On July 08, 1984 a
was filed
involving a dispute between
Yue, Xiao,
and
Chapp, Inc.,
Foerster, Cynthia,
for CIRCUIT CIVIL
in the District Court of Osceola County.
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Filing # 173128427 E-Filed 05/15/2023 11:12:48 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR OSCEOLA COUNTY, FLORIDA
XIAO SHENG YUE,
Plaintiff,
CASE NO.: 2020-CA-1106AN
v.
CYNTHIA M. FOERSTER AND
CHAPP, INC.,
Defendants.
______________________________/
MOTION FOR CASE MANAGEMENT CONFERENCE AND ALTERNATIVE
MOTION TO EXTEND TRIAL DATE
COME NOW Defendants, CYNTHIA M. FOERSTER and CHAPP, INC., by and through
undersigned counsel and pursuant to applicable Florida Rules of Civil Procedure and Florida law,
hereby file their Motion for Case Management Conference and Alternative Motion to Extend Trial
Date and in support thereof state as follows:
1. This matter stems from an automobile accident occurring on September 11, 2018,
involving Plaintiff, XIAO SHENG YUE (“Plaintiff”), and Defendant, CYNTHIA M. FOERSTER.
2. Trial in this matter is set on the June 12, 2023 trial docket per this Court’s verbal
ruling at the April 17, 2023 Case Management Conference. This case was previously continued
from the March 20, 2023 and March 21, 2022 trial dockets.
3. The parties have been working collaboratively to coordinate the discovery and
video depositions for trial of Defendants’ three medical experts. The depositions have been
scheduled and rescheduled numerous times for various and sundry reasons. As of the date of this
motion, the video depositions of Defendants’ two CME experts have not been scheduled despite
the parties’ best efforts (the video deposition for trial of Defendants’ radiology expert is scheduled
for June 7, 2023).
4. The Defendants seek this Court’s guidance and resolution on this issue at a case
management conference. Alternatively, the Defendants request a short extension of the trial date
in order to schedule the remaining video depositions for trial to ensure a more orderly and
efficient presentation at trial.
WHEREFORE, Defendants, CYNTHIA M. FOERSTER and CHAPP, INC., respectfully
request a case management conference to resolve the issue of deposition date and, in the
alternative, request a short extension of the trial date as indicated above and for any other relief
the Court deem just and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that, on this 15th day of May, 2023, I electronically filed the
foregoing with the Clerk of the Court via the Florida Courts’ e-Filing Portal, pursuant to and in
compliance with Rule 2.516, Florida Rules of Judicial Administration, which completes service
by furnishing a true and correct copy of the foregoing via electronic mail to all counsel of record.
LAW OFFICES OF SANTEIRO & GARRISON
/s/ Jorge Santeiro, Jr.
Jorge Santeiro, Jr.
FBN 66230
6300 University Parkway
Suite 101
Sarasota, FL 34240
Tel: (800) 226-3224 Ext. 1021
Primary: jsanteiro@fcci-group.com
Secondary: ssmith5@fcci-group.com
Secondary: legalservice@fcci-group.com
Attorney for Defendants
Document Filed Date
November 02, 2023
Case Filing Date
July 08, 1984
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Filing # 173128427 E-Filed 05/15/2023 11:12:48 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA XIAO SHENG YUE, Plaintiff, CASE NO.: 2020-CA-1106AN v. CYNTHIA M. FOERSTER AND CHAPP, INC., Defendants. ______________________________/ MOTION FOR CASE MANAGEMENT CONFERENCE AND ALTERNATIVE MOTION TO EXTEND TRIAL DATE COME NOW Defendants, CYNTHIA M. FOERSTER and CHAPP, INC., by and through undersigned counsel and pursuant to applicable Florida Rules of Civil Procedure and Florida law, hereby file their Motion for Case Management Conference and Alternative Motion to Extend Trial Date and in support thereof state as follows: 1. This matter stems from an automobile accident occurring on September 11, 2018, involving Plaintiff, XIAO SHENG YUE (“Plaintiff”), and Defendant, CYNTHIA M. FOERSTER. 2. Trial in this matter is set on the June 12, 2023 trial docket per this Court’s verbal ruling at the April 17, 2023 Case Management Conference. This case was previously continued from the March 20, 2023 and March 21, 2022 trial dockets. 3. The parties have been working collaboratively to coordinate the discovery and video depositions for trial of Defendants’ three medical experts. The depositions have been scheduled and rescheduled numerous times for various and sundry reasons. As of the date of this motion, the video depositions of Defendants’ two CME experts have not been scheduled despite the parties’ best efforts (the video deposition for trial of Defendants’ radiology expert is scheduled for June 7, 2023). 4. The Defendants seek this Court’s guidance and resolution on this issue at a case management conference. Alternatively, the Defendants request a short extension of the trial date in order to schedule the remaining video depositions for trial to ensure a more orderly and efficient presentation at trial. WHEREFORE, Defendants, CYNTHIA M. FOERSTER and CHAPP, INC., respectfully request a case management conference to resolve the issue of deposition date and, in the alternative, request a short extension of the trial date as indicated above and for any other relief the Court deem just and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that, on this 15th day of May, 2023, I electronically filed the foregoing with the Clerk of the Court via the Florida Courts’ e-Filing Portal, pursuant to and in compliance with Rule 2.516, Florida Rules of Judicial Administration, which completes service by furnishing a true and correct copy of the foregoing via electronic mail to all counsel of record. LAW OFFICES OF SANTEIRO & GARRISON /s/ Jorge Santeiro, Jr. Jorge Santeiro, Jr. FBN 66230 6300 University Parkway Suite 101 Sarasota, FL 34240 Tel: (800) 226-3224 Ext. 1021 Primary: jsanteiro@fcci-group.com Secondary: ssmith5@fcci-group.com Secondary: legalservice@fcci-group.com Attorney for Defendants