On August 02, 2019 a
Motion-Secondary
was filed
involving a dispute between
Rhodes, Vashone,
and
Exclusive Nationwide Delivery, Inc,
Gomez, James,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
CAUSE NO. DC-l 9-10926
VASHONE RHODES § IN THE DISTRICT COURT
§
§
V. § 160T“ JUDICLAL DISTRICT
§
JAMES GOMEZ, AND EXCLUSIVE §
NATIONWIDE DELIVERY, INC. § DALLAS COUNTY, TEXAS
AGREED SCHEDULING ORDER
1. PASSED JOINING PARTIES. No additional parties may be joined after this date
except on motion for leave showing good cause.
2. 05.31.2021 EXPERTS for PLAINTIFF(S) AND INTERVENOR(S) expected to
in or
testify person by deposition (“Testifying Expert”) will be designated by
this date. No additional testifying experts will be permitted to testify except
for good cause shown. Record custodians and cost of services afants are
excluded from report requirements.
3. 06.29.2021 EXPERTS for ALL OTHER PARTIES expected to testify in person or by
deposition (“Testifying Expert”) shall be designated by this date. No
additional testifying experts Will be permitted to testify except for good cause
shown. Record custodians and cost of services afants are excluded from
report requirements.
4. 08.27.2021 AMENDMENTS to pleadings asserting new causes of action or afrmative
defenses must be led by this date. Any other amended pleadings must be
led no later than seven (7) days after the end of the discovery period.
Amended pleadings responsive to timely led pleadings under this schedule
may be led after the deadline for amended pleadings if led within two (2)
weeks after the pleading to which they respond.
5. 08.13.2021 SUMMARY JUDGMENT motions shall be led prior to this date and set
for hearing no later than the Pre-Trial Hearing. No evidence summary
judgment motions should not be set for hearing prior to the discovery cut off.
6. 08.27.2021 SETTLEMENT CONFERENCES AND/OR MEDIATIONS shall be
completed by this date. The parties will mediate this case on March 5, 2021,
at 10:30 a.m. with Karen Gammon.
AGREED SCHEDULING ORDER Page 1
14942/grexrode
08.27.2021 DISCOVERY must be initiated in time to allow completion of discovery by
this date. No discovery may be conducted after this date without agreement
of counsel.
09.03.2021 MOTION TO EXCLUDE EXPERT and/or DAUBERT-ROBINSON
to
challenges expert testimony must be led by this date. Any hearings over
any such motion must be conducted no later than 09.17.2021 (l 0 days before
the Initial Trial Setting).
09.03.2021 MOTION TO COMPEL RESPONSES TO DISCOVERY (other than
relating to factual matters arising after the end of the discovery period) must
be led or such complaint is waived, except for the sanction of exclusion
under Rule 193.6.
10. 09.23.2021 The parties shall le with the Court:
a. Exhibit List;
b. Witness List;
c. Designation of deposition testimony to be offered in direct
examination;
d. Motion in Limine w/proposed Order; and
e. Proposed Jury Charge.
11. PRE-TRIAL HEARING.
(If required)
12. 09.27.2021 JURY TRIAL.
9:00 a.m.
Should this case not be reached for trial on the 09.27.2021 trial setting, absent a new
scheduling order being entered or a Rule ll agreement stating otherwise, all pretrial
deadlines (witness list, exhibit list, motion in limine, page-line designations and proposed
jury charge) will be moved to the same number of calendar dates prior to trial as set out
above, according to the new trial date.
Plaintiff/Plaintiff’s counsel shall serve a copy of this Order on any currently named
defendant(s) answering after this date. The party joining an additional party shall serve a copy of
this Order on the new party concurrently with the pleading joining that party.
SIGNED the of , 2021.
JUDGE PRESIDING
AGREED SCHEDULING ORDER Page 2
14942/grexrode
AGREED:
”PW
V. PAIGE ELDRIDGE
State Bar No. 24096747
WITHERITE LAW GROUP, PLLC
10440 N. Central Expressway, Ste. 400
Dallas, Texas 7523 1-2228
Tel: 214.378.6665
Fax: 214.378.6670
paige.eldridge@witheritelaw.com
ATTORNEYS FOR PLAINTIFF
(lab, 74/:
JoilN W. BREEZE
6W
State Bar No.00796248
THE LECRONE LAW FIRM, PC
123 North Crockett Street, Suite 200
Sherman, Texas 75090
Tel: 903-813-1900
Fax: 903-813-1944
eservice@lecronelaw.com
ATTORNEYS FOR DEFENDANT, JAMES GOMEZ
RANDALL G. WALTERS
State Bar. No. 20819480
WALTERS, BALIDO & CRAIN L.L.P.
Meadowpark Tower, Suite 1500
10440 North Central Expressway
Dallas, Texas 75231
Tel: 214.749.4805
Fax: 2 14.347.8381
randy.wa1ters@wbclawrrn.corn,
ATTORNEYS FOR DEFENDANT, EXCLUSIVE NATIONWIDE DELIVERY, INC.
AGREED SCHEDULING ORDER Page 3
14942/grexrode
AGREED:
V. PAIGE ELDRIDGE
State Bar No. 24096747
WITHERITE LAW GROUP, PLLC
10440 N. Central Expressway, Ste. 400
Dallas, Texas 7523 1-2228
Tel: 214.378.6665
Fax: 214.378.6670
paige.eldridge@witheritelaw.com
ATTORNEYS FOR PLAINTIFF
JOHN W. BREEZE
State Bar No.00796248
THE LECRONE LAW FIRM, PC
123 North Crockett Street, Suite 200
Sherman, Texas 75090
Tel: 903-813-1900
Fax: 903-813-1944
eservice@lecronelaw.com
ATTORNEYS FOR DEFENDANT, JAMES GOMEZ
l/g/m/a/M Wm
RANDALL G. WALTERS
State Bar. No. 20819480
WALTERS, BALIDO & CRAIN L.L.P.
Meadowpark Tower, Suite 1500
10440 North Central Expressway
Dallas, Texas 75231
Tel: 214.749.4805
Fax: 214.347.8381
randy.walters@wbclawrm.com,
ATTORNEYS FOR DEFENDANT, EXCLUSIVE NATIONWIDE DELIVERY, INC.
AGREED SCHEDULING ORDER Page 3
14942/grexrode
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.
Gena Rexrode on behalf of John Breeze
Bar No. 00796248
gena@lecronelaw.com
Envelope ID: 51067003
Status as of 3/2/2021 2:08 PM CST
Associated Case Party: VASHONE RHODES
Name BarNumber Email TimestampSubmitted Status
Amy Witherite 788698 amy.witherite@witheritelaw.com 3/2/2021 11:48:55 AM SENT
Paige Eldridge paige.eldridge@ewlawyers.com 3/2/2021 11:48:55 AM SENT
Associated Case Party: JAMES GOMEZ
Name BarNumber Email TimestampSubmitted Status
Adam LeCrone eservice@lecronelaw.com 3/2/2021 11:48:55 AM SENT
Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC
Name BarNumber Email TimestampSubmitted Status
Randall GWalters waltersedocsnotifications@wbclawfirm.com 3/2/2021 11:48:55 AM SENT
Nadine K Weatherall nadine.weatherall@wbclawfirm.com 3/2/2021 11:48:55 AM SENT
Randall GWalters randy.walters@wbclawfirm.com 3/2/2021 11:48:55 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
PAIGE VELDRIDGE paiqe.eldridqe@ewlawyers.com 3/2/2021 11:48:55 AM SENT
Craig Laird PCL@LAIRD.LAWYER 3/2/2021 11:48:55 AM SENT
Document Filed Date
March 02, 2021
Case Filing Date
August 02, 2019
Category
MOTOR VEHICLE ACCIDENT
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Preview
CAUSE NO. DC-l 9-10926 VASHONE RHODES § IN THE DISTRICT COURT § § V. § 160T“ JUDICLAL DISTRICT § JAMES GOMEZ, AND EXCLUSIVE § NATIONWIDE DELIVERY, INC. § DALLAS COUNTY, TEXAS AGREED SCHEDULING ORDER 1. PASSED JOINING PARTIES. No additional parties may be joined after this date except on motion for leave showing good cause. 2. 05.31.2021 EXPERTS for PLAINTIFF(S) AND INTERVENOR(S) expected to in or testify person by deposition (“Testifying Expert”) will be designated by this date. No additional testifying experts will be permitted to testify except for good cause shown. Record custodians and cost of services afants are excluded from report requirements. 3. 06.29.2021 EXPERTS for ALL OTHER PARTIES expected to testify in person or by deposition (“Testifying Expert”) shall be designated by this date. No additional testifying experts Will be permitted to testify except for good cause shown. Record custodians and cost of services afants are excluded from report requirements. 4. 08.27.2021 AMENDMENTS to pleadings asserting new causes of action or afrmative defenses must be led by this date. Any other amended pleadings must be led no later than seven (7) days after the end of the discovery period. Amended pleadings responsive to timely led pleadings under this schedule may be led after the deadline for amended pleadings if led within two (2) weeks after the pleading to which they respond. 5. 08.13.2021 SUMMARY JUDGMENT motions shall be led prior to this date and set for hearing no later than the Pre-Trial Hearing. No evidence summary judgment motions should not be set for hearing prior to the discovery cut off. 6. 08.27.2021 SETTLEMENT CONFERENCES AND/OR MEDIATIONS shall be completed by this date. The parties will mediate this case on March 5, 2021, at 10:30 a.m. with Karen Gammon. AGREED SCHEDULING ORDER Page 1 14942/grexrode 08.27.2021 DISCOVERY must be initiated in time to allow completion of discovery by this date. No discovery may be conducted after this date without agreement of counsel. 09.03.2021 MOTION TO EXCLUDE EXPERT and/or DAUBERT-ROBINSON to challenges expert testimony must be led by this date. Any hearings over any such motion must be conducted no later than 09.17.2021 (l 0 days before the Initial Trial Setting). 09.03.2021 MOTION TO COMPEL RESPONSES TO DISCOVERY (other than relating to factual matters arising after the end of the discovery period) must be led or such complaint is waived, except for the sanction of exclusion under Rule 193.6. 10. 09.23.2021 The parties shall le with the Court: a. Exhibit List; b. Witness List; c. Designation of deposition testimony to be offered in direct examination; d. Motion in Limine w/proposed Order; and e. Proposed Jury Charge. 11. PRE-TRIAL HEARING. (If required) 12. 09.27.2021 JURY TRIAL. 9:00 a.m. Should this case not be reached for trial on the 09.27.2021 trial setting, absent a new scheduling order being entered or a Rule ll agreement stating otherwise, all pretrial deadlines (witness list, exhibit list, motion in limine, page-line designations and proposed jury charge) will be moved to the same number of calendar dates prior to trial as set out above, according to the new trial date. Plaintiff/Plaintiff’s counsel shall serve a copy of this Order on any currently named defendant(s) answering after this date. The party joining an additional party shall serve a copy of this Order on the new party concurrently with the pleading joining that party. SIGNED the of , 2021. JUDGE PRESIDING AGREED SCHEDULING ORDER Page 2 14942/grexrode AGREED: ”PW V. PAIGE ELDRIDGE State Bar No. 24096747 WITHERITE LAW GROUP, PLLC 10440 N. Central Expressway, Ste. 400 Dallas, Texas 7523 1-2228 Tel: 214.378.6665 Fax: 214.378.6670 paige.eldridge@witheritelaw.com ATTORNEYS FOR PLAINTIFF (lab, 74/: JoilN W. BREEZE 6W State Bar No.00796248 THE LECRONE LAW FIRM, PC 123 North Crockett Street, Suite 200 Sherman, Texas 75090 Tel: 903-813-1900 Fax: 903-813-1944 eservice@lecronelaw.com ATTORNEYS FOR DEFENDANT, JAMES GOMEZ RANDALL G. WALTERS State Bar. No. 20819480 WALTERS, BALIDO & CRAIN L.L.P. Meadowpark Tower, Suite 1500 10440 North Central Expressway Dallas, Texas 75231 Tel: 214.749.4805 Fax: 2 14.347.8381 randy.wa1ters@wbclawrrn.corn, ATTORNEYS FOR DEFENDANT, EXCLUSIVE NATIONWIDE DELIVERY, INC. AGREED SCHEDULING ORDER Page 3 14942/grexrode AGREED: V. PAIGE ELDRIDGE State Bar No. 24096747 WITHERITE LAW GROUP, PLLC 10440 N. Central Expressway, Ste. 400 Dallas, Texas 7523 1-2228 Tel: 214.378.6665 Fax: 214.378.6670 paige.eldridge@witheritelaw.com ATTORNEYS FOR PLAINTIFF JOHN W. BREEZE State Bar No.00796248 THE LECRONE LAW FIRM, PC 123 North Crockett Street, Suite 200 Sherman, Texas 75090 Tel: 903-813-1900 Fax: 903-813-1944 eservice@lecronelaw.com ATTORNEYS FOR DEFENDANT, JAMES GOMEZ l/g/m/a/M Wm RANDALL G. WALTERS State Bar. No. 20819480 WALTERS, BALIDO & CRAIN L.L.P. Meadowpark Tower, Suite 1500 10440 North Central Expressway Dallas, Texas 75231 Tel: 214.749.4805 Fax: 214.347.8381 randy.walters@wbclawrm.com, ATTORNEYS FOR DEFENDANT, EXCLUSIVE NATIONWIDE DELIVERY, INC. AGREED SCHEDULING ORDER Page 3 14942/grexrode 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. Gena Rexrode on behalf of John Breeze Bar No. 00796248 gena@lecronelaw.com Envelope ID: 51067003 Status as of 3/2/2021 2:08 PM CST Associated Case Party: VASHONE RHODES Name BarNumber Email TimestampSubmitted Status Amy Witherite 788698 amy.witherite@witheritelaw.com 3/2/2021 11:48:55 AM SENT Paige Eldridge paige.eldridge@ewlawyers.com 3/2/2021 11:48:55 AM SENT Associated Case Party: JAMES GOMEZ Name BarNumber Email TimestampSubmitted Status Adam LeCrone eservice@lecronelaw.com 3/2/2021 11:48:55 AM SENT Associated Case Party: EXCLUSIVE NATIONWIDE DELIVERY, INC Name BarNumber Email TimestampSubmitted Status Randall GWalters waltersedocsnotifications@wbclawfirm.com 3/2/2021 11:48:55 AM SENT Nadine K Weatherall nadine.weatherall@wbclawfirm.com 3/2/2021 11:48:55 AM SENT Randall GWalters randy.walters@wbclawfirm.com 3/2/2021 11:48:55 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status PAIGE VELDRIDGE paiqe.eldridqe@ewlawyers.com 3/2/2021 11:48:55 AM SENT Craig Laird PCL@LAIRD.LAWYER 3/2/2021 11:48:55 AM SENT