On December 04, 2018 a
Request,Application
was filed
involving a dispute between
Torres, Paula,
and
American Sales And Management Organization Llc,
Eulen America, Inc.,
Ultra Aviation Services Inc,
Eulen America,
for Comm Premises Liability
in the District Court of Miami-Dade County.
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Filing # 148683881 E-Filed 04/29/2022 03:25:38 PM
97434-7
IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
PAULA TORRES, CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 18-040362-CA 11
vs.
AMERICAN SALES AND
MANAGEMENT ORGANIZATION,
LLC, a Florida Limited Liability
Company d/b/a EULEN AMERICA,
INC. and ULTRA AVIATION
SERVICES, INC., a Florida Profit
Corporation,
Defendants.
/
REQUEST FOR SPECIAL SET HEARING BEFORE JUDGE CARLOS LOPEZ
Defendant Ultra Aviation Services, Inc.'s Motion for Summary Judgment
X (Check if Applicable) Motion exceeds 20 pages will be hand-delivered or mailed to
chambers, in addition to uploading it to CourtMAP.
Evidentiary (requires testimony) Non- Evidentiary X_
Amount of time requested for ALL sides to complete presentation? 30 minutes
1. Is case set for Trial? If so, what is trial date: No
2. Are there other motions already scheduled for special Set hearing? No
If yes, then list motion and dates of future hearings:
3. Does undersigned counsel or pro se litigant certify that a copy of this motion has been
provided to opposing counsel or party? Yes
4. Respond either A or B: A.
CASE NO. 18-040362-CA 11
A. I certify that I have conferred with counsel or pro se party in a good effort to
resolve the matter without a hearing and to determine the amount of time
requested for the hearing; or
B. I have been unable to confer with opposing counsel or pro se party for the
following reason:
Mandatory Rules for Special Set Hearings
➢ THE JUDGE READS ALL MATERIALS PROVIDED BY THE PARTIES PRIOR
TO THE HEARING. ALL motions, memoranda and supporting documents must be
submitted, via CourtMAP, not less than 7 DAYS prior to the hearing.
➢ The Judge will not have the clerk's file, therefore if you need the Court to consider the
complaint, answer, depositions, or any other exhibits which have been filed with the clerk's
office; you must submit courtesy copies via CourtMAP. (If over 20 pages, please also
submit by mail or hand deliver to chambers.)
➢ CourtMAP is simply a means of providing a courtesy copy to the Judge electronically.
Pleadings are not filed via CourtMAP. ALL original motions and exhibits MUST be filed
as usual with the clerk's office prior to submission of CourtMAP.
➢ If both sides agree to cancel or reschedule the hearing, both sides must contact Ana
Sampedro, Judicial Assistant to Judge Carlos Lopez, at least 72 hours prior to the hearing
at (305) 349-7131. Notice of Cancellation must be emailed to
asampedro@judl1l .f courts.org
➢ Only the motion that is scheduled for hearing with the Court will be heard during the time
allotted for the Special Set hearing. The parties cannot "piggy-back" motions or add
additional motions for this time period without permission from the Court.
/s/ Christopher J. Jahr
Christopher J. Jahr, Esquire
Florida Bar No. 73066
WICKER SMITH O'HARA MCCOY & FORD,
P.A.
Attorneys for Ultra Aviation Services, Inc.
5 15 E. Las Olas Boulevard
SunTrust Center, Suite 1400
Ft. Lauderdale, FL 33301
Phone: (954) 847-4800
Fax: (954) 760-9353
fficrtpleadings@wickersmith.com
2
CASE NO. 18-040362-CA 11
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a copy hereof has been electronically served via Florida
ePortal to: Andres Millon, amillon@griffinserrano.com, apavonAgriffinserrano.com,
service@griffinserrano.com, jserrano@griffinsenano.com; Eric D. Griffin, Jr., Esquire,
egriffin@griffinserrano.corn; John T. Getz, Esquire, jgetz@mcpalegal.cotn,
nblanco@mcpalegal.com; on this 29t h day of April, 2022.
/s/Christopher J Jahr
Christopher J. Jahr, Esquire
Florida Bar No. 73066
WICKER SMITH O'HARA MCCOY & FORD, P.A.
Attorneys for Ultra Aviation Services, Inc.
515 E. Las Olas Boulevard
SunTrust Center, Suite 1400
Ft. Lauderdale, FL 33301
Phone: (954) 847-4800
Fax: (954) 760-9353
fticrtpleadings@wickersmith.corn
-3
Document Filed Date
April 29, 2022
Case Filing Date
December 04, 2018
Category
Comm Premises Liability
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Filing # 148683881 E-Filed 04/29/2022 03:25:38 PM 97434-7 IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA PAULA TORRES, CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 18-040362-CA 11 vs. AMERICAN SALES AND MANAGEMENT ORGANIZATION, LLC, a Florida Limited Liability Company d/b/a EULEN AMERICA, INC. and ULTRA AVIATION SERVICES, INC., a Florida Profit Corporation, Defendants. / REQUEST FOR SPECIAL SET HEARING BEFORE JUDGE CARLOS LOPEZ Defendant Ultra Aviation Services, Inc.'s Motion for Summary Judgment X (Check if Applicable) Motion exceeds 20 pages will be hand-delivered or mailed to chambers, in addition to uploading it to CourtMAP. Evidentiary (requires testimony) Non- Evidentiary X_ Amount of time requested for ALL sides to complete presentation? 30 minutes 1. Is case set for Trial? If so, what is trial date: No 2. Are there other motions already scheduled for special Set hearing? No If yes, then list motion and dates of future hearings: 3. Does undersigned counsel or pro se litigant certify that a copy of this motion has been provided to opposing counsel or party? Yes 4. Respond either A or B: A. CASE NO. 18-040362-CA 11 A. I certify that I have conferred with counsel or pro se party in a good effort to resolve the matter without a hearing and to determine the amount of time requested for the hearing; or B. I have been unable to confer with opposing counsel or pro se party for the following reason: Mandatory Rules for Special Set Hearings ➢ THE JUDGE READS ALL MATERIALS PROVIDED BY THE PARTIES PRIOR TO THE HEARING. ALL motions, memoranda and supporting documents must be submitted, via CourtMAP, not less than 7 DAYS prior to the hearing. ➢ The Judge will not have the clerk's file, therefore if you need the Court to consider the complaint, answer, depositions, or any other exhibits which have been filed with the clerk's office; you must submit courtesy copies via CourtMAP. (If over 20 pages, please also submit by mail or hand deliver to chambers.) ➢ CourtMAP is simply a means of providing a courtesy copy to the Judge electronically. Pleadings are not filed via CourtMAP. ALL original motions and exhibits MUST be filed as usual with the clerk's office prior to submission of CourtMAP. ➢ If both sides agree to cancel or reschedule the hearing, both sides must contact Ana Sampedro, Judicial Assistant to Judge Carlos Lopez, at least 72 hours prior to the hearing at (305) 349-7131. Notice of Cancellation must be emailed to asampedro@judl1l .f courts.org ➢ Only the motion that is scheduled for hearing with the Court will be heard during the time allotted for the Special Set hearing. The parties cannot "piggy-back" motions or add additional motions for this time period without permission from the Court. /s/ Christopher J. Jahr Christopher J. Jahr, Esquire Florida Bar No. 73066 WICKER SMITH O'HARA MCCOY & FORD, P.A. Attorneys for Ultra Aviation Services, Inc. 5 15 E. Las Olas Boulevard SunTrust Center, Suite 1400 Ft. Lauderdale, FL 33301 Phone: (954) 847-4800 Fax: (954) 760-9353 fficrtpleadings@wickersmith.com 2 CASE NO. 18-040362-CA 11 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a copy hereof has been electronically served via Florida ePortal to: Andres Millon, amillon@griffinserrano.com, apavonAgriffinserrano.com, service@griffinserrano.com, jserrano@griffinsenano.com; Eric D. Griffin, Jr., Esquire, egriffin@griffinserrano.corn; John T. Getz, Esquire, jgetz@mcpalegal.cotn, nblanco@mcpalegal.com; on this 29t h day of April, 2022. /s/Christopher J Jahr Christopher J. Jahr, Esquire Florida Bar No. 73066 WICKER SMITH O'HARA MCCOY & FORD, P.A. Attorneys for Ultra Aviation Services, Inc. 515 E. Las Olas Boulevard SunTrust Center, Suite 1400 Ft. Lauderdale, FL 33301 Phone: (954) 847-4800 Fax: (954) 760-9353 fticrtpleadings@wickersmith.corn -3