On August 30, 2021 a
Motion-Secondary
was filed
involving a dispute between
Esparza, Cesar,
and
Cp&Y, Inc.,
Skinner, Steve,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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CAUSE NO. DC-21-11880
CESAR ESPARZA, § IN THE DISTRICT COURT
Plaintifl: g
vs. g 191 ST JUDICIAL DISTRICT
STEVE SKINNER; AND g
epav, mc. §
Defendants. g DALLAS COUNTY. TEXAS
FIR T A REED D LIN ER
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 above-entitled and numbered cause unless othewvise modified by agreement of
the parties or Order of the Court:
Deadline by which all claims must be filed/all parties
April 28, 2023 identified including counterclaims, cross-claims and/or
responsible third-party claims, excluding CPRC
33.0040).
Plaintiff's deadline to designate retained experts with
March 3, 2023 reports.
Plaintiff's deadline to file CPRC 18.001 affidavits for
treatment that occurred prior to suit.
Defendant's deadline to designate retained experts with
March 24, 2023 reports.
Defendant’s deadline to file CPRC 18.001 counter
affidavits for treatment that occurred prior to suit.
FIRST AMENDED AGREED SCHEDULING ORDER— PAGE 1
Mediation deadline. Mediation is scheduled to occur
March 31. 2023 before this date.
If Plaintiff received medical treatment after
filing suit the
March 3, 2023 CPRC 18.001 affidavits for this treatment are due by
this date. Defendants have 30 days to counter each
affidavit produced by Plaintiffs on or before this date.
Deadline by which the parties must have completed
March 31,2023 discovery (all discovery must be initiated at a time early
enough to ensure that the completion of same will not
surpass this deadline).
March 31. 2023 Deadline to hear dispositive motions. Deadline to hear
any Daubert/Robinson Challenges.
Deadline by which the parties file their page/line
April 10, 2023 designations of video deposition testimony to be used
at trial.
April 12, 2023 Deadline by which parties file their objections to
page/line designations of video deposition testimony to
be used at trial.
Deadline by which the parties must file their rebuttal
April 18, 2021 page/line designations of video deposition testimony to
be used at trial.
Deadline by which the parties must file motions in
April 18, 2021 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.
JURY TRIAL
May , 2023 at
9:30 am
FIRST AMENDED AGREED SCHEDULING ORDER— PAGE 2
SIGNED THIs day of , 20 .
JUDGE PRESIDING
By: Isl Daniel Alvarado
MILLER KNAUFF LAW FIRM
Michael A. Miller
State Bar No.14100650
mmiller@mklawac.com
Daniel Alvarado
State Bar No. 24120685
dalvarado@mklawgc.com
Three Forest Plaza
12221 Merit Drive, Suite 1210
Dallas, TX 75251
(469) 916-2552
(469) 916-2555(fax)
Attorneys for Defendants
Isl
ina N. Kas l
Susan A. Allen
Susan C. Austin
KASTL LAW, P.c.
4144 North Central Expressway
Suite 1000
Dallas, Texas, 75204
(214) 821 -0230
(214)821-0231 fax
Attorney for Plaintiff
FIRST AMENDED AGREED 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.
Sandra Gomez on behalf of Kristina Kastl
Bar No. 24025467
sgomez@kastllaw.com
Envelope ID: 72928392
Status as of 2/21/2023 11:20 AM CST
Associated Case Party: CESAR ESPARZA
Name BarNumber Email TimestampSubmitted Status
Kristina N.Kast| kkastl@kastllaw.com 2/20/2023 5:06:09 PM SENT
Sandra Gomez sgomez@kastllaw.com 2/20/2023 5:06:09 PM SENT
Kristina N.Kastl eservice@kastllaw.com 2/20/2023 5:06:09 PM SENT
Sorana Ban sban@kastilaw.com 2/20/2023 5:06:09 PM SENT
Associated Case Party: CP&Y, INC.
Name BarNumber Email TimestampSubmitted Status
Michael Miller mmiller@mklawpc.com 2/20/2023 5:06:09 PM SENT
Robyn Cruze rcruze@mklawpc.com 2/20/2023 5:06:09 PM SENT
Debra Scott dscott@mklawpc.com 2/20/2023 5:06:09 PM SENT
Daniel Alvarado dalvarado@mklawpc.com 2/20/2023 5:06:09 PM SENT
Roxana Esquivel resquivel@mklawpc.com 2/20/2023 5:06:09 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
KRISTINA NKASTL eservice@kastllaw.com 2/20/2023 5:06:09 PM SENT
Document Filed Date
February 20, 2023
Case Filing Date
August 30, 2021
Category
MOTOR VEHICLE ACCIDENT
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CAUSE NO. DC-21-11880 CESAR ESPARZA, § IN THE DISTRICT COURT Plaintifl: g vs. g 191 ST JUDICIAL DISTRICT STEVE SKINNER; AND g epav, mc. § Defendants. g DALLAS COUNTY. TEXAS FIR T A REED D LIN ER 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 above-entitled and numbered cause unless othewvise modified by agreement of the parties or Order of the Court: Deadline by which all claims must be filed/all parties April 28, 2023 identified including counterclaims, cross-claims and/or responsible third-party claims, excluding CPRC 33.0040). Plaintiff's deadline to designate retained experts with March 3, 2023 reports. Plaintiff's deadline to file CPRC 18.001 affidavits for treatment that occurred prior to suit. Defendant's deadline to designate retained experts with March 24, 2023 reports. Defendant’s deadline to file CPRC 18.001 counter affidavits for treatment that occurred prior to suit. FIRST AMENDED AGREED SCHEDULING ORDER— PAGE 1 Mediation deadline. Mediation is scheduled to occur March 31. 2023 before this date. If Plaintiff received medical treatment after filing suit the March 3, 2023 CPRC 18.001 affidavits for this treatment are due by this date. Defendants have 30 days to counter each affidavit produced by Plaintiffs on or before this date. Deadline by which the parties must have completed March 31,2023 discovery (all discovery must be initiated at a time early enough to ensure that the completion of same will not surpass this deadline). March 31. 2023 Deadline to hear dispositive motions. Deadline to hear any Daubert/Robinson Challenges. Deadline by which the parties file their page/line April 10, 2023 designations of video deposition testimony to be used at trial. April 12, 2023 Deadline by which parties file their objections to page/line designations of video deposition testimony to be used at trial. Deadline by which the parties must file their rebuttal April 18, 2021 page/line designations of video deposition testimony to be used at trial. Deadline by which the parties must file motions in April 18, 2021 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. JURY TRIAL May , 2023 at 9:30 am FIRST AMENDED AGREED SCHEDULING ORDER— PAGE 2 SIGNED THIs day of , 20 . JUDGE PRESIDING By: Isl Daniel Alvarado MILLER KNAUFF LAW FIRM Michael A. Miller State Bar No.14100650 mmiller@mklawac.com Daniel Alvarado State Bar No. 24120685 dalvarado@mklawgc.com Three Forest Plaza 12221 Merit Drive, Suite 1210 Dallas, TX 75251 (469) 916-2552 (469) 916-2555(fax) Attorneys for Defendants Isl ina N. Kas l Susan A. Allen Susan C. Austin KASTL LAW, P.c. 4144 North Central Expressway Suite 1000 Dallas, Texas, 75204 (214) 821 -0230 (214)821-0231 fax Attorney for Plaintiff FIRST AMENDED AGREED 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. Sandra Gomez on behalf of Kristina Kastl Bar No. 24025467 sgomez@kastllaw.com Envelope ID: 72928392 Status as of 2/21/2023 11:20 AM CST Associated Case Party: CESAR ESPARZA Name BarNumber Email TimestampSubmitted Status Kristina N.Kast| kkastl@kastllaw.com 2/20/2023 5:06:09 PM SENT Sandra Gomez sgomez@kastllaw.com 2/20/2023 5:06:09 PM SENT Kristina N.Kastl eservice@kastllaw.com 2/20/2023 5:06:09 PM SENT Sorana Ban sban@kastilaw.com 2/20/2023 5:06:09 PM SENT Associated Case Party: CP&Y, INC. Name BarNumber Email TimestampSubmitted Status Michael Miller mmiller@mklawpc.com 2/20/2023 5:06:09 PM SENT Robyn Cruze rcruze@mklawpc.com 2/20/2023 5:06:09 PM SENT Debra Scott dscott@mklawpc.com 2/20/2023 5:06:09 PM SENT Daniel Alvarado dalvarado@mklawpc.com 2/20/2023 5:06:09 PM SENT Roxana Esquivel resquivel@mklawpc.com 2/20/2023 5:06:09 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status KRISTINA NKASTL eservice@kastllaw.com 2/20/2023 5:06:09 PM SENT