On September 03, 2019 a
Motion-Secondary
was filed
involving a dispute between
Drummond, Kristine,
and
Castillo, Julio,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
CAUSE NO. DC-19-13684
KRISTINE DRUMMOND § IN THE DISTRICT COURT
Plaintiff g
vs. g 44TH JUDICIAL DISTRICT
JULIO CASTILLO g
Defendant. g DALLAS COUNTY, TEXAS
AMENDED AGREED SCHEDULING ORDER
In accordance with Rules 166, 190 and 192 of the Texas Rules of Civil Procedure, the
Court makes the following order to control the schedule of this cause.
1. This case will be ready and is set for jury trial on J_ulv 12, 2021 at 9:00 a.m. (the
“Trial Setting).
2. Pretrial matters will be completed by the following dates:
Amended pleadings asserting new April 30, 2021
claims or defenses
Fact discovery closes May 14, 2021
Party seeking afrmative relief to February 12, 2021
designate experts & provide reports
Party opposing afrmative relief to March 15, 2021
designate experts & provide reports
Designation of rebuttal experts and April 14, 2021
provide reports
All expert discovery closes June 14, 2021
The parties may by written agreement alter these deadlines. Amended pleadings responsive
to timely led pleadings under this schedule may be led after the deadline for amended
pleadings ifled within two (2) weeks after the pleading to which they respond. Except by
agreement of the party, leave of court, or where expressly authorized by the Texas Rules
of Civil Procedure, no party may obtain discovery of information subject to disclosure
under Rule 194 by any other form of discovery.
. Any objection or motion to exclude or limit expert testimony due to qualication of
the expert or reliability of the opinions must be led no later than seven (7) days
after the close of expert discovery, or such objection is waived. Any motion to
compel responses to discovery (other than relating to factual matters arising after the
end of fact discovery) must be led no later than seven (7) days after the close of
fact discovery or such complaint is waived, except for the sanction of exclusion
under Rule 193.6.
. No additional parties may be joined more than eight (8) months after commencement
of this case except on motion for leave showing good cause. This paragraph does not
otherwise alter the requirements of Rule 38. The party joining an additional party
shall serve a copy of this Order on the new party concurrently with the pleading
joining that party.
. The parties shall mediate this case no later than thirty (30) days before the Trial
Setting, unless otherwise provided by court order. Mediation will be conducted in
accordance with the Standing Dallas County Civil District Court Order Regarding
Mediation, which is available from the Dallas County ADR Coordinator. All parties
shall contact the mediator to arrange the mediation.
The mediator has been selected by agreement of the parties: Jim Juneau with
Gilbert Mediation Group is hereby appointed mediator. Any mediator substitution
requested more than ninety (90) days after the date of this order may only be made by
motion for submission to the Court for good cause and under extraordinary
circumstances.
. Fourteen (l4) days before the TrialSetting, the parties shall exchange designations of
deposition testimony to be offered in direct examination and a list of exhibits,
including any demonstrative aids and afdavits, and shall exchange copies of any
exhibits not previously produced in discovery; over-designation is strongly
discouraged and may be sanctioned. Except for records to be offered by way of
business record afdavits, each exhibit must be identied separately and not by
category or group designation. Ten (10) days before the Trial Setting, the parties
shall exchange in writing their objections to the opposing party’s proposed exhibits,
including objections under Rule 193.7, and deposition testimony. On or before ten
(10) days before the Trial Setting, the attorneys in charge for all parties shall meet in
person to confer on stipulations regarding the materials to be submitted to the Court
under this paragraph and attempt to maximize agreement on such matters. By 4 p.m.
on the Thursday before the Trial Setting, the parties shall le with the Court the
materials stated in Rule l66(d)—(m), an estimate length of trial, designation of
deposition testimony to be offered in direct examination, and any motions in limine.
Failure to le such material may result in dismissal for want of prosecution or other
appropriate sanction.
Plaintiff/Plaintiff‘s counsel shall serve a copy of this Order on any currently named
defendant(s) answers after this date.
SIGNED THIS DAY OF , 2020.
DISTRICT JUDGE
AGREED :
/s/Justin Smith *with permission
Justin Smith
Glenn Perry
SLOAN, HATCHER, PERRY, RUNGE,
ROBERTSON & SMITH
ATTORNEYS FOR PLAINTIFF
/s/ Thomas G. Jacks
Thomas G. Jacks
Jessica Junek
HARTLINE BARGER LLP
ATTORNEYS FOR DEFENDANT
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.
Jessica Junek on behalf of Thomas Jacks
Bar No. 24067681
jjunek@hartlinebarger.com
Envelope ID: 47858930
Status as of 1 1/5/2020 4:26 PM CST
Associated Case Party: JULIO CASTILLO
Name BarNumber Email TimestampSubmitted Status
Thomas Jacks tjacks@hartlinebarger.com 11/5/2020 4:10:01 PM SENT
Jessica Junek JJunek@hartlinebarger.com 11/5/2020 4:10:01 PM SENT
Lori Tiner LTiner@hartlinebarger.com 11/5/2020 4:10:01 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Glenn APerry gap@sloanfirm.com 11/5/2020 4:10:01 PM SENT
Lida Vega lvega@sloanfirm.com 11/5/2020 4:1 0:01 PM SENT
Justin A. Smith jsmith@sloanfirm.com 11/5/2020 4:10:01 PM SENT
Kendon Womack kwomack@sloanfirm.com 11/5/2020 4:10:01 PM SENT
Document Filed Date
November 05, 2020
Case Filing Date
September 03, 2019
Category
MOTOR VEHICLE ACCIDENT
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Preview
CAUSE NO. DC-19-13684 KRISTINE DRUMMOND § IN THE DISTRICT COURT Plaintiff g vs. g 44TH JUDICIAL DISTRICT JULIO CASTILLO g Defendant. g DALLAS COUNTY, TEXAS AMENDED AGREED SCHEDULING ORDER In accordance with Rules 166, 190 and 192 of the Texas Rules of Civil Procedure, the Court makes the following order to control the schedule of this cause. 1. This case will be ready and is set for jury trial on J_ulv 12, 2021 at 9:00 a.m. (the “Trial Setting). 2. Pretrial matters will be completed by the following dates: Amended pleadings asserting new April 30, 2021 claims or defenses Fact discovery closes May 14, 2021 Party seeking afrmative relief to February 12, 2021 designate experts & provide reports Party opposing afrmative relief to March 15, 2021 designate experts & provide reports Designation of rebuttal experts and April 14, 2021 provide reports All expert discovery closes June 14, 2021 The parties may by written agreement alter these deadlines. Amended pleadings responsive to timely led pleadings under this schedule may be led after the deadline for amended pleadings ifled within two (2) weeks after the pleading to which they respond. Except by agreement of the party, leave of court, or where expressly authorized by the Texas Rules of Civil Procedure, no party may obtain discovery of information subject to disclosure under Rule 194 by any other form of discovery. . Any objection or motion to exclude or limit expert testimony due to qualication of the expert or reliability of the opinions must be led no later than seven (7) days after the close of expert discovery, or such objection is waived. Any motion to compel responses to discovery (other than relating to factual matters arising after the end of fact discovery) must be led no later than seven (7) days after the close of fact discovery or such complaint is waived, except for the sanction of exclusion under Rule 193.6. . No additional parties may be joined more than eight (8) months after commencement of this case except on motion for leave showing good cause. This paragraph does not otherwise alter the requirements of Rule 38. The party joining an additional party shall serve a copy of this Order on the new party concurrently with the pleading joining that party. . The parties shall mediate this case no later than thirty (30) days before the Trial Setting, unless otherwise provided by court order. Mediation will be conducted in accordance with the Standing Dallas County Civil District Court Order Regarding Mediation, which is available from the Dallas County ADR Coordinator. All parties shall contact the mediator to arrange the mediation. The mediator has been selected by agreement of the parties: Jim Juneau with Gilbert Mediation Group is hereby appointed mediator. Any mediator substitution requested more than ninety (90) days after the date of this order may only be made by motion for submission to the Court for good cause and under extraordinary circumstances. . Fourteen (l4) days before the TrialSetting, the parties shall exchange designations of deposition testimony to be offered in direct examination and a list of exhibits, including any demonstrative aids and afdavits, and shall exchange copies of any exhibits not previously produced in discovery; over-designation is strongly discouraged and may be sanctioned. Except for records to be offered by way of business record afdavits, each exhibit must be identied separately and not by category or group designation. Ten (10) days before the Trial Setting, the parties shall exchange in writing their objections to the opposing party’s proposed exhibits, including objections under Rule 193.7, and deposition testimony. On or before ten (10) days before the Trial Setting, the attorneys in charge for all parties shall meet in person to confer on stipulations regarding the materials to be submitted to the Court under this paragraph and attempt to maximize agreement on such matters. By 4 p.m. on the Thursday before the Trial Setting, the parties shall le with the Court the materials stated in Rule l66(d)—(m), an estimate length of trial, designation of deposition testimony to be offered in direct examination, and any motions in limine. Failure to le such material may result in dismissal for want of prosecution or other appropriate sanction. Plaintiff/Plaintiff‘s counsel shall serve a copy of this Order on any currently named defendant(s) answers after this date. SIGNED THIS DAY OF , 2020. DISTRICT JUDGE AGREED : /s/Justin Smith *with permission Justin Smith Glenn Perry SLOAN, HATCHER, PERRY, RUNGE, ROBERTSON & SMITH ATTORNEYS FOR PLAINTIFF /s/ Thomas G. Jacks Thomas G. Jacks Jessica Junek HARTLINE BARGER LLP ATTORNEYS FOR DEFENDANT 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. Jessica Junek on behalf of Thomas Jacks Bar No. 24067681 jjunek@hartlinebarger.com Envelope ID: 47858930 Status as of 1 1/5/2020 4:26 PM CST Associated Case Party: JULIO CASTILLO Name BarNumber Email TimestampSubmitted Status Thomas Jacks tjacks@hartlinebarger.com 11/5/2020 4:10:01 PM SENT Jessica Junek JJunek@hartlinebarger.com 11/5/2020 4:10:01 PM SENT Lori Tiner LTiner@hartlinebarger.com 11/5/2020 4:10:01 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Glenn APerry gap@sloanfirm.com 11/5/2020 4:10:01 PM SENT Lida Vega lvega@sloanfirm.com 11/5/2020 4:1 0:01 PM SENT Justin A. Smith jsmith@sloanfirm.com 11/5/2020 4:10:01 PM SENT Kendon Womack kwomack@sloanfirm.com 11/5/2020 4:10:01 PM SENT