`**E-FILED**
`19EV000388
`8/15/2019 2:54 PM
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`LeNora Ponzo, Clerk
`Civil Division
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`STATE COURT OF FULTON COUNTY
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`STATE OF GEORGIA
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`STANDING CASE MANAGEMENT ORDER
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`FOR ALL DIVISION F {JUDGE RICHARDSON! E-FILED CASES
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`It is hereby ORDERED that within 30 days of receiving this order, or within 30 days of
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`the filing of the last Defendants’ final Answer (whichever is later), all parties shall jointly E-file
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`one of the attached Consent Scheduling Orders,
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`(Order A for Wrongful Death/Medical
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`Malpractice/Complex Cases; Order B for all other cases) setting forth case management
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`deadlines.
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`In any matter in which an extended period of discovery is anticipated, parties shall
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`contact
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`Staff
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`Attorney
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`Trinity
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`Townsend,
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`404-613 -45 12
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`or
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`trinity.townsend@fultoncountyga. gov to schedule a conference.
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`SO ORDERED, this 15th day ofAugust, 2019.
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`fl
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`Judge Eric A. Richardson
`State Court of Fulton County
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`
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`IN THE STATE COURT OF FULTON COUNTY
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`STATE OF GEORGIA
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`Plaintiff
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`Defendant
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`Civil Action N 0:
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`CONSENT CASE MANAGEMENT ORDER “A”
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`(MEDICAL MALPRACTICE/WRONGFUL DEATH/COMPLEX CASE)
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`1.
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`PLAINTIFF’S EXPERT(S) shall be disclosed NO LATER THAN
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`2.
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`DEFENSE EXPERT(S) shall be disclosed NO LATER THAN
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`3.
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`REBUTTAL EXPERT(S) shall be disclosed NO LATER THAN
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`for
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`PLAINTIFF and
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`for DEFENSE.
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`4.
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`ALL EXPERTS shall be deposed NO LATER THAN
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`5.
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`ALL WITNESSES shall be deposed NO LATER THAN
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`6.
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`DISCOVERY shall close NO LATER THAN 12 MONTHS after the last answer is filed, which
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`date is
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`.
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`(This includes, but
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`is not
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`limited to, written discovery and
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`depositions).
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`7.
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`(a)
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`All PRELIMINARY MOTIONS,
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`including, but not
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`limited to, motions to dismiss,
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`motions regarding venue, service, statute of limitations, or motions to add parties, shall be filed
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`NO LATER THAN
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`, absent Court Order.
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`(No later than 60 days
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`after the entry of this Order).
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`(b)
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`All other SUBSTANTIVE MOTIONS, including motions for summary judgment, and
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`DAUBERT MOTIONS shall be filed NO LATER THAN
`
`
`
`. (N0 later
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`than 30 days after the close of discovery).
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`(0)
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`Notwithstanding the above, any motions regarding discovery disputes shall be filed
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`within 60 days from the date of the response or event (e.g. deposition) that is the subject of the
`
`motion, and in no event later than the close of discovery, absent Court Order.
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`In the event of a
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`discovery dispute, counsel and parties are ENCOURAGED to contact the Court’s Staff Attorney
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`at 404-613-4512 to set up a telephone conference PRIOR TO filing any motion to compel or for
`
`protective order.
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`(d)
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`There shall be no extensions of these deadlines by agreement of the parties. Any
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`extension of time to file a motion must be made by Order of this Court. If any motion is filed
`
`after these deadlines and without this Court’s prior written approval by Order, then the
`
`motion will be untimely and may not be considered. All motions/briefs are LIMITED to no
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`more than fifteen (15) pages, double spaced, exclusive of attachments, unless otherwise
`
`permitted by the Court in writing. Absent prior permission by the Court, no party shall file any
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`reply briefs, which are generally disfavored.
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`
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`8.
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`MEDIATION shall be scheduled £1 completed NO LATER THAN
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`. (N0
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`later than 90 days after the close of discovery). Counsel and all parties, or their representatives,
`
`are to appear and participate in good faith in this mediation. Attendance by an attorney or other
`
`representative who has full authority to settle all issues in the action is REQUIRED.
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`If the
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`client has not given such authorization to counsel, the client must also appear.
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`9.
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`Parties shall stipulate to this Courts’ trial calendar no later than 95 days after discovery closes.
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`Parties desiring a special setting should contact Staff Attorney Trinity Townsend, 404-613-4512
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`or trinity.townsend@fultoncountygagov, NO LATER THAN the close of discovery to make
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`such a request, understanding that a specially set
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`trial date may not be available for
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`approximately 6 months.
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`10.
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`The failure to comply with the deadlines set forth in this Case Management Order may
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`result in the imposition of sanctions, including striking pleadings, assessment of attorney’s
`
`fees, exclusion of evidence or witnesses, or other sanctions.
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`Plaintiff s Counsel
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`
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`Defendant’s Counsel
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`SO ORDERED, this
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`day of
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`, 20
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`
`
`Judge Eric A. Richardson
`State Court of Fulton County
`
`
`
`IN THE STATE COURT OF FULTON COUNTY
`
`STATE OF GEORGIA
`
`Plaintiff
`
`Defendant
`
`Civil Action No:
`
`CONSENT CASE MANAGEMENT ORDER “B”
`
`(NONSPECIFIC/GENERAL CASES)
`
`l.
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`DISCOVERY shall close NO LATER THAN 6 MONTHS after the last answer is filed, which
`
`date is
`
`.
`
`(This includes, but
`
`is not
`
`limited to, written discovery and
`
`depositions).
`
`2.
`
`(a)
`
`All PRELIMINARY MOTIONS,
`
`including, but not
`
`limited to, motions to dismiss,
`
`motions regarding venue, service, statute of limitations, or motions to add parties, shall be filed
`
`NO LATER THAN
`
`, absent Court Order.
`
`(No later than 30 days
`
`after the entry of this Order).
`
`(b)
`
`All other SUBSTANTIVE MOTIONS, including motions for summary judgment, and
`
`DAUBERT MOTIONS shall be filed NO LATER THAN
`
`. (No later
`
`than 30 days after the close of discovery).
`
`(0)
`
`Notwithstanding the above, any motions regarding discovery disputes shall be filed
`
`within 60 days from the date of the response or event (e.g. deposition) that is the subject of the
`
`
`
`motion, and in no event later than the close of discovery, absent Court Order.
`
`In the event of a
`
`discovery dispute, counsel and parties are ENCOURAGED to contact the Court’s Staff Attorney
`
`at 404-613-4512 to set up a telephone conference PRIOR TO filing any motion to compel or for
`
`protective order.
`
`((1)
`
`There shall be no extensions of these deadlines by agreement of the parties. Any
`
`extension of time to file a motion must be made by Order of this Court. If any motion is filed
`
`after these deadlines and without this Court’s prior written approval by Order, then the
`
`motion will be untimely and may not be considered. All motions/briefs are LIMITED to no
`
`more than fifteen (15) pages, double spaced, exclusive of attachments, unless otherwise
`
`permitted by the Court in writing. Absent prior permission by the Court, no party shall file any
`
`reply briefs, which are generally disfavored.
`
`3.
`
`MEDIATION shall be scheduled @ completed NO LATER THAN
`
`. (N0
`
`later than 60 days after the close of discovery). Counsel and all parties, or their representatives,
`
`are to appear and participate in good faith in this mediation. Attendance by an attorney or other
`
`representative who has full authority to settle all issues in the action is REQUIRED.
`
`If the
`
`client has not given such authorization to counsel, the client must also appear.
`
`4.
`
`Parties shall stipulate to this Court’s trial calendar no later than 95 days after discovery closes. A
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`CONSOLIDATED PRETRIAL ORDER and any motions in limine shall be E-filed NO LATER
`
`THAN 1 week prior to trial.
`
`
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`5.
`
`The failure to comply with the deadlines set forth in this Case Management Order may
`
`result in the imposition of sanctions, including striking pleadings, assessment of attorney’s
`
`fees, exclusion of evidence or witnesses, or other sanctions.
`
`
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`__________________________
`Plaintiff’s Counsel
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`__________________________
`Defense Counsel
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`
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`SO ORDERED, this _____ day of _______________, 20__.
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`____________________________________
`Judge Eric A. Richardson
`State Court of Fulton County
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