On March 17, 2021 a
Stipulation,Agreement
was filed
involving a dispute between
Williams, Marilyn,
and
Guijoza, Eutiquio,
Jru Properties, Llc,
Rodriguez, Eleazar,
Romo, Pablo, Iii,
Unell, Joe,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
CAUSE NO. DC-21-03496
MARILYN THE DISTRICT COURT
§§§§§§§§§§§§§
WILLIAMS; IN OF
Plaintiff,
VS.
DALLAS COUNTY, TEXAS
PABLO ROMO, III;JRU PROPERTIES,
LLC D/BIA 4 WHEEL DRIVE AUTO;
EUTIQUIO GUIJOZA A/KlA EUTIQUIO
GUIJOSA; AND ELEAZAR
RODRIGUEZ;
Defendants. 116T“ JUDICIAL DISTRICT
AGREED SCHEDULING ORDER
The parties submit this proposed Agreed Scheduling Order. The Court, having
considered said Order, isof the opinion that the Order should be GRANTED.
IT IS THEREFORE ORDERED that the following pre-trial deadlines shall apply
to the above—entitled and numbered cause unless otherwise modified by agreement of
the parties or Order of the Court:
February 9, 2022 Deadline by which all claims must be filed/all parties
identified including counterclaims, cross—claims and/or
responsible third-party claims, excluding CPRC
33.0040).
April 8 2022 Plaintiff’s deadline to designate retained experts with
reports.
April 8 2022 Plaintiff’s deadline to serve CPRC 18.001 affidavits for
treatment that occurred prior to suit. Defendants have
30 days from the date the affidavit isproduced to
counter each affidavit.
May 10, 2022 Defendant’s deadline to designate retained experts with
reports.
AGREED SCHEDULING ORDER — PAGE 1
May 10, 2022 Mediation deadline. Mediation is scheduled to occur
before this date with mediator Mike Carnahan, 12001 N.
Central Expressway, Suite 650, Dallas, TX 75243.
June 8, 2022 IfPlaintiff received medical treatment after filing suit the
CPRC 18.001 affidavits for this treatment are due by
this date. Defendants have 30 days from the date the
affidavit is produced to counter each affidavit.
July 8, 2022 Deadline by which the parties must have completed
discovery (alldiscovery must be initiated at a time early
enough to ensure that the completion of same will not
surpass this deadline).
August 1, 2022 Deadline by which the parties file their page/line
designations of video deposition testimony to be used at
trial.
August 3, 2022 Deadline by which parties file their objections to
page/line designations of video deposition testimony to
be used at trial.
August 4-,2022 Deadline by which the parties must file their rebuttal m
page/line designations of video deposition testimony to
be used at trial.
August 4, 2022 Deadline by which the parties must file pretrial
disclosures, motions in limine, any pre—trial motions, a
proposed jury charge, and parties must exchange true
and correct copies of exhibits not previously produced.
August 8, 2022 JURY TRIAL
All deadlines in this Scheduling Order may be modified by Rule 11 agreement,
except for the trial date. Should this case not be reached for trial on the August 8,
2022 trial setting, absent a new scheduling order being entered or a Rule 11
agreement stating otherwise, the parties agree that the discovery deadline will end 30
days before the new trial date. Additionally, all pretrial deadlines (pretrial disclosures,
AGREED SCHEDULING ORDER — PAGE 2
motion in limine, and page—line designations) will be moved to the same number of
calendar‘days prior to trial as set out above, according to the new trial date.
The parties agree that nothing in this Scheduling Order will affect any party's
right to seek leave of Court under Section 18.001(i) of the Texas Civil Practice &
Remedies Code.
SIGNED THIS ogdkday of ,2021.
EASE,
ING
APPROVED AS TO FORM AND CONTENT:
WITHER TE L GROUP, PLLC
By
LAUREN JQBm/
State Bar No. 24081236
lauren.iobin@witheritelaw.com
SHELLY GRECO
State Bar No. 24008168
shelly.qreco@witheritelaw.com
10440 N. Central Expressway
Suite 400
Dallas, TX 75231-2228
214/378-6665
214/378-6670 (fax)
ATTORNEYS FOR PLAINTIFF
AGREED SCHEDULlNG ORDER — PAGE 3
THE LECRONE LAW FIRM, P.C.
By: /s/ Adam LeCrone
ADAM B. LECRONE
State Bar No.00786447
adam@lecronelaw.com
Wall Street Plaza
123 N. Crockett Street, Suite 200
Sherman, TX 75090
(903) 813-1900
(903) 813—1944(fax)
ATTORNEY FOR DEFENDANTS PABLO ROMO, IllAND JRU PROPERTIES,
LLC DlB/A 4 WHEEL DRIVE AUTO
AGREED SCHEDULING ORDER — PAGE 4
Document Filed Date
July 26, 2021
Case Filing Date
March 17, 2021
Category
MOTOR VEHICLE ACCIDENT
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CAUSE NO. DC-21-03496 MARILYN THE DISTRICT COURT §§§§§§§§§§§§§ WILLIAMS; IN OF Plaintiff, VS. DALLAS COUNTY, TEXAS PABLO ROMO, III;JRU PROPERTIES, LLC D/BIA 4 WHEEL DRIVE AUTO; EUTIQUIO GUIJOZA A/KlA EUTIQUIO GUIJOSA; AND ELEAZAR RODRIGUEZ; Defendants. 116T“ JUDICIAL DISTRICT AGREED SCHEDULING ORDER The parties submit this proposed Agreed Scheduling Order. The Court, having considered said Order, isof the opinion that the Order should be GRANTED. IT IS THEREFORE ORDERED that the following pre-trial deadlines shall apply to the above—entitled and numbered cause unless otherwise modified by agreement of the parties or Order of the Court: February 9, 2022 Deadline by which all claims must be filed/all parties identified including counterclaims, cross—claims and/or responsible third-party claims, excluding CPRC 33.0040). April 8 2022 Plaintiff’s deadline to designate retained experts with reports. April 8 2022 Plaintiff’s deadline to serve CPRC 18.001 affidavits for treatment that occurred prior to suit. Defendants have 30 days from the date the affidavit isproduced to counter each affidavit. May 10, 2022 Defendant’s deadline to designate retained experts with reports. AGREED SCHEDULING ORDER — PAGE 1 May 10, 2022 Mediation deadline. Mediation is scheduled to occur before this date with mediator Mike Carnahan, 12001 N. Central Expressway, Suite 650, Dallas, TX 75243. June 8, 2022 IfPlaintiff received medical treatment after filing suit the CPRC 18.001 affidavits for this treatment are due by this date. Defendants have 30 days from the date the affidavit is produced to counter each affidavit. July 8, 2022 Deadline by which the parties must have completed discovery (alldiscovery must be initiated at a time early enough to ensure that the completion of same will not surpass this deadline). August 1, 2022 Deadline by which the parties file their page/line designations of video deposition testimony to be used at trial. August 3, 2022 Deadline by which parties file their objections to page/line designations of video deposition testimony to be used at trial. August 4-,2022 Deadline by which the parties must file their rebuttal m page/line designations of video deposition testimony to be used at trial. August 4, 2022 Deadline by which the parties must file pretrial disclosures, motions in limine, any pre—trial motions, a proposed jury charge, and parties must exchange true and correct copies of exhibits not previously produced. August 8, 2022 JURY TRIAL All deadlines in this Scheduling Order may be modified by Rule 11 agreement, except for the trial date. Should this case not be reached for trial on the August 8, 2022 trial setting, absent a new scheduling order being entered or a Rule 11 agreement stating otherwise, the parties agree that the discovery deadline will end 30 days before the new trial date. Additionally, all pretrial deadlines (pretrial disclosures, AGREED SCHEDULING ORDER — PAGE 2 motion in limine, and page—line designations) will be moved to the same number of calendar‘days prior to trial as set out above, according to the new trial date. The parties agree that nothing in this Scheduling Order will affect any party's right to seek leave of Court under Section 18.001(i) of the Texas Civil Practice & Remedies Code. SIGNED THIS ogdkday of ,2021. EASE, ING APPROVED AS TO FORM AND CONTENT: WITHER TE L GROUP, PLLC By LAUREN JQBm/ State Bar No. 24081236 lauren.iobin@witheritelaw.com SHELLY GRECO State Bar No. 24008168 shelly.qreco@witheritelaw.com 10440 N. Central Expressway Suite 400 Dallas, TX 75231-2228 214/378-6665 214/378-6670 (fax) ATTORNEYS FOR PLAINTIFF AGREED SCHEDULlNG ORDER — PAGE 3 THE LECRONE LAW FIRM, P.C. By: /s/ Adam LeCrone ADAM B. LECRONE State Bar No.00786447 adam@lecronelaw.com Wall Street Plaza 123 N. Crockett Street, Suite 200 Sherman, TX 75090 (903) 813-1900 (903) 813—1944(fax) ATTORNEY FOR DEFENDANTS PABLO ROMO, IllAND JRU PROPERTIES, LLC DlB/A 4 WHEEL DRIVE AUTO AGREED SCHEDULING ORDER — PAGE 4