IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA

CIRCUIT CIVIL DIVISION

CIRCUIT CIVIL DIVISION [Div. #]

CASE NO: [Case Number]-CA-01

[Plaintiff]

Plaintiff(s),

vs.

[Defendant]

Defendant(s)

______/

CASE MANAGEMENT PLAN

This case came for review and scheduling before the undersigned judge on ___/___/___Pursuant to the Court’s Order entered___/___/___the parties have conferred and propose the following case management track:

Case Track Assignment(check one)

______Streamlined:

(Case has relatively narrow issues. It appears that limited discovery will be required. All motions shall be promptly scheduled and discovery shall be completed no later than 230 days of filing of the complaint.)

______Standard:

(Case has a range of issues. All motions shall be promptly scheduled and discovery shall be completed no later than 365 days of filing of the complaint.)

______Complex:

(Case has a range of complicated legal or evidentiary issues or is complex due to the number of parties or level of conflict in the case. Discovery should be completed no later than 540 days after filing of complaint.)

DEADLINE OR EVENT / DATE
Deadline for amendment of pleadings:
Deadline for exchange of interrogatories and requests to produce:
Deadline for disclosure of fact witnesses:
Plaintiff(s):
Defendant(s):
Deadline for disclosure of expert witnesses:
Plaintiff(s):
Defendant(s):
Deadline to seek any inspections or examinations:
Plaintiff(s):
Defendant(s):
Deadline for fact discovery:
Plaintiff(s):
Defendant(s):
Deadline for expert discovery:
Plaintiff(s):
Defendant(s):
Deadline for completion of any inspections or examinations:
Plaintiff(s):
Defendant(s):

The following deadlines must be no later than 75 days prior to trial:

Deadline for Daubert motions:
Plaintiff(s):
Defendant(s):
Deadline for dispositive motions to be filed and set for
hearing: Plaintiff(s):
Defendant(s):
Deadline for Jury instructions: Plaintiff(s):
Defendant(s):

The following deadlines must be no later than 30 days prior to trial:

Deadline for deposition designations:
Plaintiff(s):
Defendant(s):
Deadline for deposition counter-designations:
Plaintiff(s):
Defendant(s):
Deadline for ADR completion:
Plaintiff(s):
Defendant(s):

Trial Information:

Estimated length of trial (please state in hours):
(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 on its own motion set the case for trial)
Plaintiff(s):
Defendant(s):
Proposed trial date per track assignment: / No later than:___/___/____
(Parties may seek an earlier trial date)

Prior to filing any motion in this case, counsel shall confer in person or by telephone as to the necessity of the motion and whether issues can be narrowed, and shall certify same in any motion filed. If a motion is filed, it shall be set for hearing on the court’s motion calendar at the time it is filed.With regard to discovery, any response raising privilege shall be accompanied by a privilege log at the time of the response. Any objection, motion for protective order, motion to compel, must be the subject of conference as referenced above. Motions and objections which are unable to be resolved shall be promptly set for hearing by the movant.

The partiesshall prepare and submit their scheduling order within 10 days of this order. Failure to submit the scheduling order timely may result in dismissal, striking of pleadings, or the unilateral imposition of a schedule by the court.

The parties may not waive any deadline by agreement once the scheduling order is adopted by the court. If the parties find they are unable to comply, they should file a motion with specific details as to why they cannot comply. Failure to complete discovery as required or lack of preparation will not constitute good cause to alter the above schedule.

Counsel should assume that trial dates are firm. Discovery should proceed in accordance with the interim deadlines set forth in this plan. Counsel should not assume cases will be continued automatically absent specific good cause and compliance with this schedule or the interim deadlines.

Date: ______

Signature, address and telephone number of Counsel and Unrepresented Parties. Counsel must include Florida Bar number:

PLAINTIFF’S COUNSELDEFENDANT’S COUNSEL

AddressAddress

Telephone #Telephone #

Fax #Fax #

E-Mail AddressE-Mail Address

Florida Bar #Florida Bar #

______

Or, if pro se, PLAINTIFFOr, if pro se, DEFENDANT

AddressAddress

Telephone #Telephone #

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA

CIRCUIT CIVIL DIVISION

CIRCUIT CIVIL DIVISION [Div. #]

CASE NO: [Case Number]-CA-01

[Plaintiff]

Plaintiff(s),

vs.

[Defendant]

Defendant(s)

______/

ORDER APPROVING CASE MANAGEMENT PLAN

THE COURT having reviewed the proposed Case Management Plan, it is hereby ORDERED AND ADJUDGED that the Case Management Plan is hereby approved and adopted and the parties shall abide the terms set forth herein.

DONE AND ORDERED in Miami-Dade County, Florida on ______.

______

Circuit Judge

CC: All Counsel of Record

CERTIFICATE OF SERVICE

Pursuant to Rule 1.080 of the Florida Rules of Civil Procedure, conformed copies have been mailed this _____ day of ______, 20__, to the Civil Case Manager and the following:

By:______

Judicial Assistant

1