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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 20-61297-CIV-ALTMAN/Hunt

BYRON HALL, et al.,

Plaintiffs,

v.

LVNV FUNDING, LLC, et al.,

Defendants.

____________________________________/

JOINT CONFERENCE REPORT

Pursuant to Rule 16.1 of the Local Rules for the Southern District of Florida, Plaintiffs

Byron Hall et al., and Defendants LVNV Funding, LLC et al. (collectively, the “Parties”), by and 

through their undersigned counsel, hereby submit this Joint Conference Report and Joint Proposed 

Scheduling Order:

A. Likelihood of Settlement

The Parties engaged in preliminary settlement discussions as required by Court order. The 

Parties are still engaged in settlement discussion, but believe settlement is unlikely at this time.

B. Likelihood of Appearance in Action of Additional Parties

At the present time, the Parties are unaware of any additional parties who are likely to 

appear or be joined in this action.

C. Proposed Limits on Time:

(i) To join other parties and to amend the pleadings: December 1, 2020

(ii) To Complete Discovery: June 1, 2021

(iii) To file Dispositive Motions: August 1, 2021

D. Proposal for Formulation and Simplification of Issues

The Parties agree to continue discussing the formulation and simplification of issues. The 

Parties are unable to further simplify the issues at this time. After discovery and further 

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investigation, the Parties are hopeful that they will be able to further simplify the issues prior to 

the pre-trial conference, if any, or the trial of this matter.

E. Necessity or Desirability of Amendments to the Pleadings

None at this time.

F. The Possibility of Obtaining Admissions of Fact and of Documents, Electronically 

Stored Information or Things Which Will Avoid Unnecessary Proof, Stipulations Regarding 

Authenticity of Documents, Electronically Stored Information or Things and the Need for 

Advance Rulings from the Court on Admissibility of Evidence

The Parties agree to endeavor in good faith efforts to enter into stipulations regarding the 

authenticity of documents and other evidentiary matters, if possible. Further, as discovery 

progresses, the Parties will attempt to minimize the need for advance rulings by the Court and 

unnecessary proof by admitting facts that are not disputed. In the event the Parties discover that 

there is relevant ESI, they will discuss the most appropriate form in which to produce that 

information.

G. Suggestions for Avoidance of Unnecessary Proof and Cumulative Evidence 

None at this time, although the Parties will continue to discuss suggestions for avoiding 

unnecessary proof and cumulative evidence throughout the litigation. 

H. Suggestions on the Advisability of Referring Matters to a Magistrate Judge

None, although the Parties acknowledge that discovery matters are generally referred to 

the Magistrate Judge as a matter of course. 

I. A preliminary estimate of the time required for trial

Plaintiff requested a jury trial. The Parties estimate that a jury trial will take one (1) to 

two (2) days.

J. Requested Dates for Conferences Before Trial, Final Pretrial Conference, and 

Trial

The Parties request that the case be set for a pre-trial conference on or around September 

15, 2021 and propose a trial date in October 2021.

K. Any issues about:

(i) Disclosure, discovery, or preservation of electronically stored information, including the 

form or form in which it should be produced: None at this time

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(ii) Claims of privilege or of protection as trial preparation materials, including-if the parties 

agree on a procedure to assert those claims after production-whether to ask the Court to 

include their agreement in an order under Federal Rule of Evidence 502: None at this 

time

(iii) When the parties have agreed to the ESI Checklist available on the Court’s website, 

matters enumerated on the ESI checklist: None at this time.

L. Any other information that might be helpful to the Court in setting the case for 

status or pretrial conference

None at this time.

Respectfully submitted this 1st day of September 2020.

LAW OFFICES OF JIBRAEL S. HINDI

By: /s/ Jibrael S. Hindi

 JIBRAEL S. HINDI, ESQUIRE

 FL Bar No. 118259

 THOMAS J. PATTI, ESQUIRE

 FL Bar No. 118377

 110 se 6th Street

 Suite 1744

 Fort Lauderdale, FL 33301

(954) 907-1136

(855) 529-9540 (fax)

jibrael@jibraellaw.com

tom@jibraellaw.com

 Counsel for Plaintiffs

MESSER STRICKLER, LTD.

By: /s/John M. Marees, II

LAUREN M. BURNETTE, ESQUIRE

FL Bar No. 0120079

JOHN M. MAREES, II, ESQUIRE

FL Bar No. 0069879

12276 San Jose Blvd., Suite 720

Jacksonville, FL 32223

(904) 527-1172

(904) 683-7353 (fax)

lburnette@messerstrickler.com

jmarees@messerstrickler.com

Counsel for Defendants

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