On June 29, 2022 a
Complaint,Petition
was filed
involving a dispute between
3625 Pleasant Acres Road, Llc,
and
Rapid Recovery Agency, Inc.,
Reliable Land Holdings Iii, Llc,
in the District Court of St. Lucie County.
Preview
Filing # 152401020 E-Filed 06/29/2022 10:39:16 AM
IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR
SAINT LUCIE COUNTY, FLORIDA
3625 PLEASANT ACRES ROAD, LLC, a CASE NO.
Florida Limited Liability Company,
Plaintiff,
v.
RAPID RECOVERY AGENCY, INC., a
Florida corporation and RELIABLE LAND
HOLDINGS III, LLC, a Florida Limited
Liability Company,
Defendants.
__________________________________/
CIVIL CASE MANAGEMENT PLAN AND ORDER
TO BE SUBMITTED TO THE COURT FOR APPROVAL (1) WITHIN 30 DAYS AFTER
DATE OF SERVICE ON THE LAST NAMED DEFENDANT OR (2) PRIOR TO 12/3/21
FOR CASES FILED PRIOR TO 4/30/21
Pursuant to Florida Rule of General Practice and Judicial Administration 2.250(a)(1)(B) and
Florida Rule of Civil Procedure 1.440, the parties hereby submit the following Case Management
Plan to the Court for approval.
I. Case Track Assignment (check one): Case disposition times for all case tracks have been
established in accordance with the Florida Rules of General Practice and Judicial
Administration 2.250(a)(1)(B).
☐Streamlined Track (Case resolved within 12 months without a jury trial or within
jurisdiction of County Court.)
☐General Track (Case resolved within 18 months with or without a jury trial.)
☐Complex Track (Case resolved pursuant to Florida Rule of Civil Procedure
1.201, with or without a jury trial).
II. Case Events and Deadlines
Event Maximum Deadline Agreed
Dates
Streamlined General
Service of complaints; Service within 120 Service within 120
under extensions; adding days of filing of the days of filing of the
parties complaint unless an complaint unless an
extension is granted, extension is granted,
1
which extension shall which extension shall
not exceed 240 days not exceed 240 days
from the date of filing from the date of filing
of the complaint of the complaint
Fact and expert discovery Within 270 days after Within 450 days after
complete complaint is filed complaint is filed
Resolution of all Within 45 days after Within 45 days after
objections to pleadings, filing and prior to the filing and prior to the
pretrial motions pretrial conference pretrial conference
Mediation occurred within 270 days after within 450 days after
the complaint is filed the complaint is filed
(Other events specified by
judge)
Projected Date of Trial (A firm trial date shall be ordered by the presiding
judge when the case is at issue. Fla. R. Civ. P. 1.440.)
III. Trial Information
Estimated Length of Trial (specify number of trial days)
Identification of Jury or Non-Jury Trial
The schedule of deadlines herein will be strictly adhered to by the parties unless 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 Civil 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.
IV. Signature of Counsel or Unrepresented Parties
__________________________________ ________________________________
Plaintiff’s Counsel Defendant’s Counsel
Address Address
Phone Phone
2
__________________________________ ________________________________
Plaintiff (if unrepresented by counsel) Defendant (if unrepresented by counsel)
Address Address
Phone Phone
ORDER APPROVING CASE MANAGEMENT PLAN
THE COURT having reviewed the preceding Case Management Plan and finding it to be
satisfactory, it is hereby
ORDERED that the Case Management Plan is approved and all parties shall abide by the
terms herein.
DONE AND ORDERED in ________ County, Florida on ____________ , 2022.
________________________________
CIRCUIT JUDGE
Service list: Per Clerk of Court E-Portal Service List
3
Document Filed Date
June 29, 2022
Case Filing Date
June 29, 2022
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Filing # 152401020 E-Filed 06/29/2022 10:39:16 AM IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR SAINT LUCIE COUNTY, FLORIDA 3625 PLEASANT ACRES ROAD, LLC, a CASE NO. Florida Limited Liability Company, Plaintiff, v. RAPID RECOVERY AGENCY, INC., a Florida corporation and RELIABLE LAND HOLDINGS III, LLC, a Florida Limited Liability Company, Defendants. __________________________________/ CIVIL CASE MANAGEMENT PLAN AND ORDER TO BE SUBMITTED TO THE COURT FOR APPROVAL (1) WITHIN 30 DAYS AFTER DATE OF SERVICE ON THE LAST NAMED DEFENDANT OR (2) PRIOR TO 12/3/21 FOR CASES FILED PRIOR TO 4/30/21 Pursuant to Florida Rule of General Practice and Judicial Administration 2.250(a)(1)(B) and Florida Rule of Civil Procedure 1.440, the parties hereby submit the following Case Management Plan to the Court for approval. I. Case Track Assignment (check one): Case disposition times for all case tracks have been established in accordance with the Florida Rules of General Practice and Judicial Administration 2.250(a)(1)(B). ☐Streamlined Track (Case resolved within 12 months without a jury trial or within jurisdiction of County Court.) ☐General Track (Case resolved within 18 months with or without a jury trial.) ☐Complex Track (Case resolved pursuant to Florida Rule of Civil Procedure 1.201, with or without a jury trial). II. Case Events and Deadlines Event Maximum Deadline Agreed Dates Streamlined General Service of complaints; Service within 120 Service within 120 under extensions; adding days of filing of the days of filing of the parties complaint unless an complaint unless an extension is granted, extension is granted, 1 which extension shall which extension shall not exceed 240 days not exceed 240 days from the date of filing from the date of filing of the complaint of the complaint Fact and expert discovery Within 270 days after Within 450 days after complete complaint is filed complaint is filed Resolution of all Within 45 days after Within 45 days after objections to pleadings, filing and prior to the filing and prior to the pretrial motions pretrial conference pretrial conference Mediation occurred within 270 days after within 450 days after the complaint is filed the complaint is filed (Other events specified by judge) Projected Date of Trial (A firm trial date shall be ordered by the presiding judge when the case is at issue. Fla. R. Civ. P. 1.440.) III. Trial Information Estimated Length of Trial (specify number of trial days) Identification of Jury or Non-Jury Trial The schedule of deadlines herein will be strictly adhered to by the parties unless 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 Civil 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. IV. Signature of Counsel or Unrepresented Parties __________________________________ ________________________________ Plaintiff’s Counsel Defendant’s Counsel Address Address Phone Phone 2 __________________________________ ________________________________ Plaintiff (if unrepresented by counsel) Defendant (if unrepresented by counsel) Address Address Phone Phone ORDER APPROVING CASE MANAGEMENT PLAN THE COURT having reviewed the preceding Case Management Plan and finding it to be satisfactory, it is hereby ORDERED that the Case Management Plan is approved and all parties shall abide by the terms herein. DONE AND ORDERED in ________ County, Florida on ____________ , 2022. ________________________________ CIRCUIT JUDGE Service list: Per Clerk of Court E-Portal Service List 3