On January 08, 2021 a
Motion-Secondary
was filed
involving a dispute between
Williams, Corintha,
and
Harvey, Patricia,
for Injury/Damage - Motor Vehicle
in the District Court of Galveston County.
Preview
Received 4/6/2021 1:33 PM
Envelope No. 52171162
CAUSE NO. ____________21-CV-0029_____________
CORINTHA WILLIAMS
_________________________________ ) IN THE JUDICIAL DISTRICT COURT
)
VS ) OF GALVESTON COUNTY, TEXAS
)
PATRICIA HARVEY
________________________________ ) 212TH DISTRICT COURT
CIVIL DISCOVERY AND DOCKET CONTROL ORDER
1. 12/01/2022 NEW PARTIES joined and served by this date. No parties may be added after this
date without approval by the Court. Approval after this date is less likely to be granted if a delay
of the trial would result.
2. 01/09/2022 EXPERTS for all Plaintiffs shall be designated by this date.
3. 02/09/2022 EXPERTS for all OTHER PARTIES shall be designated by this date. 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 expert’s opinions, unless a deposition is taken of the expert.
An expert not designated prior to the ordered deadline shall not be permitted to testify absent a
showing of good cause.
4. 04/09/2022 ROBINSON CHALLENGES are to be filed and heard by this date.
5. 04/09/2022 DISCOVERY deadlines controlled by designation of case (indicate which applies).
Counsel may in written agreement continue discovery beyond this deadline. Such continued
discovery, however, will not delay the trial date.
___/___/___Level One (Rule 190.2) and Level Two (Rule 109.3). Discovery shall be completed 30
days before the date set for trial.
04/09/2022 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.
6. Electronically Stored Information Discovery: (Indicate which applies.)
___/___/___Lawyers will abide by the Court’s Protocol for Discovery of ESI and have a Discovery
Planning Conference by this date.
___/___/___Lawyers will abide by the Court’s Order Relating to the Discovery of ESI. If lawyers
are unable to agree to any of the requirements of this Court Order, they will secure a setting for a
hearing date before this date.
__________Lawyers do not anticipate the need to abide by either the Court’s Protocol or Order
regarding ESI since prosecuting and defending these claims will not depend on large amounts of
ESI.
7. 04/09/2022 Pleadings must be amended or supplemented by this date, except by written
agreement of ALL parties.
8. 03/10/2022 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 30 days of this date. Case will not
proceed to trial unless mediation is complete. All parties agree to participate in mediation with
the following person to serve as mediator:
Name: Jose Lopez
Address: 4601 Washington Ave, Suite 200
Houston, Texas 77007
Phone: (713) 624-1070_____Fax: _(713) 961-0638_______
Email: Info@lawlopez.net
Plaintiff’s attorney shall provide a copy of the DCO to the mediator named herein.
9. 03/28/2022 DEADLINE TO FILE ALL MOTIONS, except Motions in Limine, AND FOR MOVANT TO
SECURE DATES AND TIMES FOR HEARINGS. NO HEARINGS WILL BE SET UNTIL A MOTION AND
ORDER SETTING HEARING ARE ON FILE WITH THE CLERK. This includes motions to exclude
expert testimony and any other challenges to expert testimony (6 weeks prior to pre-trial).
10. 04/29/2022 at 9:00 a.m. Pre-Trial Conference set. Court will only hear announcement of parties
and motions to continue at this setting. Parties to submit Exhibits for trial at this time. Failure
to appear will be grounds for dismissal for want of prosecution.
11. 05/09/2022 at 9:00 a.m. Trial by Jury is set for 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:
__X___Proposed jury instructions and questions
__X _Motion in Limine
__X___Exhibit list
__X___Labeled and numbered exhibits
__X___Witness lists (inform Court at earliest opportunity of scheduling problems
relating to witnesses).
12. ___/___/___at__________ ___.m. Bench Trial before Court is set.
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.
14. Proposed Findings of Fact and Conclusions of Law to be exchanged prior to trial date.
15. All attorneys shall abide by the Supreme Court of Texas and The Court of Criminal Appeals Texas
Lawyer’s Creed.
16. Cases not reached for trial during a trial sitting will be notified by the Court. Parties will then
need to file with the District Clerk a new Docket Control Order and a Motion for Continuance if
needed.
Written notice must be given to the Court of any changes in this DCO. This includes settlement, Rule
11 Agreements, cancellation of hearings, etc. Numbers 9, 10, 11 or 12 cannot be changed without
leave of the Court.
SIGNED ON ___________________________________, 2______.
_____________________________________________
JUDGE PATRICIA GRADY
212th Judicial District Court
APPROVED:
COUNSEL FOR PLAINTIFF: COUNSEL FOR DEFENDANT: Digitally signed by: T. Philip Washington
T. Philip DN: CN = T. Philip Washington email =
/s/ Priscilla C. Tran
______________________________________ ________________________________
twatb@allstate.com C = US O = Lisa
Washington Chastain & Associates
Pusch and Nguyen Law Firm PPLC
Date: 2021.04.06 12:54:28 -06'00'
______________________________________ _ Lisa Chastain & Associates
________________
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.
Document Filed Date
April 06, 2021
Case Filing Date
January 08, 2021
Category
Injury/Damage - Motor Vehicle
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Preview
Received 4/6/2021 1:33 PM Envelope No. 52171162 CAUSE NO. ____________21-CV-0029_____________ CORINTHA WILLIAMS _________________________________ ) IN THE JUDICIAL DISTRICT COURT ) VS ) OF GALVESTON COUNTY, TEXAS ) PATRICIA HARVEY ________________________________ ) 212TH DISTRICT COURT CIVIL DISCOVERY AND DOCKET CONTROL ORDER 1. 12/01/2022 NEW PARTIES joined and served by this date. No parties may be added after this date without approval by the Court. Approval after this date is less likely to be granted if a delay of the trial would result. 2. 01/09/2022 EXPERTS for all Plaintiffs shall be designated by this date. 3. 02/09/2022 EXPERTS for all OTHER PARTIES shall be designated by this date. 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 expert’s opinions, unless a deposition is taken of the expert. An expert not designated prior to the ordered deadline shall not be permitted to testify absent a showing of good cause. 4. 04/09/2022 ROBINSON CHALLENGES are to be filed and heard by this date. 5. 04/09/2022 DISCOVERY deadlines controlled by designation of case (indicate which applies). Counsel may in written agreement continue discovery beyond this deadline. Such continued discovery, however, will not delay the trial date. ___/___/___Level One (Rule 190.2) and Level Two (Rule 109.3). Discovery shall be completed 30 days before the date set for trial. 04/09/2022 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. 6. Electronically Stored Information Discovery: (Indicate which applies.) ___/___/___Lawyers will abide by the Court’s Protocol for Discovery of ESI and have a Discovery Planning Conference by this date. ___/___/___Lawyers will abide by the Court’s Order Relating to the Discovery of ESI. If lawyers are unable to agree to any of the requirements of this Court Order, they will secure a setting for a hearing date before this date. __________Lawyers do not anticipate the need to abide by either the Court’s Protocol or Order regarding ESI since prosecuting and defending these claims will not depend on large amounts of ESI. 7. 04/09/2022 Pleadings must be amended or supplemented by this date, except by written agreement of ALL parties. 8. 03/10/2022 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 30 days of this date. Case will not proceed to trial unless mediation is complete. All parties agree to participate in mediation with the following person to serve as mediator: Name: Jose Lopez Address: 4601 Washington Ave, Suite 200 Houston, Texas 77007 Phone: (713) 624-1070_____Fax: _(713) 961-0638_______ Email: Info@lawlopez.net Plaintiff’s attorney shall provide a copy of the DCO to the mediator named herein. 9. 03/28/2022 DEADLINE TO FILE ALL MOTIONS, except Motions in Limine, AND FOR MOVANT TO SECURE DATES AND TIMES FOR HEARINGS. NO HEARINGS WILL BE SET UNTIL A MOTION AND ORDER SETTING HEARING ARE ON FILE WITH THE CLERK. This includes motions to exclude expert testimony and any other challenges to expert testimony (6 weeks prior to pre-trial). 10. 04/29/2022 at 9:00 a.m. Pre-Trial Conference set. Court will only hear announcement of parties and motions to continue at this setting. Parties to submit Exhibits for trial at this time. Failure to appear will be grounds for dismissal for want of prosecution. 11. 05/09/2022 at 9:00 a.m. Trial by Jury is set for 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: __X___Proposed jury instructions and questions __X _Motion in Limine __X___Exhibit list __X___Labeled and numbered exhibits __X___Witness lists (inform Court at earliest opportunity of scheduling problems relating to witnesses). 12. ___/___/___at__________ ___.m. Bench Trial before Court is set. 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. 14. Proposed Findings of Fact and Conclusions of Law to be exchanged prior to trial date. 15. All attorneys shall abide by the Supreme Court of Texas and The Court of Criminal Appeals Texas Lawyer’s Creed. 16. Cases not reached for trial during a trial sitting will be notified by the Court. Parties will then need to file with the District Clerk a new Docket Control Order and a Motion for Continuance if needed. Written notice must be given to the Court of any changes in this DCO. This includes settlement, Rule 11 Agreements, cancellation of hearings, etc. Numbers 9, 10, 11 or 12 cannot be changed without leave of the Court. SIGNED ON ___________________________________, 2______. _____________________________________________ JUDGE PATRICIA GRADY 212th Judicial District Court APPROVED: COUNSEL FOR PLAINTIFF: COUNSEL FOR DEFENDANT: Digitally signed by: T. Philip Washington T. Philip DN: CN = T. Philip Washington email = /s/ Priscilla C. Tran ______________________________________ ________________________________ twatb@allstate.com C = US O = Lisa Washington Chastain & Associates Pusch and Nguyen Law Firm PPLC Date: 2021.04.06 12:54:28 -06'00' ______________________________________ _ Lisa Chastain & Associates ________________ 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.