On May 05, 2022 a
Hearing
was filed
involving a dispute between
and
for CONTRACT
in the District Court of Leon County.
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IN THE COURT OF THE SECOND JUDICIAL CIRCUIT
IN AND FOR LEON COUNTY, FLORIDA
CuptyPlaintiff/Petitioner,
os Restoratyan Enc
Case No QO aa, th 7 z&
Boye rly Weeds
Defendant/Respondent.
EMLrgenc f-
MOTION To/FOR Rescheduie. Hearng
(Indicate on the line above the actions you are requesting of | the court)
Reverly Weedsa> asks this Honorable Court to
Reschrdu Te Hear, Ng
(describe the action you are requesting of the court), and alleges the following facts in support
of this motion:
LL felertHy (tak _a_leter Set +0 mg
Feqular marl instica hing MOhpa +e wHhayaw/ Ly
bons) ] and rule Mr “he motto 15 Serkmber 25, 203.
> Laled Clerk f. Os uf earlier today % 23
And wes to )f be hearing Stomownw F-T- £3 €&
3°30 pM.
sL nee an LHS orn [roscfedu heenrg
4o_opftain another Lawyer 4 90 fags
BS
Rev, 9/7/2011
For the above reasons, (Schedule he ar 14 asks this
4
Honorable Court to enter an order granting his/her motio1
UpBeverly
ignature ofFilet
WWeedsay
Print name
Lost Hrah Miadpw Rr
Street Address (/
Tallah a55¢2, FL 32311
City/State/Zip
950 b3l-) 105 —
Area Code & Telephone #
haweed 5017 3/2 Shay) « CA
Email Address
Certificate of Service
THEREBY CERTIFY that a copy of the above has been provided by U.S. Mail to
, at
, onthis day of
ev. 9/7/2011
i aQPn.Sieneufe * Filer
Rev. 9/7/2011
Ba PENNINGTON. Stuart C. Poage, Esq.
Florida Bar Board Certified
Construction Lawyer
Circuit Civil Mediator &
AAA Arbitrator
Admitted in FL, GA and KY
Phone: (850) 222-3533
spoage@penningtonlaw.com
June 13, 2023
VIA EMAIL, U.S. CERTIFIED MAIL, AND REGULAR U.S. MAIL
Beverly Woodson
1054 High Meadows Drive
Tallahassee, Florida 32311
Bawoodson31 gmail.com
Re: Settlement Funds Status and Case Management Order from Judge Cooper
Dear Ms. Woodson:
I hope you are doing well. We have not heard form you since our last text message
communication in February wherein you indicated your belief that you would have the agreed-to
$70,0000 settlement funds by March 2023. Unfortunately, we have not heard anything further from
you since that time. I have spoken to Cypress Restorations’ attorney John Black on several occasions
in recent months. He has been very cooperative in delaying his client’s pursuit of the foreclosure order
against you.
However, today we received the attached Order from Circuit Judge John Cooper wherein he
has scheduled a formal case management conference to take place at 3:30PM on September 25, 2023.
The stated purpose will be to determine the status of the case and, most likely, establish a potential
sale date of your home if the settlement agreement has not been finalized by that time.
Ms. Woodson, we have reached a crossroads. As you recall, Cypress Restoration was seeking
a six-figure recovery against you which was negotiated to a Seventy Thousand Dollar ($70,000.00)
all-inclusive settlement agreement which you specifically authorized after confirming to me that you
had the necessary settlement funds. It was only after mediation, and your execution of the mediation
agreement, that you informed me you did not, in fact, have the necessary settlement funds remaining
from the previous insurance payments. From that point, we worked with opposing counsel to delay
Plaintiff's enforcement of the settlement agreement in an effort to provide you with additional time to
obtain the necessary funds, or at least a portion thereof to provide as a good-faith payment. Yet, we
have heard nothing from you.
If you now have the available $70,000 settlement funds as you previously agreed, please
contact me so we can make arrangements with Cypress Restoration to complete the settlement
agreement. Please be advised that you will also be responsible for additional attorneys’ fees incurred
by Cypress Restoration for their enforcement of the settlement agreement and accrued interest from
the time the settlement payment was due. We believe John Black will be negotiable in the amounts
owed for fees and costs if the principle amount is paid. Otherwise, I do not believe there are additional
legal services I can offer you at this point in time. If we do not hear from you by June 30", [ will
prepare a formal Motion to Withdraw as your legal counsel and ask the court to consider and rule on
the motion at the September 25" hearing.
Please update me on your efforts to collect the required settlement funds to satisfy the overdue
settlement amount at your earliest convenience. If you have any questions or need clarification on this
issue, please do not hesitate to contact us.
Sincerely,
Sta
Stuart C. Poage
SCP
Enclosure: Order for Case Management Conference
Document Filed Date
September 06, 2023
Case Filing Date
May 05, 2022
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IN THE COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR LEON COUNTY, FLORIDA CuptyPlaintiff/Petitioner, os Restoratyan Enc Case No QO aa, th 7 z& Boye rly Weeds Defendant/Respondent. EMLrgenc f- MOTION To/FOR Rescheduie. Hearng (Indicate on the line above the actions you are requesting of | the court) Reverly Weedsa> asks this Honorable Court to Reschrdu Te Hear, Ng (describe the action you are requesting of the court), and alleges the following facts in support of this motion: LL felertHy (tak _a_leter Set +0 mg Feqular marl instica hing MOhpa +e wHhayaw/ Ly bons) ] and rule Mr “he motto 15 Serkmber 25, 203. > Laled Clerk f. Os uf earlier today % 23 And wes to )f be hearing Stomownw F-T- £3 €& 3°30 pM. sL nee an LHS orn [roscfedu heenrg 4o_opftain another Lawyer 4 90 fags BS Rev, 9/7/2011 For the above reasons, (Schedule he ar 14 asks this 4 Honorable Court to enter an order granting his/her motio1 UpBeverly ignature ofFilet WWeedsay Print name Lost Hrah Miadpw Rr Street Address (/ Tallah a55¢2, FL 32311 City/State/Zip 950 b3l-) 105 — Area Code & Telephone # haweed 5017 3/2 Shay) « CA Email Address Certificate of Service THEREBY CERTIFY that a copy of the above has been provided by U.S. Mail to , at , onthis day of ev. 9/7/2011 i aQPn.Sieneufe * Filer Rev. 9/7/2011 Ba PENNINGTON. Stuart C. Poage, Esq. Florida Bar Board Certified Construction Lawyer Circuit Civil Mediator & AAA Arbitrator Admitted in FL, GA and KY Phone: (850) 222-3533 spoage@penningtonlaw.com June 13, 2023 VIA EMAIL, U.S. CERTIFIED MAIL, AND REGULAR U.S. MAIL Beverly Woodson 1054 High Meadows Drive Tallahassee, Florida 32311 Bawoodson31 gmail.com Re: Settlement Funds Status and Case Management Order from Judge Cooper Dear Ms. Woodson: I hope you are doing well. We have not heard form you since our last text message communication in February wherein you indicated your belief that you would have the agreed-to $70,0000 settlement funds by March 2023. Unfortunately, we have not heard anything further from you since that time. I have spoken to Cypress Restorations’ attorney John Black on several occasions in recent months. He has been very cooperative in delaying his client’s pursuit of the foreclosure order against you. However, today we received the attached Order from Circuit Judge John Cooper wherein he has scheduled a formal case management conference to take place at 3:30PM on September 25, 2023. The stated purpose will be to determine the status of the case and, most likely, establish a potential sale date of your home if the settlement agreement has not been finalized by that time. Ms. Woodson, we have reached a crossroads. As you recall, Cypress Restoration was seeking a six-figure recovery against you which was negotiated to a Seventy Thousand Dollar ($70,000.00) all-inclusive settlement agreement which you specifically authorized after confirming to me that you had the necessary settlement funds. It was only after mediation, and your execution of the mediation agreement, that you informed me you did not, in fact, have the necessary settlement funds remaining from the previous insurance payments. From that point, we worked with opposing counsel to delay Plaintiff's enforcement of the settlement agreement in an effort to provide you with additional time to obtain the necessary funds, or at least a portion thereof to provide as a good-faith payment. Yet, we have heard nothing from you. If you now have the available $70,000 settlement funds as you previously agreed, please contact me so we can make arrangements with Cypress Restoration to complete the settlement agreement. Please be advised that you will also be responsible for additional attorneys’ fees incurred by Cypress Restoration for their enforcement of the settlement agreement and accrued interest from the time the settlement payment was due. We believe John Black will be negotiable in the amounts owed for fees and costs if the principle amount is paid. Otherwise, I do not believe there are additional legal services I can offer you at this point in time. If we do not hear from you by June 30", [ will prepare a formal Motion to Withdraw as your legal counsel and ask the court to consider and rule on the motion at the September 25" hearing. Please update me on your efforts to collect the required settlement funds to satisfy the overdue settlement amount at your earliest convenience. If you have any questions or need clarification on this issue, please do not hesitate to contact us. Sincerely, Sta Stuart C. Poage SCP Enclosure: Order for Case Management Conference