From U.S. District Court website, pacer.gov:
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
JACKSONVILLE DIVISION
ROBINSON IMPROVEMENT COMPANY,
a Florida corporation
Plaintiff,
Case No. 3:25-cv-01275-TJC-LLL
v.
ST. JOHNS COUNTY, FLORIDA
Defendant.
_______________________________/
Uniform Case Management Report
The goal of this case management report is to “secure the just, speedy, and
inexpensive determination of” the action. See Fed. R. Civ. P. 1. Under Local Rule
3.02(a)(2), this case management report should be used in all civil cases except those
described in Local Rule 3.02(d). Individual judges may have additional case
management preferences that can be found under each judge’s name on the Court’s
website, flmd.uscourts.gov/judges/all.
1. Date and Attendees
The parties may conduct the planning conference “in person, by telephone, or by
comparable means[.]” See Local Rule 3.02(a)(1).
The parties conducted the planning conference on 3/5/2026. Zach Miller, Esq. for
the Plaintiff and Jennifer C. Barron, Esq. for Defendant attended the conference.
2. Deadlines and Dates
The parties request these deadlines and dates:
Action or Event Date
Deadline for providing mandatory initial disclosures. See Fed. R. Civ.
P. 26(a)(1). 5/1/2026Case 3:25-cv-01275-TJC-LLL Document 20 Filed 03/10/26 Page 2 of 6 PageID 401
Deadline for moving to join a party, see Fed. R. Civ. P. 14, 19, and 20,
or amend the pleadings, see Fed. R. Civ. P. 15(a). 8/1/2026
Deadline for serving expert disclosures under Rule 26(a)(2),
including any report required by Rule 26(a)(2)(B). Plaintiff Defendant Rebuttal 11/1/2026
12/1/2026
3/1/2027
Deadline for completing discovery and filing any motion to compel
discovery. See Fed. R. Civ. P. 37; Middle District Discovery (2021).
2/1/2027
Deadline for moving for class certification, if applicable. See Fed. R.
Civ. P. 23(c).
N/A
Deadline for filing any dispositive and Daubert motion. See Fed. R. Civ.
P. 56. (Must be at least five months before requested trial date.) 3/1/2027
Deadline for participating in mediation. See Local Rules, ch. 4.
The Parties shall work in good faith to select a mediator.
4/1/2027
Date of the final pretrial meeting. See Local Rule 3.06(a). 8/15/2027
Deadline for filing the joint final pretrial statement, any motion in
limine, proposed jury instructions, and verdict form. See Local Rule
3.06(b). (Must be at least seven days before the final pretrial conference.)
8/22/2027
Date of the final pretrial conference. See Fed. R. Civ. P. 16(e); Local
Rule 3.06(b). 8/29/2027
Month and year of the trial term. (On declaratory and injunctive relief) 9/1/2027
Per the applicable law, the case is required to be bifurcated between
liability and damages. As such, the parties respectfully request that if
liability is found as to any of the claims that a new case management
report be entered outlining the schedule leading to trial on damages.
The trial will last approximately 5 days and be
☒ jury. (as to damages)
☒ non-jury. (as to declaratory and injunctive relief)
2Case 3:25-cv-01275-TJC-LLL Document 20 Filed 03/10/26 Page 3 of 6 PageID 402
3. Description of the Action
UNLAWFUL GOVERNMENT TAKING (FEDERAL AND STATE), EQUAL
PROTECTION, DUE PROCESS (FEDERAL AND STATE) AND DECLARATORY ACTION
(STATE).
DEFENDANT IS TAKING PLAINTIFF’S PROPERTY WITHOUT JUST
COMPENSATION. DEFENDANT ACTED IN AN ARBITRARY AND
CAPRCIOUS MANNER WITH RESPECT TO PLAINTIFF’S ATTEMPTS
AT SECURING PROPERTY RIGHTS THAT SERVE AS JUST
COMPENSATION FOR THE TAKING. DEFENDANT APPLIED TO
PLAINTIFF CRITERIA THAT IT DID NOT APPLY TO OTHER
SIMILARLY SITUATED APPLICANTS. DEFENDANT HAS
INORDINATELY BURDENED PLAINTIFF’S PROPERTY RIGHTS IN
VIOLATION OF FLORIDA LAW. IN DENYING PLAINTIFF’S
APPLICATION TO SECURE PROPETY RIGHTS THAT SERVE AS JUST
COMPENSATION FOR THE TAKING, DEFENDANT HAS VIOLATED
FLORIDA LAW THAT REQUIRES ZONING TO BE CONSISTENT WITH
ITS LOCAL COMPREHENSIVE PLAN. PLAINTIFF DETRIMENTALLY
RELIED ON ACTIONS AND STATEMENTS BY DEFENDANT
REGARDING PLAINTIFF’S ABILITY TO EXERCISE ITS RIGHTS TO
JUST COMPENSATION FOR THE TAKING.
DEFENDANT DENIES THE ALLEGATIONS.
AS TO THE CLAIMS PRESENTED, THE PARTIES AGREE THAT THE ISSUES ARE
REQUIRED TO BE BIFURCATED BETWEEN THE DECLARATORY AND INJUNCTIVE
RELIEF (WHICH WOULD BE HANDLED AT A BENCH TRIAL) AND IF LIABILITY IS
FOUND AT SAID BENCH TRIAL, THEN A JURY TRIAL ON DAMAGES.
4. Disclosure Statement
☒ Each party has filed a disclosure statement using the required form.
5. Related Action
☒ The parties acknowledge their continuing duty under Local Rule 1.07(c) to
notify the judge of a related action pending in the Middle District or elsewhere by
filing a “Notice of a Related Action.” No notice need be filed if there are no related
actions as defined by the rule.
3Case 3:25-cv-01275-TJC-LLL Document 20 Filed 03/10/26 Page 4 of 6 PageID 403
6. Consent to a Magistrate Judge
“A United States magistrate judge in the Middle District can exercise the maximum
authority and perform any duty permitted by the Constitution and other laws of the United
States.” Local Rule 1.02(a). With the parties’ consent, a district judge can refer any civil
matter to a magistrate judge for any or all proceedings, including a non-jury or jury trial.
28 U.S.C. § 636(c).
The Court asks the parties and counsel to consider the benefits to the parties and the Court
of consenting to proceed before a magistrate judge. Consent can provide the parties
certainty and flexibility in scheduling. Consent is voluntary, and a party for any reason
can decide not to consent and continue before the district judge without adverse
consequences. See Fed. R. Civ. P. 73(b)(2).
☐ The parties do consent and file with this case management report a completed
Form AO 85 “Notice, Consent, and Reference of a Civil Action to a Magistrate
Judge,” which is available on the Court’s website under “Forms.”
☒ The parties do not consent.
7. Preliminary Pretrial Conference
☒ The parties do not request a preliminary pretrial conference before the Court
enters a scheduling order.
☐ The parties do request a preliminary pretrial conference, and the parties want to
discuss enter discussion points.
8. Discovery Practice
The parties should read the Middle District Discovery Handbook, available on the Court’s
website at flmd.uscourts.gov/civil-discovery-handbook, to understand discovery practice
in this District.
☒ The parties confirm they will comply with their duty to confer with the opposing
party in a good faith effort to resolve any discovery dispute before filing a motion.
See Local Rule 3.01(g); Middle District Discovery (2021) at § I.A.2.
9. Discovery Plan
The parties submit the following discovery plan under Rule 26(f)(2):
4Case 3:25-cv-01275-TJC-LLL Document 20 Filed 03/10/26 Page 5 of 6 PageID 404
A. The parties agree to the timing, form, or requirement for disclosures under
Rule 26(a):
☒ Yes.
☐ No; instead, the parties agree to these changes: enter changes.
B. Discovery may be needed on these subjects: Communications and
materials to and from area residents who spoke against Plaintiff’s proposed
rezoning of the Plaintiff’s Property at various public hearings.
Communications and materials to and from local officials concerning
Plaintiff’s property.
Documentation and communications in Defendant’s possession
concerning Plaintiff’s Property and Plaintiff’s applications to rezone the
Property.
C. Discovery should be conducted in phases:
☐ No.
☒ Yes; Parties request second discovery phase as to damages if
declaratory and injunctive relief is found by the court at summary
judgment or at bench.
D. Are there issues about disclosure, discovery, or preservation of
electronically stored information?
☐ No.
☒ Yes; describe the issue(s). Plaintiff anticipates subpoenaing electronic
communications to and from third parties concerning Plaintiff’s property
and Plaintiff’s applications concerning the property.
E. ☒ The parties have considered privilege and work-product issues,
including whether to ask the Court to include any agreement in an order
under Federal Rule of Evidence 502(d).
F. The parties stipulate to changes to the limitations on discovery imposed
under the Federal Rules of Civil Procedure and Local Rule 3.04 or other
limitations:
☒ No.
☐ Yes; describe the stipulation.
5Case 3:25-cv-01275-TJC-LLL Document 20 Filed 03/10/26 Page 6 of 6 PageID 405
10. Request for Special Handling
☒ The parties do not request special handling.
☐ The parties request special handling. Specifically, describe requested special
handling.
☐ Enter party’s name unilaterally requests special handling. Specifically, describe
requested special handling.
11. Certification of familiarity with the Local Rules
☒ The parties certify that they have read and are familiar with the Court’s Local
Rules.
12. Signatures
Jennifer C. Barron, Esq Jennifer C. Barron, Esq Counsel for Defendant Zach Miller, Esq.
Zach Miller, Esq.
Counsel for Plaintiff
3/10/2026 3/10/2026
6
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