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CAUSE NO. DC-22-00781
MARCUS THOMAS IN THE DISTRICT COURT
VS.
IOIST JUDICIAL DISTRICT
NOAH HAMRICK, SIA
TRANSPORTATION INC. DBA TWO
MEN AND A TRUCK, PIONEER TRUCK
LEASING, AND DALLAS MOVERS DALLAS COUNTY, TEXAS
SOUTH LLC
AGREED LEVEL III SCHEDULING ORDER
TO THE HONORABLE JUDGE OF SAID COURT:
The parties submit this proposed Agreed Scheduling Order. The Court, having considered
said Order, is of the opinion that the Order is appropriate and is hereby ENTERED.
It is, therefore, ORDERED that the following deadlines shall apply to the above-entitled
and numbered cause unless otherwise modified by agreement of the parties or further Order of the
Court.
December 16, 2022 Deadline by which Plaintiff must file amended pleadings
asserting any new claims, causes of action, or allegations.
January 3, 2023 On or before this date, Plaintiffs shall serve all attorneys
of record with their written designation and opinions of
expert witnesses expected to testify at the trial of this
cause in accordance with Tex. R. Civ. P. 194 and 195.
Plaintiffs are required to provide written reports from
retained experts.
January 17, 2023 On or before this date, Defendants shall serve all
attorneys of record with their written designation and
opinions of expert witnesses expected to testify at the
trial of this cause in accordance with Tex. R. Civ. P. 194
and 195. Defendants are required to provide written
reports from retained experts.
January 17, 2023 Deadline by which Defendants must file amended
pleadings asserting any new defenses, claims, or
allegations.
AGREED LEVEL III SCHEDULING ORDER - Page 1
January 3, 2023 Deadline by which all additional parties must be joined.
This deadline is not intended to extend or modify any
applicable statute of limitations.
January 3, 2023 The parties shall confer and attempt to agree on selection
of a mediator by this date. The parties shall notify the
Court in writing if no agreement is reached, and the
Court will appoint a mediator.
February 7, 2023 Deadline by which the parties must have completed
discovery (all discovery must be initiated at a time early
enough to ensure that the completion of same will not
surpass this deadline).
February 17, 2023 The parties shall mediate this case on or before this date.
March 10, 2023 Deadline by which the parties shall file their page/ line
designations of video deposition testimony to be used at
trial.
March 10, 2023 Deadline by which the parties must file motions in
limine, trial exhibit lists, trial witness lists, any pre-trial
motions, a proposed jury charge, and parties must
exchange true and correct copies of exhibits not
previously produced.
March 21, 2023 Deadline by which parties file their objections to
page/ line designations of video deposition testimony to
be used at trial.
March 21, 2023 Deadline by which the parties must file their rebuttal
page/ line designations of video deposition testimony to
be used at trial.
March 21, 2023 Deadline by which the parties must file objections to trial
exhibits and / or trial witnesses.
April 18, 2023 JURY TRIAL
By signature below, the parties agree that this Agreed Scheduling Order shall operate as a
Rule 11 agreement for all deadlines and terms set forth herein until signed by the Court.
All deadlines in this Scheduling Order may be modified by Rule 11 Agreement, except for
the trial date. Should this case not be reached for trial on the trial date set forth above, the deadlines
for filing and objecting to witness lists, exhibit lists, motions in limine, page-line designations, and
AGREED LEVEL III SCHEDULING ORDER - Page 2
jury charges will be moved to correspond to the same number of calendar days prior to trial as set
out above, according to the new trial date.
SO ORDERED this day of . 2022.
JUDGE PRESIDING
AGREED:
lawn MtGi/bem
JASON McGILBERRY
State Bar No. 24099708
—
jmcgj lberggQlinklawpcsom
FELIPE B. LINK
State Bar No. 24057968
flinkgQlinklaypccom
LINK & ASSOCIATES
10440 North Central Expy., Suite 950
Dallas, Texas 75231
ATTORNEY FOR PLAINTIFF
WILLIAM H. CHAMBLEE
State Bar No. 04086100
wchamblee@cr.law
WESTON L. HALL
State Bar No. 24055616
whall@cr.law
AMOS D. PETTIS
State Bar No. 24027730
—
apettisfichJaw
CHAMBLEE RYAN, P. C.
2777 Stemmons Freeway, Suite 1257
Dallas, Texas 75207
AGREED LEVEL III SCHEDULING ORDER - Page 3
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.
Angie Bullock on behalf of Weston Hall
Bar No. 24055616
abullock@cr.law
Envelope ID: 69181063
Status as of 10/13/2022 10:43 AM CST
Associated Case Party: MARCUS THOMAS
Name BarNumber Email TimestampSubmitted Status
Felipe B.Link flink@linklawpc.com 10/13/2022 10:20:58 AM SENT
Sara Link sara@linklawpc.com 10/13/2022 10:20:58 AM SENT
Link & Associates E-Filing service e-filing@linklawpc.com 10/13/2022 10:20:58 AM SENT
Lizeth G.Becerra lbecerra@linklawpc.com 10/13/2022 10:20:58 AM SENT
Andres Beteta andres@linklawpc.com 10/13/2022 10:20:58 AM SENT
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.
Angie Bullock on behalf of Weston Hall
Bar No. 24055616
abullock@cr.law
Envelope ID: 69181063
Status as of 10/13/2022 10:43 AM CST
Associated Case Party: NOAHL. HAMRICK
Name BarNumber Email TimestampSubmitted Status
William HChamblee wchamblee@cr.law 10/13/2022 10:20:58 AM SENT
Weston LHall whall@cr.law 10/13/2022 10:20:58 AM SENT
Amos Pettis apettis@cr.law 10/13/2022 10:20:58 AM SENT
Micaela Espinosa mespinosa@cr.law 10/13/2022 10:20:58 AM SENT
Karen Wiley kwiley@cr.law 10/13/2022 10:20:58 AM SENT
Whitney Gillaspie wgillaspie@cr.law 10/13/2022 10:20:58 AM SENT
Angie Bullock abullock@cr.law 10/13/2022 10:20:58 AM SENT
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.
Angie Bullock on behalf of Weston Hall
Bar No. 24055616
abullock@cr.law
Envelope ID: 69181063
Status as of 10/13/2022 10:43 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
JASON MCGILBERRY JMCGILBERRY@LINKLAWPC.COM 10/13/2022 10:20:58 AM SENT
JASON MCGILBERRY service@|inklawpc.com 10/13/2022 10:20:58 AM SENT
Preview
CAUSE NO. DC-22-00781 MARCUS THOMAS IN THE DISTRICT COURT VS. IOIST JUDICIAL DISTRICT NOAH HAMRICK, SIA TRANSPORTATION INC. DBA TWO MEN AND A TRUCK, PIONEER TRUCK LEASING, AND DALLAS MOVERS DALLAS COUNTY, TEXAS SOUTH LLC AGREED LEVEL III SCHEDULING ORDER TO THE HONORABLE JUDGE OF SAID COURT: The parties submit this proposed Agreed Scheduling Order. The Court, having considered said Order, is of the opinion that the Order is appropriate and is hereby ENTERED. It is, therefore, ORDERED that the following deadlines shall apply to the above-entitled and numbered cause unless otherwise modified by agreement of the parties or further Order of the Court. December 16, 2022 Deadline by which Plaintiff must file amended pleadings asserting any new claims, causes of action, or allegations. January 3, 2023 On or before this date, Plaintiffs shall serve all attorneys of record with their written designation and opinions of expert witnesses expected to testify at the trial of this cause in accordance with Tex. R. Civ. P. 194 and 195. Plaintiffs are required to provide written reports from retained experts. January 17, 2023 On or before this date, Defendants shall serve all attorneys of record with their written designation and opinions of expert witnesses expected to testify at the trial of this cause in accordance with Tex. R. Civ. P. 194 and 195. Defendants are required to provide written reports from retained experts. January 17, 2023 Deadline by which Defendants must file amended pleadings asserting any new defenses, claims, or allegations. AGREED LEVEL III SCHEDULING ORDER - Page 1 January 3, 2023 Deadline by which all additional parties must be joined. This deadline is not intended to extend or modify any applicable statute of limitations. January 3, 2023 The parties shall confer and attempt to agree on selection of a mediator by this date. The parties shall notify the Court in writing if no agreement is reached, and the Court will appoint a mediator. February 7, 2023 Deadline by which the parties must have completed discovery (all discovery must be initiated at a time early enough to ensure that the completion of same will not surpass this deadline). February 17, 2023 The parties shall mediate this case on or before this date. March 10, 2023 Deadline by which the parties shall file their page/ line designations of video deposition testimony to be used at trial. March 10, 2023 Deadline by which the parties must file motions in limine, trial exhibit lists, trial witness lists, any pre-trial motions, a proposed jury charge, and parties must exchange true and correct copies of exhibits not previously produced. March 21, 2023 Deadline by which parties file their objections to page/ line designations of video deposition testimony to be used at trial. March 21, 2023 Deadline by which the parties must file their rebuttal page/ line designations of video deposition testimony to be used at trial. March 21, 2023 Deadline by which the parties must file objections to trial exhibits and / or trial witnesses. April 18, 2023 JURY TRIAL By signature below, the parties agree that this Agreed Scheduling Order shall operate as a Rule 11 agreement for all deadlines and terms set forth herein until signed by the Court. All deadlines in this Scheduling Order may be modified by Rule 11 Agreement, except for the trial date. Should this case not be reached for trial on the trial date set forth above, the deadlines for filing and objecting to witness lists, exhibit lists, motions in limine, page-line designations, and AGREED LEVEL III SCHEDULING ORDER - Page 2 jury charges will be moved to correspond to the same number of calendar days prior to trial as set out above, according to the new trial date. SO ORDERED this day of . 2022. JUDGE PRESIDING AGREED: lawn MtGi/bem JASON McGILBERRY State Bar No. 24099708 — jmcgj lberggQlinklawpcsom FELIPE B. LINK State Bar No. 24057968 flinkgQlinklaypccom LINK & ASSOCIATES 10440 North Central Expy., Suite 950 Dallas, Texas 75231 ATTORNEY FOR PLAINTIFF WILLIAM H. CHAMBLEE State Bar No. 04086100 wchamblee@cr.law WESTON L. HALL State Bar No. 24055616 whall@cr.law AMOS D. PETTIS State Bar No. 24027730 — apettisfichJaw CHAMBLEE RYAN, P. C. 2777 Stemmons Freeway, Suite 1257 Dallas, Texas 75207 AGREED LEVEL III SCHEDULING ORDER - Page 3 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. Angie Bullock on behalf of Weston Hall Bar No. 24055616 abullock@cr.law Envelope ID: 69181063 Status as of 10/13/2022 10:43 AM CST Associated Case Party: MARCUS THOMAS Name BarNumber Email TimestampSubmitted Status Felipe B.Link flink@linklawpc.com 10/13/2022 10:20:58 AM SENT Sara Link sara@linklawpc.com 10/13/2022 10:20:58 AM SENT Link & Associates E-Filing service e-filing@linklawpc.com 10/13/2022 10:20:58 AM SENT Lizeth G.Becerra lbecerra@linklawpc.com 10/13/2022 10:20:58 AM SENT Andres Beteta andres@linklawpc.com 10/13/2022 10:20:58 AM SENT 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. Angie Bullock on behalf of Weston Hall Bar No. 24055616 abullock@cr.law Envelope ID: 69181063 Status as of 10/13/2022 10:43 AM CST Associated Case Party: NOAHL. HAMRICK Name BarNumber Email TimestampSubmitted Status William HChamblee wchamblee@cr.law 10/13/2022 10:20:58 AM SENT Weston LHall whall@cr.law 10/13/2022 10:20:58 AM SENT Amos Pettis apettis@cr.law 10/13/2022 10:20:58 AM SENT Micaela Espinosa mespinosa@cr.law 10/13/2022 10:20:58 AM SENT Karen Wiley kwiley@cr.law 10/13/2022 10:20:58 AM SENT Whitney Gillaspie wgillaspie@cr.law 10/13/2022 10:20:58 AM SENT Angie Bullock abullock@cr.law 10/13/2022 10:20:58 AM SENT 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. Angie Bullock on behalf of Weston Hall Bar No. 24055616 abullock@cr.law Envelope ID: 69181063 Status as of 10/13/2022 10:43 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status JASON MCGILBERRY JMCGILBERRY@LINKLAWPC.COM 10/13/2022 10:20:58 AM SENT JASON MCGILBERRY service@|inklawpc.com 10/13/2022 10:20:58 AM SENT