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PIC.26467
CAUSE NO. DC-22-01700
RONDA COBB, § IN THE DISTRICT COURT
Plaintiff, §
§
VS. §
§
RIVERSIDE CCF/CB PARTNERS, L.P. § DALLAS COUNTY, TEXAS
D/B/A THE PARK AT CLIFF CREEK §
APARTMENTS; CESAR CHAVEZ §
FOUNDATION; REYNALDO §
RODRIGUEZ D/B/A RODRIGUEZ §
PAINTING, §
Defendants. § 298m JUDICIAL DISTRICT
AMENDED AGREED SCHEDULING ORDER
COME NOW, all parties in the above-styled and numbered case, by and through their
respective counsel of record, and file this their Agreed Scheduling Order. Pursuant to Rules 166,
190 and 192 of the Tex. R. CiV. P. The Court issues the following Scheduling and Level 3
Discovery Order:
AUGUST 4, 2023 AMENDED PLEADINGS. Amended pleadings asserting new
causes of action or new defenses. No additional theories or
allegations shall be pled after this date without prior leave of court
based upon a showing a good cause or by written agreement of the
parties pursuant to a Rule 11 Agreement.
OCTOBER 20, 2023 DISCOVERY ENDS.
SEPTEMBER 5, 2023 PLAINTIFF shall designate all testifying experts by this date.
These designations shall include the information as required in
Rule 195.5 for all testifying experts.
OCTOBER 5, 2023 DEFENDANTS shall designate all testifying experts by this date.
These designations shall include the information as required in
Rule 195.5 for all testifying experts.
OCTOBER 27, 2023 REBUTTAL EXPERTS. All parties shall designate any rebuttal
testifying experts by this date. These designations shall include the
information as required in Rule 195.5 for all testifying experts.
NOVEMBER 13, 2023 DISPOSITIVE MOTIONS. Except with leave of Court, all
dispositive motions shall be heard by this date.
NOVEMBER 3, 2023 MEDIATION DEADLINE
AGREED SCHEDULING ORDER Page 1
NOVEMBER 20, 2023 EXHIBIT LISTS & DEPOSITION DESIGNATIONS. The
parties must exchange designations of deposition testimony to be
offered in direct examination and a list of exhibits and shall
exchange copies of any exhibits nt previously produced in
discovery by this date. Except for records to be offered by way of
business record affidavits, each exhibit must be identified
separately and not by category or group designation.
NOVENIBER 27, 2023 OBJECTIONS TO EXHIBITS AND DEPOSITION
TESTIMONY AND REBUTTAL DEPOSITION
DESIGNATIONS. The parties must exchange in writing
designations of deposition testimony to be offered in rebuttal
examination and their objections to the opposing party’s proposed
exhibits, including objections under Rule 193.7, and deposition
testimony by this date.
NOVEMBER 20, 2023 CHALLENGES TO EXPERT TESTIMONY. All motions to
exclude expert testimony and evidence challenges to expert
testimony must be heard by this date, or such objection is waived.
NOVEMBER 30, 2023 ATTORNEY MEETING T0 DISCUSS STIPULATION S. The
attorneys in charge for all parties shall meet in person to confer on
the matters described in Rule 166 (e)-(l), stipulations regarding the
exhibit submission, an estimate of the length of trial, designation of
deposition testimony to be offered in direct examination, and
motions in limine.
NOVEMBER 23, 2023 FILING RULE 166 (e)-(l) MATTERS. The parties shall file
with the court materials stated in Rule 166 (e)—(l), an estimate of
the length of trial, and any motions in limine. The failure to file
such materials may result in dismissal for want of prosecution or
other appropriate sanction.
PRETRIAL CONFERENCE/DEMONSTRATIVES. The
Pretrial Conference will be held at _ A.M./P.M. on this date.
All pre-trial motions, including Motions in Limine and Motions to
Apportion Jury Strikes, shall be heard at or before the Pretrial
Conference. Further, the parties shall exchange all demonstrative
exhibits by this date.
DECEMBER 4, 2023 JURY TRIAL The case will be ready and is set for Jury trial on
December 4, 2023 at 9:00 AM (“Trial Setting”). All parties are
required to announce for trial on the Thursday before their trial
begins. Failure to announce by 10:30 AM on the Friday before the
designated trial setting may result in Dismissal of the case. Cases
not reached on the designated trial date are to be ready for trial on
AGREED SCHEDULING ORDER Page 2
a 24-hour notice during their two-week trial docket. If not reached
as set, the case will be carried to the next week.
IT IS SO ORDERED.
EMILY G. TOBOLOWSKY
Judge, 298m District Court
AGREED SCHEDULING ORDER Page 3
AGREED TO:
DUKE SETH, PLLC
/s/ Gagandeep K. Seth
GAGANDEEP K. SETH
State Bar No. 24062441
gkseth@dukeseth.com
WALKER M. DUKE
State Bar No. 24036505
wduke@dukeseth.com
325 N. St. Paul Street, Suite 2220
Dallas, Texas 75201
Phone: 214-965-8100
ATTORNEYS FOR PLAINTIFF
FLETCHER, FARLEY, SHIPMAN
& SALINAS, L.L.P.
/s/ Joseph J. Harrison
DOUGLAS D. FLETCHER
State Bar No. 07139500
Email: doug.fletcher@fletcherfarlev.com
JULIA L. SINOR
State Bar No. 24032540
Email: iulia.sinor@fletcherfarlev.com
JOSEPH J. HARRISON
State Bar No. 24083143
Email: i0e.hanison@fletcherfarley.com
9201 N. Central Expressway, Suite 600
Dallas, Texas 75231
(214) 987-9600 (office)
(214) 987-9866 (telecopier)
ATTORNEYS FOR DEFENDANTS
RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A
THE PARK AT CLIFF CREEK
APARTMENTS AND CESAR CHAVEZ
FOUNDATION
AGREED SCHEDULING ORDER Page 4
RESNICK & LOUIS, P.C.
/s/ Stacy H. Thompson
STACY H. THOMPSON
Bar No. 24046971
sthompson@r1attomeys.com
2425 N. Central Expressway, Suite 231
Richardson, TX 75080
For Service: mail@r1attorneys.com
(972) 833-2977— Office/Facsimile
ATTORNEY FOR DEFENDANT REYNALDO
RODRIGUEZ D/B/A RODRIGUEZ PAINTING
AGREED SCHEDULING ORDER Page 5
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PIC.26467 CAUSE NO. DC-22-01700 RONDA COBB, § IN THE DISTRICT COURT Plaintiff, § § VS. § § RIVERSIDE CCF/CB PARTNERS, L.P. § DALLAS COUNTY, TEXAS D/B/A THE PARK AT CLIFF CREEK § APARTMENTS; CESAR CHAVEZ § FOUNDATION; REYNALDO § RODRIGUEZ D/B/A RODRIGUEZ § PAINTING, § Defendants. § 298m JUDICIAL DISTRICT AMENDED AGREED SCHEDULING ORDER COME NOW, all parties in the above-styled and numbered case, by and through their respective counsel of record, and file this their Agreed Scheduling Order. Pursuant to Rules 166, 190 and 192 of the Tex. R. CiV. P. The Court issues the following Scheduling and Level 3 Discovery Order: AUGUST 4, 2023 AMENDED PLEADINGS. Amended pleadings asserting new causes of action or new defenses. No additional theories or allegations shall be pled after this date without prior leave of court based upon a showing a good cause or by written agreement of the parties pursuant to a Rule 11 Agreement. OCTOBER 20, 2023 DISCOVERY ENDS. SEPTEMBER 5, 2023 PLAINTIFF shall designate all testifying experts by this date. These designations shall include the information as required in Rule 195.5 for all testifying experts. OCTOBER 5, 2023 DEFENDANTS shall designate all testifying experts by this date. These designations shall include the information as required in Rule 195.5 for all testifying experts. OCTOBER 27, 2023 REBUTTAL EXPERTS. All parties shall designate any rebuttal testifying experts by this date. These designations shall include the information as required in Rule 195.5 for all testifying experts. NOVEMBER 13, 2023 DISPOSITIVE MOTIONS. Except with leave of Court, all dispositive motions shall be heard by this date. NOVEMBER 3, 2023 MEDIATION DEADLINE AGREED SCHEDULING ORDER Page 1 NOVEMBER 20, 2023 EXHIBIT LISTS & DEPOSITION DESIGNATIONS. The parties must exchange designations of deposition testimony to be offered in direct examination and a list of exhibits and shall exchange copies of any exhibits nt previously produced in discovery by this date. Except for records to be offered by way of business record affidavits, each exhibit must be identified separately and not by category or group designation. NOVENIBER 27, 2023 OBJECTIONS TO EXHIBITS AND DEPOSITION TESTIMONY AND REBUTTAL DEPOSITION DESIGNATIONS. The parties must exchange in writing designations of deposition testimony to be offered in rebuttal examination and their objections to the opposing party’s proposed exhibits, including objections under Rule 193.7, and deposition testimony by this date. NOVEMBER 20, 2023 CHALLENGES TO EXPERT TESTIMONY. All motions to exclude expert testimony and evidence challenges to expert testimony must be heard by this date, or such objection is waived. NOVEMBER 30, 2023 ATTORNEY MEETING T0 DISCUSS STIPULATION S. The attorneys in charge for all parties shall meet in person to confer on the matters described in Rule 166 (e)-(l), stipulations regarding the exhibit submission, an estimate of the length of trial, designation of deposition testimony to be offered in direct examination, and motions in limine. NOVEMBER 23, 2023 FILING RULE 166 (e)-(l) MATTERS. The parties shall file with the court materials stated in Rule 166 (e)—(l), an estimate of the length of trial, and any motions in limine. The failure to file such materials may result in dismissal for want of prosecution or other appropriate sanction. PRETRIAL CONFERENCE/DEMONSTRATIVES. The Pretrial Conference will be held at _ A.M./P.M. on this date. All pre-trial motions, including Motions in Limine and Motions to Apportion Jury Strikes, shall be heard at or before the Pretrial Conference. Further, the parties shall exchange all demonstrative exhibits by this date. DECEMBER 4, 2023 JURY TRIAL The case will be ready and is set for Jury trial on December 4, 2023 at 9:00 AM (“Trial Setting”). All parties are required to announce for trial on the Thursday before their trial begins. Failure to announce by 10:30 AM on the Friday before the designated trial setting may result in Dismissal of the case. Cases not reached on the designated trial date are to be ready for trial on AGREED SCHEDULING ORDER Page 2 a 24-hour notice during their two-week trial docket. If not reached as set, the case will be carried to the next week. IT IS SO ORDERED. EMILY G. TOBOLOWSKY Judge, 298m District Court AGREED SCHEDULING ORDER Page 3 AGREED TO: DUKE SETH, PLLC /s/ Gagandeep K. Seth GAGANDEEP K. SETH State Bar No. 24062441 gkseth@dukeseth.com WALKER M. DUKE State Bar No. 24036505 wduke@dukeseth.com 325 N. St. Paul Street, Suite 2220 Dallas, Texas 75201 Phone: 214-965-8100 ATTORNEYS FOR PLAINTIFF FLETCHER, FARLEY, SHIPMAN & SALINAS, L.L.P. /s/ Joseph J. Harrison DOUGLAS D. FLETCHER State Bar No. 07139500 Email: doug.fletcher@fletcherfarlev.com JULIA L. SINOR State Bar No. 24032540 Email: iulia.sinor@fletcherfarlev.com JOSEPH J. HARRISON State Bar No. 24083143 Email: i0e.hanison@fletcherfarley.com 9201 N. Central Expressway, Suite 600 Dallas, Texas 75231 (214) 987-9600 (office) (214) 987-9866 (telecopier) ATTORNEYS FOR DEFENDANTS RIVERSIDE CCF/CB PARTNERS, L.P. D/B/A THE PARK AT CLIFF CREEK APARTMENTS AND CESAR CHAVEZ FOUNDATION AGREED SCHEDULING ORDER Page 4 RESNICK & LOUIS, P.C. /s/ Stacy H. Thompson STACY H. THOMPSON Bar No. 24046971 sthompson@r1attomeys.com 2425 N. Central Expressway, Suite 231 Richardson, TX 75080 For Service: mail@r1attorneys.com (972) 833-2977— Office/Facsimile ATTORNEY FOR DEFENDANT REYNALDO RODRIGUEZ D/B/A RODRIGUEZ PAINTING AGREED SCHEDULING ORDER Page 5