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CAUSE NO. DC-1 9-1 0926
VASHONE RHODES; IN THE DISTRICT COURT OF
Plaintiff,
VS. DALLAS COUNTY, TEXAS
JAMES GOMEZ; AND EXCLUSIVE
NATIONWIDE DELIVERY, INC.
Defendants. 160‘“ JUDICIAL DISTRICT
AMENDED AGREED SCHEDULING ORDER
The parties submit this proposed Amended Agreed Scheduling Order. The
Court, having considered said Order, is of the opinion that the Order should be
GRANTED.
IT IS THEREFORE ORDERED that the following pre—trial deadlines shall apply EL
to the above-entitled and numbered cause unless othenNise modied
J c. II
bragreeIment of
the parties or Order of the Court:
January 21, 2021 Mediation deadline. Mediation is scheduled to occur
before this date with mediator Karen Gammon, 25
Highland Park Village, Suite 100-816, Dallas, TX
75205.
February 19, 2021 Deadline by which the parties must have completed
discovery (all discovery must be initiated at a time early
enough to ensure that the completion of same will not
surpass this deadline).
March 15, 2021 Deadline by which the parties le their page/line
designations of video deposition testimony to be used
at trial.
March 17, 2021 Deadline by which parties le their objections to
page/line designations of video deposition testimony to
be used at trial.
AMENDED AGREED SCHEDULING ORDER — PAGE 1
March 18, 2021 Deadline by which the parties must file their rebuttal
page/line designations of video deposition testimony to
be used at trial.
March 18, 2021 Deadline by which the parties must le motions in
limine, trial exhibit lists, trial witness lists, any pre-trial
motions, a proposed jury charge, and parties must
exchange true and correct copies of exhibits not
previously produced.
March 22, 2021 JURY TRIAL
All deadlines in this Amended Agreed Scheduling Order may be modied by
Rule 11 agreement, except for the trial date. Should this case not be reached for trial
on the March 22, 2021 trial setting, absent a new scheduling order being entered or a
Rule 11 agreement stating otherwise, the parties agree that the discovery deadline
will end 30 days before the new trial date. Additionally, all pretrial deadlines (witness
list, exhibit list, motion in limine, and page-line designations) wili be moved to the
same number of calendar days prior to trial as set out above, according to the new
trial date.
SIGNEDTi-us 3O“ dayor O bob». ,2020.
Tarp—u;
JUDGEPRESIDING
AMENDED AGREED SCHEDULING ORDER — PAGE 2
APPROVED As To FORMAND CONTENT:
{WITHERI’ILE
'LAW‘GROUP, PLLc
/s/ V. Paige'flqridge
By:
V. PAIGE ELDRIDGE
State Bar No. 24096747
.
paige. eldridge@witherite_law. com
SHELLY GRECO
State Bar NQI 24008168
she!Iv.qrecO@Witheritelaw‘.coni
10440" N. Central ExpressWay.
Suite 400
Dallas, TX 75231-2228
(214) 378-6665
.(214) 378-6670 (fax). .
ATTORNEYS FOR PLAINTIFF
WALTERS, BALIDo.&.c'RAIN, LLP
ls/ Randall G. Walters--signe_d with permiSsion
"By:
MR. RANDALL G. VV.AL'[ERS
"
State Bar No. 20819480
randy. walters@wbclawrm‘.com
-
Meadow Park’Tower, 15th Floor
10440 North Ce'ntr'al ExpressWay
Dallas; TX T5231
(214) 749—4805
(214)760-1-670(fax)
ATTORNEY FOR- DEFENDANT EXCLUSIVE NATIONWIDE DELIVERY INC.
THE LECRONE LAW FIRIm, P.c.'
By: (lab, W 5W 5m,
.III'IRPADAM B. LECRon' .
State Bar No.00786447
adam@lec"ro_nelaw. com
Wall Street Plaza
123 N. Crockett Street, Suite 200
'
Sherman, TX 75090 '
(903) 813-1900
(903) 81 3-1 944(fax)
ATTORNEY FOR'DEFENDANT JAMES GOMEZ
AMENDED AGREED SCHEDULING ORDER —-
PAGE 3
14—;
AutomatedJCerticate of eService
;.This automated certificate of service was created by the eling system.
The ler served this document via email generated by the eling 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.
Misty Maldonado on behalf of Paige Eldridge
-
,
Bar No. 24096747
misty. maldonado@witheritelaw. com
Envelope ID: 47524694
Status as of 10/27/2020 10:59 AM CST
_
’Associa'téd Case Party:.vA'SI—I0NEI RHODES
Nam‘e BarNumb'er Email” Status
TlmeétampSubmitted
, Paige EId'ridge .
,paige.eIdridge@e_WIéwyers.cdm 10/26/20202::11 53 PM sENf
Associated Case Party: JAMES GOMEZ
H
Name BarNumber: Email TimestampSubrriitted Status
Adam LeCrOne -
'eserviCe@lecronelaw.corh‘ 10/26/2020 2:1 1 :53lPM SENT ‘-
Associated Case Party-EXCLUSIVE NATIONWIDE DELIVERY, lNC
,3
I
' '
'Name BarNumber Email ' I TimestampSubmitted 'Status
.‘Randall GWalters e
waltersedocsnotications@wbclavvtir’m.com [10/2672020 2:11:53 PM SENT
i
’
'Nadine KWeatherall -
V'nadine.wéatherall@w5clawrm.com 10/26l2'020‘2:11:53 PM SENT
" _'
RahdaII‘cwaIters .
'réridy.xijélt’ers@wbcIawnn’mm a 1012612020 2:11:53 PM SENT
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CAUSE NO. DC-1 9-1 0926 VASHONE RHODES; IN THE DISTRICT COURT OF Plaintiff, VS. DALLAS COUNTY, TEXAS JAMES GOMEZ; AND EXCLUSIVE NATIONWIDE DELIVERY, INC. Defendants. 160‘“ JUDICIAL DISTRICT AMENDED AGREED SCHEDULING ORDER The parties submit this proposed Amended Agreed Scheduling Order. The Court, having considered said Order, is of the opinion that the Order should be GRANTED. IT IS THEREFORE ORDERED that the following pre—trial deadlines shall apply EL to the above-entitled and numbered cause unless othenNise modied J c. II bragreeIment of the parties or Order of the Court: January 21, 2021 Mediation deadline. Mediation is scheduled to occur before this date with mediator Karen Gammon, 25 Highland Park Village, Suite 100-816, Dallas, TX 75205. February 19, 2021 Deadline by which the parties must have completed discovery (all discovery must be initiated at a time early enough to ensure that the completion of same will not surpass this deadline). March 15, 2021 Deadline by which the parties le their page/line designations of video deposition testimony to be used at trial. March 17, 2021 Deadline by which parties le their objections to page/line designations of video deposition testimony to be used at trial. AMENDED AGREED SCHEDULING ORDER — PAGE 1 March 18, 2021 Deadline by which the parties must file their rebuttal page/line designations of video deposition testimony to be used at trial. March 18, 2021 Deadline by which the parties must le motions in limine, trial exhibit lists, trial witness lists, any pre-trial motions, a proposed jury charge, and parties must exchange true and correct copies of exhibits not previously produced. March 22, 2021 JURY TRIAL All deadlines in this Amended Agreed Scheduling Order may be modied by Rule 11 agreement, except for the trial date. Should this case not be reached for trial on the March 22, 2021 trial setting, absent a new scheduling order being entered or a Rule 11 agreement stating otherwise, the parties agree that the discovery deadline will end 30 days before the new trial date. Additionally, all pretrial deadlines (witness list, exhibit list, motion in limine, and page-line designations) wili be moved to the same number of calendar days prior to trial as set out above, according to the new trial date. SIGNEDTi-us 3O“ dayor O bob». ,2020. Tarp—u; JUDGEPRESIDING AMENDED AGREED SCHEDULING ORDER — PAGE 2 APPROVED As To FORMAND CONTENT: {WITHERI’ILE 'LAW‘GROUP, PLLc /s/ V. Paige'flqridge By: V. PAIGE ELDRIDGE State Bar No. 24096747 . paige. eldridge@witherite_law. com SHELLY GRECO State Bar NQI 24008168 she!Iv.qrecO@Witheritelaw‘.coni 10440" N. Central ExpressWay. Suite 400 Dallas, TX 75231-2228 (214) 378-6665 .(214) 378-6670 (fax). . ATTORNEYS FOR PLAINTIFF WALTERS, BALIDo.&.c'RAIN, LLP ls/ Randall G. Walters--signe_d with permiSsion "By: MR. RANDALL G. VV.AL'[ERS " State Bar No. 20819480 randy. walters@wbclawrm‘.com - Meadow Park’Tower, 15th Floor 10440 North Ce'ntr'al ExpressWay Dallas; TX T5231 (214) 749—4805 (214)760-1-670(fax) ATTORNEY FOR- DEFENDANT EXCLUSIVE NATIONWIDE DELIVERY INC. THE LECRONE LAW FIRIm, P.c.' By: (lab, W 5W 5m, .III'IRPADAM B. LECRon' . State Bar No.00786447 adam@lec"ro_nelaw. com Wall Street Plaza 123 N. Crockett Street, Suite 200 ' Sherman, TX 75090 ' (903) 813-1900 (903) 81 3-1 944(fax) ATTORNEY FOR'DEFENDANT JAMES GOMEZ AMENDED AGREED SCHEDULING ORDER —- PAGE 3 14—; AutomatedJCerticate of eService ;.This automated certificate of service was created by the eling system. The ler served this document via email generated by the eling 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. Misty Maldonado on behalf of Paige Eldridge - , Bar No. 24096747 misty. maldonado@witheritelaw. com Envelope ID: 47524694 Status as of 10/27/2020 10:59 AM CST _ ’Associa'téd Case Party:.vA'SI—I0NEI RHODES Nam‘e BarNumb'er Email” Status TlmeétampSubmitted , Paige EId'ridge . ,paige.eIdridge@e_WIéwyers.cdm 10/26/20202::11 53 PM sENf Associated Case Party: JAMES GOMEZ H Name BarNumber: Email TimestampSubrriitted Status Adam LeCrOne - 'eserviCe@lecronelaw.corh‘ 10/26/2020 2:1 1 :53lPM SENT ‘- Associated Case Party-EXCLUSIVE NATIONWIDE DELIVERY, lNC ,3 I ' ' 'Name BarNumber Email ' I TimestampSubmitted 'Status .‘Randall GWalters e waltersedocsnotications@wbclavvtir’m.com [10/2672020 2:11:53 PM SENT i ’ 'Nadine KWeatherall - V'nadine.wéatherall@w5clawrm.com 10/26l2'020‘2:11:53 PM SENT " _' RahdaII‘cwaIters . 'réridy.xijélt’ers@wbcIawnn’mm a 1012612020 2:11:53 PM SENT