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  • Heather Grant, et al Plaintiff vs. David Vadillo, et al Defendant Auto Negligence document preview
  • Heather Grant, et al Plaintiff vs. David Vadillo, et al Defendant Auto Negligence document preview
  • Heather Grant, et al Plaintiff vs. David Vadillo, et al Defendant Auto Negligence document preview
  • Heather Grant, et al Plaintiff vs. David Vadillo, et al Defendant Auto Negligence document preview
  • Heather Grant, et al Plaintiff vs. David Vadillo, et al Defendant Auto Negligence document preview
  • Heather Grant, et al Plaintiff vs. David Vadillo, et al Defendant Auto Negligence document preview
						
                                

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Filing# 145371303 E-Filed 03/09/2022 12:47:52 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: 21-009583 (21) HEATHER GRANT, Plaintiff(s), V FRANCISO GABRIEL VADILLO and DAVID VADILLO, Defendant(s). i Jon Zepnick, Esquire George Fernandez, Esquire Ansel & Miller LLC Jaime E. Campos, Esquire 1939 Tyler Street Quintairos, Prieto,Wood & Boyer, P.A. Hollywood, FL 33020 9300 Dadeland Blvd., 4th Floor S. Email: jonzepnick@anselmiller.com; Miami, FL 33156 maketheca1103@aol.com; Email: com rshields@anselmiller. Ivette.galante@qpwblaw.com; gfernandez@qpwblaw.com; bfetokakis- fernandez@qpwblaw.com NOTICE OF MEDIATION YOU ARE HEREBY NOTIFIED, pursuant to the agreement of the parties and the provisions of Florida Statutes Chapter 44, that a Mediation Conference has been scheduled as follows: Mediator: Kevin "Bo" Dennis Mediation Date: August 8,2022 Mediation Time: 1:00 p.m. Mediation Location: Zoom Video Conference Time Reserved: 3.00 Hours The tenns and provisions ofthe confirmation letter accompanying this Notice ofMediation are hereby incorporated by reference into this Notice ofMediation. If you area person with a disabilitywho needs any accommodation in order to participatein this proceeding, you are entitled to the provision of certain assistance at no cost to you. Please contact theADA Coordinator in the Administrative office of Upchurch Watson White & Max, 125 S. Palmetto Avenue, Daytona Beach, FL 32114, Telephone 386-253-1560 or 800-264- 2622, within two (2) working days of receipt ofthis Notice of Mediation. I HEREBY CERTIFY that a true and correct copy of the foregoingNotice of Mediation has been served by e-mail to the above named addressees on Wednesday, March 09,2022. UPCHURCH WATSON WHITE & MAX Royal Palm at Southpointe 900 South Pine Island Road, Suite 410 Plantation, FL 33324 Phone: 954-423-8856 / Fax: 954-334-2838 Toll Free: 800-863-1462 Website: www.uww-adr.com BY: v Charles N. Tetunic, Esquire- Shareholder FL Bar No. 336191 FOR: Kevin "Bo" Dennis *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/09/2022 12:47:52 PM.**** Royal Palm II at Southpointe 900 South Pine Island Road Suite 410 Plantation, FL 33324 Telephone: 954-423-8856 Upchurch NVatson NVhite & Max Toll Free: 800-863-1462 MEDIATION GROUP Facsimile:954-334-2838 Website: www.uww-adr.com VIA E-MAIL March 9,2022 RE: GRANT VS VADILLO Case #: 21-009583 (21) FILE #: 22BD-204 Dear Counsel: We greatlyappreciateyour confidence and trust in choosing Bo Dennis as your mediator. To questionsand to avoid any possiblemisunderstandings,we are address your anticipated writingto confirm and clearlyset forth the terms and conditions of Mr. Dennis' engagement and the manner in which the mediation shall be conducted. Schedule: The mediation has been scheduled as set out in the Notice of Mediation. Conduct of Mediation: Unless otherwise agreed by the partiesor ordered by the Court, the mediations] shall be conducted accordingto mediation [includingpre-suite all applicable mediation Florida Statutes and Rules. This specifically includes all protectionsof privilege, and immunity. Mr. Dennis confidentiality shall serve as an independentmediator, providing nor legaladvice to neither legalrepresentation in the mediation. any participant Mediation Fee: There is a two hour minimum charge for all mediations in Plantation and Miami-Dade. For mediations conducted in-personin Palm Beach County, there is a 4-hour minimum charge.The mediation fee is calculated at Mr. Dennis' billingrate, the time reserved and pre-mediationor post mediation time he spends in this matter. There is NO administrative charge.Further,there is NO charge for travel time and expenses unless specifically mutually agreed upon. Allocation of Fees & Payment: Unless otherwise agreed,the mediation fees and costs shall be divided equallyamong the partiesparticipating in the mediation. Payment is due upon your rece*t of our bill. While our bill may be subjectto reimbursement from your client to you, or even forwarded to your client for direct payment, pleaseunderstand that our relationsh*is with you and that we will ultimatelylook to you to secure payment. Hourly BillingRate per Party: The fee set for my mediation services is based not only upon time but the complexity of the issues expected to be presented.Therefore, the mediation fee that charged is an hourly amount based upon the number of parties. FORT LAUDERDALE 0 WEST PALM BEACH 0 MIAMI 0 ORMOND BEACH 0 MAITLAND/ORLANDO 0 OCALA 0 JACKSONVILLE 0 BIRMINGHAM >A two party mediation shall be billed at the rate of $225.00 per hour per party. >For a three party mediation the rate shall be reduced to $165.00 per hour per party. >For a four party mediation the rate shall be further reduced to $130.00 per hour per party. >For a mediation among five or more parties, the rate shall be further reduced to $110.00 per hour per party. Mediation Summaries: Mr. Dennis will review any documents and materials you may regard as relevant. We request that you providethis office with copiesof such materials togetherwith a case summary at least ten (10) days priorto the mediation. Cancellation: Cancellations of all-daycases place an undue burden upon the mediator. Therefore,we request the earliest possiblenotice of cancellation as well as your anticipated cooperationin reschedulingwith the same mediator in the future. Please call me at the number above if you have any questionswhatsoever, or you may contact Mr. Dennis anytime directly at 954) 815-0055. We greatlyappreciate us to your selecting mediate this matter and we look forward to working with you in this case. Cordially, Heidi Cohen H,61w.JL- Mediation Case Manager Upchurch Watson White & Max hcohen@uww-adr.com