UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 20-cv-61693-WPD

FRANK DEMARZO,

Plaintiff,

v.

HEALTHCARE TRUST OF AMERICA, 

INC., a Foreign Profit Corporation, 

Defendant.

____________________________________/

JOINT SCHEDULING REPORT

Plaintiff, FRANK DEMARZO, and Defendant, HEALTHCARE TRUST OF AMERICA, 

INC, by and through their undersigned attorneys and pursuant to this Court’s Order Requiring 

Joint Scheduling Report [DE 3] and S.D. Fla. L.R. 16.1(b)(3), hereby jointly file their Joint 

Scheduling Report, and state as follows:

1. Local Rule 16.1.B.2

A. A discussion of the likelihood of settlement. 

At this point in the litigation the parties have been unable to amicably resolve the claim. 

Settlement negotiations will be ongoing. The parties will endeavor to resolve this matter 

as expeditiously as possible and propose a mediation conference. 

B. A discussion of the likelihood of appearance in the action of additional parties. 

Plaintiff seeks to amend his Complaint to name South Florida Construction Associates, 

Inc. (“South Florida Construction”) as an additional party Defendant to this action.

C. A discussion on proposed limits on the time:

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i. To join other parties and to amend the pleadings: 

See attached Scheduling Timeline (Attachment A).

ii. To file and hear motions:

See attached Scheduling Timeline (Attachment A).

iii. To complete discovery:

See attached Scheduling Timeline (Attachment A).

D. A proposal for the 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. 

At this time, the parties have no specific proposals for the formulation and simplification 

of issues, though the parties agree to continue to work in good faith to simplify all issues, 

claims and defenses in this action. The parties agree to stipulate as to the authenticity of 

documents where practicable. 

E. The necessity or desirability of amendments to the pleadings.

Plaintiff seeks to amend his Complaint to name South Florida Construction Associates, 

Inc. (“South Florida Construction”) as an additional party Defendant to this action.

F. A discussion of possible admissions of fact and documents which will avoid 

unnecessary proof; of possible stipulations regarding the authenticity of documents; 

and of the need for advance rulings from the Court on the admissibility of evidence. 

The parties state that they will work in good faith to obtain admissions of fact and 

stipulations regarding the authenticity of documents, electronically stored information or 

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things. The parties are not presently aware of a need for advance rulings from the Court 

on the admissibility of any evidence.

G. Suggestions for the avoidance of unnecessary proof and of cumulative evidence. 

The parties will confer in an effort to come to agreements to avoid unnecessary proof and 

cumulative evidence, including potential stipulations to the authenticity of documents 

received via subpoena or through discovery. 

H. Suggestions on the advisability of referring matters to a magistrate judge or master.

At this time, the parties have agreed to refer only discovery matters to a U.S. Magistrate 

Judge. However, as to any discovery matters heard by a U.S. Magistrate Judge, including 

those referred by this Court, the parties reserve their right to object and/or appeal 

decisions of the U.S. Magistrate Judge pursuant to Fed. R. Civ. P. 53, 72, or any other 

applicable procedural rule or statute.

I. A preliminary estimate of the time required for trial.

The parties estimate that the trial will take three (3) to four (4) days. 

J. Requested date or dates for conferences before trial, a final pretrial conference, and 

trial.

Please see Attachment “A.”

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

status or pretrial conference. 

None at this time.

Case 0:20-cv-61693-WPD Document 13 Entered on FLSD Docket 10/01/2020 Page 3 of 4
By: /s/ Megan Pariti

Megan Pariti, Esq.

Fla. Bar No.: 1002533

Thomas W. Paradise, Esq.

Fla. Bar No.: 907235

Vernis & Bowling of Broward, P.A.

5821 Hollywood Boulevard

Hollywood, FL 33021

(954) 927-5330

(954) 927-5320 (Fax)

mpariti@florida-law.com; sgalvan@florida-law.com

tparadise@florida-law.com; agarwood@florida-law.com

Attorneys for Defendant, Target Corporation

By:___/s/ Marc Lyons_________________

Marc Lyons, Esq.

Fla. Bar No.:804601

Lyons Snyder Colin, P.A.

1250 South Pine Island Road, Suite 200

Plantation, FL 33442

(954) 462- 8035

pi_filings@lyonssnyder.com

Attorney for Plaintiff

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served on 

October 1, 2020 to: Marc Lyons, Esquire [marc@lyonssnyder.com; 

pi_filings@lyonssnyder.com; natalia@lyonssnyder.com; vanessa@lyonssnyder.com].

Vernis & Bowing of Broward, P.A.

5821 Hollywood Boulevard

Hollywood, FL 33021

(954) 927-5330

(954) 927-5320 (Fax)

By: _/s/ Megan Pariti

Megan Pariti, Esq.

Fla. Bar No.: 1002533

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