Defendant’s Designation of Experts Page 1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

NATHANIEL KING § 

 § 

 Plaintiff, § 

 § 

v. § CIVIL ACTION NO. 4:22-CV-929-P 

 § 

 § 

DFW INTERNATIONAL AIRPORT § 

BOARD, § 

 Defendant. § 

DEFENDANT’S DESIGNATION OF EXPERTS

TO: Nathaniel King, Plaintiff, by and through his attorney of record, Wes Dauphinot, Law 

Offices of Wes Dauphinot, P.C., 900 West Abram, Arlington, Texas 76103. 

Pursuant to Federal Rule of Civil Procedure 26(a), Defendant hereby designates the 

following expert in this lawsuit: 

1. CAROLINE C. HARRISON, PHAM HARRISON LLP, 505 Pecan Street, Suite 200, 

Fort Worth, Texas 76102, telephone number (817) 632-6300. 

Caroline C. Harrison is Board Certified in Labor and Employment Law. Ms. 

Harrison graduated from Texas Wesleyan University School of Law in 2004, and has 

been licensed in the State of Texas since 2004. Ms. Harrison practiced law in Fort 

Worth with Cantey Hanger, LLP from 2004 to 2015. On July 1, 2015, Ms. Harrison 

and her partners Lu Pham and David B. Dowell, opened the firm Dowell Pham 

Harrison, LLP, now known as Pham Harrison LLP, in Fort Worth, Texas. Ms. 

Harrison’s practice is focused on labor and employment litigation. 

Ms. Harrison will testify regarding knowledge of the fees, expenses and costs 

incurred in this case, based upon the time records maintained by Pham Harrison LLP, 

and the reasonableness and necessity for the fees, expenses and costs incurred by 

Defendant. Ms. Harrison will also testify for purposes of rebutting any evidence 

offered by Plaintiff related to his claim for attorney’s fees in this lawsuit, if any. 

Defendant believes that Ms. Harrison will testify that she is aware of the time that 

has been expended on Defendant’s behalf by attorneys, legal assistants, and experts, as 

well as costs of litigation; the time requirements for representing Defendant; the 

novelty and difficulty of the issues involved in this litigation; the skills requisite to 

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Defendant’s Designation of Experts Page 2 

perform the legal services necessary on behalf of Defendant; the fees sought; the time 

limitations imposed by the circumstances of this litigation; and the conduct and 

activities in pre-trial and the trial of this case. 

Ms. Harrison has reviewed the existing documents filed by and exchanged by the 

parties and will review any future documents relating to Defendant’s claim for 

attorney’s fees. All such documents will be made available for inspection, at the time 

Defendant is awarded attorneys’ fees, if any. This expert will also review any 

documents produced by Plaintiff in support of his claim for attorney’s fees, if any, 

The curriculum vitae for Ms. Harrison is being produced with this Designation. 

2. At this time, Defendant has not retained or specifically employed any other person to 

provide expert testimony. Any other expert, including responsive or rebuttal experts,

will be designated later pursuant to the Court’s Order or by agreement of the Parties. 

3. All experts designated by Plaintiff.

Defendant reserves the right to seek testimony from any expert designated by 

Plaintiff on any topic for which the expert has been designated. The purpose of seeking 

such testimony is to rebut Plaintiff’s allegations and defenses in this lawsuit, as well as 

to support Defendant’s allegations and requests for relief in this lawsuit. 

Respectfully submitted,

 By: /s/ Caroline C. Harrison 

 Caroline C. Harrison 

 State Bar No. 24046034 

 Charrison@phamharrison.com 

 Spencer M. Mainka 

State Bar No. 24116707 

smainka@phamharrison.com

 PHAM HARRISON, LLP

 505 Pecan Street, Ste. 200 

 Fort Worth, Texas 76102 

 Telephone: (817) 632-6300 

 Facsimile: (817) 632-6313 

ATTORNEYS FOR DEFENDANT

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CERTIFICATE OF SERVICE

This is to certify that a copy of the foregoing instrument has been sent via electronic filing

on the 28th day of February, 2023, to all parties at following address:

 Wes Dauphinot 

 Law Offices of Wes Dauphinot, P.C. 

 900 West Abram 

 Arlington, Texas 76103 

wes@dauphinotlawfirm.com

 Hani F. Kobty 

 Kobty Law Firm

 900 West Abram 

 Arlington, Texas 76103 

hani@kobtylawfirm.com

 /s/ Caroline C. Harrison 

Caroline C. Harrison

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