Guzman v. Cascade Process Controls, Inc.

Western District of Texas, txwd-5:2019-cv-00162

Scheduling Recommendations by Daniel Guzman.

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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION DANIEL GUZMAN § § Plaintiff, § § Civil Action No. 5:19-cv-162-FB (HJB) v. § § CASCADE PROCESS CONTROLS, INC. § JURY DEMANDED § Defendant § 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 July 1, 2019. 2. The parties asserting claims for relief shall submit a written offer of settlement to opposing parties by July 1, 2019, and each opposing party shall respond, in writing, by July 15, 2019. 3. The parties shall file all motions to amend or supplement pleadings or to join additional parties by July 31, 2019. 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 July 5, 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 August 20, 2019. All designations of rebuttal experts shall be designated within 15 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 January 31, 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 November 4, 2019. Dispositive motions as defined in Local Rule CV-7(h) and responses to dispositive motions shall be limited to pages in length. 8. The trial date will be determined at a later date by the Court. The parties shall consult Local Rule CV-16(e) regarding matters to be filed in advance of trial. At the time the trial date is set, the Court will also set the deadline for the filing of matters 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 May 20, 2019 and the parties have agreed. Dated: May 20, 2019. Respectfully submitted, ANDERSON ALEXANDER, PLLC By: /s/ Clif Alexander Clif Alexander Texas Bar No. 24064805 clif@a2xlaw.com Lauren E. Braddy Texas Bar No. 24071993 lauren@a2xlaw.com Alan Clifton Gordon Texas Bar No. 00793838 cgordon@a2xlaw.com Carter T. Hastings Texas Bar No. 24101879 carter@a2xlaw.com 819 N. Upper Broadway Corpus Christi, Texas 78401 Telephone: (361) 452-1279 Facsimile: (361) 452-1284 LEICHTER LAW FIRM, PC By: /s/ David G. Langenfeld David G. Langenfeld Texas Bar No. 11911325 david@leichterlaw.com 1602 East 7th Street Austin, Texas 78702 Telephone: (512) 495-9995 Facsimile: (512) 482-0164 Attorneys for Plaintiffs and the Putative Class Members /s/ Charles A. Moster, Esq. Charles A. Moster, Esq. State Bar No. 00797782 THE MOSTER LAW FIRM, P.C. 4920 South Loop 289, Suite 101 Lubbock, TX 79414 cmoster@themosterlawfirm.com Phone: (806) 778-6486 Facsimile: (806) 302-7046 Counsel for Defendants /s/ B. Blaze Taylor, Esq. B. Blaze Taylor, Esq. State Bar No. 24106495 THE MOSTER LAW FIRM, P.C. 4920 South Loop 289, Suite 101 Lubbock, TX 79414 btaylor@themosterlawfirm.com Phone: (806) 778-6486 Facsimile: (866) 302-7046 Counsel for Defendants