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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

BRYNNE SOUKUP,

 Plaintiff,

v.

FRONTIER AIRLINES, INC. AND 

FLIGHT SERVICES & SYSTEMS, LLC,

 Defendants.

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Civil Action No. 1:20-CV-648-RP

SCHEDULING ORDER

Pursuant to Federal Rule of Civil Procedure 16, the following Scheduling Order is issued 

by the Court: 

1. A report on alternative dispute resolution in compliance with Local Rule CV-88 shall be 

filed on or before January 8, 2021.

2. The parties asserting claims for relief shall submit a written offer of settlement to opposing 

parties on or before January 22, 2021, and each opposing party shall respond, in writing, 

on or before February 5, 2021. All offers of settlement are to be private, not filed. The 

parties are ordered to retain the written offers of settlement and responses so the Court may 

use them in assessing attorney’s fees and costs at the conclusion of the trial. 

3. Each party shall complete and file the attached “Notice Concerning Reference to United 

States Magistrate Judge” on or before November 27, 2020. 

4. The parties shall file all motions to amend or supplement pleadings or to join additional 

parties on or before December 18, 2020. 

5. All parties asserting claims for relief shall file their designation of testifying experts and 

serve on all parties, but not file, the materials required by Federal Rule of Civil Procedure 

26(a)(2)(B) on or before March 12, 2021. Parties resisting claims for relief shall file their 

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designation of testifying experts and serve on all parties, but not file, the materials required 

by Federal Rule of Civil Procedure 26(a)(2)(B) on or before April 12, 2021. All parties 

shall file all designations of rebuttal experts and serve on all parties the material required 

by Federal Rule of Civil Procedure 26(a)(2)(B) for such rebuttal experts, to the extent not 

already served, 15 days from the receipt of the report of the opposing expert. 

6. An objection to the reliability of an expert’s proposed testimony under Federal Rule of 

Evidence 702 shall be made by motion, specifically stating the basis for the objection and 

identifying the objectionable testimony, within 11 days from the receipt of the written 

report of the expert’s proposed testimony, or within 11 days from the completion of the 

expert’s deposition, if a deposition is taken, whichever is later. 

7. The parties shall complete all discovery on or before August 20, 2021. 

8. All dispositive motions shall be filed on or before September 10, 2021 and shall be limited 

to 20 pages. Responses shall be filed and served on all other parties not later than 14 days 

after the service of the motion and shall be limited to 20 pages. Any replies shall be filed 

and served on all other parties not later than 7 days after the service of the response and 

shall be limited to 10 pages, but the Court need not wait for the reply before ruling on the 

motion. 

9. The Court will set this case for final pretrial conference at a later time. The final pretrial 

conference shall be attended by at least one of the attorneys who will conduct the trial for 

each of the parties and by any unrepresented parties. The parties should consult Local Rule 

CV-16(e) regarding matters to be filed in advance of the final pretrial conference. 

10. This case is set for ______________ trial commencing at 9:00 a.m. on 

___________________________________________, 20________. By filing an agreed 

motion, the parties may request that this Court extend any deadline set in this Order, with 

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Jury December 13 21

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the exception of the dispositive motions deadline and the trial date. The Court may impose 

sanctions under Federal Rule of Civil Procedure 16(f) if the parties do not make timely 

submissions under this Order. 

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ROBERT L. PITMAN

UNITED STATES DISTRICT JUDGE

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SIGNED October 28, 2020.

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AGREED:

/s/ Daniel B. Ross

Daniel B. Ross 

State Bar No. 00789810 

Trenton Lacy 

State Bar No. 24106176 

ROSS • SCALISE LAW GROUP 

1104 San Antonio Street 

Austin, Texas 78701 

Telephone: (512) 474-7677 

Facsimile: (512) 474-5306 

dan@rosslawgroup.com 

trenton@rosslawgroup.com 

ATTORNEYS FOR PLAINTIFF

/s/ Kimberly R. Miers 

Kimberly R. Miers 

State Bar No. 24041482 

Andrew Gray 

State Bar No. 24106023 

LITTLER MENDELSON P.C. 

100 Congress Avenue, Suite 1400 

Austin, Texas 78701 

Telephone: (512) 982-7250 

Facsimile: (512) 982-7248 

kmiers@littler.com 

agray@littler.com

ATTORNEYS FOR DEFENDANT, FRONTIER AIRLINES, INC.

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/s/ Sarah Voorhies Myers 

Sarah Voorhies Myers (pro hac vice) 

Amy L. McIntire (pro hac vice) 

CHAFFE McCALL, LLP 

2300 Energy Centre, 1100 Poydras Street 

New Orleans, LA 70163 

Telephone: (504) 585-7000 

Facsimile: (504) 544-6092 

myers@chaffe.com

mcintire@chaffe.com

H. Michael Bush 

Texas Bar No.24054296 

CHAFFE McCALL, LLP

2300 Energy Centre,1100 Poydras Street 

New Orleans, LA 70163 

Telephone: (504) 585-7000 

Facsimile: (504) 544-6042 

bush@chaffe.com

ATTORNEYS FOR DEFENDANT, FLIGHT SERVICES & SYSTEMS, LLC

4813-3725-0767.2 057446.1023

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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

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NOTICE CONCERNING REFERENCE TO

UNITED STATES MAGISTRATE JUDGE

In accordance with the provisions of 28 U.S.C. § 626(c), Federal Rule of Civil Procedure 73, 

and the Local Rules of the United States District Court for the Western District of Texas, the 

following party ________________________________________________________________ 

through counsel _______________________________________________________________ 

 ___ consents to having a United States Magistrate Judge preside over the trial in this case.

 ___ declines to consent to trial before a United States Magistrate Judge.

 Respectfully submitted, 

 __________________________________ 

 Attorney for:

 __________________________________ 

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