On September 21, 2021 a
Motion-Secondary
was filed
involving a dispute between
Gamble, Lesa,
Gamco Properties, Llc,
Gamvest, Lp,
and
Wham Tech, Inc.,
Wham Technologies, Inc.,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
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CAUSE NO. DC-21-14068
GAMCO PROPERTIES, LLC, IN THE DISTRICT COURT
§§§§§§§§§§§
GAMVEST, LP and LESA GAMBLE,
Plaintiffs,
v. DALLAS COUNTY, TEXAS
WHAM TECH, INC. and WHAM
TECHNOLOGIES, INC.,
Defendants. 134TH IUDICIAL DISTRICT
ORDER GRANTING AGREED MOTION FOR CONTINUAN CE AND
ENTRY OF AMENDED AGREED SCHEDULING ORDER
On this day, came to be considered the Agreed Motion for Continuance and Entry of
Amended Agreed Scheduling Order (the “Motion”) filed by the Parties? Having considered the
Motion, the pleadings, and applicable authorities, the Court finds that the Motion should be
GRANTED.
It is therefore ORDERED that the trial date of November 7, 2022 is continued to May 22,
2023.
It is further ORDERED that an Amended Agreed Scheduling Order shall be entered as
follows:
1. The deadline to file amended pleadings asserting new causes of action or affirmative
defenses and to file motions for leave to designate responsible third parties is One
Hundred Thirty (130) Days Before Trial. Pleadings directly responsive to any
timely filed pleadings must be filed by One Hundred (100) Days Before Trial.
2. Fact discovery closes Seventy (70) Days Before Trial.
3. The deadline for any Party seeking affirmative relief to designate expert(s) and/or
provide expert reports is One Hundred Five (105) Days Before Trial.
2
As used herein, the “Parties” shall mean and refer to Plaintiffs Gamco Properties, LLC, Gamvest, LP, and Lesa Gamble
and Defendants Wham Tech, Inc. and Wham Technologies, Inc., collectively.
0_RDER_GRANTING AGREED MOEON FOR'CONTTVUANCEXVD
ENTRY 0F AMENDED AGREED SCHEDULING ORDER — Page 1
4. The deadline for any Party opposing affirmative relief to designate expert(s) and/or
provide expert reports is Ninety (90) Days Before Trial.
5. The deadline for either Party to designate rebuttal expert(s) and/or provide rebuttal
reports is Seventy-Five (75) Days Before Trial.
6. Expert discovery closes Forty-Five (45) Days Before Trial.
7. The deadline to have challenges to experts heard is Thirty (30) Days Before Trial.
8. The deadline to have dispositive motions heard is Thirty (30) Days Before Trial.
9. The deadline for mediation is One Hundred Twenty (120) Days Before Trial.
10. The deadline to exchange exhibit lists is Fourteen (14) Days Before Trial.
11. The deadline to file statements of contested issues of fact, stipulated facts, Witness
lists, proposed jury charges and instructions, stipulations to admissibility of exhibits,
objections to opposing party’s exhibits, estimates of length of trial, designations of
deposition testimony, and motions in limine is Ten (10) Days Before Trial.
SIGNED this day of , 2022.
The Honorable Judge Dale Tillery
134th District Court, Dallas County, Texas
ORDER GRANTING AGREED MOTION FOR CONTINUANCE AND
ENTRY OF AMENDED AGREED SCHEDULING ORDER — Page 2
AGREED AS TO SUBSTANCE AND FORM
KESSLER & COLLINS, PC
/s/ Daniel P. Callahan
DANIEL P. CALLAHAN
State Bar No. 03648700
STEPHEN J. HUSCHKA
State Bar No. 24097861
DPC@kesslercollins.com
SHuschka@kesslercollins.com
2100 Ross Avenue, Suite 750
Dallas, Texas 75201
ATTORNEYS FOR PLAINTIFFS
MUNSCH HARDT KOPF & HARR, P.C.
/s/ Dennis L. Roosiemith permission)
DENNIS L. ROOSSIEN
State Bar No. 00784873
droossien@munsch.com
A TTORNE Y FOR DEFENDANTS
ORDER GRANTING AGREED MOTION FOR CONTINUANCE AND
ENTRY OF AMENDED AGREED SCHEDULING ORDER — Page 1
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Deborah Nyarangi on behalf of Daniel Callahan
Bar No. 03648700
dnyarangi@kesslercollins.com
Envelope ID: 66344203
Status as of 7/15/2022 11:53 AM CST
Associated Case Party: WHAM TECH, INC.
Name BarNumber Email TimestampSubmitted Status
Dennis Roossien droossien@munsch.com 7/14/2022 6:46:39 PM SENT
Lisa Garrett lgarrett@munsch.com 7/14/2022 6:46:39 PM SENT
Sharon BLACKSTOCK sblackstock@munsch.com 7/14/2022 6:46:39 PM SENT
Dennis L.Roossien droossien@munsch.com 7/14/2022 6:46:39 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Daniel P. Callahan 3648700 dpc@kesslercollins.com 7/14/2022 6:46:39 PM SENT
Francine Ly fly@dallascourts.org 7/14/2022 6:46:39 PM SENT
Gaile Willard gwillard@kesslercollins.com 7/14/2022 6:46:39 PM SENT
Document Filed Date
July 14, 2022
Case Filing Date
September 21, 2021
Category
CNTR CNSMR COM DEBT
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CAUSE NO. DC-21-14068 GAMCO PROPERTIES, LLC, IN THE DISTRICT COURT §§§§§§§§§§§ GAMVEST, LP and LESA GAMBLE, Plaintiffs, v. DALLAS COUNTY, TEXAS WHAM TECH, INC. and WHAM TECHNOLOGIES, INC., Defendants. 134TH IUDICIAL DISTRICT ORDER GRANTING AGREED MOTION FOR CONTINUAN CE AND ENTRY OF AMENDED AGREED SCHEDULING ORDER On this day, came to be considered the Agreed Motion for Continuance and Entry of Amended Agreed Scheduling Order (the “Motion”) filed by the Parties? Having considered the Motion, the pleadings, and applicable authorities, the Court finds that the Motion should be GRANTED. It is therefore ORDERED that the trial date of November 7, 2022 is continued to May 22, 2023. It is further ORDERED that an Amended Agreed Scheduling Order shall be entered as follows: 1. The deadline to file amended pleadings asserting new causes of action or affirmative defenses and to file motions for leave to designate responsible third parties is One Hundred Thirty (130) Days Before Trial. Pleadings directly responsive to any timely filed pleadings must be filed by One Hundred (100) Days Before Trial. 2. Fact discovery closes Seventy (70) Days Before Trial. 3. The deadline for any Party seeking affirmative relief to designate expert(s) and/or provide expert reports is One Hundred Five (105) Days Before Trial. 2 As used herein, the “Parties” shall mean and refer to Plaintiffs Gamco Properties, LLC, Gamvest, LP, and Lesa Gamble and Defendants Wham Tech, Inc. and Wham Technologies, Inc., collectively. 0_RDER_GRANTING AGREED MOEON FOR'CONTTVUANCEXVD ENTRY 0F AMENDED AGREED SCHEDULING ORDER — Page 1 4. The deadline for any Party opposing affirmative relief to designate expert(s) and/or provide expert reports is Ninety (90) Days Before Trial. 5. The deadline for either Party to designate rebuttal expert(s) and/or provide rebuttal reports is Seventy-Five (75) Days Before Trial. 6. Expert discovery closes Forty-Five (45) Days Before Trial. 7. The deadline to have challenges to experts heard is Thirty (30) Days Before Trial. 8. The deadline to have dispositive motions heard is Thirty (30) Days Before Trial. 9. The deadline for mediation is One Hundred Twenty (120) Days Before Trial. 10. The deadline to exchange exhibit lists is Fourteen (14) Days Before Trial. 11. The deadline to file statements of contested issues of fact, stipulated facts, Witness lists, proposed jury charges and instructions, stipulations to admissibility of exhibits, objections to opposing party’s exhibits, estimates of length of trial, designations of deposition testimony, and motions in limine is Ten (10) Days Before Trial. SIGNED this day of , 2022. The Honorable Judge Dale Tillery 134th District Court, Dallas County, Texas ORDER GRANTING AGREED MOTION FOR CONTINUANCE AND ENTRY OF AMENDED AGREED SCHEDULING ORDER — Page 2 AGREED AS TO SUBSTANCE AND FORM KESSLER & COLLINS, PC /s/ Daniel P. Callahan DANIEL P. CALLAHAN State Bar No. 03648700 STEPHEN J. HUSCHKA State Bar No. 24097861 DPC@kesslercollins.com SHuschka@kesslercollins.com 2100 Ross Avenue, Suite 750 Dallas, Texas 75201 ATTORNEYS FOR PLAINTIFFS MUNSCH HARDT KOPF & HARR, P.C. /s/ Dennis L. Roosiemith permission) DENNIS L. ROOSSIEN State Bar No. 00784873 droossien@munsch.com A TTORNE Y FOR DEFENDANTS ORDER GRANTING AGREED MOTION FOR CONTINUANCE AND ENTRY OF AMENDED AGREED SCHEDULING ORDER — Page 1 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Deborah Nyarangi on behalf of Daniel Callahan Bar No. 03648700 dnyarangi@kesslercollins.com Envelope ID: 66344203 Status as of 7/15/2022 11:53 AM CST Associated Case Party: WHAM TECH, INC. Name BarNumber Email TimestampSubmitted Status Dennis Roossien droossien@munsch.com 7/14/2022 6:46:39 PM SENT Lisa Garrett lgarrett@munsch.com 7/14/2022 6:46:39 PM SENT Sharon BLACKSTOCK sblackstock@munsch.com 7/14/2022 6:46:39 PM SENT Dennis L.Roossien droossien@munsch.com 7/14/2022 6:46:39 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Daniel P. Callahan 3648700 dpc@kesslercollins.com 7/14/2022 6:46:39 PM SENT Francine Ly fly@dallascourts.org 7/14/2022 6:46:39 PM SENT Gaile Willard gwillard@kesslercollins.com 7/14/2022 6:46:39 PM SENT