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Filing # 174608540 E-Filed 06/05/2023 02:19:44 PM
IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA.
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ
Plaintiff, CASE NO.: 21000968CA
vs.
MICHAEL G. EDWARDS,
HHS ENVIRONMENTAL SERVICES, LLC and
PORT CHARLOTTE HMA, LLC d/b/a
SHOREPOINT HEALTH PORT CHARLOTTE,
f/k/a BAYFRONT HEALTH PORT CHARLOTTE
Defendants.
/
AGREED CASE MANAGEMENT PLAN AND ORDER
The parties hereby submit to the following Agreed Case Management Plan to the Court for approval:
Case Track Assignment (check one — must be completed for cases filed 05/01/2012 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.)
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.)
Case Deadlines and Events
DEADLINE OR EVENT AGREED DATE
Statement of Facts and/or Counterclaim(s) To be included in Pre
Plaintiffs): Trial Conference order
Defendant(s):
Identification of facts the parties believe to be disputed To be included in Pre
Plaintiff(s): Trial Conference order
Defendant(s):
Identification of the issues of law to be decided by the Court To be included in Pre
Plaintiffs): Trial Conference order
Defendants(s):
Motions to Add Parties or to Amend Pleadings
Plaintiff(s): July 15, 2023
Defendant(s): July 15, 2023
' 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.
CASE NO.: 21000968CA
Disclosure of Fact Witnesses
Plaintiff(s): July 15, 2023
Defendant(s):
July 15, 2023
Disclosure of Expert Witnesses August 1, 2023
Plaintiff(s):
Defendant(s): August 1, 2023
Filing of Exhibit List
Plaintiffs): October 16, 2023
Defendant(s): October 16, 2023
Discovery Deadline for Fact Witnesses
(All discovery must be commenced in time to be completed before this
date.)
Plaintiff(s): September 1, 2023
Defendant(s): September 15, 2023
Expert Opinion Available to Opposing Party
(It is recommended that last exchange occur4 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.) October 16, 2023
Plaintiffs):
October 16, 2023
Defendant(s):
Discovery Deadline for Expert Witnesses
Plaintiffs): September 10, 2023
Defendant(s) September 10, 2023
Completion of Alternative Dispute Resolution (ADR)
(Mediation is mandatory within 12 months of trial date, unless the parties
stipulate to non-binding arbitration.)
Deadline: August 22, 2023
Type of ADR: Mediation
Deadline for Hearing Dispositive Motions
(All dispositive motions must be heard by the Court at least 10 days prior to _X__ Ten days prior to
the pretrial conference unless otherwise ordered by the Court.) pretrial conference/or
Date:
Pretrial Management Conference Date
(Unless early ADR is selected, a pretrial conference date will be scheduled An Order will be issued
within 45 days of the date of ADR not resulting in settlement or disposition by the Court scheduling
of this entire action.) this conference.
Other Deadlines or Events N/A
CASE NO.: 21000968CA
Trial Information
Estimated Date the Case Will Be Prepared To Go To Trial November 20, 2023
(if counsel and unrepresented parties do not agree on the estimated date on — December 15, 2023
which the case will be prepared to go to trial, or fail to file a Notice for Trial
by the date indicated, the Court may on its own motion set the case for trial,
or other status hearing. The filing of this plan does NOT supplant the
requirement of filing a Notice for Trial.)
Estimated Length of Trial (specify the number of trial days): 4-5 Days
Identification of Jury or Non-Jury Trial 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.
Date: I day of June, 2023.
Plaintiff Defendant
Provide in the text boxes below the attorney or self- Provide in the text boxes below the attorney or self-
represented party’s signature, name, address, and represented party’s signature, name, address, telephone and
telephone. Attorneys must include bar number. signature(s). Attorneys must include bar number.
HELEN STRATIGAKOS, ESQ. FRANCESCA IPPOLITO-CRAVEN
412 East Madison Street, Suite 814 KUBICKI DRAPER
Tampa, Florida 33606 9100 South Dadeland Blvd., Suite 1800
(P): (813) 226-0067 Miami, FL 33156
(F): (813) 259-2505 (P): (305) 982-6604
helen@stratigakoslaw.com
admin@stratigakoslaw.com
(F): (305) 374-7846
By: /s/Helen Stratigako: FIC-KD@kubickidraper.com
Florida Bar No.: 0893633 By:_/s/Francesca Ippolito-Craven
Florida Bar Number: 0145361
MICHAEL J. ROSSI, ESQ. JULIE A. CAMPBELL, ESQ.
Michael J. Rossi, P.A. WICKER SMITH O'HARA McCOY & FORD, P.A.
115 South Albany Ave 9132 Strada Pl., Suite 400
Tampa, FL 33606 Naples, FL 34108
(P): (813) 253-3351 (P): (239) 552-5300
(F): (813) 253-3431 (F): (239) 552-5399
Michael@michaelrossilaw.com NAPertpleadings@wickersmith.com
By: /s/ Michael J. Rossi By: /s/ Julie A. Campbell
Florida Bar No.: 0868000 Florida Bar No. 0050134
CASE NO.: 21000968CA
ORDER APPROVING AGREED CASE MANAGEMENT PLAN
THE COURT, having reviewed the above 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.
YD
esigh 'Y H in 21000968CA
10 0505/3025 14 0 FAWt-YN-
Honorable Geoffrey H. Gentile
Circuit Court Judge
Electronic Service List
Brittany Alexandria Perez , ,
David P Carlton ,
Efilemadeeasy Batch Admin
Francesca A. Ippolito-Craven , ,
Helen Stratigakos ,
Michael James Rossi
Helen Stratigakos, Esq. ,
MICHAEL J ROSSI
CASE MANAGEMENT
JUDICIAL ASSISTANT
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Filing # 174608540 E-Filed 06/05/2023 02:19:44 PM IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA. CIRCUIT CIVIL DIVISION BARBARA GONZALEZ Plaintiff, CASE NO.: 21000968CA vs. MICHAEL G. EDWARDS, HHS ENVIRONMENTAL SERVICES, LLC and PORT CHARLOTTE HMA, LLC d/b/a SHOREPOINT HEALTH PORT CHARLOTTE, f/k/a BAYFRONT HEALTH PORT CHARLOTTE Defendants. / AGREED CASE MANAGEMENT PLAN AND ORDER The parties hereby submit to the following Agreed Case Management Plan to the Court for approval: Case Track Assignment (check one — must be completed for cases filed 05/01/2012 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.) 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.) Case Deadlines and Events DEADLINE OR EVENT AGREED DATE Statement of Facts and/or Counterclaim(s) To be included in Pre Plaintiffs): Trial Conference order Defendant(s): Identification of facts the parties believe to be disputed To be included in Pre Plaintiff(s): Trial Conference order Defendant(s): Identification of the issues of law to be decided by the Court To be included in Pre Plaintiffs): Trial Conference order Defendants(s): Motions to Add Parties or to Amend Pleadings Plaintiff(s): July 15, 2023 Defendant(s): July 15, 2023 ' 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. CASE NO.: 21000968CA Disclosure of Fact Witnesses Plaintiff(s): July 15, 2023 Defendant(s): July 15, 2023 Disclosure of Expert Witnesses August 1, 2023 Plaintiff(s): Defendant(s): August 1, 2023 Filing of Exhibit List Plaintiffs): October 16, 2023 Defendant(s): October 16, 2023 Discovery Deadline for Fact Witnesses (All discovery must be commenced in time to be completed before this date.) Plaintiff(s): September 1, 2023 Defendant(s): September 15, 2023 Expert Opinion Available to Opposing Party (It is recommended that last exchange occur4 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.) October 16, 2023 Plaintiffs): October 16, 2023 Defendant(s): Discovery Deadline for Expert Witnesses Plaintiffs): September 10, 2023 Defendant(s) September 10, 2023 Completion of Alternative Dispute Resolution (ADR) (Mediation is mandatory within 12 months of trial date, unless the parties stipulate to non-binding arbitration.) Deadline: August 22, 2023 Type of ADR: Mediation Deadline for Hearing Dispositive Motions (All dispositive motions must be heard by the Court at least 10 days prior to _X__ Ten days prior to the pretrial conference unless otherwise ordered by the Court.) pretrial conference/or Date: Pretrial Management Conference Date (Unless early ADR is selected, a pretrial conference date will be scheduled An Order will be issued within 45 days of the date of ADR not resulting in settlement or disposition by the Court scheduling of this entire action.) this conference. Other Deadlines or Events N/A CASE NO.: 21000968CA Trial Information Estimated Date the Case Will Be Prepared To Go To Trial November 20, 2023 (if counsel and unrepresented parties do not agree on the estimated date on — December 15, 2023 which the case will be prepared to go to trial, or fail to file a Notice for Trial by the date indicated, the Court may on its own motion set the case for trial, or other status hearing. The filing of this plan does NOT supplant the requirement of filing a Notice for Trial.) Estimated Length of Trial (specify the number of trial days): 4-5 Days Identification of Jury or Non-Jury Trial 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. Date: I day of June, 2023. Plaintiff Defendant Provide in the text boxes below the attorney or self- Provide in the text boxes below the attorney or self- represented party’s signature, name, address, and represented party’s signature, name, address, telephone and telephone. Attorneys must include bar number. signature(s). Attorneys must include bar number. HELEN STRATIGAKOS, ESQ. FRANCESCA IPPOLITO-CRAVEN 412 East Madison Street, Suite 814 KUBICKI DRAPER Tampa, Florida 33606 9100 South Dadeland Blvd., Suite 1800 (P): (813) 226-0067 Miami, FL 33156 (F): (813) 259-2505 (P): (305) 982-6604 helen@stratigakoslaw.com admin@stratigakoslaw.com (F): (305) 374-7846 By: /s/Helen Stratigako: FIC-KD@kubickidraper.com Florida Bar No.: 0893633 By:_/s/Francesca Ippolito-Craven Florida Bar Number: 0145361 MICHAEL J. ROSSI, ESQ. JULIE A. CAMPBELL, ESQ. Michael J. Rossi, P.A. WICKER SMITH O'HARA McCOY & FORD, P.A. 115 South Albany Ave 9132 Strada Pl., Suite 400 Tampa, FL 33606 Naples, FL 34108 (P): (813) 253-3351 (P): (239) 552-5300 (F): (813) 253-3431 (F): (239) 552-5399 Michael@michaelrossilaw.com NAPertpleadings@wickersmith.com By: /s/ Michael J. Rossi By: /s/ Julie A. Campbell Florida Bar No.: 0868000 Florida Bar No. 0050134 CASE NO.: 21000968CA ORDER APPROVING AGREED CASE MANAGEMENT PLAN THE COURT, having reviewed the above 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. YD esigh 'Y H in 21000968CA 10 0505/3025 14 0 FAWt-YN- Honorable Geoffrey H. Gentile Circuit Court Judge Electronic Service List Brittany Alexandria Perez , , David P Carlton , Efilemadeeasy Batch Admin Francesca A. Ippolito-Craven , , Helen Stratigakos , Michael James Rossi Helen Stratigakos, Esq. , MICHAEL J ROSSI CASE MANAGEMENT JUDICIAL ASSISTANT