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IN THE COUNTY COURT OF HARRISON COUNTY, MISSISSIPPI

SECOND JUDICIAL DISTRICT


CYNTHIA MOLDOVAN PLAINTIFF

V.. CAUSE NO.: D-2402-10-001

ALLSTATE INSURANCE COMPANY, ERNEST MOLDOVAN,


JOHN DOES I-V AND JANE DOES VI-X DEFENDANTS

SCHEDULING ORDER

In accordance with Rules 26(c) and 16 of the Mississippi Rules of Civil Procedure, and
to provide for the regular and orderly progression of the above styled and numbered cause, IT
IS HEREBY, ORDERED:
I. ISSUES TO BE TRIED
Any and all issues found and raised in the allegations of either the Plaintiff’s Complaint,
the Defendants’ Answers, Defenses and other amendments to each thereto. IT IS FURTHER,
II. PLAN AND SCHEDULE OF DISCOVERY
ORDERED, that the plan and schedule of discovery shall be as follows:
1. That counsel shall complete all discovery and supplementation of discovery,
including depositions taken for discovery purposes and for evidentiary or testimonial purposes,
on or before March 10, 2011. All request for written discovery under Rules 33, 34 and 36 of the
Miss. Rules of Civil Procedure shall be served no later than March 10, 2011.
2. That Counsel shall serve and file all motions to join additional parties and amend
all pleadings no later than December 25, 2010.
3. That Plaintiff’s experts shall be designated on or before January 25, 2011,
with either reports signed by the respective expert or Rule 26 (b)(4)(A)(i) information supplied.
4. That Defendants’ experts shall be designated on or before February 25, 2011,
with either reports signed by respective expert or Rule 26 (b)(4)(A)(i) information supplied.
5. That all dispositive motions, with the exception of in limine motions shall be
served on or before March 5, 2011. The deadline for in limine motions is thirty (30) days before
the pre-trial conference, with responses due five (5) days before the pre-trial conference.
6. That a pre-trial conference shall be held before the undersigned Judge, on or
before April 5, 2011.
7. That the trial of the matter shall be April 12, 2011. IT IS FURTHER,
IV. LIMITATION ON DISCOVERY
ORDERED that all of the above deadlines shall only be extended by an Order of the
Court. There shall be no other limitation placed on discovery, other than those listed herein,
those provided in the local rules of this Court, the Uniform Rules of Circuit and County Court
Practice and the Mississippi Rules of Civil Procedure. IT IS THEREFORE,
ORDERED that the provisions of the Order shall be strictly enforced. Failure of any party
to comply with any of the provisions contained herein, may result in exclusion of evidence or any
other appropriate sanction set for under Rule 37 of the Mississippi Rules of Civil Procedure.
SO ORDERED AND ADJUDGED this the ____ day of August, 2010.

_____________________________
COUNTY COURT JUDGE
PREPARED AND AGREED BY:

By:_______________________________
Matt G. Lyons, Esq. (MSB #1743)
Clyde H. Gunn, III (MSB #5074)
Attorneys for the Plaintiff

By:_______________________________
Toby Gammil, Esq. (MSB #______)
Attorney for Defendant,
ALLSTATE INSURANCE COMPANY

By:_______________________________
_____________________(MSB #______)
Attorney for Defendant, Ernest Moldovan
TEL: (228) 872-1855 MATT G. LYONS FAX: (228) 872-1857
ATTORNEY-AT-LAW
910 WASHINGTON AVENUE
OCEAN SPRINGS, MS 39564
May 3, 2010

Gayle Parker, Circuit Clerk


P.O. Box 998
Gulfport, MS 39501

Re: Hon. Jos. P. Hudson, et al. v. Kirkland, et al. [No. A2401-09-152]

Dear Mrs. Parker:

Enclosed for filing, docketing and processing on behalf of Plaintiff, please find an original and
one [1] copy of:

1. Reply to Motion for Scheduling Order;


2. proposed Scheduling Order.

Please stamp “Filed” the copy of the enclosed pleadings and return same to my office. If you
have any questions or if there be any problem, please contact me directly.

Sincerely,

Matt G. Lyons

MGL/rgs

Enclosures

cc: All Counsel