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Filing # 113179216 E-Filed 09/10/2020 04:17:02 PM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT,
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO.: 2020-005448-CA-01
PAULO LONDRA, an individual,
Plaintiff.
v.
BIG LIGAS, LLC, a Florida limited
Liability company, CRISTIAN ANDRES
SALAZAR, an individual, DANIEL
ECHAVARRIA OVIEDO P/K/A “OVY ON
THE DRUMS,” an individual, RITHOLZ
LEVY FIELDS LLP, a New York limited
liability partnership, MATTHEW
GREENBERG, an individual, and
STEPHANIE CHOPURIAN, an individual,
Defendants.
/
DEFENDANTS, RITHOLZ LEVY FIELDS, LLP; MATTHEW GREENBERG; AND
STEPHANIE CHOPURIAN’S CORRECTED UNOPPOSED MOTION TO CONTINUE
VARIOUS TRIAL ORDER DEADLINES
(Corrected as to Exhibit 1)
Defendants, RITHOLZ LEVY FIELDS, LLP (“RLF”); MATTHEW GREENBERG
(“Greenberg”); AND STEPHANIE CHOPURIAN (“Chopurian”) (collectively the “the Law
Firm Defendants”), by and through undersigned counsel, and pursuant to Rules 1.201 and 1.460
of the Florida Rules of Civil Procedure, hereby file this unopposed Motion to Continue various
deadlines previously set forth in this Court’s CMC Trial Order/Case Management Order/Case
Management Schedule dated June 5, 2020 (the “Trial Order”) in this matter, and in support
thereof state as follows:
1. The Law Firm Defendants respectfully request a continuance of certain trial
deadlines while keeping the trial dates intact. Because the Law Firm Defendants were recently
Londra v. Big Ligas, LLC, et al.
Case Number: 2020-005448-CA-01
Defendants’ Motion for Continuance
added as party defendants, they were not able to participate in the selection of the trial deadlines
and trial dates. Accordingly, the Law Firm Defendants have been defending this case at a
disadvantage because the other parties to this consolidated lawsuit have been litigating this case
for approximately four months prior their involvement.
2. This is a complex business dispute between Plaintiff Londra, Co-Defendant
Cristian Andres Salazar (“Salazar”), and Co-Defendant Daniel Echavarria Oviedo (“Oviedo”)
arising out of the negotiation, formation, and operation of their joint venture known as Big Ligas,
LLC.
3. On March 5, 2020, Co-Defendant Big Ligas, LLC filed an action against Plaintiff
Londra in this Court (Case Number 2020-006167-CA-01).
4. The following day, Plaintiff Londra filed the instant action against Co-Defendants
(Case Number 2020-005448-CA-01).
5. Per this Court’s Order dated June 6, 2020, the two cases were consolidated.
6. Since the consolidated lawsuits were filed and prior to the time Law Firm
Defendants were served with the Amended Complaint, Plaintiff Londra and Co-Defendants Big
Ligas, LLC, Salazar, and Oviedo have: (a) filed pleadings and amended pleadings, (b) engaged
in motion practice, (c) served extensive written discovery requests, (d) exchanged thousands of
pages of documents in discovery, (e) met and conferred to discuss a proposed trial order and trial
dates, and (f) participated in a mediation.
7. On June 5, 2020, this Court entered the Trial Order, which set the case for trial on
this Court’s three week jury trial docket commencing on May 3, 2021.
2
Londra v. Big Ligas, LLC, et al.
Case Number: 2020-005448-CA-01
Defendants’ Motion for Continuance
8. Although the Amended Complaint naming the Law Firm Defendants as party
Defendants was filed on May 14, 2020, the Law Firm Defendants were not served with the
Amended Complaint until July 1, 2020.1
9. During a Case Mangement Conference on July 27, 2020, undersigned counsel,
Jeremy Colvin, advised the Court that the Law Firm Defendants were recently added to the case
and did not have an opportunity to weigh in on the trial deadlines, that Plaintiff’s counsel had
intimated he was going to amend the Complaint a second time, that the Trial Order seemed
ambitious, and that the Law Firm Defendants wanted to discuss moving the deadlines with the
other attorneys in the case.
10. In response, Judge Thomas encouraged the parties to confer about the dates, but
explained that Trial Order remain intact until otherwise ruled by the Court.
11. Later that same day, Plaintiff Londra filed a Motion for Leave to File the Second
Amended Complaint. Excluding exhibits, the Second Amended Complaint spans 42 pages and
consists of 142 paragraphs and 14 counts, including the following claims against the Law Firm
Defendants:
COUNT CAUSE OF ACTION DEFENDANTS TO THE CLAIM
I Declaratory Relief Big Ligas, Salazar, Oviedo, and RLF
IX Professional Negligence RLF, Greenberg, and Chopurian
X Breach of Fiduciary Duties RLF, Greenberg, and Chopurian
XIV Unjust Enrichment RLF, Greenberg, and Chopurian
12. On August 27, 2020, the Law Firm Defendants filed a Motion to Dismiss the
Second Amended Complaint. Accordingly, the pleadings are not set, and the case is technically
not “at issue” yet.
1
By electronic communications dated July 1, 2020, the undersigned counsel agreed to accept service on behalf of
the Law Firm Defendants.
3
Londra v. Big Ligas, LLC, et al.
Case Number: 2020-005448-CA-01
Defendants’ Motion for Continuance
13. On September 1, 2020, the parties appeared before this Court for an interim Case
Management Conference (“CMC”). During that CMC, the undersigned counsel explained that
the Law Firm Defendants anticipated filing a Motion for Continuance of the trial deadlines and
trial dates set forth in the Trial Order.
14. In response, the Court explained that while it would pre-judge such a motion for
continuance, it was “very unlikely” that it would be granted given that the trial dates were set in
May 2021.
15. Upon learning of this Court’s position, the undersigned counsel conferred with
counsel for Plaintiff Paulo Londra and counsel for Co-Defendants Big Ligas, LLC, Cristian
Salazar, and Daniel Oviedo regarding the possibility of moving certain deadlines set forth in the
Trial Order while maintaining the same trial dates.
16. To that end, all of the parties have consented to moving many, but not all, of the
trial deadlines. Per this Court’s comments during the CMC, the proposed revised Trial Order
keeps intact the deadlines for dispositive motions, Daubert motions, and the trial dates.
17. The complex nature of this case, the significant amount of record activity that
occurred before the Law Firm Defendants were brought into the case, the ongoing complications
caused by the global pandemic, and the numerous international witnesses2 involved in this
lawsuit all militate in favor of continuing the trial deadlines. The Proposed Trial Order provides
this Court and the parties a more realistic, efficient approach to prepare for and to conduct the
trial.
2
The three primary witnesses in this case, to wit: Plaintiff Londra, Defendant Salazar, and Defendant Oviedo, all
reside in South America. PlaintiffLondra resides in Argentina while Defendants Salazar and Oviedo reside in
Colombia.
4
Londra v. Big Ligas, LLC, et al.
Case Number: 2020-005448-CA-01
Defendants’ Motion for Continuance
18. This enlargement of time would not unfairly prejudice any party, and this Motion
is filed in good faith and not for purposes of delay.
19. Notably, no previous motions for continuance have been filed in this case.
WHEREFORE, Defendants, RITHOLZ LEVY FIELDS, LLP; MATTHEW
GREENBERG; AND STEPHANIE CHOPURIAN, respectfully request this Honorable Court to
grant the instant Motion for Continuance and enter an Amended Trial Order in the form attached
hereto as Exhibit 1, along with any further relief the Court deems just and appropriate.
CERTIFICATE OF CONFERRAL
On August 31, 2020, the undersigned counsel for the Law Firm Defendants, sent an email
to counsel for Co-Defendants Big Ligas, LLC, Cristian Salazar, and Daniel Oviedo enclosing a
copy of the proposed revised Case Management Schedule. The following day, counsel for Co-
Defendants advised that he consented to the proposed revised Case Management Schedule.
On September 2, 2020, the undersigned counsel for the Law Firm Defendants reached out
via email to counsel for Plaintiff Londra enclosing a copy of the proposed revised Case
Management Schedule. Later that day, counsel for Plaintiff Londra responded stating that he
consented to the proposed revised Case Management Schedule.
All parties agree that a hearing on the instant Motion is not necessary, but if the Court
requires a hearing, this matter be heard during a 10 minute hearing.
5
Londra v. Big Ligas, LLC, et al.
Case Number: 2020-005448-CA-01
Defendants’ Motion for Continuance
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Mail
to the following on this 10th day of September, 2020: ISAAC J. MITRANI, ESQ., Mitrani,
Rynor, Adamsky & Toland, P.A. 301 Arthur Godfrey Road, Penthouse, Miami Beach, FL
33140; HENRY L. SELF III, ESQ., Harder LLP, 132 South Rodeo Dr., Fourth Floor, Beverly
Hills, CA 90212 and JESUS E. CUZA, ESQ./MONICA V. CASTRO, ESQ./ANNELISE
DEL RIVERO, ESQ. Holland & Knight LLP, 701 Brickell Avenue, Suite 330, Miami, Florida
33131.
Respectfully submitted,
SCHWED KAHLE & KRESS, P.A.
11410 North Jog Road, Suite 100
Palm Beach Gardens, FL 33418
Telephone: (561) 694-0070
Facsimile: (561) 694-0057
By: /s/ Jeremy M. Colvin
Lloyd R. Schwed, Esq.
Florida Bar No.: 508713
lschwed@schwedpa.com
Jeremy M. Colvin, Esq.
Florida Bar No.: 0152226
jcolvin@schwedpa.com
6
EXHIBIT “1”
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT,
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO.: 2020-005448-CA-01
PAULO LONDRA, an individual,
Plaintiff.
v.
BIG LIGAS, LLC, a Florida limited
Liability company, CRISTIAN ANDRES
SALAZAR, an individual, DANIEL
ECHAVARRIA OVIEDO P/K/A “OVY ON
THE DRUMS,” an individual, RITHOLZ
LEVY FIELDS LLP, a New York limited
liability partnership, MATTHEW
GREENBERG, an individual, and
STEPHANIE CHOPURIAN, an individual,
Defendants.
/
AGREED ORDER ON DEFENDANTS, RITHOLZ LEVY FIELDS, LLP; MATTHEW
GREENBERG; AND STEPHANIE CHOPURIAN’S UNOPPOSED
MOTION TO CONTINUE VARIOUS TRIAL DEADLINES
THIS CAUSE having come before the Court upon Defendants RITHOLZ LEVY FIELDS,
LLP; MATTHEW GREENBERG; and STEPHANIE CHOPURIAN’s Motion to Continue Various
Trial Deadlines dated September 8, 2020 (the “Motion”), and the Court having reviewed the
Motion, having learned that it is unopposed, and after otherwise being duly advised in the premises,
it is hereby,
ORDERED and ADJUDGED as follows:
1. The Motion is hereby GRANTED.
2. This Court’s CMC-Trial Order/Case Management Order/Case Management Schedule
dated June 5, 2020 is hereby amended to reflect the following Case Management Schedule:
Londra v. Salazar, et al.
Case No.: 2020-005448-CA-01
Page 2 of 3
TASK PREVIOUS NEW DEADLINE
DEADLINE
1. MOTIONS TO AMEND July 27, 2020 October 1, 2020
PLEADINGS/ADD PARTIES
2. COMPLETION OF WRITTEN September 15, 2020 December 1, 2020
DISCOVERY
3. FACT WITNESS January 29, 2021 Same
DEPOSITIONS/DISCOVERY
CONCLUDES
4. PLAINTIFF/THIRD PARTY October 26, 2020 November 13, 2020
PLAINTIFF/CROSS PLAINTIFF(S)
DESIGNATE EXPERTS AND COMPLY
WITH CBL 6.3 AND DATES OF
AVAILABILITY FOR DEPOSITION
MUST INCLUDE: EXPERT
QUALIFICATIONS, REPORT
DETAILING OPINION, BASIS FOR
OPINION, AND DOCUMENTS
RELIED UPON FOR OPINION
5. DEFENDANT/THIRD PARTY/CROSS November 30, 2020 December 18, 2020
DEFENDANT(S) DESIGNATE
EXPERTS AND COMPLY WITH CBL
6.3 AND DATES OF AVAILABILITY
FOR DEPOSITION
MUST INCLUDE: EXPERT
QUALIFICATIONS, REPORT
DETAILING OPINION, BASIS FOR
OPINION, AND DOCUMENTS
RELIED UPON FOR OPINION
6. REBUTTAL EXPERT DISCLOSURE December 7, 2020 January 15, 2021
REPORTS DUE
MUST INCLUDE: EXPERT
QUALIFICATIONS, REPORT
DETAILING OPINION, BASIS FOR
OPINION, AND DOCUMENTS
RELIED UPON FOR OPINION
Londra v. Salazar, et al.
Case No.: 2020-005448-CA-01
Page 3 of 3
TASK PREVIOUS NEW DEADLINE
DEADLINE
7. COMPLETION OF EXPERT January 29, 2021 February 26, 2021
DEPOSITIONS
8. DISPOSITIVE MOTIONS FILED March 29, 2021 Same
9. DAUBERT/FRYE MOTIONS FILED March 29, 2021 Same
10. MOTIONS IN LIMINE FILED March 29, 2021 Same
11. FINAL MEDIATION DEADLINE April 16, 2021 Same
12. FINAL PRETRIAL CONFERENCE April 19, 2021 Same
at 10:00 a.m.
THE COURT SHALL ADDRESS ALL
PENDING MOTIONS, INCLUDING
JURY INSTRUCTIONS, VERDICT
FORM, MOTIONS IN LIMINE,
DEPOSITION DESIGNATIONS,
OBJECTIONS TO EXHIBITS AND
FRYE MOTIONS.
13. FINAL CASE MANAGEMENT April 19, 2021 Same
CONFERENCE DATE at 10:00 a.m.
14. TRIAL DATES Three week jury trial Same
docket starting May
3, 2021
3. As reflected in the Case Management Schedule above, the deadlines for dispositive
motions, Daubert/Frye Motions, motions in limine, the final mediation, the final pretrial conference,
the final case management conference, and the trial dates shall remain intact.
DONE AND ORDERED in the Chambers of Miami-Dade County, Florida, on this _____
day of September, 2020.
______________________________________
THE HONORABLE WILLIAM THOMAS
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Filing # 113179216 E-Filed 09/10/2020 04:17:02 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.: 2020-005448-CA-01 PAULO LONDRA, an individual, Plaintiff. v. BIG LIGAS, LLC, a Florida limited Liability company, CRISTIAN ANDRES SALAZAR, an individual, DANIEL ECHAVARRIA OVIEDO P/K/A “OVY ON THE DRUMS,” an individual, RITHOLZ LEVY FIELDS LLP, a New York limited liability partnership, MATTHEW GREENBERG, an individual, and STEPHANIE CHOPURIAN, an individual, Defendants. / DEFENDANTS, RITHOLZ LEVY FIELDS, LLP; MATTHEW GREENBERG; AND STEPHANIE CHOPURIAN’S CORRECTED UNOPPOSED MOTION TO CONTINUE VARIOUS TRIAL ORDER DEADLINES (Corrected as to Exhibit 1) Defendants, RITHOLZ LEVY FIELDS, LLP (“RLF”); MATTHEW GREENBERG (“Greenberg”); AND STEPHANIE CHOPURIAN (“Chopurian”) (collectively the “the Law Firm Defendants”), by and through undersigned counsel, and pursuant to Rules 1.201 and 1.460 of the Florida Rules of Civil Procedure, hereby file this unopposed Motion to Continue various deadlines previously set forth in this Court’s CMC Trial Order/Case Management Order/Case Management Schedule dated June 5, 2020 (the “Trial Order”) in this matter, and in support thereof state as follows: 1. The Law Firm Defendants respectfully request a continuance of certain trial deadlines while keeping the trial dates intact. Because the Law Firm Defendants were recently Londra v. Big Ligas, LLC, et al. Case Number: 2020-005448-CA-01 Defendants’ Motion for Continuance added as party defendants, they were not able to participate in the selection of the trial deadlines and trial dates. Accordingly, the Law Firm Defendants have been defending this case at a disadvantage because the other parties to this consolidated lawsuit have been litigating this case for approximately four months prior their involvement. 2. This is a complex business dispute between Plaintiff Londra, Co-Defendant Cristian Andres Salazar (“Salazar”), and Co-Defendant Daniel Echavarria Oviedo (“Oviedo”) arising out of the negotiation, formation, and operation of their joint venture known as Big Ligas, LLC. 3. On March 5, 2020, Co-Defendant Big Ligas, LLC filed an action against Plaintiff Londra in this Court (Case Number 2020-006167-CA-01). 4. The following day, Plaintiff Londra filed the instant action against Co-Defendants (Case Number 2020-005448-CA-01). 5. Per this Court’s Order dated June 6, 2020, the two cases were consolidated. 6. Since the consolidated lawsuits were filed and prior to the time Law Firm Defendants were served with the Amended Complaint, Plaintiff Londra and Co-Defendants Big Ligas, LLC, Salazar, and Oviedo have: (a) filed pleadings and amended pleadings, (b) engaged in motion practice, (c) served extensive written discovery requests, (d) exchanged thousands of pages of documents in discovery, (e) met and conferred to discuss a proposed trial order and trial dates, and (f) participated in a mediation. 7. On June 5, 2020, this Court entered the Trial Order, which set the case for trial on this Court’s three week jury trial docket commencing on May 3, 2021. 2 Londra v. Big Ligas, LLC, et al. Case Number: 2020-005448-CA-01 Defendants’ Motion for Continuance 8. Although the Amended Complaint naming the Law Firm Defendants as party Defendants was filed on May 14, 2020, the Law Firm Defendants were not served with the Amended Complaint until July 1, 2020.1 9. During a Case Mangement Conference on July 27, 2020, undersigned counsel, Jeremy Colvin, advised the Court that the Law Firm Defendants were recently added to the case and did not have an opportunity to weigh in on the trial deadlines, that Plaintiff’s counsel had intimated he was going to amend the Complaint a second time, that the Trial Order seemed ambitious, and that the Law Firm Defendants wanted to discuss moving the deadlines with the other attorneys in the case. 10. In response, Judge Thomas encouraged the parties to confer about the dates, but explained that Trial Order remain intact until otherwise ruled by the Court. 11. Later that same day, Plaintiff Londra filed a Motion for Leave to File the Second Amended Complaint. Excluding exhibits, the Second Amended Complaint spans 42 pages and consists of 142 paragraphs and 14 counts, including the following claims against the Law Firm Defendants: COUNT CAUSE OF ACTION DEFENDANTS TO THE CLAIM I Declaratory Relief Big Ligas, Salazar, Oviedo, and RLF IX Professional Negligence RLF, Greenberg, and Chopurian X Breach of Fiduciary Duties RLF, Greenberg, and Chopurian XIV Unjust Enrichment RLF, Greenberg, and Chopurian 12. On August 27, 2020, the Law Firm Defendants filed a Motion to Dismiss the Second Amended Complaint. Accordingly, the pleadings are not set, and the case is technically not “at issue” yet. 1 By electronic communications dated July 1, 2020, the undersigned counsel agreed to accept service on behalf of the Law Firm Defendants. 3 Londra v. Big Ligas, LLC, et al. Case Number: 2020-005448-CA-01 Defendants’ Motion for Continuance 13. On September 1, 2020, the parties appeared before this Court for an interim Case Management Conference (“CMC”). During that CMC, the undersigned counsel explained that the Law Firm Defendants anticipated filing a Motion for Continuance of the trial deadlines and trial dates set forth in the Trial Order. 14. In response, the Court explained that while it would pre-judge such a motion for continuance, it was “very unlikely” that it would be granted given that the trial dates were set in May 2021. 15. Upon learning of this Court’s position, the undersigned counsel conferred with counsel for Plaintiff Paulo Londra and counsel for Co-Defendants Big Ligas, LLC, Cristian Salazar, and Daniel Oviedo regarding the possibility of moving certain deadlines set forth in the Trial Order while maintaining the same trial dates. 16. To that end, all of the parties have consented to moving many, but not all, of the trial deadlines. Per this Court’s comments during the CMC, the proposed revised Trial Order keeps intact the deadlines for dispositive motions, Daubert motions, and the trial dates. 17. The complex nature of this case, the significant amount of record activity that occurred before the Law Firm Defendants were brought into the case, the ongoing complications caused by the global pandemic, and the numerous international witnesses2 involved in this lawsuit all militate in favor of continuing the trial deadlines. The Proposed Trial Order provides this Court and the parties a more realistic, efficient approach to prepare for and to conduct the trial. 2 The three primary witnesses in this case, to wit: Plaintiff Londra, Defendant Salazar, and Defendant Oviedo, all reside in South America. PlaintiffLondra resides in Argentina while Defendants Salazar and Oviedo reside in Colombia. 4 Londra v. Big Ligas, LLC, et al. Case Number: 2020-005448-CA-01 Defendants’ Motion for Continuance 18. This enlargement of time would not unfairly prejudice any party, and this Motion is filed in good faith and not for purposes of delay. 19. Notably, no previous motions for continuance have been filed in this case. WHEREFORE, Defendants, RITHOLZ LEVY FIELDS, LLP; MATTHEW GREENBERG; AND STEPHANIE CHOPURIAN, respectfully request this Honorable Court to grant the instant Motion for Continuance and enter an Amended Trial Order in the form attached hereto as Exhibit 1, along with any further relief the Court deems just and appropriate. CERTIFICATE OF CONFERRAL On August 31, 2020, the undersigned counsel for the Law Firm Defendants, sent an email to counsel for Co-Defendants Big Ligas, LLC, Cristian Salazar, and Daniel Oviedo enclosing a copy of the proposed revised Case Management Schedule. The following day, counsel for Co- Defendants advised that he consented to the proposed revised Case Management Schedule. On September 2, 2020, the undersigned counsel for the Law Firm Defendants reached out via email to counsel for Plaintiff Londra enclosing a copy of the proposed revised Case Management Schedule. Later that day, counsel for Plaintiff Londra responded stating that he consented to the proposed revised Case Management Schedule. All parties agree that a hearing on the instant Motion is not necessary, but if the Court requires a hearing, this matter be heard during a 10 minute hearing. 5 Londra v. Big Ligas, LLC, et al. Case Number: 2020-005448-CA-01 Defendants’ Motion for Continuance CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Mail to the following on this 10th day of September, 2020: ISAAC J. MITRANI, ESQ., Mitrani, Rynor, Adamsky & Toland, P.A. 301 Arthur Godfrey Road, Penthouse, Miami Beach, FL 33140; HENRY L. SELF III, ESQ., Harder LLP, 132 South Rodeo Dr., Fourth Floor, Beverly Hills, CA 90212 and JESUS E. CUZA, ESQ./MONICA V. CASTRO, ESQ./ANNELISE DEL RIVERO, ESQ. Holland & Knight LLP, 701 Brickell Avenue, Suite 330, Miami, Florida 33131. Respectfully submitted, SCHWED KAHLE & KRESS, P.A. 11410 North Jog Road, Suite 100 Palm Beach Gardens, FL 33418 Telephone: (561) 694-0070 Facsimile: (561) 694-0057 By: /s/ Jeremy M. Colvin Lloyd R. Schwed, Esq. Florida Bar No.: 508713 lschwed@schwedpa.com Jeremy M. Colvin, Esq. Florida Bar No.: 0152226 jcolvin@schwedpa.com 6 EXHIBIT “1” IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.: 2020-005448-CA-01 PAULO LONDRA, an individual, Plaintiff. v. BIG LIGAS, LLC, a Florida limited Liability company, CRISTIAN ANDRES SALAZAR, an individual, DANIEL ECHAVARRIA OVIEDO P/K/A “OVY ON THE DRUMS,” an individual, RITHOLZ LEVY FIELDS LLP, a New York limited liability partnership, MATTHEW GREENBERG, an individual, and STEPHANIE CHOPURIAN, an individual, Defendants. / AGREED ORDER ON DEFENDANTS, RITHOLZ LEVY FIELDS, LLP; MATTHEW GREENBERG; AND STEPHANIE CHOPURIAN’S UNOPPOSED MOTION TO CONTINUE VARIOUS TRIAL DEADLINES THIS CAUSE having come before the Court upon Defendants RITHOLZ LEVY FIELDS, LLP; MATTHEW GREENBERG; and STEPHANIE CHOPURIAN’s Motion to Continue Various Trial Deadlines dated September 8, 2020 (the “Motion”), and the Court having reviewed the Motion, having learned that it is unopposed, and after otherwise being duly advised in the premises, it is hereby, ORDERED and ADJUDGED as follows: 1. The Motion is hereby GRANTED. 2. This Court’s CMC-Trial Order/Case Management Order/Case Management Schedule dated June 5, 2020 is hereby amended to reflect the following Case Management Schedule: Londra v. Salazar, et al. Case No.: 2020-005448-CA-01 Page 2 of 3 TASK PREVIOUS NEW DEADLINE DEADLINE 1. MOTIONS TO AMEND July 27, 2020 October 1, 2020 PLEADINGS/ADD PARTIES 2. COMPLETION OF WRITTEN September 15, 2020 December 1, 2020 DISCOVERY 3. FACT WITNESS January 29, 2021 Same DEPOSITIONS/DISCOVERY CONCLUDES 4. PLAINTIFF/THIRD PARTY October 26, 2020 November 13, 2020 PLAINTIFF/CROSS PLAINTIFF(S) DESIGNATE EXPERTS AND COMPLY WITH CBL 6.3 AND DATES OF AVAILABILITY FOR DEPOSITION MUST INCLUDE: EXPERT QUALIFICATIONS, REPORT DETAILING OPINION, BASIS FOR OPINION, AND DOCUMENTS RELIED UPON FOR OPINION 5. DEFENDANT/THIRD PARTY/CROSS November 30, 2020 December 18, 2020 DEFENDANT(S) DESIGNATE EXPERTS AND COMPLY WITH CBL 6.3 AND DATES OF AVAILABILITY FOR DEPOSITION MUST INCLUDE: EXPERT QUALIFICATIONS, REPORT DETAILING OPINION, BASIS FOR OPINION, AND DOCUMENTS RELIED UPON FOR OPINION 6. REBUTTAL EXPERT DISCLOSURE December 7, 2020 January 15, 2021 REPORTS DUE MUST INCLUDE: EXPERT QUALIFICATIONS, REPORT DETAILING OPINION, BASIS FOR OPINION, AND DOCUMENTS RELIED UPON FOR OPINION Londra v. Salazar, et al. Case No.: 2020-005448-CA-01 Page 3 of 3 TASK PREVIOUS NEW DEADLINE DEADLINE 7. COMPLETION OF EXPERT January 29, 2021 February 26, 2021 DEPOSITIONS 8. DISPOSITIVE MOTIONS FILED March 29, 2021 Same 9. DAUBERT/FRYE MOTIONS FILED March 29, 2021 Same 10. MOTIONS IN LIMINE FILED March 29, 2021 Same 11. FINAL MEDIATION DEADLINE April 16, 2021 Same 12. FINAL PRETRIAL CONFERENCE April 19, 2021 Same at 10:00 a.m. THE COURT SHALL ADDRESS ALL PENDING MOTIONS, INCLUDING JURY INSTRUCTIONS, VERDICT FORM, MOTIONS IN LIMINE, DEPOSITION DESIGNATIONS, OBJECTIONS TO EXHIBITS AND FRYE MOTIONS. 13. FINAL CASE MANAGEMENT April 19, 2021 Same CONFERENCE DATE at 10:00 a.m. 14. TRIAL DATES Three week jury trial Same docket starting May 3, 2021 3. As reflected in the Case Management Schedule above, the deadlines for dispositive motions, Daubert/Frye Motions, motions in limine, the final mediation, the final pretrial conference, the final case management conference, and the trial dates shall remain intact. DONE AND ORDERED in the Chambers of Miami-Dade County, Florida, on this _____ day of September, 2020. ______________________________________ THE HONORABLE WILLIAM THOMAS