JOINT CONFERENCE REPORT PAGE 1 OF 4

10478996

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

DOUG SANDEL,

Plaintiff,

v.

BART BENKE, Individually and 

d/b/a BB TRANSPORT,

Defendant.

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CASE NO. 6:20-cv-00359-ADA-JCM

JOINT CONFERENCE REPORT

COME NOW, Plaintiff DOUG SANDEL (“Plaintiff”) and Defendant BART BENKE, 

Individually and d/b/a BB TRANSPORT (“Defendant”) (collectively the “Parties” herein) and 

submit this Joint Conference Report as required by the Court’s Docket Control Order pursuant to 

the Rules 16(b) and 26(f). Attorney for Plaintiff David A. Bryant, Jr. and attorney for Defendant 

Alan Moore conferred and the Parties show the Court as follows:

I.

(A) What changes should be made in the timing, form or requirement for 

disclosures under Rule 26(a), including a statement of when initial disclosures were made or 

will be made.

The Parties agree to exchange their disclosures under Rule 26(a) by July 31, 2020.

(B) The subjects on which discovery may be needed, when discovery should be 

completed, and whether discovery should be conducted in phases or be limited to or focused 

on particular issues.

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10478996

The Parties anticipate conducting discovery into the circumstances of the subject accident 

and the nature, timing and extent of Plaintiff’s injuries. The Parties anticipate completing discovery 

by March 5, 2021. The Parties do not believe that discovery needs to be conducted in phases.

(C) Any issue about disclosure, discovery, or preservation of electronically stored 

information, including the form or forms in which it should be produced.

The Parties do not currently anticipate any issues concerning electronically-stored 

information. 

(D) Any issues about claims of privilege or of protection as trial-preparation 

materials, including – if the parties agree on a procedure to assert these claims after 

production – whether to ask the Court to include their agreement in an order under Federal 

Rule of Evidence 502.

The Parties do not currently anticipate a need to ask the Court for an Order under Federal 

Rule of Evidence 502.

(E) What changes should be made in the limitations on discovery imposed under 

these rules or by local rule, and what other limitations should be imposed.

The Parties do not currently believe any additional limitations on discovery are required 

other than those imposed under the Federal Rules of Procedure or by local rule.

Dated: July 13, 2020.

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10478996

Respectfully submitted, 

THE BRYANT LAW FIRM

 

By: _____________________________

David A. Bryant, Jr.

Texas Bar No. 00785730

Email: dbryant@thebryantlawfirm.com

2751 S. Loop 336 West, Suite B

Conroe, Texas 77304

(713) 980-0700 Telephone

(713) 980-0701 Facsimile

And

DEREK GILLILAND 

State Bar No. 24007239

Sorey, Gilliland & Hull, LLP 

109 W. Tyler 

Longview, Texas 75601 

903.212.2822 (Telephone) 

903.212.2864 (Facsimile) 

derek@soreylaw.com 

ATTORNEYS FOR PLAINTIFF

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10478996

MARTIN, DISIERE, JEFFERSON & WISDOM, L.L.P.

By: /s/ Alan Moore

MARK J. DYER

State Bar No. 06317500

dyer@mdjwlaw.com

ALAN MOORE

State Bar No. 14320075

amoore@mdjwlaw.com

9111 Cypress Waters Blvd., Ste. 250

Dallas, Texas 75019

214-420-5500

214-420-5501 (fax)

ATTORNEYS FOR DEFENDANT

BART BENKE, Individually and d/b/a 

BB TRANSPORT

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing instrument has been e-served 

to all attorneys of record, in compliance with the Texas Rules of Civil Procedure, on this the 13th

day of July 2020.

David A. Bryant, Jr.

The Bryant Law Firm

2751 S. Loop 336 West, Suite B

Conroe, Texas 77304

Derek Gilliland 

Sorey, Gilliland & Hull, LLP 

109 W. Tyler 

Longview, Texas 75601 

/s/ Alan Moore

ALAN MOORE

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