Preview
FILED
9/15/2021 9:09 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Dorothy Strogen DEPUTY
CAUSE NO. DC-l 8-1 6554
BILL LAO, IN THE DISTRICT COURT
Plaintiffs,
vs. 192ND JUDICIAL DISTRICT
JOHN O’HAUGHERTY AND
FARMERS TEXAS COUNTY DALLAS COUNTY, TEXAS
MUTUAL INSURANCE COMPANY,
Defendant.
DEFENDANT JOHN O’HAUGHERTY’S MOTION IN LIMINE
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES JOHN O’HAUGHERTY, hereinafter referred to as "Defendant," and
before any proceedings before the jury, makes and files this MOTION IN LIMINE, and
respectfully moves the Court to instruct Plaintiff(s) and Plaintiff(s)' counsel to refrain from either
directly or indirectly, upon voir dire examination, opening statement, interrogation of witnesses,
introduction of any evidence, argument, objections before the jury, reading of any portion of the
pleadings, or by any other means or in any other manner, informing the jury, or bringing to the
jury's attention, any of the matters set forth in the numbered paragraphs below, unless and until
such matters have been first called to the attention of the Court, out of the presence and/or
hearing of the jury, and a favorable ruling has been obtained from the Court as to the
admissibility and relevance of any such matters.
Defendant would also note that due to the current pandemic climate and the premium
being placed on getting a live jury to Show up for jury selection, that these matters be strictly
enforced. A mistrial in this atmosphere is no more or less justified based upon violation of the
parties’ motions in limine, but it may be more costly to all parties involved and the community
and courts as a whole.
Lao vs. O’Haugherty et a1. PAGE l
DEFENDANT O’HAUGHERTY’S MOTION IN LIMINE
1. Insurance. Unless an insurance company is a named Defendant, that the Defendant is or
is not protected, in whole or in part, by liability insurance, or that defense counsel was
retained by, or all or any part of the costs of defense, or of any resulting judgment, are or
will be paid by an insurance company, or any other matter suggesting an involvement of
any insurance company with the defense of the case.
2. Jurors' Connection with Insurance Industry. Inquiring of potential jurors as to their
present or past employment or connection with the insurance industry, or present or past
connection of any family member with the insurance industry, except that:
a) If a potential juror's juror information card discloses employment in the insurance
industry, such potential juror may be questioned concerning same.
b) Inquiry may be made of potential jurors concerning their experience (or that of
members of their family), if any, reviewing, adjusting or allowing/disallowing
claims, as long as no express reference is made to "insurance."
3. Liability or Non-Liabilitv for Judgment. That the named Defendant(s) may or may not
have to pay any resulting judgment.
4. Attorneys' Fees. That any party will have to pay attomeys' fees, or any reference to the
amount or basis of any attomeys' fees, unless a claim for recovery of attomeys' fees in the
case will be submitted to the jury.
5. Criminal Offenses. That any party or witness has been suspected of, arrested for,
charged with or convicted of any criminal offense unless there is evidence of a specific
conviction that the Court has previously ruled is admissible in the case.
6. Alcohol or Drug Use. That any party or witness uses or abuses alcohol, tobacco, or any
controlled substance, unless and until such alleged use or abuse is shown to be
specifically relevant to the matters in controversy. Amoco Chemicals Corp. vs. Stafford,
663 S.W.2d 147 (Tex. App—Houston [15‘ Dist.] 1983, no writ).; TRCE 801(d); TRCE
403.
7. Settlement Negotiations or Mediation. Any negotiations, offers or demands with
respect to any attempted settlement or mediation. TRCE 408; Beutel vs. Paul, 741
S.W.2d 510 (Tex. App—Houston [14th Dist.] 1987, no writ).
8. Discovery Disputes. Any reference to discovery disputes that arose during the
preparation of the case for trial, any position taken by any party with respect thereto, or to
the Court's rulings thereon.
Lao vs. O’Haugherty et a1. PAGE 2
DEFENDANT O’HAUGHERTY’S MOTION IN LIMINE
Hearsav Medical Opigions. Any hearsay statement offered for the truth of the
statement by an allegedly injured person concerning any diagnosis or medical opinions
communicated to such person by a physician or other health care provider. Such would
be an attempt to introduce before the jury expert testimony Without a proper predicate
concerning the expert’s qualifications and abilities to give such testimony. Defendant
would note that TRE 803(4) specifically excepts statements made to a medical provider
for diagnosis or treatment from the hearsay rule. This does not apply to statements
medical provider to the patient. The idea is that an individual is unlikely to lie to a
medical provider since they want an accurate diagnosis and appropriate treatment.
Conversely, there is not the same reassurance of truthfulness when it comes to an
individual stating what the doctor told them in the middle of a personal injury jury trial
for money damages.
10. Reguests for Stipulations. Any request or demand in the presence of the jury for a
stipulation to any fact, or that counsel admit or deny any fact.
11. Reguests for Files. Any request or demand in the presence of the jury that opposing
counsel produce any document or thing, or that opposing counselor any party or witness
exhibit, turn over or allow examination of the contents of any file or briefcase (except
that a party may demand to see a document used by a witness on the stand to refresh
his/her recollection, or that a witness testifies that he/she has used previously to refresh
his/her recollection).
12. Discrimination. Any argument that a party should be treated more or less favorably
because of such party's race, gender, national origin, nationality, religion, marital status,
occupation, or financial status (except in the second phase of a bifurcated trial).
13. Hardship or Privation. Any argument or suggestion that a failure to award damages
will cause a Plaintiff privation or financial hardship except that Plaintiffs counsel may
certainly argue that Plaintiff has a particular amount of money outstanding for past
medical bills.
14. Golden Rule. Any argument or suggestion that the jurors should put themselves in the
position of a party. World Wide Tire Co. vs. Brown, 644 S.W.2d 144 (Tex. App.-
Houston [14th Dist] 1982, writ ref’d n.r.e.).
15. Effect of Answers to Jurv Questions. Any argument that any finding or failure to find
in response to a particular jury question will or will not result in a judgment favorable to
any party. This provision does not bar argument by counsel that a particular jury
question should be answered in a particular way. Cooper vs. Argonaut Insurance Co.,
430 S.W. 2d. 35 (Tex. Civ. App—Dallas 1968, writ refd n.r.e.). Such argument is
improper under the Texas special verdict system because it advises the jury of the effect
of its answers.
Lao vs. O’Haugherty et a1. PAGE 3
DEFENDANT O’HAUGHERTY’S MOTION IN LIMINE
16. Obiections to Evidence Not Produced in Discoverv. Any objection based on failure to
disclose evidence in pre-trial discovery. Any party desiring to urge any such objection
shall request to approach the bench and urge such objection outside the hearing of the
jury. To the extent possible or predictable, such matters should be addressed and a ruling
sought at pretrial once the case is assigned for trial, although the objection may be urged
for the record outside the hearing of the jury at the time such evidence is offered in the
event the Court has overruled the objection at pretrial.
17. Qualifying Expert Witness. Calling any Witness to testify as an expert without having
first been qualified as an expert for those matters which were disclosed in response to
Request for Disclosure. In addition, prior to the expert stating any opinion he must be
required to disclose the underlying facts or data which forms his “expert” opinion
pursuant to Rule 705 of the Texas Rules of Evidence.
18. Available Assets. Any inquiry into or reference to the assets Defendant has available for
investigating, preparing and defending this cause. First Nat ’l Bank of Marshall vs.
Beavers, 619 S.W.2d 288 (Tex. Civ. App.—Texarkana 1981, writ ref‘d n.r.e.); Wimoth
vs. Limestone Prods. C0., 255 S.W.2d 532, 534 (Tex. App—Waco 1953, writ refd
n.r.e.).
19. Superseded Pleadings. The contents of any pleadings which have been superseded by
the current pleadings on file in this case. Zock vs. Bank of the Southwest National
Association, Houston, 464 S.W.2d 375 (Tex. Civ. App—Houston [14th Dist] 1971, no
writ).
20. flilding or Floor of the Office of Deferflnt’s COILsel. Any inquiry or reference to
what building Defendant’s counsel’s office is located in or what floor it is located on (it is
on the 50th floor of Renaissance Tower) as such would be irrelevant to the issues in this
dispute in this case. Furthermore, any inquiry or reference would be a back-door attempt
to communicate insurance’s involvement in this matter or portray Defendant as having
sufficient available assets to afford an attorney in such an office.
21. Voir Dire Pre-testing Evidence / Previewing Verdict. Any inquiry attempting to
—
determine the weight jurors will give to the evidence. If a question does not seek to
discover a disqualifying bias or prejudice but seeks to determine the weight jurors will
give to the evidence, such question is an improper attempt to pre-test the evidence and
preview the verdict and therefore objectionable. Hyundai Motor Co. V. Vasquez, 189
S.W.3d 743 (Tex. 2006).
22. Prior Automobile Accidents. Any inquiry into or disclosing that the Defendant(s)
has/have been involved in any prior or subsequent automobile accident. Any testimony
regarding previous or subsequent accidents is irrelevant and far too prejudicial to discuss
before the jury.
Lao vs. O’Haugherty et a1. PAGE 4
DEFENDANT O’HAUGHERTY’S MOTION IN LIMINE
23. Prior Speeding Tickets. Any inquiry into or disclosing that the Defendant has ever been
issued any speeding tickets prior to or subsequent to this accident. As the Texas Supreme
Court wrote in Missouri-Kansas—Texas Railroad C0. vs. May, 600 S.W.2d. 755 (Tex.
1980), “as a general rule, evidence of similar acts is inadmissible on the issue of whether
someone was a negligent in doing or not doing a particular act.”
24. Comments on “effects on society” and “sending a message” or “protecting societv as
a whole.” Plaintiff be prohibited from making any argument, comment or inference
during any phase of this trial that Defendant should be held accountable 0r responsible
for the purpose of sending a message on behalf of society as a whole, to protect
‘community safety’, or sending a message that a particular behavior will not be
tolerated. This is because it appeals to a juror’s fear and plays upon bias, prejudice or
sympathy rather than a principled weighing of what the credible evidence shows.
25. Acceptance of responsibility. Plaintiff not make any argument that the Defendant has
failed to take responsibility for the accident or that Defendant has taken no responsibility
or any such similar argument, as such argument suggests prior negotiations or a failure of
the Defendant to make any offers of settlement. Furthermore, Defendant requests that
Plaintiff not be allowed to question Defendant as to whether Defendant accepts
“responsibility” for the occurrence in question. The term “responsibility” is vague and
ambiguous and such argument opens the door to negotiations, settlement and insurance.
Any suggestion of prior negotiations and offers are irrelevant and inadmissible during
trial. This does not prohibit Plaintiff from questioning Defendant about the facts of the
motor vehicle collision and whether or not they were being careful or exercising ordinary
care or Whether Defendant’s actions were consistent with those of a reasonably prudent
person under the circumstances as they existed at the time of the collision.
Lao vs. O’Haugherty et a1. PAGE 5
DEFENDANT O’HAUGHERTY’S MOTION IN LIMINE
Respectfully submitted,
LISA CHASTAIN & ASSOCMTES
WW
YOUNG C. JENKINS
TBN: 24034505
1201 Elm Street, Suite 5050
Dallas, TX 75270
E-Service Only: DallasLegal@allstate.com
(214) 659-4346
(877) 67 8-4763 (fax)
ATTORNEY FOR DEFENDANT(S)
JOHN O’HAUGHERTY
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been served in
compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on September 15, 2021
to:
George (Tex) Quesada
Sommerman & Quesada, L.L.P.
3811 Turtle Creek Blvd., Ste. 1400
Dallas, TX 75219
Attorney for Plaintiff
Clara M. Toman
Law Offices of Fanaff, Hoadland, Gonzales &Baldwin
P.O. Box 258829
Oklahoma City, OK 73125-8829
Attorney for Defendant Farmers
YOUNG C. JENKINS
Lao vs. O’Haugherty et a1. PAGE 6
DEFENDANT O’HAUGHERTY’S MOTION IN LIMINE
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.
Young Jenkins
Bar No. 24034505
yjena@allstate.com
Envelope ID: 57295254
Status as of 9/17/2021 10:12 AM CST
Associated Case Party: BILL LAO
Name BarNumber Email TimestampSubmitted Status
Alex Risinger arisinger@textrial.com 9/15/2021 9:09:02 PM SENT
George Quesada quesada@textrial.com 9/15/2021 9:09:02 PM SENT
Dana Chandler dchandler@textria|.com 9/15/2021 9:09:02 PM SENT
Bethzabeth Loya bloya@textrial.com 9/15/2021 9:09:02 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Scot Graves Doyen 792982 sdoyen@ds-lawyers.com 9/15/2021 9:09:02 PM SENT
Angela Marie Hahn 24026919 ahahn@ds-Iawyers.com 9/15/2021 9:09:02 PM SENT
Young Christian Jenkins 24034505 DallasLegal@allstate.com 9/15/2021 9:09:02 PM SENT
Associated Case Party: FARMERS TEXAS COUNTY MUTUAL INSURANCE
COMPANY
Name BarNumber Email TimestampSubmitted Status
Clara Toman dallaslaw@farmersinsurance.com 9/15/2021 9:09:02 PM SENT
Preview
FILED 9/15/2021 9:09 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Dorothy Strogen DEPUTY CAUSE NO. DC-l 8-1 6554 BILL LAO, IN THE DISTRICT COURT Plaintiffs, vs. 192ND JUDICIAL DISTRICT JOHN O’HAUGHERTY AND FARMERS TEXAS COUNTY DALLAS COUNTY, TEXAS MUTUAL INSURANCE COMPANY, Defendant. DEFENDANT JOHN O’HAUGHERTY’S MOTION IN LIMINE TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES JOHN O’HAUGHERTY, hereinafter referred to as "Defendant," and before any proceedings before the jury, makes and files this MOTION IN LIMINE, and respectfully moves the Court to instruct Plaintiff(s) and Plaintiff(s)' counsel to refrain from either directly or indirectly, upon voir dire examination, opening statement, interrogation of witnesses, introduction of any evidence, argument, objections before the jury, reading of any portion of the pleadings, or by any other means or in any other manner, informing the jury, or bringing to the jury's attention, any of the matters set forth in the numbered paragraphs below, unless and until such matters have been first called to the attention of the Court, out of the presence and/or hearing of the jury, and a favorable ruling has been obtained from the Court as to the admissibility and relevance of any such matters. Defendant would also note that due to the current pandemic climate and the premium being placed on getting a live jury to Show up for jury selection, that these matters be strictly enforced. A mistrial in this atmosphere is no more or less justified based upon violation of the parties’ motions in limine, but it may be more costly to all parties involved and the community and courts as a whole. Lao vs. O’Haugherty et a1. PAGE l DEFENDANT O’HAUGHERTY’S MOTION IN LIMINE 1. Insurance. Unless an insurance company is a named Defendant, that the Defendant is or is not protected, in whole or in part, by liability insurance, or that defense counsel was retained by, or all or any part of the costs of defense, or of any resulting judgment, are or will be paid by an insurance company, or any other matter suggesting an involvement of any insurance company with the defense of the case. 2. Jurors' Connection with Insurance Industry. Inquiring of potential jurors as to their present or past employment or connection with the insurance industry, or present or past connection of any family member with the insurance industry, except that: a) If a potential juror's juror information card discloses employment in the insurance industry, such potential juror may be questioned concerning same. b) Inquiry may be made of potential jurors concerning their experience (or that of members of their family), if any, reviewing, adjusting or allowing/disallowing claims, as long as no express reference is made to "insurance." 3. Liability or Non-Liabilitv for Judgment. That the named Defendant(s) may or may not have to pay any resulting judgment. 4. Attorneys' Fees. That any party will have to pay attomeys' fees, or any reference to the amount or basis of any attomeys' fees, unless a claim for recovery of attomeys' fees in the case will be submitted to the jury. 5. Criminal Offenses. That any party or witness has been suspected of, arrested for, charged with or convicted of any criminal offense unless there is evidence of a specific conviction that the Court has previously ruled is admissible in the case. 6. Alcohol or Drug Use. That any party or witness uses or abuses alcohol, tobacco, or any controlled substance, unless and until such alleged use or abuse is shown to be specifically relevant to the matters in controversy. Amoco Chemicals Corp. vs. Stafford, 663 S.W.2d 147 (Tex. App—Houston [15‘ Dist.] 1983, no writ).; TRCE 801(d); TRCE 403. 7. Settlement Negotiations or Mediation. Any negotiations, offers or demands with respect to any attempted settlement or mediation. TRCE 408; Beutel vs. Paul, 741 S.W.2d 510 (Tex. App—Houston [14th Dist.] 1987, no writ). 8. Discovery Disputes. Any reference to discovery disputes that arose during the preparation of the case for trial, any position taken by any party with respect thereto, or to the Court's rulings thereon. Lao vs. O’Haugherty et a1. PAGE 2 DEFENDANT O’HAUGHERTY’S MOTION IN LIMINE Hearsav Medical Opigions. Any hearsay statement offered for the truth of the statement by an allegedly injured person concerning any diagnosis or medical opinions communicated to such person by a physician or other health care provider. Such would be an attempt to introduce before the jury expert testimony Without a proper predicate concerning the expert’s qualifications and abilities to give such testimony. Defendant would note that TRE 803(4) specifically excepts statements made to a medical provider for diagnosis or treatment from the hearsay rule. This does not apply to statements medical provider to the patient. The idea is that an individual is unlikely to lie to a medical provider since they want an accurate diagnosis and appropriate treatment. Conversely, there is not the same reassurance of truthfulness when it comes to an individual stating what the doctor told them in the middle of a personal injury jury trial for money damages. 10. Reguests for Stipulations. Any request or demand in the presence of the jury for a stipulation to any fact, or that counsel admit or deny any fact. 11. Reguests for Files. Any request or demand in the presence of the jury that opposing counsel produce any document or thing, or that opposing counselor any party or witness exhibit, turn over or allow examination of the contents of any file or briefcase (except that a party may demand to see a document used by a witness on the stand to refresh his/her recollection, or that a witness testifies that he/she has used previously to refresh his/her recollection). 12. Discrimination. Any argument that a party should be treated more or less favorably because of such party's race, gender, national origin, nationality, religion, marital status, occupation, or financial status (except in the second phase of a bifurcated trial). 13. Hardship or Privation. Any argument or suggestion that a failure to award damages will cause a Plaintiff privation or financial hardship except that Plaintiffs counsel may certainly argue that Plaintiff has a particular amount of money outstanding for past medical bills. 14. Golden Rule. Any argument or suggestion that the jurors should put themselves in the position of a party. World Wide Tire Co. vs. Brown, 644 S.W.2d 144 (Tex. App.- Houston [14th Dist] 1982, writ ref’d n.r.e.). 15. Effect of Answers to Jurv Questions. Any argument that any finding or failure to find in response to a particular jury question will or will not result in a judgment favorable to any party. This provision does not bar argument by counsel that a particular jury question should be answered in a particular way. Cooper vs. Argonaut Insurance Co., 430 S.W. 2d. 35 (Tex. Civ. App—Dallas 1968, writ refd n.r.e.). Such argument is improper under the Texas special verdict system because it advises the jury of the effect of its answers. Lao vs. O’Haugherty et a1. PAGE 3 DEFENDANT O’HAUGHERTY’S MOTION IN LIMINE 16. Obiections to Evidence Not Produced in Discoverv. Any objection based on failure to disclose evidence in pre-trial discovery. Any party desiring to urge any such objection shall request to approach the bench and urge such objection outside the hearing of the jury. To the extent possible or predictable, such matters should be addressed and a ruling sought at pretrial once the case is assigned for trial, although the objection may be urged for the record outside the hearing of the jury at the time such evidence is offered in the event the Court has overruled the objection at pretrial. 17. Qualifying Expert Witness. Calling any Witness to testify as an expert without having first been qualified as an expert for those matters which were disclosed in response to Request for Disclosure. In addition, prior to the expert stating any opinion he must be required to disclose the underlying facts or data which forms his “expert” opinion pursuant to Rule 705 of the Texas Rules of Evidence. 18. Available Assets. Any inquiry into or reference to the assets Defendant has available for investigating, preparing and defending this cause. First Nat ’l Bank of Marshall vs. Beavers, 619 S.W.2d 288 (Tex. Civ. App.—Texarkana 1981, writ ref‘d n.r.e.); Wimoth vs. Limestone Prods. C0., 255 S.W.2d 532, 534 (Tex. App—Waco 1953, writ refd n.r.e.). 19. Superseded Pleadings. The contents of any pleadings which have been superseded by the current pleadings on file in this case. Zock vs. Bank of the Southwest National Association, Houston, 464 S.W.2d 375 (Tex. Civ. App—Houston [14th Dist] 1971, no writ). 20. flilding or Floor of the Office of Deferflnt’s COILsel. Any inquiry or reference to what building Defendant’s counsel’s office is located in or what floor it is located on (it is on the 50th floor of Renaissance Tower) as such would be irrelevant to the issues in this dispute in this case. Furthermore, any inquiry or reference would be a back-door attempt to communicate insurance’s involvement in this matter or portray Defendant as having sufficient available assets to afford an attorney in such an office. 21. Voir Dire Pre-testing Evidence / Previewing Verdict. Any inquiry attempting to — determine the weight jurors will give to the evidence. If a question does not seek to discover a disqualifying bias or prejudice but seeks to determine the weight jurors will give to the evidence, such question is an improper attempt to pre-test the evidence and preview the verdict and therefore objectionable. Hyundai Motor Co. V. Vasquez, 189 S.W.3d 743 (Tex. 2006). 22. Prior Automobile Accidents. Any inquiry into or disclosing that the Defendant(s) has/have been involved in any prior or subsequent automobile accident. Any testimony regarding previous or subsequent accidents is irrelevant and far too prejudicial to discuss before the jury. Lao vs. O’Haugherty et a1. PAGE 4 DEFENDANT O’HAUGHERTY’S MOTION IN LIMINE 23. Prior Speeding Tickets. Any inquiry into or disclosing that the Defendant has ever been issued any speeding tickets prior to or subsequent to this accident. As the Texas Supreme Court wrote in Missouri-Kansas—Texas Railroad C0. vs. May, 600 S.W.2d. 755 (Tex. 1980), “as a general rule, evidence of similar acts is inadmissible on the issue of whether someone was a negligent in doing or not doing a particular act.” 24. Comments on “effects on society” and “sending a message” or “protecting societv as a whole.” Plaintiff be prohibited from making any argument, comment or inference during any phase of this trial that Defendant should be held accountable 0r responsible for the purpose of sending a message on behalf of society as a whole, to protect ‘community safety’, or sending a message that a particular behavior will not be tolerated. This is because it appeals to a juror’s fear and plays upon bias, prejudice or sympathy rather than a principled weighing of what the credible evidence shows. 25. Acceptance of responsibility. Plaintiff not make any argument that the Defendant has failed to take responsibility for the accident or that Defendant has taken no responsibility or any such similar argument, as such argument suggests prior negotiations or a failure of the Defendant to make any offers of settlement. Furthermore, Defendant requests that Plaintiff not be allowed to question Defendant as to whether Defendant accepts “responsibility” for the occurrence in question. The term “responsibility” is vague and ambiguous and such argument opens the door to negotiations, settlement and insurance. Any suggestion of prior negotiations and offers are irrelevant and inadmissible during trial. This does not prohibit Plaintiff from questioning Defendant about the facts of the motor vehicle collision and whether or not they were being careful or exercising ordinary care or Whether Defendant’s actions were consistent with those of a reasonably prudent person under the circumstances as they existed at the time of the collision. Lao vs. O’Haugherty et a1. PAGE 5 DEFENDANT O’HAUGHERTY’S MOTION IN LIMINE Respectfully submitted, LISA CHASTAIN & ASSOCMTES WW YOUNG C. JENKINS TBN: 24034505 1201 Elm Street, Suite 5050 Dallas, TX 75270 E-Service Only: DallasLegal@allstate.com (214) 659-4346 (877) 67 8-4763 (fax) ATTORNEY FOR DEFENDANT(S) JOHN O’HAUGHERTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been served in compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on September 15, 2021 to: George (Tex) Quesada Sommerman & Quesada, L.L.P. 3811 Turtle Creek Blvd., Ste. 1400 Dallas, TX 75219 Attorney for Plaintiff Clara M. Toman Law Offices of Fanaff, Hoadland, Gonzales &Baldwin P.O. Box 258829 Oklahoma City, OK 73125-8829 Attorney for Defendant Farmers YOUNG C. JENKINS Lao vs. O’Haugherty et a1. PAGE 6 DEFENDANT O’HAUGHERTY’S MOTION IN LIMINE 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. Young Jenkins Bar No. 24034505 yjena@allstate.com Envelope ID: 57295254 Status as of 9/17/2021 10:12 AM CST Associated Case Party: BILL LAO Name BarNumber Email TimestampSubmitted Status Alex Risinger arisinger@textrial.com 9/15/2021 9:09:02 PM SENT George Quesada quesada@textrial.com 9/15/2021 9:09:02 PM SENT Dana Chandler dchandler@textria|.com 9/15/2021 9:09:02 PM SENT Bethzabeth Loya bloya@textrial.com 9/15/2021 9:09:02 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Scot Graves Doyen 792982 sdoyen@ds-lawyers.com 9/15/2021 9:09:02 PM SENT Angela Marie Hahn 24026919 ahahn@ds-Iawyers.com 9/15/2021 9:09:02 PM SENT Young Christian Jenkins 24034505 DallasLegal@allstate.com 9/15/2021 9:09:02 PM SENT Associated Case Party: FARMERS TEXAS COUNTY MUTUAL INSURANCE COMPANY Name BarNumber Email TimestampSubmitted Status Clara Toman dallaslaw@farmersinsurance.com 9/15/2021 9:09:02 PM SENT