IN THE UNITED STATES DISTRICT

COURT FOR THE EASTERN DISTRICT 

OF TEXAS TYLER DIVISION

LADARION HUGHES, ANGELA ALONZO, 

and DEMARCUS LIVELY,

 Plaintiffs

 v.

SMITH COUNTY, TEXAS,

 Defendant

 Case No. 6:23-cv-344

JOINT MOTION TO AMEND THE SCHEDULING ORDER

NOW COME Plaintiffs, Ladarion Hughes, Angela Alonzo, and Demarcus Lively, and 

Defendant Smith County, Texas, through their respective attorneys, who jointly move this Court 

to grant the Parties’ Joint Motion to Amend the Scheduling Order. In support, the Parties state:

1. On October 30, 2023, the Court entered its Initial Scheduling Order. Dkt. 12.

2. On August 2, 2024, the Court entered a modified scheduling order extending the 

Parties’ written and oral discovery deadlines. Dkt. 29. The Order modified the following dates:

• Written fact discovery deadline changed to September 20, 2024

• Oral discovery deadline changed to November 20, 2024. 

Id.

3. The Parties have been working diligently to meet the close of discovery deadline. 

To that end, the Parties have engaged in lengthy Rule 37.2 conferrals about production in this 

case, and have exchanged multiple rounds of written discovery. Collecting documents and 

conducting discovery have taken longer than anticipated.

4. The Parties’ mediation date has also been rescheduled multiple times. Mediation 

Case 6:23-cv-00344-JDK Document 33 Filed 09/11/24 Page 1 of 5 PageID #: 250
is currently scheduled to take place on October 1, 2024, before Magistrate Judge Mitchell.

5. Given the Parties’ current status of discovery, the Parties have also recognized 

that the deadlines included in the Court’s original Scheduling Order, Dkt. 12, and in the Court’s 

modified Scheduling Order, Dkt. 29, require modification. Accordingly, good cause exists to 

support the Parties’ Joint Motion.

6. With good cause shown, the Parties therefore request entry of the following 

amended Scheduling Order (the earliest date indicated at the bottom of the table): 

June 20, 2025 Dispositive Motions due from all parties. 

March 20, 2025 Plaintiffs’ class certification motion due.

April 20, 2025 Defendant’s Response to Plaintiffs’ class certification motion 

due.

February 20, 2025 Expert Discovery Deadline

February 20, 2025 Oral Discovery Deadline

All oral fact discovery shall be completed by this date.

November 20, 2024 Written Fact Discovery Deadline 

All written fact discovery shall be completed by this date.

30 days after any Rule 

26(a)(2) disclosure

Parties may provide further expert disclosure of expert 

testimony or evidence intended solely to contradict or rebut 

evidence on the same subject matter identified by another 

party under Rule 26(a)(2)(B) within 30 days of the disclosure 

contradicted or rebutted.

January 20, 2025 Party without the burden of proof on an issue shall file a 

written designation of the name and address of each expert 

witness, if any, who will testify at trial for that party and shall 

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otherwise comply with Federal Rule of Civil Procedure 

26(a)(2) and Local Rule CV-26(b).

December 20, 2024 Party with the burden of proof on an issue shall file a written 

designation of the name and address of each expert witness, 

if any, who will testify at trial for that party and shall 

otherwise comply with Federal Rule of Civil Procedure 

26(a)(2) and Local Rule CV-26(b).

October 20, 2024 Deadline for Motions for Leave to Join Parties or Amend 

Pleadings.

7. These modifications are necessary for the Parties to adequately prosecute and 

defend against the claims in this case. 

WHEREFORE, the Parties respectfully request that the Court enter the above-proposed 

modifications to the Scheduling Order.

Respectfully submitted,

/s/Meg Gould

Meg Gould

LOEVY &LOEVY

311 N. Aberdeen

Chicago, Illinois 60607

(312) 243-5900 

gould@loevy.com

Nathan Fennell 

nfennell@fairdefense.org

Camilla Hsu 

chsu@fairdefense.org

Texas Fair Defense Project

314 E. Highland Mall Blvd #204

Austin, TX 78752

Telephone: (512) 637-5220

Akeeb Dami Animashaun

animashaun@pm.me

355 S. Grand Ave,

Suite 2450 Los 

Case 6:23-cv-00344-JDK Document 33 Filed 09/11/24 Page 3 of 5 PageID #: 252
Angeles, CA 90071 

Telephone: (929) 266-

3971

Counsel for Plaintiffs, 

Ladarion Hughes,

Angela Alonzo, and 

Demarcus Lively

/s/ David Iglesias

David Iglesias

IGLESIAS LAW FIRM, PLLC

605 Chase Drive, Suite 8

Tyler, Texas 75701

Telephone: (903) 944-7185

Facsimile: (903) 630-5338

Dallas Office:

1412 Main Street, Suite 608

Dallas, Texas 75202

Counsel for Defendant 

Smith County, Texas

Case 6:23-cv-00344-JDK Document 33 Filed 09/11/24 Page 4 of 5 PageID #: 253
CERTIFICATE OF CONFERENCE

I hereby certify that on September 11, 2024, the undersigned attorney contacted 

Defendant's counsel regarding its position on this Motion. After discussing its merits, the Parties 

have agreed to file this Motion jointly.

CERTIFICATE OF SERVICE

I, Meg Gould, an attorney, hereby certify that on September 11, 2024, I caused the

foregoing Joint Motion to Amend the Scheduling Order to be filed using the Court’s CM/ECF 

system, which effected service on all counsel of record.

/s/ Meg Gould

One of Plaintiffs’Attorneys

Case 6:23-cv-00344-JDK Document 33 Filed 09/11/24 Page 5 of 5 PageID #: 254