Preview
CAUSE NO. DC-19-20410
ANTHONY HORTON, IN THE DISTRICT COURT
Plaintiff,
VS.
OOOOOOWOOOOOOOW'DOOOOOOW’DOOO
DALLAS COUNTY, TEXAS
JESUS VILLEDA ALVARADO and
BUHO ONE TRUCKING, LLC,
Defendants. 191“ JUDICIAL DISTRICT
AGREED UNIFORM SCHEDULING ORDER
(LEVEL III)
In accordance with Rules 166, 190, 191, and 192 0f the Texas Rules 0f Civil
Procedure, the Court makes the following Order t0 control the schedule 0f this cause.
1. “JURY TRIAL SETTING. This case shall be ready and is set for trial 0n
FEBRUARY 22, 2021. Reset 0r continuance 0f the Initial Trial Setting Will
not alter any deadlines established in this Order or established by the Texas
Rules 0f Civil Procedure, unless specifically provided by Order after Motion
showing good cause.
2. Pretrial matters Will be completed by the following dates:
a. deadline to join additional parties: OCTOBER 23, 2020
b. fact discovery closes: JANUARY 22, 2021
c. party seeking affirmative relief shall OCTOBER 23, 2020
designate experts and must provide
reports:
(expert reports are not required for
treating doctors)
d. party opposing affirmative relief shall NOVEMBER 24, 2020
designate experts and must provide
reports:
e. all experts deposed by: JANUARY 8, 2021
f. mediate with Ken Rubenstein by: JANUARY 8, 2021
AGREED UNIFORM SCHEDULING ORDER PAGE 1
P:\THE BASSETT FIRM FILES\American Sentinel\Horton vs. Buho One Trucking, LLC\Pleadings\Scheduling O.doc
g. date to amend or supplemental DECEMBER 24, 2020
pleadings:
h. date t0 file dispositive Motions JANUARY 15, 2021
i. Pre-Trial Conference
COURT T0
COMPLETE;
3. The parties may by written agreement alter these deadlines. Amended
pleadings responsive to timely filed pleadings under this schedule may be
filed after the deadline for amended pleadings filed Within two (2) weeks
if
after the pleading t0 which they respond. Except by agreement of the party,
leave 0f Court, or where expressly authorized by the Texas Rules 0f Civil
Procedure, n0 party may obtain discovery or information subject t0 disclosure
under Rule 194 by any other form 0f discovery.
4. Any objection 0r motion t0 exclude or limit expert testimony due t0
qualification 0f the expert 0r reliability 0f the opinions 0f the expert (Daubert
0r Robinson Challenges) must be filed by January 15, 2021. Any party filing
such a motion 0r challenge must obtain a hearing date prior to filing that
motion if possible. Otherwise, the party filing any such motion 0r challenge
shall, as soon as practicable, set the motion or challenge for oral hearing.
5. Each side may have 50 hours of depositions plus 6 hours per retained expert.
Furthermore, each party may have 25 interrogatories including subparts,
subject t0 the conditions of Rule 190.3(b)(2) and (3).
6. No additional parties may be joined after the deadline t0 join new parties
except 0n motion for leave showing good cause. This paragraph does not
otherwise alter the requirements of Texas Rule of Civil Procedure 38. The
party joining an additional party shall serve a copy of this Order 0n the new
party concurrently with the pleading joining that new party.
7. Affidavits t0 controvert any served or filed billing record affidavits must be
served 0n the other party in accordance with Section 18.001(e) of the Texas
Civil Practice and Remedies Code.
AGREED UNIFORM SCHEDULING ORDER PAGE 2
P:\THE BASSETT FIRM FILES\American Sentinel\Horton vs. Buho One Trucking, LLC\Pleadings\Scheduling O.doc
8. On, FEBUARY 08, 2021, fourteen (14) days before the Initial Trial Setting,
the parties shall exchange the following:
Proposed Charge;
Proposed Motions in Limine;
WQP‘PP‘?’ Proposed Exhibit List;
Proposed Witness List;
Reasonable, good faith estimate as to the length 0f trial; and
Page/Line Depositions.
SIGNED THIS THE DAY OF ,
2020.
DISTRICT JUDGE
AGREED UNIFORM SCHEDULING ORDER PAGE 3
P:\THE BASSETT FIRM FILES\American Sentinel\Horton vs. Buho One Trucking, LLC\Pleadings\Scheduling O.doc
Agreed as to form and substance:
/s/Mike H. Bassett
MIKE H. BASSETT
SBN: 01890500
mbassett@thebassettfim.com
RON T. CAPEHART
SBN: 24009939
rcapehart@thebassettfirm.com
Two Turtle Creek Village
3838 Oak Lawn Avenue, Suite 1300
Dallas, Texas 75219
(214) 219—9900 Telephone
(214) 219—9456 Facsimile
eSerVice: efi1e@thebassettfirm.com
ATTORNEYS FOR DEFENDANTS,
JESUS VILLEDA ALVARADO AND
BUHO ONE TRUCKING, LLC
And
SLOAN, HATCHER, PERRY, RUNGE, ROBERTSON, & SMITH
/s/ Carson R. Runge (with permission)
CARSON R. RUNGE
SBN: 24059262
crun e sloanfirm.com
BRANDON L. BEAGLEY
SBN: 24102824
bbeagley®sloanfirmcom
101 East Whaley St.
PO Box 2909
Longview, Texas 75606
ATTORNEY FOR PLAINTIFF
ANTHONY HORTON
AGREED UNIFORM SCHEDULING ORDER PAGE 4
P:\THE BASSETT FIRM FILES\American Sentinel\Horton vs. Buho One Trucking, LLC\Pleadiugs\Scheduling O.d0c
Preview
CAUSE NO. DC-19-20410 ANTHONY HORTON, IN THE DISTRICT COURT Plaintiff, VS. OOOOOOWOOOOOOOW'DOOOOOOW’DOOO DALLAS COUNTY, TEXAS JESUS VILLEDA ALVARADO and BUHO ONE TRUCKING, LLC, Defendants. 191“ JUDICIAL DISTRICT AGREED UNIFORM SCHEDULING ORDER (LEVEL III) In accordance with Rules 166, 190, 191, and 192 0f the Texas Rules 0f Civil Procedure, the Court makes the following Order t0 control the schedule 0f this cause. 1. “JURY TRIAL SETTING. This case shall be ready and is set for trial 0n FEBRUARY 22, 2021. Reset 0r continuance 0f the Initial Trial Setting Will not alter any deadlines established in this Order or established by the Texas Rules 0f Civil Procedure, unless specifically provided by Order after Motion showing good cause. 2. Pretrial matters Will be completed by the following dates: a. deadline to join additional parties: OCTOBER 23, 2020 b. fact discovery closes: JANUARY 22, 2021 c. party seeking affirmative relief shall OCTOBER 23, 2020 designate experts and must provide reports: (expert reports are not required for treating doctors) d. party opposing affirmative relief shall NOVEMBER 24, 2020 designate experts and must provide reports: e. all experts deposed by: JANUARY 8, 2021 f. mediate with Ken Rubenstein by: JANUARY 8, 2021 AGREED UNIFORM SCHEDULING ORDER PAGE 1 P:\THE BASSETT FIRM FILES\American Sentinel\Horton vs. Buho One Trucking, LLC\Pleadings\Scheduling O.doc g. date to amend or supplemental DECEMBER 24, 2020 pleadings: h. date t0 file dispositive Motions JANUARY 15, 2021 i. Pre-Trial Conference COURT T0 COMPLETE; 3. The parties may by written agreement alter these deadlines. Amended pleadings responsive to timely filed pleadings under this schedule may be filed after the deadline for amended pleadings filed Within two (2) weeks if after the pleading t0 which they respond. Except by agreement of the party, leave 0f Court, or where expressly authorized by the Texas Rules 0f Civil Procedure, n0 party may obtain discovery or information subject t0 disclosure under Rule 194 by any other form 0f discovery. 4. Any objection 0r motion t0 exclude or limit expert testimony due t0 qualification 0f the expert 0r reliability 0f the opinions 0f the expert (Daubert 0r Robinson Challenges) must be filed by January 15, 2021. Any party filing such a motion 0r challenge must obtain a hearing date prior to filing that motion if possible. Otherwise, the party filing any such motion 0r challenge shall, as soon as practicable, set the motion or challenge for oral hearing. 5. Each side may have 50 hours of depositions plus 6 hours per retained expert. Furthermore, each party may have 25 interrogatories including subparts, subject t0 the conditions of Rule 190.3(b)(2) and (3). 6. No additional parties may be joined after the deadline t0 join new parties except 0n motion for leave showing good cause. This paragraph does not otherwise alter the requirements of Texas Rule of Civil Procedure 38. The party joining an additional party shall serve a copy of this Order 0n the new party concurrently with the pleading joining that new party. 7. Affidavits t0 controvert any served or filed billing record affidavits must be served 0n the other party in accordance with Section 18.001(e) of the Texas Civil Practice and Remedies Code. AGREED UNIFORM SCHEDULING ORDER PAGE 2 P:\THE BASSETT FIRM FILES\American Sentinel\Horton vs. Buho One Trucking, LLC\Pleadings\Scheduling O.doc 8. On, FEBUARY 08, 2021, fourteen (14) days before the Initial Trial Setting, the parties shall exchange the following: Proposed Charge; Proposed Motions in Limine; WQP‘PP‘?’ Proposed Exhibit List; Proposed Witness List; Reasonable, good faith estimate as to the length 0f trial; and Page/Line Depositions. SIGNED THIS THE DAY OF , 2020. DISTRICT JUDGE AGREED UNIFORM SCHEDULING ORDER PAGE 3 P:\THE BASSETT FIRM FILES\American Sentinel\Horton vs. Buho One Trucking, LLC\Pleadings\Scheduling O.doc Agreed as to form and substance: /s/Mike H. Bassett MIKE H. BASSETT SBN: 01890500 mbassett@thebassettfim.com RON T. CAPEHART SBN: 24009939 rcapehart@thebassettfirm.com Two Turtle Creek Village 3838 Oak Lawn Avenue, Suite 1300 Dallas, Texas 75219 (214) 219—9900 Telephone (214) 219—9456 Facsimile eSerVice: efi1e@thebassettfirm.com ATTORNEYS FOR DEFENDANTS, JESUS VILLEDA ALVARADO AND BUHO ONE TRUCKING, LLC And SLOAN, HATCHER, PERRY, RUNGE, ROBERTSON, & SMITH /s/ Carson R. Runge (with permission) CARSON R. RUNGE SBN: 24059262 crun e sloanfirm.com BRANDON L. BEAGLEY SBN: 24102824 bbeagley®sloanfirmcom 101 East Whaley St. PO Box 2909 Longview, Texas 75606 ATTORNEY FOR PLAINTIFF ANTHONY HORTON AGREED UNIFORM SCHEDULING ORDER PAGE 4 P:\THE BASSETT FIRM FILES\American Sentinel\Horton vs. Buho One Trucking, LLC\Pleadiugs\Scheduling O.d0c