A recent order from Galveston County regarding the TWIA litigation specifically names the TWIA representatives who will be deposed and the manner in which the depositions will take place. Suffice it to say that it is no easy challenge preparing for these depositions (see attached order). As members of the Plaintiff’s Ike committee, the members of our firm have read and catalogued thousands of TWIA documents, emails, correspondence and forms in preparation for these depositions. We are expecting more as the depositions start.
The order is necessary to avoid overlapping questions and motions filed by the plaintiff and defense attorneys. If there is no set method of noticing, scheduling, and taking of these depositions, there would be thousands of depositions scheduled and, in almost all of them, the same questions would be asked over and over again. In my opinion, the manner in which these depositions have been organized thus requires the Plaintiff attorneys to cooperate with each other and use each other’s strengths to gather the best testimony from each of the TWIA representatives.
The first set of depositions scheduled deal with the issues of the 11.2% that TWIA originally determined was the damage caused by wind. The individuals involved in the calculation of the 11.2% are Dr. Schroeder and Dr. Spelman. How did TWIA arrive at the 11.2% figure? What factors were used by these “experts?” Who directed this type of analysis? These are just some of the questions that will soon be answered. These depositions will assist each and every one of us in the pursuit of a fair and equitable resolution of each case.