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Filing# 144863354 E-Filed 03/01/2022 07:30:39 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.. CACE21016165 DIVISION: 08 JUDGE: Haimes, David A. (08)
Simson Liberis
UNIFORM TRIAL ORDER
Seventeenth Judicial Circuit
ORDER FOR MANDATORY
CALENDAR CALL
/ Petitioner(s),
Plaintiff(s)
V
Geico General Insurance Company, et al
Defendant(s)/ Respondent (s).
'
UNIFORM TRIAL ORDER
THE UNIFORM TRIAL DATE LISTED HEREIN IS A FIRM TRIAL DATE AND DEADLINES
WILL BE STRICTLY ENFORCED BY THE COURT. STRICT COMPLIANCE MEANS NO
CONTINUANCES OR EXTENSIONS WILL BE GRANTED WITHOUT COURT ORDER UPON
WRITTEN MOTION SETTING FORTH GOOD CAUSE, PURSUANT TO AOSC20-23,
AMENDMENT 13 (May 6,2021), AND FLA. R. GEN. PRAC. & JUD. ADMIN. 2.545(e).
FAILURE TO ATTEND CALENDAR CALL MAY RESULT IN EITHER
THIS CASE BEING DISMISSED OR A DEFAULT BEING ENTERED.
TRIAL PERIOD COMMENCING: 03-07-2023 to 03-24-2023
:' This is a( 3 ) week calendar.
CALENDAR CALL: 02-24-2023 at 9:30 AM
4 DAYS X JURY NON-JURY
1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/01/2022 07:30:38 PM.****
I. ORDER OF TRIALS:
The order oftrials set duringthis Trial Period will be determined at Calendar Call. Parties are
subjectto being called to commence trial during any portionofthe above noted Trial Period.
II. TRIAL DATE:
The Court has determined this case is ready for trial pursuant to Florida Rule of Civil Procedure
1.440. This case is set for trial before the undersigned Judge in Courtroom
16170 or Zoom: https://17thflcourts.zoom.us/i/111475745 ,Broward
County Courthouse, 201 S.E. 6th Street,Fort Lauderdale, Florida,33301, as stated above. The
trial date is a firm trial date pursuant to AOSC20-23, Amendment 13 (May 6, 2021).
III. CIVIL TRIAL POOL:
Parties are advised that this case may be placed into the Seventeenth Judicial Circuit Court's
"Civil Trial Pool" and is subjectto being called for trial before any judge. Ifplacedin the Civil
Trial Pool, parties must be prepared to proceed to trial if called. Only the Division Judge
or the Administrative Judge of the Seventeenth Judicial Circuit Court's Civil Division may
grant a continuance of any case placed in the Civil Trial Pool.
IV. WITNESS LISTS:
A. NO LATER THAN ONE HUNDRED & TWENTY (120) DAYS PRIOR TO
CALENDAR CALL:
Fact Witnesses: Parties must and serve a list of names and addresses of all fact
file
witnesses who are expected to testifyat trial. Each party'
s fact witness list must include a
brief descriptionof the substance and scope of the testimony to be elicited from such
witness. Both sides must cooperate in the schedulingof such witness depositions.
B. NO LATER THAN NINETY (90) DAYS PRIOR TO CALENDAR CALL:
Expert Witnesses:
i. At the time of disclosure of all expert witnesses,the partiesshall file and serve
the names and addresses of all expert witnesses to be called at trial,including
their complete and updated curriculum vitae,and all information regarding
expert testimony that is requiredby Fla. R. Civ. P. 1.28(b)(5). Parties shall
furnish opposing counsel with two (2) alternative dates of availability of all
expert witnesses for the purpose of taking their Both
deposition. partiesshall
cooperate in the schedulingof expert depositions.
ii. The partiesshall also provide answers to standard form expert interrogatories
pursuant to Fla.R.Civ.P. 1.280(b)(5).All reports or other data compiled by each
disclosed expert which is intended to be used by the expert and/or referred to
during his/her deposition testimony shall be provided electronically to the
opposing party at least 72 hours priorto the date of the scheduled deposition.
C. NO LATER THAN SIXTY (60) DAYS PRIOR TO CALENDAR CALL:
Rebuttal Witnesses: Parties must file and serve a list ofnames and addresses of any rebuttal
witnesses within sixty(60)days.
V. COMPULSORY MEDICAL EVALUATIONS (' CME"): ."
A. NO LATER THAN NINETY (90) DAYS PRIOR TO CALENDAR CALL:
All CME and other examinations pursuant to Florida Rule of Civil Procedure 1.360 must
be completed no later than ninety(90) days priorto Calendar Call.
2
VI. DISCOVERY DEADLINES:
A. NO LATER THAN SIXTY-FIVE (65) DAYS PRIOR TO CALENDAR CALL:
All final discoverymust have been initiated at least sixty-five
(65) days priorto Calendar
Call.
B. NO LATER THAN THIRTY (30) DAYS PRIOR TO CALENDAR CALL:
Partiesmust complete all discovery,includingexpert discoveryin accordance with Florida
Rule of Civil Procedure 1.280(b)(5), (30)days priorto Calendar Call.
at least thirty
Discovery conducted after this time period is stronglydisfavored and will only be permitted
by order of the Court under exceptionalcircumstances.
C. ELECTRONICALLY STORED INFORMATION (ESI) DISCOVERY: ESI
discoveryproceduresare governed by Seventeenth Judicial Circuit Administrative Order
2021-20-Gen, a copy of which is available on the Circuit's webpage
(www. 17th.flcourts.org).
VII. MOTIONS:
A. NO LATER THAN SEVENTY-FIVE (75) DAYS PRIOR TO CALENDAR CALL:
1. Motions to add a party or partiesor to amend pleadingsshall be filed and set for hearing
no than seventy-five(75) days before Calendar Call absent good cause shown. The
later
deadline shall not conflict with Florida Rule of Civil Procedure 1.190(e),and the motion
may be denied if there has been undue delay,bad faith,prejudiceto the opposing side,
dilatorymotive on the part of the moving party or when the amendment would be futile.
B. NO LATER THAN FORTY-FIVE (45)DAYS PRIOR TO CALENDAR CALL:
1. DispositiveMotions: must be filed and heard no later than forty-five
(45) days before
Calendar Call.
2. Deposition Objections:objectionsraised in depositionsexpected to be introduced at
trial must be filed and heard no later than forty-five
(45)days before Calendar Call.
..
3. Expert Challenges: motions an
challenging expert witness ("ExpertChallenges"), must
be filed and heard no later (45)days before Calendar Call.
than forty-five
C. NO LATER THAN THIRTY (30) DAYS PRIOR TO CALENDAR CALL:
1. Motions in Limine: must be filed and heard no later than thirty(30) days prior to
Calendar Call.
2. All motions, other than motions in limine, not heard before Calendar Call will be
deerned abandoned.
D. PRIOR TO CALENDAR CALL:
1. Motions for Summary Judgment: must be filed and heard prior to Calendar Call.
Motions for summary judgment will not be heard at Calendar Call.
VIII. JOINT PRETRIAL STIPULATION:
A. NO LATER THAN TEN (10) DAYS PRIOR TO CALENDAR CALL:
1. The contemplates a singledocument that
Joint Pretrial Stipulation must be filed and
served, with a courtesy copy served on the undersigned judge, no later than ten (10)
days priorto Calendar Call.
2. The Joint Pretrial Stipulation
requiresthat agreed matters be fullyidentified and any
all
delineated with respect to each party.
disputedmatters be specifically
3
3. At partiesmust be preparedto discuss
the time of the above noticed Calendar Call, all
all items set forth in Florida Rule of Civil Procedure 1.200(b).
B. The Joint Pretrial Stipulationmust contain the following in separately numbered
paragraphs:
1. Statement of the Facts: A concise, impartialstatement of the facts of the case.
2. Stipulated Facts: A list ofthose facts that can be stipulatedand requireno proof at trial.
3. Statement of Disputed Law & Fact: A concise, impartialstatement of those issues of
law and fact that are to be tried.
4. Exhibit Lists: Each party must separatelylist all exhibits they intend to introduce into
evidence. Each item must be listed by number and description on a separate schedule
attached to the Joint Pretrial Stipulation. Each exhibit must be specifically described.
Generic descriptionsof exhibits are subject to being stricken. If any party objects
to the introduction of any such exhibit,such objectionmust be stated in the Joint
Pretrial Stipulation,settingforth the grounds with specificity. All exhibits must have
been made available to all partiesfor examination. Parties must initial each other's
exhibit lists and exhibits. At trial,only those exhibits properly listed and initialed
may be offered into evidence.
5. Demonstrative Exhibits: all demonstrative exhibits (e.g., charts,graphs,enlargements
of exhibits,etc.)intended to be used at a jury trial must be displayedto all partiesat
least ten (10) days before trial.
6. Witness must furnish a written list containingthe names and addresses of
Lists: Parties
order. Such list must designate
all witnesses intended to be called at trial in alphabetical
the type of witness ("expert," "rebuttal,""impeachment," or otherwise)and must be
attached to the Joint Pretrial Stipulation.All fact witness lists must include a brief
descriptionof the substance and scope of the testimony to be elicited from such
witness. All expert witness lists must designate the expert's specialties.If any party
objectsto any witness, such objectionmust be stated in the Joint Pretrial Stipulation,
setting forth the grounds with specificity. At trial,only those witnesses properly and
timely disclosed will be permitted to testify.
7. Jury Instructions: If the trial is a jury trial,the partiesmust identifyall agreed upon
standard instructions and all special instructions. Copies of all agreed upon jury
instructions and disputedjury instructions must be attached to the Joint Pretrial
Stipulationidentifyingthe party that proposed the instruction,along with copies of
supportingstatutory citations and/or case law.
8. the jury verdict form must be designatedas
Verdict Forms: If the trial is a jury trial,
"agreed to" or "disputed" and must be attached to the Joint Pretrial Stipulation.
9. the number ofperemptory challenges
Peremptory Challenges:If the trial is a jury trial,
for each party must be stated and attached to the Joint Pretrial Stipulation.
10. Pending Motions: Parties must set forth a list of all pending motions with copies
attached to the Joint Pretrial Stipulation.
11. Trial Estimate: Each party must provide an estimate ofthe number oftrial days required
for presentingits side of the case.
12. Expert Challenges:All expert related issues involving any requests for hearings on
must be noticed and heard-or agreed to by the parties-no later than
related evidence
forty-five(45) days prior to Calendar Call. FAILURE TO DO SO MAY
4
CONSTITUTE A WAIVER OF ANY EXPERT RELATED EVIDENCE ISSUE(S).
It is within the discretion ofthe Court to remove any case with pending expert issues.
IX. COURT POLICIES:
A. Parties must do all thingsreasonable and necessary to assure the
availability of witnesses
for the entire Trial Period or to otherwise preserve witness testimony for trial as provided
by the Florida Rules of Civil Procedure. See Fla. R. Civ. P. 1.300 & 1.460; see also Fla.
R. Gen. Prac. & Jud. Admin. 2.545.
B. The requirementsof this Uniform Trial Order cannot be waived by stipulation absent prior
approval from the Court pursuant to written agreement between the parties.
C. This Uniform Trial Order may be tailored by the assigned Division Judge to conform to
the particularrequirementsof the residential foreclosure and complex litigationdivisions.
D. At trial,there will only be one (1) official record transcribed by one (1) court reporter.
Plaintiff isresponsiblefor arranging for a court reporter unless otherwise agreed. If a
conflict exists,the partiesmust resolve it among themselves priorto Calendar Call.
X. CONTINUANCES:
No continuances will be granted without Court Order upon written motion settingforth
good cause pursuant to AOSC20-23, Amendment 13 (May 6, 2021), and Fla. R. Gen.
Prac. &Jud. Admin. 2.545(e). All motions seeking a continuance must comply with Fla.
R. Civ. P. 1.460 and Fla. R. Gen. Prac. & Jud. Adm. 2.545. Continuances requested for
reasons relatingto failure to follow this Order will not be granted.
A. CONTINUANCES will only be considered upon written motion filed with the Clerk
of Court and served on the undersignedjudge priorto the above noticed Calendar Call.
B. NO CONTINUANCES will be granted for reasons that should have been readily
apparent to the partieswhen this Uniform Trial Order was issued.
C. NO CONTINUANCES will be granted if expert witnesses are unavailable because
testimonymay be preservedby deposition.
D. NO CONTINUANCES will be grantedfor reasons relating
to the failure to follow this
Uniform Trial Order.
XI. MANDATORY MEDIATION:
Mediation must commence no later than sixty(60) days priorto Calendar Call. The parties
must comply with Florida Rules of Civil Procedure 1.700, 1.710, 1.720, and 1.730 as to the
conduct o f mediation. Plaintiff's counsel is appointed lead counsel to facilitate and schedule
the settlement conference with the mediator and all parties.The Court appoints:
WHOMEVER THE PARTIES AGREE UPON
as Mediator, unless,within thirty(30) days of this Uniform Trial Order, the partieschoose a
different Mediator, and file notice of that choice and the name of the substitute mediator with the
Clerk of Court. Failure to attend mediation may result in sanctions.
XII. SANCTIONS:
A. All partiesshould be familiar with Florida Rule of Civil Procedure 1.380 entitled "Failure
to Make Discovery; Sanctions" and section 57.105, Florida Statutes,entitled "Attorney's
5
fee; sanctions for raisingunsupported claims or defenses; exceptions;service of motions;
..
damages for delay of litigation.
B. FAILURE TO APPEAR, FAILURE TO FOLLOW TIME REQUIREMENTS, OR
FAILURE TO FILE DOCUMENTS REQUIRED BY THIS COURT MAY RESULT IN
THE DISMISSAL OF THE ACTION OR THE IMPOSITION OF SANCTIONS
INCLUDING THE STRIKING OF PLEADINGS.
XIII. SETTLEMENT NOTIFICATION:
Parties must immediately notifythe Court in the event of settlement and submit a stipulation
for an Order of Dismissal. Parties shall also cancel any and all pending hearingsas a result of
the settlement.
Pursuant to Florida Rule of General Practice and Judicial Administration 2.516(h)(1),
counsel must file this Uniform Trial Order with the Clerk of Court, serve any self-
represented parties with this Uniform Trial Order, and file a "Certificate of Service" with
the Clerk of Court, in compliance with Florida Rule of General Practice and Judicial
Administration 2.516(f),certifyingthe self-represented party was served with this Uniform
Trial Order.
DONE AND ORDERED in Chambers at Fort Lauderdale, Broward County, Florida on
03-01-2022 -- -=-N-F- -
CN*Setme?pesaa?tyze?=---,--
CACE21016165 03-01-2022 8:43 AM
Circuit Court Judge
who needs any accommodation in order to
person with a disability
If you are a
participatein this proceeding, you are entitled, at no cost to you, to the
provision of certain assistance. Please contact the ADA Coordinator, Room
20140, 201 S.E. Sixth Street,Fort Lauderdale, Florida 33301, 954-831-7721 at
least7 days before your scheduled court appearance, or immediately upon
receivingthis notification if the time before the scheduled appearance is less
you can contact the court
than 7 days. If you have a hearing or voice disability
through the Florida Relay Service by calling711.
6
Cassandra Rae Daum, Emai gcarreras@sgrlaw.corn
CC
:
Cassandra Rae Daum, Emai cdaum@sgrlaw.corn :
Cassandra Rae Daum, Emai jdebons@sgrlaw.corn :
Dion K Bass, Emai jdebons@sgrlaw.corn
:
Dion K Bass, Emai :
Dion K Bass, Emai dbass@sgrlaw.corn
:
Gregg A. Si verstein, Emai gfresco@ssspa-law.corn
:
Gregg A. Si verstein, Emai gsilverstein@ssspa-law.corn
:
Gregg A. Si verstein, Emai pgayle@ssspa-law.corn
:
Ivan A Schertzer, Email :
crsmittie@yahoo.com
Ivan A Schertzer, Email :
Jennifer Pruden Lawson, Emai dhsmith@sgrlaw.corn :
Jennifer Pruden Lawson, Emai asalane@sgrlaw.corn :
Jennifer Pruden Lawson, Emai jlawson@sgrlaw.corn :
Jessica Jean Williams, Email -williams@sgrlaw.corn :
Jessica Jean Williams, Email asalane@sgrlaw.corn :
Ji F Bechto d, Emai jdebons@sgrlaw.com
:
Ji F Bechto d, Emai :
Ji F Bechto d, Emai :
Jonathon D Press ey, Emai dhsmith@sgrlaw.corn :
Jonathon D Press ey, Emai jpressley@sgrlaw.corn :
Jonathon D Press ey, Emai asalane@sgrlaw.corn :
Joshua M. Goste, Emai jgostel@sgrlaw.corn :
Joshua M. Goste, Emai jdebons@sgrlaw.corn :
Joshua M. Goste, Emai :
Luke T Moreau, Emai catherine@Iukemoreaulaw.com
:
Luke T Moreau, Emai kiara@lukemoreaulaw.corn
:
Luke T Moreau, Emai : luke@Iukemoreaulaw.com
Steven Brust, Emai dhsmith@sgrlaw.corn
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Steven Brust, Emai asalane@sgrlaw.corn
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Filing# 144863354 E-Filed 03/01/2022 07:30:39 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.. CACE21016165 DIVISION: 08 JUDGE: Haimes, David A. (08) Simson Liberis UNIFORM TRIAL ORDER Seventeenth Judicial Circuit ORDER FOR MANDATORY CALENDAR CALL / Petitioner(s), Plaintiff(s) V Geico General Insurance Company, et al Defendant(s)/ Respondent (s). ' UNIFORM TRIAL ORDER THE UNIFORM TRIAL DATE LISTED HEREIN IS A FIRM TRIAL DATE AND DEADLINES WILL BE STRICTLY ENFORCED BY THE COURT. STRICT COMPLIANCE MEANS NO CONTINUANCES OR EXTENSIONS WILL BE GRANTED WITHOUT COURT ORDER UPON WRITTEN MOTION SETTING FORTH GOOD CAUSE, PURSUANT TO AOSC20-23, AMENDMENT 13 (May 6,2021), AND FLA. R. GEN. PRAC. & JUD. ADMIN. 2.545(e). FAILURE TO ATTEND CALENDAR CALL MAY RESULT IN EITHER THIS CASE BEING DISMISSED OR A DEFAULT BEING ENTERED. TRIAL PERIOD COMMENCING: 03-07-2023 to 03-24-2023 :' This is a( 3 ) week calendar. CALENDAR CALL: 02-24-2023 at 9:30 AM 4 DAYS X JURY NON-JURY 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/01/2022 07:30:38 PM.**** I. ORDER OF TRIALS: The order oftrials set duringthis Trial Period will be determined at Calendar Call. Parties are subjectto being called to commence trial during any portionofthe above noted Trial Period. II. TRIAL DATE: The Court has determined this case is ready for trial pursuant to Florida Rule of Civil Procedure 1.440. This case is set for trial before the undersigned Judge in Courtroom 16170 or Zoom: https://17thflcourts.zoom.us/i/111475745 ,Broward County Courthouse, 201 S.E. 6th Street,Fort Lauderdale, Florida,33301, as stated above. The trial date is a firm trial date pursuant to AOSC20-23, Amendment 13 (May 6, 2021). III. CIVIL TRIAL POOL: Parties are advised that this case may be placed into the Seventeenth Judicial Circuit Court's "Civil Trial Pool" and is subjectto being called for trial before any judge. Ifplacedin the Civil Trial Pool, parties must be prepared to proceed to trial if called. Only the Division Judge or the Administrative Judge of the Seventeenth Judicial Circuit Court's Civil Division may grant a continuance of any case placed in the Civil Trial Pool. IV. WITNESS LISTS: A. NO LATER THAN ONE HUNDRED & TWENTY (120) DAYS PRIOR TO CALENDAR CALL: Fact Witnesses: Parties must and serve a list of names and addresses of all fact file witnesses who are expected to testifyat trial. Each party' s fact witness list must include a brief descriptionof the substance and scope of the testimony to be elicited from such witness. Both sides must cooperate in the schedulingof such witness depositions. B. NO LATER THAN NINETY (90) DAYS PRIOR TO CALENDAR CALL: Expert Witnesses: i. At the time of disclosure of all expert witnesses,the partiesshall file and serve the names and addresses of all expert witnesses to be called at trial,including their complete and updated curriculum vitae,and all information regarding expert testimony that is requiredby Fla. R. Civ. P. 1.28(b)(5). Parties shall furnish opposing counsel with two (2) alternative dates of availability of all expert witnesses for the purpose of taking their Both deposition. partiesshall cooperate in the schedulingof expert depositions. ii. The partiesshall also provide answers to standard form expert interrogatories pursuant to Fla.R.Civ.P. 1.280(b)(5).All reports or other data compiled by each disclosed expert which is intended to be used by the expert and/or referred to during his/her deposition testimony shall be provided electronically to the opposing party at least 72 hours priorto the date of the scheduled deposition. C. NO LATER THAN SIXTY (60) DAYS PRIOR TO CALENDAR CALL: Rebuttal Witnesses: Parties must file and serve a list ofnames and addresses of any rebuttal witnesses within sixty(60)days. V. COMPULSORY MEDICAL EVALUATIONS (' CME"): ." A. NO LATER THAN NINETY (90) DAYS PRIOR TO CALENDAR CALL: All CME and other examinations pursuant to Florida Rule of Civil Procedure 1.360 must be completed no later than ninety(90) days priorto Calendar Call. 2 VI. DISCOVERY DEADLINES: A. NO LATER THAN SIXTY-FIVE (65) DAYS PRIOR TO CALENDAR CALL: All final discoverymust have been initiated at least sixty-five (65) days priorto Calendar Call. B. NO LATER THAN THIRTY (30) DAYS PRIOR TO CALENDAR CALL: Partiesmust complete all discovery,includingexpert discoveryin accordance with Florida Rule of Civil Procedure 1.280(b)(5), (30)days priorto Calendar Call. at least thirty Discovery conducted after this time period is stronglydisfavored and will only be permitted by order of the Court under exceptionalcircumstances. C. ELECTRONICALLY STORED INFORMATION (ESI) DISCOVERY: ESI discoveryproceduresare governed by Seventeenth Judicial Circuit Administrative Order 2021-20-Gen, a copy of which is available on the Circuit's webpage (www. 17th.flcourts.org). VII. MOTIONS: A. NO LATER THAN SEVENTY-FIVE (75) DAYS PRIOR TO CALENDAR CALL: 1. Motions to add a party or partiesor to amend pleadingsshall be filed and set for hearing no than seventy-five(75) days before Calendar Call absent good cause shown. The later deadline shall not conflict with Florida Rule of Civil Procedure 1.190(e),and the motion may be denied if there has been undue delay,bad faith,prejudiceto the opposing side, dilatorymotive on the part of the moving party or when the amendment would be futile. B. NO LATER THAN FORTY-FIVE (45)DAYS PRIOR TO CALENDAR CALL: 1. DispositiveMotions: must be filed and heard no later than forty-five (45) days before Calendar Call. 2. Deposition Objections:objectionsraised in depositionsexpected to be introduced at trial must be filed and heard no later than forty-five (45)days before Calendar Call. .. 3. Expert Challenges: motions an challenging expert witness ("ExpertChallenges"), must be filed and heard no later (45)days before Calendar Call. than forty-five C. NO LATER THAN THIRTY (30) DAYS PRIOR TO CALENDAR CALL: 1. Motions in Limine: must be filed and heard no later than thirty(30) days prior to Calendar Call. 2. All motions, other than motions in limine, not heard before Calendar Call will be deerned abandoned. D. PRIOR TO CALENDAR CALL: 1. Motions for Summary Judgment: must be filed and heard prior to Calendar Call. Motions for summary judgment will not be heard at Calendar Call. VIII. JOINT PRETRIAL STIPULATION: A. NO LATER THAN TEN (10) DAYS PRIOR TO CALENDAR CALL: 1. The contemplates a singledocument that Joint Pretrial Stipulation must be filed and served, with a courtesy copy served on the undersigned judge, no later than ten (10) days priorto Calendar Call. 2. The Joint Pretrial Stipulation requiresthat agreed matters be fullyidentified and any all delineated with respect to each party. disputedmatters be specifically 3 3. At partiesmust be preparedto discuss the time of the above noticed Calendar Call, all all items set forth in Florida Rule of Civil Procedure 1.200(b). B. The Joint Pretrial Stipulationmust contain the following in separately numbered paragraphs: 1. Statement of the Facts: A concise, impartialstatement of the facts of the case. 2. Stipulated Facts: A list ofthose facts that can be stipulatedand requireno proof at trial. 3. Statement of Disputed Law & Fact: A concise, impartialstatement of those issues of law and fact that are to be tried. 4. Exhibit Lists: Each party must separatelylist all exhibits they intend to introduce into evidence. Each item must be listed by number and description on a separate schedule attached to the Joint Pretrial Stipulation. Each exhibit must be specifically described. Generic descriptionsof exhibits are subject to being stricken. If any party objects to the introduction of any such exhibit,such objectionmust be stated in the Joint Pretrial Stipulation,settingforth the grounds with specificity. All exhibits must have been made available to all partiesfor examination. Parties must initial each other's exhibit lists and exhibits. At trial,only those exhibits properly listed and initialed may be offered into evidence. 5. Demonstrative Exhibits: all demonstrative exhibits (e.g., charts,graphs,enlargements of exhibits,etc.)intended to be used at a jury trial must be displayedto all partiesat least ten (10) days before trial. 6. Witness must furnish a written list containingthe names and addresses of Lists: Parties order. Such list must designate all witnesses intended to be called at trial in alphabetical the type of witness ("expert," "rebuttal,""impeachment," or otherwise)and must be attached to the Joint Pretrial Stipulation.All fact witness lists must include a brief descriptionof the substance and scope of the testimony to be elicited from such witness. All expert witness lists must designate the expert's specialties.If any party objectsto any witness, such objectionmust be stated in the Joint Pretrial Stipulation, setting forth the grounds with specificity. At trial,only those witnesses properly and timely disclosed will be permitted to testify. 7. Jury Instructions: If the trial is a jury trial,the partiesmust identifyall agreed upon standard instructions and all special instructions. Copies of all agreed upon jury instructions and disputedjury instructions must be attached to the Joint Pretrial Stipulationidentifyingthe party that proposed the instruction,along with copies of supportingstatutory citations and/or case law. 8. the jury verdict form must be designatedas Verdict Forms: If the trial is a jury trial, "agreed to" or "disputed" and must be attached to the Joint Pretrial Stipulation. 9. the number ofperemptory challenges Peremptory Challenges:If the trial is a jury trial, for each party must be stated and attached to the Joint Pretrial Stipulation. 10. Pending Motions: Parties must set forth a list of all pending motions with copies attached to the Joint Pretrial Stipulation. 11. Trial Estimate: Each party must provide an estimate ofthe number oftrial days required for presentingits side of the case. 12. Expert Challenges:All expert related issues involving any requests for hearings on must be noticed and heard-or agreed to by the parties-no later than related evidence forty-five(45) days prior to Calendar Call. FAILURE TO DO SO MAY 4 CONSTITUTE A WAIVER OF ANY EXPERT RELATED EVIDENCE ISSUE(S). It is within the discretion ofthe Court to remove any case with pending expert issues. IX. COURT POLICIES: A. Parties must do all thingsreasonable and necessary to assure the availability of witnesses for the entire Trial Period or to otherwise preserve witness testimony for trial as provided by the Florida Rules of Civil Procedure. See Fla. R. Civ. P. 1.300 & 1.460; see also Fla. R. Gen. Prac. & Jud. Admin. 2.545. B. The requirementsof this Uniform Trial Order cannot be waived by stipulation absent prior approval from the Court pursuant to written agreement between the parties. C. This Uniform Trial Order may be tailored by the assigned Division Judge to conform to the particularrequirementsof the residential foreclosure and complex litigationdivisions. D. At trial,there will only be one (1) official record transcribed by one (1) court reporter. Plaintiff isresponsiblefor arranging for a court reporter unless otherwise agreed. If a conflict exists,the partiesmust resolve it among themselves priorto Calendar Call. X. CONTINUANCES: No continuances will be granted without Court Order upon written motion settingforth good cause pursuant to AOSC20-23, Amendment 13 (May 6, 2021), and Fla. R. Gen. Prac. &Jud. Admin. 2.545(e). All motions seeking a continuance must comply with Fla. R. Civ. P. 1.460 and Fla. R. Gen. Prac. & Jud. Adm. 2.545. Continuances requested for reasons relatingto failure to follow this Order will not be granted. A. CONTINUANCES will only be considered upon written motion filed with the Clerk of Court and served on the undersignedjudge priorto the above noticed Calendar Call. B. NO CONTINUANCES will be granted for reasons that should have been readily apparent to the partieswhen this Uniform Trial Order was issued. C. NO CONTINUANCES will be granted if expert witnesses are unavailable because testimonymay be preservedby deposition. D. NO CONTINUANCES will be grantedfor reasons relating to the failure to follow this Uniform Trial Order. XI. MANDATORY MEDIATION: Mediation must commence no later than sixty(60) days priorto Calendar Call. The parties must comply with Florida Rules of Civil Procedure 1.700, 1.710, 1.720, and 1.730 as to the conduct o f mediation. Plaintiff's counsel is appointed lead counsel to facilitate and schedule the settlement conference with the mediator and all parties.The Court appoints: WHOMEVER THE PARTIES AGREE UPON as Mediator, unless,within thirty(30) days of this Uniform Trial Order, the partieschoose a different Mediator, and file notice of that choice and the name of the substitute mediator with the Clerk of Court. Failure to attend mediation may result in sanctions. XII. SANCTIONS: A. All partiesshould be familiar with Florida Rule of Civil Procedure 1.380 entitled "Failure to Make Discovery; Sanctions" and section 57.105, Florida Statutes,entitled "Attorney's 5 fee; sanctions for raisingunsupported claims or defenses; exceptions;service of motions; .. damages for delay of litigation. B. FAILURE TO APPEAR, FAILURE TO FOLLOW TIME REQUIREMENTS, OR FAILURE TO FILE DOCUMENTS REQUIRED BY THIS COURT MAY RESULT IN THE DISMISSAL OF THE ACTION OR THE IMPOSITION OF SANCTIONS INCLUDING THE STRIKING OF PLEADINGS. XIII. SETTLEMENT NOTIFICATION: Parties must immediately notifythe Court in the event of settlement and submit a stipulation for an Order of Dismissal. Parties shall also cancel any and all pending hearingsas a result of the settlement. Pursuant to Florida Rule of General Practice and Judicial Administration 2.516(h)(1), counsel must file this Uniform Trial Order with the Clerk of Court, serve any self- represented parties with this Uniform Trial Order, and file a "Certificate of Service" with the Clerk of Court, in compliance with Florida Rule of General Practice and Judicial Administration 2.516(f),certifyingthe self-represented party was served with this Uniform Trial Order. DONE AND ORDERED in Chambers at Fort Lauderdale, Broward County, Florida on 03-01-2022 -- -=-N-F- - CN*Setme?pesaa?tyze?=---,-- CACE21016165 03-01-2022 8:43 AM Circuit Court Judge who needs any accommodation in order to person with a disability If you are a participatein this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator, Room 20140, 201 S.E. Sixth Street,Fort Lauderdale, Florida 33301, 954-831-7721 at least7 days before your scheduled court appearance, or immediately upon receivingthis notification if the time before the scheduled appearance is less you can contact the court than 7 days. If you have a hearing or voice disability through the Florida Relay Service by calling711. 6 Cassandra Rae Daum, Emai gcarreras@sgrlaw.corn CC : Cassandra Rae Daum, Emai cdaum@sgrlaw.corn : Cassandra Rae Daum, Emai jdebons@sgrlaw.corn : Dion K Bass, Emai jdebons@sgrlaw.corn : Dion K Bass, Emai : Dion K Bass, Emai dbass@sgrlaw.corn : Gregg A. Si verstein, Emai gfresco@ssspa-law.corn : Gregg A. Si verstein, Emai gsilverstein@ssspa-law.corn : Gregg A. Si verstein, Emai pgayle@ssspa-law.corn : Ivan A Schertzer, Email : crsmittie@yahoo.com Ivan A Schertzer, Email : Jennifer Pruden Lawson, Emai dhsmith@sgrlaw.corn : Jennifer Pruden Lawson, Emai asalane@sgrlaw.corn : Jennifer Pruden Lawson, Emai jlawson@sgrlaw.corn : Jessica Jean Williams, Email -williams@sgrlaw.corn : Jessica Jean Williams, Email asalane@sgrlaw.corn : Ji F Bechto d, Emai jdebons@sgrlaw.com : Ji F Bechto d, Emai : Ji F Bechto d, Emai : Jonathon D Press ey, Emai dhsmith@sgrlaw.corn : Jonathon D Press ey, Emai jpressley@sgrlaw.corn : Jonathon D Press ey, Emai asalane@sgrlaw.corn : Joshua M. Goste, Emai jgostel@sgrlaw.corn : Joshua M. Goste, Emai jdebons@sgrlaw.corn : Joshua M. Goste, Emai : Luke T Moreau, Emai catherine@Iukemoreaulaw.com : Luke T Moreau, Emai kiara@lukemoreaulaw.corn : Luke T Moreau, Emai : luke@Iukemoreaulaw.com Steven Brust, Emai dhsmith@sgrlaw.corn : Steven Brust, Emai asalane@sgrlaw.corn : Steven Brust, Emai sebrust@sgrlaw.corn :