in Re Bestway Oilfield, Inc.

CourtCourt of Appeals of Texas
DecidedAugust 31, 2022
Docket09-21-00204-CV
StatusPublished

This text of in Re Bestway Oilfield, Inc. (in Re Bestway Oilfield, Inc.) 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
in Re Bestway Oilfield, Inc., (Tex. Ct. App. 2022).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-21-00204-CV __________________

IN RE BESTWAY OILFIELD, INC.

__________________________________________________________________

Original Proceeding 284th District Court of Montgomery County, Texas Trial Cause No. 19-02-02065-CV __________________________________________________________________

MEMORANDUM OPINION

In a petition for a writ of mandamus, Bestway Oilfield, Inc. (“Relator” or

“Bestway”), argues the trial court improperly applied the discovery rules to exclude

its sole rebuttal witness on American Petroleum Institute (“API”) standards in a

lawsuit where a purchaser, Sentry Wellhead Systems, LLC (“Plaintiff” or “Sentry”),

claims Bestway failed to provide the proper documentation for oilfield valves and

other parts allegedly not in compliance with API standards. Bestway also complains

that the trial court did not grant Bestway leave to re-depose Sentry’s expert witness

1 and designate a new rebuttal witness following Sentry’s untimely production of

notes prepared by the expert and an untimely document production on the eve of

trial. We conditionally grant mandamus relief.

Bestway first designated its President, Mark Albert, as an expert in December

2019. The designation stated that Albert “will have reviewed, if necessary, various

documents and items related to this case[.]” The list of potential items reviewed

included “pleadings, correspondence and documents between the parties, the

products, discovery, deposition transcripts, and other matters between the date of

this expert designation and through trial.” In November 2020, Bestway amended its

designation to disclose that

Mark Albert is the President of Defendant Bestway and has knowledge of whether Defendant’s products comply with American Petroleum Institute (API) standards. Based on his experience, Mr. Albert will testify that the products complied with API standards, industry standards, and the parties’ agreed course of dealing, that Sentry received the products it agreed to purchase but has not paid for, and that any issue with traceability or value of the products was a result of Sentry’s or a third-party’s actions.

After deposing Albert on February 4, 2021, the real party in interest, Sentry,

filed a motion to exclude his testimony because Bestway failed to identify the

documents Albert actually reviewed. According to Sentry, Bestway produced two

sets of documents, each containing more than 600 pages, with substantial duplication

of material in the two sets. In his deposition, Albert stated that he reviewed five or

six material test reports (MTRs), but out of documentation for thirty-two valves he 2 was unable to identify which ones he reviewed. The MTRs include a Certificate of

Conformity evidencing that the product was inspected by the manufacturer and

conformed to API standards. However, it should be noted that Albert’s rebuttal bases

and opinions are based upon API standards and not the manufacturer’s individual

MTRs.

Sentry complained that Albert failed to provide sufficient facts to support the

opinions he expressed, failed to identify the methodology for his opinions, and failed

to disclose the material he reviewed in anticipation of his testimony. Sentry argued

that Bestway failed to comply with the trial court’s docket control order, which on

penalty of exclusion required each party to file with the trial court a list of the party’s

experts that provides each expert’s name, address, telephone number, subject of

testimony and opinion to be offered. Additionally, Sentry argued that Bestway failed

to provide or supplement the required expert disclosure.

The trial court struck Albert as an expert witness but ruled that Albert could

testify as a fact witness. Bestway moved for reconsideration. On June 15, 2021, the

trial court signed an order clarifying that Albert’s expert testimony would be

excluded by operation of Rule 193.6 of the Texas Rules of Civil Procedure, which

provides that if a party fails to make, amend, or supplement a discovery response in

a timely manner, that party may not introduce in evidence the material or information

that was not timely disclosed or offer the testimony of a witness (other than a named

3 party) who was not timely identified, unless the court finds there was good cause for

the failure and it will not unfairly surprise or unfairly prejudice the other party. See

Tex. R. Civ. P. 193.6. The trial court did not rule on the alternative grounds for

exclusion argued by Sentry in its motion.

To obtain mandamus relief, a relator must show both that the trial court has

clearly abused its discretion and that the relator has no adequate remedy by appeal.

See In re Prudential Ins. Co. of Am., 148 S.W.3d 124, 135–36 (Tex. 2004) (orig.

proceeding). A trial court clearly abuses its discretion if it reaches a decision so

arbitrary and unreasonable as to amount to a clear and prejudicial error of law or if

it clearly fails to analyze the law correctly or apply the law correctly to the facts. In

re Cerberus Capital Mgmt. L.P., 164 S.W.3d 379, 382 (Tex. 2005) (orig.

proceeding).

Although Sentry presented additional complaints about Bestway’s discovery

responses, the trial court ruled that Albert’s expert testimony must be excluded

because Bestway failed to identify the information reviewed by Albert. The general

exclusion required by Rule 193.6 applies when a party fails to make, amend, or

supplement a discovery response in a timely manner. See Tex. R. Civ. P. 193.6(a).

The rule’s expert disclosure requirement may be met without attaching the

documents to the disclosure if the party provides ample notice of the testifying

expert’s experience and the data from which he drew his conclusions. See SCTW

4 Health Care Ctr., Inc. v. AAR Inc., No. 01-07-00762-CV, 2009 WL 3321399, at *6–

7 (Tex. App.—Houston [1st Dist.] Oct. 15, 2009, no pet.) (mem. op.).

Bestway disclosed the identity of its expert, disclosed Albert’s opinion that

the products Bestway sold to Sentry were certified by an API 6A manufacturer

licensed at the time of manufacture, and produced the manufacturers’ MTRs then in

its possession. In other words, Bestway was a distributor of products created by a

manufacturer that was a certified API manufacturer, and the manufacturer created

the MTRs. As such, Albert’s primary rebuttal was that the API standards applied to

API manufacturers and not Bestway as the distributer. Although Albert admitted in

his deposition that he had not read every MTR and could not identify exactly which

ones he did read, the documents that were available for his review were produced so

that he could be cross-examined on them. Under these circumstances, where the

witness admitted he did not read the MTRs for all of the valves at issue in the case,

but Bestway disclosed the material to the opposing party, the automatic exclusion

for failure to timely make, amend, or supplement a discovery response did not apply

to all of Albert’s expert testimony, because Bestway made a timely disclosure of

Albert’s identity and the substance of his testimony and timely produced the

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Related

In Re Prudential Insurance Co. of America
148 S.W.3d 124 (Texas Supreme Court, 2004)
In Re Cerberus Capital Management, L.P.
164 S.W.3d 379 (Texas Supreme Court, 2005)
In Re Kings Ridge Homeowners Ass'n, Inc.
303 S.W.3d 773 (Court of Appeals of Texas, 2010)
City of Ashland v. Ashland Supply Co.
7 S.W.2d 833 (Court of Appeals of Kentucky (pre-1976), 1928)

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