On August 02, 2019 a
Stipulation,Agreement
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-l9-10926 . . _ \ .
VASHONE RHODES § IN THE DISTRICT COURT
'V. §
.160” JUDICIAL DISTRICT
'
§
§
JAMES GOMEZ AND EXCLUSIVE §
NATIONWIDE DELIVERY, INC. _
§ DALLAS CO UN TY, TEXAS
AGREED SCHEDULING ORDER
I
1. 06-01-2022 DEADLINE-TOY FILE ALL CLAIMS. All claims must be filed/all parties
identified including couIIteIclaims, cross-—claims and/or Iesponsible thiId-
paIty claims excluding CPRC 33. 004(j) be Ieopened to addIess deceased
'
Defendant James Gomez.
2. 06—06—2022 EXPERTS for PLAINTIFF(S) AND INTERVENOR(S) expected to
testify in person or 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 .
affi‘ants are excluded from report requirements.
J
'
3. _
07—05—2022 EXPERTS forI-ALL OTHER PARTIES expected to testify -in person or
by deposition (“Testifying Expert”) shall be designated by this date. No
.additional testifying expeIts will be permitted to testify except for good
cause shown. Record custodians \and cost of services affiants are excluded
from report requirements.
4.- 08-19-2022 SUMMARY JUDGMENT motions shall be filed pIiOI to this date and set
,fOI no lateI than the Pr-e Trial Hearing. No evidence summary
[162111110
judgment mOtions should' not be set fOI healing pIior to the discovery cut-_
i '
Off.
s. . 09-02-2022 AMENDMENTS to pleadings asserting new causes of action or
_
affirmative defenses must be filed by this date. Any othe‘I amended
_ pleadings must be filed no later than seven (7) days afteI the end of the
diScoveIy peIiOd. Amended pleadings responsive to timely filed pleadings
under this schedule may be filed after the deadline fOI amended pleadings
f
if led within two (2) weeks after the pleading to whiCh they respOnd.
6. 09-02-2022 SETTLEMENT CONFERENCES AND/OR. MEDIATIONS shall be
completed by this date. The patties have selected KaIeII Gammon and
will
contact the t0 arIaIIge the mediation. ‘
mediator
AGREED SCHEDULING ORDER -
PAGE I
.' I 000l . l 4942/tr0by
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DISCOVERY must be initiated in time to allow completion of discove1y
by this date. No discove1y may be conducted after this date without
agreement of counsel.
-
(19-09-2022 MOTION TO EXCLUDE EXPERT and/or DAUBERT-ROBINSON
challenges to expert testimony must be filed by this date. Any hearings
ove1 any such motion 111uSt be conducted no late1 than 10 days before
the
Initial T11al Setting
09—09-2022 -MOTION TO COMPEL DISCOVERY RESPONSES TO
DISCOVERY (other than relating to factual’ matters arising after the end
of the discovery period) must be filed or such complaint is‘ waived, except
1
for the sanction of exclusion under Rule 193.6.
10. 09 29 2022 The parties shall file with the Conn:
a. Exhibit List;
,
b. Witness List;
c. Designation of deposition testimony to be offered in diiect
'
examination;
(I. MotiOn in Lin1ine W/proposed Order; and
e. , Proposed Jury Charge.
ll. 10—03-2022 J U RY TRIAL.
Should this case not be reached for trial 011 the above‘trial setting, absent a new scheduling
order being entered or a Rule li‘l agreement stating otherwise, the parties agree that the
discove1y deadline Will end 30 days bef01e the new t1ial date. Additionally, all p1et1ial . '
deadlines (witness list, exhibit list, motion in li111ine,page-line designations and proposed
ju1y cl1a10e) will be moved to the same number of calendar dates pri’01 to t1ialas set out'
above, according to tl1e11ewti1'al date.
Plaintiff/Plaintiff’s. counsel shall serve a copy of this Order on any cuirently named
defendant(s)'answe1ingafte1 this date. The party joining an additional party shall serve a copy of ‘
this 01de1 on the new party concurrently with the that paity.
pleadingJoining
SIGNED the ‘2’)“, of ,2022.
Q ”Lg!
' '
JUDGE FRESIDING
'
AGREED SCHEDULING ORDER _.
K
~
PAGE 2
lOOOl . |
4942/t1'0by
.
AGREED:
/s/’V. Q’aige (Ellfndye
V. PAIGE ELDRIDGE
State Bar No. 24096747 ‘
WITHERITE LAW GROUP, PLLC
10440 N. Central Expressway, Ste. 400
Dallas, Texas 75231-2228
-
Tel: 214.378.6665
Fax: 214.378.6670
pal9e.eldridgeGDwitheritelaw.com
ATTORNEYS FOR PLAINTIFF
'
/s/]ofin ‘W. (Breeze .
¢
,
.~\
'
_
' ’
JOHN W. BREEZE .
State Bar No. 00796248 ' ,
-
THE LECRONELAW FIRM, PC
123 North C?ockett-Street, Suite 200
Sherman, Texas 75090
Tel: 903-813-1900
Fax: 903-813-1944
esewice@lecronelaw.com
ATTORNEYS FOR DEFENDANT; JAMES GOMEZ
/s/Wad'ine K, Weatfierafl' .
,
" '
RANDALL G. WALTERS -‘
'
State Bar. No. 20819480
'
1'
NADINE K. WEATHERAL'L
‘ -
State Bar. No. 24073060
WALTERS, BALIDOA& CRAIN L.L.P.
Meadow Park Tower, Sugte 1500 ,
10440 NOrth Central Expressway
Dallas, Texas 75231
Tel: 214.749.4805
Fax: 214.347.8381
randvwaltersébwbclawfi-rm.c0m
'
WaltersEDocsNotificationsailwbclawfirm.com
FOR DEFENDANT, EXCLUSIVE NATIONWIDE DELIVERY, INC.
{\TTORNEYS
‘
AGREED’SCHEDULINGORDER ‘
_
'
\ . PAGE 3.
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,
10001.14942/troby
Document Filed Date
July 27, 2022
Case Filing Date
August 02, 2019
Category
MOTOR VEHICLE ACCIDENT
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Preview
CAUSE NO.DC-l9-10926 . . _ \ . VASHONE RHODES § IN THE DISTRICT COURT 'V. § .160” JUDICIAL DISTRICT ' § § JAMES GOMEZ AND EXCLUSIVE § NATIONWIDE DELIVERY, INC. _ § DALLAS CO UN TY, TEXAS AGREED SCHEDULING ORDER I 1. 06-01-2022 DEADLINE-TOY FILE ALL CLAIMS. All claims must be filed/all parties identified including couIIteIclaims, cross-—claims and/or Iesponsible thiId- paIty claims excluding CPRC 33. 004(j) be Ieopened to addIess deceased ' Defendant James Gomez. 2. 06—06—2022 EXPERTS for PLAINTIFF(S) AND INTERVENOR(S) expected to testify in person or 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 . affi‘ants are excluded from report requirements. J ' 3. _ 07—05—2022 EXPERTS forI-ALL OTHER PARTIES expected to testify -in person or by deposition (“Testifying Expert”) shall be designated by this date. No .additional testifying expeIts will be permitted to testify except for good cause shown. Record custodians \and cost of services affiants are excluded from report requirements. 4.- 08-19-2022 SUMMARY JUDGMENT motions shall be filed pIiOI to this date and set ,fOI no lateI than the Pr-e Trial Hearing. No evidence summary [162111110 judgment mOtions should' not be set fOI healing pIior to the discovery cut-_ i ' Off. s. . 09-02-2022 AMENDMENTS to pleadings asserting new causes of action or _ affirmative defenses must be filed by this date. Any othe‘I amended _ pleadings must be filed no later than seven (7) days afteI the end of the diScoveIy peIiOd. Amended pleadings responsive to timely filed pleadings under this schedule may be filed after the deadline fOI amended pleadings f if led within two (2) weeks after the pleading to whiCh they respOnd. 6. 09-02-2022 SETTLEMENT CONFERENCES AND/OR. MEDIATIONS shall be completed by this date. The patties have selected KaIeII Gammon and will contact the t0 arIaIIge the mediation. ‘ mediator AGREED SCHEDULING ORDER - PAGE I .' I 000l . l 4942/tr0by ' DISCOVERY must be initiated in time to allow completion of discove1y by this date. No discove1y may be conducted after this date without agreement of counsel. - (19-09-2022 MOTION TO EXCLUDE EXPERT and/or DAUBERT-ROBINSON challenges to expert testimony must be filed by this date. Any hearings ove1 any such motion 111uSt be conducted no late1 than 10 days before the Initial T11al Setting 09—09-2022 -MOTION TO COMPEL DISCOVERY RESPONSES TO DISCOVERY (other than relating to factual’ matters arising after the end of the discovery period) must be filed or such complaint is‘ waived, except 1 for the sanction of exclusion under Rule 193.6. 10. 09 29 2022 The parties shall file with the Conn: a. Exhibit List; , b. Witness List; c. Designation of deposition testimony to be offered in diiect ' examination; (I. MotiOn in Lin1ine W/proposed Order; and e. , Proposed Jury Charge. ll. 10—03-2022 J U RY TRIAL. Should this case not be reached for trial 011 the above‘trial setting, absent a new scheduling order being entered or a Rule li‘l agreement stating otherwise, the parties agree that the discove1y deadline Will end 30 days bef01e the new t1ial date. Additionally, all p1et1ial . ' deadlines (witness list, exhibit list, motion in li111ine,page-line designations and proposed ju1y cl1a10e) will be moved to the same number of calendar dates pri’01 to t1ialas set out' above, according to tl1e11ewti1'al date. Plaintiff/Plaintiff’s. counsel shall serve a copy of this Order on any cuirently named defendant(s)'answe1ingafte1 this date. The party joining an additional party shall serve a copy of ‘ this 01de1 on the new party concurrently with the that paity. pleadingJoining SIGNED the ‘2’)“, of ,2022. Q ”Lg! ' ' JUDGE FRESIDING ' AGREED SCHEDULING ORDER _. K ~ PAGE 2 lOOOl . | 4942/t1'0by . AGREED: /s/’V. Q’aige (Ellfndye V. PAIGE ELDRIDGE State Bar No. 24096747 ‘ WITHERITE LAW GROUP, PLLC 10440 N. Central Expressway, Ste. 400 Dallas, Texas 75231-2228 - Tel: 214.378.6665 Fax: 214.378.6670 pal9e.eldridgeGDwitheritelaw.com ATTORNEYS FOR PLAINTIFF ' /s/]ofin ‘W. (Breeze . ¢ , .~\ ' _ ' ’ JOHN W. BREEZE . State Bar No. 00796248 ' , - THE LECRONELAW FIRM, PC 123 North C?ockett-Street, Suite 200 Sherman, Texas 75090 Tel: 903-813-1900 Fax: 903-813-1944 esewice@lecronelaw.com ATTORNEYS FOR DEFENDANT; JAMES GOMEZ /s/Wad'ine K, Weatfierafl' . , " ' RANDALL G. WALTERS -‘ ' State Bar. No. 20819480 ' 1' NADINE K. WEATHERAL'L ‘ - State Bar. No. 24073060 WALTERS, BALIDOA& CRAIN L.L.P. Meadow Park Tower, Sugte 1500 , 10440 NOrth Central Expressway Dallas, Texas 75231 Tel: 214.749.4805 Fax: 214.347.8381 randvwaltersébwbclawfi-rm.c0m ' WaltersEDocsNotificationsailwbclawfirm.com FOR DEFENDANT, EXCLUSIVE NATIONWIDE DELIVERY, INC. {\TTORNEYS ‘ AGREED’SCHEDULINGORDER ‘ _ ' \ . PAGE 3. ' , 10001.14942/troby