On June 14, 2023 a
Motion-Secondary
was filed
involving a dispute between
Hayman, Maureen E.,
and
Galveston Independent School District,
for Contract - Employment
in the District Court of Galveston County.
Preview
Filed: 9/13/2023 10:50 AM
Envelope No. 79496796
NO. 23-CV-0928
Maureen E. Hayman § IN THE DISTRICT COURT OF
§
VS. § GALVESTON COUNTY, TEXAS
§
Galveston Independent School District § 56TH JUDICIAL DISTRICT
AGREED DISCOVERY AND DOCKET CONTROL ORDER
1. December 1, 2023____ NEW PARTIES shall be joined and served by this date.
2. February 23, 2024___ EXPERTS for all Plaintiffs shall be designated by this date.
3. March 29, 2024______ EXPERTS for all OTHER PARTIES shall be designated by this
date (30 days from date Plaintiff’s experts are ordered to be
designated.) Any party designating a testifying expert witness is
ORDERED to provide no later than the dates set for such
designation the information set forth in Rule 194.2(f) and a written
report prepared by the expert setting the substance of the experts
opinions, unless a deposition is taken of the expert. An expert not
designated prior to the ordered deadlines shall not be permitted to
testify absent a showing of good cause.
4. May 24, 2024_____ ROBINSON CHALLENGES are to be filed and heard by this date.
5. May 3, 2024_______ DISCOVERY deadlines controlled by designation of case. Counsel
may by written agreement continue discovery beyond this deadline.
Such continued discovery, however, will not delay the trial date
without the Court’s approval.
___________ Level One-(Rule 190.2) Discovery shall be completed 30 days before
the date set for trial.
No. of hours per side for oral depositions: _______________
No. of written interrogatories that may be served by any party on
another party:
___________ (excluding interrogatories asking a party to identify or
authenticate specified documents).
___________ Level Two-(Rule 190.3) Discovery shall be completed the earlier of
30 days before the date set for trial or 9 months after the date of the
first oral deposition of the due date of the first response to written
discovery.
___________ Level Three-(Rule 190.4) Discovery shall be completed by this date.
No. of hours per side for oral depositions: _______________
No. of written interrogatories that may be served by any party on
another party:
___________ (excluding interrogatories asking a party to identify or
authenticate specified documents).
Discovery and Docket Control Order -1- Revised 6/20
6. April 5, 2024______ Pleadings must be amended or supplemented by this date, except
by written agreement of all parties.
7. June 3, 2024______ Mediation shall be completed by this date. Report to be filed with
court on or before this date. Objections to mediation must be filed
within thirty days of this date (by __________)
All parties agree to participate in mediation with the following person to serve as mediator:
Name:________________________________________________________________
Address: ______________________________________________________________
Phone: _______________________________________________________________
Fax No: ______________________________________________________________
8. July 1, 2024_______ All hearing date and times are to be secured by the movant no later
than five weeks prior to the Pre-Trial Conference.
9. August 5, 2024____ at 10 A.M. Pre-Trial Conference set. Court will only hear
announcement of parties and motions to continue at this setting. Failure to appear will be
grounds for dismissal for want of prosecution.
10. August 12, 2024 at 9 A.M. Trial by Jury is set for the one-week docket commencing
on this date. Prior to commencement of voir dire, parties are ordered to exchange the
following and discuss what the parties will agree to and what issues are contested:
Proposed jury instructions and questions
Motion in Limine
Exhibit List
Labeled and numbered exhibits
Witness lists (inform court at earliest opportunity of
scheduling problems relating to witnesses)
11. __xxxxx________ at _10:00___ _A.M. Bench Trial before Court is set.
12. All counsel will be required to file a joint report on the 3rd Monday in January and the 3rd
Monday in July of each year, in all cases involving in excess of 20 parties. Such report shall
inform the Court of the remaining parties and claims currently involved in the lawsuit and
the current attorney’s name, telephone number, fax number, e-mail address.
13. Any attorney representing a party who files bankruptcy during the pendency of the litigation
must submit a written report advising the court of the status of such bankruptcy on the 2nd
Monday in January and the 2nd Monday in July.
SIGNED: _________________________, 2023.
___________________________________________
JUDGE LONNIE COX
56TH JUDICIAL DISTRICT COURT
Discovery and Docket Control Order -2- Revised 6/20
APPROVED:
COUNSEL FOR PLAINTIFF:
___/s/ Charles Dunkel (by permission)__________
COUNSEL FOR DEFENDANT:
/s/ Celena Vinson___________________________
COUNSEL FOR OTHER PARTIES:
__________________________________
__________________________________
By requesting entry of this Discovery and Docket Control Order, counsel acknowledge they
are aware of the deadlines, and acknowledge there is no guarantee of a continuance.
CERTIFICATE OF SERVICE
I hereby certify that on September 13, 2023, a true and correct copy of the foregoing
document was served on all counsel and pro se parties of record via electronic transmittal,
facsimile and/or first-class mail in accordance with the Texas Rules of Civil Procedure.
/s/ Celena C. Vinson
Celena C. Vinson
4856-3666-7007, v. 1
Discovery and Docket Control Order -3- Revised 6/20
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.
Linda Price on behalf of Celena Vinson
Bar No. 24037651
lprice@thompsonhorton.com
Envelope ID: 79496796
Filing Code Description: Proposed Order
Filing Description: Discovery and Docket Control Order
Status as of 9/13/2023 11:13 AM CST
Associated Case Party: Galveston Independent School District
Name BarNumber Email TimestampSubmitted Status
Linda Price lprice@thompsonhorton.com 9/13/2023 10:50:36 AM SENT
Celena Vinson cvinson@thompsonhorton.com 9/13/2023 10:50:36 AM SENT
Vanisia Blackmon vblackmon@thompsonhorton.com 9/13/2023 10:50:36 AM SENT
Dena Moghtader dmoghtader@thompsonhorton.com 9/13/2023 10:50:36 AM SENT
Associated Case Party: MaureenE.Hayman
Name BarNumber Email TimestampSubmitted Status
Ashley Thomson athomson@tdunklaw.com 9/13/2023 10:50:36 AM SENT
Charles PDunkel cdunkel@tdunklaw.com 9/13/2023 10:50:36 AM SENT
Raven Keeler rkeeler@tdunklaw.com 9/13/2023 10:50:36 AM SENT
Document Filed Date
September 13, 2023
Case Filing Date
June 14, 2023
Category
Contract - Employment
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Preview
Filed: 9/13/2023 10:50 AM Envelope No. 79496796 NO. 23-CV-0928 Maureen E. Hayman § IN THE DISTRICT COURT OF § VS. § GALVESTON COUNTY, TEXAS § Galveston Independent School District § 56TH JUDICIAL DISTRICT AGREED DISCOVERY AND DOCKET CONTROL ORDER 1. December 1, 2023____ NEW PARTIES shall be joined and served by this date. 2. February 23, 2024___ EXPERTS for all Plaintiffs shall be designated by this date. 3. March 29, 2024______ EXPERTS for all OTHER PARTIES shall be designated by this date (30 days from date Plaintiff’s experts are ordered to be designated.) Any party designating a testifying expert witness is ORDERED to provide no later than the dates set for such designation the information set forth in Rule 194.2(f) and a written report prepared by the expert setting the substance of the experts opinions, unless a deposition is taken of the expert. An expert not designated prior to the ordered deadlines shall not be permitted to testify absent a showing of good cause. 4. May 24, 2024_____ ROBINSON CHALLENGES are to be filed and heard by this date. 5. May 3, 2024_______ DISCOVERY deadlines controlled by designation of case. Counsel may by written agreement continue discovery beyond this deadline. Such continued discovery, however, will not delay the trial date without the Court’s approval. ___________ Level One-(Rule 190.2) Discovery shall be completed 30 days before the date set for trial. No. of hours per side for oral depositions: _______________ No. of written interrogatories that may be served by any party on another party: ___________ (excluding interrogatories asking a party to identify or authenticate specified documents). ___________ Level Two-(Rule 190.3) Discovery shall be completed the earlier of 30 days before the date set for trial or 9 months after the date of the first oral deposition of the due date of the first response to written discovery. ___________ Level Three-(Rule 190.4) Discovery shall be completed by this date. No. of hours per side for oral depositions: _______________ No. of written interrogatories that may be served by any party on another party: ___________ (excluding interrogatories asking a party to identify or authenticate specified documents). Discovery and Docket Control Order -1- Revised 6/20 6. April 5, 2024______ Pleadings must be amended or supplemented by this date, except by written agreement of all parties. 7. June 3, 2024______ Mediation shall be completed by this date. Report to be filed with court on or before this date. Objections to mediation must be filed within thirty days of this date (by __________) All parties agree to participate in mediation with the following person to serve as mediator: Name:________________________________________________________________ Address: ______________________________________________________________ Phone: _______________________________________________________________ Fax No: ______________________________________________________________ 8. July 1, 2024_______ All hearing date and times are to be secured by the movant no later than five weeks prior to the Pre-Trial Conference. 9. August 5, 2024____ at 10 A.M. Pre-Trial Conference set. Court will only hear announcement of parties and motions to continue at this setting. Failure to appear will be grounds for dismissal for want of prosecution. 10. August 12, 2024 at 9 A.M. Trial by Jury is set for the one-week docket commencing on this date. Prior to commencement of voir dire, parties are ordered to exchange the following and discuss what the parties will agree to and what issues are contested: Proposed jury instructions and questions Motion in Limine Exhibit List Labeled and numbered exhibits Witness lists (inform court at earliest opportunity of scheduling problems relating to witnesses) 11. __xxxxx________ at _10:00___ _A.M. Bench Trial before Court is set. 12. All counsel will be required to file a joint report on the 3rd Monday in January and the 3rd Monday in July of each year, in all cases involving in excess of 20 parties. Such report shall inform the Court of the remaining parties and claims currently involved in the lawsuit and the current attorney’s name, telephone number, fax number, e-mail address. 13. Any attorney representing a party who files bankruptcy during the pendency of the litigation must submit a written report advising the court of the status of such bankruptcy on the 2nd Monday in January and the 2nd Monday in July. SIGNED: _________________________, 2023. ___________________________________________ JUDGE LONNIE COX 56TH JUDICIAL DISTRICT COURT Discovery and Docket Control Order -2- Revised 6/20 APPROVED: COUNSEL FOR PLAINTIFF: ___/s/ Charles Dunkel (by permission)__________ COUNSEL FOR DEFENDANT: /s/ Celena Vinson___________________________ COUNSEL FOR OTHER PARTIES: __________________________________ __________________________________ By requesting entry of this Discovery and Docket Control Order, counsel acknowledge they are aware of the deadlines, and acknowledge there is no guarantee of a continuance. CERTIFICATE OF SERVICE I hereby certify that on September 13, 2023, a true and correct copy of the foregoing document was served on all counsel and pro se parties of record via electronic transmittal, facsimile and/or first-class mail in accordance with the Texas Rules of Civil Procedure. /s/ Celena C. Vinson Celena C. Vinson 4856-3666-7007, v. 1 Discovery and Docket Control Order -3- Revised 6/20 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. Linda Price on behalf of Celena Vinson Bar No. 24037651 lprice@thompsonhorton.com Envelope ID: 79496796 Filing Code Description: Proposed Order Filing Description: Discovery and Docket Control Order Status as of 9/13/2023 11:13 AM CST Associated Case Party: Galveston Independent School District Name BarNumber Email TimestampSubmitted Status Linda Price lprice@thompsonhorton.com 9/13/2023 10:50:36 AM SENT Celena Vinson cvinson@thompsonhorton.com 9/13/2023 10:50:36 AM SENT Vanisia Blackmon vblackmon@thompsonhorton.com 9/13/2023 10:50:36 AM SENT Dena Moghtader dmoghtader@thompsonhorton.com 9/13/2023 10:50:36 AM SENT Associated Case Party: MaureenE.Hayman Name BarNumber Email TimestampSubmitted Status Ashley Thomson athomson@tdunklaw.com 9/13/2023 10:50:36 AM SENT Charles PDunkel cdunkel@tdunklaw.com 9/13/2023 10:50:36 AM SENT Raven Keeler rkeeler@tdunklaw.com 9/13/2023 10:50:36 AM SENT