InProcessOut, LLC v. World Tech Toys, Inc.

Western District of Texas, txwd-5:2018-cv-00869

Scheduling Recommendations Joint by InProcessOut, LLC.

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United States District Court Western District of Texas San Antonio Division InProcessOut, LLC Plaintiff v. Civil Action No. 5:18-cv-00869-FB-HJB World Tech Toys, Inc. Jury Trial Defendant Joint Scheduling Recommendations Plaintiff, InProcessOut, LLC and Defendant, World Tech Toys, Inc. 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 10/17/2019. 2. The parties asserting claims for relief shall submit a written offer of settlement to opposing parties by 10/17/2019, and each opposing party shall respond, in writing, by 10/31/2019. 3. The parties shall file all motions to amend or supplement pleadings or to join additional parties by 11/16/2019. 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 11/21/2019. 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. 1 R. CIV. P. 26(a)(2)(B) by 1/5/2020. 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 2/19/2020. 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 3/20/2020. Dispositive motions as defined in Local Rule CV-7(c) and responses to dispositive motions shall be limited to 20 pages in length. 8. The trial date will be determined at a later date by the Court. The parties shall consult Local Rule CV-16(e)-(g) 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 8/14/19 and the parties have agreed as to its contents. 2 Date: August 14, 2019 Respectfully submitted, /s/ Matthew J. Booth Matthew J. Booth Dale Langley The Law Firm of H. Dale Langley Jr., P.C. Texas Bar No. 11918100 1803 West Avenue Austin TX 78701 Tel: +1 (512) 477-3830 Fax: +1 (512) 597-4775 dlangley@iptechlaw.com Matthew J. Booth Matthew J. Booth PC Texas Bar No. 02648300 5501A Balcones Drive, Suite 301 Austin Texas 78731 Tel: +1 (512) 474-8488 Fax: +1 (512) 596-2875 matthew.booth@boothlaw.com Legal Counsel for Plaintiff InProcessOut, LLC /s/ Robert L. McRae Robert L. McRae Robert L. McRae Gunn Lee & Cave PC Texas Bar No. 24046410 8023 Vantage Dr STE 1500 San Antonio, TX 78230 Tel: +1 (210) 886-9500 Fax: +1 (210) 886-9883 rob.mcrae@gunn-lee.com Legal Counsel for World Tech Toys, Inc. Defendant 3 Certificate of Service I certify that I filed this filing on August 14, 2019 electronically with the Clerk of Court using the CM/ECF system that will send notification of this filing to all counsel of record. /s/ Matthew J. Booth Matthew J. Booth 4