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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

HARMONY HAUS WESTLAKE, 

L.L.C., LING ZHOU, AND 

FENGLIN DU

Plaintiffs and Counter-Defendant,

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v.

PARKSTONE PROPERTY 

OWNERS ASSOCIATION, INC.

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CIVIL ACTION NO. 1:20-CV-486-XR

Defendant and Counter-Plaintiff. §

PARKSTONE’S TESTIFYING EXPERT DESIGNATIONS

Pursuant to the Court’s Scheduling Order, the Parkstone Property Owners 

Association, Inc. (Defendant and Counter-Plaintiff, hereafter, Parkstone), 

respectfully files the following testifying expert designations: 

A. ATTORNEYS’ FEES

Eric J. Hansum

Niemann & Heyer, LLP

1122 Colorado Street

Austin, Texas 78701

Direct Telephone: (512) 481-9292

Fax: (512) 474-0717

erichansum@niemannlaw.com

B. OTHER NON-RETAINED EXPERTS

Mitch Krauss (VP of Community Management) and/or 

Alice English (Association Manager)

Goodwin & Company 

11149 Research Blvd #100

Austin, TX 78759

Contact numbers: (512) 502-7541, (512) 502-7518, and (512) 852-7905

mitch.krauss@goodwintx.com and alice.english@goodwintx.com
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Goodwin & Company (Goodwin) is the property management company for 

Parkstone. Mr. Krauss and/or Ms. English, employees of Goodwin, are not 

providing expert reports because they are not retained or specifically employed 

experts and do not regularly give expert testimony. 

Mr. Krauss and/or Ms. English are expected to testify that the fining 

structure and escalating fines adopted by Parkstone in early 2020 were 

necessary because of an increase in the number of violations of the street parking 

restrictions in the Declarations governing the Parkstone neighborhood, that this 

increase included many residents other than the residents of Harmony Haus, 

that the increase began after Harmony Haus residents started consistently 

violating the parking restrictions, and that notices of violations and fines were 

even-handedly issued to all violators, whether or not associated with Harmony 

Haus. They will also testify that an escalating fine structure like that adopted by 

Parkstone is a common and effective means of dealing with increased violations 

of private deed restrictions generally. They will also testify that the Board of 

Parkstone never evidenced any intent to discriminate against or retaliate against

Harmony Haus in the creation or application of the fining structure. Their 

testimony will be based on their experience managing a large number of 

homeowners’ associations and/or their specific experience with Parkstone and

Harmony Haus as well as the underlying Declaration and the policy itself. 

Parkstone reserves the right to call any experts designated by Plaintiffs 

and use their records when helpful. Parkstone also reserves the right to 
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supplement this designation of testifying expert witnesses in accordance with 

the Federal Rules of Civil Procedure. 

Respectfully submitted,

NIEMANN & HEYER, LLP

Westgate Building, Suite 313

1122 Colorado Street

Austin, Texas 78701

Telephone: (512) 474-6901

Fax: (512) 474-0717

/s/ Eric J. Hansum 

Eric J. Hansum, Of Counsel

Texas State Bar No.: 24027225

erichansum@niemannlaw.com

ATTORNEYS FOR THE 

PARKSTONE PROPERTY

OWNERS ASSOCIATION, INC.

CERTIFICATE OF SERVICE

I certify that on October 5, 2020, I electronically filed the foregoing with 

the clerk of the court using the CM/ECF system, which will send notification of 

such filing to all counsel of record.

/s/ Eric J. Hansum

Eric J. Hansum