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Filing# 162666224 E-Filed 12/08/2022 02:28:29 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
ANTONIO ALFARO and DIANA CASE NO.: CACE-21-007201
ALFARO,
Plaintiffs,
V
TYPTAP INSURANCE COMPANY,
Defendant.
DEFENDANT'S MOTION TO COMPEL COMPLIANCE WITH UNIFORM TRIAL
ORDER AS TO MEDIATION
COMES NOW, Defendant, TypTap Insurance Company, by and through
undersigned counsel, pursuant to Florida rules of Civil Procedure 1.380(b), and hereby
files this Motion to Compel compliance with Uniform Trial Order dated February 19,2022,
and in support thereof states as follows:
1. This case involves a dispute over property insurance coverage.
2. On February 19, 2022, the Court entered its Uniform Trial Order.
3. Pursuant to the order mediation was to take place no later than November 4,2022.
4. Defendant reached out to Plaintiffs' counsel on September 27,2022 in order to set
mediation. Plaintiffs did not respond. See email correspondence within composite
Exhibit A.
5. Defendant reached out to Plaintiffs' counsel again on 10/5/2022 in order to set
mediation. See email correspondence within composite Exhibit A.
Page 1
COLE, SCOTT & KISSANE, P.A.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/08/2022 02:28:21 PM.****
CASE NO.: CACE-21-007201
6. On October 11, 2022 Plaintiffs' counsel finallyresponded with a mediator list.
See email correspondence within composite Exhibit A.
7. On November 1, 2022, Defendant provided an list of proposed mediators to
Plaintiffs' counsel. See email correspondence attached hereto in composite Exhibit
A.
8. On November 4,2022 Defendant sent an email following up with Plaintiffs'
counsel regarding the proposed mediators. See email correspondence within
composite Exhibit A.
9. On November 9, 2022 Defendant sent an email following up with Plaintiffs'
counsel regarding the proposed mediators. See email correspondence within
composite Exhibit A.
10. On November 9,2022 responded with its list of
Plaintiff finally proposed mediators.
which had been previously provided. See email correspondence within composite
Exhibit A.
11.On November 11, 2022 Defendant proposed a mediator from Plaintiffs' list
with availabilityon December 13, 2022 at 9:30 am. See email
correspondence within composite Exhibit A.
12. Having received no response from Plaintiff,on November 14, 2022 Defendant
followed up regarding setting mediation for December 13, 2022. See email
correspondence within composite Exhibit A.
13. on November 29, 2022 Defendant
Having received no response from Plaintiff,
followed up again regarding setting mediation. See email correspondence within
composite Exhibit A.
2
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILD NG -
222 LAKEV EW AVENUE, SUITE 120 -
WEST PALM BEACH, FLORIDA 33401 (561) 383-9200
-
(561) 683-8977 FAX
CASE NO.: CACE-21-007201
14. On November 29, 2022 Plaintiffs responded that they would provide Defendant
with dates for mediation the next day (November 30,2022). See email
correspondence within composite Exhibit A.
15. on November 30,2022 Defendant
Having received no response from Plaintiff,
followed up again regarding setting mediation. See email correspondence within
composite Exhibit A.
16. On December 2 2022, Defendant followed up again regarding setting mediation.
See email correspondence within composite Exhibit A.
17. On December 7, 2022, Defendant reached out to Plaintiff again regarding setting
mediation, stating in part, "We have reached out to your office regarding mediation
numerous times and we still do not have a date, this was originallyset for 12/13
however your office failed to confirm with the mediator. The deadline per court
order was for 11/4/22. This mediation needs to Occur by 12/20 as our client will be
out of town for the remainder of the year." Defendant also informed the Plaintiff
that it would be seeking court intervention. See email correspondence within
composite Exhibit A.
18. On December 7, 2022 Plaintiff responded stating that they were checking
mediators availabilities but did not provide a list of mediators nor did they confirm
if they were available for the 12/13/22 proposed mediation date. See email
correspondence within composite Exhibit A.
19. On December 7, 2022 Defendant provided Plaintiff with a list of mediators who
were available for mediation on 12/13/2022. See email correspondence within
composite Exhibit A.
3
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILD NG -
222 LAKEV EW AVENUE, SUITE 120 -
WEST PALM BEACH, FLORIDA 33401 (561) 383-9200
-
(561) 683-8977 FAX
CASE NO.: CACE-21-007201
20. To date the only response received from Plaintiffs' counsel is that they are
checking with the Plaintiffs for availability.
21.Accordingly, Plaintiffs have not complied with the court's Uniform Trial Order.
WHEREFORE, Defendant respectfullyrequests that the court enter an order
requiring the Plaintiffs to attend mediation within 10 days of the court's order and for any
other relief deemed appropriate by the court.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 8th day of December, 2022, a true and correct
copy of the foregoing was filed with the Clerk of Broward County by using the Florida
Courts e-Filing Portal, which will send an automatic e-mail message to the following
parties registered with the e-Filing Portal system: Maximo A. Santiago, Esq, Your
Insurance Attorney, PLLC, yia3@yourinsuranceattorney.com;
eservice@yourinsuranceattorney.com, 2601 South Bayshore Drive, 18th Floor, Coconut
Grove, FL 33133, (888) 570-5677/(888) 745-5677 (F), Attorney for Plaintiffs,Diana
Arevalo and Antonio Alfaro.
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendant TYPTAP INSURANCE
COMPANY
Esperante Building
222 Lakeview Avenue, Suite 120
West Palm Beach, Florida 33401
Telephone (561) 383-9233
Facsimile (561) 683-8977
Primary e-mail: stephen.harber@csklegal.corn
Secondary e-mail: jacqueline.meyer@csklegal.corn
Alternate e-mail: wpbfirstparty@csklegal.com
By: s/ Jacqueline P. Meyer
STEPHEN N. HARBER
Florida Bar No.: 96374
JACQUELINE P. MEYER
Florida Bar No.: 1010785
4
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILD NG -
222 LAKEV EW AVENUE, SUITE 120 -
WEST PALM BEACH, FLORIDA 33401 (561) 383-9200
-
(561) 683-8977 FAX
Exhibit A
Fmom:
To: Ariaona Vierma; Jacquelbe P, Meyer; Ariana Rubio
C-: Staphp,1 N. Harber; 18[28-Ek?LE/,#; Kamn-M=limax?n; MaL-S/Iiiagn
subject: RE: TIME SENSrl-TVERUE: 5596-050 ANTONIO ALFARO & D[ANA AREVALO V5 TYTAP
-
(CAST IRON> Claim# 12-3001394-20 CASE No.:SERVICE OF COURT DOCUMENT CA5E
NUMBER 062021CA007201-AXXXCE ALFARO, ANTONID V5 TYPTAP INSURANCE COMPANY
Datm: Wecbiesday, December 7,2022 3:43:10 PM
Importance: High
Please be advised the following mediators have availabilityfor the originally agreed upon date of December 13, 2022.
Fred Hazouri
Michael McManus
Alex Romano
Robert Moses
Please reconfrm your availabilityas well as the mediator you will agree to.
Thank you for your prompt attention in this regard.
Stacey Nafis
Legal Assistant / Paralegal
Tel 561-612-3497 I Fax 561-683-8977
Email Stacey.Nafis@csklegal.com
Cole. Scott & Kissane P.A.
The Florida Law firm 222 Lakeview Avenue, Suite 120
www.csklegal.com West Palm Beach, Florida, 33401
From: Stacey Nafis
Sent: Wednesday, December 7,2022 3:32 PM
To: Arianna Vierma ; Jacqueline F- Meyer ; Ariana Rubio
Cc: Stephen N. Harber ; WPB First Party ; Karen Martincavage
; Max Santiago
Subject: RE: TIME SENSITIVE RE 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP- (CAST IRON) Claim# 12-3001394-20 CASE No.: SERVICE
OF COURT DOCUMENT CASE NUMBER 062021CA007201AXXXCE ALFARO, ANTONIO VS TYPTAP INSURANCE COMPANY
Hi Arianna -
In addition, we have requested for Mediation
that you confirm availability on 12/13/21 If your office is available we will Iocate
a mediator who is also available so we may get this scheduled ASAP
Thank you,
From: Arianna Vierma
Sent: Wednesday, December 7,2022 3:27 PM
To: Jacqueline P. Meyer ; Ariana Rubio
Cc: Stephen N. Harber ; WPB First Party ; Karen Martincavage
; Stacey Nafis ; Max Santiago
Sub}ect: RE: TIME SENSITIVE RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP- (CAST IRON) Claim# 12-3001394-20 CASE No.: SERVICE
OF COURT DOCUMENT CASE NUMBER 062021CA007201AXXXCE ALFARO, ANTONIO VS TYPTAP INSURANCE COMPANY
[CAUTION EXTERNAL EMAIU
Good afternoon Jacqueline,
As for mediation, per our conversation I was looking at the
availability of each mediator and I was going to send it to your office.
Thankyou.
Best Regards,
Ai-launa I'7ei-ina
Legal Assistant to Mirimo A. Santiago and Ariana Rubio Di Natale
Youi hisuraiice Attorney, PLLC.
-th
2601 Soutli Baysliore Drive 5' Floor
Coconut Grove, FL 33133
Phone No.: 1-888-570-5677
Direct 786-809-2256
Ufebsite: www.yourinsuraiiceattorney.coin
E-mail: aviemia(@yourmsuraiiceattorney.coin
/? YOURINSURANCE
1?ATTORNEY
NOTICE: The information and may contain information that
in this e-mail is confidential is attorney-client privileged or exempt from disclosure. It is
intended only forthe use of the individual(s) orentity(ies) to whom it is addressed. If
you are notan intended recipient, you are hereby notified
that any use, dissemination, distribution or copying of this communication is strictly prohibited. Anyone who receives this message in error should
notify thesender immediately by telephone or by return e-mail and delete the entire message (and any attachments) from their computer. Any
opinions or advice contained in this email shall be subject to the terms and conditions set forth in the governing Your Insurance Attorney, client
engagement agreement. Thankyou.
IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a "reliance
opinion" under applicable Treasury Regulations, and accordinglyare not intended or written to be used, and may not be used or relied upon, for the
purpose of (i)avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or (ii)promoting, marketing or recommending to
another party anytax-related matters addressed herein.
*SCHEDULING NOTEr-**
**C=
The dates provided may have been offered to other counsels and will only be secured on a first come-first serve basis. PLEASE BE ADVISED THE
DATES PROPOSED ARE NOT CONFIRMED UNTIL YOU RECEIVE A FINAL RESPONSE FROM OUR OFFICE CONFIRMING SAME. PLEASE NOTE DATES
WILL BE RELEASED IF NOTICE IS NOT RECEIVED WITHIN 3 DAYS. ALL DATES AND TIMES PROVIDED ARE IN EASTERN STANDARD TIME.
From: Jacqueline P. Meyer
Sent: Wednesday, December 7,2022 3:25 PM
To: Arianna Vierma ; Ariana Rubio
Cc: Stephen N. Harber; WPB First Party ; Karen Martincavage
; Stacey Nafis ; Max Santiago
Subject: TIME SENSITIVE RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12-3001394-20 CASE No.: SERVICE OF
COURT DOCUMENT CASE NUMBER 062021CA007201AXXXCE ALFARO, ANTONIO VS TYPTAP INSURANCE COMPANY
Importance: High
Good Afternoon Ms. Rubio,
We have reached out to your office regarding mediation numerous times and we still do not have a date, this was originallyset for 12/13 however
your office failed to confirm with the mediator. The deadline per court order was for 11/4/22. This mediation needs to Occur by 12/20 as our client
will be out of town forthe remainder of the year. Additionally, youroffice has not responded to our requests for re-inspection nor have we
received your overdue discovery responses. Please call me at (561)612-3452 to discuss. Please be advised that I will be seeking court intervention
bythe end of businesstoday.
Jacqueline P. Meyer
Associate
Tel: 561-612-3452 I Fax: 561-683-8977
Email Jacqueline.Meyer@csklegal.com
The Florida Law Firm Cole, Scott & Kissane P.A.
222 Lakeview Avenue. Suite 120
www.csklegal.com West Palm Beach, Florida, 33401
Fronn: Karla Velazquez
To: Arianna Vierma; Stacey Nafis; via3@vourinsuranceattornev.com; ms@vourinsuranceattornev.com
CC: Jacqueline P. Mever; Karen Martincavaae; WPB First Party
Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12-3001394-20 CASE No.:
Date: Friday, December 2,2022 4:40:21 PM
Importance: High
Good afternoon Arianna,
I'm following up on scheduling mediation in the subject matter. Please note same
must be completed by 12/20/22.
We're currently holding 12/13 as we were holding it for mediation with K&A.
Please provide us with proposed mediators/availabilityso that we may get this set.
Thank you.
Karla Velazquez
Legal Assistant to Attorneys:
Jaqueline Meyer
Fax: 561-683-8977
Email: Karla.Velazquez@csklegal.com
The Florida Law Firm
Cole, Scott & Kissane P.A.
www.csklegal.com 222 Lakeview Avenue, Suite 120
West Palm Beach, Florida, 33401
.j
From: Karla Velazquez
Sent: Wednesday, November 30,2022 2:36 PM
To: Arianna Vierma ; Stacey Nafis
Cc: Jacqueline P. Meyer ; Karen Martincavage
; WPB First Party
Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12-
3001394-20 CASE No.:
Hi Arianna,
Just following up on this one. Can you please send me some for
availability
mediation?
From: Arianna Vierma
Sent: Tuesday, November 29, 2022 6:12 PM
To: Karla Velazquez ; Stacey Nafis
Cc: Jacqueline P. Meyer ; Karen Martincavage
; WPB First Party
Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12-
3001394-20 CASE No.:
[CAUTION: EXTERNAL EMAIL]
Good afternoon Karla,
Tomorrow, I will send you available dates for mediation on this case.
Thank you and have a great day.
Best Regards,
Ariaima Uemm
Legal ?15515miit to Maxiino A. Santjag-oaiid Al-iaiia Rubio Di .Xamle
Your Insuraiice Attorney, PLLC.
rtll
2601 South Bayshore Diive 5?1 Floor
Cocoiiut Grove, FL 33133
Phone No.: 1-888-570-5677
Direct: 786-809-2256
-Website: www.yourinsuranceattorney.coin
E-mil: aviernia@yourinsuranceattorney.coin
1 YOUR [NSURANCE
l.W ATTORNEY
NOTICE: The information in this e-mail is confidential and may contain information that is attorney-
client privilegedor exempt from disclosure. It is intended only for the use of the individual(s)
or
to
entity(ies) whom it is addressed. If you are not an intended recipient,you are hereby notified that
any use, dissemination, distribution or copying of this communication is strictlyprohibited. Anyone
who receives this message in error should notifythe sender immediately by telephone or by return
e-mail and delete the entire message (and any attachments) from their computer. Any opinions or
advice contained in this email shall be subject to the terms and conditions set forth in the governing
Your Insurance Attorney, client engagement agreement. Thank you.
IRS Circular230 Disclosure: Please note that the views expressed herein or in any attachments
hereto are not intended to constitute a "reliance opinion" under applicable Treasury Regulations,
and accordingly are not intended or written to be used, and may not be used or relied upon, for the
purpose of (i)avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or
promoting, marketing or
(ii) recommending to another party any tax-related matters addressed
herein.
**SCHEDULING NOTE**
The dates provided may have been offered to other counsels and will only be secured on a first
come-first serve basis. PLEASE BE ADVISED THE DATES PROPOSED ARE NOT CONFIRMED UNTIL
YOU RECEIVE A FINAL RESPONSE FROM OUR OFFICE CONFIRMING SAME. PLEASE NOTE DATES
WILL BE RELEASED IF NOTICE IS NOT RECEIVED WITHIN 3 DAYS. ALL DATES AND TIMES PROVIDED
ARE IN EASTERN STANDARD TIME.
From: Karla Velazquez
Sent: Tuesday, November 29,2022 4:38 PM
To: Arianna Vierma ; Stacey Nafis
Cc: Jacqueline P. Meyer ; Karen Martincavage
; WPB
Party
First
5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12-
Subject: RE:
3001394-20 CASE No.:
Good afternoon Arianna,
I have not heard back from you regarding setting mediation on this matter.
Please provide available dates.
Thank you.
Karla Velazquez
Legal Assistant to Attorneys:
Jaqueline Meyer
Fax: 561-683-8977
Email: Karla.Velazquez@csklegal.com
- The Florida Law
.csklegal.com
Firm
Cole, Scott & Kissane
222 Lakeview Avenue, Suite 120
West Palm Beach, Florida, 33401
P.A.
From: Karla Velazquez
Sent: Monday, November 14, 2022 10:09 AM
To: Arianna Vierma ; Stacey Nafis
Cc: Jacqueline P. Meyer ; Karen Martincavage
; WPB
Party
First
5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12-
Subject: RE:
3001394-20 CASE No.:
Hi Arianna,
I tried callingyou but was unable to reach you.
Please let me know if we can set for 12/13 @ 9:30 a.m. with Markel Arrizabalaga.
I've asked the mediator to please hold the date, but it will be released by the end of
the day.
Thank you.
From: Karla Velazquez
Sent: Friday,November 11, 2022 2:06 PM
To: Arianna Vierma ; Stacey Nafis
Cc: Jacqueline P. Meyer ; Karen Martincavage
; WPB First Party
Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12-
3001394-20 CASE No.:
Good afternoon Arianna,
Markel Arrizabalaga is available on 12/13 @ 9:30 a.m.
The date works for us as well as our client.
Please advise if I may confirm with the Mediator.
Thank you.
From: Arianna Vierma
Sent: Wednesday, November 9,2022 2:54 PM
To: Karla Velazquez ; Stacey Nafis
Cc: Jacqueline P. Meyer ; Karen Martincavage
; WPB First Party
Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP -
(CAST IRON) Claim# 12-
3001394-20 CASE No.:
[CAUTION: EXTERNAL EMAIL]
Good afternoon Karla,
Please see the list of mediators approved by our office:
1. Eric Kleinman
2. Markel Arrizabalaga
3. Mark Greenberg
4. Robert Dulberg
5. Ilida Alvarez
6. Yamile Tamargo
7. Holly Savino
8. Peter Abraham
9. Frank Allocca
10. Henry Hernandez
11. David Salmon
12. Michael Lax
13. Laura Bonn
14. Karen Holis (Fridaysonly)
15. Robert Flayman
16. Eric Canter
17. Frank Sexton
Thank you and have a great day.
Best Regards,
Ariaima Uemm
Your Insuraiice Attorney, PLLC.
th
2601 South Bayshore Diive 18U1 Floor
Cocoiiut Grove, FL 33133
Phone No.: 1-888-570-5677
Direct: 786-809-2256
-Website: uinv.yourinsuranceattorney.coin
E-mail: ariel ina@yourinsuranceattorney.coin
1 YOUR [NSURANCE
ATTORNEY
Y/1
NOTICE: The information in this e-mail confidential and may contain information that
is is attorney-
client privilegedor exempt from disclosure. It is intended only for the use of the individual(s)
or
to
entity(ies) whom it is addressed. If you are not an intended recipient, you are hereby notified that
any use, dissemination, distribution or copying of this communication is prohibited. Anyone
strictly
who receives this message in error should notify the sender immediately by telephone or by return
e-mail and delete the entire message (and any attachments) from their computer. Any opinions or
advice contained in this email shall be subject to the terms and conditions set forth in the governing
Your Insurance Attorney, client engagement agreement. Thank you.
IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments
hereto are not intended to constitute a "reliance opinion" under applicable Treasury Regulations,
and accordingly are not intended or written to be used, and may not be used or relied upon, for the
purpose of (i)avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or
promoting, marketing or recommending to another party any tax-related matters addressed
(ii)
herein.
From: Karla Velazquez
Sent: Wednesday, November 9,2022 2:38 PM
To: Arianna Vierma ; Stacey Nafis
Cc: Jacqueline P. Meyer ; Karen Martincavage
; WPB First Party
Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP -
(CAST IRON) Claim# 12-
3001394-20 CASE No.:
Good afternoon Arianna,
Kindly please advise as to my email below.
Please et me know who your office will agree to mediate with so that I may obtain
availabi ity.
Thank you.
Karla Velazquez
Legal Assistant to Attorneys:
Jaqueline Meyer
Fax: 561-683-8977
Email: Karla.Velazquez@csklegal.com
- 1 he Florida Law Firm
.csklegal.com
Cole, Scott & Kissane
222 Lakeview Avenue, Suite 120
West Palm Beach,
P.A.
Florida, 33401
From: Karla Velazquez
Sent: Friday,November 4, 2022 10:36 AM
To: Arianna Vierma ; Stacey Nafis
Cc: Jacqueline P. Meyer ; Karen Martincavage
; WPB First Party
Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP -
(CAST IRON) Claim# 12-
3001394-20 CASE No.:
Good morning Arianna,
I'm following up on my email below.
Kindly please advise so that I may obtain availability.
Thank you.
From: Karla Velazquez
Sent: Tuesday, November 1, 2022 11:54 AM
To: Arianna Vierma ; Stacey Nafis
Cc: Jacqueline P. Meyer ; Karen Martincavage
; WPB
First Party
5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12-
Subject: RE:
3001394-20 CASE No.:
Good morning Arianna,
P ease find below proposed Mediators.
P ease et me know who your office will agree to mediate with so that I may obtain
availabi ity.
.
AprilWalker
. K&A
. David Sullivan
. Casimir Mealiszewski
. David Ross
. Steven Teuber
. Tom Brown
Thank you.
From: Arianna Vierma
Sent: Monday, October 31, 2022 5:58 PM
To: Karla Velazquez ; Stacey Nafis
Cc: Jacqueline P. Meyer ; Karen Martincavage
; WPB First Party; Claribell
Bedolla
Subject: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12-
3001394-20 CASE No.:
[CAUTION: EXTERNAL EMAIL]
Good afternoon,
Can you please provide the list of mediators your office agrees with?
Thankyou.
Best Regards,
Ariaima Uemm
Legal ?15515miit to Maxiino A. Santjag-oaiid Al-iaiia Rubio Di .Xamle
Your Insuraiice Attorney, PLLC.
th
2601 South Bayshore Drive 18U1 Floor
Cocoiiut Grove, FL 33133
Phone No.: 1-888-570-5677
Direct: 786-809-2256
-Website: www.yourinsuranceattorney.coin
E-mil: aviernia@yourinsuranceattorney.coin
1 YOUR[NSURANCE
Iy?ATTORNEY
NOTICE: The information in this e-mail confidential and may contain information that
is is attorney-
client privileged or exempt from disclosure. It is intended only for the use of the individual(s)
or
to
entity(ies) whom it is addressed. If you are not an intended recipient,you are hereby notified that
any use, dissemination, distribution or copying of this communication is strictlyprohibited. Anyone
who receives this message in error should notifythe sender immediately by telephone or by return
e-mail and delete the entire message (and any attachments) from their computer. Any opinions or
advice contained in this email shall be subject to the terms and conditions set forth in the governing
Your Insurance Attorney, client engagement agreement. Thank you.
IRS Circular230 Disclosure: Please note that the views expressed herein or in any attachments
hereto are not intended to constitute a "reliance opinion" under applicable Treasury Regulations,
and accordingly are not intended or written to be used, and may not be used or relied upon, for the
purpose of (i)avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or
promoting, marketing or recommending to another party any tax-related matters addressed
(ii)
herein.
**SCHEDULING NOTE**
The dates provided may have been offered to other counsels and will only be secured on a first
come-first serve basis. PLEASE BE ADVISED THE DATES PROPOSED ARE NOT CONFIRMED UNTIL
YOU RECEIVE A FINAL RESPONSE FROM OUR OFFICE CONFIRMING SAME. PLEASE NOTE DATES
WILL BE RELEASED IF NOTICE IS NOT RECEIVED WITHIN 3 DAYS. ALL DATES AND TIMES PROVIDED
ARE IN EASTERN STANDARD TIME.
Fronn: Arianna Vierma
To: Claribell Bedolla
CC: WPB First Party; Jacqueline P. Mever; Karen Martincavaae
Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12-3001394-20 CASE No.:
Claim No. 12-13001394-Ll (Antonio Alfaro and Diana Arevalo v. TypTap Insurance Company) CSK File:
0365.1428-00
Date: Tuesday, October 11, 2022 3:46:34 PM
[CAUTION: EXTERNAL EMAIL]
Good afternoon Claribel,
Please see the list of mediators approved by our office:
1. Eric Kleinman
2. Markel Arrizabalaga
3. Mark Greenberg
4. Robert Dulberg
5. Ilida Alvarez
6. Yamile Tamargo
7. Holly Savino
8. Peter Abraham
9. Frank Allocca
10. Henry Hernandez
11. David Salmon
12. Michael Lax
13. Laura Bonn
14. Karen Holis (Fridaysonly)
15. Robert Flayman
16. Eric Canter
17. Frank Sexton
Thank you and have a great day.
Best Regards,
Ariaima Uemm
Your Insuraiice Attorney, PLLC.
th
2601 South Bayshore Drive 18U1 Floor
Cocoiiut Grove, FL 33133
Phone No.: 1-888-570-5677
Direct: 786-809-2256
-Website: uinv.yourinsuranceattorney.coin
E-mail: ariel ina@yourinsuranceattorney.coin
IIM.YOUR INSURANCE
T-1 ATTORNEY
NOTICE: The information in this e-mail is confidential and may contain information that is attorney-
client privileged or exempt from disclosure. It is intended only for the use of the individual(s)
or
to
entity(ies) whom it is addressed. If you are not an intended recipient, you are hereby notified that
any use, dissemination, distribution or copying of this communication is prohibited. Anyone
strictly
who receives this message in error should notify the sender immediately by telephone or by return
e-mail and delete the entire message (and any attachments) from their computer. Any opinions or
advice contained in this email shall be subject to the terms and conditions set forth in the governing
Your Insurance Attorney, client engagement agreement. Thank you.
IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments
hereto are not intended to constitute a "reliance opinion" under applicable Treasury Regulations,
and accordingly are not intended or written to be used, and may not be used or relied upon, for the
purpose of (i)avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or
promoting, marketing or recommending to another party any tax-related matters addressed
(ii)
herein.
From: Claribell Bedolla
Sent: Wednesday, October 5, 2022 10:11 AM
To: Arianna Vierma
Cc: WPB First Party ; Jacqueline P. Meyer
; Karen Martincavage
Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12-
3001394-20 CASE No.: Claim No. 12-13001394-Ll (Antonio Alfaro and Diana Arevalo v. TypTap
Insurance Company) CSK File: 0365.1428-00
Good morning,
I'm followingup with my request below to schedule Mediation, if you could pleaseadvise
which Mediator you will agree to.
Thank you,
Claribell Bedolla
Scheduler
Tel: 561-383-9225 I Fax: 561-683-8977
Email: Claribell.Bedolla@csklegal.com
-
Cole, Scott & Kissane P.A.
The Florida Law Firm
222 Lakeview Avenue. Suite 120
.csklegal.com West Palm Beach, Florida, 33401
-
From: Claribell Bedolla
Sent: Tuesday, September 27, 2022 1:46 PM
To: Arianna Vierma
Cc: WPB First Party ; Jacqueline P. Meyer
; Karen Martincavage
Subject: Claim No. 12-13001394-Ll (Antonio Alfaro and Diana Arevalo v. TypTap Insurance
Company) CSK File: 0365.1428-00
Good afternoon,
At this time, our office would like to coordinate scheduling Mediation for the above
referenced matter. We propose the followingmediators:
April Walker
K&A mediations
David Sullivan
Casimir Mealiszewski
James Nicholas
David Ross
Steven Teuber
Tom Brown
Please advise if you will agree to one o f the above so that we may coordinate same.
Thank you,
Preview
Filing# 162666224 E-Filed 12/08/2022 02:28:29 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ANTONIO ALFARO and DIANA CASE NO.: CACE-21-007201 ALFARO, Plaintiffs, V TYPTAP INSURANCE COMPANY, Defendant. DEFENDANT'S MOTION TO COMPEL COMPLIANCE WITH UNIFORM TRIAL ORDER AS TO MEDIATION COMES NOW, Defendant, TypTap Insurance Company, by and through undersigned counsel, pursuant to Florida rules of Civil Procedure 1.380(b), and hereby files this Motion to Compel compliance with Uniform Trial Order dated February 19,2022, and in support thereof states as follows: 1. This case involves a dispute over property insurance coverage. 2. On February 19, 2022, the Court entered its Uniform Trial Order. 3. Pursuant to the order mediation was to take place no later than November 4,2022. 4. Defendant reached out to Plaintiffs' counsel on September 27,2022 in order to set mediation. Plaintiffs did not respond. See email correspondence within composite Exhibit A. 5. Defendant reached out to Plaintiffs' counsel again on 10/5/2022 in order to set mediation. See email correspondence within composite Exhibit A. Page 1 COLE, SCOTT & KISSANE, P.A. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/08/2022 02:28:21 PM.**** CASE NO.: CACE-21-007201 6. On October 11, 2022 Plaintiffs' counsel finallyresponded with a mediator list. See email correspondence within composite Exhibit A. 7. On November 1, 2022, Defendant provided an list of proposed mediators to Plaintiffs' counsel. See email correspondence attached hereto in composite Exhibit A. 8. On November 4,2022 Defendant sent an email following up with Plaintiffs' counsel regarding the proposed mediators. See email correspondence within composite Exhibit A. 9. On November 9, 2022 Defendant sent an email following up with Plaintiffs' counsel regarding the proposed mediators. See email correspondence within composite Exhibit A. 10. On November 9,2022 responded with its list of Plaintiff finally proposed mediators. which had been previously provided. See email correspondence within composite Exhibit A. 11.On November 11, 2022 Defendant proposed a mediator from Plaintiffs' list with availabilityon December 13, 2022 at 9:30 am. See email correspondence within composite Exhibit A. 12. Having received no response from Plaintiff,on November 14, 2022 Defendant followed up regarding setting mediation for December 13, 2022. See email correspondence within composite Exhibit A. 13. on November 29, 2022 Defendant Having received no response from Plaintiff, followed up again regarding setting mediation. See email correspondence within composite Exhibit A. 2 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILD NG - 222 LAKEV EW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (561) 683-8977 FAX CASE NO.: CACE-21-007201 14. On November 29, 2022 Plaintiffs responded that they would provide Defendant with dates for mediation the next day (November 30,2022). See email correspondence within composite Exhibit A. 15. on November 30,2022 Defendant Having received no response from Plaintiff, followed up again regarding setting mediation. See email correspondence within composite Exhibit A. 16. On December 2 2022, Defendant followed up again regarding setting mediation. See email correspondence within composite Exhibit A. 17. On December 7, 2022, Defendant reached out to Plaintiff again regarding setting mediation, stating in part, "We have reached out to your office regarding mediation numerous times and we still do not have a date, this was originallyset for 12/13 however your office failed to confirm with the mediator. The deadline per court order was for 11/4/22. This mediation needs to Occur by 12/20 as our client will be out of town for the remainder of the year." Defendant also informed the Plaintiff that it would be seeking court intervention. See email correspondence within composite Exhibit A. 18. On December 7, 2022 Plaintiff responded stating that they were checking mediators availabilities but did not provide a list of mediators nor did they confirm if they were available for the 12/13/22 proposed mediation date. See email correspondence within composite Exhibit A. 19. On December 7, 2022 Defendant provided Plaintiff with a list of mediators who were available for mediation on 12/13/2022. See email correspondence within composite Exhibit A. 3 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILD NG - 222 LAKEV EW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (561) 683-8977 FAX CASE NO.: CACE-21-007201 20. To date the only response received from Plaintiffs' counsel is that they are checking with the Plaintiffs for availability. 21.Accordingly, Plaintiffs have not complied with the court's Uniform Trial Order. WHEREFORE, Defendant respectfullyrequests that the court enter an order requiring the Plaintiffs to attend mediation within 10 days of the court's order and for any other relief deemed appropriate by the court. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 8th day of December, 2022, a true and correct copy of the foregoing was filed with the Clerk of Broward County by using the Florida Courts e-Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: Maximo A. Santiago, Esq, Your Insurance Attorney, PLLC, yia3@yourinsuranceattorney.com; eservice@yourinsuranceattorney.com, 2601 South Bayshore Drive, 18th Floor, Coconut Grove, FL 33133, (888) 570-5677/(888) 745-5677 (F), Attorney for Plaintiffs,Diana Arevalo and Antonio Alfaro. COLE, SCOTT & KISSANE, P.A. Counsel for Defendant TYPTAP INSURANCE COMPANY Esperante Building 222 Lakeview Avenue, Suite 120 West Palm Beach, Florida 33401 Telephone (561) 383-9233 Facsimile (561) 683-8977 Primary e-mail: stephen.harber@csklegal.corn Secondary e-mail: jacqueline.meyer@csklegal.corn Alternate e-mail: wpbfirstparty@csklegal.com By: s/ Jacqueline P. Meyer STEPHEN N. HARBER Florida Bar No.: 96374 JACQUELINE P. MEYER Florida Bar No.: 1010785 4 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILD NG - 222 LAKEV EW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (561) 683-8977 FAX Exhibit A Fmom: To: Ariaona Vierma; Jacquelbe P, Meyer; Ariana Rubio C-: Staphp,1 N. Harber; 18[28-Ek?LE/,#; Kamn-M=limax?n; MaL-S/Iiiagn subject: RE: TIME SENSrl-TVERUE: 5596-050 ANTONIO ALFARO & D[ANA AREVALO V5 TYTAP - (CAST IRON> Claim# 12-3001394-20 CASE No.:SERVICE OF COURT DOCUMENT CA5E NUMBER 062021CA007201-AXXXCE ALFARO, ANTONID V5 TYPTAP INSURANCE COMPANY Datm: Wecbiesday, December 7,2022 3:43:10 PM Importance: High Please be advised the following mediators have availabilityfor the originally agreed upon date of December 13, 2022. Fred Hazouri Michael McManus Alex Romano Robert Moses Please reconfrm your availabilityas well as the mediator you will agree to. Thank you for your prompt attention in this regard. Stacey Nafis Legal Assistant / Paralegal Tel 561-612-3497 I Fax 561-683-8977 Email Stacey.Nafis@csklegal.com Cole. Scott & Kissane P.A. The Florida Law firm 222 Lakeview Avenue, Suite 120 www.csklegal.com West Palm Beach, Florida, 33401 From: Stacey Nafis Sent: Wednesday, December 7,2022 3:32 PM To: Arianna Vierma ; Jacqueline F- Meyer ; Ariana Rubio Cc: Stephen N. Harber ; WPB First Party ; Karen Martincavage ; Max Santiago Subject: RE: TIME SENSITIVE RE 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP- (CAST IRON) Claim# 12-3001394-20 CASE No.: SERVICE OF COURT DOCUMENT CASE NUMBER 062021CA007201AXXXCE ALFARO, ANTONIO VS TYPTAP INSURANCE COMPANY Hi Arianna - In addition, we have requested for Mediation that you confirm availability on 12/13/21 If your office is available we will Iocate a mediator who is also available so we may get this scheduled ASAP Thank you, From: Arianna Vierma Sent: Wednesday, December 7,2022 3:27 PM To: Jacqueline P. Meyer ; Ariana Rubio Cc: Stephen N. Harber ; WPB First Party ; Karen Martincavage ; Stacey Nafis ; Max Santiago Sub}ect: RE: TIME SENSITIVE RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP- (CAST IRON) Claim# 12-3001394-20 CASE No.: SERVICE OF COURT DOCUMENT CASE NUMBER 062021CA007201AXXXCE ALFARO, ANTONIO VS TYPTAP INSURANCE COMPANY [CAUTION EXTERNAL EMAIU Good afternoon Jacqueline, As for mediation, per our conversation I was looking at the availability of each mediator and I was going to send it to your office. Thankyou. Best Regards, Ai-launa I'7ei-ina Legal Assistant to Mirimo A. Santiago and Ariana Rubio Di Natale Youi hisuraiice Attorney, PLLC. -th 2601 Soutli Baysliore Drive 5' Floor Coconut Grove, FL 33133 Phone No.: 1-888-570-5677 Direct 786-809-2256 Ufebsite: www.yourinsuraiiceattorney.coin E-mail: aviemia(@yourmsuraiiceattorney.coin /? YOURINSURANCE 1?ATTORNEY NOTICE: The information and may contain information that in this e-mail is confidential is attorney-client privileged or exempt from disclosure. It is intended only forthe use of the individual(s) orentity(ies) to whom it is addressed. If you are notan intended recipient, you are hereby notified that any use, dissemination, distribution or copying of this communication is strictly prohibited. Anyone who receives this message in error should notify thesender immediately by telephone or by return e-mail and delete the entire message (and any attachments) from their computer. Any opinions or advice contained in this email shall be subject to the terms and conditions set forth in the governing Your Insurance Attorney, client engagement agreement. Thankyou. IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a "reliance opinion" under applicable Treasury Regulations, and accordinglyare not intended or written to be used, and may not be used or relied upon, for the purpose of (i)avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or (ii)promoting, marketing or recommending to another party anytax-related matters addressed herein. *SCHEDULING NOTEr-** **C= The dates provided may have been offered to other counsels and will only be secured on a first come-first serve basis. PLEASE BE ADVISED THE DATES PROPOSED ARE NOT CONFIRMED UNTIL YOU RECEIVE A FINAL RESPONSE FROM OUR OFFICE CONFIRMING SAME. PLEASE NOTE DATES WILL BE RELEASED IF NOTICE IS NOT RECEIVED WITHIN 3 DAYS. ALL DATES AND TIMES PROVIDED ARE IN EASTERN STANDARD TIME. From: Jacqueline P. Meyer Sent: Wednesday, December 7,2022 3:25 PM To: Arianna Vierma ; Ariana Rubio Cc: Stephen N. Harber; WPB First Party ; Karen Martincavage ; Stacey Nafis ; Max Santiago Subject: TIME SENSITIVE RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12-3001394-20 CASE No.: SERVICE OF COURT DOCUMENT CASE NUMBER 062021CA007201AXXXCE ALFARO, ANTONIO VS TYPTAP INSURANCE COMPANY Importance: High Good Afternoon Ms. Rubio, We have reached out to your office regarding mediation numerous times and we still do not have a date, this was originallyset for 12/13 however your office failed to confirm with the mediator. The deadline per court order was for 11/4/22. This mediation needs to Occur by 12/20 as our client will be out of town forthe remainder of the year. Additionally, youroffice has not responded to our requests for re-inspection nor have we received your overdue discovery responses. Please call me at (561)612-3452 to discuss. Please be advised that I will be seeking court intervention bythe end of businesstoday. Jacqueline P. Meyer Associate Tel: 561-612-3452 I Fax: 561-683-8977 Email Jacqueline.Meyer@csklegal.com The Florida Law Firm Cole, Scott & Kissane P.A. 222 Lakeview Avenue. Suite 120 www.csklegal.com West Palm Beach, Florida, 33401 Fronn: Karla Velazquez To: Arianna Vierma; Stacey Nafis; via3@vourinsuranceattornev.com; ms@vourinsuranceattornev.com CC: Jacqueline P. Mever; Karen Martincavaae; WPB First Party Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12-3001394-20 CASE No.: Date: Friday, December 2,2022 4:40:21 PM Importance: High Good afternoon Arianna, I'm following up on scheduling mediation in the subject matter. Please note same must be completed by 12/20/22. We're currently holding 12/13 as we were holding it for mediation with K&A. Please provide us with proposed mediators/availabilityso that we may get this set. Thank you. Karla Velazquez Legal Assistant to Attorneys: Jaqueline Meyer Fax: 561-683-8977 Email: Karla.Velazquez@csklegal.com The Florida Law Firm Cole, Scott & Kissane P.A. www.csklegal.com 222 Lakeview Avenue, Suite 120 West Palm Beach, Florida, 33401 .j From: Karla Velazquez Sent: Wednesday, November 30,2022 2:36 PM To: Arianna Vierma ; Stacey Nafis Cc: Jacqueline P. Meyer ; Karen Martincavage ; WPB First Party Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12- 3001394-20 CASE No.: Hi Arianna, Just following up on this one. Can you please send me some for availability mediation? From: Arianna Vierma Sent: Tuesday, November 29, 2022 6:12 PM To: Karla Velazquez ; Stacey Nafis Cc: Jacqueline P. Meyer ; Karen Martincavage ; WPB First Party Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12- 3001394-20 CASE No.: [CAUTION: EXTERNAL EMAIL] Good afternoon Karla, Tomorrow, I will send you available dates for mediation on this case. Thank you and have a great day. Best Regards, Ariaima Uemm Legal ?15515miit to Maxiino A. Santjag-oaiid Al-iaiia Rubio Di .Xamle Your Insuraiice Attorney, PLLC. rtll 2601 South Bayshore Diive 5?1 Floor Cocoiiut Grove, FL 33133 Phone No.: 1-888-570-5677 Direct: 786-809-2256 -Website: www.yourinsuranceattorney.coin E-mil: aviernia@yourinsuranceattorney.coin 1 YOUR [NSURANCE l.W ATTORNEY NOTICE: The information in this e-mail is confidential and may contain information that is attorney- client privilegedor exempt from disclosure. It is intended only for the use of the individual(s) or to entity(ies) whom it is addressed. If you are not an intended recipient,you are hereby notified that any use, dissemination, distribution or copying of this communication is strictlyprohibited. Anyone who receives this message in error should notifythe sender immediately by telephone or by return e-mail and delete the entire message (and any attachments) from their computer. Any opinions or advice contained in this email shall be subject to the terms and conditions set forth in the governing Your Insurance Attorney, client engagement agreement. Thank you. IRS Circular230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a "reliance opinion" under applicable Treasury Regulations, and accordingly are not intended or written to be used, and may not be used or relied upon, for the purpose of (i)avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or promoting, marketing or (ii) recommending to another party any tax-related matters addressed herein. **SCHEDULING NOTE** The dates provided may have been offered to other counsels and will only be secured on a first come-first serve basis. PLEASE BE ADVISED THE DATES PROPOSED ARE NOT CONFIRMED UNTIL YOU RECEIVE A FINAL RESPONSE FROM OUR OFFICE CONFIRMING SAME. PLEASE NOTE DATES WILL BE RELEASED IF NOTICE IS NOT RECEIVED WITHIN 3 DAYS. ALL DATES AND TIMES PROVIDED ARE IN EASTERN STANDARD TIME. From: Karla Velazquez Sent: Tuesday, November 29,2022 4:38 PM To: Arianna Vierma ; Stacey Nafis Cc: Jacqueline P. Meyer ; Karen Martincavage ; WPB Party First 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12- Subject: RE: 3001394-20 CASE No.: Good afternoon Arianna, I have not heard back from you regarding setting mediation on this matter. Please provide available dates. Thank you. Karla Velazquez Legal Assistant to Attorneys: Jaqueline Meyer Fax: 561-683-8977 Email: Karla.Velazquez@csklegal.com - The Florida Law .csklegal.com Firm Cole, Scott & Kissane 222 Lakeview Avenue, Suite 120 West Palm Beach, Florida, 33401 P.A. From: Karla Velazquez Sent: Monday, November 14, 2022 10:09 AM To: Arianna Vierma ; Stacey Nafis Cc: Jacqueline P. Meyer ; Karen Martincavage ; WPB Party First 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12- Subject: RE: 3001394-20 CASE No.: Hi Arianna, I tried callingyou but was unable to reach you. Please let me know if we can set for 12/13 @ 9:30 a.m. with Markel Arrizabalaga. I've asked the mediator to please hold the date, but it will be released by the end of the day. Thank you. From: Karla Velazquez Sent: Friday,November 11, 2022 2:06 PM To: Arianna Vierma ; Stacey Nafis Cc: Jacqueline P. Meyer ; Karen Martincavage ; WPB First Party Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12- 3001394-20 CASE No.: Good afternoon Arianna, Markel Arrizabalaga is available on 12/13 @ 9:30 a.m. The date works for us as well as our client. Please advise if I may confirm with the Mediator. Thank you. From: Arianna Vierma Sent: Wednesday, November 9,2022 2:54 PM To: Karla Velazquez ; Stacey Nafis Cc: Jacqueline P. Meyer ; Karen Martincavage ; WPB First Party Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12- 3001394-20 CASE No.: [CAUTION: EXTERNAL EMAIL] Good afternoon Karla, Please see the list of mediators approved by our office: 1. Eric Kleinman 2. Markel Arrizabalaga 3. Mark Greenberg 4. Robert Dulberg 5. Ilida Alvarez 6. Yamile Tamargo 7. Holly Savino 8. Peter Abraham 9. Frank Allocca 10. Henry Hernandez 11. David Salmon 12. Michael Lax 13. Laura Bonn 14. Karen Holis (Fridaysonly) 15. Robert Flayman 16. Eric Canter 17. Frank Sexton Thank you and have a great day. Best Regards, Ariaima Uemm Your Insuraiice Attorney, PLLC. th 2601 South Bayshore Diive 18U1 Floor Cocoiiut Grove, FL 33133 Phone No.: 1-888-570-5677 Direct: 786-809-2256 -Website: uinv.yourinsuranceattorney.coin E-mail: ariel ina@yourinsuranceattorney.coin 1 YOUR [NSURANCE ATTORNEY Y/1 NOTICE: The information in this e-mail confidential and may contain information that is is attorney- client privilegedor exempt from disclosure. It is intended only for the use of the individual(s) or to entity(ies) whom it is addressed. If you are not an intended recipient, you are hereby notified that any use, dissemination, distribution or copying of this communication is prohibited. Anyone strictly who receives this message in error should notify the sender immediately by telephone or by return e-mail and delete the entire message (and any attachments) from their computer. Any opinions or advice contained in this email shall be subject to the terms and conditions set forth in the governing Your Insurance Attorney, client engagement agreement. Thank you. IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a "reliance opinion" under applicable Treasury Regulations, and accordingly are not intended or written to be used, and may not be used or relied upon, for the purpose of (i)avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or promoting, marketing or recommending to another party any tax-related matters addressed (ii) herein. From: Karla Velazquez Sent: Wednesday, November 9,2022 2:38 PM To: Arianna Vierma ; Stacey Nafis Cc: Jacqueline P. Meyer ; Karen Martincavage ; WPB First Party Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12- 3001394-20 CASE No.: Good afternoon Arianna, Kindly please advise as to my email below. Please et me know who your office will agree to mediate with so that I may obtain availabi ity. Thank you. Karla Velazquez Legal Assistant to Attorneys: Jaqueline Meyer Fax: 561-683-8977 Email: Karla.Velazquez@csklegal.com - 1 he Florida Law Firm .csklegal.com Cole, Scott & Kissane 222 Lakeview Avenue, Suite 120 West Palm Beach, P.A. Florida, 33401 From: Karla Velazquez Sent: Friday,November 4, 2022 10:36 AM To: Arianna Vierma ; Stacey Nafis Cc: Jacqueline P. Meyer ; Karen Martincavage ; WPB First Party Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12- 3001394-20 CASE No.: Good morning Arianna, I'm following up on my email below. Kindly please advise so that I may obtain availability. Thank you. From: Karla Velazquez Sent: Tuesday, November 1, 2022 11:54 AM To: Arianna Vierma ; Stacey Nafis Cc: Jacqueline P. Meyer ; Karen Martincavage ; WPB First Party 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12- Subject: RE: 3001394-20 CASE No.: Good morning Arianna, P ease find below proposed Mediators. P ease et me know who your office will agree to mediate with so that I may obtain availabi ity. . AprilWalker . K&A . David Sullivan . Casimir Mealiszewski . David Ross . Steven Teuber . Tom Brown Thank you. From: Arianna Vierma Sent: Monday, October 31, 2022 5:58 PM To: Karla Velazquez ; Stacey Nafis Cc: Jacqueline P. Meyer ; Karen Martincavage ; WPB First Party; Claribell Bedolla Subject: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12- 3001394-20 CASE No.: [CAUTION: EXTERNAL EMAIL] Good afternoon, Can you please provide the list of mediators your office agrees with? Thankyou. Best Regards, Ariaima Uemm Legal ?15515miit to Maxiino A. Santjag-oaiid Al-iaiia Rubio Di .Xamle Your Insuraiice Attorney, PLLC. th 2601 South Bayshore Drive 18U1 Floor Cocoiiut Grove, FL 33133 Phone No.: 1-888-570-5677 Direct: 786-809-2256 -Website: www.yourinsuranceattorney.coin E-mil: aviernia@yourinsuranceattorney.coin 1 YOUR[NSURANCE Iy?ATTORNEY NOTICE: The information in this e-mail confidential and may contain information that is is attorney- client privileged or exempt from disclosure. It is intended only for the use of the individual(s) or to entity(ies) whom it is addressed. If you are not an intended recipient,you are hereby notified that any use, dissemination, distribution or copying of this communication is strictlyprohibited. Anyone who receives this message in error should notifythe sender immediately by telephone or by return e-mail and delete the entire message (and any attachments) from their computer. Any opinions or advice contained in this email shall be subject to the terms and conditions set forth in the governing Your Insurance Attorney, client engagement agreement. Thank you. IRS Circular230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a "reliance opinion" under applicable Treasury Regulations, and accordingly are not intended or written to be used, and may not be used or relied upon, for the purpose of (i)avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or promoting, marketing or recommending to another party any tax-related matters addressed (ii) herein. **SCHEDULING NOTE** The dates provided may have been offered to other counsels and will only be secured on a first come-first serve basis. PLEASE BE ADVISED THE DATES PROPOSED ARE NOT CONFIRMED UNTIL YOU RECEIVE A FINAL RESPONSE FROM OUR OFFICE CONFIRMING SAME. PLEASE NOTE DATES WILL BE RELEASED IF NOTICE IS NOT RECEIVED WITHIN 3 DAYS. ALL DATES AND TIMES PROVIDED ARE IN EASTERN STANDARD TIME. Fronn: Arianna Vierma To: Claribell Bedolla CC: WPB First Party; Jacqueline P. Mever; Karen Martincavaae Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12-3001394-20 CASE No.: Claim No. 12-13001394-Ll (Antonio Alfaro and Diana Arevalo v. TypTap Insurance Company) CSK File: 0365.1428-00 Date: Tuesday, October 11, 2022 3:46:34 PM [CAUTION: EXTERNAL EMAIL] Good afternoon Claribel, Please see the list of mediators approved by our office: 1. Eric Kleinman 2. Markel Arrizabalaga 3. Mark Greenberg 4. Robert Dulberg 5. Ilida Alvarez 6. Yamile Tamargo 7. Holly Savino 8. Peter Abraham 9. Frank Allocca 10. Henry Hernandez 11. David Salmon 12. Michael Lax 13. Laura Bonn 14. Karen Holis (Fridaysonly) 15. Robert Flayman 16. Eric Canter 17. Frank Sexton Thank you and have a great day. Best Regards, Ariaima Uemm Your Insuraiice Attorney, PLLC. th 2601 South Bayshore Drive 18U1 Floor Cocoiiut Grove, FL 33133 Phone No.: 1-888-570-5677 Direct: 786-809-2256 -Website: uinv.yourinsuranceattorney.coin E-mail: ariel ina@yourinsuranceattorney.coin IIM.YOUR INSURANCE T-1 ATTORNEY NOTICE: The information in this e-mail is confidential and may contain information that is attorney- client privileged or exempt from disclosure. It is intended only for the use of the individual(s) or to entity(ies) whom it is addressed. If you are not an intended recipient, you are hereby notified that any use, dissemination, distribution or copying of this communication is prohibited. Anyone strictly who receives this message in error should notify the sender immediately by telephone or by return e-mail and delete the entire message (and any attachments) from their computer. Any opinions or advice contained in this email shall be subject to the terms and conditions set forth in the governing Your Insurance Attorney, client engagement agreement. Thank you. IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a "reliance opinion" under applicable Treasury Regulations, and accordingly are not intended or written to be used, and may not be used or relied upon, for the purpose of (i)avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or promoting, marketing or recommending to another party any tax-related matters addressed (ii) herein. From: Claribell Bedolla Sent: Wednesday, October 5, 2022 10:11 AM To: Arianna Vierma Cc: WPB First Party ; Jacqueline P. Meyer ; Karen Martincavage Subject: RE: 5596-050 ANTONIO ALFARO & DIANA AREVALO VS TYTAP - (CAST IRON) Claim# 12- 3001394-20 CASE No.: Claim No. 12-13001394-Ll (Antonio Alfaro and Diana Arevalo v. TypTap Insurance Company) CSK File: 0365.1428-00 Good morning, I'm followingup with my request below to schedule Mediation, if you could pleaseadvise which Mediator you will agree to. Thank you, Claribell Bedolla Scheduler Tel: 561-383-9225 I Fax: 561-683-8977 Email: Claribell.Bedolla@csklegal.com - Cole, Scott & Kissane P.A. The Florida Law Firm 222 Lakeview Avenue. Suite 120 .csklegal.com West Palm Beach, Florida, 33401 - From: Claribell Bedolla Sent: Tuesday, September 27, 2022 1:46 PM To: Arianna Vierma Cc: WPB First Party ; Jacqueline P. Meyer ; Karen Martincavage Subject: Claim No. 12-13001394-Ll (Antonio Alfaro and Diana Arevalo v. TypTap Insurance Company) CSK File: 0365.1428-00 Good afternoon, At this time, our office would like to coordinate scheduling Mediation for the above referenced matter. We propose the followingmediators: April Walker K&A mediations David Sullivan Casimir Mealiszewski James Nicholas David Ross Steven Teuber Tom Brown Please advise if you will agree to one o f the above so that we may coordinate same. Thank you,