Attorney work product
Sample · version 2 · 9 files
Halvorsen v. Brightline Logistics, LLC
Court261st District Court, Travis County
Case no.D-1-GN-26-001873
PostureAnswer on file. Discovery not yet opened. Mediation proposed.
Rear-end collision on FM 1431 involving a Brightline tractor-trailer. Liability is contested on headlights; damages already exceed the disclosed policy limits. The driver's own log places him past the hours-of-service ceiling on the day.
Parties
- Maren HalvorsenPlaintiffReyes Law
- Brightline Logistics, LLCDefendantWhitcombe & Sato LLP
- Daniel OseiDefendant driverWhitcombe & Sato LLP
- Meridian MutualDefendant's insurerAdjuster K. Boyd
Key dates
- 2026-02-14Collision, FM 1431 at Anderson Mill Rd, 21:40
- 2026-03-02Demand letter to Meridian Mutual
- 2026-04-09Original petition filed
- 2026-05-01Defendants' answer served
- 2026-08-22Reply to mediation proposal due
- 2028-02-14Limitations period ends (two years)
Issues, ranked
- 1
Specials already exceed the disclosed policy limits
criticalMedical specials stand at $184,300 against a $250,000 liability limit, before future care. An excess exposure letter to the carrier is timely now.
- 2
Driver was 90 minutes past the hours-of-service ceiling
elevatedThe ELD summary shows 12.5 hours on duty at the time of the collision. Preserve the raw log before the 6-month retention window closes.
- 3
Six-week gap in treatment after the initial ER visit
elevatedNo records between 20 Feb and 3 Apr. The defense will argue the cervical injury resolved; the client says she was uninsured in that window.
- 4
Comparative fault: headlights alleged off
moderateThe answer pleads the Honda's headlights were off. The crash report notes lighting as 'dark, lighted' and records no headlight defect.
Facts, with sources
The Brightline unit struck the Halvorsen vehicle from behind at 21:40.
TxDOT crash report CR-3.pdf, p. 1 · “Unit 1 struck Unit 2 in the rear”
Meridian Mutual disclosed a single liability limit of $250,000.
Meridian limits letter.pdf, p. 1 · “bodily injury liability limit of $250,000 per occurrence”
Osei had been on duty 12 hours 30 minutes when the collision occurred.
ELD summary 2026-02-14.xlsx, p. 1 · “On-duty total 12:30”
Medical specials billed to date total $184,300.
Specials ledger.xlsx, p. 2 · “TOTAL BILLED 184,300.00”
Next actions
- Send ELD and dashcam preservation letter to BrightlineJ. Reyes
- Excess exposure letter to Meridian MutualJ. Reyes
- Request Dr. Alvarez records for 20 Feb to 3 Apr gapParalegal
- Calendar mediation reply, 22 AugParalegal