On May 31, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Peterson, Robert,
and
Dcs Consulting Inc,
Dsc All American Llc,
General Pump Company Llc,
Interpump Group Spa,
Nexoil Llc,
Oilnex Supply Llc,
for PERSONAL INJ (NON-AUTO)
in the District Court of Harris County.
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1456 First Colony Boulevard
Sugar Land, Texas 77479
-313-5000
MIKE JOHANSON VICKI L. DALEY
RANDY L. FAIRLESS * JOCELYN A. HOLLAND
TODD TAYLOR * KEVIN KYSER
BART BASDEN * GREG LAUGHLIN
KELLEY J. FRIEDMAN KIMBERLY M.A. NIETING
CHRIS M. VOLF BETH A. RAHWAN
TIMOTHY J. NISBET
Board Certified in Personal Injury Trial Law
Texas Board of Legal Specialization
__________
TIMOTHY J. NISBET
DIRECT DIAL 281
Mail TNisbet@jandflaw.com
5.102.19.55
April 9, 2021
The Honorable Tanya Garrison
Civil Court 201 Caroline, 11 Floor
Houston, Texas 77002
Re: Cause No. 2018-36443; Robert Peterson v. Interpump Group SPA, General
Pump Company, LLC, Oilnex, LLC, Nexoil, LLC, and DCS Consulting, Inc.;
in the 157 Judicial District Court of Harris County, Texas
To the Honorable Judge Garrison:
Defendant, General Pump, Inc. would respectfully request an emergency hearing
on its Motion to Compel a Medical Exam of Plaintiff based on the impending trial date. In
its motion, General Pump seeks to have Plaintiff, Robert Peterson present for a medical
examination of his eyes by Defense Expert, Dr. Carolyn Carman. An emergency hearing
is necessary because trial is set to commence in under 3 weeks, on April 26, 2021.
The Defense seeks this examination in order to gain a current understanding of
Plaintiff’s vision and eye health so that we are not prejudiced at the time of trial by the fact
that we have outdated information. General Pump requested this examination from
Plaintiff’s counsel at the time of Dr. Carman’s deposition and re-urged the request last
week. Plaintiff’s counsel denied the recent request and relief is now sought from the
Court.
Given the approaching trial and the need for current information on medical
concerns that are at issue in this case, General Pump seeks this examination of Plaintiff
and an emergency hearing on the motion in order to allow sufficient time to schedule the
requested exam at a time that is convenient for Mr. Peterson and Dr. Carman.
Respectfully,
Timothy J. Nisbet
TIMOTHY J. NISBET
TJN/kp
Document Filed Date
April 09, 2021
Case Filing Date
May 31, 2018
Category
PERSONAL INJ (NON-AUTO)
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1456 First Colony Boulevard Sugar Land, Texas 77479 -313-5000 MIKE JOHANSON VICKI L. DALEY RANDY L. FAIRLESS * JOCELYN A. HOLLAND TODD TAYLOR * KEVIN KYSER BART BASDEN * GREG LAUGHLIN KELLEY J. FRIEDMAN KIMBERLY M.A. NIETING CHRIS M. VOLF BETH A. RAHWAN TIMOTHY J. NISBET Board Certified in Personal Injury Trial Law Texas Board of Legal Specialization __________ TIMOTHY J. NISBET DIRECT DIAL 281 Mail TNisbet@jandflaw.com 5.102.19.55 April 9, 2021 The Honorable Tanya Garrison Civil Court 201 Caroline, 11 Floor Houston, Texas 77002 Re: Cause No. 2018-36443; Robert Peterson v. Interpump Group SPA, General Pump Company, LLC, Oilnex, LLC, Nexoil, LLC, and DCS Consulting, Inc.; in the 157 Judicial District Court of Harris County, Texas To the Honorable Judge Garrison: Defendant, General Pump, Inc. would respectfully request an emergency hearing on its Motion to Compel a Medical Exam of Plaintiff based on the impending trial date. In its motion, General Pump seeks to have Plaintiff, Robert Peterson present for a medical examination of his eyes by Defense Expert, Dr. Carolyn Carman. An emergency hearing is necessary because trial is set to commence in under 3 weeks, on April 26, 2021. The Defense seeks this examination in order to gain a current understanding of Plaintiff’s vision and eye health so that we are not prejudiced at the time of trial by the fact that we have outdated information. General Pump requested this examination from Plaintiff’s counsel at the time of Dr. Carman’s deposition and re-urged the request last week. Plaintiff’s counsel denied the recent request and relief is now sought from the Court. Given the approaching trial and the need for current information on medical concerns that are at issue in this case, General Pump seeks this examination of Plaintiff and an emergency hearing on the motion in order to allow sufficient time to schedule the requested exam at a time that is convenient for Mr. Peterson and Dr. Carman. Respectfully, Timothy J. Nisbet TIMOTHY J. NISBET TJN/kp