On September 17, 2015 a
CCPC's Request to Supplement the Record 8-11-17 - MISCELLANOUS EVENT
was filed
involving a dispute between
Ahmed, Syed Kamal Uddin,
Kamal, Zeba,
and
Castillo, Mark,
Curtis Castillo, P.C.,
for OTHER PROFESSIONAL MALPRACTICE
in the District Court of Dallas County.
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CAUSE NO. DC-15-11376
CURTIS | CASTILLO PC, IN THE DISTRICT COURT
Counter Plaintiff,
14th JUDICIAL DISTRICT
ZEBA KAMAL and SYED KAMAL
UDDIN AHMED,
Counter Defendants. DALLAS COUNTY, TEXAS
COUNTER PLAINTIFF’S LIMITED REQUEST TO SUPPLEMENT RECORD
Counter-Plaintiff Curtis | Castillo PC files the attached final invoice of fees and expenses and
respectfully requests that the Court take judicial notice of th supplemental record item and usual
and customary attorneys’ fees per Tex. Civ. Prac. & Rem. Code § 38.004(1) and accept the invoice
as evidence per Tex. R. Civ. P. 270 for purposes of the Court’s Findings of Fact and Conclusions of
Law to reflect the firm’s latest fees and expenses in this case through trial.
Curtis | Castillo PC respectfully submits that its final invoice is admissible as necessary to the
due administration of justice because (1) it was diligent in obtaining the evidence which included fees
and expenses incurred through trial that could not have been filed before the conclusion of the trial
and because trial was re set several times during this period making it difficult to know when the
incurrence of fees and expenses would end, (2) the proffered evidence is decisive in that it reflects
actual fees and expenses incurred in the ordinary and customary way, (3) there is no undue delay from
reception of the evidence because the Kamals’ presentation at trial did not include any focus on the
firm’s actual charges and the Court has determined all fees and expense incurred should be awarded,
and (4) no injustice is caused by inclusion of the final invoice based upon the Court’s rulings. See
Tex. R. Civ. P. 270 (the court may permit additional evidence to be offered at any time) Naguib v.
OTICE NNOUNCEMENT READY FOR TRIAL PAGE OF 2
Naguib, 137 S.W.3d 367, 373 (Tex. App. Dallas 2004, pet. denied) (listing factors, which, “[w]here
these factors are present, it may be a trial court’s duty to grant a party’s motion to offer additional
evidence”).
Dated: August 11, Respectfully submitted,
/s/ Mark A. Castillo
Mark A. Castillo
State Bar No. 24027795
Christopher L. Harbin
State Bar No.
URTIS ASTILLO
901 Main Street, Suite 6515
Dallas, Texas 75202
Telephone: 214.752.2222
Facsimile: 214.752.0709
mcastillo@curtislaw.net
charbin@curtislaw.net
COUNSEL FOR COUNTER PLAINTIFF
CURTIS CASTILLO PC
CERTIFICATE OF SERVICE
The undersigned certifies that on August 11, 2017, a true and correct copy of the foregoing
Notice was served via the Court’s electronic filing system all counsel of record as indicated below
in accordance with Rule 21 of the Texas Rules of Civil Procedure.
Doug Perrin William D. Cobb, Jr.
The Perrin Law Firm Cobb Martinez Woodward PLLC
1910 Pacific Avenue, Suite 6050 1700 Pacific Avenue, Suite 3100
Dallas,Texas 75201 Dallas, Texas 75201
Via electronic case filing Via electronic case filing
COUNSEL FOR COUNSEL FOR DEFENDANTS
COUNTER DEFENDANT KAMALS
/s/ Mark A. Castillo
Mark A. Castillo
OTICE NNOUNCEMENT READY FOR TRIAL AGE OF
CCPC
Exhibit 1
M. Myers.
Document Filed Date
August 11, 2017
Case Filing Date
September 17, 2015
Category
OTHER PROFESSIONAL MALPRACTICE
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CAUSE NO. DC-15-11376 CURTIS | CASTILLO PC, IN THE DISTRICT COURT Counter Plaintiff, 14th JUDICIAL DISTRICT ZEBA KAMAL and SYED KAMAL UDDIN AHMED, Counter Defendants. DALLAS COUNTY, TEXAS COUNTER PLAINTIFF’S LIMITED REQUEST TO SUPPLEMENT RECORD Counter-Plaintiff Curtis | Castillo PC files the attached final invoice of fees and expenses and respectfully requests that the Court take judicial notice of th supplemental record item and usual and customary attorneys’ fees per Tex. Civ. Prac. & Rem. Code § 38.004(1) and accept the invoice as evidence per Tex. R. Civ. P. 270 for purposes of the Court’s Findings of Fact and Conclusions of Law to reflect the firm’s latest fees and expenses in this case through trial. Curtis | Castillo PC respectfully submits that its final invoice is admissible as necessary to the due administration of justice because (1) it was diligent in obtaining the evidence which included fees and expenses incurred through trial that could not have been filed before the conclusion of the trial and because trial was re set several times during this period making it difficult to know when the incurrence of fees and expenses would end, (2) the proffered evidence is decisive in that it reflects actual fees and expenses incurred in the ordinary and customary way, (3) there is no undue delay from reception of the evidence because the Kamals’ presentation at trial did not include any focus on the firm’s actual charges and the Court has determined all fees and expense incurred should be awarded, and (4) no injustice is caused by inclusion of the final invoice based upon the Court’s rulings. See Tex. R. Civ. P. 270 (the court may permit additional evidence to be offered at any time) Naguib v. OTICE NNOUNCEMENT READY FOR TRIAL PAGE OF 2 Naguib, 137 S.W.3d 367, 373 (Tex. App. Dallas 2004, pet. denied) (listing factors, which, “[w]here these factors are present, it may be a trial court’s duty to grant a party’s motion to offer additional evidence”). Dated: August 11, Respectfully submitted, /s/ Mark A. Castillo Mark A. Castillo State Bar No. 24027795 Christopher L. Harbin State Bar No. URTIS ASTILLO 901 Main Street, Suite 6515 Dallas, Texas 75202 Telephone: 214.752.2222 Facsimile: 214.752.0709 mcastillo@curtislaw.net charbin@curtislaw.net COUNSEL FOR COUNTER PLAINTIFF CURTIS CASTILLO PC CERTIFICATE OF SERVICE The undersigned certifies that on August 11, 2017, a true and correct copy of the foregoing Notice was served via the Court’s electronic filing system all counsel of record as indicated below in accordance with Rule 21 of the Texas Rules of Civil Procedure. Doug Perrin William D. Cobb, Jr. The Perrin Law Firm Cobb Martinez Woodward PLLC 1910 Pacific Avenue, Suite 6050 1700 Pacific Avenue, Suite 3100 Dallas,Texas 75201 Dallas, Texas 75201 Via electronic case filing Via electronic case filing COUNSEL FOR COUNSEL FOR DEFENDANTS COUNTER DEFENDANT KAMALS /s/ Mark A. Castillo Mark A. Castillo OTICE NNOUNCEMENT READY FOR TRIAL AGE OF CCPC Exhibit 1 M. Myers.