On August 23, 2017 a
2019-01.05 Notice of Filing of Rule 11 Agreement - RULE 11
was filed
involving a dispute between
Murphy, Marty,
and
Labcon Inc,
Pavecon Holdings Co., Inc.,
Pavecon Ltd. Co.,
Pavecon Public Works Gp Llc,
Pavecon Public Works Lp,
Thompson, Stephanie,
Walker, C David,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
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FILED
DALLAS COUNTY
1/15/2019 12:00PM
FELICIA PITRE
DISTRICT CLERK
Kevin Molden
CAUSE NO. DC-17-10592
MARTY MURPHY, IN TI-IE DISTRICT COURT
Plaintiff and Counterclaim-
Defendant
V.
”mmmmmwmwmmmmmwwm
PAVECON HOLDING CO., INC.,
PAVECON LTD. CO., 192'” JUDICIAL DISTRICT
PAVECON PUBLIC WORKS LP,
PAVECON PUBLIC WORKS GP LLC,
LABCON, INC., DAVID WALKER,
Defendants and Counterclaim-
Plaintiffs, DALLAS COUNTY, TEXAS
NOTICE OF FILING RULE 11 AGREEMENT
Marty Murphy (“Murphy”) files this agreement under Texas Rule of Civil Procedure 11
entered into on January 10, 2019 extending certain deadlines in the Amended Agreed Level Three
Docket Control Order. This agreement is attached hereto and incorporated herein as Exhibit “A”
NOTICE 0F FILING RULE 11 AGREEMENT Page 1
Respectfully submitted,
CANTEY HANGER LLP
/s/ Stephanie L. Millett
Charles H. Smith — Attorney in Charge
State Bar No. 18550500
chsmith@cantevh_anger.com
David Denny
State Bar No. 00787354
ddennv@cantevha_nger.com
Stephanie L. Millett
State Bar No. 00797070
gmiflefl@canteyl@ger.com
1999 Bryan Street, Suite 3300
Dallas, Texas 75201
(214) 740-4200
(214) 978-4140 — Telecopier
ATTORNEYS FOR MARTY MURPHY
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy ofthe foregoing has been served on all counsel
of record in accordance with the Texas Rules of Civil Procedure this 15th day of January, 2019.
/s/ Stephanie L. Millett
NOTICE OF FILING RULE ll AGREEMENT Page 2
EXHIBIT
Stephanie Millett
i g
From: Bob Arnett < barnett@ca rterarnett.com >
Sent: Thursday, January 10, 2019 1:33PM
To: Stephanie Millett
Cc: Stacey Cho Hernandez; Charles H. Smith; Bryan David
Subject: Re: Murphy v. Pavecon
That isagreeable. Thanks.
J. Robert Arnett ll
Carter Arnett PLLC
8150 N. Central Expressway
Suite 500
Dallas, TX 75206
barnett@carterarnett.com
214-550-8209 direct
214-550-8185 fax
Sent from my mobile device.
Please excuse my typos.
On Jan 10, 2019, at 1:22 PM, Stephanie Millett wrote:
Good afternoon,
After speaking with Charlie, we will agree to extending the rebuttal expert designation deadline
to 1/23/2019 ifwe can extend the Discovery, Daubert/Robinson Challenges and Dispositive Motion
deadlines by a week as follows:
Discovery 2/11 to 2/18
Daubert/Robinson Challenges 1/25 to 2/01
Dispositive Motions 2/25 to 3/04
We believe this isbest since the expert deadlines have previously been moved and additional
time isneeded.
Thanks
-Stephanie
From: Bob Arnett |mailtozbarnettharterarnett.com|
Sent: Wednesday, January 09, 2019 2:32 PM
To: Charles H. Smith
Subject: Murphy v. Pavecon
Charles:
Would you be agreeable to extending the deadline for rebuttal expert designations/reports a week to
1/23/19?
1
Thanks.
Arnett II|
C A RT E R .11).r§1(;li);;:
A R N E T T Bfiffigfiflffii‘fi’s‘asms
www.carteramett.com
8150 N. Central Expressway, Suite 500, Dallas, Texas 75206
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Document Filed Date
January 15, 2019
Case Filing Date
August 23, 2017
Category
CNTR CNSMR COM DEBT
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FILED DALLAS COUNTY 1/15/2019 12:00PM FELICIA PITRE DISTRICT CLERK Kevin Molden CAUSE NO. DC-17-10592 MARTY MURPHY, IN TI-IE DISTRICT COURT Plaintiff and Counterclaim- Defendant V. ”mmmmmwmwmmmmmwwm PAVECON HOLDING CO., INC., PAVECON LTD. CO., 192'” JUDICIAL DISTRICT PAVECON PUBLIC WORKS LP, PAVECON PUBLIC WORKS GP LLC, LABCON, INC., DAVID WALKER, Defendants and Counterclaim- Plaintiffs, DALLAS COUNTY, TEXAS NOTICE OF FILING RULE 11 AGREEMENT Marty Murphy (“Murphy”) files this agreement under Texas Rule of Civil Procedure 11 entered into on January 10, 2019 extending certain deadlines in the Amended Agreed Level Three Docket Control Order. This agreement is attached hereto and incorporated herein as Exhibit “A” NOTICE 0F FILING RULE 11 AGREEMENT Page 1 Respectfully submitted, CANTEY HANGER LLP /s/ Stephanie L. Millett Charles H. Smith — Attorney in Charge State Bar No. 18550500 chsmith@cantevh_anger.com David Denny State Bar No. 00787354 ddennv@cantevha_nger.com Stephanie L. Millett State Bar No. 00797070 gmiflefl@canteyl@ger.com 1999 Bryan Street, Suite 3300 Dallas, Texas 75201 (214) 740-4200 (214) 978-4140 — Telecopier ATTORNEYS FOR MARTY MURPHY CERTIFICATE OF SERVICE This is to certify that a true and correct copy ofthe foregoing has been served on all counsel of record in accordance with the Texas Rules of Civil Procedure this 15th day of January, 2019. /s/ Stephanie L. Millett NOTICE OF FILING RULE ll AGREEMENT Page 2 EXHIBIT Stephanie Millett i g From: Bob Arnett < barnett@ca rterarnett.com > Sent: Thursday, January 10, 2019 1:33PM To: Stephanie Millett Cc: Stacey Cho Hernandez; Charles H. Smith; Bryan David Subject: Re: Murphy v. Pavecon That isagreeable. Thanks. J. Robert Arnett ll Carter Arnett PLLC 8150 N. Central Expressway Suite 500 Dallas, TX 75206 barnett@carterarnett.com 214-550-8209 direct 214-550-8185 fax Sent from my mobile device. Please excuse my typos. On Jan 10, 2019, at 1:22 PM, Stephanie Millett wrote: Good afternoon, After speaking with Charlie, we will agree to extending the rebuttal expert designation deadline to 1/23/2019 ifwe can extend the Discovery, Daubert/Robinson Challenges and Dispositive Motion deadlines by a week as follows: Discovery 2/11 to 2/18 Daubert/Robinson Challenges 1/25 to 2/01 Dispositive Motions 2/25 to 3/04 We believe this isbest since the expert deadlines have previously been moved and additional time isneeded. Thanks -Stephanie From: Bob Arnett |mailtozbarnettharterarnett.com| Sent: Wednesday, January 09, 2019 2:32 PM To: Charles H. Smith Subject: Murphy v. Pavecon Charles: Would you be agreeable to extending the deadline for rebuttal expert designations/reports a week to 1/23/19? 1 Thanks. Arnett II| C A RT E R .11).r§1(;li);;: A R N E T T Bfiffigfiflffii‘fi’s‘asms www.carteramett.com 8150 N. Central Expressway, Suite 500, Dallas, Texas 75206 This e-mail (including any attachments) may contain information that is private, confidential, or protected by attomey-client or other privilege. If you have received this e—mail in error, please delete itfrom your system without copying it and notify sender by reply e-mail, so that our records can be corrected. Links contained in this email have been replaced by ZixProtect Link Protection. If you click on a link in the email above, the link will be analyzed for known threats. If a known threat is found, you will not be able to proceed to the destination. If suspicious content is detected, you will see a warning.