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Filing # 125798708 E-Filed 04/28/2021 04:52:55 PM
ABAYOMI MANRIQUE, IN THE COUNTY COURT OF THE 17TH
Plaintiff (s), JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
PROGRESSIVE AMERICAN INSURANCE CASE NO.: COWE21001213
COMPANY, a Foreign Profit Corporation,
Defendant (s)
/
NOTICE OF MEDIATION
Steve Louis-Charles, Esquire Alexandra Maria Taboada, Esquire
Charles Legal, PLLC Law Offices of Michael W. Carroll
930 South State Road 7 3230 West Commercial Boulevard Suite 400
Plantation, Florida 33317-4523 Fort Lauderdale, Florida 33309-3400
Phone: (954) 342-6446 Fax: (954) 301-7700 Phone: 305-890-4433
steve@charleslegalpl.com; alexandra_m_taboada@progressive.com;
LISA_BAILEY @progressive.com;
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:
MEDIATOR: PATTI A. VELASQUEZ, ESQUIRE
LOCATION: ALL PARTIES APPEARING VIA ZOOM
DATE WEDNESDAY, JUNE 23, 2021
STARTING TIME 11:00 AM- 1:00 PM
PARTIES ARE ENCOURAGED TO SUBMIT
patti@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.
I HEREBY CERTIFY that a true and correct copy of the foregoing was provided via facsimile or email to the
above-named addressees this 28th day of April, 2021.
MATRIX BY: /s/
Patti A. Velasquez, Esquire
Florida Bar No.: 403570/Mediator No.: 22354FR
MEDIATION 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 04/28/2021 04:52:54 PM.**#*
Date: Wednesday, April 28, 2021
a MATRIX
MEDIATION
Re: Manrique vs. Progressive
Case No.: COWE21001213
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 Ms. Velasquez, and we are committed to adding value to your case and to your practice.
Page 2 of 4
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
Date: Wednesday, April 28, 2021
a MATRIX
MEDIATION
Re: Manrique vs. Progressive
Case No.: COWE21001213
Claim No.:
Notice, Terms of Engagement, Cancellation Policy, Security Information
TERMS OF ENGAGEMENT WITH MATRIX MEDIATION
Please Read Upon Receipt
Thank you for choosing Patti A. Velasquez 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 Ms. Velasquez is an experienced
trial attorney, she does not provide legal advice or representation to the parties.
Fees- Ms. Velasquez’s hourly rate is $150.00 per hour/per party for two party cases.
For more than three parties, Ms. Velasquez’s three-party hourly rate shall be allocated equally among the parties. A $49.00
per party facilities fee will be charged, which includes a break-out room, scheduling, filing, copies, long-distance calls, and
AV equipment. There is NO CHARGE for travel.
Unless agreed differently by the parties, fees are allocated equally among the separate entities (¢.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 two (2) minimum for this case. If the case exceeds the minimum, the parties guarantee
payment for time used. There is NO CHARGE for travel.
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 — Ms. Velasquez encourages parties to submit summaries and other
information at least 48 hours before the scheduled mediation. This gives Ms. Velasquez a chance to think about the
particular issues and custom design the most effective process.
Ms. Velasquez can be reached on her cell at (561) 350-7340, the office (561) 340-3500, or at patti@matrixmediation.com.
Thank you for choosing Ms. Velasquez and Matrix Mediation. Ms. Velasquez looks forward to achieving a successful
resolution.
Sincerely,
Abert Fadraga
Albert Fadraga, Scheduling Coordinator
albert@matrixmediation.com
Matrix Mediation (561) 340-3500 (800) 379-2580
Page 3 of 4
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
Date: Wednesday, April 28, 2021
a MATRIX
MEDIATION
Re: Manrique vs. Progressive
Case No.: COWE21001213
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
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 # 125798708 E-Filed 04/28/2021 04:52:55 PM ABAYOMI MANRIQUE, IN THE COUNTY COURT OF THE 17TH Plaintiff (s), JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA PROGRESSIVE AMERICAN INSURANCE CASE NO.: COWE21001213 COMPANY, a Foreign Profit Corporation, Defendant (s) / NOTICE OF MEDIATION Steve Louis-Charles, Esquire Alexandra Maria Taboada, Esquire Charles Legal, PLLC Law Offices of Michael W. Carroll 930 South State Road 7 3230 West Commercial Boulevard Suite 400 Plantation, Florida 33317-4523 Fort Lauderdale, Florida 33309-3400 Phone: (954) 342-6446 Fax: (954) 301-7700 Phone: 305-890-4433 steve@charleslegalpl.com; alexandra_m_taboada@progressive.com; LISA_BAILEY @progressive.com; 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: MEDIATOR: PATTI A. VELASQUEZ, ESQUIRE LOCATION: ALL PARTIES APPEARING VIA ZOOM DATE WEDNESDAY, JUNE 23, 2021 STARTING TIME 11:00 AM- 1:00 PM PARTIES ARE ENCOURAGED TO SUBMIT patti@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. I HEREBY CERTIFY that a true and correct copy of the foregoing was provided via facsimile or email to the above-named addressees this 28th day of April, 2021. MATRIX BY: /s/ Patti A. Velasquez, Esquire Florida Bar No.: 403570/Mediator No.: 22354FR MEDIATION 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 04/28/2021 04:52:54 PM.**#* Date: Wednesday, April 28, 2021 a MATRIX MEDIATION Re: Manrique vs. Progressive Case No.: COWE21001213 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 Ms. Velasquez, and we are committed to adding value to your case and to your practice. Page 2 of 4 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 Date: Wednesday, April 28, 2021 a MATRIX MEDIATION Re: Manrique vs. Progressive Case No.: COWE21001213 Claim No.: Notice, Terms of Engagement, Cancellation Policy, Security Information TERMS OF ENGAGEMENT WITH MATRIX MEDIATION Please Read Upon Receipt Thank you for choosing Patti A. Velasquez 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 Ms. Velasquez is an experienced trial attorney, she does not provide legal advice or representation to the parties. Fees- Ms. Velasquez’s hourly rate is $150.00 per hour/per party for two party cases. For more than three parties, Ms. Velasquez’s three-party hourly rate shall be allocated equally among the parties. A $49.00 per party facilities fee will be charged, which includes a break-out room, scheduling, filing, copies, long-distance calls, and AV equipment. There is NO CHARGE for travel. Unless agreed differently by the parties, fees are allocated equally among the separate entities (¢.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 two (2) minimum for this case. If the case exceeds the minimum, the parties guarantee payment for time used. There is NO CHARGE for travel. 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 — Ms. Velasquez encourages parties to submit summaries and other information at least 48 hours before the scheduled mediation. This gives Ms. Velasquez a chance to think about the particular issues and custom design the most effective process. Ms. Velasquez can be reached on her cell at (561) 350-7340, the office (561) 340-3500, or at patti@matrixmediation.com. Thank you for choosing Ms. Velasquez and Matrix Mediation. Ms. Velasquez looks forward to achieving a successful resolution. Sincerely, Abert Fadraga Albert Fadraga, Scheduling Coordinator albert@matrixmediation.com Matrix Mediation (561) 340-3500 (800) 379-2580 Page 3 of 4 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 Date: Wednesday, April 28, 2021 a MATRIX MEDIATION Re: Manrique vs. Progressive Case No.: COWE21001213 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 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