Jury Trial Discovery Control Plan And Scheduling Order Form

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CAUSE NO. _______________________
_________________________________
§
DISTRICT COURT
§
TH
V.
§
470
JUDICIAL DISTRICT
§
_________________________________
§
COLLIN COUNTY, TEXAS
JURY TRIAL DISCOVERY CONTROL PLAN AND SCHEDULING ORDER
The following was agreed and stipulated by the parties and/or Ordered by the Court:
Check this box for a LEVEL 2 Discovery Control Plan pursuant to the Texas Rules of Civil Procedure
-OR-
Check this box for a LEVEL 3 Discovery Control Plan and complete the below items:
1. Amended Pleadings. The deadline for filing amended pleadings is _______________________________.
2. Special Exceptions. The deadline for filing exceptions to pleadings is _____________________________.
3. Discovery. All discovery shall be completed by _______________________________________________.
Discovery requests shall be propounded in sufficient time to allow for a timely response by the
discovery deadline.
4. Time Limits for Depositions: _____________________________________________________________.
5. Limitations on Interrogatories: ___________________________________________________________.
6. Limitations on Requests for Production:____________________________________________________.
7. Other limitations: _______________________________________________________________________.
8. Deadline for Designations of Experts. Party seeking affirmative relief on an issue shall file a designation of
its testifying experts by _________________________. Party not seeking affirmative relief on an issue shall
file a designation of its testifying experts by _________________________.
Any expert not designated will not be permitted to testify. A designation includes the subject matter and
opinions to be offered by the expert.
Dispositive Motions (Summary Judgments, Plea to Jurisdiction, Plea in Abatement, etc.). All dispositive motions
shall be filed and heard at least 30 days before trial.
Formal Pre-Trial Conference. This case is set for formal pre-trial on ________________________________.
1. Pre-Trial Motions. All pre-trial motions (Motions in Limine, etc.) shall be filed at least 10 days before the
formal pre-trial conference and will be heard at the formal pre-trial conference. The Court will not hear pre-
trial motions on the day of jury selection without prior leave of court.
2. Expert Challenges. Unless good cause is shown, all "Daubert/Dupont" challenges shall be heard no later than
the formal pre-trial conference and written objections must be on file at least 10 days before hearing.
3. Each party is directed to produce the following at the Pre-Trial Conference:
o A concise trial summary as follows: state each separate cause of action and defense; each element of each
cause of action and defense; and, if appropriate, a precise legal standard for measure of damages. Please
be as brief and concise as possible. This summary is intended to be an aid for the Court and should be
limited to one page if possible.
o Proposed jury charges (instructions, definitions, and questions) emailed in editable Word format to the
court coordinator.
o Completed witness lists and exhibit lists.

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