Doe v. University of Texas Health Science Center At San Antonio et al

Western District of Texas, txwd-5:2019-cv-00248

Scheduling Recommendations JOINT by JANE UTHSCSA-AS DOE.

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION JANE UTHSCSA-AS DOE § § vs. § NO: SA:19-CV-00248-DAE § University of Texas Health Science § Center at San Antonio, et al. 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 February 23, 2020. 2. The parties asserting claims for relief shall submit a written offer of settlement to opposing parties by February 23, 2020, and each opposing party shall respond, in writing, March 8, 2020. 3. The parties shall file all motions to amend or supplement pleadings or to join additional parties by March 25, 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 February 24, 2020. Parties resisting claims for relief shall file their designation of potential witnesses, testifying experts, and proposed exhibits, and shall serve on SCHEDULING RECOMMENDATIONS 1 all parties, but not file the materials required by Fed. R. Civ. P. 26(a)(2)(B) by March 19, 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 thirty days of receipt of the written report of the expert's proposed testimony, or within thirty days of the expert's deposition, if a deposition is taken, whichever is later. 6. The parties shall complete all discovery on or before May 24, 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 June 23, 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 on or before this deadline in order to set a trial date. SCHEDULING RECOMMENDATIONS 2 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 the 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 September 26,2019, and the parties have agreed as to its contents. The following positions and reasons are given by the parties for the disagreement as to the contents of the proposed scheduling order NA. . Plaintiff offers the following explanation of why all parties have not been served NA. . Respectfully submitted, Gorman Law Firm, pllc By: Terry P Gorman, Esq. Texas Bar No. 08218200 tgorman@school-law.co 901 Mopac Expressway South, Suite 300 Austin, Texas 78746 Telephone: (512) 980-4556 (direct) Telecopier: (512) 597-1455 ATTORNEYS FOR PLAINTIFF JANE UTHSCSA-AS DOE SCHEDULING RECOMMENDATIONS 3 KEN PAXTON Attorney General of Texas /s/ Matthew A. Deal MATTHEW A. DEAL Texas Bar No. 24087397 Assistant Attorney General General Litigation Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 (512) 475-1969 | FAX: (512) 320-0667 matthew.deal@oag.texas.gov ATTORNEYS FOR DEFENDANTS CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the preceding document was served via the Court's CM/ECF system on September 27, 2019 on: Texas Attorney General MATTHEW A. DEAL Assistant Attorney General General Litigation Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 (512) 475-1969 | FAX: (512) 320-0667 matthew.deal@oag.texas.gov ATTORNEYS FOR DEFENDANTS Terry P. Gorman SCHEDULING RECOMMENDATIONS 4