UNITED STATES DISTRICT COURT FOR THE

SOUTHERN DISTRICT OF FLORIDA

Miami Division

Case Number: 20-22884-CIV-MORENO

DOUG LONGHINI, 

Plaintiff,

vs.

1450 BRICKELL, LLC,

Defendant.

_________________________________________/

SCHEDULING ORDER SETTING TRIAL

THIS COURT issues this order in accordance with Local Rule 16.1. The parties shall 

comply with the following deadlines.

Selection of a mediator to be completed no later than: August 28, 2020

Deadline to join additional parties or to amend pleadings: September 11, 2020

In the unlikely event that experts are needed, disclosure of experts’ 

names and their reports are required at least 30 days before the 

discovery deadline. 

Deadline to complete all discovery (including expert discovery):

December 4, 2020

Deadline for the filing of all motions for summary judgment: December 18, 2020

Deadline for the filing of pretrial motions (including motions in limine 

and Daubert motions):

January 15, 2021

Mediation to be completed no later than: January 15, 2021

Plaintiff's witness and exhibit lists: February 24, 2021

Defendant's witness and exhibit lists: February 26, 2021

Pretrial stipulations to be filed by: March 2, 2021

Calendar Call at 2:00 p.m., Wilkie D. Ferguson U.S. Courthouse, 

Courtroom 13-3, 400 North Miami Avenue, Miami, FL 33128: March 9, 2021

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Trial set for the two-week period commencing: March 15, 2021

Pursuant to Federal Rule of Civil Procedure 40, this action is at issue. It is 

ADJUDGED that the parties shall comply with the following trial management procedures:

(1) Pretrial Conference – The Pretrial Conference allowed under Federal Rule of 

Civil Procedure 16(a) and required by Local Rule 16.1.C, shall take place immediately following 

Calendar Call only if requested by the parties in advance. If the parties do not request a pretrial 

conference in advance of Calendar Call then no pretrial conference will be held.

(2) Plaintiff's Witness and Exhibit Lists – Plaintiff shall electronically upload onto 

the case docket a copy of Plaintiff's Witness List and a copy of Plaintiff's Exhibit List no later than 

Wednesday, February 24, 2021, at 5:00 p.m.

(a) Plaintiff's Witness List - Plaintiff's Witness List shall include all the witnesses, 

both lay and expert, that Plaintiff intends to call at trial. Plaintiff's Witness List 

shall briefly describe the nature of each witness’ testimony and whether such 

witnesses will be testifying live or by deposition. Witnesses omitted from the list 

will not be allowed at trial.

(b) Plaintiff's Exhibit List - Plaintiff's Exhibit List shall include the exhibits that 

Plaintiff intends to use at trial. Plaintiff's Exhibit List shall in consecutively 

numbered paragraphs adequately describe the nature of each document listed. The 

actual exhibits shall be pre-marked with corresponding numbers (e.g. Plaintiff's

Exhibit #1, Plaintiff's Exhibit #2, etc.) which numbers they will retain through the 

end of trial. The exhibit list shall refer to specific items and shall not include 

blanket statements such as all exhibits produced during depositions or Plaintiff

reserves the use of any other relevant evidence. Exhibits omitted from the list will 

not be allowed at trial.

(3) Defendant's Witness and Exhibit Lists – Defendant shall electronically upload 

onto the case docket a copy of Defendant's Witness List and a copy of Defendant's Exhibit List no 

later than Friday, February 26, 2021, at 5:00 p.m. 

(a) Defendant's Witness List - Defendant's Witness List shall include only those 

additional lay and expert witnesses not included on Plaintiff's Witness List. 

Witnesses listed by Plaintiff will be available for both parties and should not be reCase 1:20-cv-22884-FAM Document 9 Entered on FLSD Docket 08/14/2020 Page 2 of 5
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listed on Defendant's Witness List. Defendant's Witness List shall briefly describe 

the nature of each additional witness’ testimony and whether such witnesses will 

be testifying live or by deposition. Witnesses omitted from Defendant's Witness 

List and not listed on Plaintiff's Witness List will not be allowed at trial.

(b) Defendant's Exhibit List - Defendant's Exhibit List shall include only those 

additional exhibits that Defendant wishes to introduce at trial which are not on 

Plaintiff's Exhibit List. Defendant's Exhibit List shall in consecutively numbered 

paragraphs adequately describe the nature of each document listed. The actual 

exhibits shall be pre-marked with corresponding numbers (e.g. Defendant's Exhibit 

#1, Defendant's Exhibit #2, etc.) which numbers they will retain through the end of 

trial. The exhibit list shall refer to specific items and shall not include blanket 

statements such as all exhibits produced during depositions or Defendant reserves

the use of any other relevant evidence. Exhibits omitted from Defendant's Exhibit 

List and not listed on Plaintiff's Exhibit List will not be allowed at trial.

(4) Pretrial Stipulation – Pursuant to Local Rule 16.1.E, the parties shall file a Pretrial 

Stipulation no later than Tuesday, March 2, 2021. The Pretrial Stipulation shall conform to the 

requirements of Local Rule 16.1.E. The parties shall attach to the Pretrial Stipulation copies of 

the witness and exhibit lists along with any objections allowed under Local Rule 16.1.E.9. A 

pending motion for continuance shall not stay the requirement for filing of a Joint Pretrial 

Stipulation.

(5) Continuance / Settlement – To the extent that the parties request modification of any date 

in this Court’s Scheduling Order, the parties shall file either a Motion to Continue Trial or a Motion 

to Continue Pretrial Deadlines. A stipulation of settlement must also be in writing. See Local 

Rule 7.1.4. Unless the Court grants the motion in writing, counsel must appear at the Calendar 

Call.

(6) Motions – When submitting motions, the parties shall submit a proposed order only for 

those motions listed in Local Rule 7.1.A.1.

(7) Depositions – Depositions are limited to seven hours during one day absent court order or 

agreement of the parties and any affected non-party witnesses. See Local Rule 26.1K.

(8) Summary Judgment – The practice of filing multiple motions for partial summary 

judgment which are collectively intended to dispose of the case (as opposed to one comprehensive 

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motion for summary judgment) in order to evade memorandum page-limitations is specifically 

prohibited. See Administrative Order 97-06 (S.D. Fla. Jan. 31, 1997) (amending Local Rule 

7.1.C.2). 

DONE AND ORDERED in Chambers at Miami, Florida, this 14th of August 2020.

______________________________________

FEDERICO A. MORENO

UNITED STATES DISTRICT JUDGE

Copies furnished to:

Counsel of Record

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