Preview
Filing # 166412782 E-Filed 02/08/2023 03:31:51 PM
IN THE CIRCUIT COURT OF THE
FOURTH JUDICIAL CIRCUIT, IN AND
FOR DUVAL COUNTY, FLORIDA
CASE NO.: 2022-CA-006036
DIVISION: CV-H
ANGELA JORDAN and KETERYNA
SHEREMET,
Plaintiff(s),
v.
SECURITY FIRST INSURANCE
COMPANY,
Defendant(s).
____________________________________/
TRIAL ORDER
This case is at issue and ready for trial. This Order sets several deadlines for the parties
leading up to the trial in order to ensure the orderly administration of justice. Accordingly, it is,
therefore,
ORDERED as follows:
1. TRIAL DATE.
This cause is hereby set for jury trial on April 22, 2024, at 9:30 a.m. Time allocated for
trial is four days.
2. PRE-TRIAL CONFERENCE.
Pretrial Conference will be held in Chambers, Hearing Room 712, Duval County
Courthouse, Jacksonville, Florida on April 4, 2024, at 9:45 a.m. in accordance with the provisions
of Rule 1.200, Florida Rules of Civil Procedure. The Conference is scheduled for 15 minutes.
3. REQUIREMENTS PRIOR TO PRE-TRIAL CONFERENCE.
No later than seven days prior to the Pre-Trial Conference, attorneys for each party shall
meet together by agreement instigated by counsel for the Plaintiff, to discuss the possibility of
settlement; stipulate to as many facts and issues as possible; examine all exhibits and documents
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ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 02/09/2023 09:19:19 AM
which may be used at trial; furnish opposing counsel the names and addresses of all witnesses who
may testify at trial; review all video depositions or exhibits to be used at trial; review and prepare
proposed jury instructions and verdict forms; and complete all other matters which may expedite
both the Pre-Trial Conference and the Trial of this case.
4. REQUIREMENTS OF PRE-TRIAL STIPULATION.
Counsel shall prepare a Pre-Trial Stipulation which shall be filed with the Court at the Pre-
Trial Conference and shall contain the following: (a) a concise factual statement of the nature of
the action, which shall include the date and place of accrual, identity of the parties as they relate
to the action, and a brief general statement of each party's case or contention. The statement shall
be in such form and contain such necessary information for the Court to read to and apprise the
jury of the claims to be tried, including any Counter-Claims, Cross-Claims, or Third-Party Claims;
(b) a concise statement of those facts which are admitted and will require no proof at trial; (c) a
concise statement of those issues of fact which remain to be litigated; (d) any proposed
amendments to the pleadings; (e) a complete list of witnesses, including anticipated impeachment
witnesses, specifying the name and address of each from whom testimony may be presented at
trial; (f) a statement reflecting objections to specific portions of video depositions, testimony, or
video exhibits which may be offered in evidence at trial; and (g) a list of any undisposed matters
to be heard at the Pre-Trial Conference.
5. TRIAL EXHIBITS.
All exhibits intended to be offered at trial shall be exhibited to all opposing counsel prior
to the Pre-Trial Conference. The Pre-Trial Stipulation shall contain a list of all exhibits which may
be offered in evidence at trial, together with a statement of objections, if any, to exhibits offered
by the opposing party. With respect to each item, the Pre-Trial Stipulation shall reflect whether or
not the evidence will be stipulated into evidence, stipulated as to authenticity, with objection
reserved for relevancy and materiality, or objected to in its entirety and the ground therefor. All
exhibits which are the subject of any objection raised in the Pre-Trial Stipulation shall be brought
to the Pre-Trial Conference.
6. RETAINED EXPERT WITNESSES.
No later than 180 days prior to the Pre-Trial Conference, Plaintiff(s) shall serve on all
opposing counsel and file with the Court a Notice containing the following information regarding
each retained expert witness who will testify at trial on behalf of Plaintiff(s): (a) the name and
address of the witness; (b) the area(s) of expertise of the witness; (c) the subject matter of the
expected testimony of the witness; (d) the substance of the facts and opinions about which the
witness is expected to testify; and (e) a summary of the grounds on which each of the opinions of
the witnesses will be based. At the time of disclosure, Plaintiff(s) shall furnish opposing counsel
with two alternative deposition dates within the following 45 days for each retained expert witness.
No later than 150 days prior to the Pre-Trial Conference, each Defendant shall serve on all other
counsel and file with the Court a Notice containing the same information regarding each expert
witness who will testify at trial on behalf of that defendant. At the time of disclosure, each
Defendant shall furnish opposing counsel with two alternative deposition dates within the
following 45 days for each retained expert witness. No later than 30 days after the plaintiff(s) is
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served with the defendant’s expert witness disclosure, the plaintiff(s) may serve on all other
counsel and file with the Court a notice containing the same information regarding retained rebuttal
expert witnesses, if any, who will testify at trial on behalf of the plaintiff(s). At the time of
disclosure, Plaintiff(s) shall furnish opposing counsel with two alternative deposition dates within
the following 45 days for each retained expert witness. Any expert witness not included on the
Notice as provided herein will not be allowed to testify without an order of the Court. All parties
shall cooperate in the scheduling of expert depositions. Notwithstanding the foregoing, the Court
expects the parties to truthfully and thoroughly answer interrogatories and other discovery. If
interrogatories seeking information regarding expert witnesses have been served, the party
answering such discovery shall do so in good faith and shall not delay furnishing the information
regarding expert witnesses until the time such disclosure is required by this order.
Nothing in the foregoing should be interpreted to cause discovery regarding experts to
commence on the deadlines referenced above. Should it be determined that a party failed to
conduct discovery in good faith by refusing to identify expert witnesses or their opinions in a
timely manner pursuant to interrogatories or other discovery, the Court may strike such experts'
testimony.
7. DISCOVERY.
All discovery shall be completed 90 days prior to the Pre-Trial Conference unless otherwise
extended by Order of the Court.
8. SUMMARY JUDGMENT
Motions for summary judgment shall be filed no later than 75 days prior to the Pre-Trial
Conference. Responses in opposition to summary judgment shall be filed no later than 60 days
prior to the Pre-Trial Conference.
9. MOTIONS TO AMEND PLEADINGS
Any motion seeking to amend the pleadings shall be filed no later than 60 days prior to the
Pre-Trial Conference.
10. EXPERT ISSUES.
All expert related motions or objections shall be filed and served at least 75 days prior to
the Pre-Trial Conference. A copy of all such motions shall be delivered to the Court at the same
time they are filed and served. The party filing expert related motions or objections shall be
responsible to do that which is necessary so that hearings regarding expert related evidence shall
be noticed to be heard or agreed to by the parties no later than 30 days prior to the first day of the
date the case is set for trial. Any expert related motions or objections shall state with particularity
the grounds upon which they are based and the substantial matters of law to be argued and shall
identify any evidence or supporting material on which the movant relies. Any expert related
motions or objections not filed or noticed for hearing within the time referenced in this paragraph
are denied and such objections are overruled. The Court may summarily rule on any expert related
motion not written with particularity as described above.
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11. MOTIONS IN LIMINE.
All case-specific Motions in Limine shall be filed, served, noticed and heard or agreed to
by the parties no later than 30 days prior to the Pre-Trial Conference. A copy of all such motions
shall be delivered to the Court at the same time they are filed and served. The Motion shall state
with particularity the grounds upon which it is based and the substantial matters of law to be argued
and shall identify any evidence or supporting material on which the movant relies. The Court may
summarily rule on any Motions in Limine not case-specific.
12. JURY INSTRUCTIONS AND VERDICT FORMS.
Typed proposed jury instructions and verdict forms shall be filed with the Court at the Pre-
Trial Conference and may be supplemented prior to the Jury Instruction Conference. As set forth
in Paragraph 3, the parties shall jointly prepare and review proposed jury instructions and verdict
forms prior to the Pre-Trial Conference.
13. ATTORNEY REPRESENTATION.
The Pre-Trial meeting and the Pre-Trial Conference shall be attended by an attorney who
will participate in the trial of the case, and all admissions and disclosures of fact made at those
times shall be binding on the client.
14. MEDIATION.
This matter is hereby referred to a Mediator. The Mediator shall be Michael Burnett.
Mediation shall occur prior to the Pre-Trial Conference. If the case should settle, the mediator
and all counsel for the Plaintiff(s) and Defendant(s) shall immediately contact the Judge's office
and remove the trial and pretrial conference from the Judge's calendar. Copy of mediation
report is not sufficient to remove the case from the docket.
15. ADMONITIONS.
Failure to comply with the requirement of this Order will subject the party or attorney to
appropriate sanctions.
16. SETTLEMENT.
All counsel shall immediately notify this Court in the event of settlement or dismissal.
Additionally, the parties shall submit a stipulation for an order of dismissal or shall file a dismissal
with prejudice of the case. Counsel shall also notify the Court of any pending hearings that will
be canceled as a result of the settlement.
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DONE AND ORDERED in Chambers at Jacksonville, Duval County, Florida, this 8th day
of February, 2023.
G.L. FELTEL, JR.
CIRCUIT JUDGE
Copies to counsel of record via electronic filing
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 the ADA Coordinator at (904) 255-1695 or crtintrp@coj.net, 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.
5
Preview
Filing # 166412782 E-Filed 02/08/2023 03:31:51 PM IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA CASE NO.: 2022-CA-006036 DIVISION: CV-H ANGELA JORDAN and KETERYNA SHEREMET, Plaintiff(s), v. SECURITY FIRST INSURANCE COMPANY, Defendant(s). ____________________________________/ TRIAL ORDER This case is at issue and ready for trial. This Order sets several deadlines for the parties leading up to the trial in order to ensure the orderly administration of justice. Accordingly, it is, therefore, ORDERED as follows: 1. TRIAL DATE. This cause is hereby set for jury trial on April 22, 2024, at 9:30 a.m. Time allocated for trial is four days. 2. PRE-TRIAL CONFERENCE. Pretrial Conference will be held in Chambers, Hearing Room 712, Duval County Courthouse, Jacksonville, Florida on April 4, 2024, at 9:45 a.m. in accordance with the provisions of Rule 1.200, Florida Rules of Civil Procedure. The Conference is scheduled for 15 minutes. 3. REQUIREMENTS PRIOR TO PRE-TRIAL CONFERENCE. No later than seven days prior to the Pre-Trial Conference, attorneys for each party shall meet together by agreement instigated by counsel for the Plaintiff, to discuss the possibility of settlement; stipulate to as many facts and issues as possible; examine all exhibits and documents 1 ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 02/09/2023 09:19:19 AM which may be used at trial; furnish opposing counsel the names and addresses of all witnesses who may testify at trial; review all video depositions or exhibits to be used at trial; review and prepare proposed jury instructions and verdict forms; and complete all other matters which may expedite both the Pre-Trial Conference and the Trial of this case. 4. REQUIREMENTS OF PRE-TRIAL STIPULATION. Counsel shall prepare a Pre-Trial Stipulation which shall be filed with the Court at the Pre- Trial Conference and shall contain the following: (a) a concise factual statement of the nature of the action, which shall include the date and place of accrual, identity of the parties as they relate to the action, and a brief general statement of each party's case or contention. The statement shall be in such form and contain such necessary information for the Court to read to and apprise the jury of the claims to be tried, including any Counter-Claims, Cross-Claims, or Third-Party Claims; (b) a concise statement of those facts which are admitted and will require no proof at trial; (c) a concise statement of those issues of fact which remain to be litigated; (d) any proposed amendments to the pleadings; (e) a complete list of witnesses, including anticipated impeachment witnesses, specifying the name and address of each from whom testimony may be presented at trial; (f) a statement reflecting objections to specific portions of video depositions, testimony, or video exhibits which may be offered in evidence at trial; and (g) a list of any undisposed matters to be heard at the Pre-Trial Conference. 5. TRIAL EXHIBITS. All exhibits intended to be offered at trial shall be exhibited to all opposing counsel prior to the Pre-Trial Conference. The Pre-Trial Stipulation shall contain a list of all exhibits which may be offered in evidence at trial, together with a statement of objections, if any, to exhibits offered by the opposing party. With respect to each item, the Pre-Trial Stipulation shall reflect whether or not the evidence will be stipulated into evidence, stipulated as to authenticity, with objection reserved for relevancy and materiality, or objected to in its entirety and the ground therefor. All exhibits which are the subject of any objection raised in the Pre-Trial Stipulation shall be brought to the Pre-Trial Conference. 6. RETAINED EXPERT WITNESSES. No later than 180 days prior to the Pre-Trial Conference, Plaintiff(s) shall serve on all opposing counsel and file with the Court a Notice containing the following information regarding each retained expert witness who will testify at trial on behalf of Plaintiff(s): (a) the name and address of the witness; (b) the area(s) of expertise of the witness; (c) the subject matter of the expected testimony of the witness; (d) the substance of the facts and opinions about which the witness is expected to testify; and (e) a summary of the grounds on which each of the opinions of the witnesses will be based. At the time of disclosure, Plaintiff(s) shall furnish opposing counsel with two alternative deposition dates within the following 45 days for each retained expert witness. No later than 150 days prior to the Pre-Trial Conference, each Defendant shall serve on all other counsel and file with the Court a Notice containing the same information regarding each expert witness who will testify at trial on behalf of that defendant. At the time of disclosure, each Defendant shall furnish opposing counsel with two alternative deposition dates within the following 45 days for each retained expert witness. No later than 30 days after the plaintiff(s) is 2 served with the defendant’s expert witness disclosure, the plaintiff(s) may serve on all other counsel and file with the Court a notice containing the same information regarding retained rebuttal expert witnesses, if any, who will testify at trial on behalf of the plaintiff(s). At the time of disclosure, Plaintiff(s) shall furnish opposing counsel with two alternative deposition dates within the following 45 days for each retained expert witness. Any expert witness not included on the Notice as provided herein will not be allowed to testify without an order of the Court. All parties shall cooperate in the scheduling of expert depositions. Notwithstanding the foregoing, the Court expects the parties to truthfully and thoroughly answer interrogatories and other discovery. If interrogatories seeking information regarding expert witnesses have been served, the party answering such discovery shall do so in good faith and shall not delay furnishing the information regarding expert witnesses until the time such disclosure is required by this order. Nothing in the foregoing should be interpreted to cause discovery regarding experts to commence on the deadlines referenced above. Should it be determined that a party failed to conduct discovery in good faith by refusing to identify expert witnesses or their opinions in a timely manner pursuant to interrogatories or other discovery, the Court may strike such experts' testimony. 7. DISCOVERY. All discovery shall be completed 90 days prior to the Pre-Trial Conference unless otherwise extended by Order of the Court. 8. SUMMARY JUDGMENT Motions for summary judgment shall be filed no later than 75 days prior to the Pre-Trial Conference. Responses in opposition to summary judgment shall be filed no later than 60 days prior to the Pre-Trial Conference. 9. MOTIONS TO AMEND PLEADINGS Any motion seeking to amend the pleadings shall be filed no later than 60 days prior to the Pre-Trial Conference. 10. EXPERT ISSUES. All expert related motions or objections shall be filed and served at least 75 days prior to the Pre-Trial Conference. A copy of all such motions shall be delivered to the Court at the same time they are filed and served. The party filing expert related motions or objections shall be responsible to do that which is necessary so that hearings regarding expert related evidence shall be noticed to be heard or agreed to by the parties no later than 30 days prior to the first day of the date the case is set for trial. Any expert related motions or objections shall state with particularity the grounds upon which they are based and the substantial matters of law to be argued and shall identify any evidence or supporting material on which the movant relies. Any expert related motions or objections not filed or noticed for hearing within the time referenced in this paragraph are denied and such objections are overruled. The Court may summarily rule on any expert related motion not written with particularity as described above. 3 11. MOTIONS IN LIMINE. All case-specific Motions in Limine shall be filed, served, noticed and heard or agreed to by the parties no later than 30 days prior to the Pre-Trial Conference. A copy of all such motions shall be delivered to the Court at the same time they are filed and served. The Motion shall state with particularity the grounds upon which it is based and the substantial matters of law to be argued and shall identify any evidence or supporting material on which the movant relies. The Court may summarily rule on any Motions in Limine not case-specific. 12. JURY INSTRUCTIONS AND VERDICT FORMS. Typed proposed jury instructions and verdict forms shall be filed with the Court at the Pre- Trial Conference and may be supplemented prior to the Jury Instruction Conference. As set forth in Paragraph 3, the parties shall jointly prepare and review proposed jury instructions and verdict forms prior to the Pre-Trial Conference. 13. ATTORNEY REPRESENTATION. The Pre-Trial meeting and the Pre-Trial Conference shall be attended by an attorney who will participate in the trial of the case, and all admissions and disclosures of fact made at those times shall be binding on the client. 14. MEDIATION. This matter is hereby referred to a Mediator. The Mediator shall be Michael Burnett. Mediation shall occur prior to the Pre-Trial Conference. If the case should settle, the mediator and all counsel for the Plaintiff(s) and Defendant(s) shall immediately contact the Judge's office and remove the trial and pretrial conference from the Judge's calendar. Copy of mediation report is not sufficient to remove the case from the docket. 15. ADMONITIONS. Failure to comply with the requirement of this Order will subject the party or attorney to appropriate sanctions. 16. SETTLEMENT. All counsel shall immediately notify this Court in the event of settlement or dismissal. Additionally, the parties shall submit a stipulation for an order of dismissal or shall file a dismissal with prejudice of the case. Counsel shall also notify the Court of any pending hearings that will be canceled as a result of the settlement. 4 DONE AND ORDERED in Chambers at Jacksonville, Duval County, Florida, this 8th day of February, 2023. G.L. FELTEL, JR. CIRCUIT JUDGE Copies to counsel of record via electronic filing 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 the ADA Coordinator at (904) 255-1695 or crtintrp@coj.net, 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. 5