Dolores Jennings v. Mark C. Hatfield

CourtCourt of Appeals of Texas
DecidedOctober 20, 2005
Docket14-04-00907-CV
StatusPublished

This text of Dolores Jennings v. Mark C. Hatfield (Dolores Jennings v. Mark C. Hatfield) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dolores Jennings v. Mark C. Hatfield, (Tex. Ct. App. 2005).

Opinion

Affirmed and Memorandum Opinion filed October 20, 2005

Affirmed and Memorandum Opinion filed October 20, 2005.

In The

Fourteenth Court of Appeals

____________

NO. 14-04-00907-CV

DOLORES JENNINGS, Appellant

V.

MARK C. HATFIELD, Appellee

On Appeal from the 125th District Court

Harris County, Texas

Trial Court Cause No. 03-26012

M E M O R A N D U M   O P I N I O N

Appellant Dolores Jennings sued appellee Mark C. Hatfield after the parties were involved in a minor traffic accident.  Appellant raises three issues on appeal: (1) appellee=s  open-ended pre-trial settlement offer is enforceable despite the jury=s having reached a verdict; (2) the trial court erred in excluding the testimony of appellant=s accident reconstruction expert, which resulted in an erroneous verdict; and (3) the trial court erred by excluding evidence of certain medical expenses.  We affirm.


Background

The parties were involved in a minor traffic accident on May 24, 2001.  Although the facts are disputed, the collision apparently occurred while the parties were driving through a construction zone in adjacent lanes, and one vehicle crossed into the other vehicle=s lane.  Appellant later complained of neck, back, and shoulder  pain, and had surgery approximately two years after the accident.  Appellant sued to recover the costs of her medical treatment, which she claims to be $83,976.00.

During discovery, appellee served requests for disclosure and requests for production of documents on appellant, including requests regarding appellant=s expert witnesses and her medical bills.  Specifically, appellee=s Request for Disclosure (f)(4)(A) requests A[a]ll documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert=s testimony.@ However, when appellant first responded on September 15, 2003, she listed only the experts= contact information and did not produce any documents.  Additionally, appellee=s Request for Disclosure (d) asked for the amount of economic damages and the method of calculation, to which appellant responded: AAmount of medical bills past and future.  Lost time from work, past and future at the amount [appellant] was earning.  The amounts will be supplemented.@  Appellant also responded AWill supplement@ to appellee=s Request for Disclosure (j), which addressed appellant=s relevant medical bills and records.


On September 15, 2003, appellant also responded to appellee=s requests for production of documents.  Appellee=s Request for Production No. 8 sought documents about consulting experts, and Request for Production No. 9 asked for A[a]ll documents and things including all tangible reports, physical models, compilations of data and other material prepared by an expert of [sic] for an expert in anticipation of the expert=s trial and deposition testimony; and any such materials prepared by an expert used for consultation whose work product or opinions have been reviewed, either in whole or in part, by any expert who is to be called as a witness.@  Objecting to both of these requests as A[d]uplicitous of Request for Disclosure,@ appellant did not produce the requested materials.

On February 16, 2004, appellant supplemented her responses to appellee=s requests for disclosure.  While appellant gave a figure for lost income, she again responded Awill supplement@ to appellee=s request for medical bills and records and still did not produce any documents.  Appellant also supplemented her response to appellee=s request regarding testifying expert witnesses by supplying the name and contact information of her reconstruction expert, Dr. Mike E. James, Jr., and further stated: ACurriculum Vitae of Mike E. James, Jr., Ph.D., P.E. has been previously produced.  A copy of Dr. Mike E. James= file is available in this office for review upon request.@

On April 12, 2004, shortly before trial, appellant submitted her second supplemental response to appellee=s requests for disclosure and her first supplemental responses and objections to appellee=s requests for production of documents.   In response to appellee=s request about economic damages, appellant stated that her income tax returns from 1999-2002 had been previously produced.  Regarding her testifying expert, appellant stated that A[t]he basis of his testimony will be reconstruction of the accident and causation,@ and reiterated  that ACurriculum Vitae of Mike E. James, Jr., Ph.D., P.E. has been previously produced. 

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Advantage Physical Therapy, Inc. v. Cruse
165 S.W.3d 21 (Court of Appeals of Texas, 2005)
Garza v. Tan
849 S.W.2d 430 (Court of Appeals of Texas, 1993)
Padilla v. LaFrance
907 S.W.2d 454 (Texas Supreme Court, 1995)
Shamrock Oil Co. v. Gulf Coast Natural Gas, Inc.
68 S.W.3d 737 (Court of Appeals of Texas, 2001)
Moore v. Memorial Hermann Hospital System, Inc.
140 S.W.3d 870 (Court of Appeals of Texas, 2004)
Handelman v. Handelman
608 S.W.2d 298 (Court of Appeals of Texas, 1980)
Perry v. Brooks
808 S.W.2d 227 (Court of Appeals of Texas, 1991)
Lacquement v. Handy
876 S.W.2d 932 (Court of Appeals of Texas, 1994)
Dewitt v. Prudential Insurance Co. of America
717 S.W.2d 414 (Court of Appeals of Texas, 1986)
Christy v. Andrus
722 S.W.2d 822 (Court of Appeals of Texas, 1987)
McCleary v. Armstrong World Industries, Inc.
913 F.2d 257 (Fifth Circuit, 1990)

Cite This Page — Counsel Stack

Bluebook (online)
Dolores Jennings v. Mark C. Hatfield, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dolores-jennings-v-mark-c-hatfield-texapp-2005.