Preview
Filing # 127596750 E-Filed 05/26/2021 03:03:35 PM
RHETT CADY and EDILANE CADY, IN THE CIRCUIT COURT OF THE 17TH
Plaintiff (s), JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA
vs.
JOHN KIDD, CASE NO.: CACE-20-016553 (25)
Defendant (s)
/
NOTICE OF MEDIATION
Donald T. Norton, Esquire Rand Ackerman, Esquire
Ansel and Miller L.L.C. Green & Ackerman PA
1939 Tyler Street 1200 North Federal Highway, Suite 301
Hollywood, Florida 33020 Boca Raton, Florida 33432
Phone: 954-922-9100 Fax: (954) 922-9176 Phone: (954) 523-1900
rshields@anselmiller.com; rackerman@gaflaw.com,; RAassist@gaflaw.com;
dnorton@anselmiller.com; Counsel for Defendant, JOHN KIDD
William Gregg Wolk, Esquire
Eaton & Wolk PL
2665 S Bayshore Drive Suite 609
Miami, Florida 33133
Phone: (305) 249-1640 Fax: (786) 350-3079
wwolk@eatonwolk.com;
emartinez@eatonwolk.com;
Co-Counsel for Plaintiffs
YOU ARE HEREBY NOTIFIED, pursuant to the agreement of the parties, that a confidential Mediation Conference subject to
the provisions of Florida Statutes Chapter 44 shall be held in this case as follows:
GARY S. DICKSTEIN, ESQUIRE
ALL PARTIES APPEARING VIA ZOOM
DATE: — WEDNESDAY, AUGUST 18, 2021
STARTING TIME: 1:00 PM- 4:00 PM
PARTIES ARE ENCOURAGED TO SUBMIT ary@matrixmediation.com
WRITTEN MEDIATION SUMMARIES TO: - :
The Terms of Engagement in the letter accompanying this Notice of Mediation are hereby incorporated by reference into
this Notice of Mediation. Cancellations must be made two (2) business days prior to mediation to avoid cancellation fees,
including SETTLED cases, (see attached Terms of Engagement for cancellation policy and fees).
YOU ARE HEREBY NOTIFIED, pursuant to the written agreement of the parties, that a confidential mediation
conference subject to the provisions of Florida Statues Chapter 44 for court ordered mediations shall be held in this case
as follows:
If you are a person with a disability, as defined by the Americans with Disabilities Act, who needs any reasonable
accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain
assistance. Our offices are ADA accessible. If you require other accommodations, please contact our office at least 72
hours in advance of your mediation to discuss your needs.
IT HEREBY CERTIFY that a true and correct copy of the foregoing was provided via facsimile or email to the above-
named addressees this 26th day of May, 2021.
BY: /s/
Gary S. Dickstein, Esquire
M E dD i AT j f N Florida Bar No.: 503827/Mediator No.: 18923R
1655 Palm Beach Lakes Boulevard, Suite 700, The Forum
West Palm Beach, Florida 33401
Phone: (561) 340-3500 Fax: (561) 584-7792
Matrix Mediation, LLC (561) 340-3500
Palm Beach County: 1655 Palm Beach Lakes Boulevard, Suite 700, The Forum, West Palm Beach, Florida 33401
Broward County: 600 West Hillsboro Boulevard, Suite 104, Deerfield Beach, Florida 33441
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/26/2021 03:03:35 PM.****MATRIX
MEDIATION
Date: Wednesday, May 26, 2021
Re: Cady vs. Kidd
Case No.: CACE-20-016553 (25)
Claim No.:
Notice, Terms of Engagement, Cancellation Policy, Security Information
TERMS OF ENGAGEMENT WITH MATRIX MEDIATION
CANCELLATION POLICY
Matrix strives to provide consistently excellent mediation services in a cost-effective way. Our scheduling system and
cancellation policy provide client flexibility while respecting the mediator’s valuable time. All matrix mediators dedicate
their full time to dispute resolution and rely on you and your clients to appear when scheduled.
Courtesy Confirmations - As a courtesy, we make every effort to remind clients of their mediation by e-mail two (2)
business days in advance and by telephone confirmation seven (7) business days in advance. It is your responsibility to
provide us with appropriate advance notice if you need to cancel your mediation. Cancellations can be made at ANY time
by calling 561-340-3500 or by emailing/texting the mediator directly.
Cases may be cancelled up to two full business days (not including the date of the mediation) before the scheduled mediation
date without incurring a cancellation fee.
If your case is scheduled to occur on a:
Monday, it must be cancelled by close of business the previous Thursday to avoid a cancellation fee.
Tuesday, it must be cancelled by close of business the previous Friday to avoid a cancellation fee.
Wednesday, it must be cancelled by close of business the previous Monday to avoid a cancellation fee.
Thursday, it must be cancelled by close of business the previous Tuesday to avoid a cancellation fee.
Friday, it must be cancelled by close of business the previous Wednesday to avoid a cancellation fee.
We respectfully request that you place these deadlines into your scheduling calendar to remind yourself and avoid
unnecessary cancellation charges.
Cases cancelled fewer than two (2) business days will incur a fee equal to 50% of the time reserved, split among the parties.
We believe this policy allows our clients maximum flexibility for their practices, while recognizing that the mediator’s time
is valuable as well. CHARGES APPLY TO ALL CASES REGARDLESS OF THE REASON, EVEN IF SETTLED.
PLEASE CALCULATE THIS CANCELLATION FEE AS PART OF ANY SETTLEMENT MADE LESS THAN TWO
(2) BUSINESS DAYS OF THE SCHEDULED MEDIATION.
How to cancel your mediation — Cancel by replying to our pre-confirmation email or contact Matrix directly at
(561) 340-3500, (800) 379-2580, or contact the mediator.
Mediators are professionals who deserve the respect of a phone call or email TWO (2) FULL BUSINESS DAYS in advance
so that they can utilize their time.
By scheduling your mediation with Matrix, you have agreed to the above Terms of Engagement and Cancellation policy.
Please contact us immediately if you have any questions or concerns. We value the trust and confidence you have placed
in Matrix Mediation and in Mr. Dickstein, and we are committed to adding value to your case and to your practice.
Page 2 of 4
Matrix Mediation, LLC (561) 340-3500
Palm Beach County: 1655 Palm Beach Lakes Boulevard, Suite 700, The Forum, West Palm Beach, Florida 33401
Broward County: 600 West Hillsboro Boulevard, Suite 104, Deerfield Beach, Florida 33441MATRIX
MEDIATION
Date: Wednesday, May 26, 2021
Re: Cady vs. Kidd
Case No.: CACE-20-016553 (25)
Claim No.:
Notice, Terms of Engagement, Cancellation Policy, Security Information
TERMS OF ENGAGEMENT WITH MATRIX MEDIATION
Please Read Upon Receipt
Thank you for choosing Gary Dickstein as your expert mediator. Please review the below Terms of Engagement to confirm
your understanding of the Matrix Mediation policy.
Scheduling— Now that the parties have agreed on the mediator, the date and time of mediation, rates and minimums, Matrix
will send out and file Notice of Mediation and Terms of Engagement to counsel for the parties or pro se litigants. Only the
Notice of Mediation will be e-filed with Court.
Conduct of Mediation- By their appearance, all participants and their counsel, agree that the Mediation and Confidentiality
and Privilege Act (F.S. §44) and F.R.Civ.P. 1.720 shall apply to this mediation. Although Mr. Dickstein is an experienced
trial attorney, he does not provide legal advice or representation to the parties.
Fees- Mr. Dickstein’s hourly rate is $197.50 per hour/per party for two party cases.
For a three-party case, Mr. Dickstein’s hourly rate is $166.00 per hour/per party.
For more than three parties, Mr. Dickstein’s three-party hourly rate shall be allocated equally among the parties.
There is NO CHARGE for travel.
Unless agreed differently by the parties, fees are allocated equally among the separate entities (e.g., a married couple
represented by one lawyer in a personal injury case is considered a single entity; a defendant driver and vehicle owner who
are represented by the same lawyer is a single entity; a doctor and a hospital being sued for the same event but represented
by separate lawyers are considered two separate entities).
Minimum- The parties guarantee a payment for a two (2) and a half hour minimum for this case which shall include
one half hour of preparation time If the case exceeds the minimum, the parties guarantee payment for time used. There is
NO CHARGE for travel. (Preparation may include review of submitted summaries, phone conversations with counsel and
review of court files and applicable law).
Payment — Each party’s attorney agrees to be responsible for timely payment within 30 days after receipt of the Matrix
invoice for that party’s fees. Should payment not be received by the 30-day period, collection efforts against the Party and
Attorney may be commenced. Attorney also agrees that no file shall be closed, or money distributed in the case of a personal
injury matter, prior to the payment of any outstanding Matrix invoice. Alternatively, the Party or Attorney may pay at the
time of Mediation.
Mediation Summaries/Demonstrative Information — Mr. Dickstein encourages parties to submit summaries and other
information at least 48 hours before the scheduled mediation.
Mr. Dickstein can be reached on his cell at (561) 827-7222, the office (561) 340-3500, or at gary@matrixmediation.com.
Thank you for choosing Mr. Dickstein and Matrix Mediation. Mr. Dickstein looks forward to achieving a successful
resolution.
Sincerely,
Tamara Polk, Scheduling Coordinator
tamara@matrixmediation.com
Matrix Mediation (561) 340-3500 (800) 379-2580
Page 3 of 4
Matrix Mediation, LLC (561) 340-3500
Palm Beach County: 1655 Palm Beach Lakes Boulevard, Suite 700, The Forum, West Palm Beach, Florida 33401
Broward County: 600 West Hillsboro Boulevard, Suite 104, Deerfield Beach, Florida 33441MATRIX
MEDIATION
Date: Wednesday, May 26, 2021
Re: Cady vs. Kidd
Case No.: CACE-20-016553 (25)
Claim No.:
Notice, Terms of Engagement, Cancellation Policy, Security Information
TERMS OF ENGAGEMENT WITH MATRIX MEDIATION
SECURITY AND SAFETY
In the event any mediation participant has concerns about security or safety for
the mediation for any reason including a history of threats or violence, they must
notify Matrix Mediation upon scheduling, or immediately upon discovering
such concerns. If you are unsure, please speak with the mediator in advance.
There are no metal detectors at any of our locations. If the parties deem it
necessary, the attorneys or pro-se parties are responsible for making
arrangements for moving the mediation to the courthouse or other secure
environment or retain private security.
The possession of weapons of any kind, except by Florida licensed and certified
law enforcement officers, is strictly prohibited on Matrix Mediation properties.
Page 4 of 4
Matrix Mediation, LLC (561) 340-3500
Palm Beach County: 1655 Palm Beach Lakes Boulevard, Suite 700, The Forum, West Palm Beach, Florida 33401
Broward County: 600 West Hillsboro Boulevard, Suite 104, Deerfield Beach, Florida 33441
Preview
Filing # 127596750 E-Filed 05/26/2021 03:03:35 PM RHETT CADY and EDILANE CADY, IN THE CIRCUIT COURT OF THE 17TH Plaintiff (s), JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA vs. JOHN KIDD, CASE NO.: CACE-20-016553 (25) Defendant (s) / NOTICE OF MEDIATION Donald T. Norton, Esquire Rand Ackerman, Esquire Ansel and Miller L.L.C. Green & Ackerman PA 1939 Tyler Street 1200 North Federal Highway, Suite 301 Hollywood, Florida 33020 Boca Raton, Florida 33432 Phone: 954-922-9100 Fax: (954) 922-9176 Phone: (954) 523-1900 rshields@anselmiller.com; rackerman@gaflaw.com,; RAassist@gaflaw.com; dnorton@anselmiller.com; Counsel for Defendant, JOHN KIDD William Gregg Wolk, Esquire Eaton & Wolk PL 2665 S Bayshore Drive Suite 609 Miami, Florida 33133 Phone: (305) 249-1640 Fax: (786) 350-3079 wwolk@eatonwolk.com; emartinez@eatonwolk.com; Co-Counsel for Plaintiffs YOU ARE HEREBY NOTIFIED, pursuant to the agreement of the parties, that a confidential Mediation Conference subject to the provisions of Florida Statutes Chapter 44 shall be held in this case as follows: GARY S. DICKSTEIN, ESQUIRE ALL PARTIES APPEARING VIA ZOOM DATE: — WEDNESDAY, AUGUST 18, 2021 STARTING TIME: 1:00 PM- 4:00 PM PARTIES ARE ENCOURAGED TO SUBMIT ary@matrixmediation.com WRITTEN MEDIATION SUMMARIES TO: - : The Terms of Engagement in the letter accompanying this Notice of Mediation are hereby incorporated by reference into this Notice of Mediation. Cancellations must be made two (2) business days prior to mediation to avoid cancellation fees, including SETTLED cases, (see attached Terms of Engagement for cancellation policy and fees). YOU ARE HEREBY NOTIFIED, pursuant to the written agreement of the parties, that a confidential mediation conference subject to the provisions of Florida Statues Chapter 44 for court ordered mediations shall be held in this case as follows: If you are a person with a disability, as defined by the Americans with Disabilities Act, who needs any reasonable accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Our offices are ADA accessible. If you require other accommodations, please contact our office at least 72 hours in advance of your mediation to discuss your needs. IT HEREBY CERTIFY that a true and correct copy of the foregoing was provided via facsimile or email to the above- named addressees this 26th day of May, 2021. BY: /s/ Gary S. Dickstein, Esquire M E dD i AT j f N Florida Bar No.: 503827/Mediator No.: 18923R 1655 Palm Beach Lakes Boulevard, Suite 700, The Forum West Palm Beach, Florida 33401 Phone: (561) 340-3500 Fax: (561) 584-7792 Matrix Mediation, LLC (561) 340-3500 Palm Beach County: 1655 Palm Beach Lakes Boulevard, Suite 700, The Forum, West Palm Beach, Florida 33401 Broward County: 600 West Hillsboro Boulevard, Suite 104, Deerfield Beach, Florida 33441 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/26/2021 03:03:35 PM.****MATRIX MEDIATION Date: Wednesday, May 26, 2021 Re: Cady vs. Kidd Case No.: CACE-20-016553 (25) Claim No.: Notice, Terms of Engagement, Cancellation Policy, Security Information TERMS OF ENGAGEMENT WITH MATRIX MEDIATION CANCELLATION POLICY Matrix strives to provide consistently excellent mediation services in a cost-effective way. Our scheduling system and cancellation policy provide client flexibility while respecting the mediator’s valuable time. All matrix mediators dedicate their full time to dispute resolution and rely on you and your clients to appear when scheduled. Courtesy Confirmations - As a courtesy, we make every effort to remind clients of their mediation by e-mail two (2) business days in advance and by telephone confirmation seven (7) business days in advance. It is your responsibility to provide us with appropriate advance notice if you need to cancel your mediation. Cancellations can be made at ANY time by calling 561-340-3500 or by emailing/texting the mediator directly. Cases may be cancelled up to two full business days (not including the date of the mediation) before the scheduled mediation date without incurring a cancellation fee. If your case is scheduled to occur on a: Monday, it must be cancelled by close of business the previous Thursday to avoid a cancellation fee. Tuesday, it must be cancelled by close of business the previous Friday to avoid a cancellation fee. Wednesday, it must be cancelled by close of business the previous Monday to avoid a cancellation fee. Thursday, it must be cancelled by close of business the previous Tuesday to avoid a cancellation fee. Friday, it must be cancelled by close of business the previous Wednesday to avoid a cancellation fee. We respectfully request that you place these deadlines into your scheduling calendar to remind yourself and avoid unnecessary cancellation charges. Cases cancelled fewer than two (2) business days will incur a fee equal to 50% of the time reserved, split among the parties. We believe this policy allows our clients maximum flexibility for their practices, while recognizing that the mediator’s time is valuable as well. CHARGES APPLY TO ALL CASES REGARDLESS OF THE REASON, EVEN IF SETTLED. PLEASE CALCULATE THIS CANCELLATION FEE AS PART OF ANY SETTLEMENT MADE LESS THAN TWO (2) BUSINESS DAYS OF THE SCHEDULED MEDIATION. How to cancel your mediation — Cancel by replying to our pre-confirmation email or contact Matrix directly at (561) 340-3500, (800) 379-2580, or contact the mediator. Mediators are professionals who deserve the respect of a phone call or email TWO (2) FULL BUSINESS DAYS in advance so that they can utilize their time. By scheduling your mediation with Matrix, you have agreed to the above Terms of Engagement and Cancellation policy. Please contact us immediately if you have any questions or concerns. We value the trust and confidence you have placed in Matrix Mediation and in Mr. Dickstein, and we are committed to adding value to your case and to your practice. Page 2 of 4 Matrix Mediation, LLC (561) 340-3500 Palm Beach County: 1655 Palm Beach Lakes Boulevard, Suite 700, The Forum, West Palm Beach, Florida 33401 Broward County: 600 West Hillsboro Boulevard, Suite 104, Deerfield Beach, Florida 33441MATRIX MEDIATION Date: Wednesday, May 26, 2021 Re: Cady vs. Kidd Case No.: CACE-20-016553 (25) Claim No.: Notice, Terms of Engagement, Cancellation Policy, Security Information TERMS OF ENGAGEMENT WITH MATRIX MEDIATION Please Read Upon Receipt Thank you for choosing Gary Dickstein as your expert mediator. Please review the below Terms of Engagement to confirm your understanding of the Matrix Mediation policy. Scheduling— Now that the parties have agreed on the mediator, the date and time of mediation, rates and minimums, Matrix will send out and file Notice of Mediation and Terms of Engagement to counsel for the parties or pro se litigants. Only the Notice of Mediation will be e-filed with Court. Conduct of Mediation- By their appearance, all participants and their counsel, agree that the Mediation and Confidentiality and Privilege Act (F.S. §44) and F.R.Civ.P. 1.720 shall apply to this mediation. Although Mr. Dickstein is an experienced trial attorney, he does not provide legal advice or representation to the parties. Fees- Mr. Dickstein’s hourly rate is $197.50 per hour/per party for two party cases. For a three-party case, Mr. Dickstein’s hourly rate is $166.00 per hour/per party. For more than three parties, Mr. Dickstein’s three-party hourly rate shall be allocated equally among the parties. There is NO CHARGE for travel. Unless agreed differently by the parties, fees are allocated equally among the separate entities (e.g., a married couple represented by one lawyer in a personal injury case is considered a single entity; a defendant driver and vehicle owner who are represented by the same lawyer is a single entity; a doctor and a hospital being sued for the same event but represented by separate lawyers are considered two separate entities). Minimum- The parties guarantee a payment for a two (2) and a half hour minimum for this case which shall include one half hour of preparation time If the case exceeds the minimum, the parties guarantee payment for time used. There is NO CHARGE for travel. (Preparation may include review of submitted summaries, phone conversations with counsel and review of court files and applicable law). Payment — Each party’s attorney agrees to be responsible for timely payment within 30 days after receipt of the Matrix invoice for that party’s fees. Should payment not be received by the 30-day period, collection efforts against the Party and Attorney may be commenced. Attorney also agrees that no file shall be closed, or money distributed in the case of a personal injury matter, prior to the payment of any outstanding Matrix invoice. Alternatively, the Party or Attorney may pay at the time of Mediation. Mediation Summaries/Demonstrative Information — Mr. Dickstein encourages parties to submit summaries and other information at least 48 hours before the scheduled mediation. Mr. Dickstein can be reached on his cell at (561) 827-7222, the office (561) 340-3500, or at gary@matrixmediation.com. Thank you for choosing Mr. Dickstein and Matrix Mediation. Mr. Dickstein looks forward to achieving a successful resolution. Sincerely, Tamara Polk, Scheduling Coordinator tamara@matrixmediation.com Matrix Mediation (561) 340-3500 (800) 379-2580 Page 3 of 4 Matrix Mediation, LLC (561) 340-3500 Palm Beach County: 1655 Palm Beach Lakes Boulevard, Suite 700, The Forum, West Palm Beach, Florida 33401 Broward County: 600 West Hillsboro Boulevard, Suite 104, Deerfield Beach, Florida 33441MATRIX MEDIATION Date: Wednesday, May 26, 2021 Re: Cady vs. Kidd Case No.: CACE-20-016553 (25) Claim No.: Notice, Terms of Engagement, Cancellation Policy, Security Information TERMS OF ENGAGEMENT WITH MATRIX MEDIATION SECURITY AND SAFETY In the event any mediation participant has concerns about security or safety for the mediation for any reason including a history of threats or violence, they must notify Matrix Mediation upon scheduling, or immediately upon discovering such concerns. If you are unsure, please speak with the mediator in advance. There are no metal detectors at any of our locations. If the parties deem it necessary, the attorneys or pro-se parties are responsible for making arrangements for moving the mediation to the courthouse or other secure environment or retain private security. The possession of weapons of any kind, except by Florida licensed and certified law enforcement officers, is strictly prohibited on Matrix Mediation properties. Page 4 of 4 Matrix Mediation, LLC (561) 340-3500 Palm Beach County: 1655 Palm Beach Lakes Boulevard, Suite 700, The Forum, West Palm Beach, Florida 33401 Broward County: 600 West Hillsboro Boulevard, Suite 104, Deerfield Beach, Florida 33441