On December 05, 2019 a
Stipulation,Agreement
was filed
involving a dispute between
Garcia Fil, Gary Alberto,
and
Ladega, Maria Oluwasheun,
Miami Urology & Sexual Wellness Institute Pa,
for Auto Negligence
in the District Court of Collier County.
Preview
Filing # 113577007 E-Filed 09/18/2020 10:16:38 AM
IN THE TWENTIETH JUDICIAL CIRCUIT COURT IN AND FOR COLLIER
COUNTY, FLORIDA CIVIL DIVISION
CASE NO: 11-2019-CA-004766-0001-XX
GARY ALBERTO GARCIA GIL,
Plaintiff,
vs.
MIAMI UROLOGY & SEXUAL
WELLNESS INSTITUTE, P.A. and
MARIA OLUWASHEUN LADEGA
Defendants.
/
AGREED CASE MANAGEMENT PLAN AND ORDER
AGREED CASK MARKO
The parties hereby submit the following Agreed Case Management Plan to the Court for
approval;
Case Track Assignment I (check one — must be completed for cases, filed 1/1/10 or thereafter):
Expedited Track (Case resolved within 12 months);
(It is recommended that discovery and an alternative dispute resolution be
completed within 270 days after the complaint is filed and a final
disposition entered within 365 days after the complaint is filed)
X Standard Track (Case is resolved within 18 months);
(It is recommended that discovery and an alternative dispute resolution 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)
(Case will likely be declared complex per Florida Rule of Civil Procedure
1.201)
1 Case disposition times for all Case Tracks have been established in accordance with Florida Rule of Judicial
Administration 2,250(a)(1}(B). Although Standard and Complex Track cases may or may not be resolved with a jury
trial, it is expected that Expedited Track cases will be resolved without a Jury trial.
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 09/18/2020 10:16:38 AMCase Deadlines and Events
DEADLINE OR EVENT
Statement of Facts and/or Counterclaim(s) .
AGREED DATE
6/5/2021
‘Plaintiff(s):
Defendant(s); | 6/5/2021
Identification of facts the parties believe to be disputed
Plaintiff(s);
6/5/2021
Defendant(s): | 6/5/2021
Ydentification of the issues of law to be decided by the Court
Plaintiff(s)
6/5/2021
Defendant(s) | 6/5/2021
Motions to Add Parties or to Amend Pleadings
Plaintiff(s) | 6/5/2021
Defendant(s) { 6/5/2021
Disclosure of Fact Witnesses
Plaintiff(s): | 3/11/2021
Defendant(s): | 3/26/2021
Disclosure of Expert Witnesses
Plaintiff(s): | 3/11/2021
Defendant(s): | 3/262021
Filing of Exhibit List
Plaintiff(s): | 6/19/2021
Defendant(s): | 7/3/2021
Discovery Deadline for Fact Witnesses
(All discovery must be commenced in time to be completed before
this date)
-Plaintiff(s): | 5/5/2021
Defendant(s); | 5/5/2021
Expert Opinion Available to Opposing Party
(it is recommended that the last exchange occur 4 months before
trial and
1 —2 months before discovery deadline to allow time for expert
depositions, This does not require a written report unless otherwise
required by the rule.) -
Plaintiff(s); | 5/3/2021
Defendant(s): | 5/3/2021Discovery Deadline for Expert Witnesses
Plaintiff(s): | 6/4/2021
Defendant(s): | 6/4/2021
Completion of Alternative Dispute Resolution (ADR)
(Mediation is mandatory unless the parties agree to another form of
ADR. If early ADR is selected and it does not result in settlement
or disposition of this entire action, a case management conference
will be scheduled within 45 days from the date of ADR)
Deadline: | 6/2/2021
Type of ADR: | Mediation
Deadline for Filing Dispositive Motions
(Court requires filing not later than 10 days prior to the pretrial 7/4/2021
management conference
Pretrial Conference Date An Order will be issued
(Unless early ADR is selected, a pretrial conference date will be by the Court scheduling
scheduled within 45 days of the date of ADR not resulting in the Pretrial Conference.
settlement or disposition of this entire action.) _ .
Other Deadlines or Events
Trial Information
Estimated Date the Case Will Be Prepared To Go To Trial
(If counsel and unrepresented parties do not agree on the 9/9/2021
estimated date on which the case will be prepared to go to
2
Estimated Length of Trial (specify the number of trial
days):
Identification of Jury or Non-Jury Trial
The 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.
Dated:Filing # 113546455 E-Filed 09/17/2020 03:41:39 PM
Signature, address and telep
must state FL Bar number:
David Crockett, Esquire
FBN: 1001455
Morgan & Morgan
12800 University Drive
Fort Myers, FL 33907
Phone: (239) 432-6679
Fax: (239) 204-4085
Attorney for Plaintiff(s)
Email: dcrockett@forthepeople.com
hone number of Counsel and Un
represented Parties. Counsel
Mitchell. Katley
Mitchell Katler, Esquire
FBN: 454982
f James W. Kehoe, Ww
_ Law Offices 9!
3230 West Commercial Blvd/Ste 250
Ft. Lauderdale, Fi 33903
Phone: (954) 677-3723
Fax: (866) 292-4641 -
Attorney for Defendant(s)
Email: mkatler@travelers.com.ORDER APPROVING AGREED CASE MANAGEMENT PLAN
THE COURT having reviewed the preceding Agreed Case Management Plan and finding
it to be satisfactory, it is:
ORDERED AND ADJUDGED that the Agreed Case Management Plan is hereby
APPROVED AND ALL PARTIES SHALL ABIDE BY THE TERMS HEREIN.
ORDERED in Lee County, Fort Myers, Florida, this / a day of September, 2020.
Collier
Circuit Judge, Twentieth Judicial Circuit
cc: David Crockett, Attorney
derockett@forthepeople.com
Mista —(‘6pie% 4 Clunsel of Lecorel vic
cenrich@: 18.CON
ce ee (ers email
Case Filing Date
December 05, 2019
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 113577007 E-Filed 09/18/2020 10:16:38 AM IN THE TWENTIETH JUDICIAL CIRCUIT COURT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL DIVISION CASE NO: 11-2019-CA-004766-0001-XX GARY ALBERTO GARCIA GIL, Plaintiff, vs. MIAMI UROLOGY & SEXUAL WELLNESS INSTITUTE, P.A. and MARIA OLUWASHEUN LADEGA Defendants. / AGREED CASE MANAGEMENT PLAN AND ORDER AGREED CASK MARKO The parties hereby submit the following Agreed Case Management Plan to the Court for approval; Case Track Assignment I (check one — must be completed for cases, filed 1/1/10 or thereafter): Expedited Track (Case resolved within 12 months); (It is recommended that discovery and an alternative dispute resolution be completed within 270 days after the complaint is filed and a final disposition entered within 365 days after the complaint is filed) X Standard Track (Case is resolved within 18 months); (It is recommended that discovery and an alternative dispute resolution 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) (Case will likely be declared complex per Florida Rule of Civil Procedure 1.201) 1 Case disposition times for all Case Tracks have been established in accordance with Florida Rule of Judicial Administration 2,250(a)(1}(B). Although Standard and Complex Track cases may or may not be resolved with a jury trial, it is expected that Expedited Track cases will be resolved without a Jury trial. FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 09/18/2020 10:16:38 AMCase Deadlines and Events DEADLINE OR EVENT Statement of Facts and/or Counterclaim(s) . AGREED DATE 6/5/2021 ‘Plaintiff(s): Defendant(s); | 6/5/2021 Identification of facts the parties believe to be disputed Plaintiff(s); 6/5/2021 Defendant(s): | 6/5/2021 Ydentification of the issues of law to be decided by the Court Plaintiff(s) 6/5/2021 Defendant(s) | 6/5/2021 Motions to Add Parties or to Amend Pleadings Plaintiff(s) | 6/5/2021 Defendant(s) { 6/5/2021 Disclosure of Fact Witnesses Plaintiff(s): | 3/11/2021 Defendant(s): | 3/26/2021 Disclosure of Expert Witnesses Plaintiff(s): | 3/11/2021 Defendant(s): | 3/262021 Filing of Exhibit List Plaintiff(s): | 6/19/2021 Defendant(s): | 7/3/2021 Discovery Deadline for Fact Witnesses (All discovery must be commenced in time to be completed before this date) -Plaintiff(s): | 5/5/2021 Defendant(s); | 5/5/2021 Expert Opinion Available to Opposing Party (it is recommended that the last exchange occur 4 months before trial and 1 —2 months before discovery deadline to allow time for expert depositions, This does not require a written report unless otherwise required by the rule.) - Plaintiff(s); | 5/3/2021 Defendant(s): | 5/3/2021Discovery Deadline for Expert Witnesses Plaintiff(s): | 6/4/2021 Defendant(s): | 6/4/2021 Completion of Alternative Dispute Resolution (ADR) (Mediation is mandatory unless the parties agree to another form of ADR. If early ADR is selected and it does not result in settlement or disposition of this entire action, a case management conference will be scheduled within 45 days from the date of ADR) Deadline: | 6/2/2021 Type of ADR: | Mediation Deadline for Filing Dispositive Motions (Court requires filing not later than 10 days prior to the pretrial 7/4/2021 management conference Pretrial Conference Date An Order will be issued (Unless early ADR is selected, a pretrial conference date will be by the Court scheduling scheduled within 45 days of the date of ADR not resulting in the Pretrial Conference. settlement or disposition of this entire action.) _ . Other Deadlines or Events Trial Information Estimated Date the Case Will Be Prepared To Go To Trial (If counsel and unrepresented parties do not agree on the 9/9/2021 estimated date on which the case will be prepared to go to 2 Estimated Length of Trial (specify the number of trial days): Identification of Jury or Non-Jury Trial The 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. Dated:Filing # 113546455 E-Filed 09/17/2020 03:41:39 PM Signature, address and telep must state FL Bar number: David Crockett, Esquire FBN: 1001455 Morgan & Morgan 12800 University Drive Fort Myers, FL 33907 Phone: (239) 432-6679 Fax: (239) 204-4085 Attorney for Plaintiff(s) Email: dcrockett@forthepeople.com hone number of Counsel and Un represented Parties. Counsel Mitchell. Katley Mitchell Katler, Esquire FBN: 454982 f James W. Kehoe, Ww _ Law Offices 9! 3230 West Commercial Blvd/Ste 250 Ft. Lauderdale, Fi 33903 Phone: (954) 677-3723 Fax: (866) 292-4641 - Attorney for Defendant(s) Email: mkatler@travelers.com.ORDER APPROVING AGREED CASE MANAGEMENT PLAN THE COURT having reviewed the preceding Agreed Case Management Plan and finding it to be satisfactory, it is: ORDERED AND ADJUDGED that the Agreed Case Management Plan is hereby APPROVED AND ALL PARTIES SHALL ABIDE BY THE TERMS HEREIN. ORDERED in Lee County, Fort Myers, Florida, this / a day of September, 2020. Collier Circuit Judge, Twentieth Judicial Circuit cc: David Crockett, Attorney derockett@forthepeople.com Mista —(‘6pie% 4 Clunsel of Lecorel vic cenrich@: 18.CON ce ee (ers email