Defendants’ Designation of Experts

H610-2238 / BDF No. 9487273 Zitoun

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

JORDAN ZITOUN and 

ERIN ZITOUN,

§

§

§

Plaintiffs, §

§

v. §

§

Civil Action No. 3:22-cv-2192-N 

ALLY BANK and CENLAR FSB, 

as Loan Servicer,

§

§

§

Defendants. §

DEFENDANT’S EXPERT WITNESS DESIGNATIONS

Pursuant to the Court’s Scheduling Order [Doc. 5] and Federal Rule of Civil Procedure 

26(a)(2)(B), Defendants Ally Bank and Cenlar FSB (collectively “Defendants”) hereby file this 

Designation of Testifying Experts as follows:

1. The following experts are expected to give testimony, under Federal Rule of Civil 

Evidence 701-705, at the time of trial:

Shelley L. Hopkins 

Hopkins Law, PLLC

Barrett Daffin Frappier Turner & Engel, LLP – Of Counsel

3 Lakeway Centre Ct., Suite 110

Austin, Texas 78734

Tel: (512) 600-4320

Shelley L. Hopkins has been licensed to practice law in the State of Texas since 2002 

(licensed in Arkansasin 2001). She islicensed in allstate courtsin the State of Texas and admitted 

into the United States District Court for the Southern District of Texas, United States District

Court for the Northern District of Texas, United States District Court for the Western District of 

Texas, United States District Court for the Eastern District of Texas, United States District Court

for the

Case 3:22-cv-02192-N-BT Document 9 Filed 07/20/23 Page 1 of 4 PageID 154
Defendant’s Designation of Experts

H610-2238 / BDF No. 9487273 Zitoun

Page 2 of 4

Eastern and Western Districts of Arkansas, the State of Arkansas, the Fifth Circuit, the Second 

Circuit, and the United States Supreme Court.

Ms. Hopkins has practiced extensively in litigation in Texas since 2002. She is familiar 

with attorneys’ fees charged in cases such as this, in the Northern District of Texas, as well as the 

counties in the state courts of the Northern District of Texas. Ms. Hopkins is expected to testify 

regarding the necessity of obtaining counsel in this matter and the reasonableness and necessity of 

attorneys’ fees incurred in the prosecution and defense of this cause of action. Further, she is 

expected to testify as to the reasonableness and necessity, or lack thereof, of any other attorneys’ 

fees asserted by any other party in this cause. She is also expected to testify in regard to the possible 

attorneys’ fees that might be incurred in the event of appeal to the Fifth Court of Appeals, or further 

appeal to the United States Supreme Court.

Ryan Bourgeois

Barrett Daffin Frappier Turner & Engel, LLP

4004 Belt Line Road, Ste. 100

Addison, Texas 75001

(972) 341-0916

Mr. Bourgeois is expected to testify regarding the default servicing of the underlying loan 

as well as foreclosure actions undertaken in protecting the mortgagee’s interest in the property.

Any and all documents that the experts have reviewed, or will be reviewed, have been 

produced, or will be produced, and/or are available for inspection and copying in accordance with 

the Federal Rules of Civil Procedure, subject to attorney/client privilege, or such documents are 

matter of public record.

2. Written Reports.

a. No reports have been prepared at this time. Defendants will supplement as 

reports become available.

b. Reports will be supplemented as additional information is revealed during 

Case 3:22-cv-02192-N-BT Document 9 Filed 07/20/23 Page 2 of 4 PageID 155
Defendant’s Designation of Experts

H610-2238 / BDF No. 9487273 Zitoun

Page 3 of 4

discovery and Defendants reserve the right to supplement as discovery has 

not been completed in this case.

3. Defendants reserve the right to designate, at or before trial, any expert(s) that have 

been or may be designated by any other party to this lawsuit.

4. Defendants reserve the right to call and/or designate other expert witnesses as 

rebuttal witnesses, the need for which and identity of which cannot be reasonably anticipated at 

this time.

5. Defendants and its experts reserve the right to utilize all or part of the literature 

and/or documents produced, identified or relied upon by any other party’s expert witnesses. 

Defendants and its experts reserve the right to utilize the deposition testimony of any other party’s

expert witnesses, to the extent such individuals created documents, as fact/expert witnesses, and 

Defendants and their designated experts may utilize all such facts, findings, opinions and 

recommendations contained within those individual records. Although Defendants do not vouch 

for all or part of the deposition testimony which may be given by any other party, any of any other 

party’s designated expert witnesses, and/or adverse witnesses, Defendants reserve the right to 

utilize the deposition and oral testimony of any expert witnesses designated by any other party. 

Defendants and their expertsreserve the right to utilize all or part of the literature and/or documents 

produced, identified or relied upon by other experts designated by any party hereto.

6. In addition to the previous individual, Defendants reserve the right to designate any 

person, or persons, with knowledge of relevant facts that may be identified by any party to this 

cause of action as an expert witness, or who may be designated as an expert witness by any party 

to this cause of action in response to discovery propounded to that party by any other party in this 

case.

Dated: July 20, 2023.

Case 3:22-cv-02192-N-BT Document 9 Filed 07/20/23 Page 3 of 4 PageID 156
Defendant’s Designation of Experts

H610-2238 / BDF No. 9487273 Zitoun

Page 4 of 4

Respectfully submitted,

By: /s/ Shelley L. Hopkins

Shelley L. Hopkins 

State Bar No. 24036497 

HOPKINS LAW, PLLC

3 Lakeway Centre Ct., Suite 110

Austin, Texas 78734

(512) 600-4320

BARRETT DAFFIN FRAPPIER

TURNER & ENGEL, LLP - Of Counsel 

ShelleyH@bdfgroup.com

shelley@hopkinslawtexas.com

Robert D. Forster, II 

State Bar No. 24048470

BARRETT DAFFIN FRAPPIER 

TURNER & ENGEL, LLP

4004 Belt Line Road, Ste. 100

Addison, Texas 75001

(972) 386-5040

RobertFO@bdfgroup.com

ATTORNEYS FOR DEFENDANTS

CERTIFICATE OF SERVICE

I hereby certify that on this 20th day of July 2023, I electronically filed the foregoing with

the Clerk of the Court using the CM/ECF filing system, and will send a true and correct copy to the 

following:

Jordan Zitoun

331 S Larkin Rd.

Sunnyvale, Texas 75182

Erin Zitoun

331 S Larkin Rd.

Sunnyvale, Texas 75182

PRO SE PLAINTIFFS

/s/ Shelley L. Hopkins

Shelley L. Hopkins

Case 3:22-cv-02192-N-BT Document 9 Filed 07/20/23 Page 4 of 4 PageID 157