On September 26, 2019 a
Designation of Experts
was filed
involving a dispute between
M.A.R. Designs & Construction, Inc.,
Ridley, Robert,
Sierra Title Of Hidalgo County, Inc.,
and
Moore, Patrick,
Moreno, Alejandro,
for Real Property - Other Real Property (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Filed
9/27/2021 4:34 PM
Hidalgo County District Clerks
Reviewed By: Jose Hernandez
CAUSE NO. C-4215-19-C
M.A.R. DESIGNS & CONSTRUCTION, INC. § IN THE DISTRICT COURT
Plaintiff, §
§
V. §
§
ALEJANDRO MORENO AND §
PATRICK MOORE, TRUSTEE, §
Defendants. §
§
AND § 139th JUDICIAL DISTRICT
§
SIERRA TITLE OF HIDLAGO COUNTY, INC., §
GLORIA AVALOS, AND ROBERT RIDLEY, §
Third Party Plaintiffs, §
§
V. §
§
M.A.R. DESIGNS & CONSTRUCTION, INC., §
ALEJANDRO MORENO, AND PATRICK §
MOORE, TRUSTEE, §
Third Party Defendants. § HIDALGO COUNTY, TEXAS
COUNTER-PLAINTIFF ALEJANDRO MORENO’S
DESIGNATION OF EXPERT WITNESSES
TO THE HONORABLE JUDGE OF THIS COURT:
COMES NOW, Counter-Plaintiff ALEJANDRO MORENO and files his designation of
expert witnesses, stating as follows:
I.
RETAINED EXPERTS
Plaintiff has no retained experts.
II.
NON-RETAINED EXPERTS
Channing Slusher
SLUSHER & ASSOCIATES
4900 N. 10th Street, Suite F3
McAllen, Texas 78501
(T) 956-682-4842
Moreno – Counter-Plaintiff’s Expert Designation Page 1
Electronically Filed
9/27/2021 4:34 PM
Hidalgo County District Clerks
Reviewed By: Jose Hernandez
Mr. Slusher is an attorney who is licensed to practice law in the State of Texas and whose practice includes
real estate. Mr. Slusher is expected to provide testimony regarding the preparation of closing documents
required to insure all liens and/or encumbrances are addressed so that clear title can be conveyed to the
recipient/insured of a title policy to secure that the property subject of purchase is free and clear of any
encumbrance/lien.
Carlos Macias
MACIAS LAW FIRM
515 Pecan Blvd.
McAllen, Texas 78501
(T) 956-630-1133
(F) 956-630-3144
Attorney for Defendant/Counter-Plaintiff Alejandro Moreno. Mr. Macias is an attorney licensed to
practice law in the State of Texas. Mr. Macias may provide expert testimony as to the reasonable and
necessary attorneys’ fees and cost of expenses incurred by Defendant/Counter-Plaintiff in the prosecution
of this matter and/or offer rebuttal testimony to attorneys’ fees testimony of the attorneys for
Plaintiffs/Counter-Defendants. Mr. Macias’ testimony will be based on his education, background,
training, and knowledge as an attorney, and based on his familiarity with reasonable and customary charges
for legal services in Texas.
III.
COUNTER-DEFENDANTS’ EXPERTS
Counter-Plaintiff incorporates by reference herein as if fully set out all experts of any kind
or nature identified in any designation of expert witnesses filed or produced by Counter-
Defendants prior to trial. Without acknowledging their expertise or the validity of their opinions,
Counter-Plaintiff also reserves the right to offer testimony of witnesses identified as experts by
the Counter-Defendants in this case.
Respectfully submitted,
MACIAS LAW FIRM
515 Pecan
McAllen, Texas 78501
(956) 630-1133 – Telephone
(956) 630-3144 – Facsimile
/s/Carlos Macias
By:________________________________
Carlos Macias
State Bar No: 24037012
Email: maciaslawoffice@yahoo.com
Attorneys for Alejandro Moreno
Moreno – Counter-Plaintiff’s Expert Designation Page 2
Electronically Filed
9/27/2021 4:34 PM
Hidalgo County District Clerks
Reviewed By: Jose Hernandez
CERTIFICATE OF SERVICE
I hereby certify that the foregoing document was sent to all counsel of record in the
manner in accordance with the Texas Rules of Civil Procedure on the 27th day of September, 2021:
Jordan King
KING LAW FIRM
3409 N. 10th Street
McAllen, Texas 78501
David Ewers
LAW OFFICE OF DAVID A. EWERS, PC
323 West Nolana
McAllen, Texas 78504
Rolando Cantu
ROLANDO CANTU & ASSOCIATES
1111 W. Nolana
McAllen, Texas 78504
Marcus C. Barrera
BARRERA, SANCHEZ & ASSOCIATES, PC
10113 N. 10th Street, Suite A
McAllen, Texas 78504
Gerald B. Sager
FIDELITY NATIONAL LAW GROUP
6900 Dallas Parkway, Suite 610
Plano, Texas 75024
/s/Carlos Macias
____________________________________
Carlos Macias
Moreno – Counter-Plaintiff’s Expert Designation Page 3
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Carlos Macias
Bar No. 24037012
maciaslawoffice1@gmail.com
Envelope ID: 57641141
Status as of 9/28/2021 8:32 AM CST
Associated Case Party: M.A.R. Designs & Construction, Inc.
Name BarNumber Email TimestampSubmitted Status
ROLANDO CANTU rcantu@cantulawfirm.com 9/27/2021 4:34:42 PM SENT
Associated Case Party: Alejandro Moreno
Name BarNumber Email TimestampSubmitted Status
Carlos Macias maciaslawoffice1@gmail.com 9/27/2021 4:34:42 PM SENT
Gil PPeralez gpp@peralezfranzlaw.com 9/27/2021 4:34:42 PM SENT
Gil PPeralez service@peralezfranzlaw.com 9/27/2021 4:34:42 PM SENT
Associated Case Party: Patrick Moore
Name BarNumber Email TimestampSubmitted Status
Marcus C.Barrera marcus@bsmlawyers.com 9/27/2021 4:34:42 PM SENT
Melissa Kalifa melissa@bsmlawyers.com 9/27/2021 4:34:42 PM SENT
Case Contacts
Name
Susan ACagle
Gregory Brewer
April Goekin
Jordan King
DAVID EWERS
CHRIS FRANZ
Zulma Rosa
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Carlos Macias
Bar No. 24037012
maciaslawoffice1@gmail.com
Envelope ID: 57641141
Status as of 9/28/2021 8:32 AM CST
Case Contacts
John King jking@kingrgvlaw.com 9/27/2021 4:34:42 PM SENT
John King svasquez@kingrgvlaw.com 9/27/2021 4:34:42 PM SENT
Gerald B.Sager jerry.sager@fnf.com 9/27/2021 4:34:42 PM SENT
Amy Deck legal_asst@cantulawfirm.com 9/27/2021 4:34:42 PM SENT
Zachary Spector zachary.spector@fnf.com 9/27/2021 4:34:42 PM SENT
Associated Case Party: SIERRA TITLE OF HIDALGO COUNTY, INC.
Name BarNumber Email TimestampSubmitted Status
Emely Orozco eorozco@kingrgvlaw.com 9/27/2021 4:34:42 PM SENT
Jordan King jordan.king@kingrgvlaw.com 9/27/2021 4:34:42 PM SENT
Document Filed Date
September 27, 2021
Case Filing Date
September 26, 2019
Category
Real Property - Other Real Property (OCA)
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Preview
Electronically Filed 9/27/2021 4:34 PM Hidalgo County District Clerks Reviewed By: Jose Hernandez CAUSE NO. C-4215-19-C M.A.R. DESIGNS & CONSTRUCTION, INC. § IN THE DISTRICT COURT Plaintiff, § § V. § § ALEJANDRO MORENO AND § PATRICK MOORE, TRUSTEE, § Defendants. § § AND § 139th JUDICIAL DISTRICT § SIERRA TITLE OF HIDLAGO COUNTY, INC., § GLORIA AVALOS, AND ROBERT RIDLEY, § Third Party Plaintiffs, § § V. § § M.A.R. DESIGNS & CONSTRUCTION, INC., § ALEJANDRO MORENO, AND PATRICK § MOORE, TRUSTEE, § Third Party Defendants. § HIDALGO COUNTY, TEXAS COUNTER-PLAINTIFF ALEJANDRO MORENO’S DESIGNATION OF EXPERT WITNESSES TO THE HONORABLE JUDGE OF THIS COURT: COMES NOW, Counter-Plaintiff ALEJANDRO MORENO and files his designation of expert witnesses, stating as follows: I. RETAINED EXPERTS Plaintiff has no retained experts. II. NON-RETAINED EXPERTS Channing Slusher SLUSHER & ASSOCIATES 4900 N. 10th Street, Suite F3 McAllen, Texas 78501 (T) 956-682-4842 Moreno – Counter-Plaintiff’s Expert Designation Page 1 Electronically Filed 9/27/2021 4:34 PM Hidalgo County District Clerks Reviewed By: Jose Hernandez Mr. Slusher is an attorney who is licensed to practice law in the State of Texas and whose practice includes real estate. Mr. Slusher is expected to provide testimony regarding the preparation of closing documents required to insure all liens and/or encumbrances are addressed so that clear title can be conveyed to the recipient/insured of a title policy to secure that the property subject of purchase is free and clear of any encumbrance/lien. Carlos Macias MACIAS LAW FIRM 515 Pecan Blvd. McAllen, Texas 78501 (T) 956-630-1133 (F) 956-630-3144 Attorney for Defendant/Counter-Plaintiff Alejandro Moreno. Mr. Macias is an attorney licensed to practice law in the State of Texas. Mr. Macias may provide expert testimony as to the reasonable and necessary attorneys’ fees and cost of expenses incurred by Defendant/Counter-Plaintiff in the prosecution of this matter and/or offer rebuttal testimony to attorneys’ fees testimony of the attorneys for Plaintiffs/Counter-Defendants. Mr. Macias’ testimony will be based on his education, background, training, and knowledge as an attorney, and based on his familiarity with reasonable and customary charges for legal services in Texas. III. COUNTER-DEFENDANTS’ EXPERTS Counter-Plaintiff incorporates by reference herein as if fully set out all experts of any kind or nature identified in any designation of expert witnesses filed or produced by Counter- Defendants prior to trial. Without acknowledging their expertise or the validity of their opinions, Counter-Plaintiff also reserves the right to offer testimony of witnesses identified as experts by the Counter-Defendants in this case. Respectfully submitted, MACIAS LAW FIRM 515 Pecan McAllen, Texas 78501 (956) 630-1133 – Telephone (956) 630-3144 – Facsimile /s/Carlos Macias By:________________________________ Carlos Macias State Bar No: 24037012 Email: maciaslawoffice@yahoo.com Attorneys for Alejandro Moreno Moreno – Counter-Plaintiff’s Expert Designation Page 2 Electronically Filed 9/27/2021 4:34 PM Hidalgo County District Clerks Reviewed By: Jose Hernandez CERTIFICATE OF SERVICE I hereby certify that the foregoing document was sent to all counsel of record in the manner in accordance with the Texas Rules of Civil Procedure on the 27th day of September, 2021: Jordan King KING LAW FIRM 3409 N. 10th Street McAllen, Texas 78501 David Ewers LAW OFFICE OF DAVID A. EWERS, PC 323 West Nolana McAllen, Texas 78504 Rolando Cantu ROLANDO CANTU & ASSOCIATES 1111 W. Nolana McAllen, Texas 78504 Marcus C. Barrera BARRERA, SANCHEZ & ASSOCIATES, PC 10113 N. 10th Street, Suite A McAllen, Texas 78504 Gerald B. Sager FIDELITY NATIONAL LAW GROUP 6900 Dallas Parkway, Suite 610 Plano, Texas 75024 /s/Carlos Macias ____________________________________ Carlos Macias Moreno – Counter-Plaintiff’s Expert Designation Page 3 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Carlos Macias Bar No. 24037012 maciaslawoffice1@gmail.com Envelope ID: 57641141 Status as of 9/28/2021 8:32 AM CST Associated Case Party: M.A.R. Designs & Construction, Inc. Name BarNumber Email TimestampSubmitted Status ROLANDO CANTU rcantu@cantulawfirm.com 9/27/2021 4:34:42 PM SENT Associated Case Party: Alejandro Moreno Name BarNumber Email TimestampSubmitted Status Carlos Macias maciaslawoffice1@gmail.com 9/27/2021 4:34:42 PM SENT Gil PPeralez gpp@peralezfranzlaw.com 9/27/2021 4:34:42 PM SENT Gil PPeralez service@peralezfranzlaw.com 9/27/2021 4:34:42 PM SENT Associated Case Party: Patrick Moore Name BarNumber Email TimestampSubmitted Status Marcus C.Barrera marcus@bsmlawyers.com 9/27/2021 4:34:42 PM SENT Melissa Kalifa melissa@bsmlawyers.com 9/27/2021 4:34:42 PM SENT Case Contacts Name Susan ACagle Gregory Brewer April Goekin Jordan King DAVID EWERS CHRIS FRANZ Zulma Rosa Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Carlos Macias Bar No. 24037012 maciaslawoffice1@gmail.com Envelope ID: 57641141 Status as of 9/28/2021 8:32 AM CST Case Contacts John King jking@kingrgvlaw.com 9/27/2021 4:34:42 PM SENT John King svasquez@kingrgvlaw.com 9/27/2021 4:34:42 PM SENT Gerald B.Sager jerry.sager@fnf.com 9/27/2021 4:34:42 PM SENT Amy Deck legal_asst@cantulawfirm.com 9/27/2021 4:34:42 PM SENT Zachary Spector zachary.spector@fnf.com 9/27/2021 4:34:42 PM SENT Associated Case Party: SIERRA TITLE OF HIDALGO COUNTY, INC. Name BarNumber Email TimestampSubmitted Status Emely Orozco eorozco@kingrgvlaw.com 9/27/2021 4:34:42 PM SENT Jordan King jordan.king@kingrgvlaw.com 9/27/2021 4:34:42 PM SENT