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Filing # 138079099 E-Filed 1 1/08/2021 11:28:44 AM
IN THE CIRCUIT COURT OF THE 17th
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
IRMA
QURESHI,
an
individual,
and
GENERAL JURISDICTION DIVISION
GEORGE GUERRERO, an individual,
CASE NO- CACE 2021-007238 (08)
Plaintiffs,
V
UNIVRESAL PROPERTY & CASUALTY
INSURANCE
COMPANY,
a
Florida
corporation,
Defendant.
i
TAYLOR ESPINO VEGA & TOURON, PLLC'S
NOTICE AND CLAIM OF EQUITABLE CHARGING LIEN
Taylor Espino Vega & Touron, PLLC ("TEVT"), by and through its undersigned attorney,
hereby files its Notice and Claim of Equitable Charging Lien and, in support, states as follows:
1.
On or about December 31, 2020, Irma Qureshi and George Guerrero ("Plaintiffs")
retained TEVT to provide legal services on his behalfin connectionwith this lawsuit.
2.
Pursuant to the Fee Agreement, TEVT was entitled to the reasonablevalue of its
legal services pursuant to section 627.428 of the Florida Statutes, plus costs incurred, including
any applicablemultiplier and enhancementcontingent upon said recovery from Defendant.
3
On July 20, 2021, a Joint Letter Announcing Departure of Amy E. Ruiz ("Ms.
Ruiz"), who had served as lead counsel on the case, was sent to Plaintiffs informing them oftheir
right to continue having Ms. Ruiz represent them and handling their claim at her new firm. The
Joint Letter notified Plaintiffs that should they elect to have Ms. Ruiz or a new lawyer continue to
represent them, TEVT would subsequently file its Charging Lien with the Court to preserve its
rights of recovery under the parties' Fee Agreement.
TAYLOR ESPINO VEGA & TOURON,PLLC
*** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 11/08/2021 11:28:44 AM.****
CASE NO.: 20-024790 CA 24
4.
On July 27, 2021, Ms. Ruiz resigned from TEVT and subsequentlyopened up her
new firm, Ruiz I Getman Law, PLLC ("RG Law") and, on July 26, 2021, Plaintiffs elected to hire
Ms. Ruiz and RG Law to representthem.
5.
TEVT is entitled to recover the reasonable value of its services rendered prior to
July 21, 2021. See Rosenberg v. Levin, 409 So. 2d 1016, 1021 (Fla. 1982); Rosenthal, Levy &
Simon, P.A. v. Scott, 17 So. 3d 872, 874 (Fla. 1st DCA 2009).
6.
Consequently, as of July 26, 2021, the reasonablevalue of TEVT's legal services
and costs incurred in connection with prosecuting this claim is $13,050.94.
WHEREFORE, TEVT respectfully requests that the Court impose a charging lien on any
award or judgmentrendered in Plaintiff's favor, in TEVT's favor, equal to the amount of TEVT's
unpaid attorneys' fees and costs.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 8th day ofNovember2021, a true and correct copy of
this document is being served on Joshua Strudwick, Esq. at:
and
from Universal
Property & CasualtyInsuranceCompany, P.O. Box 9388 Fort Lauderdale,Florida 33309 andAmy
E. Ruiz, Esq.
from Ruiz I Getman Law, PLLC, 6800 SW 40th Street,
#394, Miami, FL 33155.
Respectfully submitted,
/s/ Francisco Touron III
Francisco Touron, III, FBN: 527319
FTouron@tevtlaw.com
Taylor Espino Vega & Touron, PLLC
201 Alhambra Circle, Suite 801
Coral Gables, Florida 33134
Telephone: 305.443.2043
Telefacsimile:305.443.2048
-2-
TAYLOR ESPINO VEGA & TOURON,PLLC
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Filing # 138079099 E-Filed 1 1/08/2021 11:28:44 AM IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA IRMA QURESHI, an individual, and GENERAL JURISDICTION DIVISION GEORGE GUERRERO, an individual, CASE NO- CACE 2021-007238 (08) Plaintiffs, V UNIVRESAL PROPERTY & CASUALTY INSURANCE COMPANY, a Florida corporation, Defendant. i TAYLOR ESPINO VEGA & TOURON, PLLC'S NOTICE AND CLAIM OF EQUITABLE CHARGING LIEN Taylor Espino Vega & Touron, PLLC ("TEVT"), by and through its undersigned attorney, hereby files its Notice and Claim of Equitable Charging Lien and, in support, states as follows: 1. On or about December 31, 2020, Irma Qureshi and George Guerrero ("Plaintiffs") retained TEVT to provide legal services on his behalfin connectionwith this lawsuit. 2. Pursuant to the Fee Agreement, TEVT was entitled to the reasonablevalue of its legal services pursuant to section 627.428 of the Florida Statutes, plus costs incurred, including any applicablemultiplier and enhancementcontingent upon said recovery from Defendant. 3 On July 20, 2021, a Joint Letter Announcing Departure of Amy E. Ruiz ("Ms. Ruiz"), who had served as lead counsel on the case, was sent to Plaintiffs informing them oftheir right to continue having Ms. Ruiz represent them and handling their claim at her new firm. The Joint Letter notified Plaintiffs that should they elect to have Ms. Ruiz or a new lawyer continue to represent them, TEVT would subsequently file its Charging Lien with the Court to preserve its rights of recovery under the parties' Fee Agreement. TAYLOR ESPINO VEGA & TOURON,PLLC *** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 11/08/2021 11:28:44 AM.**** CASE NO.: 20-024790 CA 24 4. On July 27, 2021, Ms. Ruiz resigned from TEVT and subsequentlyopened up her new firm, Ruiz I Getman Law, PLLC ("RG Law") and, on July 26, 2021, Plaintiffs elected to hire Ms. Ruiz and RG Law to representthem. 5. TEVT is entitled to recover the reasonable value of its services rendered prior to July 21, 2021. See Rosenberg v. Levin, 409 So. 2d 1016, 1021 (Fla. 1982); Rosenthal, Levy & Simon, P.A. v. Scott, 17 So. 3d 872, 874 (Fla. 1st DCA 2009). 6. Consequently, as of July 26, 2021, the reasonablevalue of TEVT's legal services and costs incurred in connection with prosecuting this claim is $13,050.94. WHEREFORE, TEVT respectfully requests that the Court impose a charging lien on any award or judgmentrendered in Plaintiff's favor, in TEVT's favor, equal to the amount of TEVT's unpaid attorneys' fees and costs. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 8th day ofNovember2021, a true and correct copy of this document is being served on Joshua Strudwick, Esq. at: and from Universal Property & CasualtyInsuranceCompany, P.O. Box 9388 Fort Lauderdale,Florida 33309 andAmy E. Ruiz, Esq. from Ruiz I Getman Law, PLLC, 6800 SW 40th Street, #394, Miami, FL 33155. Respectfully submitted, /s/ Francisco Touron III Francisco Touron, III, FBN: 527319 FTouron@tevtlaw.com Taylor Espino Vega & Touron, PLLC 201 Alhambra Circle, Suite 801 Coral Gables, Florida 33134 Telephone: 305.443.2043 Telefacsimile:305.443.2048 -2- TAYLOR ESPINO VEGA & TOURON,PLLC