On August 02, 2019 a
SCHEDULING ORDER - LEVEL 3
was filed
involving a dispute between
Rhodes, Vashone,
and
Exclusive Nationwide Delivery, Inc,
Gomez, James,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
CAUSE NO. DC-19-1 0926
VASHONE RHODES; § IN THE DISTRICT COURT OF
§
§
Plaintiff, §
§
VS. § DALLAS COUNTY, TEXAS
§
.
JAMES GOMEZ; §
§
§
§
Defendant. § JUDICIAL DISTRICT
AGREED SCIfiDULING ORDgfl
The parties submit this proposed Agreed Scheduling Order. The Court, having
considered said Order, is of the opinion that the Order should be GRANTED.
IT IS THEREFORE ORDERED that the following pre-trial deadlines shall apply
’
~
,c
A fl
and numbered cause unless otherwise modified é‘érrele’ine‘fitof
to the above-entitled by
the parties or Oréier of the Court:
April 22, 2020 Deadline by which all claims must be filed/allparties
identified including counterclaims, cross-claims and/or
responsible third-party claims, excluding CPRC
33.0040).
June 22, 2020 Plaintiff’s deadline to designate retained experts with
Eons.
July 21, 2020 Defendant’s deadline to designate retained experts
with reports.
August 20, 2020 Mediation deadline. Mediation is scheduled to occur
before this date with mediator Karen Gammon.
September 18, 2020 Deadline by which the parties must have compIeted
discovery (all discovery must be initiated at a time early
enough to ensure that the completion of same will not
surpass this deadline).
AGREED SCHEDULING ORDER — PAGE 1
October 12, 2020 Deadline by which the parties file their page/Iine
designations of video deposition testimony to be used
at trial.
October 14, 2020 Deadline by which parties file their objections to
page/line designations of video deposition testimony to
be used at trial.
October 15, 2020 Deadline by which the parties must file their rebuttal
page/Iine designations of video deposition testimony to
be used at trial.
October 15, 2020 Deadline by which the parties must file motions in
limine, trial exhibit lists, trial witness lists, any pre-trial
motions, a proposed jury charge, and parties must
exchange true and correct copies of exhibits not
previously produced.
October 19, 2020 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 trialon the October 19,
2020 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
before the new date. Additionally, all pretrial deadlines (witness list,exhibit
days trial
list,motion in limine, and page-Iine designations) will be moved to the same number
of calendar days prior to trialas set out above, according to the new trial date.
SIGNED THIs ?jhday of gfifl/1&A¢ ,
20L?
AGREED SCHEDULING ORDER — PAGE 2
APPROVED AS TO FORM AND CONTENT:
EBERSTEIN & WITHERITE, LLP
By:
:DM
v. PAIGE’ELDRIDGEU
State Bar No. 24096747
Daiqeeldridqe@ewlawvers.com
AMY K. WITHERITE
State Bar No. 00788698
amv.witherite@ewlawvers.com
10440 N. Central Expressway
Suite 400
Dallas, TX 75231 -2228
214/378-6665
214/378-6670 (fax)
ATTORNEYS FOR PLAINTIFF
THE LECRONE LAW FIRM, P.C.
By:
MR.
am ADAM B.
6. OflJC/LO'ILL
LECRONE
State Bar No.00786447
adam@lecronelaw.com
Wall Street Plaza
123 N. Crockett Street, Suite 200
Sherman, TX 75090
(903) 813—1900
(903) 81 3-1 944(fax)
ATTORNEY FOR DEFENDANT
AGREED SCHEDULING ORDER — PAGE 3
Document Filed Date
September 29, 2019
Case Filing Date
August 02, 2019
Category
MOTOR VEHICLE ACCIDENT
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CAUSE NO. DC-19-1 0926 VASHONE RHODES; § IN THE DISTRICT COURT OF § § Plaintiff, § § VS. § DALLAS COUNTY, TEXAS § . JAMES GOMEZ; § § § § Defendant. § JUDICIAL DISTRICT AGREED SCIfiDULING ORDgfl The parties submit this proposed Agreed Scheduling Order. The Court, having considered said Order, is of the opinion that the Order should be GRANTED. IT IS THEREFORE ORDERED that the following pre-trial deadlines shall apply ’ ~ ,c A fl and numbered cause unless otherwise modified é‘érrele’ine‘fitof to the above-entitled by the parties or Oréier of the Court: April 22, 2020 Deadline by which all claims must be filed/allparties identified including counterclaims, cross-claims and/or responsible third-party claims, excluding CPRC 33.0040). June 22, 2020 Plaintiff’s deadline to designate retained experts with Eons. July 21, 2020 Defendant’s deadline to designate retained experts with reports. August 20, 2020 Mediation deadline. Mediation is scheduled to occur before this date with mediator Karen Gammon. September 18, 2020 Deadline by which the parties must have compIeted discovery (all discovery must be initiated at a time early enough to ensure that the completion of same will not surpass this deadline). AGREED SCHEDULING ORDER — PAGE 1 October 12, 2020 Deadline by which the parties file their page/Iine designations of video deposition testimony to be used at trial. October 14, 2020 Deadline by which parties file their objections to page/line designations of video deposition testimony to be used at trial. October 15, 2020 Deadline by which the parties must file their rebuttal page/Iine designations of video deposition testimony to be used at trial. October 15, 2020 Deadline by which the parties must file motions in limine, trial exhibit lists, trial witness lists, any pre-trial motions, a proposed jury charge, and parties must exchange true and correct copies of exhibits not previously produced. October 19, 2020 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 trialon the October 19, 2020 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 before the new date. Additionally, all pretrial deadlines (witness list,exhibit days trial list,motion in limine, and page-Iine designations) will be moved to the same number of calendar days prior to trialas set out above, according to the new trial date. SIGNED THIs ?jhday of gfifl/1&A¢ , 20L? AGREED SCHEDULING ORDER — PAGE 2 APPROVED AS TO FORM AND CONTENT: EBERSTEIN & WITHERITE, LLP By: :DM v. PAIGE’ELDRIDGEU State Bar No. 24096747 Daiqeeldridqe@ewlawvers.com AMY K. WITHERITE State Bar No. 00788698 amv.witherite@ewlawvers.com 10440 N. Central Expressway Suite 400 Dallas, TX 75231 -2228 214/378-6665 214/378-6670 (fax) ATTORNEYS FOR PLAINTIFF THE LECRONE LAW FIRM, P.C. By: MR. am ADAM B. 6. OflJC/LO'ILL LECRONE State Bar No.00786447 adam@lecronelaw.com Wall Street Plaza 123 N. Crockett Street, Suite 200 Sherman, TX 75090 (903) 813—1900 (903) 81 3-1 944(fax) ATTORNEY FOR DEFENDANT AGREED SCHEDULING ORDER — PAGE 3