Preview
FILED
10/13/2023 3:35 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Loaidi Grove DEPUTY
CAUSE NO. DC-21-09623
COURTNEY DEAN GARCM, ALFRED THE DISTRICT COURT OF
§§§§§§§§§§§§§§
1N
B. CISCO, III and RYAN J. CISCO, as
Wrongful Death Beneficiaries and Heirs of
JOY H. CISCO, Deceased,
Plaintiffis,
DALLAS COUNTY, TEXAS
V.
XPO LOGISTICS FREIGHT, INC., and
FEDEX GROUND PACKAGE SYSTEM,
INC.,
Defendants. 192nd JUDICIAL DISTRICT
PLAINTIFFS’ MOTION TO EQUALIZE PREEMPTORY STRIKES
COME NOW, COURTNEY DEAN GARCLA, ALFRED B. CISCO, III and RYAN J.
CISCO, Plaintiffs in the above-styled and numbered cause of action, and file this Motion to
Equalize Peremptory Strikes. In support thereof, Plaintiffs would respectfully show as follows:
I. SUMMARY 0F THE ARGUMENT
This is multi-vehicle wrongful death case in which Marcos Gonzalez, driving a double-
trailer l8—wheeler for XPO Logistics, was involved in a highway wreck wherein he rear-ended
another 18-wheeler, operated by David Mata for his employer, FedEx, and the two 18-wheelers
collided with a pickup truck occupied by Keith Jenkins, Frances Jenkins, Megan Jenkins, and
Joseph Foley (herein, “the Jenkins Plaintiffs”) and a Cintas work van driven by Decedent Joy
Cisco. The collision killed Cisco, and the Jenkins Plaintiffs were allegedly injured. Gonzalez later
passed away for reasons unrelated to the crash, and his parents Martir Salvador Gonzalez and
Maria Zoila Gomez were named defendants as heirs of his estate. Former defendant FedEx has
been non-suited from the case. The Jenkins Plaintiffs have settled with Defendants XPO and
Gonzalez’s estate.
Plaintiffs’ Motion to Equalize Preemptory Strikes - 1 -
So at this point in the case, only two sides remain: (1) the wrongful-death beneficiaries and
heirs of Decedent Joy Cisco, namely the plaintiffs Courtney Garcia, Alfred Cisco, III, and Ryan
Cisco, and (2) the remaining defendants, XPO Logistics Freight, Inc. and the estate of their driver
Marcos Gonzalez. Defendant Gonzalez’s estate is represented by different attorneys than
Defendant XPO. Accordingly, although Defendant XPO and Defendant Gonzalez’s estate are
represented by two different firms, their interest on liability and damages is the same. Both
Defendants seek findings that Gonzalez was not liable for causing the crash that killed Cisco (or
at least that his percentage of responsibility was minimal). Both Defendants want Plaintiffs’
damages to be minimized so that there is less money awarded to Plaintiffs for their claims.
Accordingly, Defendant Gonzalez’s estate and its counsel are perfectly aligned with Defendant
XPO and its counsel for both liability and damages questions, and they should be treated as on the
same side in this case.
As such, Plaintiffs now move the Court to equalize the number of peremptory challenges
to the same total for the Plaintiffs and for Defendant XPO and Defendant Gonzalez’s estate. This
means if the Plaintiffs get six (6) strikes, Defendants XPO and Gonzalez’s estate should share six
(6) strikes as well; likewise, if the Plaintiffs receive twelve (12) strikes, Defendants XPO and
Gonzalez’s estate should have twelve (12) strikes total as well. See Tex. R. Civ. P. 233 (requiring
equalizing number of preemptory challenges); Garcia v. Central Power & Light C0., 704 S.W.2d
734, 735 -36 (Tex. 1986) (stating trial court must determine whether litigants on the same side are
antagonistic with respect to an issue of fact).
II. ARGUMENT & AUTHORITIES
In a multiparty case like the one at bar, it shall be the duty of the trial judge to equalize the
number of peremptory challenges so that no side is given unfair advantage as a result of the
Plaintiffs’ Motion to Equalize Preemptory Strikes -2-
alignment of the litigants. Tex. R. CiV. P. 233; Moore v. Altra Energy Techs., Inc., 321 S.W.3d
727, 741 (Tex. App—Houston [14th Dist] 2010, pet. denied). The term “side” is not synonymous
with “party,” “litigant,” or “person,” but rather, refers to “one or more litigants who have common
interests on the matters with which the jury is concerned.” Moore, 321 S.W.3d at 741 (citing
Patterson Dental Co. v. Dunn, 592 S.W.2d 914, 920 (Tex. 1979)). The existence of antagonism
and degree to which parties are on the same “side” is a question of law for the court. Garcia, 704
S.W.2d at 736 (citing Patterson, 592 S.W.2d at 919).
Here, XPO Logistics and the heirs to Marcos Gonzalez’s estate are on the same “side.”
XPO and Gonzalez’s estate are united in denying liability for Gonzalez’s conduct, vicariously
imputed to XPO as his employer, including on important matters such as the degree to which
Gonzalez was impaired by marijuana during the crash. And even more critically, they are
completely united in opposing all of Plaintiffs’ damages claims. Defendants have both filed
challenges to Plaintiffs’ expert on marijuana impairment, shared experts, and more. Developments
like these in pretrial discovery and motion practice can overcome any technical antagonism
evinced in the parties’ pleadings. See Moore, 321 S.W.3d at 741 (citing Garcia, 704 S.W.2d at
737; Scurlock Oil Co. v. Smithwick, 724 S.W.2d 1, 5 (Tex. 1986)).
Given Defendants’ total unity on these critical former points, it is this Court’s duty “to
equalize the number of peremptory strikes so that any litigant or side is not given an unfair
advantage as a result of the number of peremptory challenges.” Moore, 321 S.W.3d at 741
(citing Tex. R. Civ. P. 233, Van Allen v. Blackledge, 35 S.W.3d 61, 64 (Tex. App—Houston [14th
Dist] 2000, pet. denied)). Indeed, Defendants are in such perfect alignment that they should be
required to share a single set of peremptory strikes, but at the very least they should have the same
number as Plaintiffs to ensure that no thumb weighs too heavily on the scales at voir dire. As a
Plaintiffs’ Motion to Equalize Preemptory Strikes -3 -
matter of justice and pursuant to its discretion under Rule 233, the Court should thus equalize the
parties’ number of peremptory challenges at twelve (12) total for Plaintiffs and twelve (12) total
for Defendants; or, six (6) for the Plaintiffs and six (6) for Defendants.
III. PRAYER
WHEREFORE, PREMISES CONSIDERED, Plaintiffs respectfiilly pray that the Court
grant their Motion to Equalize Peremptory Strikes in its entirety. Plaintiffs further pray that the
Court grant them any and all other relief, Whether general or special, at law or in equity, to which
they may be justly entitled.
Respectfully submitted,
JIM S. ADLER & ASSOCIATES
/s/ Frank W. Robertson
FRANK W. ROBERTSON
State Bar No. 24033129
frobertson@iimadler.com
MICHAEL GOMEZ
State Bar No. 24029578
mgomez@jimadler.com
PHILIP K. BRODERICK
State Bar No. 240945 61
pbroderick@iimadler.com
12605 East Freeway, Suite 400
Houston, Texas 77015
Telephone: (713) 335-1021
Facsimile: (713) 335-1018
ATTORNEYS FOR PLAINTIFFS
Plaintiffs’ Motion to Equalize Preemptory Strikes -4-
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing instrument was served on all
counsel of record, as indicated below, pursuant to the TEXAS RULES 0F CIVIL PROCEDURE, on
October 13, 2023.
Via E-File Via E -File
Mark Scudder / Dylan S. Savage P. Clark Aspy
Quilling, Selander, Lownds, Winslett & Moser Naman, Howell, Smith & Lee, PLLC
2001 Bryan Street, Suite 1800 8310 Capital of Texas Highway North #490
Dallas, Texas 75201 Austin, Texas 78731
Via E-File Via E -File
Todd Parks Jessica Z. Barger and Brian J. Cathey
WALTERS, BALIDO & CRAIN, LLP WRIGHT CLOSE & BARGER, LLP
400 East Main Street One Riverway, Suite 2200
Decatur, Texas 76234 Houston, Texas 77056
Via E-File Via E -F ile
Eunice Fernnadez Moore Keith C. Purdue / E. Michael Grossman
The Law Offices Of George Salinas Emily Price / Gene Mattison
6143 IH-10 West. Suire 955 GROSSMAN LAW OFFICES, P.C.
San Antonio, Texas 78201 3890 W. Northwest Highway, Suite 100
Dallas, Texas 75220
Via E-File Via E -F ile
Dana M. Gannon Mike H. Bassett and Aaron J. Rolen
THORNTON, BIECHLIN, THE BASSETT FIRM
REYNOLDS & GUERRA, L.C. Two Turtle Creek Village
Fifth Floor - One International Centre 3838 Oak Lawn Avenue, Suite 1300
100 N.E. Loop 410 Dallas, Texas 75219
San Antonio, Texas 78216
Via E-File
W. Chris Surber
GAUNTT KOEN BINNEY & KIDD LLP
25700 I-45 North, Suite 130
Spring, Texas 77386
/s/ Frank W. Robertson
FRANK W. ROBERTSON
Plaintiffs’ Motion to Equalize Preemptory Strikes
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.
Maria Garcia on behalf of Frank Robertson
Bar No. 24033129
mgarcia@jimadler.com
Envelope ID: 80587594
Filing Code Description: Motion - Miscellanous
Filing Description: PLAINTIFFS??? MOTION TO EQUALIZE
PREEMPTORY STRIKES
Status as of 10/13/2023 3:49 PM CST
Associated Case Party: XPO LOGISTICS FREIGHT, INC.
Name BarNumber Email TimestampSubmitted Status
s. Todd fiarks parksedocsnotifications@wbclawfirm.com 10/13/2023 3:35:07 PM SENT
ANA CANSON acanson@qslwm.com 10/13/2023 3:35:07 PM SENT
TORRIE ABBOTTWATKINS, ESQ. torrie.abbott.watkins@wbclawfirm.com 10/13/2023 3:35:07 PM SENT
_SARAH LONG, ESQ. sarah.long@wbclawfirm.com 10/13/2023 3:35:07 PM SENT
Associated Case Party: Travelers Indemnity Company of Connecticut
Name BarNumber Email TimestampSubmitted Status
John Engvall, Jr. jengvall@engvalltxlaw.com 10/13/2023 3:35:07 PM SENT
Christine York cyork@engvalltxlaw.com 10/13/2023 3:35:07 PM SENT
Associated Case Party: MARTIR GONZALEZ
Name BarNumber Email TimestampSubmitted Status
P. Clark Aspy 1394170 aspy@namanhowell.com 10/13/2023 3:35:07 PM SENT
Associated Case Party: KEITH JENKINS
Name BarNumber Email TimestampSubmitted Status
Zhenya Hood zhenya@salinastriallaw.com 10/13/2023 3:35:07 PM SENT
Delfina Finos dfinos@salinastriallaw.com 10/13/2023 3:35:07 PM SENT
Associated Case Party: MARTIR SALVADOR
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.
Maria Garcia on behalf of Frank Robertson
Bar No. 24033129
mgarcia@jimadler.com
Envelope ID: 80587594
Filing Code Description: Motion - Miscellanous
Filing Description: PLAINTIFFS??? MOTION TO EQUALIZE
PREEMPTORY STRIKES
Status as of 10/13/2023 3:49 PM CST
Associated Case Party: MARTIR SALVADOR
Name BarNumber Email TimestampSubmitted Status
LORI A lori@namanhowell.com 10/13/2023 3:35:07 PM SENT
Associated Case Party: DAVID MATA
Name BarNumber Email TimestampSubmitted Status
E. MICHAELGROSSMAN, ESQ. legal@injuryrelief.com 10/13/2023 3:35:07 PM SENT
KEITH C.PURDUE, ESQ. kpurdue@injuryrelief.com 10/13/2023 3:35:07 PM SENT
EMILY PRICE, ESQ. eprice@injuryrelief.com 10/13/2023 3:35:07 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Dana Gannon dgannon@thorntonfirm.com 10/13/2023 3:35:07 PM SENT
Mark S. Scudder 17936300 mscudder@qslwm.com 10/13/2023 3:35:07 PM SENT
Eunice Fernandez Moore 24091453 eunice@salinastriallaw.com 10/13/2023 3:35:07 PM SENT
George Salinas 24044929 george@salinastriallaw.com 10/13/2023 3:35:07 PM SENT
Marini Torres mtorres@injuryrelief.com 10/13/2023 3:35:07 PM SENT
Kim Price kprice@qslwm.com 10/13/2023 3:35:07 PM SENT
Jason Sheffield jsheffield@namanhowell.com 10/13/2023 3:35:07 PM SENT
Keith Purdue Iegal@injuryrelief.com 10/13/2023 3:35:07 PM SENT
Michael Duncan mduncan@namanhowell.com 10/13/2023 3:35:07 PM SENT
Ryan Funderburg rfunderburg@qslwm.com 10/13/2023 3:35:07 PM SENT
Robbie Moore rmoore@thorntonfirm.com 10/13/2023 3:35:07 PM SENT
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.
Maria Garcia on behalf of Frank Robertson
Bar No. 24033129
mgarcia@jimadler.com
Envelope ID: 80587594
Filing Code Description: Motion - Miscellanous
Filing Description: PLAINTIFFS??? MOTION TO EQUALIZE
PREEMPTORY STRIKES
Status as of 10/13/2023 3:49 PM CST
Case Contacts
Kristi LMiller kmiller@thorntonfirm.com 10/13/2023 3:35:07 PM SENT
Kristi Lassiter efile@mcpheeterslaw.com 10/13/2023 3:35:07 PM SENT
Morgan McPheeters morgan@mcpheeterslaw.com 10/13/2023 3:35:07 PM SENT
Dominique Valenzuela dominique.valenzuela@roystonlaw.com 10/13/2023 3:35:07 PM SENT
Scott Noel scott.noel@roystonlaw.com 10/13/2023 3:35:07 PM SENT
Patricia Stevens patricia.stevens@roystonlaw.com 10/13/2023 3:35:07 PM SENT
Jessica Z.Barger barger@wrightclosebarger.com 10/13/2023 3:35:07 PM SENT
Brian J.Cathey cathey@wrightclosebarger.com 10/13/2023 3:35:07 PM SENT
SA Service servicesa@roystonlaw.com 10/13/2023 3:35:07 PM SENT
Christopher HunterVeirs hveirs@injuryrelief.com 10/13/2023 3:35:07 PM ERROR
Associated Case Party: Federal Express Corporation
Name BarNumber Email TimestampSubmitted Status
Aaron JRolen efile@thebassettfirm.com 10/13/2023 3:35:07 PM SENT
Preview
FILED 10/13/2023 3:35 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Loaidi Grove DEPUTY CAUSE NO. DC-21-09623 COURTNEY DEAN GARCM, ALFRED THE DISTRICT COURT OF §§§§§§§§§§§§§§ 1N B. CISCO, III and RYAN J. CISCO, as Wrongful Death Beneficiaries and Heirs of JOY H. CISCO, Deceased, Plaintiffis, DALLAS COUNTY, TEXAS V. XPO LOGISTICS FREIGHT, INC., and FEDEX GROUND PACKAGE SYSTEM, INC., Defendants. 192nd JUDICIAL DISTRICT PLAINTIFFS’ MOTION TO EQUALIZE PREEMPTORY STRIKES COME NOW, COURTNEY DEAN GARCLA, ALFRED B. CISCO, III and RYAN J. CISCO, Plaintiffs in the above-styled and numbered cause of action, and file this Motion to Equalize Peremptory Strikes. In support thereof, Plaintiffs would respectfully show as follows: I. SUMMARY 0F THE ARGUMENT This is multi-vehicle wrongful death case in which Marcos Gonzalez, driving a double- trailer l8—wheeler for XPO Logistics, was involved in a highway wreck wherein he rear-ended another 18-wheeler, operated by David Mata for his employer, FedEx, and the two 18-wheelers collided with a pickup truck occupied by Keith Jenkins, Frances Jenkins, Megan Jenkins, and Joseph Foley (herein, “the Jenkins Plaintiffs”) and a Cintas work van driven by Decedent Joy Cisco. The collision killed Cisco, and the Jenkins Plaintiffs were allegedly injured. Gonzalez later passed away for reasons unrelated to the crash, and his parents Martir Salvador Gonzalez and Maria Zoila Gomez were named defendants as heirs of his estate. Former defendant FedEx has been non-suited from the case. The Jenkins Plaintiffs have settled with Defendants XPO and Gonzalez’s estate. Plaintiffs’ Motion to Equalize Preemptory Strikes - 1 - So at this point in the case, only two sides remain: (1) the wrongful-death beneficiaries and heirs of Decedent Joy Cisco, namely the plaintiffs Courtney Garcia, Alfred Cisco, III, and Ryan Cisco, and (2) the remaining defendants, XPO Logistics Freight, Inc. and the estate of their driver Marcos Gonzalez. Defendant Gonzalez’s estate is represented by different attorneys than Defendant XPO. Accordingly, although Defendant XPO and Defendant Gonzalez’s estate are represented by two different firms, their interest on liability and damages is the same. Both Defendants seek findings that Gonzalez was not liable for causing the crash that killed Cisco (or at least that his percentage of responsibility was minimal). Both Defendants want Plaintiffs’ damages to be minimized so that there is less money awarded to Plaintiffs for their claims. Accordingly, Defendant Gonzalez’s estate and its counsel are perfectly aligned with Defendant XPO and its counsel for both liability and damages questions, and they should be treated as on the same side in this case. As such, Plaintiffs now move the Court to equalize the number of peremptory challenges to the same total for the Plaintiffs and for Defendant XPO and Defendant Gonzalez’s estate. This means if the Plaintiffs get six (6) strikes, Defendants XPO and Gonzalez’s estate should share six (6) strikes as well; likewise, if the Plaintiffs receive twelve (12) strikes, Defendants XPO and Gonzalez’s estate should have twelve (12) strikes total as well. See Tex. R. Civ. P. 233 (requiring equalizing number of preemptory challenges); Garcia v. Central Power & Light C0., 704 S.W.2d 734, 735 -36 (Tex. 1986) (stating trial court must determine whether litigants on the same side are antagonistic with respect to an issue of fact). II. ARGUMENT & AUTHORITIES In a multiparty case like the one at bar, it shall be the duty of the trial judge to equalize the number of peremptory challenges so that no side is given unfair advantage as a result of the Plaintiffs’ Motion to Equalize Preemptory Strikes -2- alignment of the litigants. Tex. R. CiV. P. 233; Moore v. Altra Energy Techs., Inc., 321 S.W.3d 727, 741 (Tex. App—Houston [14th Dist] 2010, pet. denied). The term “side” is not synonymous with “party,” “litigant,” or “person,” but rather, refers to “one or more litigants who have common interests on the matters with which the jury is concerned.” Moore, 321 S.W.3d at 741 (citing Patterson Dental Co. v. Dunn, 592 S.W.2d 914, 920 (Tex. 1979)). The existence of antagonism and degree to which parties are on the same “side” is a question of law for the court. Garcia, 704 S.W.2d at 736 (citing Patterson, 592 S.W.2d at 919). Here, XPO Logistics and the heirs to Marcos Gonzalez’s estate are on the same “side.” XPO and Gonzalez’s estate are united in denying liability for Gonzalez’s conduct, vicariously imputed to XPO as his employer, including on important matters such as the degree to which Gonzalez was impaired by marijuana during the crash. And even more critically, they are completely united in opposing all of Plaintiffs’ damages claims. Defendants have both filed challenges to Plaintiffs’ expert on marijuana impairment, shared experts, and more. Developments like these in pretrial discovery and motion practice can overcome any technical antagonism evinced in the parties’ pleadings. See Moore, 321 S.W.3d at 741 (citing Garcia, 704 S.W.2d at 737; Scurlock Oil Co. v. Smithwick, 724 S.W.2d 1, 5 (Tex. 1986)). Given Defendants’ total unity on these critical former points, it is this Court’s duty “to equalize the number of peremptory strikes so that any litigant or side is not given an unfair advantage as a result of the number of peremptory challenges.” Moore, 321 S.W.3d at 741 (citing Tex. R. Civ. P. 233, Van Allen v. Blackledge, 35 S.W.3d 61, 64 (Tex. App—Houston [14th Dist] 2000, pet. denied)). Indeed, Defendants are in such perfect alignment that they should be required to share a single set of peremptory strikes, but at the very least they should have the same number as Plaintiffs to ensure that no thumb weighs too heavily on the scales at voir dire. As a Plaintiffs’ Motion to Equalize Preemptory Strikes -3 - matter of justice and pursuant to its discretion under Rule 233, the Court should thus equalize the parties’ number of peremptory challenges at twelve (12) total for Plaintiffs and twelve (12) total for Defendants; or, six (6) for the Plaintiffs and six (6) for Defendants. III. PRAYER WHEREFORE, PREMISES CONSIDERED, Plaintiffs respectfiilly pray that the Court grant their Motion to Equalize Peremptory Strikes in its entirety. Plaintiffs further pray that the Court grant them any and all other relief, Whether general or special, at law or in equity, to which they may be justly entitled. Respectfully submitted, JIM S. ADLER & ASSOCIATES /s/ Frank W. Robertson FRANK W. ROBERTSON State Bar No. 24033129 frobertson@iimadler.com MICHAEL GOMEZ State Bar No. 24029578 mgomez@jimadler.com PHILIP K. BRODERICK State Bar No. 240945 61 pbroderick@iimadler.com 12605 East Freeway, Suite 400 Houston, Texas 77015 Telephone: (713) 335-1021 Facsimile: (713) 335-1018 ATTORNEYS FOR PLAINTIFFS Plaintiffs’ Motion to Equalize Preemptory Strikes -4- CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument was served on all counsel of record, as indicated below, pursuant to the TEXAS RULES 0F CIVIL PROCEDURE, on October 13, 2023. Via E-File Via E -File Mark Scudder / Dylan S. Savage P. Clark Aspy Quilling, Selander, Lownds, Winslett & Moser Naman, Howell, Smith & Lee, PLLC 2001 Bryan Street, Suite 1800 8310 Capital of Texas Highway North #490 Dallas, Texas 75201 Austin, Texas 78731 Via E-File Via E -File Todd Parks Jessica Z. Barger and Brian J. Cathey WALTERS, BALIDO & CRAIN, LLP WRIGHT CLOSE & BARGER, LLP 400 East Main Street One Riverway, Suite 2200 Decatur, Texas 76234 Houston, Texas 77056 Via E-File Via E -F ile Eunice Fernnadez Moore Keith C. Purdue / E. Michael Grossman The Law Offices Of George Salinas Emily Price / Gene Mattison 6143 IH-10 West. Suire 955 GROSSMAN LAW OFFICES, P.C. San Antonio, Texas 78201 3890 W. Northwest Highway, Suite 100 Dallas, Texas 75220 Via E-File Via E -F ile Dana M. Gannon Mike H. Bassett and Aaron J. Rolen THORNTON, BIECHLIN, THE BASSETT FIRM REYNOLDS & GUERRA, L.C. Two Turtle Creek Village Fifth Floor - One International Centre 3838 Oak Lawn Avenue, Suite 1300 100 N.E. Loop 410 Dallas, Texas 75219 San Antonio, Texas 78216 Via E-File W. Chris Surber GAUNTT KOEN BINNEY & KIDD LLP 25700 I-45 North, Suite 130 Spring, Texas 77386 /s/ Frank W. Robertson FRANK W. ROBERTSON Plaintiffs’ Motion to Equalize Preemptory Strikes 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. Maria Garcia on behalf of Frank Robertson Bar No. 24033129 mgarcia@jimadler.com Envelope ID: 80587594 Filing Code Description: Motion - Miscellanous Filing Description: PLAINTIFFS??? MOTION TO EQUALIZE PREEMPTORY STRIKES Status as of 10/13/2023 3:49 PM CST Associated Case Party: XPO LOGISTICS FREIGHT, INC. Name BarNumber Email TimestampSubmitted Status s. Todd fiarks parksedocsnotifications@wbclawfirm.com 10/13/2023 3:35:07 PM SENT ANA CANSON acanson@qslwm.com 10/13/2023 3:35:07 PM SENT TORRIE ABBOTTWATKINS, ESQ. torrie.abbott.watkins@wbclawfirm.com 10/13/2023 3:35:07 PM SENT _SARAH LONG, ESQ. sarah.long@wbclawfirm.com 10/13/2023 3:35:07 PM SENT Associated Case Party: Travelers Indemnity Company of Connecticut Name BarNumber Email TimestampSubmitted Status John Engvall, Jr. jengvall@engvalltxlaw.com 10/13/2023 3:35:07 PM SENT Christine York cyork@engvalltxlaw.com 10/13/2023 3:35:07 PM SENT Associated Case Party: MARTIR GONZALEZ Name BarNumber Email TimestampSubmitted Status P. Clark Aspy 1394170 aspy@namanhowell.com 10/13/2023 3:35:07 PM SENT Associated Case Party: KEITH JENKINS Name BarNumber Email TimestampSubmitted Status Zhenya Hood zhenya@salinastriallaw.com 10/13/2023 3:35:07 PM SENT Delfina Finos dfinos@salinastriallaw.com 10/13/2023 3:35:07 PM SENT Associated Case Party: MARTIR SALVADOR 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. Maria Garcia on behalf of Frank Robertson Bar No. 24033129 mgarcia@jimadler.com Envelope ID: 80587594 Filing Code Description: Motion - Miscellanous Filing Description: PLAINTIFFS??? MOTION TO EQUALIZE PREEMPTORY STRIKES Status as of 10/13/2023 3:49 PM CST Associated Case Party: MARTIR SALVADOR Name BarNumber Email TimestampSubmitted Status LORI A lori@namanhowell.com 10/13/2023 3:35:07 PM SENT Associated Case Party: DAVID MATA Name BarNumber Email TimestampSubmitted Status E. MICHAELGROSSMAN, ESQ. legal@injuryrelief.com 10/13/2023 3:35:07 PM SENT KEITH C.PURDUE, ESQ. kpurdue@injuryrelief.com 10/13/2023 3:35:07 PM SENT EMILY PRICE, ESQ. eprice@injuryrelief.com 10/13/2023 3:35:07 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Dana Gannon dgannon@thorntonfirm.com 10/13/2023 3:35:07 PM SENT Mark S. Scudder 17936300 mscudder@qslwm.com 10/13/2023 3:35:07 PM SENT Eunice Fernandez Moore 24091453 eunice@salinastriallaw.com 10/13/2023 3:35:07 PM SENT George Salinas 24044929 george@salinastriallaw.com 10/13/2023 3:35:07 PM SENT Marini Torres mtorres@injuryrelief.com 10/13/2023 3:35:07 PM SENT Kim Price kprice@qslwm.com 10/13/2023 3:35:07 PM SENT Jason Sheffield jsheffield@namanhowell.com 10/13/2023 3:35:07 PM SENT Keith Purdue Iegal@injuryrelief.com 10/13/2023 3:35:07 PM SENT Michael Duncan mduncan@namanhowell.com 10/13/2023 3:35:07 PM SENT Ryan Funderburg rfunderburg@qslwm.com 10/13/2023 3:35:07 PM SENT Robbie Moore rmoore@thorntonfirm.com 10/13/2023 3:35:07 PM SENT 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. Maria Garcia on behalf of Frank Robertson Bar No. 24033129 mgarcia@jimadler.com Envelope ID: 80587594 Filing Code Description: Motion - Miscellanous Filing Description: PLAINTIFFS??? MOTION TO EQUALIZE PREEMPTORY STRIKES Status as of 10/13/2023 3:49 PM CST Case Contacts Kristi LMiller kmiller@thorntonfirm.com 10/13/2023 3:35:07 PM SENT Kristi Lassiter efile@mcpheeterslaw.com 10/13/2023 3:35:07 PM SENT Morgan McPheeters morgan@mcpheeterslaw.com 10/13/2023 3:35:07 PM SENT Dominique Valenzuela dominique.valenzuela@roystonlaw.com 10/13/2023 3:35:07 PM SENT Scott Noel scott.noel@roystonlaw.com 10/13/2023 3:35:07 PM SENT Patricia Stevens patricia.stevens@roystonlaw.com 10/13/2023 3:35:07 PM SENT Jessica Z.Barger barger@wrightclosebarger.com 10/13/2023 3:35:07 PM SENT Brian J.Cathey cathey@wrightclosebarger.com 10/13/2023 3:35:07 PM SENT SA Service servicesa@roystonlaw.com 10/13/2023 3:35:07 PM SENT Christopher HunterVeirs hveirs@injuryrelief.com 10/13/2023 3:35:07 PM ERROR Associated Case Party: Federal Express Corporation Name BarNumber Email TimestampSubmitted Status Aaron JRolen efile@thebassettfirm.com 10/13/2023 3:35:07 PM SENT