Chaney v. Diversified Consultants, Inc.

Western District of Texas, txwd-5:2019-cv-00892

Scheduling Recommendations Joint by Tina M Chaney.

Interested in this case?

Current View

Full Text

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION Tina M. Chaney § § § § v § No. 5:19-cv-892-DAE § § § Diversified Consultants, Inc. § JOINT SCHEDULING RECOMMENDATIONS The parties recommend that the following deadlines be entered in the scheduling order to control the course of this case: 1. A report on alternative dispute resolution in compliance with Local Rule CV-88 shall be filed by ​January 7, 2020​. 2. The parties asserting claims for relief shall submit a written offer of settlement to opposing parties by ​January 7, 2020​, and each opposing party shall respond, in writing, by​ January 21, 2020. 3. The parties shall file all motions to amend or supplement pleadings or to join additional parties by​ February 6, 2020​. 4. All parties asserting claims for relief shall file their designation of potential witnesses, testifying experts, and proposed exhibits, and shall ​serve on all parties, but not file the materials required by FED. R. CIV. P. 26(a)(2)(B) ​by ​January 10, 2020​. Parties resisting claims for relief shall file their designation of potential witnesses, testifying experts, and proposed exhibits, and shall ​serve on all parties, but not file the materials required by FED. R. CIV. P. 26(a)(2)(B)​ by ​February 24, 2020​. All designations of rebuttal experts shall be designated within 14 days of receipt of the report of the opposing expert. 5. An objection to the reliability of an expert's proposed testimony under Federal Rule of Evidence 702 shall be made by motion, specifically stating the basis for the objection and identifying the objectionable testimony, the within thirty (30) days of receipt of the written report of the expert's proposed testimony, or within thirty (30) days of the expert's deposition, if a deposition is taken, whichever is later. 6. The parties shall complete all discovery on or before​ April 9, 2020​. Counsel may by agreement continue discovery beyond the deadline, but there will be no intervention by the Court except in extraordinary circumstances, and no trial setting will be vacated because of information obtained in post-deadline discovery. 7. All dispositive motions shall be filed no later than​ May 11, 2020​. Dispositive motions as defined in Local Rule CV-7(c) and responses to dispositive motions shall be limited to twenty (20) pages in length. Replies, if any, shall be limited to ten (10) pages in length in accordance with Local Rule CV-7(e). ​If the parties elect not to file dispositive motions, they must contact the courtroom deputy, Priscilla Springs at (210) 472-6550 ext. 5016, or by email Priscilla_Springs@txwd.uscourts.gov​, on or before this deadline in order to set a trial date​. 8. If required, a hearing on dispositive motions will be set by the Court after all responses and replies have been filed. 9. The Court will set this case for trial by separate order. The order will establish trial type deadlines to include pretrial matters pursuant to Local Rule CV-16(e)-(g). 10. All of the parties who have appeared in the action conferred concerning the contents of the proposed scheduling order on​Nov. 8, 2019​, and the parties have agreed as to its contents. Respectfully Submitted, William M. Clanton Texas Bar No. 24049436 Law Office of Bill Clanton, P.C. 926 Chulie Dr. San Antonio, Texas 78216 210 226 0800 210 338 8660 fax bill@clantonlawoffice.com Attorney for Plaintiff Respectfully Submitted, /s/ ​Charles R. Penot, Jr. Charles R. Penot, Jr. TX Bar No. 24062455 Sessions, Fishman, Nathan & Israel, LLC 900 Jackson Street, Suite 440 Dallas, Texas 75202 Telephone: (214) 741-3009 Facsimile: (214) 741-3098 Email: cpenot@sessions.legal Attorney for Defendant, Diversified Consultants, Inc.