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IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

TEXARKANA DIVISION 

JERRAL W. JONES, 

Plaintiff, 

vs. 

ALEXANDRA DAVIS and CYNTHIA 

DAVIS f/k/a CYNTHIA DAVIS-SPENCER, 

Defendants.

CIVIL ACTION No. 5:23-cv-00032-RWS 

JOINT REPORT ON DEFENDANTS’ OBJECTIONS TO PLAINTIFF’S 

DEMONSTRATIVE GRAPHICS AND TRIAL EXHIBITS 

Jerral W. Jones (“Plaintiff” or “Jones”) and Cynthia Davis and Alexandra Davis 

(“Defendants”) report to the Court regarding the Plaintiff’s demonstrative graphics and trial 

exhibits for the first day of trial as follows: 

I. BACKGROUND 

Pursuant to the Court’s Order, Plaintiff timely submitted Graphics to opposing counsel 

and then participated in a face-to-face meet and confer regarding them. Agreement was reached 

on all but three graphics. Those are numbered 108, 110 and 111, which are attached hereto. 

II. DEMONSTRATIVE GRAPHICS

On graphic 108 Defendants objection is to the reference to Michael Marcus under the 

Aug. 14 date as “Alex’s” lawyer because they say that Marcus was only representing Cynthia. 

Plaintiff argues that the referenced document speaks for itself and shows that Marcus was 

representing Cynthia both individually and in her representative capacity but that, in any event, 

the evidence will be before the jury as will the parties’ contentions about it significance. 

On Graphic 110 Defendants claim that the entire graphic references matters that the 

Court has limined out of the case. Plaintiff disagrees. 

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On Graphic 112 Defendants object to the term “Disaffirm Zone” in the red box. Plaintiff 

says that in life as in football there is a zone where you must score and the evidence will show 

that Alex Davis did not cross the goal line (1 year). Plaintiff does, however, apologize for mixing 

his metaphors. 

III. PLAINTIFF’S TRIAL EXHIBITS 

Defendants served their objections to Plaintiff’s previously served list of exhibits he 

plans to offer on Monday (July 22). Some limited agreement was reached at the face to face 

meet and confer and Defendants stated their preference to make objections before the jury at the 

time the Plaintiff’s exhibits are offered 

IV. DEPOSITIONS EXCERPTS FOR STEVE WATSON 

Defendants did not raise any objection to Plaintiff’s deposition excerpts of Steve Watson. 

V. CONCLUSION 

The parties ask the Court to accept these agreements and resolve their remaining disputes 

and for such other relief as to which they may be entitled. 

 

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FOLSOM ADR PLLC 

/s/ David Folsom 

David Folsom 

State Bar No. 07210800 

david@folsomadr.com 

6002-B Summerfield Dr. 

Texarkana, TX 75503 

(903) 277-7303 

JACKSON WALKER LLP 

/s/Charles L. Babcock 

Charles L. Babcock 

State Bar No. 01479500 

cbabcock@jw.com 

Nancy W. Hamilton 

State Bar No. 11587925 

nhamilton@jw.com 

1401 McKinney Street 

Suite 1900 

Houston, TX 77010 

(713) 752-4210 

(713) 752-4221 - Fax 

David T. Moran 

State Bar No. 14419400 

dmoran@jw.com 

Edwin Buffmire 

State Bar No. 24078283 

ebuffmire@jw.com 

Cody Martinez 

State Bar No. 24102146 

cmartinez@jw.com 

2323 Ross Avenue 

Suite 600 

Dallas, TX 75201 

(214) 953-6000 

(214) 953-5822 – Fax 

ATTORNEYS FOR PLAINTIFF JERRAL W. JONES

 

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CERTIFICATE OF SERVICE

On July 21, 2024, I electronically submitted the foregoing document with the clerk of the 

court of the U.S. District Court, Eastern District of Texas, using the electronic case filing system 

of the court. I hereby certify that I will serve all counsel and/or pro se parties of record 

electronically or by another manner authorized by Federal Rule of Civil Procedure 5(b)(2). 

/s/ Edwin Buffmire 

Edwin Buffmire 

CERTIFICATE OF CONFERENCE

I hereby certify that on July 21, 2024, Chip Babcock and Edwin Buffmire, counsel for Mr. 

Jones, conferred in person with Matt Keil , Erin Keil, and Hailee Amox, counsel for Alexandra 

Davis, and Kris Hayes, counsel for Cynthia Davis regarding the objections to Plaintiff’s 

demonstratives, graphics and trial exhibits for the first day of trial, as well as the content of this 

Report. . 

/s/ Edwin Buffmire 

Edwin Buffmire 

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