`STATE OF GEORGIA
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` STANDING CASE MANAGEMENT ORDER
`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, (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. 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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`404-613-4512
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`or
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`trinity.townsend@fultoncountyga.gov to schedule a conference.
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`SO ORDERED, this 24th day of September, 2019.
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`Judge Eric A. Richardson
`State Court of Fulton County
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`State Court of Fulton County
`***EFILED***
`File & ServeXpress
`Transaction ID: 64235839
`Case Number: Multi-Case
`Date: Sep 24 2019 11:18AM
`LeNora Ponzo, Chief Clerk
`Civil Division
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`IN THE STATE COURT OF FULTON COUNTY
`STATE OF GEORGIA
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`___________________________
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`Plaintiff
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`___________________________
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`Defendant
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`Civil Action No: ____________________
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`CONSENT CASE MANAGEMENT ORDER “A”
`(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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`DEFENSE EXPERT(S) shall be disclosed NO LATER THAN___________________.
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`2.
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`REBUTTAL EXPERT(S) shall be disclosed NO LATER THAN ________________ for
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`3.
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`PLAINTIFF and __________________ 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 ________________. (This includes, but is not 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, including, but not 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. (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 ______________________ . (No later
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`than 30 days after the close of discovery).
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`(c)
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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
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`motion, and in no event later than the close of discovery, absent Court Order. 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
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`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
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`after these deadlines and without this Court’s prior written approval by Order, then the
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`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
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`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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`8.
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`MEDIATION shall be scheduled and completed NO LATER THAN _________________. (No
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`later than 90 days after the close of discovery). Counsel and all parties, or their representatives,
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`are to appear and participate in good faith in this mediation. Attendance by an attorney or other
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`representative who has full authority to settle all issues in the action is REQUIRED. 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@fultoncountyga.gov, NO LATER THAN the close of discovery to make
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`such a request, understanding that a specially set 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
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`fees, exclusion of evidence or witnesses, or other sanctions.
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`_________________________
`Plaintiff’s Counsel
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`_________________________
`Defendant’s Counsel
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`SO ORDERED, this _____ day of ________________, 20__.
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`________________________
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`Judge Eric A. Richardson
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`State Court of Fulton County
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`IN THE STATE COURT OF FULTON COUNTY
`STATE OF GEORGIA
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`___________________________
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`Plaintiff
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`___________________________
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`Defendant
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`Civil Action No: ____________________
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`CONSENT CASE MANAGEMENT ORDER “B”
`(NONSPECIFIC/GENERAL CASES)
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`1.
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`DISCOVERY shall close NO LATER THAN 6 MONTHS after the last answer is filed, which
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`date is _______________. ALL discovery shall be COMPLETED by this date; this includes,
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`but is not limited to: identification of, written discovery from, and depositions from BOTH fact
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`and expert witnesses.
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`2.
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`(a)
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`All PRELIMINARY MOTIONS, including, but not 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. (No later than 30 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 ______________________ . (No later
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`than 30 days after the close of discovery).
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`(c)
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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
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`motion, and in no event later than the close of discovery, absent Court Order. 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
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`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
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`after these deadlines and without this Court’s prior written approval by Order, then the
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`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
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`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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`3.
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`MEDIATION shall be scheduled and completed NO LATER THAN _________________. (No
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`later than 60 days after the close of discovery). Counsel and all parties, or their representatives,
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`are to appear and participate in good faith in this mediation. Attendance by an attorney or other
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`representative who has full authority to settle all issues in the action is REQUIRED. If the
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`client has not given such authorization to counsel, the client must also appear.
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`4.
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`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
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`THAN 1 week prior to trial.
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`5.
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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
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`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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`SO ORDERED, this _____ day of _______________, 20__.
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`____________________________________
`Judge Eric A. Richardson
`State Court of Fulton County
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