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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

www.flsb.uscourts.gov

In re:

CHRISTI LEE STRAUB

Debtor.

/

Case Number: 21-13230-EPK

Chapter 7

CHRISTI LEE STRAUB

Plaintiff,

Adversary Number: 21-01155-MAM

vs.

MISSOURI HIGHER EDUCATION LOAN

AUTHORITY, DEPARTMENT OF 

EDUCATION OF THE UNITED STATES, 

AND THE UNIVERSITY OF MINNESOTA

Defendants.

/

ORDER SETTING FILING AND DISCLOSURE 

REQUIREMENTS FOR PRETRIAL AND TRIAL

Mindy A. Mora, Judge

United States Bankruptcy Court

_____________________________________________________________________________

ORDERED in the Southern District of Florida on December 5, 2022.

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To expedite and facilitate the trial of this adversary proceeding, in accordance with Fed. 

R. Civ. P. 16, made applicable here by Fed. R. Bankr. P. 7016, after having held a 

scheduling conference, it is ORDERED as follows:

1. ATTENDANCE AT PRETRIAL CONFERENCE. Unless judgment has been 

entered or the Court advises the parties that the pretrial conference has been 

continued or canceled, counsel for all parties (or the parties themselves, if 

unrepresented) must appear at the pretrial conference. 

2. PRETRIAL CONFERENCE DATE AND TRIAL DATE. The pretrial conference will 

be held at:

Date: June 14, 2023

Time: 10:00 a.m.

Location: The Court shall conduct this Pretrial Conference on June 14, 

2023 at 10:00 a.m. solely by videoconference. To participate in the 

hearing remotely via Zoom (whether by video or by telephone), you 

must register in advance no later than 3:00 p.m., one business day 

before the date of the hearing. To register, click on or enter the 

following registration link in a browser:

https://www.zoomgov.com/meeting/register/vJItdumqrzstGdoBW4nz

6tq3IJmn8ydPxj4.

If a party is unable to register online, please contact Maria Romaguera, 

Courtroom Deputy, at 561-514-4109 or 

email Maria_Romaguera@flsb.uscourts.gov.

All participants must observe the formalities of the courtroom, 

exercise civility, and otherwise conduct themselves in a manner 

consistent with the dignity of the Court. This includes appropriate 

courtroom attire.

At the pretrial conference, the Court will set the trial of this adversary proceeding.

3. CONTINUANCES. Continuances of the pretrial conference or trial or any 

deadlines set forth in this order must be requested by written motion. Any request 

for continuance or amendment to this order must set forth the status of discovery, 

including exchange of disclosures required under this order, must state the 

reasons why the party or parties seek a continuance, and must state whether the 

client and other parties consent to a continuance. The stipulation of all parties is 

not sufficient grounds, standing alone, for a continuance.

4. DEADLINES TO JOIN ADDITIONAL PARTIES AND TO MOVE TO AMEND 

PLEADINGS. Unless otherwise ordered by the Court, the deadlines to join 

additional parties and to file motions to amend the pleadings are 14 days* before 

the pretrial conference.

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5. DEADLINES FOR DISPOSITIVE AND OTHER PRETRIAL MOTIONS. The 

deadlines for filing motions for judgment on the pleadings, motions for summary 

judgment, motions in limine, and Fed. R. Evid. 702 motions are 14 days* before 

the pretrial conference. Absent good cause, failure to file and serve such a motion 

in a timely manner constitutes waiver of the right to do so. All dispositive motions, 

responses, and replies must comply with the page limits set forth in the Order 

Setting Scheduling Conference and Establishing Procedures and Deadlines. Any 

motion for summary judgment must also comply with paragraph 8 of the Order 

Setting Scheduling Conference and Establishing Procedures and Deadlines –

including the requirement to file a separate Statement of Material Facts and Local 

Rule 7056−1, if applicable.

6. DISCLOSURES. The disclosures required by Fed. R. Civ. P. Rules 26(a)(1), 

26(a)(2), and 26(a)(3)(A) must be made by the following deadlines:

a. The initial disclosures required by Fed. R. Civ. P. 26(a)(1), must be made not 

later than 14 days* after entry of this Order.

b. The disclosures of expert testimony under Fed. R. Civ. P. 26(a)(2), must be 

made (i) at least 60 days* before the pretrial conference or (ii) within 14 days* 

after an opposing party’s disclosure of evidence that gives rise to the need for 

the expert, whichever is later. The party disclosing an expert witness must, 

within 14 days* of the disclosure, provide to each opposing party a written 

report prepared and signed by the witness as required by Fed. R. Civ. P.

26(a)(2)(B).

c. The pretrial disclosures under Fed. R. Civ. P. 26(a)(3)(A), must be made no 

later than one business day before the pretrial conference. 

d. All disclosures under Fed. R. Civ. P. 26(a)(1), 26(a)(2), and 26(a)(3)(A), must 

be made in writing, signed, served, and, except for copies of exhibits and expert 

witness reports, filed with the Court.

7. SUMMARIES TO PROVE CONTENT. If any party intends to offer in evidence at 

trial a summary, chart or calculation to prove content as permitted by Fed. R. Evid. 

1006, that party must provide to the other parties a notice of the location(s) of the 

books, records, and the like, from which each summary has been made, and the 

reasonable times when they may be inspected and copied by adverse parties, as 

soon as practicable but in no event later than seven days before the pretrial 

conference.

8. DISCOVERY. The parties must complete discovery not later than 14 days* before 

the pretrial conference, except that any previously scheduled depositions may be 

completed up to one business day before the pretrial conference. The Court will 

allow discovery after the pretrial conference only upon a showing of good cause. 

 ∗ This deadline is the default and minimum deadline required by the Court, however the parties are free to agree to 

and propose any other reasonable deadline, subject to Court approval at the Scheduling Conference.

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9. JOINT PRETRIAL STIPULATION WHERE ALL PARTIES REPRESENTED BY 

COUNSEL. If any party is not represented by counsel in this proceeding as of the 

date of entry of this Order, this paragraph will not apply. All parties to this 

proceeding must meet (in person, if geographically feasible, and otherwise by 

video conference or by telephone) not later than 14 days before the pretrial 

conference to confer on the preparation of a Joint Pretrial Stipulation in 

substantially the form of Local Form 63C. The plaintiff must file the fully executed 

Joint Pretrial Stipulation no later than one business day before the pretrial 

conference. The Court will not accept unilateral statements and will strike sua

sponte any such submissions. Should any of the parties fail to cooperate in the 

preparation of the Joint Pretrial Stipulation, any other party may file a motion 

requesting an order to show cause why such party or parties (and/or their counsel) 

should not be held in contempt and sanctioned for failure to comply with this order. 

10.SUBMISSION AND EXCHANGE OF EXHIBITS. 

a. All parties must comply with the requirements regarding exhibits set forth in 

Local Rule 9070-1. 

b. OBJECTIONS TO EXHIBITS. Any objection to the admissibility of any 

proposed exhibit must be filed and served, so as to be received not later than 

4:00 p.m. two business days before trial. Objections to any deposition 

transcripts, including a recording (audio or video) or summary thereof, must 

follow the procedure specified in this paragraph: 

(1) The objection must: (a) identify the exhibit, (b) state the grounds for the 

objection, and (c) provide citations to case law and other authority in 

support of the objection. 

(2) An objection not so made − except for one under Fed. R. Evid. 402 or 403 

− is waived unless excused by the Court for good cause. 

11.PRESENTATION OF EXHIBITS DURING TRIAL. The parties are strongly 

encouraged to use the Court’s information technology equipment to show exhibits 

at trial. The parties are further encouraged to contact the courtroom deputy in 

advance of the trial for access to the equipment to ensure counsel can properly 

use the equipment at trial. Unless otherwise ordered, each party must bring at least 

one paper copy of its exhibit register for the Court’s use, and at least two hardcopy books of all its exhibits, for witnesses and the Court.

12.FINAL ARGUMENT. At the conclusion of the trial, in lieu of final argument, the 

Court may request that each party file with the Court (a) a written closing statement 

with supporting legal argument or (b) a proposed memorandum opinion with 

findings of fact and conclusions of law with a separate proposed final judgment. 

Each submission must contain individually numbered paragraphs and follow the 

formatting requirements set forth in Part Two of the Court’s Guidelines for 

Preparing, Submitting, and Serving Orders. Each proposed finding of fact must be 

supported by a citation to the record, or it will be disregarded. Each proposed 

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conclusion of law must be supported by a citation to applicable law, or it will be 

disregarded. Absent prior permission of the Court, submissions may not exceed a 

total of twenty pages. If specifically requested, the Court may also direct the 

parties to submit a copy of the proposed memorandum opinion with findings of fact 

and conclusions of law, along with a copy of the separate proposed final judgment, 

in word processing format to an electronic mailbox designated by the Court. The 

filer must include in the “subject” line of the email the case name and number and 

the date of the relevant hearing. 

13.FAILURE TO ATTEND PRETRIAL CONFERENCE; SANCTIONS. Failure to 

comply with any provision of this order or failure to appear at the pretrial conference 

may result in appropriate sanctions, including the award of attorney’s fees, striking 

of pleadings, dismissal of the action, or entry of default judgment. 

14.SERVICE. Plaintiff(’s)(s’) counsel must serve a copy of this Order on the 

defendant(s) and file an appropriate certificate of service in accordance with Local 

Rule 5005-1(G)(2). 

# # #

Submitted by:

Chad T. Van Horn, Esq.

Florida Bar No. 64500

VAN HORN LAW GROUP, P.A.

500 NE 4th St., Suite 200 

Fort Lauderdale, FL 33301 

Telephone: (954) 765-3166

Facsimile: (954) 756-7103 

Email: Chad@cvhlawgroup.com

Chad Van Horn, Esq. is hereby directed to provide a conformed copy of this Order to all 

parties-in-interest and to file a Certificate of Service as to same.

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