arrow left
arrow right
  • MCCONNELL, MADELINE vs. P.D.K, INC. BUSINESS TORTS document preview
  • MCCONNELL, MADELINE vs. P.D.K, INC. BUSINESS TORTS document preview
  • MCCONNELL, MADELINE vs. P.D.K, INC. BUSINESS TORTS document preview
  • MCCONNELL, MADELINE vs. P.D.K, INC. BUSINESS TORTS document preview
  • MCCONNELL, MADELINE vs. P.D.K, INC. BUSINESS TORTS document preview
  • MCCONNELL, MADELINE vs. P.D.K, INC. BUSINESS TORTS document preview
  • MCCONNELL, MADELINE vs. P.D.K, INC. BUSINESS TORTS document preview
  • MCCONNELL, MADELINE vs. P.D.K, INC. BUSINESS TORTS document preview
						
                                

Preview

Filing # 123529764 E-Filed 03/22/2021 03:36:26 PM IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR ST. LUCIE COUNTY, FLORIDA MADELINE and WILLIAM MCCONNELL, Case No. 562017CA1650AXXXHC Plaintiffs/Counter-Defendants, Vv. P.D.K, INC., A Florida Corporation, Defendant/Counter-Plaintiff. NOTICE OF HEARING (Special Set-30 Minutes) YOU ARE NOTIFIED that Plaintiffs, through undersigned counsel, will call up for hearing via Zoom or conference call before: JUDGE: The Honorable Judge Laurie Buchanan PLACE: 312 Courthouse Addition 218 South Second Street Fort Pierce, FL 34950 MATTERS: PLAINTIFFS’ MOTION AND INCORPORATED MEMORANDUM OF LAW TO COMPEL THE PRODUCTION OF DOCUMENTS DATE: April 9, 2021 TIME: 2 p.m. Thereby certify that counsel have made a good faith attempt to resolve this matter prior to noticing this motion for hearing but were unable to do so as set forth in Plaintiffs’ Motion andIncorporated Memorandum of Law to Compel the Production of Documents. In addition, Plaintiffs have attempted to schedule a hearing on this matter with no success. On February 24, 2021, undersigned counsel sought by email and text, to obtain an agreed date for the March 9-12 time period, indicating that she thought it would take approximately 30 minutes. She did not receive a definite date from counsel for Defendant. Even though undersigned counsel could have unilaterally scheduled a hearing two weeks in advance pursuant to the Court’s Procedures, Courtroom Guidelines and Expectations for Civil Cases (“Procedures”’), on Match 2, 2021, undersigned counsel again sought to schedule a hearing in the March 15-17 time period. She did not receive a response to her email. On March 8, 2021, undersigned counsel again attempted to schedule a definite date by email with counsel for PDK but was advised by counsel that they had a family accident, and he would get back the following day once he went into the office to obtain his calendar. It has been two weeks with no response. In accordance with this Court’s Procedures, undersigned counsel has made every attempt to reach a cooperative agreement on a hearing date (§ 2), as well as the length of time necessary to reserve, but in the absence of such cooperation, counsel has unilaterally set a hearing which has at least two weeks’ notice to opposing counsel ({j 4). In accordance with the American with Disabilities Act, if you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Lisa DiLucente- Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie, FL 34986, telephone number (772) 807-4370 at least seven (7) working days before your scheduled court appearance or other court activity; or immediately upon receiving your notification if the time before the scheduled appearance is less than seven (7) working days; if you are hearing or voice impaired, call 711.Dated: March 22, 2021 KOMLOSSY LAW, P.A. By: Emily C. Komlossy Emily C. Komlossy (FL Bar No. 7714) 4700 Sheridan St., Suite J Hollywood, FL 33021 (954) 842-2021 (954) 416-6223 (fax)CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing was served on counsel for defendant through the Florida Courts E-portal, which served counsel of record on March 22, 2021: Louis C. Arslanian arsgabriela@comcast.net 5800 Sheridan St. Hollywood, FL 33021 /s/_ Emily C. Komlossy (FBN 7714)