On June 07, 2019 a
Letter,Correspondence
was filed
involving a dispute between
Ainsworth, Ashton,
Elite Racing Development Llc,
and
Engle Martin & Associates Llc,
Gessel, Andrew Van,
Gonzalo Jimenez Insurance Agency Inc,
Jimenez, Bryan,
Jimenez, Gonzalo,
K&K Insurance Group,
National Casualty Company,
Nationwide Mutual Insurance Company,
Navas, Saray,
Prescott, Natalie,
Scottsdale Insurance Company,
Spindle Group Inc,
for Debt/Contract - Consumer/DTPA
in the District Court of Harris County.
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Patrick M. Kemp
Direct (512) 370-1235
pkemp@smsm.com
June 25, 2021
Judge Fredericka Phillips Via E-File
Harris County Civil Courthouse
201 Caroline, 9th Floor
Houston, Texas 77002
Re: Cause No. 2019-39477; Elite Racing Development, LLC. and Ashton Ainsworth,
Individually and as Sole Owner of Elite Racing Development, LLC v. National
Casualty Company, et. al.; In the 61 Jud. Dist. Court of Harris County, Texas.
Honorable Judge Phillips:
Upon review of Plaintiffs’ proposed Docket Control Order filed today, the only date
opposed by the Defendants is the inclusion of new expert designation deadlines. Plaintiffs
designated experts on March 23, 2020, and Defendants designated experts on April 2, 2020.
Defendants do not see the need for new expert deadlines. Moreover, Defendants object to
Plaintiffs’ proposed expert deadline of October 4, 2021 and object to a combined deadline for
both Plaintiffs and Defendants. With a November 1, 2021 discovery deadline, Plaintiffs’
proposed deadline of October 4, 2021 would not allow sufficient time for depositions or rebuttal
expert designations. Defendants request the entry of the Docket Control Order proposed today
by Plaintiffs without new expert designation deadlines, or in the alternative, expert designation
deadlines of no less than 60 and 90 days before the close of discovery for the respective parties.
Very truly yours,
Patrick M. Kemp
Patrick M. Kemp
cc: Lance Kassab, David Kassab, and Larry Doherty (Via E-File)
E. Ray Edwards (Via E-File)
Cuong M. Le (Via E-File)
National Casualty Company, K&K Insurance Group, Inc., Engle Martin & Associates, LLC, Nationwide Mutual
Insurance Company, Scottsdale Insurance Company, Andrew Van Gessel and Natalie Prescott (collectively,
“Defendants”).
100 Congress Avenue | Suite 800 | Austin, TX 78701 | T: (512) 476.7834 | F: (512) 476.7832
Document Filed Date
June 25, 2021
Case Filing Date
June 07, 2019
Category
Debt/Contract - Consumer/DTPA
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Patrick M. Kemp Direct (512) 370-1235 pkemp@smsm.com June 25, 2021 Judge Fredericka Phillips Via E-File Harris County Civil Courthouse 201 Caroline, 9th Floor Houston, Texas 77002 Re: Cause No. 2019-39477; Elite Racing Development, LLC. and Ashton Ainsworth, Individually and as Sole Owner of Elite Racing Development, LLC v. National Casualty Company, et. al.; In the 61 Jud. Dist. Court of Harris County, Texas. Honorable Judge Phillips: Upon review of Plaintiffs’ proposed Docket Control Order filed today, the only date opposed by the Defendants is the inclusion of new expert designation deadlines. Plaintiffs designated experts on March 23, 2020, and Defendants designated experts on April 2, 2020. Defendants do not see the need for new expert deadlines. Moreover, Defendants object to Plaintiffs’ proposed expert deadline of October 4, 2021 and object to a combined deadline for both Plaintiffs and Defendants. With a November 1, 2021 discovery deadline, Plaintiffs’ proposed deadline of October 4, 2021 would not allow sufficient time for depositions or rebuttal expert designations. Defendants request the entry of the Docket Control Order proposed today by Plaintiffs without new expert designation deadlines, or in the alternative, expert designation deadlines of no less than 60 and 90 days before the close of discovery for the respective parties. Very truly yours, Patrick M. Kemp Patrick M. Kemp cc: Lance Kassab, David Kassab, and Larry Doherty (Via E-File) E. Ray Edwards (Via E-File) Cuong M. Le (Via E-File) National Casualty Company, K&K Insurance Group, Inc., Engle Martin & Associates, LLC, Nationwide Mutual Insurance Company, Scottsdale Insurance Company, Andrew Van Gessel and Natalie Prescott (collectively, “Defendants”). 100 Congress Avenue | Suite 800 | Austin, TX 78701 | T: (512) 476.7834 | F: (512) 476.7832