State Court of Fulton County
`***EFILED***
`File & ServeXpress
`Transaction ID: 65871433
`Case Number: 20EV000820
`Date: Aug 24 2020 02:54PM
`LeNora Ponzo, Chief Clerk
`Civil Division
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`***EFILED***
`File & ServeXpress
`Transaction ID: 65871433
`Case Number: 20EV000820
`Date: Aug 24 2020 02:54PM
`LeNora Ponzo, Chief Clerk
`Civil Division
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`3.
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`(a)
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`All PRELIMINARY MOTIONS, including, but not limited to, motions to dismiss
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`for lack of venue, jurisdiction or service; motions to dismiss on account of the expiration of the
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`various statutes of limitation; or motions to add parties, shall be filed NO LATER THAN
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`JULY 1'? 2020, which date precedes the close of discovery absent Court Order.
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`(b)
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`All SUBSTANTIVE MOTIONS, including motions for summary judgment and
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`Daubert motions, shall be filed NO LATER THAN JANUARY 19, 2021.
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`(c)
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`All motions/briefs are LIMITED to no more than 15 pages, 12-point font, double
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`spaced, exclusive of attachments, unless otherwise permitted by the Court in writing. Absent
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`prior permission by the Court, no party shall file any reply briefs, which are generally
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`disfavored.
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`(d)
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`The parties are reminded that email addresses must be included in their signature
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`lines, and that where a signature is set forth on a separate page from the contents of the
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`document, the signature page must identify the parties, the case number, and the document. See,
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`USCR36.4.
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`(c)
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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.
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`4.
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`In the event of a discovery dispute, counsel and parties SHALL contact the Court’s Staff
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`Attorney at 404-613-7761 to set up a telephone conference within 90 days from the date of the
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`response or event (6. g. deposition) that is the subject of the dispute, and in no event later than the
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`{Finn/201/0289l/PLEADING/02679163DOCX}
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`2
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`close of discovery, absent Court Order. This must happen PRIOR TO filing any motion
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`concerning a discovery dispute between the parties.
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`5.
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`MEDIATION shall be scheduled and completed NO LATER THAN MARCH 19 2021
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`Counsel and all parties, or their representatives, are to appear and participate in good faith in this
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`mediation. Attendance by an attorney or other representative who has full authority to settle all
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`issues in the action is REQUIRED. If the client has not given such authorization to counsel, the
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`client must also appear.
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`The parties are ORDERED to notify the Court of the date mediation was actually
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`conducted and whether an agreement was reached.
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`6.
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`Parties shall stipulate to this Court’s trial calendar NO LATER THAN 90 days after the
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`close of discovery. A CONSOLIDATED PRETRIAL ORDER and any motions in limine shall
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`be efiled ONE WEEK prior to the trial calendar. Those documents and witnesses upon which a
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`litigant intends to rely affirmatively to meet his or her burden must be disclosed in the pretrial
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`order. See Ballard v. Meyers, 275 Ga. 819 (2002). In the event a witness or document not
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`previously disclosed during discovery is listed on the pretrial order, the Court may impose
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`sanctions pursuant to paragraph six below.
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`7.
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`The failure to comply with the deadlines and other provisions set forth in this Case
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`Management Order may result in the imposition of sanctions, including the striking of
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`pleadings, the disregard of motions (particularly late-filed motions), the assessment of
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`attorney’s fees, the exclusion of evidence or witnesses at trial, and/or other sanctions this
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`{Firm/201/02891/PLEADING/02679163.DOCX }
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`3
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`Court deems warranted under the facts and circumstances. See, Doherty v. Brown, 339 Ga.
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`App. 567, 576 (2016); 0TS, Inc. v. Weinstock & Scavo, PC, 339 Ga. App. 511, 517 (2016); Hart
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`v. Northside Hospital, Inc., 291 Ga. App. 208 (2008). Further, the Court may choose to consider
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`motions filed outside of the deadlines set in this Order to prevent manifest injustice. See Velasco
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`v. Chambless, 295 Ga. App. 377 (2008).
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`This the
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`day of
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`20
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`,
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`.
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`Submitted this 24th day of August, 2020.
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`JUDGE DIANE E. BESSEN
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`State Court of Fulton County
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`THE BROSNAHAN LAW FIRM
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` KENNETH W. BROSNA AN
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`Georgia Bar No. 086345
`LINDA G. CARPENTER
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`Georgia Bar No. 111285
`Attorneys for Plaintifl"
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`CRUSER, MITCHELL, NOVITZ,
`SANCHEZ, GASTON & ZIMET, LLP
`ff
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`J.
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`B CRUSER
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`Georgia Bar No. 199480
`CANDICE R. BRYANT
`Georgia Bar No. 807404
`Attorneys for Defendant
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`51 Lenox Point, N.E.
`Atlanta, GA 30324
`(404) 923-7570
`(678) 904-6391 — fax
`kwbgafiibrosnahan-iawcom
`lgcga‘brosnahan—law.com
`
`Meridian II, Suite 2000
`275 Scientific Drive
`Norcross, GA 30092
`(404) 881-2622
`(404) 881-2630 — Facsimile
`rcrusergwcmlawfizmsom
`cbgam@cmlawfiml.com
`
`{Finn/20 1/02891 /PLEADING/026791 63 .DOCX }
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`4
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`
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`IN THE STATE COURT OF FULTON COUNTY
`STATE OF GEORGIA
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`CIVIL ACTION
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`FILE NO.: 20EV000820
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`§ §
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`§ §
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`§ §
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`§ §
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`§ §
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`WELINGTON OLIVEIM,
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`Plaintiff,
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`vs.
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`JAMES QUIROZ,
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`Defendant.
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFY that I have this day electronically filed the within and foregoing
`AMENDED CONSENT CASE MANAGEMENT ORDER “B” (NONSPECIFIC
`/GENERAL CASES) with the Clerk of Court using the File & ServeXpress system which will
`send e-mail notification of such filing to the following counsel of record:
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`Kenneth W. Brosnahan, Esq.
`Linda G. Carpenter, Esq.
`The Brosnahan Law Firm
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`51 Lenox Point, NE.
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`Atlanta, GA 30324
`Attomev for Plaintiff
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`This 24th day of August, 2020.
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`CRUSER, MITCHELL, NOVITZ,
`SANCHEZ, GASTON & ZIMET, LLP
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`Meridian 11, Suite 2000
`275 Scientific Drive
`Peachtree Corners, GA 30092
`(404) 881-2622
`(404) 881-2630 — Facsimile
`
`J. ROBB CRUSER
`Georgia Bar No. 199480
`CANDICE R. BRYANT
`Georgia Bar No. 807404
`Attorneys for Defendant
`
`{Film/201/02891/PLEADING/02679163.DOCX }
`
`
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