Corbacho Daudinot v. Puig Valdes et al

Filing 38

SCHEDULING REPORT - Rule 16.1 by MIGUEL ANGEL CORBACHO DAUDINOT (Attachments: # 1 Exhibit A - Joine Scheduling Report)(Gonzalez, Avelino)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIGUEL ANGEL CORBACHO DAUDINOT
Plaintiff,

CASE NO.: 1:13-cv-22589-KMW

v.
YASIEL PUIG VALDES a/k/a YASIEL PUIG and
MARITZA VALDES GONZALEZ.
Defendants.
______________________________________/

SCHEDULING CONFERENCE REPORT
COME NOW, counsel for the Plaintiff and the Defendants and file the following
Scheduling Conference Report:
(A) Likelihood of Settlement. The parties will discuss settlement of this claim
throughout litigation and will inform the Court if any settlement is reached.
(B) Likelihood of Appearance in the Action of Additional Parties. Plaintiffs contend
that it is unlikely, but possible, that additional parties may arise as a result of reasonable
discovery conducted. Defendants do not intend to add additional parties and believe that it is
unlikely that additional parties shall be added to the case.
(C) Proposed limits on the time. The parties agreed on November 15, 2014 as the
deadline to join other parties and to amend the pleadings. But due to an inherent disagreement
about the rigors required during the discovery period and the time each party believes that they
will need for discovery, the parties were unable to agree to time limits on (ii) the time to file and
hear motions and (iii) the time to complete discovery. Please see Exhibit A, the proposed joint
scheduling order.
(D) Proposals for the Formulation and Simplification of Issues. At this time, the
parties do not have any specific proposals for the formulation and simplification of any issues.
As the case progresses, the parties will continue to confer in good faith to discuss proposals for
the formulation and simplification of issues in this case.

(E) Necessity of Amendments to Pleadings. An amendment to Plaintiffs’ Complaint
may be necessary depending on the outcome of Defendants’ Motion to Dismiss [DE 11].
(F) Admissions and Stipulations Which Will Avoid Unnecessary Proof. The parties
will work together to obtain admissions and stipulations that will avoid unnecessary proof at
trial.
(G) Suggestions for the Avoidance of Unnecessary Proof and of Cumulative
Evidence. The parties will work together to develop any suggestions that will avoid unnecessary
proof and presentation of cumulative evidence at trial.
(H) Referral of Matters to Magistrate Judge. The parties consent to the court’s sending
discovery matters to the Magistrate judge, but do not consent to trial by the Magistrate Judge, nor
to the disposition of dispositive pre-trial motions by a Magistrate Judge.
(I) Preliminary Estimate of the Time Required for Trial. The parties believe this
matter will require 3-5 days of trial.
(J) Pretrial Conference and Trial Dates. The parties agree that the trial should be held
on November 9, 2015 with final pretrial conference to take place on October 15, 2015.
(K) Manual on Complex Litigation. At this time the parties believe that the Manual on
Complex Litigation and any other need for rule variations is unnecessary.
LAW OFFICES OF AVELINO
J. GONZALEZ, P.A.
Counsel for Plaintiff
6780 Coral Way
Miami, Florida 33155
Telephone [phone]
Facsimile [phone]
E-mail: [e-mail]

SANTINI LAW
1001 Brickell Bay Drive, Suite 2650
Miami, FL 33131
Telephone: [phone]
Facsimile: 305-372-7308
Email: [e-mail]

By: s/Kenia Bravo
KENIA BRAVO, ESQ.
Fl. Bar No. 68296

By: s/Sean R. Santini
SEAN R. SANTINI, ESQ.
Fl. Bar No. 832898