CAUSE NO.

DC-18-00639

INTERSTATE 35W AT FM407, LP, § IN THE DISTRICT COURT

by and through its General Partner §
INTERSTATE 35W AT 407 GP, LLC, §

Plaintiff,

GARRETT, GALVIN & DELAO- DALLAS COUNTY, TEXAS

INTERSTATE 35W AT 407, LLC,
GARRETT, GALVIN & DELAO-
PARKER COUNTY, LLC
KATHY GARRETT, and
JOHN DELAO,

Defendants. 191“ 3UDICIAL DISTRICT

DEFENDANT'S RESPONSE TO RULE 194 REOUEST FOR DISCLOSURES

TO: Plaintiff (s) INTERSTATE 35W at FM407, LP, by and through lts General
Partner INTERSTATE 35W at 407 GP, LLC, by and through their attorney of
record, Cody L. Towns, Esq., Towns Law Firm, PC, 1314 W. McDermott, Suite
106-626, Allen, Texas 75013.

In response to your request, and pursuant to Rule 194 of the Texas Rules of Civil

Procedure, Defendant hereby discloses the following information or material described in Rule

194.

Rule 194 Dis Page 1 1 P-1721

closures V
 RESPONSE TO RULE 194 REQUEST FOR DISCLOSURES

(a) The correct names of the parties to the lawsuit: Defendant believes the parties are
correctly named.

(b) The name, address, and telephone number of any potential parties: At this time,
Defendant identifies Ralph Mason (whose contact information is known to Plalntiffl as a
potential party. Other potential parties may be named later.

(c) The legal theories and, in general, the factual bases of the Defendant/Third-
Party Plaintiff s claims or defenses: See the pleadings of the Defendant/Third-Party
Plaintiff filed herein; and the discovery in this lawsuit, including documents produced by
the parties, depositions, and discovery responses by the partles.

(d) The amount and any method of calculating economic damages: will supplement.

(e) The name, address, and telephone number of persons having knowledge of relevant
facts, and a brief statement of each ldentified person’s connection with the case:

1. All parties to this action, their agents, representatives, and assigns.

2. Kathy Garrett.

3. Stephen Schattner.

4. John Delao.

5. William (Bill) Galvin.

6. David Davldson—real estate broker involved in relevant real estate transaction(s).

7. Scott Seward—a limited partner in the subject investment(s).

8. Ralph Mason—an investor in the subject real estate; and longtime frlend and
business associate of Stephen Schattner.

The contact information for all listed persons is known to Plaintiff.

(II Expert witness: Lawrence E. Ackels, Jr. may testify regarding attorney’s fees. Resume
available at www.acke1slaw.com.

(g) Any indemnity and insuring agreements: None.

 (h) Any settlement agreements: None.

(i) Any witness statements: None.

(j) Medical records and bills: Not applicable.

(k) Medical records and bills. Not applicable.

(I) The name, address, and telephone number or any person who may be designated as
a responsible third party: Ralph Mason and/or his affiliated entities may be designated as
responsible third parties in this action. [Contact information is known to Plaintiff]. Other and
additional persons may also be designated as responsible third parties herein.

Respectfully Submitted,

/s/ Lawrence E. Ackels. Jr.

LAWRENCE E. ACKELS, JR.
State Bar No. 00830100
ACKELS & ACKELS, L.L.P.
3030 LBJ Freeway, Suite 1550
Dallas, Texas 75234
Tel 214-267-8600
Fax 214-267-8605
Email: Larry@ackels1aw.com
Attorney for Defendant Kathy
CiaNett

CERTIFICATE OF SERVICE

The undersigned attorney certifies that he has served or will serve a copy of the foregoing

instrument upon attorneys of record for all other parties in this action in accordance with the

Rules of Procedure, this 27" day of July, 2018.

/s/ Lawrence E. Ackels_, Jr.

LAWRENCE E. ACKELS,
JR.

Rule 194 Dis cI Page 3

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