On February 21, 2012 a
Motion,Ex Parte
was filed
involving a dispute between
Kunjbehari, Joyce,
and
Lamfis Inc,
Roussin, Peter, Jr.,
for Auto Negligence
in the District Court of Broward County.
Preview
#4* FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 5/22/2013 3:23:24 PM.****
Electronically Filed 05/22/2013 03:23:24 PM ET
IN THE CIRCUIT COURT OF THE
17" JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
JOYCE KUNJBEHARI,
CASE NO.: CACE 12-004693 (21)
Plaintiff,
v.
PETER ROUSSIN, JR. and
LAMFIS INC.,
Defendants.
/
PLAINTIFF’S MOTION TO DETERMINE REASONABLENESS OF CHARGES FOR
DEFENSE EXPERT DEPOSITION
COMES NOW, Plaintiff, Joyce Kunjbehari, by and through her undersigned counsel,
hereby file this her Motion to Determine Reasonableness of Charges so that Defendants’ Expert,
Jordan Grabel, M.D., be compensated on an hourly basis for the time he expends at his
deposition and as grounds therefore states the following:
1 Plaintiff sustained a severe neck injury as a result of a motor vehicle accident
which gives rise to the instant lawsuit.
2. Defense has identified a medical expert and Plaintiff coordinated dates for the
taking of his deposition currently set for July 10, 2013 to learn of his opinions prior to trial.
3. Plaintiff's counsel received an invoice from Dr. Grabel requiring pre-payment one
week in advance of said deposition and a two hour minimum at $1,500 per hour for his
deposition. See, Dr. Grabel’s invoice attached hereto as Exhibit “A”.
4. Plaintiff's counsel will only need one (1) hour of Dr. Grabel’s time for the taking
of his deposition and it is Plaintiff's counsel practice to bring the check to the deposition to
compensate Dr. Grabel for the time of his deposition.
WHEREFORE, Plaintiff respectfully request this Court enter an order compelling Dr.
Grabel to be compensated on an hourly basis for the time he expends at said deposition and for
whatever relief this Court finds just and proper.CASE NO.: CACE 12-004693 (21)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing was e-mailed, this 22"! day of May,
2013, to Sheri Critelli-Fabiano, Esq., flor.law-shericritelli.298019@statefarm.com and faxed to
Jordan Grabel, M.D., 1411 N. Flagler Drive, Suite 5900, West Palm Beach, FL 33401
LAW OFFICES OF ALAN ANCHELL, P. A.
Attorney for Plaintiff
200 S. E. 18" Court
Fort Lauderdale, Florida 33316
Telephone: (954)472-3131
Facsimile: (954)653-0579
Anchell_ law@att.net
oakanch@bellsouth.net.
By:
ALAN@“ ANCHELL
Florida Bar No. 13500@5-22-°13 68:59 FROM-BRODNER & GRABEL 5618336353 7-041 P@AG2/082 F-118
Jordan C. Grabel, M.D., F.A.C.S.
NEUROLOGICAL SURGERY
{41 { NORTH FLAGLER DRIVE, SUITE 5900, WEST PALM BEACH, FLORIDA 33401
PHONE: (561) 833-6388 FAX: (561) 833-6353
DIPLOMATE, AMERICAN BOARD www.gammaknifecenter.com
OF NEUROLOGICAL SURGERY trigeminalneuralgia-florida.com
INVOICE
TO: Allen Anchell, ESQ
FAX: 954-653-0579
RE: Joyce Kurjbehari
Plaintiff Deposition on 07/10/13 @ 5:00pm
DATE: May 22, 2013
Depositions are to be paid 1 week in advance; $1,500 per hour with a two hour minimum
required payment due.
*Cancellation policy is 72 hrs notice or the entire prepayment fee is
forfeited.
*Tax ID: 65-0340540
TOTAL DUE: 8 3,000.00
PLEASE REMIT PAYMENT PROMPTLY
PLAINTIFF'S
} EXHIBIT
Document Filed Date
May 22, 2013
Case Filing Date
February 21, 2012
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
#4* FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 5/22/2013 3:23:24 PM.**** Electronically Filed 05/22/2013 03:23:24 PM ET IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JOYCE KUNJBEHARI, CASE NO.: CACE 12-004693 (21) Plaintiff, v. PETER ROUSSIN, JR. and LAMFIS INC., Defendants. / PLAINTIFF’S MOTION TO DETERMINE REASONABLENESS OF CHARGES FOR DEFENSE EXPERT DEPOSITION COMES NOW, Plaintiff, Joyce Kunjbehari, by and through her undersigned counsel, hereby file this her Motion to Determine Reasonableness of Charges so that Defendants’ Expert, Jordan Grabel, M.D., be compensated on an hourly basis for the time he expends at his deposition and as grounds therefore states the following: 1 Plaintiff sustained a severe neck injury as a result of a motor vehicle accident which gives rise to the instant lawsuit. 2. Defense has identified a medical expert and Plaintiff coordinated dates for the taking of his deposition currently set for July 10, 2013 to learn of his opinions prior to trial. 3. Plaintiff's counsel received an invoice from Dr. Grabel requiring pre-payment one week in advance of said deposition and a two hour minimum at $1,500 per hour for his deposition. See, Dr. Grabel’s invoice attached hereto as Exhibit “A”. 4. Plaintiff's counsel will only need one (1) hour of Dr. Grabel’s time for the taking of his deposition and it is Plaintiff's counsel practice to bring the check to the deposition to compensate Dr. Grabel for the time of his deposition. WHEREFORE, Plaintiff respectfully request this Court enter an order compelling Dr. Grabel to be compensated on an hourly basis for the time he expends at said deposition and for whatever relief this Court finds just and proper.CASE NO.: CACE 12-004693 (21) CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing was e-mailed, this 22"! day of May, 2013, to Sheri Critelli-Fabiano, Esq., flor.law-shericritelli.298019@statefarm.com and faxed to Jordan Grabel, M.D., 1411 N. Flagler Drive, Suite 5900, West Palm Beach, FL 33401 LAW OFFICES OF ALAN ANCHELL, P. A. Attorney for Plaintiff 200 S. E. 18" Court Fort Lauderdale, Florida 33316 Telephone: (954)472-3131 Facsimile: (954)653-0579 Anchell_ law@att.net oakanch@bellsouth.net. By: ALAN@“ ANCHELL Florida Bar No. 13500@5-22-°13 68:59 FROM-BRODNER & GRABEL 5618336353 7-041 P@AG2/082 F-118 Jordan C. Grabel, M.D., F.A.C.S. NEUROLOGICAL SURGERY {41 { NORTH FLAGLER DRIVE, SUITE 5900, WEST PALM BEACH, FLORIDA 33401 PHONE: (561) 833-6388 FAX: (561) 833-6353 DIPLOMATE, AMERICAN BOARD www.gammaknifecenter.com OF NEUROLOGICAL SURGERY trigeminalneuralgia-florida.com INVOICE TO: Allen Anchell, ESQ FAX: 954-653-0579 RE: Joyce Kurjbehari Plaintiff Deposition on 07/10/13 @ 5:00pm DATE: May 22, 2013 Depositions are to be paid 1 week in advance; $1,500 per hour with a two hour minimum required payment due. *Cancellation policy is 72 hrs notice or the entire prepayment fee is forfeited. *Tax ID: 65-0340540 TOTAL DUE: 8 3,000.00 PLEASE REMIT PAYMENT PROMPTLY PLAINTIFF'S } EXHIBIT