IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT HILLSBOROUGH COUNTY, FLORIDA GENERAL CIVIL DIVISION ____________________________ Plaintiff(s), CASE NO.:______________________ v. DIVISION: _____________________ ____________________________. Defendant(s). _________________________________/ UNIFORM ORDER SETTING CAUSE FOR TRIAL AND PRETRIAL (JURY TRIAL) (Revised ­ July 1, 2013) This cause being at issue, it is hereby ORDERED AND ADJUDGED: 1. The above-entitled cause is hereby set for JURY TRIAL during the week(s) of ______________________________________, commencing at ________________, or as soon thereafter as the cause may be heard. 2. A PRETRIAL CONFERENCE shall be held in Chambers before the Honorable ____________________________, Circuit Judge, George Edgecomb Courthouse, 800 E. Twiggs Street, Room _______, Tampa, Florida 33602, on ___________________________, at _________ AM / PM, in accordance with Florida Rule of Civil Procedure 1.200. 3. At least 120 days before the Pretrial Conference, counsel for the Plaintiff shall furnish to counsel for the Defendant and file directly with the Clerk, a list of the names and addresses of all witnesses, including expert witnesses and rebuttal witnesses, who are expected to testify at the trial of this cause. At least 90 days before the Pretrial Conference, counsel for the Defendant shall furnish to counsel for Plaintiff, and file directly with the Clerk, a list of names and addresses of all witnesses, including expert American LegalNet, Inc. www.FormsWorkFlow.com witnesses and rebuttal witnesses, who are expected to testify at the trial of this cause. Each party's witness list shall specifically designate all expert witnesses and with respect to each expert witness, each party shall disclose the expert's area of expertise, and serve a copy of each expert's reports or answers to expert interrogatories. With respect to each disclosed expert witness, the disclosing party shall provide to all other parties, not less than five (5) proposed deposition dates. In the absence of answers to expert interrogatories or an expert report, a party shall provide a summary of the testimony the expert is expected to provide. 4. Counsel shall complete all discovery, including expert discovery in accordance with Florida Rule of Civil Procedure 1.280(b)(4), at least 30 days prior to the Pretrial Conference. Discovery conducted after this time period is strongly disfavored and shall be permitted by order of the Court only under exceptional circumstances. 5. All compulsory medical examinations (CME) shall be completed no later than 60 days prior to the Pretrial conference, with a report in accordance with Florida Rule of Civil Procedure 1.360(b) served on Plaintiff's counsel no later than 15 days after the CME is conducted. 6. All dispositive motions and motions filed pursuant to section 90.702, Florida Statutes (Daubert challenges), shall be filed not later than 45 days before the Pretrial Conference and must be scheduled for hearing prior to the Pretrial Conference. All other motions shall be filed and heard prior to the Pretrial Conference. All motions other than motions in limine not heard before the Pretrial Conference shall be deemed abandoned. Motions in limine shall be filed not less than 30 days prior to the trial and shall be scheduled for hearing on or before the Friday before trial. Objections raised in depositions expected to be introduced at trial shall be filed with the Court prior to the Pretrial Conference. Those objections shall be scheduled for hearing on or before the Friday before trial. 7. The attorneys for all parties are directed to meet together by agreement initiated by counsel for the Plaintiff, no later than 10 days before the Pretrial conference, to: a) Mark all exhibits for identification; b) Prepare an exhibit list for the Clerk and Court (actual exhibits and documentation evidence shall be available for inspection at this time); Page 2 American LegalNet, Inc. www.FormsWorkFlow.com c) Stipulate to the admission into evidence or list specific objections, if any, to each proposed exhibit; d) Stipulate as to any matter of fact and law about which there is no issue to avoid unnecessary proof; e) Review all depositions which are to be offered for any purpose other than impeachment to resolve objections to the portions to be offered in evidence; f) Discuss the possibility of settlement; g) Submit an itemized statement of special damages Plaintiff expects to prove; h) Discuss and complete any other matters which may simplify the issues or aid in the speedy disposition of this action, its Pretrial Conference and Trial; and i) Draft one Pretrial Conference Order (using the form order located at the Court website www.fljud13.org), signed by all participating counsel, that shall be submitted directly to the Court at least 3 days prior to the Pretrial Conference. If the parties are unable to agree on a matter in the Pretrial Conference Order, the matter will be resolved at the Pretrial Conference. 8. The parties shall submit the cause to mediation or arbitration which shall be completed prior to the Pretrial Conference unless waived by the Court. 9. Instructions and verdict forms shall be submitted to the Court no later than the Pretrial Conference. Each instruction shall be on a separate sheet of paper. Counsel shall confer prior to the Pretrial Conference as to any agreement they can reach on the instructions and verdict forms and advise the court at the Pretrial Conference. So the Court may provide the jury with a set of written jury instructions for consideration during deliberations, the parties shall provide the Court at trial a clean copy of the requested instructions for each juror and alternate and a proposed verdict form (not numbered and with no designation as to the requesting party or citations to supporting authority). 10. Counsel shall be prepared to negotiate settlement at the Pretrial Conference and have full authority to settle the case or have available at the conference a party or representative who does have full authority to settle. Page 3 American LegalNet, Inc. www.FormsWorkFlow.com 11. Failure to comply with the requirements of this Order shall subject counsel and the parties to such sanctions as the Court shall determine just and proper under the circumstances. 12. The parties shall do all things reasonable and necessary to assure the availability of their witnesses for the entire trial period or to other