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Litigate!

Stay safe, Rob Kwok
Kwok Daniel LLP
Address: 9805 Katy Freeway Ste 850
Email: 1P@kwoklaw.com
Web: www.kwoklaw.com

From Rob Kwok:

In my 28+ years of law practice this explosion hits closest to home. Literally, 5 miles from home. We woke up to the sonic boom that set off our house alarm on January 24, 2020 at 4:23am. My phone started ringing around 7am and hasn't stopped ringing since. Many close friends live near the Watson facility. Many of my kids' classmates were affected. In fact, our lead Plaintiffs have 4 kids in school with our 4 kids. We're so glad to serve their family during this explosion that destroyed their home. A bit about me, I'm board certified in personal injury trial law, and have represented people my entire career. I am AV rated, peer review rated and judicial review rated - the highest possible rating. I filed the first wrongful death case in the tragic 2005 BP Amaco Explosion that killed 23 workers. We had incredible results for all of our clients. I actually presented my last BP case to a Galveston County jury - that case settled on the first night of trial, after jury selection. I also won the record setting jury verdict in the Channelview Explosion in 2014, that killed 1 worker and injured others. The 5-week jury trial record verdict landed us in the Texas Lawyers Hall of Fame. When not working Explosion cases, my firm is one of the highest volume personal injury trial law firms in Houston. I'm so grateful for our world-class team of 50+ talented professionals. Update: we have been adding team members in the past year to staff up for the Watson litigation and have tripled our mass torts division. We are grateful for our explosive growth! Please know that I take each one of your cases personally. I'm deeply honored to represent so many affected families in this tragic Explosion. In December, I successfully concluded my appointment as co-chair of the January 24 Claimants Committee, and now as a Plaintiff's Steering Committee member in state court I am "All In" on the Watson case. Together we are rebuilding your neighborhood, one home at a time. Best, Rob Kwok - rkwok@kwoklaw.com
In the past few weeks we have filed notices of remand in all our state court cases. In cases like this with numerous claimants, any party may move for a multi-district litigation (MDL) proceeding and request an MDL judge for pre-trial matters. This judge may be a retired judge or a sitting judge. Generally, anyone who moves for MDL at any time is granted the MDL. So in bankruptcy court we agreed to a joint motion to transfer to MDL and even included a few potential judges. Usually, the MDL panel ignores suggestions and is certainly free to ignore our suggestions, but all this was negotiated for our return to state court. The Defendants have this week filed the motion to transfer to MDL, we hope to get our MDL judge soon. Once the MDL panel assigns an MDL judge we will present our Case Mangement Order (CMO). Our team is negotiating the CMO which contains various deadlines and trial settings. We hope to get our bellwether cases to trial in 18-24 months, covid permitting. Our team will also actively participate on the Plaintiffs Steering Committee and litigate this important case. Our team continues to serve on the bankruptcy oversight committee with regular calls. Meanwhile, our experts are working on inspecting "artifacts" from the explosion to further prove the liability theories in our case. Due to our hard work this past year, a multi-day inspection involving our experts was done (with virtual streaming), and key evidence was bagged and tagged for inspection. All material evidence has been properly preserved in chain of custody and will be presented at trial. Our Watson office team continues to work well on your first party cases against your homeowners insurance carriers. We have a large group of 1P lawsuits in active litigation to combat low offers. If you believe you need to file a 1P lawsuit, please e-mail attorney Ranny at rsawaf@kwoklaw.com. Finally, we are working on the Plaintiff Fact Sheet (PFS), and we will eventually need your input to complete. Once the content is negotiated, our Watson discovery team has automated your responses to document your damages. Remember every dollar of your damages must be proven at trial for any recovery. If you have questions proving your property damages e-mail attorney Marcos at mcardenas @kwoklaw.com; for proving your injury damages e-mail attorney Adam at advorak@kwoklaw.com. Both teams have been working hard getting your evidence in order to present to a jury, please cooperate fully with them and their staff! We had a great turnout for our last virtual town hall and will set another one once we have an MDL judge appointed. Until then, stay safe. Best, Rob Reminders for our clients: Our legal team has been actively reaching out to each one of you personally, so please cooperate with us to prove up your cases. All losses, property, injury, etc. must be properly documented for Court. As always, e-mail questions and documents/photos 24/7 to watsondocs@kwoklaw.com.
We have many clients experiencing continuing ringing in the ears and hearing damage/loss. You need to document your hearing damage for your case. Please contact our medical team at advorak@kwoklaw.com.
We also have many clients experiencing continuing explosion related thoughts/feelings, affecting every day life. This includes unwanted upsetting memories, nightmares, flashbacks, emotional/physical distress after exposure to traumatic reminders, irritability, anger/aggression, risky or destructive behavior, hypervigilance, jumpy on edge, difficulty concentrating, difficulty sleeping etc. If this is you, please contact our medical team at advorak@kwoklaw.com. If you are uninsured, contact Memorial Area Ministries. MAM approved a repair claim for one of our uninsured clients with a severely damaged home and work is near completion. We were glad to pack out and move out our clients into an apartment while their home is being restored safe to live. Thank you Texas Vanguard Construction and others who donated their time. If you are not happy with your insurance offer, e-mail us at 1P@kwoklaw.com. Our 1P Team has been getting amazing results for our clients. Rebuilding is already underway in many client's homes. If you live on Stanford Court, Lybert, Rockcrest, Valleywood, Sunwood, Bell Gardens, Talina Way, Richmond Hill, Gladewood, Fieldstone, Sommerville, Bridgeland, Eagle Glenn, Cottage Field, Terrace Manor, or near those streets, your home may have structural damage that must be accounted for in your insurance settlement. You may be entitled to policy limits for your home like many of your neighbors - giving you the freedom to repair or rebuild - your choice! Your home is your greatest asset and place of rest, please trust us and allow us to maximize your insurance claim.
During this stay at home order, reach us by phone at 713.773.3380 or email at 1P@kwoklaw.com. Expect even more client group texts, e-mail, zoom and social media contacts. We had a great turnout for our last virtual town hall and will set another one once we have an MDL judge appointed. As usual, find real-time updates here at www.watsongrindingexplosion.com.

• The SBA is offering low interest loans. Terms are up to 30 years and rates as low as 1.5% for property damage victims from the Watson explosion. If you were uninsured or underinsured you now have the option to take a loan and rebuild. Call Diana for help applying: 713.773.3380.

Know your legal rights.

Lawsuit filed - 3 TROs Granted

Rob Kwok has already filed and won 3 TRO's in this case. See Temporary Restraining Order (TRO) - here See Houston Chronicle Article - here See ABC news - here See Fox 26 news story - here See KPRC Ch2 news story - here See ABC Watson/Kwok news story - here See AP news story - here See KPRC Ch2 walk through news story - here See KPRC Ch2 TRO vs. City of Houston news story - here See 1st TRO vs. City - here See 2nd TRO vs. City - here See Houston Chronicle Article - here See Agreed 5-8-20 Lift Stay Order - here See 06.21.20 Houston Chronicle Article - here See 07.03.20 Houston Chronicle Article - here See 12.30.20 Houston Chronicle Article - here

Speak with a lawyer for free:

713.773.3380

E-mail us:

1P@kwoklaw.com

Thank you!

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Call or e-mail us:

9805 Katy Fwy Ste 850
713.773.3380
1P@kwoklaw.com
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