Altagrace Exume v. United Cargo Logistics, LLC

CourtDistrict Court, E.D. Texas
DecidedJune 16, 2025
Docket4:24-cv-00205
StatusUnknown

This text of Altagrace Exume v. United Cargo Logistics, LLC (Altagrace Exume v. United Cargo Logistics, LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Altagrace Exume v. United Cargo Logistics, LLC, (E.D. Tex. 2025).

Opinion

United States District Court EASTERN DISTRICT OF TEXAS SHERMAN DIVISION

ALTAGRACE EXUME, § § Plaintiff, § v. § Civil Action No. 4:24-cv-205 § Judge Mazzant UNITED CARGO LOGISTICS, LLC, § et al., § § Defendants. §

MEMORANDUM OPINION AND ORDER Pending before the Court is Defendant United Cargo Logistics, LLC’s Motion to Exclude Expert Testimony of Roberto Cavazos, Ph.D. (Dkt. #29). Having considered the Motion, the relevant pleadings, and the applicable law, the Court finds that the Motion should be GRANTED. BACKGROUND The current dispute arises from a motor vehicle accident that occurred on October 26, 2022 (Dkt. #22 at ¶ 11). While Plaintiff Altagrace Exume was following behind a tractor-trailer driven by Defendant Alexys Figueredo, a spare tire fell from the truck and struck Plaintiff’s vehicle (Dkt. #22 at ¶ 11). Plaintiff allegedly suffered injuries as a result of the collision (Dkt. #22 at ¶ 11). Plaintiff alleges that Defendant United Cargo Logistics, LLC (“UCL”) is liable for Plaintiff’s injuries under a variety of negligence and vicarious liability theories (See Dkt. #22 at ¶¶ 14–17). Plaintiff filed suit in Texas State Court on January 24, 2024 (Dkt. #2). UCL removed the action to this Court on March 6, 2024, asserting diversity of citizenship as a basis for jurisdiction (Dkt. #1; Dkt. #8). Plaintiff moved to remand the case on April 4, 2024 (Dkt. #7). The Court found that it has subject matter jurisdiction and denied the motion to remand on October 31, 2024 (Dkt. #39). UCL moved to strike Plaintiff’s expert economist, Robert Cavazos, on September 4, 2024, arguing that his opinion was unreliable, speculative, and unsupported by the evidence (Dkt. #29). Plaintiff filed her Response on September 18, 2024 (Dkt. #31). UCL filed its Reply on September

25, 2024 (Dkt. #32). LEGAL STANDARD Federal Rule of Evidence 702 provides for the admission of expert testimony that assists the trier of fact to understand the evidence or to determine a fact in issue. FED. R. EVID. 702. In Daubert v. Merrell Dow Pharms., Inc., the Supreme Court instructed courts to function as gatekeepers and determine whether expert testimony should be presented to the jury. 509 U.S.

579, 590–93 (1993). Courts act as gatekeepers of expert testimony “to make certain that an expert, whether basing testimony upon professional studies or personal experience, employs in the courtroom the same level of intellectual rigor that characterizes the practice of an expert in the relevant field.” Kuhmo Tire Co. v. Carmichael, 526 U.S. 137, 152 (1999). The party offering the expert’s testimony has the burden to prove that: (1) the expert is qualified; (2) the testimony is relevant to an issue in the case; and (3) the testimony is reliable. Daubert, 509 U.S. at 590–91. A proffered expert witness is qualified to testify by virtue of his or her

“knowledge, skill, experience, training, or education.” FED. R. EVID. 702. Moreover, to be admissible, expert testimony must be “not only relevant but reliable.” Daubert, 509 U.S. at 589. “This gate-keeping obligation applies to all types of expert testimony, not just scientific testimony.” Pipitone v. Biomatrix, Inc., 288 F.3d 239, 244 (5th Cir. 2002) (citing Kuhmo, 526 U.S. at 147). In deciding whether to admit or exclude expert testimony, the Court should consider

numerous factors. Daubert, 509 U.S. at 594. In Daubert, the Supreme Court offered the following, non-exclusive list of factors that courts may use when evaluating the reliability of expert testimony: (1) whether the expert’s theory or technique can be or has been tested; (2) whether the theory or technique has been subjected to peer review and publication; (3) the known or potential rate of error of the challenged method; and (4) whether the theory or technique is generally accepted in the relevant scientific community. Id. at 593–94; Pipitone, 288 F.3d at 244. When evaluating

Daubert challenges, courts focus “on [the experts’] principles and methodology, not on the conclusions that [the experts] generate.” Daubert, 509 U.S. at 595. The Daubert factors are not “a definitive checklist or test.” Id. at 593. As the Supreme Court has emphasized, the Daubert framework is “a flexible one.” Id. at 594. The test for determining reliability can adapt to the particular circumstances underlying the testimony at issue. Kuhmo, 526 U.S. at 152. Accordingly, the decision to allow or exclude experts from testifying under Daubert is committed to the sound discretion of the district court. St. Martin v. Mobil Expl. &

Producing U.S., Inc., 224 F.3d 402, 405 (5th Cir. 2000) (citations omitted). ANALYSIS UCL challenges the admissibility of Cavazos’s opinions, arguing that they are speculative, unreliable, and not based on supporting evidence (See Dkt. #29 at ¶¶ 9–11). Primarily, UCL focuses on the lack of evidence to support Cavazos’s opinions (See Dkt. #29 at ¶¶ 9–11). Specifically, UCL notes that Cavazos relied on an interview with Plaintiff to conclude the amount of lost wages and earning capacity she will be subjected to, but that Plaintiff did not disclose any part of the interview (Dkt. #29 at ¶ 9). Further, UCL argues that Cavazos did not consider any other factors when determining Plaintiff’s income at the time of her injury, basing his opinion on

three pay stubs from 2024 (Dkt. #329 at ¶¶ 9–10). Similarly, UCL challenges Cavazos’s opinion of lost household services because it is based on the undisclosed interview (Dkt. #29 at ¶ 9). Plaintiff initially responds by arguing that the Court should continue its ruling on UCL’s motion until UCL deposes Cavazos (Dkt. #31 at pp. 2–4). On Plaintiff’s understanding, it would be improper for the Court to consider Cavazos’s reliability and methodology without his deposition (Dkt. #31 at pp. 2–4). Thus, according to Plaintiff, the Court should wait to rule on UCL’s motion

until after UCL deposes Cavazos (Dkt. #31 at pp. 2–4). Next, Plaintiff argues that Cavazos’s opinions are admissible because he relied on the type of information that economists normally utilize in their analyses (Dkt. #31 at pp. 6–8). Specifically, Plaintiff argues that Cavazos’s interview with her, the three pay stubs, and the Social Security Earnings Statement provide sufficient information to support the reliability of Cavazos’s opinions (Dkt. #31 at pp. 6–8). In addition to these arguments, Plaintiff briefly addresses two other points. First, she argues that UCL presented no argument against Cavazos’s loss of household services opinion and has thereby waived that

challenge (Dkt. #31 at p. 6). Second, Plaintiff argues that UCL did not cite to any authority for its argument that Plaintiff must disclose the content of the interview (Dkt. #31 at p. 8). Essentially, Plaintiff argues that UCL can only learn the content of the interview if it deposes Cavazos (Dkt. #31 at p. 8).1

1 Plaintiff cites no authority to support this proposition (See Dkt. #31 at p. 8). UCL addresses Plaintiff’s arguments in its Reply (See Dkt. #32). UCL first addresses Plaintiff’s request for a continuance by arguing that an expert report is required to be a complete and accurate statement of all opinions to be expressed, such that a deposition is not required to fix

a deficient expert report (See Dkt. #32 at pp. 2–3).

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Related

Guillory v. Domtar Industries Inc.
95 F.3d 1320 (Fifth Circuit, 1996)
Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Kumho Tire Co. v. Carmichael
526 U.S. 137 (Supreme Court, 1999)
Orthoflex, Inc. v. Thermotek, Inc.
986 F. Supp. 2d 776 (N.D. Texas, 2013)

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