On December 21, 2017 a
Stipulation,Agreement
was filed
involving a dispute between
Graziano, Anthony W,
and
Johnston, Kaylin I,
for Auto Negligence
in the District Court of Collier County.
Preview
IN THE CIRCUIT COURT FOR THE TWENTIETH
JUDICIAL CIRCUIT IN AND FOR COLLIER
COUNTY, FLORIDA
CASE NO: 2017-CA-002200
ANTHONY W. GRAZIANO,
Plaintiff,
vs.
KAYLIN I. JOHNSTON,
Defendants.
ED E EME: AN R
The parties hereby submit the following Agreed Case Management Plan to the Court for
approval:
Case Track Assignment (check one — must be completed for cases filed 1/1/10 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)
Kl 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)
S—— Complex Track (Case resolved within 2 years)
(Case will likely be declared complex per Florida Rule of Civil Procedure
1.201)
' 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.
FILEDOA/20¢ 18 O9GBDl LierteCase Deadlines and Events
DEADLINE OR EVENT AGREED DATE.
Statement of Facts and/or Counterclaim(s)
Plaintiff(s): | 03/26/19
Defendant(s): | 03/26/19
Identification of facts the parties believe to be disputed
Plaintifi{s); | 03/26/19
Defendant(s): | 03/26/19
Identification of the issues of law to be decided by the Court
Plaintiff(s) | 03/26/19
Defendant(s) | 03/26/19
Motions to Add Parties or to Amend Pleadings
Plaintifi{s) | 03/26/19
Defendant(s) | 03/26/19
Disclosure of Fact Witnesses
Plaintiff(s): | 01/25/19
Defendant(s): | 01/25/19
Disclosure of Expert Witnesses
Plaintiff(s): | 01/25/19
Defendant(s): | 01/25/19
Filing of Exhibit List
Plaintiff(s): | 05/27/19
Defendant(s): | 05/27/19
Discovery Deadline for Fact Witnesses
(All discovery must be commenced in time to be completed before
this date)
Plaintiff(s): | 03/26/19
Defendant(s): | 03/26/19
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): | 02/25/19Defendant(s):
02/25/19
Discovery Deadline for Expert Witnesses
Plaintiff(s):
Defendant(s):
03/26/19
03/26/19
Completion of Alternative Dispute Resolution (ADR)
(Mediation is mandatory unless the parties agree to another form of
ADR. Ifearly ADR is selected and it does not result in settlement or
disposition of this entire action, a case management conference will
be scheduled within 45 days from the date of ADR )
Deadline:
Type of ADR:
12/19/18
Mediation
Deadline for Filing Dispositive Motions
(Court requires filing not later than 10 days prior to the pretrial
management conference)
04/25/19
Pretrial Conference Date
An Order will be issued
(Unless early ADR is selected, a pretrial conference date will be by the Court scheduling
scheduled within 45 days of the date of ADR not resulting in the Pretrial Conference.
settlement or disposition of this entire action.)
Other Deadlines or Events
none
Trial Information
Estimated Date the Case Will Be Prepared To Go To Trial
(lf counsel and unrepresented parties do not agree on the 06/24/19
estimated date on which the case will be prepared to go to trial,
the Court may on its own motion set the case for trial)
Estimated Length of Trial (specify the number of trial days):
3 days
Identification of Jury or Non-Jury Trial
Jury
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.
pated 4/B1BSignature, address and telephone number of Counsel and Unrepresented Parties. Counsel
must state FL Bar number:
Alexander Billias, Esquire Joseph Dernbach, Esquire
FBN: 329680 FBN: 103274
Morgan & Morgan Law Offices of Robert J. Smith
3360 Pine Ridge Road, Suite 203 12751 New Brittany Boulevard, Suite 403
Naples, Florida 34109 Fort Myers, Fl 33907
Phone: (239) 433-6880 Phone: (239) 334-2351
Fax: (239) 433-6836 Fax: (866) 303-4759
Attomey for Plaintiff Attorney for Defendant
Email: abservice@forthepeople.com Email: ftmyerslegal@allstate.com
IRDER APP! AGRE) SE iE PL,
THE COURT having reviewed the preceding 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.
ORDERED in Collier County, Naples, Florida, this _/_ day of Leyoutl ,
2018.
Honoré Yh y Hayes
Circuit Judge, Twentieth Judicial Circuit
cc: Alexander Billias, Esquire
Joseph Dembach, Esquire
Document Filed Date
April 20, 2018
Case Filing Date
December 21, 2017
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Preview
IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CASE NO: 2017-CA-002200 ANTHONY W. GRAZIANO, Plaintiff, vs. KAYLIN I. JOHNSTON, Defendants. ED E EME: AN R The parties hereby submit the following Agreed Case Management Plan to the Court for approval: Case Track Assignment (check one — must be completed for cases filed 1/1/10 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) Kl 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) S—— Complex Track (Case resolved within 2 years) (Case will likely be declared complex per Florida Rule of Civil Procedure 1.201) ' 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. FILEDOA/20¢ 18 O9GBDl LierteCase Deadlines and Events DEADLINE OR EVENT AGREED DATE. Statement of Facts and/or Counterclaim(s) Plaintiff(s): | 03/26/19 Defendant(s): | 03/26/19 Identification of facts the parties believe to be disputed Plaintifi{s); | 03/26/19 Defendant(s): | 03/26/19 Identification of the issues of law to be decided by the Court Plaintiff(s) | 03/26/19 Defendant(s) | 03/26/19 Motions to Add Parties or to Amend Pleadings Plaintifi{s) | 03/26/19 Defendant(s) | 03/26/19 Disclosure of Fact Witnesses Plaintiff(s): | 01/25/19 Defendant(s): | 01/25/19 Disclosure of Expert Witnesses Plaintiff(s): | 01/25/19 Defendant(s): | 01/25/19 Filing of Exhibit List Plaintiff(s): | 05/27/19 Defendant(s): | 05/27/19 Discovery Deadline for Fact Witnesses (All discovery must be commenced in time to be completed before this date) Plaintiff(s): | 03/26/19 Defendant(s): | 03/26/19 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): | 02/25/19Defendant(s): 02/25/19 Discovery Deadline for Expert Witnesses Plaintiff(s): Defendant(s): 03/26/19 03/26/19 Completion of Alternative Dispute Resolution (ADR) (Mediation is mandatory unless the parties agree to another form of ADR. Ifearly ADR is selected and it does not result in settlement or disposition of this entire action, a case management conference will be scheduled within 45 days from the date of ADR ) Deadline: Type of ADR: 12/19/18 Mediation Deadline for Filing Dispositive Motions (Court requires filing not later than 10 days prior to the pretrial management conference) 04/25/19 Pretrial Conference Date An Order will be issued (Unless early ADR is selected, a pretrial conference date will be by the Court scheduling scheduled within 45 days of the date of ADR not resulting in the Pretrial Conference. settlement or disposition of this entire action.) Other Deadlines or Events none Trial Information Estimated Date the Case Will Be Prepared To Go To Trial (lf counsel and unrepresented parties do not agree on the 06/24/19 estimated date on which the case will be prepared to go to trial, the Court may on its own motion set the case for trial) Estimated Length of Trial (specify the number of trial days): 3 days Identification of Jury or Non-Jury Trial Jury 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. pated 4/B1BSignature, address and telephone number of Counsel and Unrepresented Parties. Counsel must state FL Bar number: Alexander Billias, Esquire Joseph Dernbach, Esquire FBN: 329680 FBN: 103274 Morgan & Morgan Law Offices of Robert J. Smith 3360 Pine Ridge Road, Suite 203 12751 New Brittany Boulevard, Suite 403 Naples, Florida 34109 Fort Myers, Fl 33907 Phone: (239) 433-6880 Phone: (239) 334-2351 Fax: (239) 433-6836 Fax: (866) 303-4759 Attomey for Plaintiff Attorney for Defendant Email: abservice@forthepeople.com Email: ftmyerslegal@allstate.com IRDER APP! AGRE) SE iE PL, THE COURT having reviewed the preceding 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. ORDERED in Collier County, Naples, Florida, this _/_ day of Leyoutl , 2018. Honoré Yh y Hayes Circuit Judge, Twentieth Judicial Circuit cc: Alexander Billias, Esquire Joseph Dembach, Esquire