On September 09, 2008 a
Letter,Correspondence
was filed
involving a dispute between
and
for OTHER CIVIL, TEMP RESTRAINING ORDER/INJUNCTION
in the District Court of Tarrant County.
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KIRKLEY & BERRYMAN, L.L.P.
100 N. FOREST PARK BLVD., SUITE 220
FORT WORTH, TEXAS 76102
J. Lyndell Kirkley Sean R. Looney
kirkley@kbbltmyers.com TELEPHONE: 817.335.3311 slooney@bbltmyers.com
B. Dan Berryman FACSIMILE: 817.335.7733 Ana I. Forcum
berryman@j"ITHikD AMENDED AGRI.ED LEVEL THRn: SCILEDIIUNG ORDEK..wpd
''
----------------·
C. May 5, 2011- Designation ofTestifying Experts for Party/Parties with the
burden of proof. Any party with the burden of proof designating a testifying
expert witness is ORDERED to provide, no later than this date, the
information set forth in TEX. R. CIV. P. 194.2(f) and a written report prepared
by the expert setting forth the substance of the expert's opinion. (The
requirements of a written report shall not extend to an expert witness called
solely for the issue of attorneys' fees.) An expert not designated or report not
submitted prior to the deadlines set forth herein shall result in the expert not
being permitted to testify unless good cause is shown for the late designation.
D. June 3, 2011- Designation of a Testifying Experts for Parties Respondent.
Any party designating an expert witness to respond to an expert identified
above is ORDERED to provide, no later than this date the information set
forth in TEX. R. CIV. P. 194.2(f) and a written report prepared by the expert
setting forth the substance of the expert's opinion. (The requirement of a
written report shall not extend to an expert witness called solely for the issue
of attorneys' fees.) An expert not designated or report not being submitted
prior to the deadlines set forth herein shall result in the expert not being
permitted to testify unless good cause is shown for the late designation.
E. August 18, 2011- Any motion to exclude or limit expert testimony must be
filed by this date.
F. July 14, 2011- Completion of all Discovery. Allowing sufficient time for:
(1) timely responses to such requests to be served or filed; and (2) completion
of all depositions, including supplementation of the record, by such deadline.
The "Order Denying Plaintiffs' First Amended Motion to Quash Notices of
Intention to Take Oral Depositions and Motion for Protective Order" dated
June 10, 2009, is vacated insofar as it allows Defendants to take Plaintiffs'
depositions before Plaintiffs may take Defendants' depositions. There shall be
no preference given to any party or side with regard to the order of depositions
taken in this lawsuit.
G. May 5, 2011 - Filing Additional, Amended, New, or Supplemental
Pleadings by the Party with the burden of proof.
H. May 19, 2011- Filing Objections, Special Exceptions, or other Responses
to pleadings by all parties.
THIRD AMENDED LEVEL THREE SCHEDULING ORDER Page2
G:\Klrl. KJNSELIJ'lLADISGSITHIRD AJ\IENDEDAGR.U:D U:VEL niREE SCHI:DUUNG 0RD£R.'*j>d
Document Filed Date
March 29, 2011
Case Filing Date
September 09, 2008
Category
OTHER CIVIL, TEMP RESTRAINING ORDER/INJUNCTION
Status
DISMISSED OR NON-SUITED
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KIRKLEY & BERRYMAN, L.L.P. 100 N. FOREST PARK BLVD., SUITE 220 FORT WORTH, TEXAS 76102 J. Lyndell Kirkley Sean R. Looney kirkley@kbbltmyers.com TELEPHONE: 817.335.3311 slooney@bbltmyers.com B. Dan Berryman FACSIMILE: 817.335.7733 Ana I. Forcum berryman@j"ITHikD AMENDED AGRI.ED LEVEL THRn: SCILEDIIUNG ORDEK..wpd '' ----------------· C. May 5, 2011- Designation ofTestifying Experts for Party/Parties with the burden of proof. Any party with the burden of proof designating a testifying expert witness is ORDERED to provide, no later than this date, the information set forth in TEX. R. CIV. P. 194.2(f) and a written report prepared by the expert setting forth the substance of the expert's opinion. (The requirements of a written report shall not extend to an expert witness called solely for the issue of attorneys' fees.) An expert not designated or report not submitted prior to the deadlines set forth herein shall result in the expert not being permitted to testify unless good cause is shown for the late designation. D. June 3, 2011- Designation of a Testifying Experts for Parties Respondent. Any party designating an expert witness to respond to an expert identified above is ORDERED to provide, no later than this date the information set forth in TEX. R. CIV. P. 194.2(f) and a written report prepared by the expert setting forth the substance of the expert's opinion. (The requirement of a written report shall not extend to an expert witness called solely for the issue of attorneys' fees.) An expert not designated or report not being submitted prior to the deadlines set forth herein shall result in the expert not being permitted to testify unless good cause is shown for the late designation. E. August 18, 2011- Any motion to exclude or limit expert testimony must be filed by this date. F. July 14, 2011- Completion of all Discovery. Allowing sufficient time for: (1) timely responses to such requests to be served or filed; and (2) completion of all depositions, including supplementation of the record, by such deadline. The "Order Denying Plaintiffs' First Amended Motion to Quash Notices of Intention to Take Oral Depositions and Motion for Protective Order" dated June 10, 2009, is vacated insofar as it allows Defendants to take Plaintiffs' depositions before Plaintiffs may take Defendants' depositions. There shall be no preference given to any party or side with regard to the order of depositions taken in this lawsuit. G. May 5, 2011 - Filing Additional, Amended, New, or Supplemental Pleadings by the Party with the burden of proof. H. May 19, 2011- Filing Objections, Special Exceptions, or other Responses to pleadings by all parties. THIRD AMENDED LEVEL THREE SCHEDULING ORDER Page2 G:\Klrl. KJNSELIJ'lLADISGSITHIRD AJ\IENDEDAGR.U:D U:VEL niREE SCHI:DUUNG 0RD£R.'*j>d