On May 09, 2013 a
Letter,Correspondence
was filed
involving a dispute between
Johnson, Carl,
Johnson, Sandra,
and
Cmc Steel Fabricators Inc,
Commercial Metals Company,
Dayton Superior Corporation,
Symons Manufacturing,
for OTHER PRODUCT LIABILITY
in the District Court of Dallas County.
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CAUSE NO. DC-13-05222
CARL and SANDRA JOHNSON § IN THE DISTRICT COURT
Plaintiffs, §
§
VS. §
§
DAYTON SUPERIOR CORPORATION; § DALLAS COUNTY, TEXAS
CMC STEEL FABRICATORS, INC. §
D/B/A CMC CONSTRUCTION §
SERVICES; and COMMERCIAL §
METALS COMPANY §
Defendants § 68th JUDICIAL DISTRICT
AGREED LEVEL 3 DISCOVERY CONTROL PLAN AND SCHEDULING ORDER
In accordance with Rules 166, 190 and 192, of the Texas Rules of Civil Procedure, the
Court enters the following Agreed Level 3 Discovery Control Plan and Scheduling Order:
1. March 20, 2015 PLAINTIFF'S EXPERT WITNESS DESIGNATIONS
Plaintiff shall file by this date a list of all experts who may be
called to testify at trial, listing each expert’s name, address,
telephone number and the subject matter on which the expert is
expected to testify. Plaintiff shall also be required to produce on
this date, a report from each retained testifying expert that contains
all of their opinions, and the basis for same, along with a current
curriculum vitae.
2. April 20, 2015 DEFENDANT'S EXPERT WITNESS DESIGNATIONS
Defendant shall file by this date a list of all experts who may be
called to testify at trial, listing each expert’s name, address,
telephone number and subject matter on which the expert is
expected to testify. Defendant shall also be required to produce on
this date, a report from each retained testifying expert that contains
all of their opinions, and the basis for same, along with a current
curriculum vitae.
3. May 16, 2015 DISCOVERY DEADLINE
The cutoff date for all discovery shall be on this date. All written
discovery must be due before the cutoff date and no oral
depositions will be taken beyond the cutoff date, absent an
agreement of all parties or an order of the Court.
4. May 4, 2015 MEDIATION
Mediation shall be conducted by this date by James J. Juneau.
AGREED LEVEL 3 DISCOVERY CONTROL PLAN AND SCHEDULING ORDER - PAGE 1
5. May 15, 2015 DISPOSITIVE MOTIONS/EXPERT CHALLENGES
Dispositive motions and any motions challenging the qualifications
or reliability of opinions of any expert designated by an opposing
party, including any challenges under Robinson/Daubert must be
filed by this date.
6. May 18, 2015 PLEADINGS
All amendments and supplements to pleadings shall be filed by this
date.
7. June 2, 2015 WITNESS LISTS, EXHIBIT LISTS, MOTIONS IN LIMINE
AND PROPOSED JURY CHARGE
The parties shall file by this date a witness list,exhibit list, any
motions in limine and a proposed jury charge.
8. June 9, 2015 DEADLINE TO OBJECT TO PRETRIAL DOCUMENTS
Objections to any party’s witness list, exhibit list, motions in
limine, etc., must be made by this date.
9. June 16, 2015 JURY TRIAL
SIGNED this ___ day of ____________, 2015.
________________________________________
JUDGE PRESIDING
AGREED:
/s/ J. Gregory Marks
J. Gregory Marks,
Counsel for Plaintiff
/s/ Allison J. Maynard
Allison J. Maynard,
Counsel for Defendants CMC
/s/ Jamison Newberg
Jamison Newberg,
Counsel for Defendant Dayton Superior
AGREED LEVEL 3 DISCOVERY CONTROL PLAN AND SCHEDULING ORDER - PAGE 2
Document Filed Date
February 03, 2015
Case Filing Date
May 09, 2013
Category
OTHER PRODUCT LIABILITY
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CAUSE NO. DC-13-05222 CARL and SANDRA JOHNSON § IN THE DISTRICT COURT Plaintiffs, § § VS. § § DAYTON SUPERIOR CORPORATION; § DALLAS COUNTY, TEXAS CMC STEEL FABRICATORS, INC. § D/B/A CMC CONSTRUCTION § SERVICES; and COMMERCIAL § METALS COMPANY § Defendants § 68th JUDICIAL DISTRICT AGREED LEVEL 3 DISCOVERY CONTROL PLAN AND SCHEDULING ORDER In accordance with Rules 166, 190 and 192, of the Texas Rules of Civil Procedure, the Court enters the following Agreed Level 3 Discovery Control Plan and Scheduling Order: 1. March 20, 2015 PLAINTIFF'S EXPERT WITNESS DESIGNATIONS Plaintiff shall file by this date a list of all experts who may be called to testify at trial, listing each expert’s name, address, telephone number and the subject matter on which the expert is expected to testify. Plaintiff shall also be required to produce on this date, a report from each retained testifying expert that contains all of their opinions, and the basis for same, along with a current curriculum vitae. 2. April 20, 2015 DEFENDANT'S EXPERT WITNESS DESIGNATIONS Defendant shall file by this date a list of all experts who may be called to testify at trial, listing each expert’s name, address, telephone number and subject matter on which the expert is expected to testify. Defendant shall also be required to produce on this date, a report from each retained testifying expert that contains all of their opinions, and the basis for same, along with a current curriculum vitae. 3. May 16, 2015 DISCOVERY DEADLINE The cutoff date for all discovery shall be on this date. All written discovery must be due before the cutoff date and no oral depositions will be taken beyond the cutoff date, absent an agreement of all parties or an order of the Court. 4. May 4, 2015 MEDIATION Mediation shall be conducted by this date by James J. Juneau. AGREED LEVEL 3 DISCOVERY CONTROL PLAN AND SCHEDULING ORDER - PAGE 1 5. May 15, 2015 DISPOSITIVE MOTIONS/EXPERT CHALLENGES Dispositive motions and any motions challenging the qualifications or reliability of opinions of any expert designated by an opposing party, including any challenges under Robinson/Daubert must be filed by this date. 6. May 18, 2015 PLEADINGS All amendments and supplements to pleadings shall be filed by this date. 7. June 2, 2015 WITNESS LISTS, EXHIBIT LISTS, MOTIONS IN LIMINE AND PROPOSED JURY CHARGE The parties shall file by this date a witness list,exhibit list, any motions in limine and a proposed jury charge. 8. June 9, 2015 DEADLINE TO OBJECT TO PRETRIAL DOCUMENTS Objections to any party’s witness list, exhibit list, motions in limine, etc., must be made by this date. 9. June 16, 2015 JURY TRIAL SIGNED this ___ day of ____________, 2015. ________________________________________ JUDGE PRESIDING AGREED: /s/ J. Gregory Marks J. Gregory Marks, Counsel for Plaintiff /s/ Allison J. Maynard Allison J. Maynard, Counsel for Defendants CMC /s/ Jamison Newberg Jamison Newberg, Counsel for Defendant Dayton Superior AGREED LEVEL 3 DISCOVERY CONTROL PLAN AND SCHEDULING ORDER - PAGE 2