On April 22, 2021 a
PROP ASO - NON-SIGNED PROPOSED ORDER/JUDGMENT
was filed
involving a dispute between
Williby, Regina,
and
Garcia, Alberto,
Ramirez, Jose Roberto,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
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CAUSE NO. DC-21-05084
REGINA WILLIBY § IN THE DISTRICT COURT OF
Plaintiff, §
§
V. § 116TH JUDICML DISTRICT
§
JOSE ROBERTO RAMIREZ and §
ALBERTO GARCIA §
Defendants. § DALLAS COUNTY, TEXAS
AGREED SCHEDULING ORDER
The conduct of discovery in this action is to be governed by the following deadlines
pursuant to Level Three Discovery Control Plan under TEXAS RULE 0F CIVIL PROCEDURE 190.4.
Deadline for amending pleadings asserting new causes of action or defenses is May 12,
2022.
Plaintiffs must designate expert witnesses by May 26, 2023. Only retained experts need
to do reports. May 26, 2023 is the deadline for serving CPRC 18.001 affidavits under
18.001(d) and (d-l).
Defendant must designate expert witnesses by June 26, 2023. Only retained experts need
to do reports. June 26, 2023 is the deadline for serving CPRC 18.001 counter-affidavits
under 18.001(e) and (e-l).
Designation of rebuttal experts must be done by July 7, 2023. Only retained experts need
to do reports.
Mediation deadline is June 21, 2023. The Court has appointed a mediator.
August 11, 2023. Pleadings amendment deadline.
A11 discovery is to be commenced in time to be completed by August 11, 2023.
All dispositive motions are to be filed no later than July 21, 2023.
All dispositive motions are to be heard no later than August 11, 2023.
AGREED SCHEDULING ORDER PAGE 1
10. August 28, 2023. Deadline by which the parties file their page/line designations of Video
deposition testimony to be used at trial and their Exhibit Lists.
11. September 1, 2023. Deadline by which parties file their objections to page/line
designations of Video deposition testimony to be used at trial and objections to Exhibits.
12. September 5, 2023. Deadline by which the parties must file their rebuttal page/line
designations of Video deposition testimony to be used at trial.
13. The parties shall file all pre-trial documents, including Witness Lists, Motions in Limine
and proposed Jury Charge, by 4:00 p.m. on September 7, 2023. The materials filed will
include an estimate of the length of trial and designation of deposition testimony to be
offered in direct examination.
14. The pre-trial conference is scheduled for the morning of trial.
15. The above-numbered and styled cause is set on this Court’s docket for jury trial on
September 11, 2023.
16. The parties may alter this scheduling order by written agreement, except that the parties
cannot agree to change the deadlines in paragraphs l3 and 15, Without seeking court
approval.
Should this case not be reached for trial on this trial setting, absent a new scheduling order
being entered or a rule 11 agreement stating otherwise, all pretrial deadlines (witness list, exhibit
list, motion in limine, and page-line designations) will be moved to the same number of calendar
days prior to trial as set out above, according to the new trial date.
IT IS FURTHER ORDERED that this discovery control order affects this case in its
entirety.
IT IS SO ORDERED.
SIGNED this day of , 2023.
PRESIDING JUDGE
AGREED SCHEDULING ORDER PAGE 2
AGREED TO:
FREDEN LAW FIRM
By: /s/ Mike Freden
MIKE FREDEN
STATE BAR N0. 07412050
950 E. State Highway 114, Ste. 160
Southlake, Texas 76092
(817) 726-1636
(817) 231-0033 Fax
mike@dfivpersonalinjury.com
ATTORNEY FOR PLAINTIFF
KIMBLE & SMITH, P.C.
/s/ Chad Kimble, with permission bv Mike Freden
Chad Kimble
State Bar No. 24007483
Kyle Smith
State Bar No. 24102512
1204 S. Whitechapel Blvd.
Southlake, TX 76092
eservice@kimblesmithlaw.com
817-766-7488 phone
817-423-7492 fax
ATTORNEY FOR DEFENDANT
ALBERTO GARCIA
AGREED SCHEDULING ORDER PAGE 3
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.
Mike Freden
Bar No. 7412050
mike@dfwpersonalinjury.com
Envelope ID: 73566307
Filing Code Description: Motion - Continuance
Filing Description: JOINT
Status as of 3/13/2023 9:49 AM CST
Associated Case Party: ALBERTO GARCIA
Name BarNumber Email TimestampSubmitted Status
CHAD KIMBLE eservice@kimblesmithlaw.com 3/10/2023 3:45:47 PM SENT
Associated Case Party: REGINA WILLIBY
Name BarNumber Email TimestampSubmitted Status
Mike Freden mike@dfwpersonalinjury.com 3/10/2023 3:45:47 PM SENT
Document Filed Date
March 10, 2023
Case Filing Date
April 22, 2021
Category
MOTOR VEHICLE ACCIDENT
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CAUSE NO. DC-21-05084 REGINA WILLIBY § IN THE DISTRICT COURT OF Plaintiff, § § V. § 116TH JUDICML DISTRICT § JOSE ROBERTO RAMIREZ and § ALBERTO GARCIA § Defendants. § DALLAS COUNTY, TEXAS AGREED SCHEDULING ORDER The conduct of discovery in this action is to be governed by the following deadlines pursuant to Level Three Discovery Control Plan under TEXAS RULE 0F CIVIL PROCEDURE 190.4. Deadline for amending pleadings asserting new causes of action or defenses is May 12, 2022. Plaintiffs must designate expert witnesses by May 26, 2023. Only retained experts need to do reports. May 26, 2023 is the deadline for serving CPRC 18.001 affidavits under 18.001(d) and (d-l). Defendant must designate expert witnesses by June 26, 2023. Only retained experts need to do reports. June 26, 2023 is the deadline for serving CPRC 18.001 counter-affidavits under 18.001(e) and (e-l). Designation of rebuttal experts must be done by July 7, 2023. Only retained experts need to do reports. Mediation deadline is June 21, 2023. The Court has appointed a mediator. August 11, 2023. Pleadings amendment deadline. A11 discovery is to be commenced in time to be completed by August 11, 2023. All dispositive motions are to be filed no later than July 21, 2023. All dispositive motions are to be heard no later than August 11, 2023. AGREED SCHEDULING ORDER PAGE 1 10. August 28, 2023. Deadline by which the parties file their page/line designations of Video deposition testimony to be used at trial and their Exhibit Lists. 11. September 1, 2023. Deadline by which parties file their objections to page/line designations of Video deposition testimony to be used at trial and objections to Exhibits. 12. September 5, 2023. Deadline by which the parties must file their rebuttal page/line designations of Video deposition testimony to be used at trial. 13. The parties shall file all pre-trial documents, including Witness Lists, Motions in Limine and proposed Jury Charge, by 4:00 p.m. on September 7, 2023. The materials filed will include an estimate of the length of trial and designation of deposition testimony to be offered in direct examination. 14. The pre-trial conference is scheduled for the morning of trial. 15. The above-numbered and styled cause is set on this Court’s docket for jury trial on September 11, 2023. 16. The parties may alter this scheduling order by written agreement, except that the parties cannot agree to change the deadlines in paragraphs l3 and 15, Without seeking court approval. Should this case not be reached for trial on this trial setting, absent a new scheduling order being entered or a rule 11 agreement stating otherwise, all pretrial deadlines (witness list, exhibit list, motion in limine, and page-line designations) will be moved to the same number of calendar days prior to trial as set out above, according to the new trial date. IT IS FURTHER ORDERED that this discovery control order affects this case in its entirety. IT IS SO ORDERED. SIGNED this day of , 2023. PRESIDING JUDGE AGREED SCHEDULING ORDER PAGE 2 AGREED TO: FREDEN LAW FIRM By: /s/ Mike Freden MIKE FREDEN STATE BAR N0. 07412050 950 E. State Highway 114, Ste. 160 Southlake, Texas 76092 (817) 726-1636 (817) 231-0033 Fax mike@dfivpersonalinjury.com ATTORNEY FOR PLAINTIFF KIMBLE & SMITH, P.C. /s/ Chad Kimble, with permission bv Mike Freden Chad Kimble State Bar No. 24007483 Kyle Smith State Bar No. 24102512 1204 S. Whitechapel Blvd. Southlake, TX 76092 eservice@kimblesmithlaw.com 817-766-7488 phone 817-423-7492 fax ATTORNEY FOR DEFENDANT ALBERTO GARCIA AGREED SCHEDULING ORDER PAGE 3 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. Mike Freden Bar No. 7412050 mike@dfwpersonalinjury.com Envelope ID: 73566307 Filing Code Description: Motion - Continuance Filing Description: JOINT Status as of 3/13/2023 9:49 AM CST Associated Case Party: ALBERTO GARCIA Name BarNumber Email TimestampSubmitted Status CHAD KIMBLE eservice@kimblesmithlaw.com 3/10/2023 3:45:47 PM SENT Associated Case Party: REGINA WILLIBY Name BarNumber Email TimestampSubmitted Status Mike Freden mike@dfwpersonalinjury.com 3/10/2023 3:45:47 PM SENT