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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,
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TYPTAP INSURANCE COMPANY,
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Defendant.
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CASE MANAGEMENT PLAN
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(STREAMLINED)
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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
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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.
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1. Date of First Response (i.e., Answer,
Notice of appearance, Motion for Extension
20 days after the Court’s Pre-Trial
Conference
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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
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information
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regarding expert testimony that is required
Rule
1.280(b)(5). Each party is limited to one
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expert per specialty. No other expert
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testimony should be permitted at trial.
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Information furnished pursuant to this
paragraph should be timely filed with the
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Clerk of the Court.)
5. Objections to pleadings prior to projected trial date
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Deadline for Discovery Completion
(including Depositions)
prior to projected trial date
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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
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William S England, Esquire
Fla. Bar No.: 0098941
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Chad Barr Law, P.A.
238 N. Westmonte Dr., Suite 200
Altamonte Springs, Florida 32714
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ORDER APPROVING CASE MANAGEMENT PLAN ORDERED that the preceding
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deadlines apply to this action and that the same will be strictly applied and enforced by the
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Court:
1. COMPLIANCE WITH THIS CASE MANAGEMENT ORDER: The parties shall
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strictly comply with the terms of this Case Management Plan and Order unless
otherwise ordered by the Court. FAILURE TO COMPLY WITH ALL THE
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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
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(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
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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
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to the Court with submission of this and any other proposed Order.
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DONE and ORDERED in Chambers at ____________, Seminole County, Florida.
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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
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the eportal to all attorney(s)/interested parties identified on the eportal Electronic Service
List.”
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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.