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.
______________________________________/

SCHEDULE PROPOSED BY THE PLAINTIFFS
The parties were unable to come to an agreement on all of the pretrial deadlines in this
case due to a fundamental disagreement on the time required to complete discovery in this
matter. Plaintiff believes that there could be a substantial number of witnesses, depending on
what the discovery reveals, many of who may live outside of Miami, Florida and even outside of
the United States, while Defendants believe that there will be a limited number of witnesses and
the case will therefore not require extensive discovery. The deadlines as agreed upon and
suggested by the parties are detailed below:
This MATTER is set for trial for the week of November 9, 2015. The Parties request to
adhere to the following schedule:
Plaintiff’s Dates

Defendants’ Dates

21 days after the
court decides
Defendants’ Motion
to Dismiss

21 days after the court
decides Defendants’
Motion to Dismiss

The Parties shall furnish lists with names and addresses
of fact witnesses. The Parties are under a continuing
obligation to supplement discovery responses with ten
(10) days of receipt or other notice of new or revised
information.

November 15, 2014

November 15, 2014

The Parties shall file motions to amend pleadings or join
Parties.

June 2, 2015

March 15, 2015

The Plaintiff shall disclose experts, expert witness
summaries and reports, as required by Federal Rule of
Civil Procedure 26(2).

June 16, 2015

April 15, 2015

The Parties shall exchange rebuttal expert witness
summaries and reports, as required by Federal Rule of
Civil Procedure 26(2).

July 30, 2015

May 30, 2015

The Parties shall complete all discovery, including expert
discovery.

August 7, 2015

June 15, 2015

Parties shall complete mediation and file a mediation
report with the Court.

August 21, 2015

July 15, 2015

The Parties shall file all dispositive pre-trial motions and
memoranda of law.

September 10, 2015

August 31, 2015

The Parties shall file a joint pre-trial stipulation, as
required by Local Rule 16.1(3) and final proposed jury
instructions. Joint proposed jury instructions or
conclusions of law (for non-jury trials) shall outline: 1)
the legal elements of Plaintiff’s claims, including
demages; and 2) the legal elements of the defenses that
are raised.

September 30, 2015

September 30, 2015

The Parties shall file witness and exhibit lists and all
motions in limine. The witness list shall include only
those witneses the Parties actually intend to call at trial
and shall include a brief synopsis of their testimony. The
exhibit lists shall identify each witness that will introduce
each exhibit.

By: s/Kenia Bravo
Kenia Bravo, Esq. FBN 68296

By: s/Sean R. Santini
Sean Santini, Esq., FBN 832898