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`State Court of Fulton County
`***EFILED***
`File & ServeXpress
`Transaction ID: 65861261
`Case Number: 20EV002052
`Date: Aug 19 2020 03:49PM
`LeNora Ponzo, Chief Clerk
`Civil Division
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`b.
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`All other SUBSTANTIVE MOTIONS, including motions for summary judgment,
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`and DAUBERT MOTIONS shall be filed NO LATER THAN February 15, 2021.
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`(No later than
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`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
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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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`(1.
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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
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`these deadlines and without this Court’s prior written approval by Order, then the motion will be
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`untimely and may not be considered. All motions/briefs are LIMITED to no more than fifteen (15)
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`pages, double spaced, exclusive of attachments, unless otherwise permitted by the Court in writing.
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`Absent prior permission by the Court, no party shall file any reply briefs, which are generally
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`disfavored.
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`MEDIATION shall be scheduled and completed NO LATER THAN March 15, 2021. (No later
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`than 60 days after the close of discovery). Counsel and all parties, or their representatives, are to
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`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 client
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`has not given such authorization to counsel, the client must also appear.
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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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`The failure to comply with the deadlines set forth in this Case Management Order may result
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`in the imposition of sanctions, including striking pleadings, assessment of attorney’s fees,
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`exclusion of evidence or witnesses, or other sanctions.
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`/s/ Alwyn R. Fredericks
`ALWYN R. FREDERICKS
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`Georgia Bar Number 275092
`LISA E. MCNARY
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`Georgia Bar Number 456926
`CASH, KRUGLER, & FREDERICKS, LLC
`5447 Roswell Road NE
`Atlanta, Georgia 30342
`(404) 659-1710
`(404) 264-1149 [fax]
`afredericks@ckandf.com
`1mcnary@ckandf.com
`Attorneys for Plaintiff
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`/s/ Matthew P. Lazarus
`MATTHEW P. LAZARUS
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`Georgia Bar Number 441590
`DAVID C. RHODES
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`Georgia Bar Number 340295
`(w/ express permission Signed by
`Alwyn R. Fredericks, Esq.)
`SCRUDDER, BASS, QUILLIAN,
`HORLOCK, TAYLOR & LAZARUS, LLP
`900 Circle 75 Pkwy, Suite 850
`Atlanta, GA 30339
`mlazarus@scrudderbass.com
`drhodes@scrudderbass.com
`Attorneys for Defendant Northside Hospital,
`Inc.
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`SO ORDERED, this
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`day of
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`, 2020.
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`
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`Judge Eric A. Richardson
`State Court of Fulton County
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