On June 11, 2020 a
Motion-Secondary
was filed
involving a dispute between
Dehghani, Parisa,
and
Gomez Floor Covering Inc.,
Mendez, Jose Juan,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
Preview
FILED
11/9/2021 9:09 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Debra Clark DEPUTY
CAUSE N O. DC-20-08097
PARISA DEHGHANI § IN THE DISTRICT COURT
§
Plaintiff, §
§
v. § DALLAS COUNTY, TEXAS
§
GOMEZ FLOOR COVERING, INC. and §
JOSE JUAN MENDEZ dba MENDEZ §
TILE AND FLOOR, §
§
Defendants. § 19IST JUDICIAL DISTRICT
AGREED SCHEDULING ORDER
The Court issues the following Scheduling and Level 2 Discovery Order. Unless otherwise
ordered herein or hereafter, discovery in this case will be controlled by the provisions of Tex. R.
Civ. P. 190.3 (Level 2)
1. November 9, 2021 PLEADINGS. A11 of Defendants’ pleadings, amendments
and supplements must be filed by this date. This does not
preclude prompt filing of pleadings directly responsive to
any timely filed pleadings.
2. December 7, 2021 PLAINTIFF’S DEADLINE TO SUBMIT EXPERT
WITNESS DESIGNATION Plaintiff‘s expert Witness
designations are required and must be served by the
following date. The designation must include all of the
information and documentation listed in Rule 194.2(f),
including written reports. Failure to timely respond will be
governed by Rule 193.6. This does not override the
requirements of T.R.C.P. § 18.001.
3. January 21,2022 DEFENDANT’S DEADLINE TO SUBMIT EXPERT
WITNESS DESIGNATION Defendant’s expert witness
designations are required and must be served by the
following date. The designation must include all of the
information and documentation listed in Rule 194.2(f),
including written reports. Failure to timely respond will be
governed by Rule 193.6. This does not override the
requirements of T.R.C.P. § 18.001.
AGREED SCHEDULING ORDER Page 1 of 4
4. March 22, 2022 MEDIATION Mediation is scheduled to occur with all
named parties present before this date with mediator Mark
Gilbert.
5. March 22, 2022 DISCOVERY Shall be completed by this date. Parties
seeking discovery must serve requests sufficiently far in
advance of the end of the discovery period that the deadline
for responding will be within the discovery period. Counsel
may conduct discovery beyond this deadline by agreement.
6. March 22, 2022 DISPOSITIVE MOTIONS / EXPERT CHALLENGES.
Dispositive motions and any motions challenging the
qualifications or reliability of opinions of any expert
designated by an opposing party, including any challenges
under Robinson / Daubert must be filed, set & heard by this
date.
7. April 21, 2022 PRETRIAL DOCUMENTS: WITNESS LIST,
EXHIBIT LIST, MOTIONS IN LIMINE, DEPOSITION
DESIGNATIONS AND PROPOSED JURY CHARGE.
The parties shall file and exchange by this date.
8. April 28, 2022 OBJECTIONS TO PRETRIAL DOCUMENTS AND
DEPOSITION DESIGNATIONS. CROSS-
DESIGNATION OF DEPOSITION TESTIMONY.
Objections to pretrial documents and designated deposition
excerpts must be made by this date. Cross-designation of
deposition testimony must be made by this date.
9. May 5, 2021 OBJECTIONS TO CROSS-DEPOSITION
DESINGATIONS. Objections to cross-designation of
deposition testimony must be made by this date.
10. May 9, 2022 JURY TRIAL SETTING
SIGNED this day of October, 2021.
PRESIDING JUDGE
AGREED SCHEDULING ORDER Page 2 of 4
AGREED:
CHALAKI LAW, P.C.
By: /s/ Robert Alvarez
E-service: efile@chalakilaw.com
Robert Alvarez
Texas Bar No. 24095344
Shawn Hashemi
Texas Bar No. 24090151
Chastity McNair
Texas Bar N0. 24109537
Sean Chalaki
Texas Bar N0. 24072032
North Dallas Law Center
3234 Commander Drive, Suite 100
Carrollton, Texas 75006
Tel. (972) 793-8500
Fax. (800) 991-6288
ATTORNEYS FOR PLAlNTIFFS
AYIK & ASSOCIATES
By: /s/ Jonathan Cheatam (With permission)
E-service: jcheatha@travelers.com
Jonathan E. Cheatham
Texas Bar No. 00793494
1301 E. Collins B1Vd., Suite 490
Richardson, Texas 75081
Tel. (214) 570-6300
Fax. (855) 748-3821
ATTORNEY FOR DEFENDANT
GOMEZ FLOOR COVERING, INC.
AGREED SCHEDULING ORDER Page 3 of 4
QUILLING, SEALANDER, LOWNDS, WINSLETT & MOSER, P.C.
By: _/s/ Ed Carlton (with permission)
E-service: gyinslettgQgslwm£om
Greg K. Winslett
Texas Bar No. 21781900
2001 Bryan Street, Suite 1800
Dallas, Texas 75201
Tel. (214) 871-2100
Fax. (214)871-2111
ATTORNEY FOR DEFENDANT
JOSE JUAN MENDEZ DBA MENDEZ
TILE AND FLOOR
AGREED SCHEDULING ORDER Page 4 of 4
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.
Chalaki Law E-Service on behalf of Robert Alvarez
Bar No. 24095344
efile@chalakilaw.com
Envelope ID: 58976808
Status as of 11/9/2021 12:09 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Karina Vargas kvargas@qslwm.com 11/9/2021 9:09:22 AM SENT
Robert Alvarez robert@chalakilaw.com 11/9/2021 9:09:22 AM SENT
ROBERT ALVAREZ efile@chalakilaw.com 11/9/2021 9:09:22 AM SENT
Associated Case Party: GOMEZ FLOOR COVERING INC.
Name BarNumber Email TimestampSubmitted Status
Jonathan E.Cheatham jcheatha@travelers.com 11/9/2021 9:09:22 AM SENT
Associated Case Party: JOSEJUANMENDEZ
Name BarNumber Email TimestampSubmitted Status
Ed Carlton ecarlton@qslwm.com 11/9/2021 9:09:22 AM SENT
Document Filed Date
November 09, 2021
Case Filing Date
June 11, 2020
Category
OTHER PERSONAL INJURY
For full print and download access, please subscribe at https://www.trellis.law/.
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FILED 11/9/2021 9:09 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Debra Clark DEPUTY CAUSE N O. DC-20-08097 PARISA DEHGHANI § IN THE DISTRICT COURT § Plaintiff, § § v. § DALLAS COUNTY, TEXAS § GOMEZ FLOOR COVERING, INC. and § JOSE JUAN MENDEZ dba MENDEZ § TILE AND FLOOR, § § Defendants. § 19IST JUDICIAL DISTRICT AGREED SCHEDULING ORDER The Court issues the following Scheduling and Level 2 Discovery Order. Unless otherwise ordered herein or hereafter, discovery in this case will be controlled by the provisions of Tex. R. Civ. P. 190.3 (Level 2) 1. November 9, 2021 PLEADINGS. A11 of Defendants’ pleadings, amendments and supplements must be filed by this date. This does not preclude prompt filing of pleadings directly responsive to any timely filed pleadings. 2. December 7, 2021 PLAINTIFF’S DEADLINE TO SUBMIT EXPERT WITNESS DESIGNATION Plaintiff‘s expert Witness designations are required and must be served by the following date. The designation must include all of the information and documentation listed in Rule 194.2(f), including written reports. Failure to timely respond will be governed by Rule 193.6. This does not override the requirements of T.R.C.P. § 18.001. 3. January 21,2022 DEFENDANT’S DEADLINE TO SUBMIT EXPERT WITNESS DESIGNATION Defendant’s expert witness designations are required and must be served by the following date. The designation must include all of the information and documentation listed in Rule 194.2(f), including written reports. Failure to timely respond will be governed by Rule 193.6. This does not override the requirements of T.R.C.P. § 18.001. AGREED SCHEDULING ORDER Page 1 of 4 4. March 22, 2022 MEDIATION Mediation is scheduled to occur with all named parties present before this date with mediator Mark Gilbert. 5. March 22, 2022 DISCOVERY Shall be completed by this date. Parties seeking discovery must serve requests sufficiently far in advance of the end of the discovery period that the deadline for responding will be within the discovery period. Counsel may conduct discovery beyond this deadline by agreement. 6. March 22, 2022 DISPOSITIVE MOTIONS / EXPERT CHALLENGES. Dispositive motions and any motions challenging the qualifications or reliability of opinions of any expert designated by an opposing party, including any challenges under Robinson / Daubert must be filed, set & heard by this date. 7. April 21, 2022 PRETRIAL DOCUMENTS: WITNESS LIST, EXHIBIT LIST, MOTIONS IN LIMINE, DEPOSITION DESIGNATIONS AND PROPOSED JURY CHARGE. The parties shall file and exchange by this date. 8. April 28, 2022 OBJECTIONS TO PRETRIAL DOCUMENTS AND DEPOSITION DESIGNATIONS. CROSS- DESIGNATION OF DEPOSITION TESTIMONY. Objections to pretrial documents and designated deposition excerpts must be made by this date. Cross-designation of deposition testimony must be made by this date. 9. May 5, 2021 OBJECTIONS TO CROSS-DEPOSITION DESINGATIONS. Objections to cross-designation of deposition testimony must be made by this date. 10. May 9, 2022 JURY TRIAL SETTING SIGNED this day of October, 2021. PRESIDING JUDGE AGREED SCHEDULING ORDER Page 2 of 4 AGREED: CHALAKI LAW, P.C. By: /s/ Robert Alvarez E-service: efile@chalakilaw.com Robert Alvarez Texas Bar No. 24095344 Shawn Hashemi Texas Bar No. 24090151 Chastity McNair Texas Bar N0. 24109537 Sean Chalaki Texas Bar N0. 24072032 North Dallas Law Center 3234 Commander Drive, Suite 100 Carrollton, Texas 75006 Tel. (972) 793-8500 Fax. (800) 991-6288 ATTORNEYS FOR PLAlNTIFFS AYIK & ASSOCIATES By: /s/ Jonathan Cheatam (With permission) E-service: jcheatha@travelers.com Jonathan E. Cheatham Texas Bar No. 00793494 1301 E. Collins B1Vd., Suite 490 Richardson, Texas 75081 Tel. (214) 570-6300 Fax. (855) 748-3821 ATTORNEY FOR DEFENDANT GOMEZ FLOOR COVERING, INC. AGREED SCHEDULING ORDER Page 3 of 4 QUILLING, SEALANDER, LOWNDS, WINSLETT & MOSER, P.C. By: _/s/ Ed Carlton (with permission) E-service: gyinslettgQgslwm£om Greg K. Winslett Texas Bar No. 21781900 2001 Bryan Street, Suite 1800 Dallas, Texas 75201 Tel. (214) 871-2100 Fax. (214)871-2111 ATTORNEY FOR DEFENDANT JOSE JUAN MENDEZ DBA MENDEZ TILE AND FLOOR AGREED SCHEDULING ORDER Page 4 of 4 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. Chalaki Law E-Service on behalf of Robert Alvarez Bar No. 24095344 efile@chalakilaw.com Envelope ID: 58976808 Status as of 11/9/2021 12:09 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Karina Vargas kvargas@qslwm.com 11/9/2021 9:09:22 AM SENT Robert Alvarez robert@chalakilaw.com 11/9/2021 9:09:22 AM SENT ROBERT ALVAREZ efile@chalakilaw.com 11/9/2021 9:09:22 AM SENT Associated Case Party: GOMEZ FLOOR COVERING INC. Name BarNumber Email TimestampSubmitted Status Jonathan E.Cheatham jcheatha@travelers.com 11/9/2021 9:09:22 AM SENT Associated Case Party: JOSEJUANMENDEZ Name BarNumber Email TimestampSubmitted Status Ed Carlton ecarlton@qslwm.com 11/9/2021 9:09:22 AM SENT