On January 08, 2018 a
Trial Materials
was filed
involving a dispute between
Rolls, William,
and
Elite Industrial Services Inc,
Elite Specialty Welding Llc,
Packaging Corporation Of America Inc,
for PERSONAL INJ (NON-AUTO)
in the District Court of Harris County.
Preview
CAUSE NO.
WILLIAM ROLLS, R. IN THE DISTRICT COURT OF
Plaintiffs,
HARRIS COUNTY, TEXAS
ELITE SPECIALTY WELDING, LLC, 190TH JUDICIAL DISTRICT
ELITE INDUSTRIAL SERVICES, INC. &
PACKAGING CORP. OF AMERICA, INC.
Defendants. JURY TRIAL DEMANDED
SIGNATION OF EXPERT WITNESSES
Plaintiff Designation of Expert Witnesses.
RETAINED EXPERTS
Expert Peter K. Taaffe
600 Travis Street, Suite 7300
Houston, TX 77002
Phone:
Mr. Taaffe practices law at The Buzbee Law Firm, Houston. He will give direct and rebuttal
testimony as a fact and expert witness on Plaintiff entitlement to and amount of attorney's fees
and related costs. His testimony will be based on Lodestar calculations, consistent with controlling
legal precedents in this Court. He will give further testimony on the Firm's customary rates for
attorneys and support staff, the amount of time spent on this litigation, and the amount of expenses
incurred in this matter. Plaintiff will supplement discovery related to attorney's fees through the
course of their representation consistent with their customary billing practices and in a timely
manner. The Buzbee Law Firm's customary rates are as follows:
Anthony G. Buzbee $1200/Hr
Senior Attorneys $500/Hr.
Junior Attorneys $300/Hr.
Paralegals/Law Clerks $100/Hr.
RETAINED EXPERTS
Expert: Mike Sawyer, P.E., CSP
Apex Safety Consultants, LLC
301 Regents Park, Suite 101
Houston, Texas 77058
Phone: (281) 337 0337
Subject matter on which expert will testify: Mr. Sawyer is expected to testify on the safety condition
of PCA in DeRidder, Louisiana.
General substance of the expert's mental impressions and opinions and basis of them: Mr. Sawyer is
expected to testify that the risk of explosions while conducting hot work around tanks associated with
the non-condensable gas system and foul condensate stripper feed tank were well documented and
would have been readily known to PCA dating back to its Tomahawk incident in 2008. Despite this,
PCA failed to include the NGC and FCT in their process hazard analyses and failed to analyze and
install the appropriate safety instrumented systems on the FCT to detect explosive/flammable range
within the headspace; amongst other failures. Plaintiff was ultimately injured as a direct result of these
failures by PCA.
Documents and other data provided: The documents that Mr. Sawyer reviewed and relied upon were
produced to Plaintiff or Plaintiff produced to Defendant. These documents have been produced to,
or were produced by, opposing counsel. It is also anticipated that Mr. Sawyer may review additional
data and items that will be produced by or to Defendant through the discovery process.
Plaintiff also reserves the right to call at trial any of the following experts:
1) Any expert which has been or will be named by any party in any answer to
interrogatory, or designated by any other party;
2) Any expert whose name appears on any documents which have been or will be
produced by any party in response to request for production;
3) Any expert whose name is reflected in any document which has been or will be obtained
through the use of a medical authorization;
4) Any expert whose name is reflected in any document which has been or will be submitted
to the Court by Affidavit;
5) Any expert whose name is reflected in any document which has been or will be
subpoenaed by any party;
6) Any expert whose name appears in the transcript of any deposition taken in this matter;
7) Any expert who is deposed in this lawsuit;
8) Any expert whose name is reflected in any document which has been or will be attached
to the transcript of any deposition; and
9) All other persons listed on answers to interrogatories filed by any party.
Page 2 of 3
Respectfully submitted,
THE BUZBEE LAW FIRM
By: /s/ Christopher J. Leavitt
Anthony G. Buzbee
State Bar No. 24001820
tbuzbee@txattorneys.com
Christopher J. Leavitt
State Bar No. 24053318
cleavitt@txattorneys.com
J.P. Morgan Chase Tower
600 Travis, Suite 7300
Houston, Texas 77002
Telephone: (713) 223-5393
Facsimile: (713) 223-5909
www.txattorneys.com
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of this document has been duly served on all
known counsel of record and pro se parties in accordance with the Texas Rules of Civil Procedure
on February 28, 2020.
/s/ Christopher J. Leavitt
Christopher J. Leavitt
Page 3 of 3
Document Filed Date
February 28, 2020
Case Filing Date
January 08, 2018
Category
PERSONAL INJ (NON-AUTO)
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CAUSE NO. WILLIAM ROLLS, R. IN THE DISTRICT COURT OF Plaintiffs, HARRIS COUNTY, TEXAS ELITE SPECIALTY WELDING, LLC, 190TH JUDICIAL DISTRICT ELITE INDUSTRIAL SERVICES, INC. & PACKAGING CORP. OF AMERICA, INC. Defendants. JURY TRIAL DEMANDED SIGNATION OF EXPERT WITNESSES Plaintiff Designation of Expert Witnesses. RETAINED EXPERTS Expert Peter K. Taaffe 600 Travis Street, Suite 7300 Houston, TX 77002 Phone: Mr. Taaffe practices law at The Buzbee Law Firm, Houston. He will give direct and rebuttal testimony as a fact and expert witness on Plaintiff entitlement to and amount of attorney's fees and related costs. His testimony will be based on Lodestar calculations, consistent with controlling legal precedents in this Court. He will give further testimony on the Firm's customary rates for attorneys and support staff, the amount of time spent on this litigation, and the amount of expenses incurred in this matter. Plaintiff will supplement discovery related to attorney's fees through the course of their representation consistent with their customary billing practices and in a timely manner. The Buzbee Law Firm's customary rates are as follows: Anthony G. Buzbee $1200/Hr Senior Attorneys $500/Hr. Junior Attorneys $300/Hr. Paralegals/Law Clerks $100/Hr. RETAINED EXPERTS Expert: Mike Sawyer, P.E., CSP Apex Safety Consultants, LLC 301 Regents Park, Suite 101 Houston, Texas 77058 Phone: (281) 337 0337 Subject matter on which expert will testify: Mr. Sawyer is expected to testify on the safety condition of PCA in DeRidder, Louisiana. General substance of the expert's mental impressions and opinions and basis of them: Mr. Sawyer is expected to testify that the risk of explosions while conducting hot work around tanks associated with the non-condensable gas system and foul condensate stripper feed tank were well documented and would have been readily known to PCA dating back to its Tomahawk incident in 2008. Despite this, PCA failed to include the NGC and FCT in their process hazard analyses and failed to analyze and install the appropriate safety instrumented systems on the FCT to detect explosive/flammable range within the headspace; amongst other failures. Plaintiff was ultimately injured as a direct result of these failures by PCA. Documents and other data provided: The documents that Mr. Sawyer reviewed and relied upon were produced to Plaintiff or Plaintiff produced to Defendant. These documents have been produced to, or were produced by, opposing counsel. It is also anticipated that Mr. Sawyer may review additional data and items that will be produced by or to Defendant through the discovery process. Plaintiff also reserves the right to call at trial any of the following experts: 1) Any expert which has been or will be named by any party in any answer to interrogatory, or designated by any other party; 2) Any expert whose name appears on any documents which have been or will be produced by any party in response to request for production; 3) Any expert whose name is reflected in any document which has been or will be obtained through the use of a medical authorization; 4) Any expert whose name is reflected in any document which has been or will be submitted to the Court by Affidavit; 5) Any expert whose name is reflected in any document which has been or will be subpoenaed by any party; 6) Any expert whose name appears in the transcript of any deposition taken in this matter; 7) Any expert who is deposed in this lawsuit; 8) Any expert whose name is reflected in any document which has been or will be attached to the transcript of any deposition; and 9) All other persons listed on answers to interrogatories filed by any party. Page 2 of 3 Respectfully submitted, THE BUZBEE LAW FIRM By: /s/ Christopher J. Leavitt Anthony G. Buzbee State Bar No. 24001820 tbuzbee@txattorneys.com Christopher J. Leavitt State Bar No. 24053318 cleavitt@txattorneys.com J.P. Morgan Chase Tower 600 Travis, Suite 7300 Houston, Texas 77002 Telephone: (713) 223-5393 Facsimile: (713) 223-5909 www.txattorneys.com ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of this document has been duly served on all known counsel of record and pro se parties in accordance with the Texas Rules of Civil Procedure on February 28, 2020. /s/ Christopher J. Leavitt Christopher J. Leavitt Page 3 of 3