitted in this case and in similar cases. All documents reviewed by Mr. Caplan and Mr. Klasing will be produced at a mutually convenient time with appropriate redactions to preserve the attorney client and work product privileges which are hereby asserted for all purposes. Andrew M. Caplan and/or Murphy Klasing’s opinions will relate to the reasonable hourly rates for attorneys practicing in Harris County, Texas, and the necessary work done in this case. may also provide expert rebuttal testimony to claims for attorneys' fees potentially proffered on behalf of the Defendant. Their qualifications are available at www.wkpz.com. {TEJ000/00024/1519968.DOC;1/LKO } Plaintiff reserve the right to depose, call, examine and/or cross examine any expert(s) designated by any other party. Plaintiff the right to qualify any lay witness, as an expert witness and to depose, call, examine or crossexamine any such witness(s). Due to the fact that discovery has not been completed, Plaintiff reserves the right to amend or supplement this designation as the case develops with additional designation(s) of expert witnesses and/or expert opinions within the time limits imposed by the Court or any alterations of same by subsequent Court Order or agreement between the parties, or pursuant to the Texas Rules of Civil Procedure. Plaintiff reserves the right to amend or supplement this designation upon being advised by the Defendant to the opinions of Defendant's expert witnesses. Plaintiff reserves the right to call rebuttal expert witnesses, whos testimony cannot reasonably be foreseen until the presentation of the evidence at trial or designation of the Defendantexpert(s). 8. Plaintiff reserves the right to dedesignate any expert witness and to assert that any such previously designated expert will not be called as a witness at trial, and to re designate same as a consulting expert, who cannot be called by opposing counsel. 9. Plaintiff incorporates herein by reference each and every expert witness designated by the Plaintiff/Defendant 10 This designation serves as a supplement to any prior designation or disclosure response. {TEJ000/00024/1519968.DOC;1/LKO } Respectfully submitted, WEYCER, KAPLAN, PULASKI & ZUBER, P.C. :__/S/ ANDREW M. CAPLAN___________ ANDREW M. CAPLAN State Bar No. 03776700 acaplan@wkpz.com 11 Greenway Plaza, Suite 1400 Houston, Texas 77046 Telephone: (713) 961 9045 Facsimile: (713) 961 5341 ATTORNEYS FOR PLAINTIFF TEJAS TUBULAR PRODUCTS, INC. CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument was served upon the parties listed below by the method(s) indicated on December 21, 2018 Rusty D. Sewell Winstead PC 24 Waterway Avenue, Suite 500 The Woodlands, Texas 77380 krwatson@winstead.com ll@winstead.com :__/S/ ANDREW M. CAPLAN Andrew M. Caplan {TEJ000/00024/1519968.DOC;1/LKO }