PLAINTIFF’S DESIGNATION OF EXPERT WITNESSES Page 1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

LINDA HUGHES,

 Plaintiff,

vs.

LIBERTY MUTUAL FIRE 

INSURANCE COMPANY,

 Defendant.

CIVIL ACTION NO. 4:22-CV-00723-O

PLAINTIFF’S DESIGNATION OF EXPERT WITNESSES

______________________________________________________________________________

To: Defendant, LIBERTY MUTUAL FIRE INSURANCE COMPANY, by and through its

attorney of record, Aaron L. Mitchell and Lori Murphy, TOLLEFSON BRADLEY MITCHELL &

MELENDI, LLP, 2811 McKinney Ave, Suite 250 West, Dallas, Texas 75204.

Pursuant to Rule 26(a)(2) of the Federal Rules of Civil Procedure and the Scheduling 

Order dated September 8, 2022 (Doc. 7), Plaintiff, Linda Hughes, in the above-styled and 

numbered cause, submits this, her Designation of Expert Witnesses.

Plaintiff hereby designates the following experts who may be called to testify at trial: 

I. LOSS EXPERT

1. Michael Ogden, CGC, HCI, IICRC, CDDC, CDDR, PA

All Disaster Claims, Inc.

3235 Pawnee Pride

San Antonio, Texas 78261

Phone: (210) 300-4404

Mr. Michael Ogden, general contractor and licensed public adjuster for the State 

of Texas, is a retained expert. Mr. Ogden will testify to his factual and/or expert 

knowledge of the extent, nature, and causation of the damages to the Plaintiff’s 

property. His opinions will be based on his own inspection of the subject 

property, photographs of the property, his review of documents and materials, and 

his education, training, and experience as a general contractor and public adjuster. 

Mr. Ogden has factual and/or expert knowledge as to the proper means, method 

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PLAINTIFF’S DESIGNATION OF EXPERT WITNESSES Page 2

and costs of repairing, replacing or correcting the damages caused to Plaintiff’s 

property as well as general commercial construction practices and procedures and 

cost estimation. Mr. Ogden will also testify to the particulars of the adjusting 

process and will testify for Plaintiff that his estimate is valid and proper and 

should be paid by Defendant. A copy of Mr. Ogden’s report is attached hereto as 

Exhibit “A” and his current curriculum vitae is attached hereto as Exhibit “B”. 

Mr. Ogden’s testimony history is attached as Exhibit “C” and invoice attached as

Exhibit “D”.

II. ATTORNEYS FEES EXPERT

2. Shaun Hodge 

Hodge Law Firm, PLLC

1301 Market Street

Galveston, Texas 77550

Phone: (409) 762-5000

Mr. Shaun Hodge is an attorney licensed to practice in the State of Texas, and he 

will testify regarding the reasonable and necessary attorney’s fees and expenses 

and time expended in handling and prosecuting this case. Mr. Hodge will testify 

as to the nature and extent of the attorney’s services performed in this case and as 

to the nature and degree of skill and knowledge required to render the legal 

services. Mr. Hodge will also testify as to the reasonableness of the hourly rate

charged for legal services and as to the reasonable hourly rate charged by other 

attorneys in the area for same or similar work. Mr. Hodge will also testify as to 

his credentials, resume and experience in the legal profession and his experience 

in handling similar legal matters and issues. A copy of Mr. Hodge’s current 

curriculum vitae is attached hereto as Exhibit “E”.

Plaintiff, Linda Hughes, reserves the right to supplement and/or amend these 

responses in accordance with the Federal Rules of Civil Procedure and/or Scheduling 

Order entered in this case. Plaintiff further reserves the right to withdraw the designation 

of any expert witness and to affirm that such previously designated expert will not be 

called as an expert witness at trial. Plaintiff also reserves the right to cross examine, elicit 

testimony and opinions, and/or call as a witness, live or by deposition, any expert 

witnesses designated by the Defendant. Plaintiff does not affirm or attest to the 

qualifications of such experts to render any particular opinion or the accuracy or veracity 

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of any opinion expressed by Defendant’s expert witnesses. Plaintiff reserves the right to 

seek to exclude any such experts designated by Defendant from testifying at trial and/or 

the right to object to the proffer of any opinion by such experts designated by Defendant. 

Finally, Plaintiff reserves the right to designate and to call expert witnesses to provide 

rebuttal testimony, the exact nature of which cannot currently be anticipated. Plaintiff

will supplement in accordance with the Federal Rules of Civil Procedure.

Respectfully submitted, 

/s/ Racchel D. Cabrera

Shaun W. Hodge 

State Bar No. 24052995

shodge@hodgefirm.com

Racchel D. Cabrera 

State Bar No. 24109093

rcabrera@hodgefirm.com

The Hodge Law Firm, PLLC 

The Historic Runge House 

1301 Market Street 

Galveston, Texas 77550 

Telephone: (409) 762-5000 

Facsimile: (409) 763-2300 

ATTORNEYS FOR PLAINTIFF

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PLAINTIFF’S DESIGNATION OF EXPERT WITNESSES Page 4

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing has been served in 

compliance with the Federal Rules of Civil Procedure on the 23rd day of September, 2022, to: 

Aaron L. Mitchell 

State Bar No. 14205590 

aaronm@tbmmlaw.com 

Lori Murphy 

State Bar No. 14701744 

lorim@tbmmlaw.com 

TOLLEFSON BRADLEY MITCHELL & MELENDI, LLP 

2811 McKinney Avenue, Suite 250 West 

Dallas, Texas 75204 

Telephone: 214-665-0100 

Facsimile: 214-665-0199 

ATTORNEYS FOR DEFENDANT

/s/ Racchel D. Cabrera

Racchel D. Cabrera

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