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Filing# 159415812 E-Filed 10/17/2022 07:43:32 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: 21-16240 (07)
COMPLEX CIVIL DIVISION
JUDGE JACK TUTER
STRIKE X, LLC,
Plaintiff(s)
VS.
VILLAGE AT GULFSTREAM PARK, LLC,
Defendant(s)
ORDER RESETTING TRIAL
PRE.TRIAL INSTRUCTIONS AND CALENDAR CALL
THIS CAUSE IS SET FOR THE DOCKET COMMENCING
Monday, April3,2023 through June 23,2023
Calendar Call on Wednesday, March 8,2023 at 8:45 a.m.
Courtroom 17150
Counsel shall keep apprisedof the status and progress
of the cases in frontof them on the docket.
THIS CAUSE is set for Jury/Non Jury Trial before JUDGE JACK TUTER in
Courtroom 17150, Broward County Courthouse, 201 S.E. 6th Street, Fort
Lauderdale, Florida. The time standards set forth herein are directives
established by Florida Supreme Court Administrative Order AOSC20-23,
Amendment 12 (April 13, 2021) and Florida Rule of General Practice and
Judicial Administration 2.250, which have set a time frame for the completion
of complex civil cases within twenty-four (24) months.
However, the court
recognizes that certain unique cases may have cause for reasonable delay
beyond this time period. The parties and their counsel are on notice that due
to the nature of the cases and the potentiallength of trial,
cases in the Complex
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/17/2022 07:43:29 PM.****
Civil Division are set for an approximate trial date followingthe completion of
the preceding case. Counsel are ordered to monitor the progress of the
preceding case to ensure their preparation to immediately commence trial
when the case is called to trial. COUNSEL ARE ADVISED DUE TO THE
LENGTH OF CASES IN THIS DIVISION ANY CIRCUIT JUDGE WHO
BECOMES AVAILABLE MAY TRY THIS CASE. AS SUCH EACH CASE ON
THIS CALENDAR SHALL BE READY FOR TRIAL WHEN THE CASE IS
CALLED. FAILURE TO BE READY WHEN THE CASE IS CALLED MAY
RESULT IN THE COURT DISMISSING THE CASE OR ORDERING
APPROPRIATE SANCTIONS.
The followingrequirements are imposed on all parties by the Court:
NO LATER THAN NINETY (90) DAYS FROM THE DATE OF THIS ORDER - EXPERT
WITNESS DISCLOSURE (Filed with the Clerk and served on all counsel) The parties shall
furnish opposing counsel with the names and addresses along with complete and updated
curriculum vitae of all expert witnesses to be called at trial;
and all information regarding
expert testimony that is required by Fla. R. Civ. P. 1.280 (b)(4)(A); and shall furnish opposing
counsel with two (2) alternative dates of availability of all expert witnesses for the purpose
of taking their deposition.Both sides shall cooperate in the scheduling of expert depositions.
11. NO LATER THAN SIXTY (60) DAYS PRIOR TO TRIAL - MEDICAL EVALUATIONS: All
medical evaluations and other examinations pursuant to Fla. R. Civ. P. 1.360 shall have
been completed.
111. NO LATER THAN FORTY- FIVE {45) DAYS PRIOR TO TRIAL: All final discovery shall
have been initiated.
!M= TEN (10) DAYS PRIOR TO TRIAL: All
pretrialdiscovery,includingdiscovery
depositions or testimony preserved by video of witnesses or experts to be used at trial,
shall have been completed. Any motions in Iimine, shall be filed and served on opposing
counsel.
V. AT THE TIME OF THE ABOVE NOTICED CALENDAR CALL, the Joint Pretrial Stipulation
must be completed and timely filed with the Clerk with a copy provided to the
undersigned judge. At the time of the pretrialconference/calendar call the partiesshall be
prepared to discuss all items set forth in Fla R. Civ. P. 1.200(b).
a. Electronically Stored Information (ESI) discovery procedures can be found in 2021-20-
Gen, but are at all times governed by 2021-19-Civ.
VI. THE JOINT PRETRIAL STIPULATION MUST CONTAIN IN SEPARATELY NUMBERED
PARAGRAPHS: [A joint pretrial stipulation contemplates a single document. It
requires that all agreed matters be fully identified, and anv disputed matters be
specificallv delineated with respect to each partyl:
1. Statement of the Facts: A concise, impartialstatement of the facts of the case.
2. Stipulated Facts: A listof those facts that can be stipulatedand require no proof
at the trial.
3. Statements of Disputed Law & Fact: Those issues of law and fact that are to be
tried.
4. Exhibit Lists: Each party shall separatelylist all exhibits they intend to introduce
into evidence. Each item shall be listed
by number and description on a separate
schedule attached to the stipulation. Each exhibit shall be specifically described.
Generic descriptions of exhibits are subiect to being stricken. Counsel shall initia
each other's exhibit list and exhibits. Ali exhibits to be offered in evidence at tria
shall have been made available to
opposing counsel for examination and initialing.
Only those exhibits listed and initialed may be offered in evidence. If any party
objectsto the introduction of any such exhibit,such objectionmust be stated in the
stipulation,settingforth the grounds with specificity. Demonstrative exhibits (e.g.
charts, enlargements of exhibits) to be used at a jurytrial must be displayedto all
counsel before being shown to the jury.
5. Witness Lists: Parties shall attach and furnish counsel with a written list in
order containingthe names and addresses of all witnesses
alphabetical ("rebuttal",
"impeachment" or otherwise) intended to be called at trial.Only those witnesses
listed shall be permittedto testify.All witness lists shall include a brief
description
of the substance and scope of the testimony to be elicited from such witness. All
expert witnesses and their specialtiesshall be designated. If any party objects to
any witness, such objection must be stated in the stipulation, setting forth the
grounds with specificity. At trial all parties shall be strictly limited to witnesses
properly and timely disclosed.
6. Jury Instructions: If the trial is a jurytrial counsel shall
identifyall agreed upon
standard instructions and all special instructions. Any disputed jury instructions
shall be attached and identified as to the party that
proposed the instruction.
Copies of all agreed upon instructions or disputed instructions shall be attached to
the stipulation,along with copies of supporting statutory citations and/or case law.
7. Verdict Forms: Ifthe trial is a jurytrialthe juryverdict form shall be attached and
' designated as agreed to or disputed.-Agreed and/or disputed verdict forms shall
be attached.
8. Peremptorv Challenges: If the trial is a jurytrial,state the number of peremptory
challenges for each party.
9.
Pending Motions: Set forth a
list of all pending motions with copies attached to
the pre-trial To the extent the court has time priorto commencement of
stipulation.
the trial;all pending motions will be heard or set for hearing at the above notice
3
conference.
pretrial Ail parties shall be fullyprepared to present legalargument for
all pending motions conference.
at the pre-trial
10. Trial Estimate: Each party shall provide an estimate of the number of days of trial
for its side.
11. Daube,Y issues. All DAUBERT related issues involving any requests for
hearings on DAUBERT related evidence shall be noticed and heard - or
agreed to by the parties- no later than (30) days prior to the trial period.
FAILURE TO DO SO SHALL CONSTITUTE A WAVER OF ANY DAUBERT
RELATED EVIDENCE ISSUE. Itis within thediscretion of the Court to remove
any case for trial with pending DAUBERT issues.
M!!. NO LATER THAN TEN (10) DAYS priorto the trial period set forth above the followingshall
be completed or heard by the Court:
1. Depositions to preserve testimony of any witness, includingexperts, shall have been
completed;
2. Allpretrialmotions, depositions or proceedings related thereto and MOTIONS IN
LIMINE: AII motions to exclude witnesses or evidence of other motions directed to
the conduct of the trial for which grounds then exist must be filed and heard 2[io[ to
commencement of the trial.
VLU. MOTIONS FOR SUMMARY JUDGMENT will NOT be heard at the calendar call, or at the
time of trial.
18. SETTLEMENT: Counsel shall immediately notifythis Court in the event of settlement and
for and order of dismissal. Counsel shall also notify the Court of any
submit a stipulation
pending hearings that will be canceled as a result of the settlement.
THE PARTIES ARE CAUTIONED
REGARDING THE FOLLOWING POLICIES OF THE COURT:
1. The parties shall do all things reasonable and necessary to assure the availabilityof their
witnesses for the entire trial period or to otherwise preserve their testimony for trial as
provided by the Florida Rules of Civil Procedure. See Rules 1.300 and 1.460 Fla.R.Civ.P.
and Rule 2.545 of the Florida Rules of Judicial Administration. CONTINUANCES will only
be considered on written motion prior to calendar call.
2. NO CONTINUANCES will be granted for reasons that should have been readilyapparent
to counsel when the trial orderwas received, or due to the unavailabilityof expert
witnesses, since testimony may be preserved by deposition. No continuances will be
4
granted without Court Order upon written motion settingforth good cause pursuant to
AOSC20-23, Amendment 12 (April13, 2021) and Fla. R. Jud. Admin. 2.545(e). All
motions seeking a continuance must comply with Fla. R. Div. P. 1.460 and Fla. R. Jud.
Adm. 2.545, Continuances requested for reasons relatingto failure to follow this Order
will not be granted. ALL EXPERT TESTIMONY SHALL BE PRESERVED FOR
.
USE AT
TRIAL. UNAVAILABILITY OF EXPERTS SHALL NOT BE GROUNDS FOR
CONTINUANCE OR DELAY OF THE TRIAL. Continuances requested for reasons
relating to failure to follow this Order will not be granted.
3. The pa,tiesand counsel should be familiar with Fla. R. Civ. P 1.380 regarding Failure to
Make Discovery: Sanctions", and, Fla. Stat., §57.105, entitled "Attorney'sFee: sanctions
for raising unsupported claims or defenses; service of motions; damages for delay of
The
litigation," court may impose sanctions for failure to comply with the
requirements of
order includingdismissal of the action.
this pretrial
4. FAILURE TO ATTEND, FAILURE TO FOLLOW TIME REQUIREMENTS OR FILE
DOCUMENTS REQUIRED BY THIS COURT MAY RESULT IN THE DISMISSAL OF
THE ACTION OR THE IMPOSITION OF SANCTIONS INCLUDING STRIKING OF THE
PLEADINGS.
5. MEDIATION IS MANDATORY: Mediation shall commence no later than (60) days prior
to the calendar call. The partiesshall comply with Fla. R. Civ. P. 1.700, 1.710,1.720, and
1.730 as to the conduct of mediation. Plaintiffs counsel is appointed lead counsel to
facilitate andschedule the settlement conference with the mediator and all parties.The
partiesare free to agree to a mediator or submit three names to the court for
appointment.
6. At trial,there only be one official record transcribed by one court reporter. Plaintiff
will
shall be responsible for arranging for a court reporter unless otherwise
agreed. If a conflict
exists, the parties must resolve such conflict among themselves prior to trial.
7. Counsel any Plaintiff who is self-representedshall be responsiblefor
for the Plaintiff or
making sure counsel or any self-represented
all party is served a copy of this order in
accordance with the Florida Rules of General Practice and Judicial Administration and
Florida Rules of Civil Procedure.
DONE AND ORDERED at Fort Lauderdale, Florida, this 17th day of October, 2022.
E,d.POE
JACK TUTER
Circuit Court Judge
Complex Civil Division
5
Copies furnished to counsel of record:
If you are a person with a disability who needs any accommodation in order to
participate in this proceeding,you are entitled at no cost to you to the provisionof
certain assistance. Please contact the Court Administrator's ADA Coordinator at
201 S.E. 6th Street, Fort Lauderdale, Florida 33301, telephone number 954-831-
7721 within two working days of your receiptof this document. If
you are hearing
impaired, call (954) 831-7017 (TTY), or 1-800-955-8770 (Voice).
6
Copies Furnished to:
Jennifer Junger, Email :
jungerj@gtlaw.corn
Jennifer Junger, Email :
Jon Polenberg, Email :
tfritz@beckerlawyers.com
Jon Polenberg, Email jpolenberg@beckerlawyers.corn
:
Jon Polenberg, Email : ftlefile@beckerlawyers.corn
Jordanna Ishmael, Email :
Jordanna Ishmael, Email :
cohenpa@gtlaw.corn
Jordanna Ishmael, Email :
ishmaelj@gtlaw.corn
MICHAEL N. KREITZER, Email : kreitzerm@gtlaw.com
MICHAEL N. KREITZER, Email belloy@gtlaw.com :
Mary Nikezic, Email mnikezic@zarcolaw.com
:
Mary Nikezic, Email :
Nancy Ginart, Email : ginartn@gtlaw.corn
Robert F. Salkowski, Email :
rsalkowski@zarcolaw.corn
Robert F. Salkowski, Email :
acoro@zarcolaw.corn
Robert F. Salkowski, Email :
eservice@zarcolaw.corn
Robert Zarco, Email :
abustillo@zarcolaw.corn
Robert Zarco, Email :
reception@zarcolaw.corn
Robert Zarco, Email :
Preview
Filing# 159415812 E-Filed 10/17/2022 07:43:32 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: 21-16240 (07) COMPLEX CIVIL DIVISION JUDGE JACK TUTER STRIKE X, LLC, Plaintiff(s) VS. VILLAGE AT GULFSTREAM PARK, LLC, Defendant(s) ORDER RESETTING TRIAL PRE.TRIAL INSTRUCTIONS AND CALENDAR CALL THIS CAUSE IS SET FOR THE DOCKET COMMENCING Monday, April3,2023 through June 23,2023 Calendar Call on Wednesday, March 8,2023 at 8:45 a.m. Courtroom 17150 Counsel shall keep apprisedof the status and progress of the cases in frontof them on the docket. THIS CAUSE is set for Jury/Non Jury Trial before JUDGE JACK TUTER in Courtroom 17150, Broward County Courthouse, 201 S.E. 6th Street, Fort Lauderdale, Florida. The time standards set forth herein are directives established by Florida Supreme Court Administrative Order AOSC20-23, Amendment 12 (April 13, 2021) and Florida Rule of General Practice and Judicial Administration 2.250, which have set a time frame for the completion of complex civil cases within twenty-four (24) months. However, the court recognizes that certain unique cases may have cause for reasonable delay beyond this time period. The parties and their counsel are on notice that due to the nature of the cases and the potentiallength of trial, cases in the Complex *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/17/2022 07:43:29 PM.**** Civil Division are set for an approximate trial date followingthe completion of the preceding case. Counsel are ordered to monitor the progress of the preceding case to ensure their preparation to immediately commence trial when the case is called to trial. COUNSEL ARE ADVISED DUE TO THE LENGTH OF CASES IN THIS DIVISION ANY CIRCUIT JUDGE WHO BECOMES AVAILABLE MAY TRY THIS CASE. AS SUCH EACH CASE ON THIS CALENDAR SHALL BE READY FOR TRIAL WHEN THE CASE IS CALLED. FAILURE TO BE READY WHEN THE CASE IS CALLED MAY RESULT IN THE COURT DISMISSING THE CASE OR ORDERING APPROPRIATE SANCTIONS. The followingrequirements are imposed on all parties by the Court: NO LATER THAN NINETY (90) DAYS FROM THE DATE OF THIS ORDER - EXPERT WITNESS DISCLOSURE (Filed with the Clerk and served on all counsel) The parties shall furnish opposing counsel with the names and addresses along with complete and updated curriculum vitae of all expert witnesses to be called at trial; and all information regarding expert testimony that is required by Fla. R. Civ. P. 1.280 (b)(4)(A); and shall furnish opposing counsel with two (2) alternative dates of availability of all expert witnesses for the purpose of taking their deposition.Both sides shall cooperate in the scheduling of expert depositions. 11. NO LATER THAN SIXTY (60) DAYS PRIOR TO TRIAL - MEDICAL EVALUATIONS: All medical evaluations and other examinations pursuant to Fla. R. Civ. P. 1.360 shall have been completed. 111. NO LATER THAN FORTY- FIVE {45) DAYS PRIOR TO TRIAL: All final discovery shall have been initiated. !M= TEN (10) DAYS PRIOR TO TRIAL: All pretrialdiscovery,includingdiscovery depositions or testimony preserved by video of witnesses or experts to be used at trial, shall have been completed. Any motions in Iimine, shall be filed and served on opposing counsel. V. AT THE TIME OF THE ABOVE NOTICED CALENDAR CALL, the Joint Pretrial Stipulation must be completed and timely filed with the Clerk with a copy provided to the undersigned judge. At the time of the pretrialconference/calendar call the partiesshall be prepared to discuss all items set forth in Fla R. Civ. P. 1.200(b). a. Electronically Stored Information (ESI) discovery procedures can be found in 2021-20- Gen, but are at all times governed by 2021-19-Civ. VI. THE JOINT PRETRIAL STIPULATION MUST CONTAIN IN SEPARATELY NUMBERED PARAGRAPHS: [A joint pretrial stipulation contemplates a single document. It requires that all agreed matters be fully identified, and anv disputed matters be specificallv delineated with respect to each partyl: 1. Statement of the Facts: A concise, impartialstatement of the facts of the case. 2. Stipulated Facts: A listof those facts that can be stipulatedand require no proof at the trial. 3. Statements of Disputed Law & Fact: Those issues of law and fact that are to be tried. 4. Exhibit Lists: Each party shall separatelylist all exhibits they intend to introduce into evidence. Each item shall be listed by number and description on a separate schedule attached to the stipulation. Each exhibit shall be specifically described. Generic descriptions of exhibits are subiect to being stricken. Counsel shall initia each other's exhibit list and exhibits. Ali exhibits to be offered in evidence at tria shall have been made available to opposing counsel for examination and initialing. Only those exhibits listed and initialed may be offered in evidence. If any party objectsto the introduction of any such exhibit,such objectionmust be stated in the stipulation,settingforth the grounds with specificity. Demonstrative exhibits (e.g. charts, enlargements of exhibits) to be used at a jurytrial must be displayedto all counsel before being shown to the jury. 5. Witness Lists: Parties shall attach and furnish counsel with a written list in order containingthe names and addresses of all witnesses alphabetical ("rebuttal", "impeachment" or otherwise) intended to be called at trial.Only those witnesses listed shall be permittedto testify.All witness lists shall include a brief description of the substance and scope of the testimony to be elicited from such witness. All expert witnesses and their specialtiesshall be designated. If any party objects to any witness, such objection must be stated in the stipulation, setting forth the grounds with specificity. At trial all parties shall be strictly limited to witnesses properly and timely disclosed. 6. Jury Instructions: If the trial is a jurytrial counsel shall identifyall agreed upon standard instructions and all special instructions. Any disputed jury instructions shall be attached and identified as to the party that proposed the instruction. Copies of all agreed upon instructions or disputed instructions shall be attached to the stipulation,along with copies of supporting statutory citations and/or case law. 7. Verdict Forms: Ifthe trial is a jurytrialthe juryverdict form shall be attached and ' designated as agreed to or disputed.-Agreed and/or disputed verdict forms shall be attached. 8. Peremptorv Challenges: If the trial is a jurytrial,state the number of peremptory challenges for each party. 9. Pending Motions: Set forth a list of all pending motions with copies attached to the pre-trial To the extent the court has time priorto commencement of stipulation. the trial;all pending motions will be heard or set for hearing at the above notice 3 conference. pretrial Ail parties shall be fullyprepared to present legalargument for all pending motions conference. at the pre-trial 10. Trial Estimate: Each party shall provide an estimate of the number of days of trial for its side. 11. Daube,Y issues. All DAUBERT related issues involving any requests for hearings on DAUBERT related evidence shall be noticed and heard - or agreed to by the parties- no later than (30) days prior to the trial period. FAILURE TO DO SO SHALL CONSTITUTE A WAVER OF ANY DAUBERT RELATED EVIDENCE ISSUE. Itis within thediscretion of the Court to remove any case for trial with pending DAUBERT issues. M!!. NO LATER THAN TEN (10) DAYS priorto the trial period set forth above the followingshall be completed or heard by the Court: 1. Depositions to preserve testimony of any witness, includingexperts, shall have been completed; 2. Allpretrialmotions, depositions or proceedings related thereto and MOTIONS IN LIMINE: AII motions to exclude witnesses or evidence of other motions directed to the conduct of the trial for which grounds then exist must be filed and heard 2[io[ to commencement of the trial. VLU. MOTIONS FOR SUMMARY JUDGMENT will NOT be heard at the calendar call, or at the time of trial. 18. SETTLEMENT: Counsel shall immediately notifythis Court in the event of settlement and for and order of dismissal. Counsel shall also notify the Court of any submit a stipulation pending hearings that will be canceled as a result of the settlement. THE PARTIES ARE CAUTIONED REGARDING THE FOLLOWING POLICIES OF THE COURT: 1. The parties shall do all things reasonable and necessary to assure the availabilityof their witnesses for the entire trial period or to otherwise preserve their testimony for trial as provided by the Florida Rules of Civil Procedure. See Rules 1.300 and 1.460 Fla.R.Civ.P. and Rule 2.545 of the Florida Rules of Judicial Administration. CONTINUANCES will only be considered on written motion prior to calendar call. 2. NO CONTINUANCES will be granted for reasons that should have been readilyapparent to counsel when the trial orderwas received, or due to the unavailabilityof expert witnesses, since testimony may be preserved by deposition. No continuances will be 4 granted without Court Order upon written motion settingforth good cause pursuant to AOSC20-23, Amendment 12 (April13, 2021) and Fla. R. Jud. Admin. 2.545(e). All motions seeking a continuance must comply with Fla. R. Div. P. 1.460 and Fla. R. Jud. Adm. 2.545, Continuances requested for reasons relatingto failure to follow this Order will not be granted. ALL EXPERT TESTIMONY SHALL BE PRESERVED FOR . USE AT TRIAL. UNAVAILABILITY OF EXPERTS SHALL NOT BE GROUNDS FOR CONTINUANCE OR DELAY OF THE TRIAL. Continuances requested for reasons relating to failure to follow this Order will not be granted. 3. The pa,tiesand counsel should be familiar with Fla. R. Civ. P 1.380 regarding Failure to Make Discovery: Sanctions", and, Fla. Stat., §57.105, entitled "Attorney'sFee: sanctions for raising unsupported claims or defenses; service of motions; damages for delay of The litigation," court may impose sanctions for failure to comply with the requirements of order includingdismissal of the action. this pretrial 4. FAILURE TO ATTEND, FAILURE TO FOLLOW TIME REQUIREMENTS OR FILE DOCUMENTS REQUIRED BY THIS COURT MAY RESULT IN THE DISMISSAL OF THE ACTION OR THE IMPOSITION OF SANCTIONS INCLUDING STRIKING OF THE PLEADINGS. 5. MEDIATION IS MANDATORY: Mediation shall commence no later than (60) days prior to the calendar call. The partiesshall comply with Fla. R. Civ. P. 1.700, 1.710,1.720, and 1.730 as to the conduct of mediation. Plaintiffs counsel is appointed lead counsel to facilitate andschedule the settlement conference with the mediator and all parties.The partiesare free to agree to a mediator or submit three names to the court for appointment. 6. At trial,there only be one official record transcribed by one court reporter. Plaintiff will shall be responsible for arranging for a court reporter unless otherwise agreed. If a conflict exists, the parties must resolve such conflict among themselves prior to trial. 7. Counsel any Plaintiff who is self-representedshall be responsiblefor for the Plaintiff or making sure counsel or any self-represented all party is served a copy of this order in accordance with the Florida Rules of General Practice and Judicial Administration and Florida Rules of Civil Procedure. DONE AND ORDERED at Fort Lauderdale, Florida, this 17th day of October, 2022. E,d.POE JACK TUTER Circuit Court Judge Complex Civil Division 5 Copies furnished to counsel of record: If you are a person with a disability who needs any accommodation in order to participate in this proceeding,you are entitled at no cost to you to the provisionof certain assistance. Please contact the Court Administrator's ADA Coordinator at 201 S.E. 6th Street, Fort Lauderdale, Florida 33301, telephone number 954-831- 7721 within two working days of your receiptof this document. If you are hearing impaired, call (954) 831-7017 (TTY), or 1-800-955-8770 (Voice). 6 Copies Furnished to: Jennifer Junger, Email : jungerj@gtlaw.corn Jennifer Junger, Email : Jon Polenberg, Email : tfritz@beckerlawyers.com Jon Polenberg, Email jpolenberg@beckerlawyers.corn : Jon Polenberg, Email : ftlefile@beckerlawyers.corn Jordanna Ishmael, Email : Jordanna Ishmael, Email : cohenpa@gtlaw.corn Jordanna Ishmael, Email : ishmaelj@gtlaw.corn MICHAEL N. KREITZER, Email : kreitzerm@gtlaw.com MICHAEL N. KREITZER, Email belloy@gtlaw.com : Mary Nikezic, Email mnikezic@zarcolaw.com : Mary Nikezic, Email : Nancy Ginart, Email : ginartn@gtlaw.corn Robert F. Salkowski, Email : rsalkowski@zarcolaw.corn Robert F. Salkowski, Email : acoro@zarcolaw.corn Robert F. Salkowski, Email : eservice@zarcolaw.corn Robert Zarco, Email : abustillo@zarcolaw.corn Robert Zarco, Email : reception@zarcolaw.corn Robert Zarco, Email :