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  • Oshane Moodie, et al Plaintiff vs. Panfridays Events Llc, et al Defendant Contract and Indebtedness document preview
  • Oshane Moodie, et al Plaintiff vs. Panfridays Events Llc, et al Defendant Contract and Indebtedness document preview
  • Oshane Moodie, et al Plaintiff vs. Panfridays Events Llc, et al Defendant Contract and Indebtedness document preview
						
                                

Preview

Filing # 68384120 E-Filed 02/23/2018 12:50:49 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-2015-017977 WOLFPAKK, LLC, et al., Plaintiff(s), ve PANFRIDAYS, LLC, et al., Defendant(s). / Lee Friedland, Esquire Eneami Bestman, Esquire Friedland & Associates, P.A. The Bestman Law Firm, P.A. Email: lee@yourfightourbattle.com; Email: ebestman@bestmanlaw.com nicole@yourfightourbattle.com; pleadings@yourfightourbattle.com Peter D. Fellows, Esquire Law Firm of Fellows & Associates, P.A. Email: fellowslawfirm@yahoo.com RE-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: Charles N. Tetunic Mediation Date: March 2, 2018 Mediation Time: 10:00 a.m. Mediation Location: Upchurch Watson White & Max, Royal Palm II at Southpointe, 900 S. Pine Island Road, Suite 410, Plantation, FL, 33324. Time Reserved: 2,00 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. IT 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 Friday, February 23, 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 /2, Wh by TV gto: 7 LoL Vet Charles N. Tetunic, Esquire~ Shareholder FL Bar No. 336191 Daytona BEACH * MAITLAND/ORLANDO * OCALA * JACKSONVILLE * FORT LAUDERDALE ¢ West PALMBEACH * MIAMI* BIRMINGHAM *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/23/2018 12:50:49 PM.****Royal Palm II at Southpointe 900 South Pine Island Road \ | Suite 410 \ tA Plantation, FL 33324 Saree Telephone: 954-423-8856 7 Toll Free: 800-863-1462 Upchurch Watson White & Max Facsimile:954-334-2838 MEDIATION GROUP Website: www .uww-adr.com VIA E-MAIL February 23, 2018 RE: WOLFPAKK VS PANFRIDAY'S Case #: CACE-2015-017977 FILE #: 18CNT-172 Dear Counsel: We greatly appreciate your confidence and trust in choosing Charles (Chuck) Tetunic as your mediator. Mr. Tetunic is a shareholder with our firm. To address your anticipated questions and to avoid any possible misunderstandings, we are writing to confirm and clearly set forth the terms and conditions of Mr. Tetunic’s 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, the mediation shall be conducted according to all applicable mediation Florida Statutes and Rules. This specifically includes all protections of privilege, confidentiality and immunity. Mr. Tetunic shall serve as an independent mediator, providing neither legal representation nor legal advice to any participant in the mediation. Mediation Fee: The mediation fee is calculated at Mr. Tetunic’s billing rate, the time reserved and pre-mediation or post mediation time he spends in this matter. There is a two hour minimum charge for all mediations held in Broward County and a four hour minimum charge for mediations held in Palm Beach and Dade counties. There is NO administrative charge. For mediations held in Palm Beach and Dade counties, there may also be a one hour charge for travel time, depending upon the actual length of the mediation. 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, please understand that our relationship is with you and that we will ultimately look to you to secure payment. DAYTONA BEACH ¢ MAITLAND/ORLANDO ¢ OCALA ¢ JACKSONVILLE ¢ FORT LAUDERDALE * WEST PALM BEACH * MIAMI * BIRMINGHAMHourly Billing Rate: The mediation fee that is charged is an hourly amount based upon the number of parties. A two or three-party mediation shall be billed at the rate of $450 per hour. Mediations with four or more parties shall be billed at the rate of $500 per hour. Mediation Summaries: Mr. Tetunic 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: Cancellations of all-day cases place an undue burden upon the mediator. Therefore, we must receive at least a 10 day notice in order to avoid a 4-hour cancellation charge. All cases cancelled less than 3 business days prior to the mediation are also subject to a cancellation charge of 50% of the time reserved for the mediation. Please call me at the number above if you have any questions, or you may contact Mr. Tetunic directly at 954-232-0064. We appreciate your bringing this matter to us and look forward to reaching an amicable settlement. Cordially, Heidi Cohen 7 /,4, Mediation Case Manager Upchurch Watson White & Max heohen@uww-adr.com DayToNA BEACH * MAITLAND/ORLANDO * OCALA * JACKSONVILLE * FORT LAUDERDALE * WEST PALM BEACH * MIAMI * BIRMINGHAM