Chaves v. Cogent Medical Laboratory, LLC

Western District of Texas, txwd-5:2019-cv-00861

NOTICE of Filing Designation of Witnesses, Experts and Exhibits by Toni Chaves

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UNITED STATES DISTRICT COURT Western District of Texas San Antonio Division Toni Chaves § Plaintiff, § § § Civil Action Number: 5:19-cv-861-ESC § v. § § Cogent Medical Laboratory, LLC, § Jury Demanded Defendant § § Plaintiff's Designation of Potential Witnesses, Testifying Experts, and Proposed Exhibits To: Cogent Medical Laboratory, LLC (the "Company" or "Defendant"), through its counsel of record. Pursuant to the Court's Scheduling Order (Dkt. 15), Paragraph 4, Toni Chaves ("Plaintiff") designates at this time the following potential witnesses, testifying experts, and proposed exhibits. Plaintiff will supplement as more information becomes available to her through the discovery process. The information contained herein and any proposed exhibits identified are based only upon information presently available to Plaintiff and is produced in a good faith effort to comply with the Court's Scheduling Order. These Designations are therefore made without prejudice to Plaintiff's right to designate any information or persons that may subsequently be discovered or determined to be relevant to the subject matter of this action. POTENTIAL WITNESSES a. Toni Chaves. Ms. Chaves can be contacted via the Law Office of Chris R. Miltenberger, PLLC at 1360 N. White Chapel, Suite 200, Southlake, Texas 76092. Phone number 817-416-5060. i. Ms. Chaves can testify about her claims in the lawsuit, including but not limited duties performed and hours worked, and the damages she has suffered. _____________________________________________________________________________________________ Plaintiff's Designation of Potential Witnesses, Testifying Page |1 Experts, and Proposed Exhibits b. Robert Gates. Mr. Gates is the chief officer of Defendant. i. He can testify about Ms. Chaves' duties performed and hours worked, and the damages she has suffered. c. All of the current and former employees of Defendant who worked with Plaintiff. i. Each individual may be able to testify about Plaintiff's employment by Defendant and the hours Plaintiff worked. d. Representatives of Defendant who have knowledge of the hours worked by Plaintiff. and the class members, the job duties performed by Plaintiff and the class members, and the respective method of pay. Plaintiff is not aware of the names, addresses and telephone numbers of all such individuals but they include management employees of Defendant. e. Each of the individuals identified by Defendant in Defendant's Initial or Supplemental Disclosures or Interrogatory Responses. TESTIFYING EXPERTS No testifying experts are known to be needed or to be designated as discovery is only beginning. PROPOSED EXHIBITS Not all exhibits can be designated at this time as discovery has not been completed. 1. Plaintiff will introduce the call detail records from her personal cell phone during the time when was employed by Defendant. 2. Plaintiff will introduce her compensation records. _____________________________________________________________________________________________ Plaintiff's Designation of Potential Witnesses, Testifying Page |2 Experts, and Proposed Exhibits Respectfully submitted: The Law Office of Chris R. Miltenberger, PLLC By: /s/ Chris R. Miltenberger Chris R. Miltenberger Texas State Bar Number 14171200 1360 N. White Chapel, Suite 200 Southlake, Texas 76092 817-416-5060 (office) 817-416-5062 (fax) chris@crmlawpractice.com Attorney for Plaintiff CERTIFICATE OF SERVICE This is to certify that on December 16, 2019, a true and correct copy of the above document was filed with the Court electronically and thereby served on counsel of record for Defendant. By: /s/ Chris R. Miltenberger Chris R. Miltenberger _____________________________________________________________________________________________ Plaintiff's Designation of Potential Witnesses, Testifying Page |3 Experts, and Proposed Exhibits