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  • THE KIDWELL GROUP LLC -VS- TYPTAP INSURANCE COMPANY19P - PERSONAL INJURY PROTECTION document preview
  • THE KIDWELL GROUP LLC -VS- TYPTAP INSURANCE COMPANY19P - PERSONAL INJURY PROTECTION document preview
  • THE KIDWELL GROUP LLC -VS- TYPTAP INSURANCE COMPANY19P - PERSONAL INJURY PROTECTION document preview
  • THE KIDWELL GROUP LLC -VS- TYPTAP INSURANCE COMPANY19P - PERSONAL INJURY PROTECTION document preview
  • THE KIDWELL GROUP LLC -VS- TYPTAP INSURANCE COMPANY19P - PERSONAL INJURY PROTECTION document preview
  • THE KIDWELL GROUP LLC -VS- TYPTAP INSURANCE COMPANY19P - PERSONAL INJURY PROTECTION document preview
  • THE KIDWELL GROUP LLC -VS- TYPTAP INSURANCE COMPANY19P - PERSONAL INJURY PROTECTION document preview
  • THE KIDWELL GROUP LLC -VS- TYPTAP INSURANCE COMPANY19P - PERSONAL INJURY PROTECTION document preview
						
                                

Preview

IN THE COUNTY COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR SEMINOLE COUNTY FLORIDA CASE NO: 2024SC001916 THE KIDWELL GROUP LLC d/b/a AIR QUALITY ASSESSORS OF FLORIDA a/a/o Lourdes Reyes, Plaintiff, L TYPTAP INSURANCE COMPANY, IA Defendant. C CASE MANAGEMENT PLAN I (STREAMLINED) F The parties are to meet, review, and discuss the Case Management Plan to agree upon dates according to the guidelines set forth in the above Case Management Plan. The F parties are to sign the certification below and submit the proposed Case Management Order with the agreed upon dates to the Court for approval and signature. NO 1. Date of First Response (i.e., Answer, Notice of appearance, Motion for Extension 20 days after the Court’s Pre-Trial Conference U of Time, Motion to Dismiss) 2. Deadline for adding new parties, amendment of pleadings 45 days since response date 3. Deadline for Witness & Exhibit List 45 days before Trial (Witnesses MUST be listed by actual NAME of the witness, and not by designation (i.e., use of such designations as “Corporate Representative,” “Records Custodian,” “Adjustor,” or “IME Doctor” standing alone is insufficient) Deadline for Expert Disclosure 120 days prior to projected trial date for Plaintiff (Parties should furnish opposing counsel 90 days prior to projected trial date for with the names and addresses of all expert witnesses Defendant under Rule 1.390(a) to be called at trial and all L information IA regarding expert testimony that is required Rule 1.280(b)(5). Each party is limited to one C expert per specialty. No other expert I testimony should be permitted at trial. F Information furnished pursuant to this paragraph should be timely filed with the F Clerk of the Court.) 5. Objections to pleadings prior to projected trial date NO Deadline for Discovery Completion (including Depositions) prior to projected trial date U 7. Deadline for Dispositive Motions, including Daubert Motions-Failure to do so shall constitute a waiver at Trial of any prior to projected trial date Daubert related evidence objection or issue Responsibility for scheduling of the Hearing shall be upon the party filing the Motion or Objection. 8. Deadline for Mediation: days prior projected trial date 9. Trial Date The trial is projected to take 8 hours. 480 days after the first response CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 4, 2024, I electronically filed the foregoing with the Clerk of Court by using the ECF system, which will send a notice to all counsel of record. /s/ William S England L William S England, Esquire Fla. Bar No.: 0098941 IA Chad Barr Law, P.A. 238 N. Westmonte Dr., Suite 200 Altamonte Springs, Florida 32714 I C ORDER APPROVING CASE MANAGEMENT PLAN ORDERED that the preceding F deadlines apply to this action and that the same will be strictly applied and enforced by the F Court: 1. COMPLIANCE WITH THIS CASE MANAGEMENT ORDER: The parties shall O strictly comply with the terms of this Case Management Plan and Order unless otherwise ordered by the Court. FAILURE TO COMPLY WITH ALL THE N REQUIREMENTS OF THIS ORDER MAY RESULT IN THE IMPOSITION OF SANCTIONS. U ADDITIONAL EIGHTEENTH CIRCUIT AND DIVISION SPECIFIC GUIDELINES: All counsel and unrepresented parties shall familiarize themselves and comply with the requirements of the following: (i) Amended Administrative Order Establishing the Eighteenth Judicial Circuit Courtroom Decorum Policy (AO 09-06); and (ii) any division-specific guidelines and policies that may be applicable. MODIFICATION OF THIS ORDER: The parties may not, individually or by agreement, alter, extend, or waive the deadlines in this Order. The provisions in this Order may only be modified upon motion/stipulation and Court order approving the modification. NOTICES/MOTIONS FOR TRIAL: Parties may file a Notice for Trial if they are ready for trial more than 120 days before the above-projected trial date. The Plaintiff shall confer with opposing counsel/party regarding the anticipated length of the trial and file a Motion or Notice for Trial. The Plaintiff shall forward a copy of the Motion or Notice for Trial to the Case Manager at the email address noted on the Eighteenth Judicial Circuit website. DISCOVERY: All counsel and unrepresented parties shall familiarize themselves with the current edition of the Florida Handbook on Civil Discovery Practice and seek to resolve discovery issues without court intervention whenever possible. SERVICE OF THIS ORDER: Counsel is ordered to promptly serve and file proof with the Clerk, no more than five (5) business days from the date of this Order that all pro se parties, subsequently named or appearing herein, have been served copies of this Order. In the event a party is unrepresented and has not designated an email address for purposes of electronic service, counsel for Plaintiff shall be responsible for serving this Order and all future orders of the Court via a non-electronic means L (U.S. mail, Federal Express or the equivalent) and shall file a Certificate of Service with the Court indicating who was served, the date of service, and the method of IA service (including any address or email used) within three (3) business days. If Plaintiff is unrepresented, Counsel for Defendant shall have this same obligation. If all parties are unrepresented, the Plaintiff shall provide stamped addressed envelopes C to the Court with submission of this and any other proposed Order. F I DONE and ORDERED in Chambers at ____________, Seminole County, Florida. O F cc via email via eportal: All Attorneys of Record cc via U.S. Mail if unregistered in the eportal: All unrepresented parties “A true and correct copy of the foregoing was distributed to all parties by filing and service via N the eportal to all attorney(s)/interested parties identified on the eportal Electronic Service List.” U 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 If you require assistance please contact: ADA Coordinator at Seminole Court Administration, 301 N. Park Avenue, Suite N301, Sanford, Florida, 32771-1292; (407) 665-4227. NOTE: You must contact coordinator 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, in Seminole County, call 711.