On October 14, 2021 a
Stipulation,Agreement
was filed
involving a dispute between
Tinsman, Divya,
and
Couch, Thomas,
State Farm Mutual Automobile Insurance Company,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
CAUSE NO. DC-21 -15195
DIWA TINSMAN; § IN THE DISTRICT COURT OF
'§
Plaintiff. §
§
VS. § DALLAS COUNTY, TEXAS
-
§ .
SJATE FARM MUTUAL AUTOMOBILE §
INSURANCE COMPANY; AND §
THOMAS COUCH; § '
§ _ _
Defendants. § 298T" JUDICIAL DISTRICT
AGREED scHEDULING oéDER
The parties submit this proposed Agreed Scheduling Order. The Court, having
considered said Order, is of the opinion that the Order should be GRANTED.
IT IS THEREFORE ORDERED that the following .pre-trial deadlines shall apply
to the abo'veLentitied and numbered cause, unless othenivise,modified by agreement-of;
the parties or Order of the Court:_
September 28, '2022 Deadline by which all Claims must be filed/all parties-
identified including counterclaims, cross-claims and/or
responsible third-party Claims, excluding CPRC
33. 0040).
November 23. 2022 If Plaintiff received medical treatment after filing suit the
CPRC 18. 001 affidavits for this treatment are due by
this date. Defendants have 30 days from the date the
affidavitIs produced to' Counter each affidavit.
November 23. 2022 Plaintiff’s deadline to designate retained experts with‘
reports.
December 27, 2022 Defendant’s deadline to designate retained experts '
with reports. \
I
January 26. 2023 Mediation deadline. Mediation is scheduled to occur
before this date with mediator Adam LeCrone'.
AGREED SCHEDULING ORDER PAGE 1
—
February 24, 2023 Deadline by which the parties must have completed .
discovery (all discovery must be initiated at a time ea'rly
enough to ensure that the completion of same will not
surpass this deadline).
March 20. 2023 Deadline by which the parties file their page/line
designations of video deposition testimony to be used
at trial.
March 22, 2023 Deadline by which parties file their objections‘to
page/line designations of video deposition testimony to
be used at trial.
'
March 23. 2023 Deadline by which the parties must file their rebuttal
page/line designations of video deposition testimony to
be used at trial.
March 23, 2023 Deadline by which the parties must file pretrial
disclosures, motions in limine, any pre-trial motions, a
proposed jury charge, and parties mdstexchange true
and correct copies of exhibits not previously produced:
March 27, 2023 JURY TRIAL
All deadlines in this Scheduling Order may be modified by Rule 1.1 agreement.
except for the trial- date. Should this case not be reached for trial on the' March 27,
2023 trial setting. a‘bsenta new schedulihg order being entered or a Rule 11
agreement stating othenivise. the parties agree that the discovery deadline will end 30
days before the new trial date. Additionally, all pretrial deadlines (pretrial disClosures,
It'll...
motion in limine, and page-line designations) will be moved to the same number of
IIIIIIII
calendar days prior to trial as set out above, according to the new trial date.
The parties agree that nothing in this Scheduling Order will affect any party's
right to seek leave of Court under Section 18.0010) of the Texas Civil Practice &
Remedies Code.
AGREED SCHEDULING ORDER — PAGE 2
6’
W
l
SIGNEDTHIS day of
k#" .2022.
APPROVED AS TO FORM AND CONTENT:
WITHERITE LAW GROUP, PLLc
\
By: /s/ Christopher K. Provost
CHRISTOPHER K. PROVOST
State Bar No. 24085759
christopher.provost@witheritelaw.com ‘
SHELLY GRECO
State Bar No. 24008168
shellv.mco@witheritelaw.com
10440 N. Central Expressway
Suite 400
Dallas, TX 75231-2228
214/378-6665
214/378—6670 (fax)
ATTORNEYS FOR PLAINTIFF
.
WALTERS BALIDO 8: CRAIN
_
-ou.
By: /s/ Can'os A. Balido
CARLOS A. BALIDO
State Bar No. 01631230
carlos.balido@wbclawfirm.com
Meadow Park Towers, 15th Floor
10440 North Central Expressway
Dallas. TX 75231
214/749-4805
214/760-1670 (fax)
ATTORNEY FOR DEFENDANTS
AGREED SCHEDULING ORDER — PAGE 3
Document Filed Date
August 05, 2022
Case Filing Date
October 14, 2021
Category
MOTOR VEHICLE ACCIDENT
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
CAUSE NO. DC-21 -15195 DIWA TINSMAN; § IN THE DISTRICT COURT OF '§ Plaintiff. § § VS. § DALLAS COUNTY, TEXAS - § . SJATE FARM MUTUAL AUTOMOBILE § INSURANCE COMPANY; AND § THOMAS COUCH; § ' § _ _ Defendants. § 298T" JUDICIAL DISTRICT AGREED scHEDULING oéDER The parties submit this proposed Agreed Scheduling Order. The Court, having considered said Order, is of the opinion that the Order should be GRANTED. IT IS THEREFORE ORDERED that the following .pre-trial deadlines shall apply to the abo'veLentitied and numbered cause, unless othenivise,modified by agreement-of; the parties or Order of the Court:_ September 28, '2022 Deadline by which all Claims must be filed/all parties- identified including counterclaims, cross-claims and/or responsible third-party Claims, excluding CPRC 33. 0040). November 23. 2022 If Plaintiff received medical treatment after filing suit the CPRC 18. 001 affidavits for this treatment are due by this date. Defendants have 30 days from the date the affidavitIs produced to' Counter each affidavit. November 23. 2022 Plaintiff’s deadline to designate retained experts with‘ reports. December 27, 2022 Defendant’s deadline to designate retained experts ' with reports. \ I January 26. 2023 Mediation deadline. Mediation is scheduled to occur before this date with mediator Adam LeCrone'. AGREED SCHEDULING ORDER PAGE 1 — February 24, 2023 Deadline by which the parties must have completed . discovery (all discovery must be initiated at a time ea'rly enough to ensure that the completion of same will not surpass this deadline). March 20. 2023 Deadline by which the parties file their page/line designations of video deposition testimony to be used at trial. March 22, 2023 Deadline by which parties file their objections‘to page/line designations of video deposition testimony to be used at trial. ' March 23. 2023 Deadline by which the parties must file their rebuttal page/line designations of video deposition testimony to be used at trial. March 23, 2023 Deadline by which the parties must file pretrial disclosures, motions in limine, any pre-trial motions, a proposed jury charge, and parties mdstexchange true and correct copies of exhibits not previously produced: March 27, 2023 JURY TRIAL All deadlines in this Scheduling Order may be modified by Rule 1.1 agreement. except for the trial- date. Should this case not be reached for trial on the' March 27, 2023 trial setting. a‘bsenta new schedulihg order being entered or a Rule 11 agreement stating othenivise. the parties agree that the discovery deadline will end 30 days before the new trial date. Additionally, all pretrial deadlines (pretrial disClosures, It'll... motion in limine, and page-line designations) will be moved to the same number of IIIIIIII calendar days prior to trial as set out above, according to the new trial date. The parties agree that nothing in this Scheduling Order will affect any party's right to seek leave of Court under Section 18.0010) of the Texas Civil Practice & Remedies Code. AGREED SCHEDULING ORDER — PAGE 2 6’ W l SIGNEDTHIS day of k#" .2022. APPROVED AS TO FORM AND CONTENT: WITHERITE LAW GROUP, PLLc \ By: /s/ Christopher K. Provost CHRISTOPHER K. PROVOST State Bar No. 24085759 christopher.provost@witheritelaw.com ‘ SHELLY GRECO State Bar No. 24008168 shellv.mco@witheritelaw.com 10440 N. Central Expressway Suite 400 Dallas, TX 75231-2228 214/378-6665 214/378—6670 (fax) ATTORNEYS FOR PLAINTIFF . WALTERS BALIDO 8: CRAIN _ -ou. By: /s/ Can'os A. Balido CARLOS A. BALIDO State Bar No. 01631230 carlos.balido@wbclawfirm.com Meadow Park Towers, 15th Floor 10440 North Central Expressway Dallas. TX 75231 214/749-4805 214/760-1670 (fax) ATTORNEY FOR DEFENDANTS AGREED SCHEDULING ORDER — PAGE 3