On May 31, 1974 a
Stipulation,Agreement
was filed
involving a dispute between
Jane Doe,
and
Boca Raton Regional Hospital Inc Dba Boca Raton Reginal Hospital,
Devon Briganti,
for OTHER NEGLIGENCE
in the District Court of Palm Beach County.
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Filing # 136502296 E-Filed 10/13/2021 04:27:23 PM
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
Jane Doe, Case No: 50-2020-CA-014445-XXXX-MB
Plaintiffs),
vy.
BOCA RATON REGIONAL HOSPITAL, INC.
d/b/a BOCA RATON REGIONAL HOSPITAL,
and DEVON BRIGANTI,
Defendant(s)
AMENDED AGREED CASE
MANAGEMENT P. (DCMAP)
The parties hereby submit the following Agreed Case Management Plan to the Court for approval:
Case Track Assignment! (check one):
Exnedited Track (Case resolved wit
in 8 months)
(It is recommended that discovery and an alternative dispute
resolution/mediation be completed within 180 days after the complaint
is filed and a final disposition entered within 245 days after the
complaint is filed)
Streamlined Track (Case resolved within 12 months)
(1b in sannemmandad that dinanvees and an altarnative dient
{ut iS TECOMIMENUCG Uiat GISCOVETY anG am aucimauve Gispurc
resolution/mediation be completed within 270 days after the complaint
is filed and a final disposition entered within 365 days after the
complaint is filed)
ex General Track (Case resolved within 18 months)
(It is recommended that discovery and an alternative dispute
resolution/mediation be completed within 450 days after the
complaint is filed and a final disposition entered within 540 days after
the complaint is filed)
1 Case disposition times for all Case Tracks have been established based on Florida Rule of General Practice
and Judicial Administration 2.250(a)(1)(B) and the Circuit’s historic data. Although General and Complex
Track cases may or may not be resolved with a jury trial, it is expected that Streamlined and Expedited
Track cases will be resolved without a jury trial.
CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLED 4NM21INNNA NA.97-92 DNA
HILLY. PAL DLA VUUINE TT, PL, vUOL I mDnuecy, ULL, lUnioreue! ut2r.2u ritComplex Track (Case resolved within 2 years)
(This track cannot be seiected without a hearing and order granting motion
to designate the case as complex per Florida Rule of Civil Procedure
1.201)
Case Deadlines and Events
DEADLINE OR EVENT AGREED DATE
Service of Unserved Parties February 14, 2022
Plaintiff(s):
Cross/Counter Plaintiffs:
Motions to Add Parties or to Amend Pleadings
Motions to add parties or amend pleadings for all parties shall be
filed and set for hearing no later the agreed date
February 14, 2022
Resolution of Objections to Pleadings and Pretrial Motions (All
motions to dismiss, quash service, strike affirmative defenses or
extend the time to answer or respond to a pleading must be heard by
this date)
Plaintiff(s):
Defendant(s):
Must be filed no later
than 30 days prior to
calendar call
and heard no later than 7
days prior to the pre-trial
conference.
Discovery Deadline for Fact Witnesses
(All discovery must be commenced in time to be completed before
this date)
Plaintiff(s):
Defendant(s):
90 days prior to
calendar call.
Discovery Deadline for Expert Witnesses (All discovery must be
commenced in time to be completed before this date)
Plaintiff(s):
Defendant(s):
45 prior to calendar
call.Completion of Alternative Dispute Resolution (ADR) Must be completed prior]
(Mediation is mandatory unless the parties agree to another form of | to or by March 17, 2022
ADR).
Deadline: March 17, 2022
Type of ADR: Mediation
Other Deadlines or Events Upon receipt of the
trial order, the parties
will prepare a joint
scheduling order if it is
deemed necessary.
Trial Information
Is this Case At Issue pursuant to Rule 1.440? (Yes or No) No
Estimated Date the Case Will Be Prepared To Go To Trial Pit date:
[PLEASE READ FOOTNOTE BEFORE COMPLETING/?? June 2022
(If counsel and unrepresented parties do not agree on the
estimated date on which the case will he nrenared to go to trial, Deft date:
the Court may set the case for trial on its own motion) June 2022
Agreed:
Yes
? For retroactive cases pending prior to April 30, 2021, the estimated date the case will be prepared to go to
trial should not exceed the disposition time frame for the chosen case track. Cases that have been pending
longer than the corresponding case track disposition time frame must follow the following time frames:
Case Track Age of Case Estimated Date of Trial
Expedited More than 8 months Within 4 Months
Streamlined 12-18 Months Within 6 Months
More than 18 months Within 4 Months
General 18-24 Months Within 6 Months
More than 24 Months Within 4 MonthsEstimated Length of Trial (specify the number of trial days): 5 days
Identification of Jury or Non-Jury Trial
Jury Trial
(remainder of page intentionally left blank)
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.
Date: October 13, 2021.
Signature, address and telephone number of Counsel and Unrepresented Parties. Counsel must state
Fl Bar number:
/s/ David J. Brevda
Dawid T Reade Beanira
Davia J. preva, oSquire
Florida Bar No.: 1008373
Senior Justice Law Firm
7700 Congress Ave., Suite 3216
Boca Raton, Florida 33487
Phone: (561) 717-0813
Fax: (561) 708-6781
Ema
Attorney for Plaintiff
eservice(@seniarinstice com
eservices yustice.com
/s/ RoseMarie Antonacci-Pollock
RoseMarie Antonacci-Pollock, Esq.
Florida Bar No.: 509752
FALK, WAAS, HERNANDEZ, SOLOMON,
MENDLESTEIN & DAVIS. P.A.
Attorney for Boca Raton Regional Hospital, Inc.
d/b/a Boca Raton Regional Hospital
1900 NW Corporate Blvd., Suite 210-E
Boca Raton, FL 33431
Telephone: (561) 367-2510
Email: ServiceRMAntonacci@falkwaas.com
/s/ Julie Pagni
Julie N. Pagni, Esq.
Florida Bar No.: 111459
Pagni Law, PLLC
Attorney for Devon Briganti
9510 Listow Ter
Boynton Beach, FL 33472-2718
Phone: (954) 817-3441
Email: Pagnilaw@gmail.com
eservicepagnilaw@gmail.com
Document Filed Date
January 15, 1975
Case Filing Date
May 31, 1974
Category
OTHER NEGLIGENCE
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Filing # 136502296 E-Filed 10/13/2021 04:27:23 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Jane Doe, Case No: 50-2020-CA-014445-XXXX-MB Plaintiffs), vy. BOCA RATON REGIONAL HOSPITAL, INC. d/b/a BOCA RATON REGIONAL HOSPITAL, and DEVON BRIGANTI, Defendant(s) AMENDED AGREED CASE MANAGEMENT P. (DCMAP) The parties hereby submit the following Agreed Case Management Plan to the Court for approval: Case Track Assignment! (check one): Exnedited Track (Case resolved wit in 8 months) (It is recommended that discovery and an alternative dispute resolution/mediation be completed within 180 days after the complaint is filed and a final disposition entered within 245 days after the complaint is filed) Streamlined Track (Case resolved within 12 months) (1b in sannemmandad that dinanvees and an altarnative dient {ut iS TECOMIMENUCG Uiat GISCOVETY anG am aucimauve Gispurc resolution/mediation be completed within 270 days after the complaint is filed and a final disposition entered within 365 days after the complaint is filed) ex General Track (Case resolved within 18 months) (It is recommended that discovery and an alternative dispute resolution/mediation be completed within 450 days after the complaint is filed and a final disposition entered within 540 days after the complaint is filed) 1 Case disposition times for all Case Tracks have been established based on Florida Rule of General Practice and Judicial Administration 2.250(a)(1)(B) and the Circuit’s historic data. Although General and Complex Track cases may or may not be resolved with a jury trial, it is expected that Streamlined and Expedited Track cases will be resolved without a jury trial. CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLED 4NM21INNNA NA.97-92 DNA HILLY. PAL DLA VUUINE TT, PL, vUOL I mDnuecy, ULL, lUnioreue! ut2r.2u ritComplex Track (Case resolved within 2 years) (This track cannot be seiected without a hearing and order granting motion to designate the case as complex per Florida Rule of Civil Procedure 1.201) Case Deadlines and Events DEADLINE OR EVENT AGREED DATE Service of Unserved Parties February 14, 2022 Plaintiff(s): Cross/Counter Plaintiffs: Motions to Add Parties or to Amend Pleadings Motions to add parties or amend pleadings for all parties shall be filed and set for hearing no later the agreed date February 14, 2022 Resolution of Objections to Pleadings and Pretrial Motions (All motions to dismiss, quash service, strike affirmative defenses or extend the time to answer or respond to a pleading must be heard by this date) Plaintiff(s): Defendant(s): Must be filed no later than 30 days prior to calendar call and heard no later than 7 days prior to the pre-trial conference. Discovery Deadline for Fact Witnesses (All discovery must be commenced in time to be completed before this date) Plaintiff(s): Defendant(s): 90 days prior to calendar call. Discovery Deadline for Expert Witnesses (All discovery must be commenced in time to be completed before this date) Plaintiff(s): Defendant(s): 45 prior to calendar call.Completion of Alternative Dispute Resolution (ADR) Must be completed prior] (Mediation is mandatory unless the parties agree to another form of | to or by March 17, 2022 ADR). Deadline: March 17, 2022 Type of ADR: Mediation Other Deadlines or Events Upon receipt of the trial order, the parties will prepare a joint scheduling order if it is deemed necessary. Trial Information Is this Case At Issue pursuant to Rule 1.440? (Yes or No) No Estimated Date the Case Will Be Prepared To Go To Trial Pit date: [PLEASE READ FOOTNOTE BEFORE COMPLETING/?? June 2022 (If counsel and unrepresented parties do not agree on the estimated date on which the case will he nrenared to go to trial, Deft date: the Court may set the case for trial on its own motion) June 2022 Agreed: Yes ? For retroactive cases pending prior to April 30, 2021, the estimated date the case will be prepared to go to trial should not exceed the disposition time frame for the chosen case track. Cases that have been pending longer than the corresponding case track disposition time frame must follow the following time frames: Case Track Age of Case Estimated Date of Trial Expedited More than 8 months Within 4 Months Streamlined 12-18 Months Within 6 Months More than 18 months Within 4 Months General 18-24 Months Within 6 Months More than 24 Months Within 4 MonthsEstimated Length of Trial (specify the number of trial days): 5 days Identification of Jury or Non-Jury Trial Jury Trial (remainder of page intentionally left blank) 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. Date: October 13, 2021. Signature, address and telephone number of Counsel and Unrepresented Parties. Counsel must state Fl Bar number: /s/ David J. Brevda Dawid T Reade Beanira Davia J. preva, oSquire Florida Bar No.: 1008373 Senior Justice Law Firm 7700 Congress Ave., Suite 3216 Boca Raton, Florida 33487 Phone: (561) 717-0813 Fax: (561) 708-6781 Ema Attorney for Plaintiff eservice(@seniarinstice com eservices yustice.com /s/ RoseMarie Antonacci-Pollock RoseMarie Antonacci-Pollock, Esq. Florida Bar No.: 509752 FALK, WAAS, HERNANDEZ, SOLOMON, MENDLESTEIN & DAVIS. P.A. Attorney for Boca Raton Regional Hospital, Inc. d/b/a Boca Raton Regional Hospital 1900 NW Corporate Blvd., Suite 210-E Boca Raton, FL 33431 Telephone: (561) 367-2510 Email: ServiceRMAntonacci@falkwaas.com /s/ Julie Pagni Julie N. Pagni, Esq. Florida Bar No.: 111459 Pagni Law, PLLC Attorney for Devon Briganti 9510 Listow Ter Boynton Beach, FL 33472-2718 Phone: (954) 817-3441 Email: Pagnilaw@gmail.com eservicepagnilaw@gmail.com