Status Conference/Case Update

Stay safe, Rob Kwok
Kwok Daniel LLP
Address: 9805 Katy Freeway Ste 850

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/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've added more 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 1,000+ of your family members, friends and neighbors. In December, I successfully concluded my appointment as co-chair of the January 24 Claimants Committee, and now we get to finally litigate your cases in state court. In short - I am "All In" on the Watson explosion case. Together we are rebuilding your neighborhood, one home at a time. Best, Rob Kwok - rkwok@kwoklaw.com
Dear Clients, It was good to be with over 100 of you in our latest virtual town hall meeting. We got a ton of positive feedback, with the crowd favorite being the Q&A session. Your top questions centered around how long it would take for your family to get justice. We know many of you have been patiently waiting for your day in Court. As we discussed in our last town hall meeting, we are aware many of your homes are partially repaired and others still need full repairs. Our first party team continues to work with your insurance companies to approve supplements and repairs. Some first party insurance companies are fighting hard to underpay, even though your homes are close to Watson. The insurance fight is so unnecessary, as most insurance companies have joined the Watson lawsuit to get their money back. As we have discussed many times, your insurance companies generally have a right of subrogation to get reimbursed by the responsible parties what they paid as a result of this explosion. Our On Friday April 9, we again appeared before the Judge and got more clarity on pushing your cases to trial. The Court has instructed us to create 5 trial groups for an early trial setting. While we are working those cases up for trial we will also be working up the liability portion of the case. Remember your case has 2 parts - liability (who did what wrong) and damages (what were your losses due to that wrong). We have identified our potential trial cases and your case manager will contact you to ensure you are able to testify by deposition and at trial, and to fully assess all of your damages - injuries and property. Remember, we must properly document all losses for the Court/jury. Again, under Rule 13 of the Judicial Rules: once a case is certified for trial your case is going to trial. This concept is called mandatory trial on remand - once set, your case will go to a jury trial, no exceptions. If you may have a scheduling conflict this time next year, let us know now please. We may select a different case for mandatory trial on remand. Also this week our experts team from around the country continued their artifact inspection, testing various materials and identifying the cause, origin and ignition source for this massive explosion. We have been getting regular updates from our experts and the inspection is proceeding along well. I will have a full update on their findings in our next virtual town hall meeting - notice coming soon. This week, our legal team will continue drafting/negotiating the case management order (also called master scheduling order - MSO) and our Plaintiff fact sheets. Please cooperate with our Watson team to get your fact sheets completed once available. Our Watson Fact Sheet Team is already contacting you for basic information, please cooperate fully! There will be certain time deadlines to provide your information and documents. Given Rule 13, your case will need to be fully documented before we can certify your case for trial. Continue to send your evidence - documents, photos, estimates, medical records/bills to Watsondocs@kwoklaw.com. This email address automatically places the documents you send into your file on our secure server. Our team of 50 professionals are actively contacting clients, please fully cooperate with us! Please e-mail our mass torts manager, attorney Ranny with any questions about your fact sheet - rsawaf@kwoklaw.com. Our next appearance before Judge Davidson will be in the next 30 days, I'll report back after the hearing. Meanwhile, look for real-time text updates and notice of our upcoming virtual town hall. If you are not getting real-time updates (several a week), please make sure we have your latest contact info, including your cell phone. Group texts in Spanish and Vietnamese available, make sure you are in the right language group by e-mailing your cell phone number and language preference to dbrowne@kwoklaw.com. In the coming weeks we'll be in the neighborhood near the community pool on weekends to meet with you on your fact sheets and get your documents scanned in - look for our red tents. Free Chick-fil-a lunch to those who complete their fact sheets with our team! Stay safe, Rob Kwok 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 attorney Adam 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 attorney Adam 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 in the coming weeks. 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. Contact Diana dbrowne@kwoklaw.com for help applying: 713.773.3380.

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
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