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IN THE UNITED STATES DISTRICT COURT FOR THE 

SOUTHERN DISTRICT OF FLORIDA

Case No. 20-cv-61208-RKA

SIMPLIFIED IMAGING & DIAGNOSTICS, SIMPLIFIED 

IMAGING SOLUTIONS LLC d/b/a SIMPLIFIED 

IMAGING SOLUTIONS (SIS), 

A Florida Limited Liability Company,

Plaintiff,

v.

PETER ROUVELAS M.D. P.C.,

A New York Corporation

Defendant.

______________________________/

JOINT SCHEDULING REPORT

Plaintiff SIMPLIFIED IMAGING & DIAGNOSTICS, SIMPLIFIED IMAGING 

SOLUTIONS LLC d/b/a SIMPLIFIED IMAGING SOLUTIONS (SIS), and Defendant PETER 

ROUVELAS M.D. P.C., pursuant to Local Rule 16.1 and this Court’s Order Requiring 

Scheduling Report and Certificate of Interested Parties, and submit the following:

1. The following persons participated in a telephone conference discussing the 

court’s scheduling requirements:

a. Peter J. Solnick, Esquire – attorney for Plaintiff; and

b. Lance O. Leider, Esquire – attorney for Defendant.

2. The parties recommend that this case be assigned to the Standard Track.

3. The likelihood of settlement is possible.

4. Presently, but subject to facts learned in discovery, it is not likely that additional 

parties in this action will appear.

5. The parties propose the limitations on time stated in the Joint Proposed 

Scheduling Order, which is attached as Exhibit 1 to this submission per the Court’s order. 

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6. The parties propose the following for formulation and simplification of issues 

including the elimination of frivolous claims or defenses, and the number and timing of motions 

for summary judgment or partial summary judgment: 

a. Standard motion practice.

7. The parties believe the necessity and desirability of amendments to the pleadings 

is presently unknown as no defendant has answered or responded to the complaint at this 

juncture.

8. The parties believe the possibility of obtaining admissions of fact and documents, 

electronically stored information (ESI) or things which will avoid unnecessary proof, stipulations 

regarding the authenticity of documents, ESI, and the need for advance rulings from the Court on 

admissibility of evidence is likely after discovery closes.

9. Pursuant to Local Rule 16.1(3)(C), the parties will enter into a mutual protective 

order/confidentiality agreement related to documents and things containing trade secrets, 

confidential business and personal information of the parties, and documents containing 

protected health information of Defendant’s patients.

10. The parties will hold a Zoom meeting after discovery closes but before the pretrial 

stipulation is due to discuss evidence and to facilitate eliminating unnecessary proof and 

cumulative evidence.

11. The parties do not suggest the advisability of referring matters to a Magistrate

Judge, and pursuant to 28 U.S.C. § 636(c), do not waive their right to proceed before a District 

Judge of this Court.

12. The parties’ preliminary estimate for trial is 3-4 days.

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13. The parties request the following dates for conferences and the trial of this matter: 

a. Conference to examine exhibits and discuss evidence pursuant to paragraph 9 

above: _______________;

b. Final Pretrial conference: ________________; and

c. Trial: ________________.

14. The parties believe the following information may be helpful to the Court and the 

parties relating to 16(b)(2)(k): The parties do not believe that the document production in this 

case will be so great that a third-party vendor for ESI is necessary, although agree to work 

together on this issue as discovery progresses. 

15. The parties submit the following Joint Proposed Scheduling Order:

JOINT PROPOSED SCHEDULING ORDER

November 30 Joinder of parties, claims, and amendment of pleadings.

May 15, 2021 Parties shall furnish opposing counsel with a written list of containing the 

names and addresses of all fact witnesses intended to be called at trial and 

only those witnesses listed shall be permitted to testify unless good cause 

is shown and there is no prejudice to opposing party. The parties are under 

a continuing obligation to supplement discovery responses within ten (10) 

days of receipt or other notice of new or revised information.

April 1, 2021 All fact discovery must be completed.

May 1, 2021 Plaintiff must furnish expert witness list to the Defendant, along with the 

summaries/reports required by Fed. R. Civ. P. 26(a)(2), and only those 

expert witnesses shall be permitted to testify. Within the fourteen (14) day 

period thereafter, Plaintiff shall make its experts available for deposition 

by Defendant.

________________

All dispositive and other pretrial motions not explicitly excluded by Local 

Rule 7.1(a)(1), and accompanying memoranda of law must be filed.

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________________ Resolution of all pretrial Motions by the Court.

May 15, 2021 Defendant must furnish expert witness list to the Plaintiff along with the 

summaries/reports required by Fed. R. Civ. P. 26(a)(2), and only those 

expert witnesses shall be permitted to testify. Within the fourteen day 

period thereafter, Defendant shall make its experts available for deposition 

by Plaintiff.

June 30, 2021. All expert discovery must be completed.

July 15, 2021 All Daubert and Markman motions and accompanying memoranda of law 

must be filed.

July 15, 2021 Mediation must be completed.

________________

Joint pretrial stipulation must be filed pursuant to Local Rule 16.1(e). The 

pretrial stipulation shall include Plaintiff’s non-binding breakdown of 

damages with corresponding amounts; the witness lists shall be pared 

down to those witnesses the parties actually intend to call at trial; and the 

exhibit lists shall identify the witness introducing each exhibit. The parties 

shall meet at least one (1) month prior to the deadline for filing the pretrial

stipulation to confer on the preparation of that stipulation. The Court will 

not accept unilateral pretrial stipulations, and will strike, sua sponte, any 

such submissions.

________________ Pretrial Conference

________________ Trial Date

Dated this 7

th

 day of August 2020.

/s/ Peter J. Solnick

_____________________________

PETER J. SOLNICK, ESQUIRE

Fla. Bar. 670006

SOLNICK LAW P.A. 

Attorney for Plaintiff

1634 Island Way

Weston, Florida 33326

17501 Biscayne Boulevard, Suite 420

Aventura, FL 33160

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Tel: 786-629-6530

Email: pete@solnicklaw.com

/s/ Lance O. Leider

______________________________

LANCE O. LEIDER, J.D., LL.M.

Florida Bar No.: 96408

Primary E-mail: 

LLeider@TheHealthLawFirm.com

Secondary e-mail: 

CourtFilings@TheHealthLawFirm.com

TRIAL COUNSEL/LEAD ATTORNEY

ATTORNEY TO BE NOTICED

GEORGE F. INDEST III, J.D., M.P.A., LL.M.

Florida Bar No.: 382426

Primary e-mail: GIndest@TheHealthLawFirm.com

Secondary e-mail: 

CourtFilings@TheHealthLawFirm.com

TRIAL COUNSEL/LEAD ATTORNEY

ATTORNEY TO BE NOTICED

THE HEALTH LAW FIRM, P.A.

1101 Douglas Avenue, Suite 1000

Altamonte Springs, Florida 32714

Telephone: (407) 331-6620

Telefax: (407) 331-3030

ATTORNEYS FOR DEFENDANT

PETER ROUVELAS, M.D., P.C.

[Electronically filed by Lance O. Leider with the 

consent of all parties.]

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