Preview
Filing # 124876692 E-Filed 04/14/2021 09:11:16 AM
IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA -
CIVIL DIVISION
RIDGE TOP EXTERIORS, LLC, Case No.: 2020-006863-SC
a Florida limited liability company, Division:
Plaintiff
V
MATT S. TURPIN, and
ELISABETH PARKER,
Defendants. i
PLAINTIFF'S NOTICE OF FILING
PLEASE TAKE NOTICE that Plaintiff RIDGE TOP EXTERIORS, LLC by and through the
undersigned counsel, hereby files with the Court the following documents:
,, ,,
1. Supporting Fee Orders Part 2, bates stamped as Composite Exhibit A.334 -
340.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by e-
designation on this 14th day of April 2021 to: and Counsel for
DefendantsRhodus Law Firm, PLLC, Kristin Rhodus, Esq., 447 3rd Ave N., Ste. 406, St. Petersburg, FL
33701 @ kristin@rhoduslawfiirrm.com.
Cox Law, PLLC
By: /s/ SG.Pl-
Sean P. Cox, Esq.
Florida Bar Number 706760
156 E. Bloomindale Ave.
Brandon, FL 33511-8179
Tel: 813-685-8600
Fax: 813-685-8699
SPC/vag sean @coxlawplc.com
Cc: Client vanessa @coxlawplc.com
Attorney for Plaintiff RIDGE TOP EXTERIORS
***ELECTRONICALLYFILED 04/14/2021 09:11:15 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
Filing # 118788581 E-Filed 12/28/2020 04:58:34 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT, IN AND
FOR ORANGE COUNTY, FLORIDA
2020-CA-004096-O
DONTAE THOMPSON
Plaintiff(s),
VS.
THOMAS A VAN DIJK
ALEJANDRO P VAN DIJK
KAREN E VAN DIJK
Defendant(s).
i
FINAL JUDGMENT AWARDING ATTORNEYS' FEES AND COSTS
This Court held an evidentiary hearing on December 21, 2020, before the Honorable
Kevin B. Weiss, to determine the amount due to the Defendant for costs and the amount due to
the Plaintiff for attorney's fees. The Court, having reviewed the Court file, taken testimony,
heard argument of counsel, weighed the weight and credibility of each of the witnesses, having
used its own knowledge and being otherwise fully advised in the premises, finds the following:
FINDINGS OF FACTS
1. On September 14,2020, Defendant Karen E. Van Dijk filed "Defendant Karen E.
Van Dijk's Motion for Costs and Attorney's Fees." The Defendant claimed that she was entitled
to costs and attorney's fees as a result of the Plaintiff's dismissal of one of the Defendants from
the lawsuit.
2. On October 8,2020, the Court held a
hearing on the Defendant's Motion.
3. On October 12,2020, the Court issued an Order
granting the Defendant's request for
taxable costs pursuant to Fla. R. Civ. P. 1.420(d).
Page 1 of 7
2020-CA-004096-O
,, "
Composite Exhibit A.334
4. The Court reserved as to the amount of taxable costs incurred by the Defendant.
5. The Court denied the Defendant srequest for attorney's fees, finding that the
Defendant pled no substantive basis to support its demand for
attorney's fees.
6. In addition, the Court found that the Defendant's claim for attorney's fees was
without basis in fact or law. Consequently, on its own motion, the Court granted entitlement, to
the Plaintiff, for the attorney's fees incurred for having to defend what this Court found to be a
frivolous claim. The Court found that at the time the Defendant
presented her claim to the Court,
the Defendant knew or should have known that her claim for
attorney's fees against the Plaintiff
was not supported by the application of law to the existing facts.
7. The Court reserved as to the amount of attorney's fees to be awarded.
8. The Defendant filed a Motion for which this Court denied
in an Order dated December 2,2020.
9. On December 4,2020, the Court noticed an
evidentiaryhearing on the amount of
costs due to the Defendant and the amount of attorney's fees due to the Plaintiff.
ENTITLEMENT TO AND PAYMENT OF FEES AND COSTS
10. At the evidentiary hearing the Defendant withdrew her claim for that
costs this
Court previously awarded in the October 12,2020 Order. Accordingly, the only remaining issues
before the Court was the amount of fees due
attorney's to the Plaintiff and whether the
Defendant was personally responsible to
pay those fees.
11. This Court previously found entitlement to attorney s fees pursuant to Fla. Stat.
Section 57.105.1 At the hearing, the parties did not the Court with
present any evidence or
1
See this Court's prior Orders dated October
12,2020 and December 2,2020.
Page 2 of 7
2020-CA-004096-O
,,
Composite Exhibit "A.335
argument regarding this Court's finding of entitlement, including whether the attorney's fees
awarded to the Plaintiff should be paid by the Defendant or her attorneys.
12. When a trial court imposes liability against counsel for a fee award entered under
section 57.105, it "must make t11 an express finding that the claim was frivolous and,... l21 an
express finding that the attorney was not acting in good faith based upon the representations of
his client." Perlmanv. Ameriquest Mortgage Co., 987 So. 2d 1292, 1292 (Fla. 4th DCA 2008)
(emphasis supplied) (citing Valdes v. Lovaas, 784 So. 2d 474 (Fla. 3d DCA 2001); Weatherby
Assocs. Inc. v. Ballack, 783 So. ld 1138, 1143 (Fla. 4th DCA 2001)). This Court previously
expressly found that the Defendant's claim was frivolous and not filed in good faith.
13. The Court finds that the fee award shall be taxed solely against the attorneys
representing the Defendant. See #37.105(3)(c) (providing that an attorney's fee award imposed
under 57.105(1)(b) not be awarded against party who is represented
may a
by counsel).
Accordingly, this fee award shall be paid by the attorneys for the Defendant.
REASONABLE HOURS EXPENDED
14. At the hearing, Defendant stipulated that the hours
following were
reasonably
expended by Plaintiffs counsel and the Court finds that the following hours were
reasonably
expended by Plaintiff's counsel in the prosecution ofthis case:
a. Todd E. Copeland, Esq. 4.1 hours
b. Keith J. Robertson, Esq. 7.3 hours
Total: 11.4 hours
15. The Court reached its determination based upon its review and the
own
stipulation
ofthe parties.
Page 3 of 7
2020-CA-004096-O
Composite Exhibit "A.336 ,,
HOURLY RATES AND LODESTAR
16. The Plaintiffs attorney's fees expert was Glenn Klausman, Esq. The Court is
familiar with Mr. Klausman and his experience, knowledge and reputation in the relevant market
and accepts Mr. Klausman as a well-qualified expert in the areas testified upon. The Defendant
stipulated to Mr. Klausman's qualifications to testify as an expert, to testify in a narrative and
further did not challenge his hourly rate.2 Mr. Klausman has practiced law in the Central Florida
community since 1976 and has extensive experience representing plaintiffs in legal matters
involving the litigation of automobile accidents. Mr. Klausman has litigated thousands of cases
in Orange County, Florida, and has significant leadership experience in the area of personal
injury litigation, including serving as the President of the Central Florida Trial Lawyers
Association.
17. Mr. Klausman has served as an expert witness in numerous attorney's fee
hearings in Orange County and has reviewed many fee orders. Mr. Klausman is very familiar
with the hourly rates charged in the relevant market and has firsthand knowledge about those
rates. The Court finds that Mr. Klausman is sufficiently familiar with Mr. and
Copeland Mr.
Robertson and their reputations in handling automobile accidents in the relevant community.
18. The Defendant presented expert testimony from Sean Cox, from
an attorney
Brandon, Florida, licensed to practice law since 2004. Mr. Cox testified that he has experience in
motor vehicle litigation, experience as insurance and
an
adjuster experience as an insurance
defense attorney. Mr. Cox also reviewed many fee orders from the Central Florida area. The
Court found Mr. Cox's testimony to be persuasive as to Mr. Robertson's hourly rate.
2
The parties also stipulated that the witnesses were not required to be placed under oath.
The Court accepted this stipulation given the circumstances of the telephonic hearing and the fact
that the witnesses licensed members o f the Florida Bar, and
are as such, are o fficers o f thecourt.
Page 4 of 7
2020-CA-004096-O
Composite Exhibit "A.337 ,,
19. Mr. Klausman has more experience than Mr. Cox in Orange County and was able
to provide specific examples of hourly rates awarded to personal injury attorneys in the
community. He also has been involved in the local legal community since 1976. Accordingly,
the Court accepts Mr. Klausman s recommendation
regarding Mr. Copeland's hourly rate.
20. At the fee hearing, Mr. Copeland sought $750.00 hour for his time. Mr.
per
Robertson sought $350.00 per hour for his time. The Court is familiar with both
attorneys. As to
Mr. Copeland, the Court recognizes Mr. Copeland of the
as one most experienced and well-
respected attorneys in Orlando and perhaps the State of Florida in the areas of insurance and
personal injury litigation. Mr. Copeland has been licensed to practice law in Florida since 1992,
is Past President of the Central Florida Trial
a
Lawyers Association and a Past President of the
statewide Florida Justice Association. Mr. Copeland has tried numerous personal injury cases,
has handled thousands of hearings and has
previously provided expert witness testimony in both
Division 33 and the other Civil Divisions within Orange County.
21. Based the entirety of the and
on
testimony evidence at the hearing, and based
upon this Court's personal experience, the Court awards Plaintiff's
attorneys the hourly rates set
forth below.
22. The Court has considered the factors set forth in Florida Rule of Professional
Conduct 4-1.5 and Florida Patient's Compensation Fund v. Rowe, 411 So.2d 1145 (Fla. 1985).
Considering those factors, and based upon the Court's own experience, the Court finds that the
following hourly rates are reasonablefor Plaintiffs counsel in this case:
Attorney Rate Hours Lodestar
a. Todd E. Copeland, Esq. $750.00/hour 4.1 $3,075.00
b. Keith J. Robertson, Esq. $325.00/hour 7.3 $2,372.50
Page 5 of 7
2020-CA-004096-O
,,
Composite Exhibit "A.338
Total: $5,447.50
EXPERT WITNESS FEES
23. Plaintiff's expert witness, Glenn Klausman, Esq., is entitled be
to compensated
for the time he expended in preparing to testify and testifying in this case. Travieso v. Travieso,
474 So.2d 1184 (Fla. 1985); Stokus v. Phillps, 651 SO.2d 1244 (Fla. 2d DCA 1995); and Mangel
v. Bob Dance Dodge, Inc., 739 50.2d 720 (Fla. 5th DCA 1999).
24. Mr. Klausman reviewed the file, conducted research and testified that he expected
to be compensated for his time, that he reasonably expended 3.7 hours in this case. The Court
finds that a reasonable hourly rate for Mr. Klausman's helpful testimony is $750.00 per hour.3 A
reasonable attorney's fee for Mr. Klausman's expert witness time is $2,775.00.
PREJUDGMENT INTEREST
25. The attorneys for the Plaintiffs entitled interest the
are to on
attorney fees and
from the date of entitlement until the of this
entry judgment pursuant to Quality Engineering
Inc. Higley South, 670 So.2d 929 (Fla. This
v.
1996). Court found entitlement to attorney's fees
in the October 12,2020 Order. The total number of
days interest is owed is 77 days.
WHEREFORE, it is hereby ORDERED AND ADJUDGED:
The Plaintiff shall have and recover from the Defendant's attorneys, the following:
a. Reasonable attorney's fees in the amount of $5,447.50 +
prejudgment interest in
the amount of $54.58 (based on 77 days @ 4.75%) for a total of $5,502.08, for
which let execution issue after twenty (20) days.
3
The Defendant did not challenge Mr. Klausman's
hourly rate.
Page 6 of 7
2020-CA-004096-O
,,
Composite Exhibit "A.339
b. Glenn Klausman, Esquire, does have and recovers from the Defendant's
attorneys expert witness fees in the amount of $2,775.00, for which let
execution issue after twenty (20) days.
Post-judgment interest shall run on these amounts pursuant to Florida Statute Section
55.03, Fla. Stat.
DONE AND ORDERED in Chambers in ORANGE County, Florida this 68'V.or
67.m,1r ,2020.
/
-/.-
Hon. Kevin B. Weiss
Circuit Judge
CERTIFICATEOF SERVICE
I HEREBY CERTIFY that the foregoing was filed with the Clerk of the Court this =28%?··-?
day of 'bpc em Gr, 2020 by using the Florida Courts E-Filing Portal System.
Accordingly, a copy of the foregoing is being served on this day to all
parties identified on the ePortal Electronic Service List, via transmission of Notices of Electronic
Filing generated by the ePortal System.
Page 7 of 7
2020-CA-004096-O
,,
Composite Exhibit "A.340
Preview
Filing # 124876692 E-Filed 04/14/2021 09:11:16 AM IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA - CIVIL DIVISION RIDGE TOP EXTERIORS, LLC, Case No.: 2020-006863-SC a Florida limited liability company, Division: Plaintiff V MATT S. TURPIN, and ELISABETH PARKER, Defendants. i PLAINTIFF'S NOTICE OF FILING PLEASE TAKE NOTICE that Plaintiff RIDGE TOP EXTERIORS, LLC by and through the undersigned counsel, hereby files with the Court the following documents: ,, ,, 1. Supporting Fee Orders Part 2, bates stamped as Composite Exhibit A.334 - 340. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by e- designation on this 14th day of April 2021 to: and Counsel for DefendantsRhodus Law Firm, PLLC, Kristin Rhodus, Esq., 447 3rd Ave N., Ste. 406, St. Petersburg, FL 33701 @ kristin@rhoduslawfiirrm.com. Cox Law, PLLC By: /s/ SG.Pl- Sean P. Cox, Esq. Florida Bar Number 706760 156 E. Bloomindale Ave. Brandon, FL 33511-8179 Tel: 813-685-8600 Fax: 813-685-8699 SPC/vag sean @coxlawplc.com Cc: Client vanessa @coxlawplc.com Attorney for Plaintiff RIDGE TOP EXTERIORS ***ELECTRONICALLYFILED 04/14/2021 09:11:15 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** Filing # 118788581 E-Filed 12/28/2020 04:58:34 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA 2020-CA-004096-O DONTAE THOMPSON Plaintiff(s), VS. THOMAS A VAN DIJK ALEJANDRO P VAN DIJK KAREN E VAN DIJK Defendant(s). i FINAL JUDGMENT AWARDING ATTORNEYS' FEES AND COSTS This Court held an evidentiary hearing on December 21, 2020, before the Honorable Kevin B. Weiss, to determine the amount due to the Defendant for costs and the amount due to the Plaintiff for attorney's fees. The Court, having reviewed the Court file, taken testimony, heard argument of counsel, weighed the weight and credibility of each of the witnesses, having used its own knowledge and being otherwise fully advised in the premises, finds the following: FINDINGS OF FACTS 1. On September 14,2020, Defendant Karen E. Van Dijk filed "Defendant Karen E. Van Dijk's Motion for Costs and Attorney's Fees." The Defendant claimed that she was entitled to costs and attorney's fees as a result of the Plaintiff's dismissal of one of the Defendants from the lawsuit. 2. On October 8,2020, the Court held a hearing on the Defendant's Motion. 3. On October 12,2020, the Court issued an Order granting the Defendant's request for taxable costs pursuant to Fla. R. Civ. P. 1.420(d). Page 1 of 7 2020-CA-004096-O ,, " Composite Exhibit A.334 4. The Court reserved as to the amount of taxable costs incurred by the Defendant. 5. The Court denied the Defendant srequest for attorney's fees, finding that the Defendant pled no substantive basis to support its demand for attorney's fees. 6. In addition, the Court found that the Defendant's claim for attorney's fees was without basis in fact or law. Consequently, on its own motion, the Court granted entitlement, to the Plaintiff, for the attorney's fees incurred for having to defend what this Court found to be a frivolous claim. The Court found that at the time the Defendant presented her claim to the Court, the Defendant knew or should have known that her claim for attorney's fees against the Plaintiff was not supported by the application of law to the existing facts. 7. The Court reserved as to the amount of attorney's fees to be awarded. 8. The Defendant filed a Motion for which this Court denied in an Order dated December 2,2020. 9. On December 4,2020, the Court noticed an evidentiaryhearing on the amount of costs due to the Defendant and the amount of attorney's fees due to the Plaintiff. ENTITLEMENT TO AND PAYMENT OF FEES AND COSTS 10. At the evidentiary hearing the Defendant withdrew her claim for that costs this Court previously awarded in the October 12,2020 Order. Accordingly, the only remaining issues before the Court was the amount of fees due attorney's to the Plaintiff and whether the Defendant was personally responsible to pay those fees. 11. This Court previously found entitlement to attorney s fees pursuant to Fla. Stat. Section 57.105.1 At the hearing, the parties did not the Court with present any evidence or 1 See this Court's prior Orders dated October 12,2020 and December 2,2020. Page 2 of 7 2020-CA-004096-O ,, Composite Exhibit "A.335 argument regarding this Court's finding of entitlement, including whether the attorney's fees awarded to the Plaintiff should be paid by the Defendant or her attorneys. 12. When a trial court imposes liability against counsel for a fee award entered under section 57.105, it "must make t11 an express finding that the claim was frivolous and,... l21 an express finding that the attorney was not acting in good faith based upon the representations of his client." Perlmanv. Ameriquest Mortgage Co., 987 So. 2d 1292, 1292 (Fla. 4th DCA 2008) (emphasis supplied) (citing Valdes v. Lovaas, 784 So. 2d 474 (Fla. 3d DCA 2001); Weatherby Assocs. Inc. v. Ballack, 783 So. ld 1138, 1143 (Fla. 4th DCA 2001)). This Court previously expressly found that the Defendant's claim was frivolous and not filed in good faith. 13. The Court finds that the fee award shall be taxed solely against the attorneys representing the Defendant. See #37.105(3)(c) (providing that an attorney's fee award imposed under 57.105(1)(b) not be awarded against party who is represented may a by counsel). Accordingly, this fee award shall be paid by the attorneys for the Defendant. REASONABLE HOURS EXPENDED 14. At the hearing, Defendant stipulated that the hours following were reasonably expended by Plaintiffs counsel and the Court finds that the following hours were reasonably expended by Plaintiff's counsel in the prosecution ofthis case: a. Todd E. Copeland, Esq. 4.1 hours b. Keith J. Robertson, Esq. 7.3 hours Total: 11.4 hours 15. The Court reached its determination based upon its review and the own stipulation ofthe parties. Page 3 of 7 2020-CA-004096-O Composite Exhibit "A.336 ,, HOURLY RATES AND LODESTAR 16. The Plaintiffs attorney's fees expert was Glenn Klausman, Esq. The Court is familiar with Mr. Klausman and his experience, knowledge and reputation in the relevant market and accepts Mr. Klausman as a well-qualified expert in the areas testified upon. The Defendant stipulated to Mr. Klausman's qualifications to testify as an expert, to testify in a narrative and further did not challenge his hourly rate.2 Mr. Klausman has practiced law in the Central Florida community since 1976 and has extensive experience representing plaintiffs in legal matters involving the litigation of automobile accidents. Mr. Klausman has litigated thousands of cases in Orange County, Florida, and has significant leadership experience in the area of personal injury litigation, including serving as the President of the Central Florida Trial Lawyers Association. 17. Mr. Klausman has served as an expert witness in numerous attorney's fee hearings in Orange County and has reviewed many fee orders. Mr. Klausman is very familiar with the hourly rates charged in the relevant market and has firsthand knowledge about those rates. The Court finds that Mr. Klausman is sufficiently familiar with Mr. and Copeland Mr. Robertson and their reputations in handling automobile accidents in the relevant community. 18. The Defendant presented expert testimony from Sean Cox, from an attorney Brandon, Florida, licensed to practice law since 2004. Mr. Cox testified that he has experience in motor vehicle litigation, experience as insurance and an adjuster experience as an insurance defense attorney. Mr. Cox also reviewed many fee orders from the Central Florida area. The Court found Mr. Cox's testimony to be persuasive as to Mr. Robertson's hourly rate. 2 The parties also stipulated that the witnesses were not required to be placed under oath. The Court accepted this stipulation given the circumstances of the telephonic hearing and the fact that the witnesses licensed members o f the Florida Bar, and are as such, are o fficers o f thecourt. Page 4 of 7 2020-CA-004096-O Composite Exhibit "A.337 ,, 19. Mr. Klausman has more experience than Mr. Cox in Orange County and was able to provide specific examples of hourly rates awarded to personal injury attorneys in the community. He also has been involved in the local legal community since 1976. Accordingly, the Court accepts Mr. Klausman s recommendation regarding Mr. Copeland's hourly rate. 20. At the fee hearing, Mr. Copeland sought $750.00 hour for his time. Mr. per Robertson sought $350.00 per hour for his time. The Court is familiar with both attorneys. As to Mr. Copeland, the Court recognizes Mr. Copeland of the as one most experienced and well- respected attorneys in Orlando and perhaps the State of Florida in the areas of insurance and personal injury litigation. Mr. Copeland has been licensed to practice law in Florida since 1992, is Past President of the Central Florida Trial a Lawyers Association and a Past President of the statewide Florida Justice Association. Mr. Copeland has tried numerous personal injury cases, has handled thousands of hearings and has previously provided expert witness testimony in both Division 33 and the other Civil Divisions within Orange County. 21. Based the entirety of the and on testimony evidence at the hearing, and based upon this Court's personal experience, the Court awards Plaintiff's attorneys the hourly rates set forth below. 22. The Court has considered the factors set forth in Florida Rule of Professional Conduct 4-1.5 and Florida Patient's Compensation Fund v. Rowe, 411 So.2d 1145 (Fla. 1985). Considering those factors, and based upon the Court's own experience, the Court finds that the following hourly rates are reasonablefor Plaintiffs counsel in this case: Attorney Rate Hours Lodestar a. Todd E. Copeland, Esq. $750.00/hour 4.1 $3,075.00 b. Keith J. Robertson, Esq. $325.00/hour 7.3 $2,372.50 Page 5 of 7 2020-CA-004096-O ,, Composite Exhibit "A.338 Total: $5,447.50 EXPERT WITNESS FEES 23. Plaintiff's expert witness, Glenn Klausman, Esq., is entitled be to compensated for the time he expended in preparing to testify and testifying in this case. Travieso v. Travieso, 474 So.2d 1184 (Fla. 1985); Stokus v. Phillps, 651 SO.2d 1244 (Fla. 2d DCA 1995); and Mangel v. Bob Dance Dodge, Inc., 739 50.2d 720 (Fla. 5th DCA 1999). 24. Mr. Klausman reviewed the file, conducted research and testified that he expected to be compensated for his time, that he reasonably expended 3.7 hours in this case. The Court finds that a reasonable hourly rate for Mr. Klausman's helpful testimony is $750.00 per hour.3 A reasonable attorney's fee for Mr. Klausman's expert witness time is $2,775.00. PREJUDGMENT INTEREST 25. The attorneys for the Plaintiffs entitled interest the are to on attorney fees and from the date of entitlement until the of this entry judgment pursuant to Quality Engineering Inc. Higley South, 670 So.2d 929 (Fla. This v. 1996). Court found entitlement to attorney's fees in the October 12,2020 Order. The total number of days interest is owed is 77 days. WHEREFORE, it is hereby ORDERED AND ADJUDGED: The Plaintiff shall have and recover from the Defendant's attorneys, the following: a. Reasonable attorney's fees in the amount of $5,447.50 + prejudgment interest in the amount of $54.58 (based on 77 days @ 4.75%) for a total of $5,502.08, for which let execution issue after twenty (20) days. 3 The Defendant did not challenge Mr. Klausman's hourly rate. Page 6 of 7 2020-CA-004096-O ,, Composite Exhibit "A.339 b. Glenn Klausman, Esquire, does have and recovers from the Defendant's attorneys expert witness fees in the amount of $2,775.00, for which let execution issue after twenty (20) days. Post-judgment interest shall run on these amounts pursuant to Florida Statute Section 55.03, Fla. Stat. DONE AND ORDERED in Chambers in ORANGE County, Florida this 68'V.or 67.m,1r ,2020. / -/.- Hon. Kevin B. Weiss Circuit Judge CERTIFICATEOF SERVICE I HEREBY CERTIFY that the foregoing was filed with the Clerk of the Court this =28%?··-? day of 'bpc em Gr, 2020 by using the Florida Courts E-Filing Portal System. Accordingly, a copy of the foregoing is being served on this day to all parties identified on the ePortal Electronic Service List, via transmission of Notices of Electronic Filing generated by the ePortal System. Page 7 of 7 2020-CA-004096-O ,, Composite Exhibit "A.340