IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS 

WICHITA FALLS DIVISION

____________________________________

)

JACKI PICK, )

)

Plaintiff, ) Civil Action No. 7:22-cv-00112-O

)

v. )

)

BRADLEY JAY RAFFENSPERGER, ) JURY TRIAL DEMANDED

 )

Defendant. )

____________________________________) 

PLAINTIFF JACKI PICK’S DESIGNATION OF EXPERT AND 

DISCLOSURE OF EXPERT TESTIMONY

Plaintiff, by and through undersigned counsel, hereby designates her expert witness in

accordance with the Federal Rules of Civil Procedure and the Scheduling Order of this Court (Dkt. 

No. 24) and states that the following person may be called to provide expert testimony or present 

evidence at trial on behalf of Plaintiff. 

RETAINED EXPERT

Marlena Alexia Haddad

550 Okeechobee Blvd., Apt. 812

West Palm Beach, FL 33401

Phone: (203) 910-8303

Ms. Haddad may be called to testify on the following topics: 1) why and how the 

defamatory statements at issue and their repetition in and by the media would affect Plaintiff’s 

prospective opportunities of seeking political appointments within the executive branch of the 

federal government; 2) policies and procedures involved in selecting political appointments within 

the executive branch of the federal government; and 3) any other subjects or opinions referenced 

Case 7:22-cv-00112-O Document 27 Filed 07/17/23 Page 1 of 3 PageID 339
PLAINTIFF’S EXPERT DESIGNATION AND DISCLOSURE 2

in her report or in subsequent deposition testimony, including reasonable inferences arising 

therein. Any necessary report, curriculum vitae, and testifying history will be produced to

Defendant.

Plaintiff reserves the right to call any expert designated by Defendant or called by 

Defendant at hearing or trial. Plaintiff further reserves the right to solicit testimony from any 

person identified by Defendant as a fact witness in this case, which may require such witness to 

rely upon their specialized knowledge, training, experience, education, or expertise in a particular 

filed or which may be considered “opinion” testimony. Plaintiff reserves the right to supplement 

this designation. Plaintiff also reserves the right to designate additional experts and Plaintiff’s

expert(s) reserve(s) the right to supplement, amend, or modify any of the opinions expressed in 

reports as additional information may become available through discovery and at trial.

Dated: July 17, 2023 Respectfully Submitted,

DHILLON LAW GROUP, INC.

 /s/ Matthew Sarelson

Matthew Seth Sarelson, Esq.

msarelson@dhillonlaw.com

Christopher Halbohn, Esq. (SBN 24109967)

chalbohn@dhillonlaw.com

Dhillon Law Group Inc.

1601 Forum Place, Suite 403

West Palm Beach, FL 33401

T 305.773.1952

Counsel for Plaintiff

William G. Whitehill (SBN 21356550)

bwhitehill@condontobin.com

Condon Tobin Sladek Thornton Nerenberg, PLLC

8080 Park Lane, Suite 700

Dallas, Texas 75231

Case 7:22-cv-00112-O Document 27 Filed 07/17/23 Page 2 of 3 PageID 340
PLAINTIFF’S EXPERT DESIGNATION AND DISCLOSURE 3

T 214.265.3862 | F 214.691.6311

Local Counsel for Plaintiff

CERTIFICATE OF SERVICE

I hereby certify that on the 17th day of July 2023, I electronically transmitted the attached 

document using the CM/ECF System for filing.

/s/ Matthew Sarelson

Dhillon Law Group Inc.

1601 Forum Place, Suite 403

West Palm Beach, FL 33401

T 305.773.1952

msarelson@dhillonlaw.com

Case 7:22-cv-00112-O Document 27 Filed 07/17/23 Page 3 of 3 PageID 341