Document for YOLANDA M ALLEN vs. SAMI HABASH, et al

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                                Cause N0. DC-19-06208

YOLANDA M. ALLEN,                                                  §        IN   THE DISTRICT COURT
                                                                   §
       Plaintiff,                                                  §
                                                                   §
V.                                                                 §
                                                                   §
SAMI HABASH and CHRISTINE SAHOURY,                                 §        160th     DISTRICT COURT
                                                                   §
                                                                   §
       Defendants                                                  §
                                                                   §
v.                                                                 §
                                                                   §
VICKI ALEXANDER,                                                   §
                                                                   §
       Third-Party Defendant.                                      §        DALLAS COUNTY, TEXAS

                      UNIFORM SCHEDULING ORDER (LEVEL 1 OR 2)

         In accordance With Rules 166, 190 and 192 0fthe Texas Rules ofCiVil Procedure, the Court
 makes   the following order to control discovery               and the schedule 0f this cause:


         1.      This case will be ready and           is set   for trial at 8:30   am. 0n August   1,   2020   (the "Initial
 Trial Setting"). Reset 0r continuance            of the        Initial Trial Setting Will     not alter any deadlines
 established in this Order, except those set out in paragraph 7 of this Order, or established                        by   the
 Texas Rules of Civil Procedure, unless otherwise provided by order. If not reached as set, the case
 may be carried for that week. FAILURE TO COMPLY WITH THE DEADLINES
 CONTAINED HEREIN SHALL NOT SUPPORT A MOTION TO CONTINUE THIS
 MATTER.

         2.      Unless otherwise ordered, discovery in                this case Will    be controlled by:


          K       Rule 190.3 (Level 2)

 0f the Texas Rules 0f Civil Procedure. Except by agreement 0f the party, leave 0f court, or where
 expressly authorized by the Texas Rules of Civil Procedure, no party may obtain discovery 0f
 information subj ect to disclosure under Rule 194 by any other form of discovery.


         3.      Any   obj ection 0r    motion    to exclude 0r limit expert testimony           due   to qualification     of
 the expert or reliability 0f the opinions       must be filed n0         later   than seven (7) days after the close of
 the discovery period, or such objection          is   waived.     Any   such objection not heard 30 days prior to
 the Initial Trial Setting   is   waived.   Any motion t0 compel responses t0             discovery (other than relating
 to factual matters arising after the       end of the discovery period) must be filed n0            later than seven (7)
 days after the close 0f the discovery period 0r such complaint                  is   waived, except for the sanction of
 exclusion under Rule 193.6.
            4.         Any amended pleadings asserting new causes                  0f action 0r affirmative defenses must
be filed no         later   than thirty (3 0) days before the end 0f the discovery period and any other amended
pleadings must be filed no later than seven (7) days after the end 0f the discovery period. Amended
pleadings responsive to timely filed pleadings under this schedule may be filed after the deadline for
amended pleadings                Within two (2) weeks after the pleading to Which they respond. Except With leave
                             if filed

of court,   TRCP       166a motions must be heard n0 later than thirty (3 0) days before trial.


            5.         N0 additional parties may be joined more than five (5) months after entry 0fthis order
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 0f this Order 0n
the   new party       concurrently With the pleading joining that party.


            6.a.   The     parties shall mediate this case      no        than thirty (3 0) days before the Initial Trial
                                                                      later

Setting, unless otherwise provided             by court      order.   Mediation Will be conducted in accordance with
the Standing DallasCounty Civil District Court Order Regarding Mediation, which is available
from the Dallas County ADR Coordinator. A11 parties shall contact the mediator t0 arrange the
mediation. Motions for continuances 0f trial will not be granted due t0 failure t0 mediate.


            b.    The mediator has been selected by agreement 0f the parties: Accordingly, Jim
            Cuaderes is hereby appointed mediator. Any mediator substitution requested more than
            90 days    after the date 0f this order may only be made by motion                for submission to the Court
            for    good cause and under extraordinary circumstances.


Fourteen (14) days before the Initial Trial Setting, the parties shall exchange a list of exhibits,
including any demonstrative aids and affidavits, and shall exchange copies 0f any exhibits not
previously produced in discovery; over-designation                      is    strongly discouraged and   may be
sanctioned. Except for records t0 be offered by way of business record affidavits, each exhibit
must be identified separately and not by category 0r group designation. Rule 193.7 applies t0 this
designation.        On 0r before ten (10)      days before the        Initial Trial Setting, the   attorneys in charge for
all parties shall          meet   in person to confer   on   stipulations regarding the materials t0      be submitted t0
the Court under this paragraph and attempt t0                  maximize agreement 0n such           matters.   By 4 pm on
the Thursday before the Initial Trial Setting, the parties shall file with the Court the materials stated
in   Rule   166(e)-(l),       an estimate of the length 0f trial, designation 0f deposition testimony to be
offered in direct examination, and any motions in limine. Failure to file such materials                         may result
in dismissal for           want 0f prosecution 0r other appropriate             sanction.


Plaintiff/Plaintiffs counsel shall serve a              copy 0f       this    Order 0n any currently named defendant(s)
answering after            this date.




SIGNED ON:
                                                                        JUDGE PRESIDING

cc:   Counsel of Record/Pro Se Parties and Mediator
AGREED AND APPROVED:



  Tonvce Gustave
/s/

Tonyce Gustave
Attorney for Plaintiff Yolanda M. Allen



/s/   Marguerite Broussard
Marguerite Broussard
Attorney for Defendants Sami Habash and Christine Sahoury




                                            (signature attached)
Vicki Alexander — Pro Se
Third-Party Defendant
Plaintiff/Plaintiff’s   counsel shall serve a copy of this Order on any currently   named   defendant(s)
answering after this date.



SIGNED ON:
                                                         JUDGE PRESIDING

cc:   Counsel of Record/Pro Se Parties and Mediator



AGREED AND APPROVED:




Tonyce Gustave
Attorney for Plaintiff Yolanda            M. Allen




Marguerite Broussard
Attorney for Defendants Sami Habash and Christine Sahoury


                             ....-a   >




Vicki Alexander    {Pro Se
Third-Party Defqhdant