On October 26, 2020 a
Stipulation,Agreement
was filed
involving a dispute between
Sergio Farias,
and
Centauri Specialty Insurance Company,
for INSURANCE CLAIM
in the District Court of Palm Beach County.
Preview
Filing # 131691210 E-Filed 07/29/2021 04:16:44 PM
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO.:50-2020-CA-011700XXXXMB
SERGIO FARIAS,
Plaintiff,
Vv.
CENTAURI SPECIALTY INSURANCE COMPANY,
Defendant.
/
AGREED CASE MANAGEMENT PLAN
The parties hereby submit the following Agreed Case Management Plan to the Court for
approval:
Case Track Assignment! (check one):
Expedited Track (Case resolved within 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
aeneelatent Io CladY
Coiipraine is weap
Streamlined Track (Case resolved within 12 months)
(It is recommended that discovery and an alternative dispute
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)
xX 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)
Complex Track (Case resolved wit
(This track cannot be selected without a hearing and order granting motion
to designate the case as complex per Florida Rule of Civil Procedure
1.201)
' 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 1 Complex
Track cases may or may not be resolved with a jury triai, it is expected that Streamiined and Expedited
Track cases will be resolved without a jury trial.
CHEN. DAIAARCACUAAIINTY Cl INCEDU ARDIIV7ZN FLED A7INAINNA NAA AA DN
Pm. PAL DLA VUUINE TT, PL, JUOL IE mDNUeey, ULUIAN, Ure“. lo ut butt oieCase Deadlines and Events
Service of Unserved Parties
Plaintiff(s):
Cross/Counter Plaintiffs:
October 1, 2021
Motions to Add Parties or to Amend Pleadings
Plaintiffs):
Defendant(s):
Octoher 1 9091
VCORE ay oven
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):
20 DAYS PRIOR TO
PRE-TRIAL
CONFERENCE
WHICH IS 10 BE
SET VIA SEPARATE
ORDER OF THIS
COURT
Discovery Deadline for Fact Witnesses
(All discovery must be commenced in time to be completed before
Hite Anta)
ulis Gate;
Plaintiff(s):
Defendant(s):
August 1, 2022
August 1, 2022
Discovery Deadline for Expert Witnesses (All discovery must be
commenced in time to be completed before this date)
Plaintiff(s):
Defendant(s):
August 1, 2022
August 1, 2022
Completion of Alternative Dispute Resolution (ADR)
(Mediation is mandatory unless the parties agree to another form of
ADR).
Deadline:
Type of ADR:
September 1, 2022
Mediation
Other Deadlines or EventTrial Information
Is this Case At Issue pursuant to Rule 1.440? (Yes or No) YES
Estimated Date the Case Will Be Prepared To Go To Trial
(If counsel and unrepresented parties do not agree on the
estimated date on which the case will be prepared to go to trial,
the Court may set the case for trial on its own motion)
November 1,
Plaintiff: 2022
Defendant: November 1,
2022
Agreed: YES
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
chanae ic otherwice aareed to hy the narties and annraved hv the Court The Conrt will concider
cnange IS Cinerwise agreed fo oy the parties and approved oy the Court, The Court wit 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:
Respectfully submitted by:
____/s/ Aileen Siles /s/ Joshua Gluck
Ailcen Siles, Esq. Joshua Gluck, Esq.
Florida Bar No. 1015640 Florida Bar No. 1010970
Pazos Law Group, P.A. BeharBehar
800 Douglas Road, Suite 830 490 Sawgrass Corporate Parkway, Suite 300,
Coral Gables, FL, 33134 Sunrise, FL 33325
Telephone #: 305-330-1643 Telephone #: (954) 990-8639
Email: aileen@pazoslawgroup.com Email: jg@beharbehar.com
Plaintiff's Counsel Defendant’s Counsel
Document Filed Date
January 25, 2024
Case Filing Date
October 26, 2020
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Filing # 131691210 E-Filed 07/29/2021 04:16:44 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.:50-2020-CA-011700XXXXMB SERGIO FARIAS, Plaintiff, Vv. CENTAURI SPECIALTY INSURANCE COMPANY, Defendant. / AGREED CASE MANAGEMENT PLAN The parties hereby submit the following Agreed Case Management Plan to the Court for approval: Case Track Assignment! (check one): Expedited Track (Case resolved within 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 aeneelatent Io CladY Coiipraine is weap Streamlined Track (Case resolved within 12 months) (It is recommended that discovery and an alternative dispute 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) xX 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) Complex Track (Case resolved wit (This track cannot be selected without a hearing and order granting motion to designate the case as complex per Florida Rule of Civil Procedure 1.201) ' 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 1 Complex Track cases may or may not be resolved with a jury triai, it is expected that Streamiined and Expedited Track cases will be resolved without a jury trial. CHEN. DAIAARCACUAAIINTY Cl INCEDU ARDIIV7ZN FLED A7INAINNA NAA AA DN Pm. PAL DLA VUUINE TT, PL, JUOL IE mDNUeey, ULUIAN, Ure“. lo ut butt oieCase Deadlines and Events Service of Unserved Parties Plaintiff(s): Cross/Counter Plaintiffs: October 1, 2021 Motions to Add Parties or to Amend Pleadings Plaintiffs): Defendant(s): Octoher 1 9091 VCORE ay oven 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): 20 DAYS PRIOR TO PRE-TRIAL CONFERENCE WHICH IS 10 BE SET VIA SEPARATE ORDER OF THIS COURT Discovery Deadline for Fact Witnesses (All discovery must be commenced in time to be completed before Hite Anta) ulis Gate; Plaintiff(s): Defendant(s): August 1, 2022 August 1, 2022 Discovery Deadline for Expert Witnesses (All discovery must be commenced in time to be completed before this date) Plaintiff(s): Defendant(s): August 1, 2022 August 1, 2022 Completion of Alternative Dispute Resolution (ADR) (Mediation is mandatory unless the parties agree to another form of ADR). Deadline: Type of ADR: September 1, 2022 Mediation Other Deadlines or EventTrial Information Is this Case At Issue pursuant to Rule 1.440? (Yes or No) YES Estimated Date the Case Will Be Prepared To Go To Trial (If counsel and unrepresented parties do not agree on the estimated date on which the case will be prepared to go to trial, the Court may set the case for trial on its own motion) November 1, Plaintiff: 2022 Defendant: November 1, 2022 Agreed: YES 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 chanae ic otherwice aareed to hy the narties and annraved hv the Court The Conrt will concider cnange IS Cinerwise agreed fo oy the parties and approved oy the Court, The Court wit 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: Respectfully submitted by: ____/s/ Aileen Siles /s/ Joshua Gluck Ailcen Siles, Esq. Joshua Gluck, Esq. Florida Bar No. 1015640 Florida Bar No. 1010970 Pazos Law Group, P.A. BeharBehar 800 Douglas Road, Suite 830 490 Sawgrass Corporate Parkway, Suite 300, Coral Gables, FL, 33134 Sunrise, FL 33325 Telephone #: 305-330-1643 Telephone #: (954) 990-8639 Email: aileen@pazoslawgroup.com Email: jg@beharbehar.com Plaintiff's Counsel Defendant’s Counsel