Ligda, Linda v. Watts, Laurence W. and Watts & Associates, Attorneys at Law

CourtCourt of Appeals of Texas
DecidedMay 30, 2002
Docket14-00-00919-CV
StatusPublished

This text of Ligda, Linda v. Watts, Laurence W. and Watts & Associates, Attorneys at Law (Ligda, Linda v. Watts, Laurence W. and Watts & Associates, Attorneys at Law) 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
Ligda, Linda v. Watts, Laurence W. and Watts & Associates, Attorneys at Law, (Tex. Ct. App. 2002).

Opinion

Affirmed and Opinion filed May 30, 2002

Affirmed and Opinion filed May 30, 2002.

In The

Fourteenth Court of Appeals

____________

NO. 14-00-00919-CV

LINDA LIGDA, Appellant

V.

LAURENCE W. WATTS AND

WATTS & ASSOCIATES, ATTORNEYS AT LAW, Appellees

On Appeal from the 113th District Court

Harris County, Texas

Trial Court Cause No. 97-00847

O P I N I O N

Appellant Linda Ligda appeals a take-nothing judgment rendered against her and in favor of her former attorneys, appellees Laurence W. Watts and Watts and Associates, Attorneys at Law (collectively AWatts@).  Ligda contends the trial court erred by admitting the testimony of a late-designated expert and by admitting medical records obtained after the discovery deadline.  Ligda further contends the court erred by refusing to allow her to testify regarding Watts=s representation.  We affirm.


I.  Background

Ligda sued Watts alleging, among other things, violations of the Deceptive Trade PracticesBConsumer Protection Act (ADTPA@).  On January 20, 1998, Watts designated expert witnesses in responding to Ligda=s first set of interrogatories.  On April 25, 2000, just 41 days before trial, Watts supplemented his response to the interrogatories and named Dr. Byron Howard as an expert witness for the first time.  Before trial, Ligda filed a motion to exclude Dr. Howard=s testimony, alleging that Watts had untimely identified him as an expert witness, as calculated under Rule 190.3(b)(1)(B)(ii).[1]  See Tex. R. App. P. 190.3(b)(1)(B).  The trial court denied her motion.

During trial, the court overruled Ligda=s objections to admission of the following evidence: (1) Ligda=s medical records, on the ground they were obtained after the discovery deadline; and (2) the testimony of Dr. Howard because he was untimely designated.  Also during trial, the court refused to allow Ligda to testify in support of her allegation that Watts committed unconscionable acts in rendering legal services.

The trial court signed a take-nothing judgment against Ligda.  In two points of error, Ligda appeals the above evidentiary rulings and the trial court=s denial of her motion to exclude evidence.

II.  Discussion

A.  Failure to Exclude Evidence


In her first point of error, Ligda contends the trial court abused its discretion by  denying her motion to exclude the testimony of Dr. Howard and, during trial, admitting his  testimony and extensive medical records over her objection.  Because Ligda=s trial objections, and not her motion to exclude, preserved these complaints for our review, we address only whether the trial court abused its discretion in admitting the evidence during trial and not whether the trial court erred in denying Ligda=s motion to exclude.  See Clark v. Trailways, 774 S.W.2d 644, 647 (Tex. 1989) (holding that a pretrial motion will not preserve a complaint as to the admission of an untimely disclosed witness=s testimony); Welsh v. Welsh, 905 S.W.2d 615, 617 (Tex. App.CHouston [14th Dist.] 1995, writ denied).

We review a trial court=s evidentiary rulings for an abuse of discretion.  See Owens‑Corning Fiberglass Corp. v. Malone, 972 S.W.2d 35, 43 (Tex. 1998).  The test is whether the trial court acted without reference to any guiding rules or principles.  Id.  We look to the Texas Rules of Civil Procedure to determine whether Watts timely (1) supplemented his designation of expert witnesses; and (2) obtained Ligda=s medical records.  Here, both parties disagree about whether the revised discovery rules apply to these questions.

Generally, absent an express intention to the contrary, procedural rules adopted by the Texas Supreme Court are applied to pending litigation.  Cavitt v. Jetton=s Greenway Plaza Cafeteria, 563 S.W.2d 319 (Tex. Civ. App.CHouston [1st Dist.] 1978, no writ); see Tex. R. Civ. P. 1. 

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Related

Welsh v. Welsh
905 S.W.2d 615 (Court of Appeals of Texas, 1995)
Clark v. Trailways, Inc.
774 S.W.2d 644 (Texas Supreme Court, 1989)
Smith v. State
737 S.W.2d 910 (Court of Appeals of Texas, 1987)
State Farm Fire & Casualty Co. v. Morua
979 S.W.2d 616 (Texas Supreme Court, 1998)
Owens-Corning Fiberglas Corp. v. Malone
972 S.W.2d 35 (Texas Supreme Court, 1998)
Cavitt v. Jetton's Greenway Plaza Cafeteria
563 S.W.2d 319 (Court of Appeals of Texas, 1978)

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