Court: Florida State, Duval County, Fourth Circuit Court
Docket: 2019-CA-008879
Firm: Alexander DeGance Barnett
2020-10-28T00:00:00 — Rachael Long () — discovery — 9.2 — Court Reporter Charges Hearing Attendance
2020-11-30T00:00:00 — MGA () — discovery — 0.3 — Consider answer and defenses to counterclaim
2020-11-30T00:00:00 — CJ () — discovery — 2.9 — Emailed with client to confirm that they did not have any suggested changes to draft answer; prepared answer to be filed; reviewed motion for reconsideration and hearing transcript in preparation for summary judgment motion
2020-11-30T00:00:00 — RL () — discovery — 0.2 — Review finalize and serve WORK_OF_ART ; Update the case file with WORK_OF_ART date and time; Correspond with ORG regarding covering the hearing
2020-10-08T00:00:00 — MGA () — discovery — 0.9 — Review court s order and forward to client with comments; consider next steps and telephone conversation with ORG regarding specific allegations; review LAW and prepare for filing; telephone conversation with PERSON about next steps Reviewed transcript of hearing on motion to dismiss LAW Due diligence on claim against restaurants including telephone conversation with PERSON and review of photographs provided by client; revise and finalize third amended complaint and file with court
2020-10-08T00:00:00 — CJ () — discovery — 0.7 — Continued to review transcript of motion to dismiss hearing; reviewed complaints and other relevant case documents
2020-10-09T00:00:00 — MGA () — discovery — 0.8 — Review finalize and serve LAW
2020-10-09T00:00:00 — CJ () — discovery — 0.8 — Review transcript of motion to dismiss hearing; reviewed complaints and other relevant case documents
2020-10-09T00:00:00 — RL () — discovery — 0.4 — Review finalize and serve LAW
2020-10-12T00:00:00 — MGA () — discovery — 0.3 — Telephone conversation with PERSON regarding discovery responses
2020-10-12T00:00:00 — CJ () — discovery — 0.2 — Reviewed email from opposing counsel raising various discovery issues
2020-10-14T00:00:00 — CJ () — discovery — 2.5 — Reviewed online file and paper file to identify missing discovery documents we need from prior counsel
2020-10-14T00:00:00 — RL () — discovery — 1.0 — Review the court docket and compare it to the pleadings received from PERSON notating which are missing
2020-10-15T00:00:00 — MGA () — discovery — 0.9 — Consider course of action and instructions to team on plan of action
2020-10-15T00:00:00 — CJ () — discovery — 4.3 — Communicated with prior to counsel to access missing discovery documents; began to review all discovery sent and received; evaluated next steps
2020-10-15T00:00:00 — RL () — discovery — 2.8 — Finish comparing the court docket to the pleadings received from PERSON noting which documents are missing so we can retrieve them
2020-10-16T00:00:00 — MGA () — discovery — 1.4 — Meet with PERSON and PERSON regarding the strategy for the case; Review and analyze the missing discovery documents received from PERSON in preparation for the upcoming case meeting
2020-10-16T00:00:00 — CJ () — discovery — 2.2 — Participate in meeting with client; instructions following meeting
2020-10-16T00:00:00 — RL () — discovery — 2.1 — Reviewed case documents for meeting; began researching damages model; meeting with client to discuss next steps
2020-10-19T00:00:00 — MGA () — discovery — 0.3 — Finish organizing the PERSON v PERSON pleadings ensuring we have the entire file; Correspond with PERSON regarding taking photographs of the parking lot shopping mall; Make an extended phone call to PERSON reporting regarding the transcript from ORG hearing
2020-10-19T00:00:00 — CJ () — discovery — 2.7 — Consider discovery issues raised by opposing counsel
2020-10-19T00:00:00 — RL () — discovery — 2.4 — Begun to evaluate discovery issues raised by opposing counsel; communicated with opposing counsel re discovery issues
2020-10-21T00:00:00 — CJ () — discovery — 2.1 — Update the case file with the additional pleadings received from PERSON that were initially missing upon taking the file over
2020-10-22T00:00:00 — MGA () — discovery — 0.4 — Continued to evaluate discovery issues raised by Defendant
2020-10-22T00:00:00 — CJ () — discovery — 2.1 — Consider discovery issues and instructions on same; review email exchanges with client
2020-11-06T00:00:00 — CJ () — discovery — 1.1 — Finalized supplemental interrogatory and requests for production responses and served to opposing counsel
2020-11-06T00:00:00 — RL () — discovery — 0.4 — Review finalize and serve LAW Supplemental Responses to Request for Production Supplemental Documents and LAW
2020-11-12T00:00:00 — CJ () — discovery — 0.3 — Reviewed Defendant BACM s Motion for Summary Judgment
2020-11-13T00:00:00 — MGA () — discovery — 0.3 — Review email exchanges on scheduling hearing on pending motion
2020-11-16T00:00:00 — MGA () — discovery — 0.4 — Email exchange with client; review preparation required for course of action
2020-11-17T00:00:00 — MGA () — discovery — 2.8 — Consider course of action; calendar Reply to defenses and Answer to Counterclaim; begin review of discovery status
2020-11-20T00:00:00 — MGA () — discovery — 3.7 — Review defendant s answers defenses and counterclaim; prepare for conference with client and consider course of action; participate in call with client
2020-11-20T00:00:00 — CJ () — discovery — 4.1 — Reviewed discovery in case to date; evaluated need for additional discovery; evaluated issues to discuss in partial motion for summary judgment; ORG meeting with clients to discuss next steps in lawsuit
2020-11-23T00:00:00 — CJ () — discovery — 0.3 — Reviewed PERSON counterclaim and the third amended complaint in preparation to draft answer to counterclaim; ORG to draft answer to PERSON counterclaim
2020-11-23T00:00:00 — RL () — discovery — 0.6 — Review and analyze the most recent documents received from the client printing copies for PERSON review
2020-11-24T00:00:00 — MGA () — discovery — 2.2 — Review draft answer and defenses to counterclaim; instructions on revision and sending to client with comments
2020-11-25T00:00:00 — CJ () — discovery — 0.3 — Finalized answer to PERSON counterclaim; drafted affirmative defenses; emailed counterclaim and draft answer to clients for their review; began reviewing third amended complaint and defendants answer for undisputed facts in preparation for summary judgment motion
2020-11-25T00:00:00 — MGA () — discovery — 0.2 — Consider Motion to Compel and scheduling issues on hearing
2020-12-31T00:00:00 — Chandler Jolly () — discovery — 3.9 — Complete drafting response to ORG motion for summary judgment
2020-10-22T00:00:00 — CJ () — discovery — 2.1 — Continued to evaluate discovery issues raised by Defendant; communicated with client about supplemental responses
2020-10-23T00:00:00 — CJ () — discovery — 1.5 — Reviewed discovery documents in preparation for phone call with opposing counsel phone call with opposing counsel re discovery issues; drafted email to opposing counsel providing an account of what was agreed to on the phone call
2020-10-26T00:00:00 — MGA () — discovery — 1.4 — Consider issues on discovery responses; participate in office meeting with client
2020-10-26T00:00:00 — CJ () — discovery — 2.6 — Reviewed discovery documents for meeting with client; met with client to discuss supplemental discovery responses and additional documents; drafted email summary of meeting for clients; communicated with opposing counsel re supplemental discovery
2020-10-28T00:00:00 — MGA () — discovery — 0.3 — Review surveys and photo produced by client and instructions regarding same
2020-10-29T00:00:00 — RL () — discovery — 0.5 — Conduct a search for a professional photographer and drone pilot for pictures of the shopping center parking lot
2020-10-30T00:00:00 — CJ () — discovery — 2.6 — Began to draft supplemental responses to interrogatories and requests for production; communicated with opposing counsel re status of discovery; reviewed motions to dismiss for LOC and PERSON
2020-10-30T00:00:00 — BG () — discovery — 0.5 — Receipt review and process LAW Or In WORK_OF_ART and document files
2020-12-17T00:00:00 — RL () — discovery — 1.9 — Serve the Motion for Partial Summary Judgment; Email the JA regarding adding additional time to the DATE hearing; Correspond with the
2020-12-18T00:00:00 — MGA () — discovery — 1.5 — Review draft memo in response to ORG swells motion; finalize and file motion to consolidate hearings; prepare letter to judge
2020-12-23T00:00:00 — CJ () — discovery — 2.5 — Complete drafting ORG response to restaurants motions to dismiss
2020-12-09T00:00:00 — MGA () — discovery — 0.4 — Review and comment on draft court order
2020-12-09T00:00:00 — CJ () — discovery — 4.0 — Consider issues with production of redacted documents as required by court
2020-12-10T00:00:00 — MGA () — discovery — 0.3 — Revised proposed order on ORG motion to compel; continued to evaluate issues for motion for summary judgment
2020-12-10T00:00:00 — CJ () — discovery — 5.8 — Review letter from tenant provided by client; consider issues on document production
2020-12-11T00:00:00 — CJ () — discovery — 5.0 — Began to draft motion for partial summary judgment
2020-12-14T00:00:00 — MGA () — discovery — 0.8 — Review and comment on draft motion for partial summary judgment
2020-12-14T00:00:00 — CJ () — discovery — 5.3 — Finalize draft of motion for partial summary judgment; call with client re discovery
2020-12-15T00:00:00 — MGA () — discovery — 1.6 — Participate in meeting with clients; review and comment on draft dispositive motion
2020-12-15T00:00:00 — CJ () — discovery — 4.6 — Continued to revise draft motion for summary judgment; reviewed leases in preparation for client meeting re discovery; attended meeting with client to discuss the redactions in the leases that need to be made before production
2020-12-15T00:00:00 — RL () — discovery — 3.5 — Review and analyze the documents recently received from the client organizing them into the case file for PERSON review; Begin working on WORK_OF_ART organizing all of the documents received and produced in preparation for possible trial
2020-12-16T00:00:00 — MGA () — discovery — 0.8 — Review and revise draft motion for summary judgment
2020-12-16T00:00:00 — RL () — discovery — 0.9 — Continue updating the exhibit list adding all documents in the case file to it in preparation for possible trial
2020-12-17T00:00:00 — MGA () — discovery — 0.5 — Finalize and file motion for summary judgment with court; email exchange with opposing counsel about scheduling hearing on motion
2020-12-23T00:00:00 — RL () — discovery — 2.8 — Serve the Notice of Hearing for LAW ; WORK_OF_ART ; Update the case file with the hearing date and time for LAW ; WORK_OF_ART regarding; Correspond with the client with the ORG links and notices for the upcoming hearings; Update the casefile with the correspondences between parties regarding the upcoming hearings and motions
2020-12-27T00:00:00 — CJ () — discovery —  — Began highlighting proposed redactions on additional leases from client
2020-12-28T00:00:00 — MGA () — discovery — 1.5 — Work on response to ORG motions; forward draft response to co counsel for comment; forward draft response to client for comment; review outline for response to ORG motion
2020-12-28T00:00:00 — CJ () — discovery — 1.4 — Drafted email to client re upcoming discovery; reviewed leases to ensure all economic terms were being redacted
2020-12-29T00:00:00 — MGA () — discovery — 0.6 — Further review of draft response to motions filed by ORG
2020-12-29T00:00:00 — CJ () — discovery — 1.4 — Began evaluating issues for ORG response in Opposition to BACM s Motion for Summary Judgment
2020-12-30T00:00:00 — MGA () — discovery — 1.7 — Evaluate and consider issues regarding ORG dispositive motion; participate in call with PERSON about ORG motion; review and serve discovery responses
2020-12-30T00:00:00 — CJ () — discovery — 4.0 — Prepared leases for production; drafted supplemental response to request for production; reviewed privilege log; began drafting response to ORG motion for summary judgment
2020-12-30T00:00:00 — RL () — discovery — 5.3 — Draft the privilege log based on the redactions made to the leases; Redact the leases pursuant to PERSON and the client s notes; Meet with the client so he can witness the leases in preparation for service to ORG ; Review finalize and serve LAW to interrogatories; Third Supplemental Answers to Interrogatories; Third Supplemental Response to Request to Production; WORK_OF_ART and the responsive documents; Correspond with the client regarding the discovery served on their behalf; Update the casefile with the client correspondence