Chaves v. Cogent Medical Laboratory, LLC

Western District of Texas, txwd-5:2019-cv-00861

Scheduling Recommendations Joint Scheduling Recommendations by Cogent Medical Laboratory, LLC.

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION § TONI CHAVES, § § Plaintiff, § v. § Civil Action No. 5:19-cv-00861-ESC § COGENT MEDICAL LABORATORY, § LLC, § § Defendant. § 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 November 4, 2019. 2. The parties asserting claims for relief shall submit a written offer of settlement to opposing parties by January 6, 2020, and each opposing party shall respond, in writing, by February 6, 2020. 3. The parties shall file all motions to amend or supplement pleadings or to join additional parties by January 22, 2020. 4. All parties asserting claims for relief shall file their designation of testifying experts and shall serve on all parties, but not file the materials required by FED. R. CIV. P. 26(a)(2)(B) by December 9, 2019. Parties resisting claims for relief shall filed their designation of testifying experts and shall serve on all parties, but not file the materials required by FED. R. CIV. P. 26(a)(2)(B) by January 17, 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, within 30 days of receipt of the written report of the expert's proposed testimony, or within 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 March 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 April 10, 2020. Dispositive motions as defined in Local Rule CV-7(c) and responses to dispositive motions shall be limited to 20 pages in length. 8. This case is set for jury selection and trial on _____________, 2020 at ________a.m. The final pretrial conference is set for ____________, 2020 at _______a.m. The Court will set a status conference in this case approximately three (3) to four (4) months prior to the above-referenced trial setting. The parties shall consult Local Rule CV-16(e)-(g) regarding matters to be filed in advance of trial. 9. All of the parties who have appeared in the action conferred concerning the contents of the proposed scheduling order on and the parties have agreed as to its contents. Respectfully submitted, /S/ MICHAEL V. GALO, JR. Michael V. Galo, Jr. State Bar No. 00790734 GALO LAW FIRM, P.C. 4230 Gardendale, Bldg. 401 San Antonio, Texas 78229 Telephone: 210.616.9800 Facsimile: 210.616.9898 Email: mgalo@galolaw.com ATTORNEY FOR DEFENDANT /S/ CHRIS R. MILTENBERGER Chris R. Miltenberger State Bar No. 14171200 THE LAW OFFICE OF CHRIS R. MILTENBERGER, PLLC 1340 N. White Chapel, Suite 100 Southlake, Texas 76092 Telephone: 817.416.5060 Facsimile: 817.416.5062 Email: chris@crmlawpractice.com ATTORNEY FOR PLAINTIFF CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing has been served on the following counsel of record through the Court's electronic filing system, in accordance with the Federal Rules of Civil Procedure on this 15th day of October, 2019. Mr. Chris R. Miltenberger The Law Office of Chris R. Miltenberger, PLLC 1340 N. White Chapel, Suite 100 Southlake, Texas 76092 and Electronic Filing System /s/ Michael V. Galo, Jr. MICHAEL V. GALO, JR.