On May 02, 2019 a
SCHEDULING ORDER - LEVEL 2 - (SIGNED ON LAST PAGE)
was filed
involving a dispute between
Allen, Yolanda M,
and
Habash, Sami,
Neo Proteus Llc,
Sahoury, Christine,
Sams, Clayton,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
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Cause N0. DC-19-06208
YOLANDA M. ALLEN, § IN THE DISTRICT COURT
§
Plaintiff, §
§
v. §
§
SAMI HABASH and CHRISTINE SAHOURY, § >
160m DISTRICT COURT
§
§
Defendants §
§
v. §
§
VICKI ALEXANDER, §
§
Third-Party Defendant. § DALLAS COUNTY, TEXAS
UNIFORM SCHEDULING ORDER (LEVEL 1 OR 2)
1n accordance with Rules 166, 190 and 192 ofthe Texas Rules ofCiVil Procedure, the Court
makes the following order to control discovery and the schedule of this cause:
l. This case will be ready and is set for trial at 8:30 a.m. on August 32 2020 (the
"Initial Trial Setting"). Reset or continuance of the Initial Trial Setting will not alter any
Order, except those set out in paragraph 7 of this Order, 0r
deadlines established in this
Rules of Civil Procedure, unless otherwise provided by order. If not
established by the Texas
reached as set,the case may be carried for that week. FAILURE TO COMPLY WITH
THE DEADLINES CONTAINED HEREIN SHALL NOT SUPPORT A MOTION TO
CONTINUE THIS MATTER.
2. Unless otherwise ordered, discovery in this case will be controlled by:
K Rule 190.3 (Level 2)
agreement 0f the party, leave of court, or where
of the Texas Rules of Civil Procedure. Except by
the Texas Rules of Civil Procedure, no party may obtain discovery of
expressly authorized by
information subject to disclosure under Rule 194 by any other form of discovery.
objection or motion t0 exclude or limit expert testimony due to qualification
of
3. Any
the expert 0r reliability of the opinions must be filed no later than seven (7) days after the close of
the discovery period, 0r such objection is waived. Any such objection not heard 30 days prior to
(other than relating
the Initial Trial Setting is waived. Any motion to compel responses to discovery
must be filed no laterthan seven (7)
to factual matters arising after the end ofthe discovery period)
except for the sanction of
days after the close of the discovery period or such complaint is waived,
exclusion under Rule 193.6.
4. Any amended pleadings asserting new causes of action or affirmative defenses must
be filed no laterthan thirty (30) days before the end of the discovery period and any ‘other amended
pleadings must be filed no later than seven (7) days after the end of the discovery period. Amended
pleadings responsive t0 timely filed pleadings under this schedule may be filed after the deadline for
amended pleadings iffiled within two (2) weeks after the pleading to which they respond. Except with leave
of court,TRCP 166a motions must be heard n0 later than thirty (30) days before trial.
5. No additional parties may be joined more than five (5) months after entry ofthis order
except 0n motion for leave showing good cause. This paragraph does not otherwise alter the
requirements of Rule 38. The partyjoining an additional party shall serve a copy of this Order on
the new party concurrently with the pleading joining that party.
6.a. The parties shall mediate this case no later than thirty (30) days before the Initial Trial
Setting, unless otherwise provided by court order. Mediation will be conducted in accordance with
the Standing Dallas County Civil District Court Order Regarding Mediation, which is available
from the Dallas County ADR Coordinator. All parties shall contact the mediator to arrange the
mediation. Motions for continuances of trial will not be granted due to failure to mediate.
b. The mediator has been selected by agreement of the parties: Accordingly, Jim
Cuaderes ishereby appointed mediator. Any mediator substitution requested more than
9O days after the date of this order may only be made by motion for submission to the Court
for good cause and under extraordinary circumstances.
Fourteen (14) days before the Initial Trial Setting, the patties shall exchange a list of exhibits,
including any demonstrative aids and affidavits, and shall exchange copies of any exhibits not
previously produced in discovery; over-designation is strongly discouraged and may be
sanctioned. Except for records to be offered by way of business record affidavits, each exhibit
must be identified separately and not by category or group designation. Rule 193.7 applies to this
designation. On or before ten (10) days before the Initial Trial Setting, the attorneys in charge for
allparties shall meet in person t0 confer on stipulations regarding the materials to be submitted to
the Court under this paragraph and attempt t0 maximize agreement on such matters. By 4 pm on
the Thursday before the Initial Trial Setting, the parties shall file with the Court the materials stated
in Rule 166(e)-(l), an estimate 0f the length of trial, designation of deposition testimony to be
offered in direct examination, and any motions in limine. Failure to file such materials may result
in dismissal for want of prosecution or other appropriate sanction.
Plaintiff/Plaintist counsel shall serve a copy of this Order on any currently named defendant(s)
answering after this date.
SIGNED ON:
JUDGE PRESIDING
cc: Counsel of Record/Pro Se Parties and Mediator
AGREED AND APPROVED:
/s/Tonyce Gustave
Tonyce Gustave
Attorney for Plaintiff Yolanda M. Allen
/s/ Marguerite Broussard
Marguerite Broussard
Attorney for Defendants Sami Habash and Christine Sahoury
(signature attached)
Vicki Alexander — Pro Se
Third-Party Defendant
PlaintifflPlaintiff’ s counsel shall serve
answering after
SIGNEDON:
cc:
this date.
0LMM
Counsel of Record/Pro
H/ w”
Se Parties and Mediator
4ML1.
JUDGE P‘RESIDING
w
a copy of this Order on any currently named defendant(s)
AGREED AND APPROVED:
Tonyce Gustave
Attorney for Plaintiff Yolanda M. Allen
Marguerite Broussard
Attorney for Defendants Sami Habash and Christine Sahoury
f
/
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f
3
f
w
WW....m-unmnu,"W .
{a f, h,
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k
Vicki Alexander {Pro Se
Third-Party Defghdant
f
§
Document Filed Date
December 11, 2019
Case Filing Date
May 02, 2019
Category
CNTR CNSMR COM DEBT
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Cause N0. DC-19-06208 YOLANDA M. ALLEN, § IN THE DISTRICT COURT § Plaintiff, § § v. § § SAMI HABASH and CHRISTINE SAHOURY, § > 160m DISTRICT COURT § § Defendants § § v. § § VICKI ALEXANDER, § § Third-Party Defendant. § DALLAS COUNTY, TEXAS UNIFORM SCHEDULING ORDER (LEVEL 1 OR 2) 1n accordance with Rules 166, 190 and 192 ofthe Texas Rules ofCiVil Procedure, the Court makes the following order to control discovery and the schedule of this cause: l. This case will be ready and is set for trial at 8:30 a.m. on August 32 2020 (the "Initial Trial Setting"). Reset or continuance of the Initial Trial Setting will not alter any Order, except those set out in paragraph 7 of this Order, 0r deadlines established in this Rules of Civil Procedure, unless otherwise provided by order. If not established by the Texas reached as set,the case may be carried for that week. FAILURE TO COMPLY WITH THE DEADLINES CONTAINED HEREIN SHALL NOT SUPPORT A MOTION TO CONTINUE THIS MATTER. 2. Unless otherwise ordered, discovery in this case will be controlled by: K Rule 190.3 (Level 2) agreement 0f the party, leave of court, or where of the Texas Rules of Civil Procedure. Except by the Texas Rules of Civil Procedure, no party may obtain discovery of expressly authorized by information subject to disclosure under Rule 194 by any other form of discovery. objection or motion t0 exclude or limit expert testimony due to qualification of 3. Any the expert 0r reliability of the opinions must be filed no later than seven (7) days after the close of the discovery period, 0r such objection is waived. Any such objection not heard 30 days prior to (other than relating the Initial Trial Setting is waived. Any motion to compel responses to discovery must be filed no laterthan seven (7) to factual matters arising after the end ofthe discovery period) except for the sanction of days after the close of the discovery period or such complaint is waived, exclusion under Rule 193.6. 4. Any amended pleadings asserting new causes of action or affirmative defenses must be filed no laterthan thirty (30) days before the end of the discovery period and any ‘other amended pleadings must be filed no later than seven (7) days after the end of the discovery period. Amended pleadings responsive t0 timely filed pleadings under this schedule may be filed after the deadline for amended pleadings iffiled within two (2) weeks after the pleading to which they respond. Except with leave of court,TRCP 166a motions must be heard n0 later than thirty (30) days before trial. 5. No additional parties may be joined more than five (5) months after entry ofthis order except 0n motion for leave showing good cause. This paragraph does not otherwise alter the requirements of Rule 38. The partyjoining an additional party shall serve a copy of this Order on the new party concurrently with the pleading joining that party. 6.a. The parties shall mediate this case no later than thirty (30) days before the Initial Trial Setting, unless otherwise provided by court order. Mediation will be conducted in accordance with the Standing Dallas County Civil District Court Order Regarding Mediation, which is available from the Dallas County ADR Coordinator. All parties shall contact the mediator to arrange the mediation. Motions for continuances of trial will not be granted due to failure to mediate. b. The mediator has been selected by agreement of the parties: Accordingly, Jim Cuaderes ishereby appointed mediator. Any mediator substitution requested more than 9O days after the date of this order may only be made by motion for submission to the Court for good cause and under extraordinary circumstances. Fourteen (14) days before the Initial Trial Setting, the patties shall exchange a list of exhibits, including any demonstrative aids and affidavits, and shall exchange copies of any exhibits not previously produced in discovery; over-designation is strongly discouraged and may be sanctioned. Except for records to be offered by way of business record affidavits, each exhibit must be identified separately and not by category or group designation. Rule 193.7 applies to this designation. On or before ten (10) days before the Initial Trial Setting, the attorneys in charge for allparties shall meet in person t0 confer on stipulations regarding the materials to be submitted to the Court under this paragraph and attempt t0 maximize agreement on such matters. By 4 pm on the Thursday before the Initial Trial Setting, the parties shall file with the Court the materials stated in Rule 166(e)-(l), an estimate 0f the length of trial, designation of deposition testimony to be offered in direct examination, and any motions in limine. Failure to file such materials may result in dismissal for want of prosecution or other appropriate sanction. Plaintiff/Plaintist counsel shall serve a copy of this Order on any currently named defendant(s) answering after this date. SIGNED ON: JUDGE PRESIDING cc: Counsel of Record/Pro Se Parties and Mediator AGREED AND APPROVED: /s/Tonyce Gustave Tonyce Gustave Attorney for Plaintiff Yolanda M. Allen /s/ Marguerite Broussard Marguerite Broussard Attorney for Defendants Sami Habash and Christine Sahoury (signature attached) Vicki Alexander — Pro Se Third-Party Defendant PlaintifflPlaintiff’ s counsel shall serve answering after SIGNEDON: cc: this date. 0LMM Counsel of Record/Pro H/ w” Se Parties and Mediator 4ML1. JUDGE P‘RESIDING w a copy of this Order on any currently named defendant(s) AGREED AND APPROVED: Tonyce Gustave Attorney for Plaintiff Yolanda M. Allen Marguerite Broussard Attorney for Defendants Sami Habash and Christine Sahoury f / ‘ f 3 f w WW....m-unmnu,"W . {a f, h, f3 k Vicki Alexander {Pro Se Third-Party Defghdant f §