Vernon's Texas Rules Annotated - VTRA TX R WEBB CTY Appendix C. Complex Case Docket Control & Scheduling Order (LR 3.33)

1.

New Parties shall be joined and served by this date:

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2.

Deadline for written discovery to opposing party(ies) (Requests for Disclosure, Interrogatories, Requests for Production and Requests for Admission).

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3.

Deadline to produce all documents requested by the parties.

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4.

Lay--witness depositions

Noticed by Plaintiffs

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Noticed by Defendants/Third Party Plaintiffs

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Notice by Third Party Defendants

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5.

Experts by Party(ies) Seeking Affirmative Relief:

Deadline to designate

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Deadline for submission of reports

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Deadline to depose experts of party(ies) seeking Affirmative relief

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6.

Experts by Responding Party(ies):

Deadline to designate

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Deadline for submission of reports

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Deadline to depose experts of responding party(ies)

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7.

Deadline to file Daubert/Robinson motions.

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8.

Production of proposed computerized summaries and samples:

Plaintiff(s) Deadline

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Defendant(s) Deadline

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Third Party Defendant(s) Deadline

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9.

Deadline for designating factual witnesses.

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10.

Deadline to file all dispositive motions.

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11.

Except for good cause shown:

Relief from the this schedule shall not be granted and all Discovery shall be completed by:

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Discovery Shall be limited to matters occurring after [DATE] and before [DATE]

No more than __________ hours of deposition of lay Witnesses may be taken by each side, and no single Deposition may take more than __________ hours.

No more than __________ hours of deposition of expert Witnesses may be taken by each side, and no single Deposition may take more than __________ hours.

12.

AMENDED PLEADINGS: Party(ies) seeking affirmative Relief will file by this date. Responding party(ies) will be filed Within ten (10) days of this date.

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13.

Plaintiffs deadline to designate video deposition testimony for use at trial.

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14.

Defendants' and Third Party Defendants' deadline to Designate video deposition testimony for use at trial.

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15.

Plaintiffs deadline to submit exhibit list to opposing counsel.

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16.

Defendants' and Third Party Defendants' deadline submit

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17.

ALL TRIAL MOTIONS, OBJECTIONS TO THE OTHER PARTY'S DESIGNATIONS OF VIDEO TESTIMONY AND TO EXHIBITS, MOTIONS IN LIMINE AND POPOSED JURY QUESTIONS, AND INSTRUCTIONS SHALL BE FILED. FAILURE TO FILE by this date will cause a show Cause order to be issued for contempt and/or for the imposition or any other sanctions against trial counsel and/or the parties.

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18.

ALTERNATIVE DISPUTE RESOLUTION. The parties or Their duly authorized representatives and, in any case Involving insurance, a representative or the insurance Carrier, who is authorized to settle the case, are all ordered to Attend the mediation or arbitration session. Failure to do so Will result in imposition of sanctions. Attorneys and the Mediator are ordered to bring to the attention of the court any Failure of any party or attorney to comply with this order.

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19.

PRE-TRIAL CONFERENCE will be held at __________ a.m./p.m. All trial motions, including motion in limine and objections to deposition testimony and to exhibits, will be heard at the pre-trial conference.

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20.

Jury Trial will start at 9:__________: a.m.

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