Irahetaj's Weblog

Linebarger is not above the law!

Iraheta v. Linebarger Goggan Blair & Sampson LLP: The Pre-Trial Order

Posted by irahetaj on June 22,

A pretrial conference has been set for July 12, 2017 at 2:00 p.m. before Judge Hittner in Houston, Texas.  In preparation for that a Joint Pre-Trial Order (“JPO”) has to be prepared and submitted by midnight next Monday, June 26, 2017.  Judge Hittner requires that the JPO include various other documents, including the following:

  • Witness Lists;
  • Expert Witness Qualifications;
  • Exhibit Lists
  • proposed JOINT Jury Instructions and Interrogatories;
  • proposed Voir Dire Questions (even though counsel will often conduct voir dire);
  • proposed Findings of Fact & Conclusions of Law

A JPO that includes all of the above is a daunting task, particularly for those of us that are not attorney (proceeding pro se).  Combine that with an opponent attorney, such as Mr. Edward “Nick” Nicholas, who is also a Linebarger employee, and it makes the JPO the most challenging document I have had to prepare.

Mr. Nicholas and I have been facing off in both state and federal Court in my two suits against Linebarger Goggan Blair & Sampson, et al., who is both a Defendant and Mr. Nicholas employer.  When you’ve spent 10 years of litigation against the Linebarger lawfirm, who believes it can steamroll an opponent, though it is exhausting, the actions of Linebarger and Mr. Nicholas are a reminder of why I’ve committed so much to this case and a motivation to see it to the end.

So, back to the JPO.  Should you ever be in a position that trial is within two months, and you have to do a JPO, be prepared to spend many, many, (let me say it again) many hours…several dozen hours to be exact.  Here is my first draft of the JPO which includes Jury Instructions, Voir Dire, Verdict Form, and Proposed Findings of Fact and Conclusion of Law.  The JPO relates to my claims against Linebarger Goggan Blair & Sampson which includes violations of the Servicemember Civil Relief Act, the Civil Rights Act, the Racketeer Influenced and Corrupt Organizations Act, the Texas Property Tax Code, as well as for fraud, negligent misrepresentation, negligence, and tortuous interference.

Pre-Trial Order Package

Case titled: Jose D. Iraheta v. Linebarger Goggan Blair & Sampson, et al. (Case No 4:15-cv-03227, S.D. Texas),


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