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Filing # 139265288 E-Filed 11/29/2021 02:48:42 PM
IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT, IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
YVETTE BONHEUR, as Personal CASE NO.: 18-34416 CA 01
Representative of the Estate of LEGITIME
ELISBRUN,
Plaintiff,
vs.
FLORIDA POWER & LIGHT COMPANY,
and LEWIS TREE SERVICE, INC.
Defendants.
__________________________________/
PLAINTIFF’S MOTION FOR CASE MANAGEMENT CONFERENCE
Plaintiff, YVETTE BONHEUR, as Personal Representative of the Estate of LEGITIME
ELISBRUN, by and through undersigned counsel, hereby files this Motion for Case Management
and states as follows:
1. This is a wrongful death action arising out of the electrocution of Legitime Elisbrun
while trimming a palm tree near power lines owned and maintained by Defendant FP&L. The
case was recently transferred to the instant Court from another judge.
2. On October 28, 2021, a Zoom/Virtual Uniform Order Setting Cause for Non-Jury
Trial, Mediation and Pre-trial Instructions was entered.
3. However, the form submitted by Plaintiff mistakenly requested a non-jury trial,
whereas the issues in this case require a jury trial.
4. Plaintiff submits that a case management conference is appropriate in order to
address the scheduling of a jury trial in this case, the scheduling of witness depositions, and the
need for a special-set hearing on Plaintiff’s pending Omnibus Motion.
5. Undersigned counsel believes that a hearing is necessary to discuss the
aforementioned issues so that the case can move forward as efficiently as possible.
WHEREFORE, Plaintiff, YVETTE BONHEUR, as Personal Representative of the Estate
of LEGITIME ELISBRUN, respectfully requests that the Court conduct a case management
conference in this case.
F REI D I N B ROW N, P. A.
One Biscayne Tower, Suite 3100, 2 South Biscayne Boulevard, Miami, FL 33131, Phone: 305.371.3666, Fax: 305.371.6725
CASE NO. 18-34416 CA 01
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
furnished by Electronic Mail on November 29, 2021 to the following recipients:
Robert E. Boan, Esq. Christopher T. Corkan, Esq.
Angelica Torrents Roque, Esq. CONROY SIMBERG
FLORIDA POWER & LIGHT COMPANY 3440 Hollywood Boulevard
LAW DEPARTMENT 2nd Floor
4200 West Flagler Street Hollywood, Florida 33021
LAW/SCS – Second Floor Telephone: (954) 518-1221
Miami, Florida 33134 ccorkan@conroysimberg.com
Telephone: (305) 442-5115 ddemarais@conroysimberg.com
robert.boan@fpl.com Counsel for Lewis Tree Services, Inc.
angelica.roque@fpl.com
miriam.corzo.garcia@fpl.com
Counsel for Florida Power & Light
Steven M. Singer, Esq.
STEVEN M. SINGER, P.A.
7901 SW 6th Court
Suite 305
Plantation, Florida 33324
steven.m.singerpa@gmail.com
Co-counsel for Plaintiff
FREIDIN BROWN P.A.
Counsel for Plaintiff
One Biscayne Tower
Suite 3100
2 South Biscayne Boulevard
Miami, Florida 33131
Phone (305) 371-3666
Facsimile: (305) 371-6725
By: /s/ Jonathan E. Freidin
JOEL H. BROWN
Florida Bar No.: 131231
JONATHAN FREIDIN
Florida Bar No: 098955
jhb@fblawyers.net
jf@fblawyners.net
ka@fblawyers.net
pleadings@fblawyers.net
F REI D I N B ROW N, P. A.
One Biscayne Tower, Suite 3100, 2 South Biscayne Boulevard, Miami, FL 33131, Phone: 305.371.3666, Fax: 305.371.6725
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Filing # 139265288 E-Filed 11/29/2021 02:48:42 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA YVETTE BONHEUR, as Personal CASE NO.: 18-34416 CA 01 Representative of the Estate of LEGITIME ELISBRUN, Plaintiff, vs. FLORIDA POWER & LIGHT COMPANY, and LEWIS TREE SERVICE, INC. Defendants. __________________________________/ PLAINTIFF’S MOTION FOR CASE MANAGEMENT CONFERENCE Plaintiff, YVETTE BONHEUR, as Personal Representative of the Estate of LEGITIME ELISBRUN, by and through undersigned counsel, hereby files this Motion for Case Management and states as follows: 1. This is a wrongful death action arising out of the electrocution of Legitime Elisbrun while trimming a palm tree near power lines owned and maintained by Defendant FP&L. The case was recently transferred to the instant Court from another judge. 2. On October 28, 2021, a Zoom/Virtual Uniform Order Setting Cause for Non-Jury Trial, Mediation and Pre-trial Instructions was entered. 3. However, the form submitted by Plaintiff mistakenly requested a non-jury trial, whereas the issues in this case require a jury trial. 4. Plaintiff submits that a case management conference is appropriate in order to address the scheduling of a jury trial in this case, the scheduling of witness depositions, and the need for a special-set hearing on Plaintiff’s pending Omnibus Motion. 5. Undersigned counsel believes that a hearing is necessary to discuss the aforementioned issues so that the case can move forward as efficiently as possible. WHEREFORE, Plaintiff, YVETTE BONHEUR, as Personal Representative of the Estate of LEGITIME ELISBRUN, respectfully requests that the Court conduct a case management conference in this case. F REI D I N B ROW N, P. A. One Biscayne Tower, Suite 3100, 2 South Biscayne Boulevard, Miami, FL 33131, Phone: 305.371.3666, Fax: 305.371.6725 CASE NO. 18-34416 CA 01 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished by Electronic Mail on November 29, 2021 to the following recipients: Robert E. Boan, Esq. Christopher T. Corkan, Esq. Angelica Torrents Roque, Esq. CONROY SIMBERG FLORIDA POWER & LIGHT COMPANY 3440 Hollywood Boulevard LAW DEPARTMENT 2nd Floor 4200 West Flagler Street Hollywood, Florida 33021 LAW/SCS – Second Floor Telephone: (954) 518-1221 Miami, Florida 33134 ccorkan@conroysimberg.com Telephone: (305) 442-5115 ddemarais@conroysimberg.com robert.boan@fpl.com Counsel for Lewis Tree Services, Inc. angelica.roque@fpl.com miriam.corzo.garcia@fpl.com Counsel for Florida Power & Light Steven M. Singer, Esq. STEVEN M. SINGER, P.A. 7901 SW 6th Court Suite 305 Plantation, Florida 33324 steven.m.singerpa@gmail.com Co-counsel for Plaintiff FREIDIN BROWN P.A. Counsel for Plaintiff One Biscayne Tower Suite 3100 2 South Biscayne Boulevard Miami, Florida 33131 Phone (305) 371-3666 Facsimile: (305) 371-6725 By: /s/ Jonathan E. Freidin JOEL H. BROWN Florida Bar No.: 131231 JONATHAN FREIDIN Florida Bar No: 098955 jhb@fblawyers.net jf@fblawyners.net ka@fblawyers.net pleadings@fblawyers.net F REI D I N B ROW N, P. A. One Biscayne Tower, Suite 3100, 2 South Biscayne Boulevard, Miami, FL 33131, Phone: 305.371.3666, Fax: 305.371.6725