IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF ALABAMA, NORTHERN DIVISION

WILLIAM D. BOWDEN, )

)

Plaintiff, )

)

v. ) Civil Action No.: 2:06-cv-665

)

MISSION PETROLEUM CARRIERS, )

ANTONIO MARTINEZ NAVARRO )

)

Defendants. )

DEFENDANTS’ OBJECTIONS TO PLAINTIFF’S

EXHIBIT LIST

Comes now the Defendants, Mission Petroleum Carriers, and Antonio M. Navarro, and

pursuant to the Federal Rules of Civil Procedure and the scheduling order entered in this case,

makes the following objections to Plaintiff’s exhibit list.

1. Exhibit 1, Alabama Uniform Traffic Accident Report. Defendants object to this

exhibit as being inadmissible hearsay. 

2. Defendants object to Exhibit 7, designated as the Case Summary Form signed

by Providence Property and Casualty as being inadmissible hearsay.

3. Defendants object to Exhibit 32, photographs taken by Southeast Pallet and Box

and/or their employees and/or representatives of the accident scene and/or vehicles involved in

this collision as documents not previously produced. To the extent that these documents are

produced to the Defendants, this objection may be withdrawn.

4. Defendants object to Exhibits 36-44 to the extent not proven reasonable,

customary, necessary, and related to the accident made the basis of this suit.

5. Defendants object to Plaintiff Exhibit 6, to the extent that the medical treatment

evidenced therein is not proven related to the accident made the basis of this suit and the

charges are not shown to be customary. 

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6. Defendants object to Exhibits 13-23, as being unrelated to the claims made the

basis of this suit and damages sought by Plaintiff. 

7. Defendants object to Plaintiff’s exhibit 34 to the extent that the benefits shown

therein are not proven to be customary, reasonable and related to the accident made the basis

of this suit. 

8. Defendants object to Plaintiff’s designated exhibits 45-46, all exhibits, documents

mentioned and/or referred to in depositions taken in this case to the extent that these potential

exhibits are in any way inadmissible, immaterial or irrelevant to the claims made in this suit.

9. Defendants object to Plaintiff’s designated exhibit 47, any documents, photos,

and/or information received by the Plaintiff and produced in response to a non-party subpoena

to the extent that such information is irrelevant, immaterial and otherwise inadmissible.

10. Defendants object to Plaintiff’s designated exhibit 48, any documents, photos

and/or information received by the Plaintiff and produced in response to a non-party subpoena

to Southeast Pallet and Box and/or Crawford and Company to the extent that such information

is irrelevant, immaterial and otherwise inadmissible.

_/s/Vincent A. Noletto, Jr.______________

VINCENT A. NOLETTO, JR. (NOL008)

CAROLINE T. PRYOR (PRY005)

Attorneys for Defendants

OF COUNSEL:

CARR ALLISON

P.O. Box 1126

Daphne, AL 36526

251-626-9340

ctp@carrallison.com

Case 2:06-cv-00665-WHA-WC Document 41 Filed 04/19/2007 Page 2 of 3
CERTIFICATE OF SERVICE

I hereby certify that I have on this 19th of April, 2007, served a copy of the foregoing

pleading upon all counsel of record via the Court’s electronic filing system.

James Bodin

McPhillips, Shinbaum & Gill, L.L.P.

Post Office Box 64

Montgomery, Alabama 36101-0064

_/s/Vincent A. Noletto, Jr.______________

OF COUNSEL

Case 2:06-cv-00665-WHA-WC Document 41 Filed 04/19/2007 Page 3 of 3