Preview
Filing # 141180440 E-Filed 01/02/2022 06:06:03 AM
Court Stamp Here
RETURN OF SERVICE
IN THE COUNTY COURT IN AND FOR COLLIER COUNTY, FLORIDA
Plaintiff Case #
DISCOVER BANK 112021CC0023090001XX
Defendant Hearing Date
SANDRA ALVAREZ
Person to be Served Came to Hand Date/Time
SANDRA ALVAREZ
emerson ‘(2130/2024 8:33 AM
Manner of Service Service Date/Time
Personal
pm t2isoi2024 7:08 PM
Documents Service Fee
Summons;Complaint;Exhibits;Standing Order
On 12/30/2021 at:
4752 SW 31ST AVE, NAPLES, FL 34116 | served SANDRA ALVAREZ by:
Personally delivering 1 copy(ies) of Summons, Complaint, Exhibits and Standing Order to SANDRA ALVAREZ, with
the date and hour of service endorsed thereon by me.
THE DESCRIPTION OF THE PERSON WITH WHOM THE COPY OF THIS PROCESS WAS LEFT IS AS FOLLOWS:
I delivered the documents to SANDRA ALVAREZ with identity confirmed by subject stating their name. The
individual accepted service with direct delivery. The individual appeared to be a brown-haired Hispanic female
contact 45-55 years of age, 5'4"-5'6" tall and weighing 140-160 Ibs with an accent. At the address I observed a
package/mail addressed to subject. | spoke with a neighbor who says subject resides
1 asked the indicated person whether the defendant was presently in the military service of the United States Government
or in active duty in the military service of the State of Florida and was told defendant was not.
Notary not required pursuant to F.S. 92.525(2).
RY to nor interested in this case and | have the proper authority in the jurisdiction where | effected
Wy aptey 48. Per U.S. Code § 1746, | declare under penalty of perjury under the laws of the United
j LIS ig and correct.
157345 | 157345 | December 30, 2021
187345 | 157345 |
Searle Arminio ~ Process Server ID Date Executed
Ref 4382569 Tracking # 0081210944
ee @abclegol Rausch Sturm LLP i
KAMION
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 01/02/2022 06:06:03 AM11-2021-CC-002309-0001-XX
Filing # 140041934 E-Filed 12/09/2021 01:04:39 PM
IN THE COUNTY COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLPER COUNTY FL BRB AM By Camille Arminio Reg. # 157345 Ex. 12/31/202
CIVIL DIVISION
DISCOVER BANK
Plaintiff, CASE NUMBER:
vs.
JUDGE:
SANDRA ALVAREZ
Defendant(s).
/ Our File #4382569
SUMMONS
THE STATE OF FLORIDA:
To Each Sheriff of the State:
YOU ARE COMMANDED to serve this summons and a copy of the complaint in this law-suit on
defendant, SANDRA ALVAREZ, 4752 SW 31ST AVE, NAPLES FL 34116.
DATED ON Dec 102021
CLERK OF CIVIL COURT
Crystal K. Kinzel
As Clerk of Court
py Bianca Fernandez
As Deputy Clerk
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 12/09/2021 01:04:39 PMIMPORTANT
A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to
the attached complaint with the clerk of this court. 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
response on time, you may lose the case, and your wages, money, and property may thereafter be taken 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 mail or
take a copy of your written response to the “Plaintiff/Plaintiff’s Attorney” named below.
IMPORTANTE
Usted ha sido demandado legalmente. Tiene 20 dias, contados a partir del recibo de esta notificacion, para contestar la demanda
adjunta, por escrito, y presentarla ante este tribunal. Una llamada telefonica no lo protegera. Si usted desea que el tribunal considere su
defensa, debe presentar su respuesta por escrito, incluyendo el numero del caso y los nombres de las partes interesadas. Si usted no
contesta la demanda a tiempo, pudiese perder el caso y podria ser despojado de sus ingresos y propiedades, o privado de sus derechos,
sin previo aviso del tribunal. Existen otros requisitos legales. Si no conoce a un abogado, puede llamar a una de las oficinas de
asistencia legal que aparecen en la guia telefonica.
Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta su resuesta ante el tribunal, debera usted enviar
por correo o entregar una copia de su respuesta a la persona denominada abajo como “Plaintiff/Plaintiff’s Attorney” (Demandante o
Abogado del Demandante).
IMPORTANT
Des poursuites judiciares ont ete entreprises contre vous. Vous avez 20 jours consecutifs a partir de la date de l’asignation de cette
citation pour deposer une reponse ecrite a la plainte ci-jointe aupres de ce tribunal. Un simple coup de telephone est insuffisant pour
vous proteger. Vous etes obliges de deposer votre reponse ecrite, avec mention du numero de dossier ci-dessus et du nom des parties
nommees ici, si vous souhaitez que le tribunal entende votre cause. Si vous ne deposez pas votre reponse ecrite dans le relai requis,
vous risquez de perdre la cause ainsi que votre salaire, votre argent, et vos biens peuvent etre saisis par la suite, sans aucun preavis
ulterieur du tribunal. II y a d’autres obligations juridiques et vous pouvez requerir les services immediats d’un avocat. Si vous ne
connaissez pas d’avocat,vos pourriez telephoner a un bureau d’assistance juridique (figurant a l’annuaire de telephones).
Si vous choisissez de deposer vous-meme une reponse ecrite, il vous faudra egalement, en meme temps que cette formalite, faire
parvenir ou expedier une copie de votre reponse ecrite au “Plaintiff/Plaintiff's Attorney” (Plaignant ou a son avocat) nomme ci-
dessous.AMERICANS WITH DISABILITY ACT: If you are a person with a disability who needs
any accommodation in order to participate in this proceeding, you are entitled at no cost
to you, to the provision of certain assistance. Please contact Charles Rice, Administrative
Court Services Manager, whose office is located at 3315 East Tamiami Trail, Suite 501,
Naples, Florida 34112, and whose telephone number is (239) 252-8800, at least 7 days
before your scheduled court appearance, or immediately upon receiving this notification
if the time before the scheduled appearance is less than 7 days; if you are hearing or voice
impaired, call 711.
Date: 12/07/2021 4S Michelle Quiles
Jessica J. Fagen - Bar No. 50668
Michelle Quiles - Bar No. 0121901
Matthew Fornaro - Bar No. 0650641
Arantxa S. Diaz-Caballero - Bar No. 1015278
Stephanie D. Simmonds - Bar #0085404
Tasia B. Ward - Bar #1016204
Guianeya Herrera-Osorio - Bar #1015316
Keith W. Alexander - Bar #1018422
Leslie Ann Lunsford Dunn - Bar #158320
Matthew Overpeck - Bar #0121625
RAUSCH STURM LLP
ATTORNEY FOR PLAINTIFF
100 Second Avenue South, Suite 306S
Saint Petersburg, FL 33701
(855) 560-6866 TTY: 711
lawfirmFL@rsieh.comIN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER
COUNTY, FLORIDA CIVIL ACTION
Discover Bank
Plaintiff(s),
vs. CASE NO: 11-2021-CC-002309-0001-XX
Sandra Alvarez
Defendant(s).
STANDING ORDER IN COUNTY CIVIL CASES IN THE TWENTIETH JUDICIAL CIRCUIT
WITH CASE MANAGEMENT PLAN
PURSUANT to Florida Rule of Civil Procedure 1.200(a), Florida Rule of Judicial Administration 2.545,
Florida Supreme Court Administrative Order AOSC 20-23 (Amendment12), and Administrative Order
1.13 (as amended) entered by the Chief Judge of this Circuit, the parties are ordered to adhere to the
following information and procedures applicable to civil lawsuits in the County Court, excluding Small
Claims cases, in which the Florida Rules of Civil Procedure have not been invoked, and Eviction cases:
1. SERVICE OF THIS ORDER. The Plaintiff is directed to serve a copy of this order, with the
attached Case Management Plan, with each Summons issued in this case. One copy of this Order is to be
filed with the Clerk of Court with proof of service. The Plaintiff shall pay the appropriate statutory clerk’s
fees for copies for each Standing Order issued and attached to the Summons.
2. CIVIL CASE MANAGEMENT SYSTEM. The Supreme Court of Florida has established
guidelines and directives for the prompt processing and resolution of civil cases and the issuance of a case
management plan. This Court has adopted a case management system to help meet those guidelines. In
contested cases (other than Small Claims cases, in which the Florida Rules of Civil Procedure have not
been invoked, and eviction cases), the parties are required to participate in the case management system.
In order to meet these guidelines and directives, the Court hereby issues the Case Management Plan
attached hereto. Should the parties wish to amend this plan during the course of the case, they may submit
a proposed Amended Case Management Plan along with their reasons that the Court should consider
approving same. The county civil Case Management Plan may be accessed on the Court’s website at:
http://www.ca.cjis20.org/web/main/civil.asp.
3. ALTERNATIVE DISPUTE RESOLUTION (ADR). ADR provides parties with an out-of-
court alternative for settling disagreements. The most common form of ADR is Mediation, which is a
conference at which a Supreme Court Certified mediator, who is a specially trained third party, attempts to
facilitate a settlement between the parties. The Court, at its discretion, may require the parties to
participate in Mediation prior to trial, unless the parties agree to another form of ADR, such as Non-
Binding Arbitration. The Court may, on its own motion or the motion of the parties, refer a case to Non-
Binding Arbitration. Non-Binding Arbitration is a process in which the Court refers a case to a registered
arbitrator, or panel of arbitrators, who will hear evidence and make an award. That award may become a
final judgment in the case if a Motion for Trial De Novo is not filed pursuant to Fla. R. Civ. P. 1.820(h).
4. FAILURE TO PROSECUTE. The Court will issue a Notice of Intent to Dismiss a case if there is
no record activity within a ten (10) month period of time.
5. ELECTRONIC SERVICE (e-Service) AND ELECTRONIC FILING (e-File). In general,
attorneys are required to designate a primary e-mail address for the purpose of serving and receivingservice of pleadings (after the initial pleading), and are required to electronically file documents through
the Florida Courts e-filing Portal. Self-represented litigants are not required, but are encouraged to file
with the Clerk a designation of a primary e-mail address for the purpose of serving and receiving service
of pleadings (after the initial pleading), and to electronically file documents through the Florida Courts e-
filing Portal at https://www.myflcourtaccess.com. If a self-represented litigant does not designate a
primary e-mail address, service by and on that self-represented litigant is to be by hand-delivery or mail
and in accordance with Fla. R. Jud. Admin. 2.516, and the filing of documents by that self-represented
litigant with the Clerk is to be done manually and in accordance with Fla. R. Jud. Admin. 2.525.
6. RULES OF PROFESSIONALISM. The Twentieth Judicial Circuit has adopted Administrative
Order 2.20, which sets forth standards of professional courtesy and conduct for all counsel practicing
within the Circuit and self-represented litigants. The Court requires that all parties familiarize themselves
and comply with Administrative Order 2.20. Administrative Order 2.20 may be viewed on the Court’s
website at: http://www.ca.cjis20.org/web/main/ao_admin.asp.
DONE AND ORDERED in Chambers at Naples, Collier County, Florida, on this 10th of December,
AILO
Janeice T Martin, County JudgeIN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER
COUNTY, FLORIDA CIVIL ACTION
Discover Bank
Plaintiff(s),
vs. CASE NO: 11-2021-CC-002309-0001-XX
Sandra Alvarez
Defendant(s).
COUNTY CIVIL CASE MANAGEMENT PLAN
The parties shall comply with the below Case Management Plan:
Case Track Assignment!:
x Expedited Track (Case to be resolved within 12 months of filing):
(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)
Standard Track (Case to be resolved within 18 months of filing):
(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 to be resolved within 2 years of filing):
(Case will likely be declared complex per Florida Rule of Civil Procedure 1.201)
Case Deadlines and Events
DATE
180 days prior to trial
90 days prior to trial
90 days prior to trial
180 days prior to trial
120 days prior to trial
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.Discovery Deadline for Expert Witnesses 60 days prior to trial
Completion of Alternative Dispute 60 days prior to trial, unless waived by the
Resolution (ADR) Court.
Deadline for Filing Dispositive Motions 60 days prior to trial. Must be heard not later
(Court requires filing not later than 10 days than 30 days prior to commencement of trial
prior to the pretrial conference) period.
Pretrial/Trial Conference Date An Order will be issued by the Court
scheduling the Pretrial/Trial Conference.
Trial Information
Estimated Date the Case Will Be Expedited Track deadline is 12 months
Prepared To Go To Trial. This is the from date initial Complaint was filed.
estimated time the case should be ready
for trial based on the Expedited Track and
upon which all deadlines are based.
Estimated Length of Trial No more than 3 days. If more than 3
days are needed, the court shall be
notified in writing prior to or at the
pretrial conference.
Identification of Jury or Non-Jury Trial Either party shall file a Notice for Trial
immediately upon the case being at issue
indicating jury or non-jury and length of
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, procrastination in the completing of
discovery 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.
DONE AND ORDERED in Chambers at Naples, Collier County, Florida, on this 10th of December,
AIL
Janeice T Martin, County Judge