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Filing # 80161736 E-Filed 10/31/2018 05:00:36 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: 18-001290
KAREN ECHEVERRY,
PLAINTIFF,
ve
MICHAEL R. HOWARD,
DEFENDANT.
Pee eee
Evan R. Krakower, Esquire Lisa J. Baligian, Esquire
Evan R. Krakower, P.A. Nicholas J. Ryan & Associates
10061 N.W. 1st Court 110 S.E. 6th Street, Suite 2100
Plantation, FL 33324 Ft. Lauderdale, FL 33301
Email: evanrkrakowerpa@yahoo.com; Email: florlaw-
lisabaligian.294019@statefarm.com;
marva.goulbourne.pemd@statefarm.com
NOTICE OF MEDIATION
YOU ARE HEREBY NOTIFIED, pursuant to the agreement of the parties and the provisions of Florida
Statutes Chapter 44, that a Mediation Conference has been scheduled as follows:
Mediator: Judith A. Bass
Mediation Date: January 9, 2019
Mediation Time: 1:00 P.M.
Mediation Location: Upchurch Watson White & Max, Royal Palm II at Southpointe, 900 S. Pine
Island Road, Suite 410, Plantation, FL 33324
Time Reserved: 3.00 Hours
‘The terms and provisions of the confirmation letter accompanying this Notice of Mediation are hereby incorporated
by reference into this Notice of Mediation.
If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are
entitled to the provision of certain assistance at no cost to you. Please contact the ADA Coordinator in the
Administrative office of Upchurch Watson White & Max, 125 S. Palmetto Avenue, Daytona Beach, FL 32114,
Telephone 386-253-1560 or 800-264-2622, within two (2) working days of receipt of this Notice of Mediation.
I HEREBY CERTIFY that a true and correct copy of the foregoing Notice of Mediation has been served
by e-mail to the above named addressees on Wednesday, October 31, 2018,
UPCHURCH WATSON WHITE & MAX
Royal Palm at Southpointe
900 South Pine Island Road, Suite 410
Plantation, FL 33324
Phone: 954-423-8856 / Fax: 954-334-2838
Toll Free: 800-863-1462
Website: www.uww-adr.com
Pons
BY:
Judith A. Bass, Esquire~ Shareholder
FL Bar No. 262927
DAYTONA BEACH * MAITLAND/ORLANDO ¢ OCALA ¢ JACKSONVILLE ¢ FORT LAUDERDALE * WesT PALM BEACH * MIAMI ¢ BIRMINGHAM
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/31/2018 5:00:36 PM.****Royal Palm II at Southpointe
900 South Pine Island Road
Suite 410
Plantation, FL 33324
: Telephone: 954-423-8856
Upchurch Watson White & Max Toll Free: 800-863-1462
MEDIATION GROUP Facsimile:954-334-2838
Website: www.uww-adr.com
VIA E-MAIL
October 31, 2018
RE: ECHEVERRY VS HOWARD
Case #: 18-001290
FILE #: 19JAB-003
Dear Counsel:
We greatly appreciate your confidence and trust in choosing Judy Bass as your mediator.
To address your anticipated questions and avoid any possible misunderstandings, this letter
confirms the terms and conditions of her engagement and the manner in which the mediation shall
be conducted.
Conduct of mediation: Unless otherwise agreed by the parties or ordered by the Court, this
mediation shall be conducted according to all applicable Florida statutes and rules and specifically
includes all protections of privilege, confidentiality, and immunity. Ms. Bass shall serve as an
independent mediator and will not provide legal representation or legal advice to any mediation
participant.
Interpreter: Should your client or any mediation participant require an interpreter, please make
the necessary arrangements in advance for an interpreter’s presence at the time of mediation.
Mediation Fee: The mediation fee is calculated based upon Ms. Bass's billing rate, the time
reserved, and any pre-mediation or post-mediation time she spends on this matter. There is a two
hour minimum charge for all mediations held in Broward County and Boca Raton, and a three
hour minimum charge for those held in Miami-Dade County and West Palm Beach. There is NO
administrative charge and NO charge for travel time and expenses unless mutually agreed upon in
writing.
Allocation of Fees & Payment: Unless otherwise agreed, the mediation fees and costs shall be
divided equally among the parties participating in the mediation. Payment is due upon your receipt
of our bill. While our bill may be subject to reimbursement from your client to you, or even
forwarded to your client for direct payment, our relationship is with you, and we look to you to
secure payment.
Hourly Billing Rate per Party: A two-party mediation will be billed at the rate of $200.00 per
hour per party. For a three-party mediation, the rate will be reduced to $150.00 per hour per party.
DavTona BEACH * MAITLAND/ORLANDO ¢ OCALA * JACKSONVILLE ¢ FORT LAUDERDALE * WEST PALM BEACH ¢ MIAMI * BIRMINGHAMFor a four-party or five-party mediation, the rate will be $480.00 per hour, divided equally among
the parties.
Mediation Summaries: Ms. Bass will review any documents and materials you may regard as
relevant. We request that you provide this office with copies of such materials together with a
case summary at least ten (10) days prior to the mediation.
Cancellation: Cancellation of cases scheduled for four or more hours places an undue burden on
the mediator because we have reserved this time and date exclusively for your case. As a result,
we must receive written or e-mail notice of cancellation at least ten days before the mediation date
for cases scheduled for four or more hours. If the mediation is cancelled less than ten days before
the scheduled mediation conference date, you are subject to a cancellation charge equal to one-
half of your share of the per-party charge for the time reserved. All scheduled cases, even if
reserved for less than four hours, that are cancelled less than two days before the mediation may
be subject to a reasonable cancellation charge based upon the circumstances.
Please call me at 954-423-8856 should you have any questions, or you may contact Ms. Bass
directly at 954.647.9984.
We appreciate your bringing this matter to us and look forward to working with you toward a
mutually satisfactory resolution.
Cordially,
Heidi Cohen
dp lilen__
Mediation Case Manager
Upchurch Watson White & Max
heohen@uww-adr.com
DAYTONA BEACH ¢ MAITLAND/ORLANDO ¢ OCALA * JACKSONVILLE ¢ FoRT LAUDERDALE * WesTPALMBEACH * MIAMI ¢ BIRMINGHAM
Preview
Filing # 80161736 E-Filed 10/31/2018 05:00:36 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: 18-001290 KAREN ECHEVERRY, PLAINTIFF, ve MICHAEL R. HOWARD, DEFENDANT. Pee eee Evan R. Krakower, Esquire Lisa J. Baligian, Esquire Evan R. Krakower, P.A. Nicholas J. Ryan & Associates 10061 N.W. 1st Court 110 S.E. 6th Street, Suite 2100 Plantation, FL 33324 Ft. Lauderdale, FL 33301 Email: evanrkrakowerpa@yahoo.com; Email: florlaw- lisabaligian.294019@statefarm.com; marva.goulbourne.pemd@statefarm.com NOTICE OF MEDIATION YOU ARE HEREBY NOTIFIED, pursuant to the agreement of the parties and the provisions of Florida Statutes Chapter 44, that a Mediation Conference has been scheduled as follows: Mediator: Judith A. Bass Mediation Date: January 9, 2019 Mediation Time: 1:00 P.M. Mediation Location: Upchurch Watson White & Max, Royal Palm II at Southpointe, 900 S. Pine Island Road, Suite 410, Plantation, FL 33324 Time Reserved: 3.00 Hours ‘The terms and provisions of the confirmation letter accompanying this Notice of Mediation are hereby incorporated by reference into this Notice of Mediation. If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled to the provision of certain assistance at no cost to you. Please contact the ADA Coordinator in the Administrative office of Upchurch Watson White & Max, 125 S. Palmetto Avenue, Daytona Beach, FL 32114, Telephone 386-253-1560 or 800-264-2622, within two (2) working days of receipt of this Notice of Mediation. I HEREBY CERTIFY that a true and correct copy of the foregoing Notice of Mediation has been served by e-mail to the above named addressees on Wednesday, October 31, 2018, UPCHURCH WATSON WHITE & MAX Royal Palm at Southpointe 900 South Pine Island Road, Suite 410 Plantation, FL 33324 Phone: 954-423-8856 / Fax: 954-334-2838 Toll Free: 800-863-1462 Website: www.uww-adr.com Pons BY: Judith A. Bass, Esquire~ Shareholder FL Bar No. 262927 DAYTONA BEACH * MAITLAND/ORLANDO ¢ OCALA ¢ JACKSONVILLE ¢ FORT LAUDERDALE * WesT PALM BEACH * MIAMI ¢ BIRMINGHAM *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/31/2018 5:00:36 PM.****Royal Palm II at Southpointe 900 South Pine Island Road Suite 410 Plantation, FL 33324 : Telephone: 954-423-8856 Upchurch Watson White & Max Toll Free: 800-863-1462 MEDIATION GROUP Facsimile:954-334-2838 Website: www.uww-adr.com VIA E-MAIL October 31, 2018 RE: ECHEVERRY VS HOWARD Case #: 18-001290 FILE #: 19JAB-003 Dear Counsel: We greatly appreciate your confidence and trust in choosing Judy Bass as your mediator. To address your anticipated questions and avoid any possible misunderstandings, this letter confirms the terms and conditions of her engagement and the manner in which the mediation shall be conducted. Conduct of mediation: Unless otherwise agreed by the parties or ordered by the Court, this mediation shall be conducted according to all applicable Florida statutes and rules and specifically includes all protections of privilege, confidentiality, and immunity. Ms. Bass shall serve as an independent mediator and will not provide legal representation or legal advice to any mediation participant. Interpreter: Should your client or any mediation participant require an interpreter, please make the necessary arrangements in advance for an interpreter’s presence at the time of mediation. Mediation Fee: The mediation fee is calculated based upon Ms. Bass's billing rate, the time reserved, and any pre-mediation or post-mediation time she spends on this matter. There is a two hour minimum charge for all mediations held in Broward County and Boca Raton, and a three hour minimum charge for those held in Miami-Dade County and West Palm Beach. There is NO administrative charge and NO charge for travel time and expenses unless mutually agreed upon in writing. Allocation of Fees & Payment: Unless otherwise agreed, the mediation fees and costs shall be divided equally among the parties participating in the mediation. Payment is due upon your receipt of our bill. While our bill may be subject to reimbursement from your client to you, or even forwarded to your client for direct payment, our relationship is with you, and we look to you to secure payment. Hourly Billing Rate per Party: A two-party mediation will be billed at the rate of $200.00 per hour per party. For a three-party mediation, the rate will be reduced to $150.00 per hour per party. DavTona BEACH * MAITLAND/ORLANDO ¢ OCALA * JACKSONVILLE ¢ FORT LAUDERDALE * WEST PALM BEACH ¢ MIAMI * BIRMINGHAMFor a four-party or five-party mediation, the rate will be $480.00 per hour, divided equally among the parties. Mediation Summaries: Ms. Bass will review any documents and materials you may regard as relevant. We request that you provide this office with copies of such materials together with a case summary at least ten (10) days prior to the mediation. Cancellation: Cancellation of cases scheduled for four or more hours places an undue burden on the mediator because we have reserved this time and date exclusively for your case. As a result, we must receive written or e-mail notice of cancellation at least ten days before the mediation date for cases scheduled for four or more hours. If the mediation is cancelled less than ten days before the scheduled mediation conference date, you are subject to a cancellation charge equal to one- half of your share of the per-party charge for the time reserved. All scheduled cases, even if reserved for less than four hours, that are cancelled less than two days before the mediation may be subject to a reasonable cancellation charge based upon the circumstances. Please call me at 954-423-8856 should you have any questions, or you may contact Ms. Bass directly at 954.647.9984. We appreciate your bringing this matter to us and look forward to working with you toward a mutually satisfactory resolution. Cordially, Heidi Cohen dp lilen__ Mediation Case Manager Upchurch Watson White & Max heohen@uww-adr.com DAYTONA BEACH ¢ MAITLAND/ORLANDO ¢ OCALA * JACKSONVILLE ¢ FoRT LAUDERDALE * WesTPALMBEACH * MIAMI ¢ BIRMINGHAM