On August 08, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Mclaurin, John,
and
Baylor Scott & White Health,
Trac-Work, Inc.,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
Preview
FILED
9/9/2021 6:27 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
CAROLYN SELLERS DEPUTY
CAUSE NO. DC-l 9-1 1346
John McLaurin, IN THE DISTRICT COURT OF
§§§§§§§§§
Plaintiffi
V. DALLAS COUNTY, TEXAS
Trac-Work, Inc.,
Defendant. 116TH JUDICIAL DISTRICT
PLAINTIFF ’S RESPONSE TO TRAC-WORK, IN C.’S
PARTIALLY OPPOSED EMERGENCY MOTION FOR CON TINUANCE
As outlined in Trac-Work, Inc.’s emergency motion for continuance, Plaintiff does not
oppose an order continuing the current September 13 trial date, but objects to moving trialinto
2022. This case has been on file since August 2019. The parties have conducted extensive
discovery, taken multiple depositions, and were all but ready for trial. Plaintiff acknowledges the
tragic nature of the death of Trac-Work’s expert. But Plaintiff argues that a continuance of 45-60
days is more than enough time for Trac-Work to hire a replacement expert who can review the
documents and discovery and prepare opinions about the case. This is not a complex case with
complex issues that would justify a five-month continuance this close to trial. A continuance of
45-60 days should more than suffice. Plaintiff is more than willing to work with Trac-Work if
they require additional discovery, although none should be necessary given the late stage of the
proceedings. Accordingly, Plaintiff asks the Court to deny Trac-Work’s motion to the extent
Trac-Work seeks to continue the case into early 2022.
Respectfully Submitted,
ARNOLD & ITKIN LLP
/s/ Roland Christensen
Kurt Arnold
SBN: 24036150
kamold@ amolditkin.com
Caj Boatright
SBN: 24036237
cboatright@arnolditkin.com
Roland Christensen
SBN: 24101222
rchristensen@ arnolditkin.com
6009 Memorial Drive
Houston, Texas 77007
Tel: 713.222.3800
Fax: 713.222.3850
e-service(a)arnolditkin.com
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
I hereby certify that on September 9, 2021, a true and correct copy of the foregoing was
served on all counsel of record in compliance with Rules 21 and 21a of the Texas Rules of Civil
Procedure.
/s/ Roland Christensen
Roland Christensen
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.
Cristal Becerra on behalf of Roland Christensen
Bar No. 24101222
cbecerra@arnolditkin.com
Envelope ID: 57113867
Status as of 9/10/2021 7:55 AM CST
Associated Case Party: TRAC-WORK, INC.
Name BarNumber Email TimestampSubmitted Status
George (Trey) NWilson twilson@thompsoncoe.com 9/9/2021 6:27:26 PM SENT
Deborah King dking@thompsoncoe.com 9/9/2021 6:27:26 PM SENT
Dymris Williams ddwilliams@thompsoncoe.com 9/9/2021 6:27:26 PM SENT
Joanna M.Tollenaere JTollenaere@thompsoncoe.com 9/9/2021 6:27:26 PM SENT
Rosa Delafuente rdelafuente@thompsoncoe.com 9/9/2021 6:27:26 PM SENT
Charles Jimerson cjimerson@thompsoncoe.com 9/9/2021 6:27:26 PM SENT
Grace Rojas grojas@thompsoncoe.com 9/9/2021 6:27:26 PM SENT
Megan Altobelli maltobelli@thompsoncoe.com 9/9/2021 6:27:26 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Kurt Arnold e-service@arnolditkin.com 9/9/2021 6:27:26 PM SENT
Roland Christensen 24101222 rchristensen@arnolditkin.com 9/9/2021 6:27:26 PM SENT
Cristal Becerra cbecerra@arnolditkin.com 9/9/2021 6:27:26 PM SENT
Document Filed Date
September 09, 2021
Case Filing Date
August 08, 2019
Category
OTHER PERSONAL INJURY
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FILED 9/9/2021 6:27 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS CAROLYN SELLERS DEPUTY CAUSE NO. DC-l 9-1 1346 John McLaurin, IN THE DISTRICT COURT OF §§§§§§§§§ Plaintiffi V. DALLAS COUNTY, TEXAS Trac-Work, Inc., Defendant. 116TH JUDICIAL DISTRICT PLAINTIFF ’S RESPONSE TO TRAC-WORK, IN C.’S PARTIALLY OPPOSED EMERGENCY MOTION FOR CON TINUANCE As outlined in Trac-Work, Inc.’s emergency motion for continuance, Plaintiff does not oppose an order continuing the current September 13 trial date, but objects to moving trialinto 2022. This case has been on file since August 2019. The parties have conducted extensive discovery, taken multiple depositions, and were all but ready for trial. Plaintiff acknowledges the tragic nature of the death of Trac-Work’s expert. But Plaintiff argues that a continuance of 45-60 days is more than enough time for Trac-Work to hire a replacement expert who can review the documents and discovery and prepare opinions about the case. This is not a complex case with complex issues that would justify a five-month continuance this close to trial. A continuance of 45-60 days should more than suffice. Plaintiff is more than willing to work with Trac-Work if they require additional discovery, although none should be necessary given the late stage of the proceedings. Accordingly, Plaintiff asks the Court to deny Trac-Work’s motion to the extent Trac-Work seeks to continue the case into early 2022. Respectfully Submitted, ARNOLD & ITKIN LLP /s/ Roland Christensen Kurt Arnold SBN: 24036150 kamold@ amolditkin.com Caj Boatright SBN: 24036237 cboatright@arnolditkin.com Roland Christensen SBN: 24101222 rchristensen@ arnolditkin.com 6009 Memorial Drive Houston, Texas 77007 Tel: 713.222.3800 Fax: 713.222.3850 e-service(a)arnolditkin.com ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE I hereby certify that on September 9, 2021, a true and correct copy of the foregoing was served on all counsel of record in compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure. /s/ Roland Christensen Roland Christensen 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. Cristal Becerra on behalf of Roland Christensen Bar No. 24101222 cbecerra@arnolditkin.com Envelope ID: 57113867 Status as of 9/10/2021 7:55 AM CST Associated Case Party: TRAC-WORK, INC. Name BarNumber Email TimestampSubmitted Status George (Trey) NWilson twilson@thompsoncoe.com 9/9/2021 6:27:26 PM SENT Deborah King dking@thompsoncoe.com 9/9/2021 6:27:26 PM SENT Dymris Williams ddwilliams@thompsoncoe.com 9/9/2021 6:27:26 PM SENT Joanna M.Tollenaere JTollenaere@thompsoncoe.com 9/9/2021 6:27:26 PM SENT Rosa Delafuente rdelafuente@thompsoncoe.com 9/9/2021 6:27:26 PM SENT Charles Jimerson cjimerson@thompsoncoe.com 9/9/2021 6:27:26 PM SENT Grace Rojas grojas@thompsoncoe.com 9/9/2021 6:27:26 PM SENT Megan Altobelli maltobelli@thompsoncoe.com 9/9/2021 6:27:26 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Kurt Arnold e-service@arnolditkin.com 9/9/2021 6:27:26 PM SENT Roland Christensen 24101222 rchristensen@arnolditkin.com 9/9/2021 6:27:26 PM SENT Cristal Becerra cbecerra@arnolditkin.com 9/9/2021 6:27:26 PM SENT