UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 22-cv-62268-BLOOM/Valle

JESSE IWUJI MOTORSPORTS, LLC, 

Plaintiff, 

v. 

EQUITY PRIME MORTGAGE, LLC, 

Defendant. 

_________________________________/ 

ORDER SCHEDULING TRIAL

AND ORDER OF INSTRUCTIONS BEFORE CALENDAR CALL

This cause is set for trial during the Court’s two-week trial calendar beginning on May 20, 

2024 at 9:00 a.m. at the United States Courthouse, 400 North Miami, Avenue, Courtroom 

10-2, Miami, Florida. The parties shall appear before the Court for calendar call at 1:45 p.m. on 

Tuesday, May 14, 2024. In order to allow the parties to properly prepare for trial and ensure an 

efficient trial schedule, it is ORDERED AND ADJUDGED as follows: 

By April 29, 2024, the parties shall prepare and file the following:

(1) Deposition Filings and Designations 

Deposition designations that advise of the deposition portions to be used at trial by 

designating the page and line of each deposition. Any objections or counter-designations and 

copies of all depositions to be used shall be filed by May 3, 2024. 

By May 6, 2024, the parties shall prepare and file the following materials:

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(2) Pretrial Stipulation in Accordance with Local Rule 16.1(e) 

(3) Neutral Statement of Case and List of Witnesses for Venire Panel 

(A) A joint concise, neutral statement of the case that can be read to the venire panel 

prior to voir dire to apprise the panel of the subject matter involved in the case. The joint concise 

statement shall address the positions of each party to this litigation in a succinct and neutral 

manner.

(B) A joint list of all witnesses that will be called at trial. This list shall provide the 

full name of the witness and succinct identifying information, such as area of residence or 

employment affiliation, to help the prospective jurors determine whether they recognize a potential 

witness. 

(4) Voir Dire Questions

Any proposed voir dire questions that the parties would like the Court to ask the 

venire panel. 

(5) Exhibit Notebooks

If the parties do not plan to use the ELMO or a laptop to publish exhibits, they shall prepare 

Exhibit Notebooks. The Exhibit Notebooks shall contain three divisions. The first division shall 

contain the parties’ joint exhibits which both parties intend to use at trial; the second division shall 

contain Plaintiff=s exhibits; and the third division shall contain Defendants’ exhibits. Each division 

shall be clearly and adequately designated (tabbed) and each exhibit appropriately labeled. Any 

composite exhibits shall include page numbers for each page of the exhibit for ease of reference. 

At the time of jury selection, the parties shall be required to provide at least fourteen (14)

copies of the Exhibit Notebook: one for each of the eight jurors, one for the Court, one for the 

witness stand, one for the Court Reporter, one for the Law Clerk, and one for each of the parties. 

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At the opening of trial, the jurors’ Exhibit Notebooks shall contain all exhibits from the three 

divisions described above to which there are no objections. As to the remaining exhibits to which 

there are objections, Counsel shall have sufficient tabbed, hole-punched copies of each exhibit to 

give to the jurors for addition to their Notebooks in the event the exhibit is admitted into evidence. 

The Notebooks for the Court, witness stand, court reporter and parties should include all exhibits, 

even those to which there may be objections and an exhibit index for each of the three sections. 

(6) Jury Instructions and Verdict Form 

Proposed jury instructions and verdict form in Word format to chambers via e-mail, 

bloom@flsd.uscourts.gov. The parties shall submit their proposed jury instructions jointly, though 

they need not agree on each proposed instruction. Additionally, the parties are instructed to include 

a notetaking instruction. Where the parties do not agree on a proposed instruction, that instruction 

shall be set forth in bold type. Instructions proposed only by a plaintiff shall be underlined. 

Instructions proposed only by a defendant shall be italicized. Every instruction must be supported 

by citation to authority. The parties shall use as a guide the Eleventh Circuit Pattern Jury 

Instructions for Civil Cases, including the directions to counsel contained therein. 

(7) Witness Lists and Exhibit Lists

(A) Witness Lists: Revised Witness Lists that include the estimated time for direct 

and cross-examination of each of the witnesses, taking into account the time necessary for 

translation. This list shall include each anticipated impeachment witness.

(B) Exhibit Lists: Revised exhibit lists. Prior to filing the lists, the parties shall meet 

and confer to resolve as many issues as possible regarding the other’s exhibits. Any remaining 

objections shall be reflected on the exhibit list identifying the legal basis for the objection. The 

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parties are instructed to have each exhibit objected to with them at calendar call for review and 

ruling. 

(8) Stipulated Facts

The parties shall discuss all items not in dispute and file a list of stipulated facts.

(9) Demonstrative and Summary Exhibits 

If the parties desire to use demonstrative exhibits during trial (including photos, diagrams 

or time-lines and the like), each such item must be disclosed to the opposing party. No 

demonstrative exhibit may be displayed absent prior written agreement between the parties or, 

absent such agreement, prior approval by the Court. 

(10) Translators

(A) Exhibits: Exchange exhibit translations and attempt to resolve any issues 

regarding the translations. If the parties are unable to resolve the issues, they shall file a notice 

with the Court explaining the remaining issues and setting out each sides’ proposed resolution to 

the remaining issues. 

(B) At Trial: Prior to calendar call, the parties shall confer and agree on a single 

translator service for the trial. The parties shall split the cost of the service. The service must be 

federal court certified and must be able to provide a team of translators for the trial so that 

translators can switch every 30-40 minutes during the trial. 

At the Calendar Call:

(11) Computers and Other Equipment 

Parties desiring to utilize laptop computers or other electronic equipment in the courtroom 

shall file a motion and submit a proposed order granting such use. The motion and proposed order 

should describe with specificity (1) the equipment, (2) the make and model of the equipment, and 

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(3) the identity of the person who will bring the proposed equipment. A sample order permitting 

electronic equipment into the courtroom is available for viewing on the Court’s website at: 

http://www.flsd.uscourts.gov. Counsel shall contact the courtroom deputy at least one week prior 

to trial to discuss any special equipment (video monitor, etc.) that may require special 

arrangements.

(12) Opening and Closing Statements 

The parties should be prepared to tell the Court how long they each will need for their 

opening and closing statements. 

(13) The Rule Against Witnesses in the Courtroom 

Excepting the parties or their designated corporate representative, any witness who may 

testify in this case is precluded from the courtroom at any time prior to their testimony. Each party 

shall bring to the Court’s attention the appearance of any witness in the courtroom which violates 

this rule.

(14) Copies to Court Reporter 

The parties shall provide to the Official Court Reporter copies of: (a) the final witness and 

exhibit lists; and (b) a list of all names and other proper nouns material to the disposition of the 

case that are likely to be raised at trial.

No later than the Friday before trial by 3 p.m.: 

(15) Notice of Settlement

The parties must notify the Court if the parties settle this matter before trial.

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No later than ten (10) days following the conclusion of the trial: 

(16) Exhibits Post-Trial

The parties shall electronically file all exhibits admitted into evidence in their original or, 

if altered during trial, in their altered state. At the close of all of the evidence, the parties shall 

provide an index reflecting the admitted exhibits. 

DONE AND ORDERED in Chambers at Miami, Florida, on March 15, 2024. 

_________________________________ 

BETH BLOOM

UNITED STATES DISTRICT JUDGE

Copies to: 

Counsel of Record 

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