UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

ANDRE LEWIS,

Plaintiff, CASE NO.: 0:20-cv-61159-RKA

vs.

DISCOUNT PARKING FLL, LLC,

a Florida Limited Liability Company

Defendant.

____________________________________/

JOINT SCHEDULING REPORT

Pursuant to Rule 16.1(b)(2) of the Local Rules of the United States District Court for the 

Southern District of Florida, and this Court’s Order Requiring Scheduling Report and Certificates 

of Interested Parties [ECF 11], Plaintiff, ANDRE LEWIS (“Plaintiff”), by and through her

undersigned counsel, in conference with Defendant, DISCOUNT PARKING FLL, LLC

(“Defendant”), by and through its undersigned counsel, (collectively referred to herein as the 

“Parties”), hereby file this Joint Scheduling Report and accompanying Joint Proposed Scheduling 

Order:

(A) Likelihood of Settlement. The Parties will engage in settlement discussions and the 

Parties will notify the Court as soon as possible if any settlement is reached.

(B) Likelihood of Appearance in the Action of Additional Parties.

The Parties do not anticipate adding any additional parties at the present time. 

(C) Discovery Schedule. The Parties propose the following pretrial discovery schedule, 

which is based on the standard case management track pursuant to S.D. Fla. L.R. 16.1.A.2:

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DATE ACTION

8/25/20 The Parties shall furnish their initial disclosures pursuant to Fed. R. 

Civ. P. 26. The Parties are under a continuing obligation to furnish 

supplements within ten (10) days of receipt or other notice of new 

or revised information.

9/25/20 The Parties shall file motions to amend pleadings or join Parties.

12/22/20 The Plaintiff shall disclose experts, expert witness summaries 

and reports, as required by Federal Rule of Civil Procedure 

26(a)(2).

01/22/21 The Defendants shall disclose experts, expert witness summaries 

and reports, as required by Federal Rule of Civil Procedure 

26(a)(2).

02/12/21 The Parties shall exchange rebuttal expert witness summaries and 

reports, as required by Federal Rule of Civil Procedure 26(a)(2).

03/16/21 The Parties shall complete all discovery, including expert 

discovery.

04/13/21 The Parties shall complete mediation.

05/04/21 The Parties shall file all dispositive pre-trial motions and 

memoranda of law. The Parties shall also file any motions to 

strike or exclude expert testimony, whether based on Federal 

Rule of Evidence 702 and Daubert v. Merrell Dow 

Pharmaceuticals, Inc., 509 U.S. 579 (1993), or any another basis.

05/31/21 The Parties shall file motions in limine. All motions in limine 

must be filed at least six (6) weeks before calendar call.

06/15/21 The Parties shall file their joint pretrial stipulation, witness lists, 

and exhibit lists in accordance with Local Rule 16.1(d) and (e). 

The Parties shall also file final proposed jury instructions or 

conclusions of law (for non-jury trials).

07/06/21 Calendar Call

07/20/21 Trial

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(D) Proposals for the Formulation and Simplification of Issues. The Parties shall 

endeavor to simplify the issues throughout this action and via discovery and the filing of Motions 

for Summary Judgment, which will not only serve to assist in the formulation and simplification 

of issues but may also eliminate certain claims and/or defenses.

(E) Necessity of Amendments to Pleadings. At this time, the Parties do not anticipate 

filing any amendments to the pleadings. 

(F) Admissions and Stipulations Which Will Avoid Unnecessary Proof. At this time, 

it is unknown whether admissions of fact may be obtained, whether authenticity of documents 

will be an issue, or whether the Parties will need advance rulings from the Court as to certain 

evidentiary matters. The Parties will endeavor to resolve as many evidentiary issues as possible 

by means of admissions and stipulations.

(G) Suggestions for the Avoidance of Unnecessary Proof and of Cumulative 

Evidence. The Parties will work together in advance of trial to stipulate to the authenticity of 

documents, to the extent possible, and to stipulate to as many facts as possible. This should assist 

in eliminating the presentation of unnecessary proof and cumulative evidence at trial.

(H) Referral of Matters to Magistrate Judge. The Parties agree to the referral of 

discovery matters only to a Magistrate Judge.

(I) Preliminary Estimate of the Time Required for Trial. The Parties believe this 

matter will require 3-4 days of a jury trial.

(J) Calendar Call and Trial Dates. The Parties request that a calendar call be scheduled 

for July 6, 2021, and that trial be scheduled to commence on or after July 20, 2021.

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(K) Other Information Helpful to the Court in Setting the Case for Status or Pretrial 

Conference. At this time, the Parties are unaware of any other information that might be helpful 

to the Court in setting the case for status or pretrial conference. 

A Joint Proposed Scheduling Order, contemplated under S.D. Fla. L.R. 16.1 (b)(3) is 

attached hereto as Exhibit “A.”

Dated: July 29, 2020.

 

Respectfully submitted,

/s/ Gregory Sconzo

Gregory S. Sconzo, Esq. 

Florida Bar No.: 0105553

Andrea C. Sconzo, Esq.

Florida Bar No.: 0105578

Sconzo Law Office, P.A.

3825 PGA Boulevard, Suite 207

Palm Beach Gardens, FL 33410

Telephone: (561) 729-0940

Email: greg@sconzolawoffice.com 

Attorneys for Plaintiff

/s/ Ronnie Guillen

Ronnie Guillen

Florida Bar No.: 842001

WINGET, SPADAFORA, SCHWARTZBERG, LLP

14 NE 1st Avenue, Suite 600

Miami, FL 33132

(305) 830-0600 – Telephone

(305) 830-0601 – Telecopy

Guillen.R@wssllp.com

Attorneys for Defendant 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on July 29, 2020, a true and correct copy of the foregoing was 

served via transmission of Notice of Electronic Filing generated by CM/ECF on all counsel of 

record on the below Service List. 

By: /s/ Gregory Sconzo

Gregory S. Sconzo, Esq. 

SERVICE LIST

Gregory S. Sconzo, Esq. 

Florida Bar No.: 0105553

Andrea C. Sconzo, Esq.

Florida Bar No.: 0105578

The Law Office of 

Gregory S. Sconzo, P.A.

5080 PGA Boulevard, Suite 213

Palm Beach Gardens, FL 33408

Telephone: (561) 729-0940

Email: greg@sconzolawoffice.com 

Attorneys for Plaintiff

Ronnie Guillen

Florida Bar No.: 842001

WINGET, SPADAFORA, SCHWARTZBERG, LLP

14 NE 1st Avenue, Suite 600

Miami, FL 33132

(305) 830-0600 – Telephone

(305) 830-0601 – Telecopy

Guillen.R@wssllp.com

Attorneys for Defendant 

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