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Filing # 139260521 E-Filed 11/29/2021 02:21:10 PM
IN THE CIRCUIT COURT, FOURTH
JUDICIAL CIRCUIT, IN AND FOR
DUVAL COUNTY, FLORIDA
CASE NUMBER: 16-2020-CA-5928
DIVISION: CV-G
BRENDA BOSTON-HUDSON,
Plaintiff,
vs.
NOVAD MANAGEMENT
CONSULTING, LLC., a Maryland
limited liability company,
Defendant
DEFENDANT’S CASE MANAGEMENT PLAN
(Streamlined Track)
Defendant submits the following Case Management Plan to the Court for approval in all
cases filed before April 30, 2021. Note: All dates are to be calculated from the date of the Order
Approving Case Management Plan, unless otherwise noted.
DEADLINE OR EVENT AGREED DATE
Preliminary Summary of Pleadings: A Clerk’s Default has been entered on all
counts against Defendant on November 24,
2020. On February 9, 2021, a Final Judgment
was entered against Defendant as to Count II.
Plaintiff then filed a Motion For Final
Judgment As To Count I, Assessment Of Legal
Fees And Costs, And Plaintiff's Motion For
Pre-Judgment Writ of Attachment on June 18,
2021. On July 9, 2021, Defendant filed its
Response in Opposition to the foregoing
Motion, as well as a Motion to Vacate Default
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 11/29/2021 02:21:31 PM
as to Count I and for Dismissal of Count I, and
on July 15, 2021, Plaintiff filed a Motion to
Strike said Response. All motions are set for
hearing before this Honorable Court on
January 22, 2022, at 1:30 p.m..
Deadline for Service of Process Not applicable. Defendant Novad was served
on November 2, 2020.
Deadline for Service of Process extended if not Not applicable.
accomplished within 120 days.
Deadline to Add Parties and Amend Pleadings Not applicable.
Motions to Dismiss, Motions for More All Motions identified above have been filed,
Definite Statement, Motions to Strike, and any and are scheduled for hearing on January 22,
objections to the pleadings 2022, at 1:30 p.m.
Deadline for Completion of Fact and Expert 45 days prior to trial on Count I.
Discovery
Pre-Trial Motions, including Dispositive and 30 days prior to trial on Count I
Daubert Motions
Mediation / Alternative Dispute Resolution 30 days prior to trial on Count I
Approximate Pre-Trial Conference 15 days prior to trial on Count L
Approximate Trial Date June 2022.
Dated: November 29, 2021
/s/ Teris A. McGovern.
TERIS MCGOVERN, ESQUIRE
Attorney for Defendant
Florida Bar No.: 111898
Bitman, O’Brien & Morat, PLLC
CERTIFICATE OF SERVICE
THEREBY CERTIFY that a true and correct copy hereof was served upon the following
parties/counsel on this day, November 29, 2021 by hand delivery, 0 email transmission, ¥
electronic filing, o completed facsimile transmission, 0 overnight delivery (Federal Express),
and/or o U.S. Mail.
JAMES L. NIPPER
200 WEST FORSYTH STREET, SUITE C-6
JACKSONVILLE, FL 32202
JAMES@JAMESNIPPER.COM
Counsel for Plaintiff
BITMAN, O’BRIEN & MORAT, PLLC
/s/Teris McGovern
Teris McGovern, Esquire
Florida Bar No.: 111898
tmegovern@bitman-law.com
krahberg@bitman-law.com
255 Primera Blvd., Suite 128
Lake Mary, Florida 32746
Telephone: (407) 815-3110
Facsimile: (407) 815-2635
Attorneys for Defendant
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Filing # 139260521 E-Filed 11/29/2021 02:21:10 PM IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA CASE NUMBER: 16-2020-CA-5928 DIVISION: CV-G BRENDA BOSTON-HUDSON, Plaintiff, vs. NOVAD MANAGEMENT CONSULTING, LLC., a Maryland limited liability company, Defendant DEFENDANT’S CASE MANAGEMENT PLAN (Streamlined Track) Defendant submits the following Case Management Plan to the Court for approval in all cases filed before April 30, 2021. Note: All dates are to be calculated from the date of the Order Approving Case Management Plan, unless otherwise noted. DEADLINE OR EVENT AGREED DATE Preliminary Summary of Pleadings: A Clerk’s Default has been entered on all counts against Defendant on November 24, 2020. On February 9, 2021, a Final Judgment was entered against Defendant as to Count II. Plaintiff then filed a Motion For Final Judgment As To Count I, Assessment Of Legal Fees And Costs, And Plaintiff's Motion For Pre-Judgment Writ of Attachment on June 18, 2021. On July 9, 2021, Defendant filed its Response in Opposition to the foregoing Motion, as well as a Motion to Vacate Default ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 11/29/2021 02:21:31 PM as to Count I and for Dismissal of Count I, and on July 15, 2021, Plaintiff filed a Motion to Strike said Response. All motions are set for hearing before this Honorable Court on January 22, 2022, at 1:30 p.m.. Deadline for Service of Process Not applicable. Defendant Novad was served on November 2, 2020. Deadline for Service of Process extended if not Not applicable. accomplished within 120 days. Deadline to Add Parties and Amend Pleadings Not applicable. Motions to Dismiss, Motions for More All Motions identified above have been filed, Definite Statement, Motions to Strike, and any and are scheduled for hearing on January 22, objections to the pleadings 2022, at 1:30 p.m. Deadline for Completion of Fact and Expert 45 days prior to trial on Count I. Discovery Pre-Trial Motions, including Dispositive and 30 days prior to trial on Count I Daubert Motions Mediation / Alternative Dispute Resolution 30 days prior to trial on Count I Approximate Pre-Trial Conference 15 days prior to trial on Count L Approximate Trial Date June 2022. Dated: November 29, 2021 /s/ Teris A. McGovern. TERIS MCGOVERN, ESQUIRE Attorney for Defendant Florida Bar No.: 111898 Bitman, O’Brien & Morat, PLLC CERTIFICATE OF SERVICE THEREBY CERTIFY that a true and correct copy hereof was served upon the following parties/counsel on this day, November 29, 2021 by hand delivery, 0 email transmission, ¥ electronic filing, o completed facsimile transmission, 0 overnight delivery (Federal Express), and/or o U.S. Mail. JAMES L. NIPPER 200 WEST FORSYTH STREET, SUITE C-6 JACKSONVILLE, FL 32202 JAMES@JAMESNIPPER.COM Counsel for Plaintiff BITMAN, O’BRIEN & MORAT, PLLC /s/Teris McGovern Teris McGovern, Esquire Florida Bar No.: 111898 tmegovern@bitman-law.com krahberg@bitman-law.com 255 Primera Blvd., Suite 128 Lake Mary, Florida 32746 Telephone: (407) 815-3110 Facsimile: (407) 815-2635 Attorneys for Defendant