Smith v. Acme Corp • Judge Thompson • Case No. 2024-CV-1234
Due Jan 15 • Filed Jan 12
Due Feb 15
3 of 5 items complete
Due Mar 30
Due May 15
Due Jun 30
Aug 15, 2024
Due January 15, 2024 • Filed January 12, 2024
Drafted initial disclosure document
Jan 5 • Listed all witnesses and documents
Client review and approval
Jan 8 • Phone call with client
Served on opposing counsel
Jan 12 • Via email and certified mail
Filed with Court
Jan 12 • E-filed via Florida Courts E-Filing Portal
Due February 15, 2024
Success Criteria
Request sent to Dr. Martinez
Jan 20 • Letter sent via certified mail
Request sent to Memorial Hospital
Jan 20 • HIPAA authorization included
Records received from Dr. Martinez
Feb 1 • 47 pages
Review findings with client
SCHEDULEDFeb 8, 2024 at 2:00 PM • Office Meeting
Awaiting records from Memorial Hospital
Follow up sent Feb 3
Compile and organize all records
Blocked by hospital records
Due March 30, 2024
Success Criteria
Received Interrogatories from Defense
Jan 28 • 25 interrogatories
Received Request for Production from Defense
Jan 28 • 15 document requests
Client meeting to answer interrogatories
SCHEDULEDFeb 12, 2024 at 10:00 AM • Office Meeting
Draft responses to interrogatories
After client meeting
Gather documents for production
Need client photos, employment records
Serve our Interrogatories on Defense
Draft in progress
Due May 15, 2024
Pending Motion May Affect Scheduled Deposition
Defense filed Motion for Protective Order on Feb 20. Hearing scheduled for March 5.
Success Criteria
Deposition of Plaintiff (John Smith)
PENDING MOTIONMarch 15, 2024 at 10:00 AM • May be affected by protective order
Motion for Protective Order
MOTIONFiled Feb 20 by Defense • Hearing: March 5
Hearing: Motion for Protective Order
HEARINGMarch 5, 2024 at 2:00 PM • Courtroom 4B
Deposition of Defendant Driver
Need to notice
Deposition of Eyewitness (Sarah Johnson)
Need to notice
Prepare client for deposition
Schedule prep session before depo date
Due June 30, 2024
Success Criteria
Identify medical expert
Orthopedic specialist for injury causation
Identify accident reconstruction expert
If needed based on liability dispute
Obtain expert reports
Allow 4-6 weeks for report preparation
Draft expert disclosure document
Include CV, opinions, basis for opinions
Note: Expert selection should happen after depositions reveal the defense's theory of the case. Budget approximately $3,000-5,000 for medical expert.
August 15, 2024
Aug 15
2024
Circuit Court, Courtroom 4B
Judge Thompson presiding
Estimated duration: 3-5 days
Pre-trial conference
Usually 2-4 weeks before trial
Exchange exhibit lists
Per CMO requirements
Exchange witness lists
Per CMO requirements
File motions in limine
Exclude prejudicial evidence
Prepare jury instructions
Standard PI instructions + case-specific
Trial preparation with client
Testimony prep, courtroom expectations
Settlement consideration: Most cases settle before trial. Mediation typically occurs after discovery is complete. Consider scheduling mediation 60-90 days before trial.