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FILED
4/11/2024 2:35 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Rosa Delacerda DEPUTY
CAUSE NO. DC-22-15205
JAMES PETERSON § IN THE DISTRICT COURT
Plaintiff, §
§
V. § 116th JUDICIAL DISTRICT
§
CITY OF DALLAS §
Defendant. § DALLAS COUNTY, TEXAS
DEFENDANT CITY OF DALLAS’S MOTION IN LIMINE
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES THE CITY OF DALLAS, (the City), and before any proceedings before
the jury, makes and files this MOTION IN LIMINE, and respectfully moves the Court to instruct
Plaintiff 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:
1. Attorneys' Fees. That any party will have to pay attorneys' 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.
2. Income Tax. That any recovery will or will not be subject to income taxes, in whole or in
part.
3. Hearsay Statements Of Witnesses. Any reference to any hearsay statement of any
witness or alleged witness, other than an adverse party or agent of an adverse party, unless
and until such witness has been called to testify. A deposition or a statement in business or
medical records that have been proved up as required by the Rules of Evidence are not a
hearsay statements.
DEFENDANT’S MOTION IN LIMINE Page 1
Testimonv Of AbseI_1t Witness. Any statement or suggestion as to the probable testimony
of any witness or alleged witness Who is unavailable to testify, or whom the party
suggesting such testimony does not, in good faith, expect to testify in the trial. If the party
is expected to testify by deposition, this provision does not apply to testimony contained in
the deposition expected to be offered. Sanders v. St. Paul Fire & Marine Ins. C0,, 429
S.W.2d 516 (Tex. CiV. Apkaexarkana 1968, writ re’d n.r.e.).
Hearsay Medical Opinions. 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.
Requests 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.
Hardship Or Privation. Any argument or suggestion that a failure to award damages will
cause plaintiff’s privation or financial hardship.
Golden Rule. Any argument or suggestion that the jurors should put themselves in the
position of a party. World Wide Tire C0. vs. Brown, 644 S.W.2d 144 (Tex. App-Houston
[14th Dist] 1982, writ ret‘d n.r.e.).
Counsel’s Opinion Of Credibility. Any expression of counsel's personal opinion
regarding the credibility of any witness. Wallace vs. Liberty Mutual Ins. C0., 413 S.W.2d
787, 790 (Tex. Civ. App—Houston 1967, writ ref’ d n.r.e.).
10. Effect Of Answers To Jury 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 C0,, 430 S.W. 2d.
35 (Tex. Civ. App—Dallas 1968, writ ref’ d n.r.e.). Such argument is improper under the
Texas special verdict system because it advises the jury of the effect of its answers.
11. Evidence Not Produced In Discovery Response To A Proper Request. Calling any
witness, or offering any document in evidence, if the identity of such witness or the
document has not been disclosed in response to a proper discovery request. If a party has
a good faith basis to urge that such witness or document should be received either because
(a) no discovery request properly called for its disclosure, or (b) good cause existed for
failure timely to disclose, such party shall first approach the bench and secure a ruling
thereon. Counsel are advised that to the extent possible or predictable, such matters should
be addressed and a ruling sought at pretrial once the case is assigned for trial. City of San
Antonio vs. Fulcher, 749 S.W.2d 217, 220 (Tex. App—San Antonio 1988, writ den).
TRCP 215.
DEFENDANT’S MOTION IN LIMINE Page 2
12. 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.
13. Experts Not Designated Or Lav Witnesses Not Disclosed. Calling any expert or lay
witness to testify at trial, other than the experts and lay witnesses expressly identified in
response to the City’s Request for Disclosure. TRCP 194 and 195; Trubell vs. Patton, 582
S.W. 2d 606 (Tex. Civ. App-Tyler 1979, no writ); Smithson v. Cessna Aircraft Co., 655
S.W.2d 439 (Tex. 1984).
14. 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.
15. Prior Automobile Accidents. Any inquiry into or disclosing that the City’s driver
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.
16. Available Assets. Any inquiry into or reference to the assets the City 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. Co., 255 S.W.2d 532, 534 (Tex. App—Waco 1953, writ refid n.r.e.).
17. Existence 0f Motion In Limine. Any reference to this Motion in Limine being filed or
that all or any portion of the relief requested herein has been granted or denied. Burdick
vs. York Oil C0,, 364 S.W.2d 766 (Tex. Civ. App—San Antonio 1963, writ refd n.r.e.).
18. Privileged Information. Any inquiry or discussion regarding matters protected by the
work product doctrine and the party communications privilege. Specifically, examination
regarding the preparation and review of documents or information generated or
accumulated after anticipation of litigation.
19. Calculation 0f Economic Damages. Plaintiff be prohibited from introducing any
evidence, offering any testimony, or making any argument regarding economic damages.
Pursuant to TRCP 194.2, Plaintiff is required to disclose the amount and method of
calculating economic damages. Pursuant to TRCP 193.6, information and material not
disclosed through discovery may not be introduced into evidence.
DEFENDANT’S MOTION IN LIMINE Page 3
20. Statements Of Law. Plaintiff be prohibited from making any statement of the law other
than that regarding the burden of proof and the basic legal definitions before the Charge
conference.
21. Loss Of Earning Cgapacitv. Any amounts of Plaintiff s loss of earnings and loss of earning
capacity, if any, over and above the present value of a net loss after reduction for income
tax payments or unpaid tax liability pursuant to any federal income tax law. Tex. CiV. Prac.
& Code §18.091.
22. Affidavits Not In Compliance. Plaintiff be precluded from introducing into evidence any
affidavits which do not comply with Section 18.001 of the Texas Civil Practice and
Remedies Code.
23. Photographs And Visual Airy. Showing any documents, photographs or visual aids to
the jury, or displaying same in such manner that the jury or any member thereof can see
the same, unless and until the same has been tendered to opposing counsel, and has been
admitted in evidence or approved for admission or use before the jury, either by the Court
or by all counsel.
24. Any Moving Violations. Any inquiry into or disclosing that the City’s driver has ever
been issued any speeding tickets or any other moving Violations 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.”
25. Future Medical. Plaintiff be prohibited from introducing any records or presenting any
testimony or evidence of future medical care until such a time a proper predicate (a valid
basis for opinion) is laid and that such opinion is based on reasonable medical probability.
26. Medical Expenses Owed. Plaintiff be prohibited from offering any evidence or testimony
that Plaintiff will have to pay Plaintiff’s healthcare providers regardless of the outcome of
the subject lawsuit. The foregoing is irrelevant as to any issue that is to be the event the
foregoing is admissible, the same would create confusion of the issues submitted at trial.
27. Discipline of Employee. Plaintiff be prohibited from offering any evidence or testimony
that City’s driver received discipline from the City of Dallas or violated any City of Dallas
Policies relating to this incident or unrelated incidents, as well as the driver’s current
administrative status, as the internal employment procedures of the City of Dallas are
irrelevant to the jury’s determination of whether City’s Driver was negligent, and such
evidence would be irrelevant, and any probative value would be outweighed by undue
prejudice to the defense. Moreover, said evidence or testimony would cause confusion of
the issues because claims for negligent entrustment, negligent hiring, training and
supervision do not come within the waiver of governmental immunity under the Texas Tort
Claims Act. Waldon v. City ofLongview, 855 S.W.2d 875, 880 (Tex. App—Tyler 1993,
DEFENDANT’S MOTION IN LIMINE Page 4
no writ); McCord v. Memorial Medical Center H0sp., 750 S.W.2d 362 (Tex. App.—
Corpus Christi 1988, no writ).
28. Unauthenticated Writings. Plaintiff be prohibited from offering any evidence or
testimony regarding any handwritten letters, notes, or signatures from the City’s driver
unless properly authenticated. See Tex. R. EVid. 901; see also Howard v. White, 2002 WL
1470071, at *3 (Tex. AppiDallas July 10, 2002, no pet.) (Ruling that the mere statement
that another individual provided the proponent with a writing is insufficient to support a
finding of proper authentication under Rule 901 .)
Respectfully submitted,
CITY ATTORNEY OF THE CITY OF DALLAS
Tammy L. Palomino
City Attorney
/S/ Lauren M. Hopkins
LAUREN M. HOPKINS
Assistant City Attorney
State Bar No. 24060250
Email: lauren.hopkins@dallas.gov
LINDSAY WILSON GOWIN
Senior Assistant City Attorney
State Bar No. 24111401
Email: lindsay.gowin@dallas.gov
City Attorney’s Office
1500 Marilla Street, Room 7D North
Dallas, Texas 75201
Telephone: 214-670-3519
Telecopier: 214-670-0622
ATTORNEYS FOR DEFENDANT
CITY OF DALLAS
DEFENDANT’S MOTION IN LIMINE Page 5
CERTIFICATE OF SERVICE
I certify that Rules 21 and 21a of the Texas Rules of Civil Procedure were complied with
in the service of the foregoing document on the 10th day of April, 2024.
Via E-Service: rabia.said@witheritelaw.com
Rabia Said
Witherite Law Group, PLLC
10440 N. Central Expressway, Suite 400
Dallas, TX 75231
Attorney for Plaintifl
/s/Lauren McDermott Hopkins
LAUREN MCDERMOTT HOPKINS
DEFENDANT’S MOTION IN LIMINE Page 6
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.
Lauren Hopkins
Bar No. 24060250
lauren.hopkins@dallas.gov
Envelope ID: 86561313
Filing Code Description: Motion - In Limine
Filing Description: DEFENDANT
Status as of 4/12/2024 8:28 AM CST
Associated Case Party: JAMES PETERSON
Name BarNumber Email TimestampSubmitted Status
Rabia Said Rabia.Said@witheritelaw.com 4/11/2024 2:35:35 PM SENT
Associated Case Party: CITY OF DALLAS
Name BarNumber Email TimestampSubmitted Status
Donna Hinkle donna.hinkle@da|las.gov 4/11/2024 2:35:35 PM SENT
Lauren Hopkins lauren.hopkins@dallas.gov 4/11/2024 2:35:35 PM SENT
Patricia Shake atttortsteam@dallas.gov 4/11/2024 2:35:35 PM SENT
Lindsay Gowin lindsay.gowin@dallas.gov 4/11/2024 2:35:35 PM SENT
Princess Hall princess.hal|@dallas.gov 4/11/2024 2:35:35 PM SENT
Preview
FILED 4/11/2024 2:35 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Rosa Delacerda DEPUTY CAUSE NO. DC-22-15205 JAMES PETERSON § IN THE DISTRICT COURT Plaintiff, § § V. § 116th JUDICIAL DISTRICT § CITY OF DALLAS § Defendant. § DALLAS COUNTY, TEXAS DEFENDANT CITY OF DALLAS’S MOTION IN LIMINE TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES THE CITY OF DALLAS, (the City), and before any proceedings before the jury, makes and files this MOTION IN LIMINE, and respectfully moves the Court to instruct Plaintiff 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: 1. Attorneys' Fees. That any party will have to pay attorneys' 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. 2. Income Tax. That any recovery will or will not be subject to income taxes, in whole or in part. 3. Hearsay Statements Of Witnesses. Any reference to any hearsay statement of any witness or alleged witness, other than an adverse party or agent of an adverse party, unless and until such witness has been called to testify. A deposition or a statement in business or medical records that have been proved up as required by the Rules of Evidence are not a hearsay statements. DEFENDANT’S MOTION IN LIMINE Page 1 Testimonv Of AbseI_1t Witness. Any statement or suggestion as to the probable testimony of any witness or alleged witness Who is unavailable to testify, or whom the party suggesting such testimony does not, in good faith, expect to testify in the trial. If the party is expected to testify by deposition, this provision does not apply to testimony contained in the deposition expected to be offered. Sanders v. St. Paul Fire & Marine Ins. C0,, 429 S.W.2d 516 (Tex. CiV. Apkaexarkana 1968, writ re’d n.r.e.). Hearsay Medical Opinions. 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. Requests 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. Hardship Or Privation. Any argument or suggestion that a failure to award damages will cause plaintiff’s privation or financial hardship. Golden Rule. Any argument or suggestion that the jurors should put themselves in the position of a party. World Wide Tire C0. vs. Brown, 644 S.W.2d 144 (Tex. App-Houston [14th Dist] 1982, writ ret‘d n.r.e.). Counsel’s Opinion Of Credibility. Any expression of counsel's personal opinion regarding the credibility of any witness. Wallace vs. Liberty Mutual Ins. C0., 413 S.W.2d 787, 790 (Tex. Civ. App—Houston 1967, writ ref’ d n.r.e.). 10. Effect Of Answers To Jury 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 C0,, 430 S.W. 2d. 35 (Tex. Civ. App—Dallas 1968, writ ref’ d n.r.e.). Such argument is improper under the Texas special verdict system because it advises the jury of the effect of its answers. 11. Evidence Not Produced In Discovery Response To A Proper Request. Calling any witness, or offering any document in evidence, if the identity of such witness or the document has not been disclosed in response to a proper discovery request. If a party has a good faith basis to urge that such witness or document should be received either because (a) no discovery request properly called for its disclosure, or (b) good cause existed for failure timely to disclose, such party shall first approach the bench and secure a ruling thereon. Counsel are advised that to the extent possible or predictable, such matters should be addressed and a ruling sought at pretrial once the case is assigned for trial. City of San Antonio vs. Fulcher, 749 S.W.2d 217, 220 (Tex. App—San Antonio 1988, writ den). TRCP 215. DEFENDANT’S MOTION IN LIMINE Page 2 12. 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. 13. Experts Not Designated Or Lav Witnesses Not Disclosed. Calling any expert or lay witness to testify at trial, other than the experts and lay witnesses expressly identified in response to the City’s Request for Disclosure. TRCP 194 and 195; Trubell vs. Patton, 582 S.W. 2d 606 (Tex. Civ. App-Tyler 1979, no writ); Smithson v. Cessna Aircraft Co., 655 S.W.2d 439 (Tex. 1984). 14. 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. 15. Prior Automobile Accidents. Any inquiry into or disclosing that the City’s driver 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. 16. Available Assets. Any inquiry into or reference to the assets the City 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. Co., 255 S.W.2d 532, 534 (Tex. App—Waco 1953, writ refid n.r.e.). 17. Existence 0f Motion In Limine. Any reference to this Motion in Limine being filed or that all or any portion of the relief requested herein has been granted or denied. Burdick vs. York Oil C0,, 364 S.W.2d 766 (Tex. Civ. App—San Antonio 1963, writ refd n.r.e.). 18. Privileged Information. Any inquiry or discussion regarding matters protected by the work product doctrine and the party communications privilege. Specifically, examination regarding the preparation and review of documents or information generated or accumulated after anticipation of litigation. 19. Calculation 0f Economic Damages. Plaintiff be prohibited from introducing any evidence, offering any testimony, or making any argument regarding economic damages. Pursuant to TRCP 194.2, Plaintiff is required to disclose the amount and method of calculating economic damages. Pursuant to TRCP 193.6, information and material not disclosed through discovery may not be introduced into evidence. DEFENDANT’S MOTION IN LIMINE Page 3 20. Statements Of Law. Plaintiff be prohibited from making any statement of the law other than that regarding the burden of proof and the basic legal definitions before the Charge conference. 21. Loss Of Earning Cgapacitv. Any amounts of Plaintiff s loss of earnings and loss of earning capacity, if any, over and above the present value of a net loss after reduction for income tax payments or unpaid tax liability pursuant to any federal income tax law. Tex. CiV. Prac. & Code §18.091. 22. Affidavits Not In Compliance. Plaintiff be precluded from introducing into evidence any affidavits which do not comply with Section 18.001 of the Texas Civil Practice and Remedies Code. 23. Photographs And Visual Airy. Showing any documents, photographs or visual aids to the jury, or displaying same in such manner that the jury or any member thereof can see the same, unless and until the same has been tendered to opposing counsel, and has been admitted in evidence or approved for admission or use before the jury, either by the Court or by all counsel. 24. Any Moving Violations. Any inquiry into or disclosing that the City’s driver has ever been issued any speeding tickets or any other moving Violations 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.” 25. Future Medical. Plaintiff be prohibited from introducing any records or presenting any testimony or evidence of future medical care until such a time a proper predicate (a valid basis for opinion) is laid and that such opinion is based on reasonable medical probability. 26. Medical Expenses Owed. Plaintiff be prohibited from offering any evidence or testimony that Plaintiff will have to pay Plaintiff’s healthcare providers regardless of the outcome of the subject lawsuit. The foregoing is irrelevant as to any issue that is to be the event the foregoing is admissible, the same would create confusion of the issues submitted at trial. 27. Discipline of Employee. Plaintiff be prohibited from offering any evidence or testimony that City’s driver received discipline from the City of Dallas or violated any City of Dallas Policies relating to this incident or unrelated incidents, as well as the driver’s current administrative status, as the internal employment procedures of the City of Dallas are irrelevant to the jury’s determination of whether City’s Driver was negligent, and such evidence would be irrelevant, and any probative value would be outweighed by undue prejudice to the defense. Moreover, said evidence or testimony would cause confusion of the issues because claims for negligent entrustment, negligent hiring, training and supervision do not come within the waiver of governmental immunity under the Texas Tort Claims Act. Waldon v. City ofLongview, 855 S.W.2d 875, 880 (Tex. App—Tyler 1993, DEFENDANT’S MOTION IN LIMINE Page 4 no writ); McCord v. Memorial Medical Center H0sp., 750 S.W.2d 362 (Tex. App.— Corpus Christi 1988, no writ). 28. Unauthenticated Writings. Plaintiff be prohibited from offering any evidence or testimony regarding any handwritten letters, notes, or signatures from the City’s driver unless properly authenticated. See Tex. R. EVid. 901; see also Howard v. White, 2002 WL 1470071, at *3 (Tex. AppiDallas July 10, 2002, no pet.) (Ruling that the mere statement that another individual provided the proponent with a writing is insufficient to support a finding of proper authentication under Rule 901 .) Respectfully submitted, CITY ATTORNEY OF THE CITY OF DALLAS Tammy L. Palomino City Attorney /S/ Lauren M. Hopkins LAUREN M. HOPKINS Assistant City Attorney State Bar No. 24060250 Email: lauren.hopkins@dallas.gov LINDSAY WILSON GOWIN Senior Assistant City Attorney State Bar No. 24111401 Email: lindsay.gowin@dallas.gov City Attorney’s Office 1500 Marilla Street, Room 7D North Dallas, Texas 75201 Telephone: 214-670-3519 Telecopier: 214-670-0622 ATTORNEYS FOR DEFENDANT CITY OF DALLAS DEFENDANT’S MOTION IN LIMINE Page 5 CERTIFICATE OF SERVICE I certify that Rules 21 and 21a of the Texas Rules of Civil Procedure were complied with in the service of the foregoing document on the 10th day of April, 2024. Via E-Service: rabia.said@witheritelaw.com Rabia Said Witherite Law Group, PLLC 10440 N. Central Expressway, Suite 400 Dallas, TX 75231 Attorney for Plaintifl /s/Lauren McDermott Hopkins LAUREN MCDERMOTT HOPKINS DEFENDANT’S MOTION IN LIMINE Page 6 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. Lauren Hopkins Bar No. 24060250 lauren.hopkins@dallas.gov Envelope ID: 86561313 Filing Code Description: Motion - In Limine Filing Description: DEFENDANT Status as of 4/12/2024 8:28 AM CST Associated Case Party: JAMES PETERSON Name BarNumber Email TimestampSubmitted Status Rabia Said Rabia.Said@witheritelaw.com 4/11/2024 2:35:35 PM SENT Associated Case Party: CITY OF DALLAS Name BarNumber Email TimestampSubmitted Status Donna Hinkle donna.hinkle@da|las.gov 4/11/2024 2:35:35 PM SENT Lauren Hopkins lauren.hopkins@dallas.gov 4/11/2024 2:35:35 PM SENT Patricia Shake atttortsteam@dallas.gov 4/11/2024 2:35:35 PM SENT Lindsay Gowin lindsay.gowin@dallas.gov 4/11/2024 2:35:35 PM SENT Princess Hall princess.hal|@dallas.gov 4/11/2024 2:35:35 PM SENT