Multiple medical billing affidavits have been filed in a suit accusing a man of not maintaining his roping arena, which allegedly caused the plaintiff’s horse to slip.
As previously reported, Denise Morgan filed suit against Beaumont local John Shackelford on Nov. 9, 2011, in Jefferson County District Court Jr., claiming it was the roping arena owner’s fault that her horse slipped.
Court records show that on March 28 a notice of filing of records and affidavits was filed, showing that following documents will be offered in evidence at trial:
- Affidavit of billing records of Radiology Associates;
- Affidavit of billing records of Jefferson Emergency Medical Associates;
- And affidavit of billing records off Anesthesia Associates.
Court records further show Shackelford answered the suit on Jan. 30, 2012, asserting Morgan failed to exercise a degree of care that a person of ordinary care would have.
Shackelford has also filed a demand for a jury trial.
According to the lawsuit, on Nov. 14, 2009, Morgan was exercising her horse at Shackelford’s roping arena when the horse suddenly slipped and fell while making a cut.
Morgan alleges Shackelford failed to disc and plow the entire arena, leaving a portion with grass that would be slippery to a horse.
Because of the incident, Morgan, a licensed barber, claims that she broke her wrist and can no longer hold scissors to cut hair.
Morgan also claims that her face and mouth have been disfigured because her front teeth bit through her upper lip in the fall.
She is suing for her alleged past and future medical expenses, mental anguish, pain, impairment, disfigurement and lost wages, plus all court costs.
Beaumont attorney Thomas Moses represents her.
Houston attorney Glenn Fahl represents Shackelford.
Judge Donald Floyd, 172nd District Court, is assigned to the case.
Case No. E191-319