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wes CASE NUMBER: 502021CA005610XXXXMB Div: AF ****
Filing # 125991415 E-Filed 05/02/2021 05:53:51 PM
UIT COURT OF THE
1 OK!
FIFTEENTH
UDICIAL CIRCUIT IN
Petitioners, AND FOR PALM BEACH COUNTY,
FLORIDA
v.
FEDNAT INSURANCE COMPANY, CASE NO.:
DIVISION:
Respondent.
SUMMONS
DEFENDANT TO BE SERVED:
FEDNAT INSURANCE COMPANY
c/o Florida Chief Financial Officer as RA
200 East Gaines Street
Tallahassee, FL 32399-4201
IMPORTANT
served on you to file a written response to the attached aa ion with the clerk
of this circuit court, located at: 205 North Dixie Highway, West Palm Beach, FL 33401.
A phone call will not protect you. Your written response, including the case number
given above and the names of the parties, must be filed if you want the Court to hear
your side of the case. If you do not file your written response on time, you may lose the
case, and your wages, money. and property may be taken thereafter without further
warning from the Court. There are other legal requirements. You may want to call an
attorney right away. If you do not know an attorney, you may call an attorney referral
service or a legal aid office (listed in the phone book). If you choose to file a written
response yourself, at the same time you file your written response to the Court, you
must also serve a copy of your written response on the party serving this summons at:
SCHATZMAN & HOVANYECZ, P.A.
3475 Sheridan Street, #206
Hollywood, Florida 33021
If the party serving summons has designated e-mail address(es) for service or is
represented by an attorney, you may designate e-mail address(es) for service by or on
you. Service must be in accordance with Florida Rule of Judicial Administration 2.516.
Copies of all court documents in this case, including orders, are available at the Clerk of
tha Circuit Criirte affica Vai maw raviaw thace dartimante tinan reniiact
Me UHOUL VOUILS CINUG, POU Tay FOVIGW WICGS GUCUNTOIG, UPI TOGUcck
CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZA FLED AEINIINNA NE-£2-64 DNA
Pm. PAL DLA VUUINE TT, PL, JUOL IE mDnNUueey, ULLIAN, Yuruei2ue |! U.yu.g toiTHE STATE OF FLORIDA
TO EACH SHERIFF OF THE STATE: You are commanded to serve this summons and
a copy of the complaint in this lawsuit on the above-named person.
DATED:
CLERK OF THE CIRCUIT COURT
(SEAL)
Deputy ClerkIN THE CIRCUIT COURT FOR THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
IN RE: STANDING ORDER FOR,
CASE MANAGEMENT FOR SUBMISSION
OF AGREED CASE MANAGEMENT PLAN FOR
CASES FILED ON OR AFTER APRIL 30, 2021
/
STANDING ORDER FOR CASE MANAGEMENT AND SUBMISSION OF AGREED
CASE MANAGEMENT PLAN IN CIVIL CASES
IN THE FIFTEENTH JUDICIAL CIRCUIT FILED ON_OR AFTER APRIL 30,2021
PPEEet (DCMSO) 7
Pursuant to Florida Rule of Civil Procedure 1.200(a), Florida Rule of General Practice and
Judicial Administration 2.545, and Administrative Order 3.107 entered by the Chief Judge of this
Circuit, the parties are informed of the following information and procedures applicable to civil
lawsuits filed in the Circuit Court on or after April 30, 2021:
. SERVICE OF THIS ORDER. The Plaintiff is directed 7 serve a copy of this ed
with each Summons issued in this case. One copy of tis Orde
Circuit Court with proof of service.
2. CIVIL CASE MANAGEMENT SYSTEM. The Supreme Court of Florida has
established guidelines for the prompt processing and resolution of civil cases. This Court has
adopted a case management system to help meet those guidelines. In contested cases, the parties
are required to participate in the ¢ case management system. The case management system requires
tha nastian far the nvanaratian and onhmiccian af an
10S (Or Wie preparation anG Suomission Cr an
Agreed Case Management Plan and early involvement by the Court. The Agreed Case
Management Plan requires the parties to identify a case track, confer in good faith and attempt to
narrow the matters in controversy, identify the issues that require direct involvement by the Court,
and establish a schedule for addressing those issues’! The Agreed Case Management Plan may be
accessed at the Court’s website at: https://1 Sthcircuit.com/civil-differentiated-forms-and-orders.
Unless all of the Defendants have been served and have been defaulted or dropped, an Agreed
Case Management Plan must be submitted to the assigned divisional queue via the Court’s online
scheduling system (OLS) as an attachment, in PDF format, to a proposed Order Accepting Agreed
Case Management Plan on or before 130 days from the date of filing of the initial complaint. If
the parties are unable to agree on an Agreed Case Management Plan by the applicable deadline, a
' Case Track options include Expedited, Streamlined, General, or Complex. Case Tracks have been
8 Standards set forth in Florida Rule of General
actahlichad in ardar ta camnly with the eace dion,
QStacnsneG ih CrGer to COmpay Wits ule Case oe
Practice and Judicial Administration 2.250(a)(1)(B).case management conference will be scheduled by the Court or the Court will review and issue an
Order Implementing Case Management Plan without agreement of the Parties. No matters that
arise as a result of this standing order, including lack of agreement, will be set on the Court’s
Uniform Motion Calendar and will, instead, be settled by the Court either at the case management
conference or via an Order Implementing Case Management Plan without agreement of the parties.
If a case management conference is scheduled, attendance by trial counsel and those parties who
are not represented by counsel is mandatory.
if aii Deiendants are served and defauited or dropped, the Piaintif? will file the appropriaie
documentation to pursue a Default Final Judgment within 130 days of the filing of the complaint
and Final Judgment is to be entered or set for hearing within 150 days of the filing of the complaint.
3.. MEDIATION/ALTERNATIVE DISPUTE RESOLUTION (ADR). ADR
provides parties with an out-of-court alternative to settling disagreements. Mediation is a type of
ADR wherein an independent third party attempts to arrange a settlement at a conference between
the parties
DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County,
Florida, on this 26 day of April, 2021.
Administrative Circuit JudgeIN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
Plaintiff(s),
MG Case No.
Nafandant(o\
CLenUaLsy
/
AGREED CASE MANAGEMENT PLAN
(DGMAP)
The parties hereby submit the following Agreed Case Management Plan to the Court for approval:
Case Track Assignment! (check one):
Expedited Track (Case resolved within 8 months)
(It is recommended that discovery and an alternative dispute
resolution/mediation be completed within 180 days after the complaint
is filed and a final disposition entered within 245 days after the
complaint is filed)
Streamlined Track (Case resolved within 12 months
(It is recommended that discovery and an alternative dispute
resolution/mediation be completed within 270 days after the complaint
is filed and a final disposition entered within 365 days after the
complaint is filed)
General Track (Case resolved within 18 months)
(It is recommended that discovery and an alternative dispute
resolution/mediation be completed within 450 days after the
complaint is filed and a final disposition entered within 540 days after
the complaint is filed)
Complex Track (Case resolved within 2 years)’
(Thin tenal aannat ha calactad withant a hearing and order arantina matian
(and Wan Camnoe 0G SUcOwG Windus a gearing ana C1Ger gianung Cuca
to designate the case as complex per Florida Rule of Civil Procedure
1.201)
' Case disposition times for all Case Tracks have been established based on Florida Rule of General Practice
and Judicial Administration 2.250(a)(1)(B) and the Circuit’s historic data. Although General and Complex
he racaluad with a iney trial it ic avnacted that Streamlined and Fynedited
Uv iesdiveu Wit @ jury uted, tb is Capeure une Cue Cand oxpecned
Track cases will be resolved without a jury trial.Case Deadlines and Events
DEADLINE OR EVENT.
AGREED DATE
Service of Unserved Parties
Plaintiff(s):
Cross/Counter Plaintiffs:
Motions to Add Parties or to Amend Pleadings
Plaintiff(s):
Defendant(s):
Resolution of Objections to Pleadings and Pretrial Motions (All
motions to dismiss, quash service, strike affirmative defenses or
extend the time to answer or respond to a pleading must be heard by
this date)
Plaintiff(s):
Defendant(s):
Discovery Deadline for Fact Witnesses
(Aii discovery must be commenced in time io be compieied DEtorE
this date)
Plaintiff(s):
Defendant(s):
Discovery Deadline for Expert Witnesses (All discovery must be
2 ta he camnleted hefore this date)
ne fo be comnleted hetore this date)
Plaintiffs):
Defendant(s):
Completion of Alternative Dispute Resolution (ADR)
(Mediation is mandatory unless the parties agree to another form of
ADR).
Deadline:
Type of ADR:
Other Deadlines or EventsTrial Information
Is this Case At Issue pursuant to Rule 1.440? (Yes or No)
Estimated Date the Case Will Be Prepared To Go To Trial
[PLEASE READ FOOTNOTE BEFORE COMPLETING) Pit date:
(If counsel and unrepresented parties do not agree on the
estimated date on which the case will be prepared to go to trial,
the Court may set the case for trial on its own motion) Deft date:
Agreed:
Ves or No
Estimated Length of Trial (specify the number of trial days):
Identification of Jury or Non-Jury Trial
(remainder of page intentionally left blank)
2 For retroactive cases pending prior to April 30, 2021, the estimated date the case will be prepared to go to
trial should not exceed the disposition time frame for the chosen case track. Cases that have been pending
longer than the corresponding case track disposition time frame must follow the following time frames:
Case Track Age of Case Estimated Date of Trial
"Expedited ~ More thai 8 montis | Within 4 Monts
7 Streamlined 12-18 Months Within 6 Months
More than 18 months Within 4 Months
General 18-24 Months Within 6 Months
More than 24 Months Within 4 MonthsThe above-referenced schedule of deadlines will be strictly adhered to by the parties unless a change is
otherwise agreed to by the parties and approved by the Court. The Court will consider a request to approve
changes to these deadlines upon a showing of good cause by either party based on matters arising from an
emergency nature or unavailability. However, once the Agreed Case Management Plan has been approved
by the Court, procrastination in completing discovery or the unavailability of counsel will not constitute
good cause for a change to these deadlines. The failure to abide by these deadlines may result in sanctions
by the Court, including the award of attorney’s fees, the striking of pleadings, and/or a dismissal of the
action.
Signature, address and telephone number of Counsel and Unrepresented Parties. Counsel must state
Fil Bar number:
PLAINTIFF’S COUNSEL. Or, if unrepresented, PLAINTIFF
Address Address,
Telephone #. : Telephone #. -
E-Mail Address The Plaintiff(s) is registered to receive
Florida Bar #. eI eservice at
DEFENDANT’S PRINTED NAME
DEFENDANT’S COUNSEL
Address
Telephone #.
E-Mail Address
Florida Bar #.
CANEAR ARN AADICS TA.
CURTURMLEY CUPS LUL
or, if unrepresented, DEFENDANT
Address,
Telephone #.
The Defendant(s) is registered to receive
eservice at _
Preview
wes CASE NUMBER: 502021CA005610XXXXMB Div: AF **** Filing # 125991415 E-Filed 05/02/2021 05:53:51 PM UIT COURT OF THE 1 OK! FIFTEENTH UDICIAL CIRCUIT IN Petitioners, AND FOR PALM BEACH COUNTY, FLORIDA v. FEDNAT INSURANCE COMPANY, CASE NO.: DIVISION: Respondent. SUMMONS DEFENDANT TO BE SERVED: FEDNAT INSURANCE COMPANY c/o Florida Chief Financial Officer as RA 200 East Gaines Street Tallahassee, FL 32399-4201 IMPORTANT served on you to file a written response to the attached aa ion with the clerk of this circuit court, located at: 205 North Dixie Highway, West Palm Beach, FL 33401. A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the Court to hear your side of the case. If you do not file your written response on time, you may lose the case, and your wages, money. and property may be taken thereafter without further warning from the Court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response to the Court, you must also serve a copy of your written response on the party serving this summons at: SCHATZMAN & HOVANYECZ, P.A. 3475 Sheridan Street, #206 Hollywood, Florida 33021 If the party serving summons has designated e-mail address(es) for service or is represented by an attorney, you may designate e-mail address(es) for service by or on you. Service must be in accordance with Florida Rule of Judicial Administration 2.516. Copies of all court documents in this case, including orders, are available at the Clerk of tha Circuit Criirte affica Vai maw raviaw thace dartimante tinan reniiact Me UHOUL VOUILS CINUG, POU Tay FOVIGW WICGS GUCUNTOIG, UPI TOGUcck CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZA FLED AEINIINNA NE-£2-64 DNA Pm. PAL DLA VUUINE TT, PL, JUOL IE mDnNUueey, ULLIAN, Yuruei2ue |! U.yu.g toiTHE STATE OF FLORIDA TO EACH SHERIFF OF THE STATE: You are commanded to serve this summons and a copy of the complaint in this lawsuit on the above-named person. DATED: CLERK OF THE CIRCUIT COURT (SEAL) Deputy ClerkIN THE CIRCUIT COURT FOR THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA IN RE: STANDING ORDER FOR, CASE MANAGEMENT FOR SUBMISSION OF AGREED CASE MANAGEMENT PLAN FOR CASES FILED ON OR AFTER APRIL 30, 2021 / STANDING ORDER FOR CASE MANAGEMENT AND SUBMISSION OF AGREED CASE MANAGEMENT PLAN IN CIVIL CASES IN THE FIFTEENTH JUDICIAL CIRCUIT FILED ON_OR AFTER APRIL 30,2021 PPEEet (DCMSO) 7 Pursuant to Florida Rule of Civil Procedure 1.200(a), Florida Rule of General Practice and Judicial Administration 2.545, and Administrative Order 3.107 entered by the Chief Judge of this Circuit, the parties are informed of the following information and procedures applicable to civil lawsuits filed in the Circuit Court on or after April 30, 2021: . SERVICE OF THIS ORDER. The Plaintiff is directed 7 serve a copy of this ed with each Summons issued in this case. One copy of tis Orde Circuit Court with proof of service. 2. CIVIL CASE MANAGEMENT SYSTEM. The Supreme Court of Florida has established guidelines for the prompt processing and resolution of civil cases. This Court has adopted a case management system to help meet those guidelines. In contested cases, the parties are required to participate in the ¢ case management system. The case management system requires tha nastian far the nvanaratian and onhmiccian af an 10S (Or Wie preparation anG Suomission Cr an Agreed Case Management Plan and early involvement by the Court. The Agreed Case Management Plan requires the parties to identify a case track, confer in good faith and attempt to narrow the matters in controversy, identify the issues that require direct involvement by the Court, and establish a schedule for addressing those issues’! The Agreed Case Management Plan may be accessed at the Court’s website at: https://1 Sthcircuit.com/civil-differentiated-forms-and-orders. Unless all of the Defendants have been served and have been defaulted or dropped, an Agreed Case Management Plan must be submitted to the assigned divisional queue via the Court’s online scheduling system (OLS) as an attachment, in PDF format, to a proposed Order Accepting Agreed Case Management Plan on or before 130 days from the date of filing of the initial complaint. If the parties are unable to agree on an Agreed Case Management Plan by the applicable deadline, a ' Case Track options include Expedited, Streamlined, General, or Complex. Case Tracks have been 8 Standards set forth in Florida Rule of General actahlichad in ardar ta camnly with the eace dion, QStacnsneG ih CrGer to COmpay Wits ule Case oe Practice and Judicial Administration 2.250(a)(1)(B).case management conference will be scheduled by the Court or the Court will review and issue an Order Implementing Case Management Plan without agreement of the Parties. No matters that arise as a result of this standing order, including lack of agreement, will be set on the Court’s Uniform Motion Calendar and will, instead, be settled by the Court either at the case management conference or via an Order Implementing Case Management Plan without agreement of the parties. If a case management conference is scheduled, attendance by trial counsel and those parties who are not represented by counsel is mandatory. if aii Deiendants are served and defauited or dropped, the Piaintif? will file the appropriaie documentation to pursue a Default Final Judgment within 130 days of the filing of the complaint and Final Judgment is to be entered or set for hearing within 150 days of the filing of the complaint. 3.. MEDIATION/ALTERNATIVE DISPUTE RESOLUTION (ADR). ADR provides parties with an out-of-court alternative to settling disagreements. Mediation is a type of ADR wherein an independent third party attempts to arrange a settlement at a conference between the parties DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida, on this 26 day of April, 2021. Administrative Circuit JudgeIN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Plaintiff(s), MG Case No. Nafandant(o\ CLenUaLsy / AGREED CASE MANAGEMENT PLAN (DGMAP) The parties hereby submit the following Agreed Case Management Plan to the Court for approval: Case Track Assignment! (check one): Expedited Track (Case resolved within 8 months) (It is recommended that discovery and an alternative dispute resolution/mediation be completed within 180 days after the complaint is filed and a final disposition entered within 245 days after the complaint is filed) Streamlined Track (Case resolved within 12 months (It is recommended that discovery and an alternative dispute resolution/mediation be completed within 270 days after the complaint is filed and a final disposition entered within 365 days after the complaint is filed) General Track (Case resolved within 18 months) (It is recommended that discovery and an alternative dispute resolution/mediation be completed within 450 days after the complaint is filed and a final disposition entered within 540 days after the complaint is filed) Complex Track (Case resolved within 2 years)’ (Thin tenal aannat ha calactad withant a hearing and order arantina matian (and Wan Camnoe 0G SUcOwG Windus a gearing ana C1Ger gianung Cuca to designate the case as complex per Florida Rule of Civil Procedure 1.201) ' Case disposition times for all Case Tracks have been established based on Florida Rule of General Practice and Judicial Administration 2.250(a)(1)(B) and the Circuit’s historic data. Although General and Complex he racaluad with a iney trial it ic avnacted that Streamlined and Fynedited Uv iesdiveu Wit @ jury uted, tb is Capeure une Cue Cand oxpecned Track cases will be resolved without a jury trial.Case Deadlines and Events DEADLINE OR EVENT. AGREED DATE Service of Unserved Parties Plaintiff(s): Cross/Counter Plaintiffs: Motions to Add Parties or to Amend Pleadings Plaintiff(s): Defendant(s): Resolution of Objections to Pleadings and Pretrial Motions (All motions to dismiss, quash service, strike affirmative defenses or extend the time to answer or respond to a pleading must be heard by this date) Plaintiff(s): Defendant(s): Discovery Deadline for Fact Witnesses (Aii discovery must be commenced in time io be compieied DEtorE this date) Plaintiff(s): Defendant(s): Discovery Deadline for Expert Witnesses (All discovery must be 2 ta he camnleted hefore this date) ne fo be comnleted hetore this date) Plaintiffs): Defendant(s): Completion of Alternative Dispute Resolution (ADR) (Mediation is mandatory unless the parties agree to another form of ADR). Deadline: Type of ADR: Other Deadlines or EventsTrial Information Is this Case At Issue pursuant to Rule 1.440? (Yes or No) Estimated Date the Case Will Be Prepared To Go To Trial [PLEASE READ FOOTNOTE BEFORE COMPLETING) Pit date: (If counsel and unrepresented parties do not agree on the estimated date on which the case will be prepared to go to trial, the Court may set the case for trial on its own motion) Deft date: Agreed: Ves or No Estimated Length of Trial (specify the number of trial days): Identification of Jury or Non-Jury Trial (remainder of page intentionally left blank) 2 For retroactive cases pending prior to April 30, 2021, the estimated date the case will be prepared to go to trial should not exceed the disposition time frame for the chosen case track. Cases that have been pending longer than the corresponding case track disposition time frame must follow the following time frames: Case Track Age of Case Estimated Date of Trial "Expedited ~ More thai 8 montis | Within 4 Monts 7 Streamlined 12-18 Months Within 6 Months More than 18 months Within 4 Months General 18-24 Months Within 6 Months More than 24 Months Within 4 MonthsThe above-referenced schedule of deadlines will be strictly adhered to by the parties unless a change is otherwise agreed to by the parties and approved by the Court. The Court will consider a request to approve changes to these deadlines upon a showing of good cause by either party based on matters arising from an emergency nature or unavailability. However, once the Agreed Case Management Plan has been approved by the Court, procrastination in completing discovery or the unavailability of counsel will not constitute good cause for a change to these deadlines. The failure to abide by these deadlines may result in sanctions by the Court, including the award of attorney’s fees, the striking of pleadings, and/or a dismissal of the action. Signature, address and telephone number of Counsel and Unrepresented Parties. Counsel must state Fil Bar number: PLAINTIFF’S COUNSEL. Or, if unrepresented, PLAINTIFF Address Address, Telephone #. : Telephone #. - E-Mail Address The Plaintiff(s) is registered to receive Florida Bar #. eI eservice at DEFENDANT’S PRINTED NAME DEFENDANT’S COUNSEL Address Telephone #. E-Mail Address Florida Bar #. CANEAR ARN AADICS TA. CURTURMLEY CUPS LUL or, if unrepresented, DEFENDANT Address, Telephone #. The Defendant(s) is registered to receive eservice at _