On March 18, 2023 a
was filed
involving a dispute between
Tynes, Christopher Alexander,
and
Door Dash, Inc.,
Errasti, Daymara Cardenas,
for Auto Negligence
in the District Court of Charlotte County.
Preview
Filing # 181388324 E-Filed 09/08/2023 11:08:21 AM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CIVIL ACTION
CHRISTOPHER ALEXANDER TYNES
Plaintifi(s),
vs. CASE NO: 23000625CA
DAYMARA CARDENAS ERRASTI, CASE TYPE: Auto Negligence
DOOR DASH, INC.
Defendant(s).
CASE MANAGEMENT PLAN AND ORDER
(Circuit Civil Cases)
The parties shall comply with the below Case Management Plan:
Case Track Assignment! (check one):
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 Fla. R. Civ. P. 1.201)
Case Deadlines and Events
DEADLINE OR EVENT AGREED DATE
Statement of Facts and/or Counterclaim(s)
Plaintiff(s): 180 days prior to trial
Defendant(s): 150 days prior to trial
Identification of facts the parties believe to be disputed
Plaintiff(s): 90 days prior to trial
Defendant(s) 90 days prior to trial
Identification of the issues of law to be decided by the Court 90 days prior to trial
Motions to Add Parties or to Amend Pleadings 180 days prior to trial
Disclosure of Fact Witnesses
Plaintiff(s): 45 days after date of this order
Defendant(s): 60 days after date of this order
' 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.
Disclosure of Expert Witnesses
Plaintiff(s) 180 days prior to trial
Defendant(s) 150 days prior to trial
Filing of Exhibit List
Plaintiff(s) 90 days prior to trial
Defendant(s): 90 days prior to trial
Discovery Deadline for Fact Witnesses
(All discovery must be commenced in time to be completed before
this date)
Plaintiff(s) 90 days prior to trial
Defendant(s): 90 days prior to trial
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) 120 days prior to trial
Defendant(s) 120 days prior to trial
Discovery Deadline for Expert Witnesses
Plaintiff(s) 30 days prior to trial
Defendant(s) 30 days prior to trial
Completion of Alternative Dispute Resolution (ADR)
(Mediation is mandatory unless the parties agree to another form of Nonbinding Arbitration
ADR. If early ADR is selected and it does not result in settlement MANDATORY if more
or disposition of this entire action, a case management conference than 3 jury trial days
will be scheduled within 45 days from the date of ADR ) requested.
Deadline: A separate Order will be
Type of ADR: issued by the Court.
Deadline for Filing Dispositive Motions
(Court requires filing not later than 10 days prior to the pretrial 60 days prior to trial
conference)
Pretrial Conference Date An Order will be issued by
(Unless early ADR is selected, a pretrial conference date will be the Court scheduling
scheduled within 45 days of the date of ADR not resulting in
settlement or disposition of this entire action.) Initial Pretrial Conference:
60 days prior to trial
Final Pretrial Conference:
1 week prior to trial
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 15 months from date
estimated date on which the case will be prepared to go to trial, of filing complaint
2
the Court may on its own motion set the case for trial) June 2024
Estimated Length of Trial (specify the number of trial days): 4DAYS
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.
ORDER APPROVING CASE MANAGEMENT PLAN
THE COURT having reviewed the preceding Case Management Plan and finding it to be
satisfactory, it is
ORDERED AND ADJUDGED that the Case Management Plan is hereby APPROVED
AND ALL PARTIES SHALL ABIDE BY THE TERMS HEREIN.
DONE AND ORDERED in Punta Gorda, Charlotte County, Florida on 8th day of
1)
September, 2023
Honorable Geoffrey H. Gentile
Circuit Judge
Electronic Service:
Eusebio Gonzalez , ,
Jason Rafael Leonard , ,
Lara Weems Rezapour ,
,
Elizabeth Grindell ,
LARA WEEMS REZAPOUR
JUDICIAL ASSISTANT
CASE MANAGEMENT
Document Filed Date
November 03, 2023
Case Filing Date
March 18, 2023
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Filing # 181388324 E-Filed 09/08/2023 11:08:21 AM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION CHRISTOPHER ALEXANDER TYNES Plaintifi(s), vs. CASE NO: 23000625CA DAYMARA CARDENAS ERRASTI, CASE TYPE: Auto Negligence DOOR DASH, INC. Defendant(s). CASE MANAGEMENT PLAN AND ORDER (Circuit Civil Cases) The parties shall comply with the below Case Management Plan: Case Track Assignment! (check one): 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 Fla. R. Civ. P. 1.201) Case Deadlines and Events DEADLINE OR EVENT AGREED DATE Statement of Facts and/or Counterclaim(s) Plaintiff(s): 180 days prior to trial Defendant(s): 150 days prior to trial Identification of facts the parties believe to be disputed Plaintiff(s): 90 days prior to trial Defendant(s) 90 days prior to trial Identification of the issues of law to be decided by the Court 90 days prior to trial Motions to Add Parties or to Amend Pleadings 180 days prior to trial Disclosure of Fact Witnesses Plaintiff(s): 45 days after date of this order Defendant(s): 60 days after date of this order ' 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. Disclosure of Expert Witnesses Plaintiff(s) 180 days prior to trial Defendant(s) 150 days prior to trial Filing of Exhibit List Plaintiff(s) 90 days prior to trial Defendant(s): 90 days prior to trial Discovery Deadline for Fact Witnesses (All discovery must be commenced in time to be completed before this date) Plaintiff(s) 90 days prior to trial Defendant(s): 90 days prior to trial 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) 120 days prior to trial Defendant(s) 120 days prior to trial Discovery Deadline for Expert Witnesses Plaintiff(s) 30 days prior to trial Defendant(s) 30 days prior to trial Completion of Alternative Dispute Resolution (ADR) (Mediation is mandatory unless the parties agree to another form of Nonbinding Arbitration ADR. If early ADR is selected and it does not result in settlement MANDATORY if more or disposition of this entire action, a case management conference than 3 jury trial days will be scheduled within 45 days from the date of ADR ) requested. Deadline: A separate Order will be Type of ADR: issued by the Court. Deadline for Filing Dispositive Motions (Court requires filing not later than 10 days prior to the pretrial 60 days prior to trial conference) Pretrial Conference Date An Order will be issued by (Unless early ADR is selected, a pretrial conference date will be the Court scheduling scheduled within 45 days of the date of ADR not resulting in settlement or disposition of this entire action.) Initial Pretrial Conference: 60 days prior to trial Final Pretrial Conference: 1 week prior to trial 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 15 months from date estimated date on which the case will be prepared to go to trial, of filing complaint 2 the Court may on its own motion set the case for trial) June 2024 Estimated Length of Trial (specify the number of trial days): 4DAYS 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. ORDER APPROVING CASE MANAGEMENT PLAN THE COURT having reviewed the preceding Case Management Plan and finding it to be satisfactory, it is ORDERED AND ADJUDGED that the Case Management Plan is hereby APPROVED AND ALL PARTIES SHALL ABIDE BY THE TERMS HEREIN. DONE AND ORDERED in Punta Gorda, Charlotte County, Florida on 8th day of 1) September, 2023 Honorable Geoffrey H. Gentile Circuit Judge Electronic Service: Eusebio Gonzalez , , Jason Rafael Leonard , , Lara Weems Rezapour , , Elizabeth Grindell , LARA WEEMS REZAPOUR JUDICIAL ASSISTANT CASE MANAGEMENT