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Filing # 78462943 E-Filed 09/26/2018 02:28:02 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.:CACE 2018-001322 (12)
KARMEL RUNCIE,
Plaintiff,
v.
INTERNATIONAL VILLAGE
ASSOCIATION, INC. and DOREEN
SYRLIK
Defendants.
/
DEFENDANTS’ NOTICE OF FILING AFFIDAVITS
COME NOW, Defendants, INTERNATIONAL VILLAGE ASSOCIATION, INC.
and DOREEN SYRLIK, by and through their undersigned counsel, and file the following
Affidavits in support of Plaintiffs Cross Motion to Disqualify Defense Counsel as follows:
1. Affidavit of John Labriola
2. Affidavit of Doreen Syrlik
COLE, SCOTT & KISSANE, P.A.
COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (305) 373-2294 FAX
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 9/26/2018 2:28:02 PM.****Case No.: CACE 2018-001322 (12)
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that on this 26th day of September, 2018, a true and correct
copy of the foregoing was filed with the Clerk of Broward County by using the Florida
Courts e-Filing Portal, which will send an automatic e-mail message to the following
parties registered with the e-Filing Portal system: chelsalewispa.@gmail.com;
lewislawpleadings@gmail.com; Chelsea Lewis, Esquire, Lewis Law LLC,,151 N. Nob Hill
Road, Suite 348, Plantation, FL 33324, Attorneys for Plaintiff.
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendants,
International Village Association, Inc. and
Doreen Syrlik
Cole, Scott & Kissane Building
9150 South Dadeland Boulevard, Suite 1400
P.O. Box 569015
Miami, Florida 33256
Telephone (786) 268-6749
Facsimile (305) 373-2294
Primary e-mail: daniel.klein@csklegal.com
Secondary e-mail: tania.cabrera@csklegal.com
Primary e-mail: Samuel. Falk@csklegal.com
Secondary e-mail: Linda.Vitti@csklegal.com
py: s/Sanud J. Falk
DANIEL J. KLEIN
Florida Bar No.: 16126
SAMUEL J. FALK
Florida Bar No.: 123539
-2-
COLE, SCOTT & KISSANE, P.A.
COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (305) 373-2294 FAXIN THE CIRCUIT COURT OF THE 17TH
JUDICIAL, CIRCUIT IN. AND FOR
BROWARD COUNTY, FLORIDA
CASE NO: CACE 2018-001322 (12)
KARMEL RUNCIE,
Plaintiff,
Vv.
INTERNATIONAL VILLAGE
ASSOCIATION, ING, and DOREEN. -
SYRLIK
Defendants.
/
AFFIDAVIT OF JOHN LABRIOLA
BEFORE ME, the undersigned authority, personally appeared JOHN LABRIOLA,
after being duly sworn upon oath, who deposes and says:
1. My name is JOHN LABRIOLA and | am over eighteen (18) years old and
competent to make this affidavit.
2, lam currently a resident of Loudgrh | Flex ie
3. lam currently the President for the International Village Association,-Inc.
4, | have executed this affidavit in response to Plaintiff's Cross-Motion to
Disqualify Defense Counsel.
5. On July 23, 2018, Plaintiff filed a Response in Opposition to Defendants’
Motion to Disqualify Plaintiffs Attorney and Cross-Motion to Disqualify Defense
Counsel.
6. In Plaintiffs Cross-Motion to Disqualify Défense Counsel, Plaintiff alleges
that “Defense Counsel should be disqualified because of the incompatibility in positionsin relation to IVA and Syrlik, and/or the fact that there are substantially different
possibilities of settlement of ‘the claims or liabilities in question, given Syrlik’s
admissions,”
ifs Notwithstanding. Plaintiff's allegations that there could be “incompatibility in
positions in relation to IVA and Syrlik,” the undersigned consents to Cole, Scott &
Kissane, P.A. representing Doreen Syrlik and the. International Village Association, Inc.
in the subject lawsuit,
8, There are-no legal conflicts of ‘interest in. Cole, Scott & Kissane, P.A’s
representation of Doreen Syrlik and the International Village Association, Inc.
FURTHER AFFIANT SAYETH NAUGHT.
STATE OF __Floerha
COUNTY OF Misti - DADE
SWORN TO AND SUBSCRIBED before me
on
Th Sa of September, 2018.
as Ze say oS eRromeh MY COMMISSION # GG 220648
__ EXPIRES: Adgust 22, 2022
Bonded They HOaly Public Underwiters
NOTARY PUBLIC; State of Flogba +
AT LARGE
MY COMMISSION EXPIRES:IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO: CACE 2018-001322 (12)
KARMEL RUNCIE,
Plaintiff,
v.
INTERNATIONAL VILLAGE
ASSOCIATION, INC, and DOREEN
SYRLIK
Defendants.
/
AFFIDAVIT OF DOREEN SYRLIK
BEFORE ME, the undersigned authority, personally appeared DOREEN
SYRLIK, after being duly sworn upon oath, who deposes and says:
1. My name is DOREEN SYRLIK and | am over eighteen (18) years old and
competent to make this affidavit.
Bes
2. | am currently a resident of Pemegurs , wh, state. F} 7
3. | am currently the Assistant Property Manager for International Village
Association, Inc.
4. | have executed this affidavit in response to Plaintiff's Cross-Motion to
Disqualify Defense Counsel.
5. On July 23, 2018, Plaintiff filed a Response in Opposition to Defendants’
Motion to Disqualify Plaintiffs Attorney and Cross-Motion to Disqualify Defense
Counsel.
6. In Plaintiff's Cross-Motion to Disqualify Defense Counsel, Plaintiff allegesthat "Defense Counsel should be disqualified because of the incompatibility in positions
in relation to (VA and Syrlik, and/or the fact that there are substantially different
possibilities of settlement of the claims or liabilities in question, given Syrlik’s
admissions.”
7. Notwithstanding Plaintiff's allegations that there could be “incompatibility in
positions in relation to IVA and Syrlik,” the undersigned consents to Cole, Scott &
Kissane, P.A. representing myself and the International Village Association, Inc. in the
subject lawsuit,
8. There are no legal conflicts of interest in Cole, Scott & Kissane, P.A.’s
representation of myself and the International Village Association, Inc.
FURTHER AFFIANT SAYETH NAUGHT.
Dr. Ly ld rhs HE
Doreen Syrlik Date
STATE OF ov
COUNTY OF
SWORN TO AND SUBSCRIBED before me
This 22 day of September, 2018.
NOTARY PUBLIC; State of Elovida
AT LARGE
MY COMMISSION EXPIRES: : ; Qujene 0
Pa, GIOVANNI REGINELLO
‘Commission # OG 156177
Expires October 90, 2024
SS Bens Ths Badge Notary Serene
Preview
Filing # 78462943 E-Filed 09/26/2018 02:28:02 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.:CACE 2018-001322 (12) KARMEL RUNCIE, Plaintiff, v. INTERNATIONAL VILLAGE ASSOCIATION, INC. and DOREEN SYRLIK Defendants. / DEFENDANTS’ NOTICE OF FILING AFFIDAVITS COME NOW, Defendants, INTERNATIONAL VILLAGE ASSOCIATION, INC. and DOREEN SYRLIK, by and through their undersigned counsel, and file the following Affidavits in support of Plaintiffs Cross Motion to Disqualify Defense Counsel as follows: 1. Affidavit of John Labriola 2. Affidavit of Doreen Syrlik COLE, SCOTT & KISSANE, P.A. COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (305) 373-2294 FAX *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 9/26/2018 2:28:02 PM.****Case No.: CACE 2018-001322 (12) CERTIFICATE OF SERVICE | HEREBY CERTIFY that on this 26th day of September, 2018, a true and correct copy of the foregoing was filed with the Clerk of Broward County by using the Florida Courts e-Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: chelsalewispa.@gmail.com; lewislawpleadings@gmail.com; Chelsea Lewis, Esquire, Lewis Law LLC,,151 N. Nob Hill Road, Suite 348, Plantation, FL 33324, Attorneys for Plaintiff. COLE, SCOTT & KISSANE, P.A. Counsel for Defendants, International Village Association, Inc. and Doreen Syrlik Cole, Scott & Kissane Building 9150 South Dadeland Boulevard, Suite 1400 P.O. Box 569015 Miami, Florida 33256 Telephone (786) 268-6749 Facsimile (305) 373-2294 Primary e-mail: daniel.klein@csklegal.com Secondary e-mail: tania.cabrera@csklegal.com Primary e-mail: Samuel. Falk@csklegal.com Secondary e-mail: Linda.Vitti@csklegal.com py: s/Sanud J. Falk DANIEL J. KLEIN Florida Bar No.: 16126 SAMUEL J. FALK Florida Bar No.: 123539 -2- COLE, SCOTT & KISSANE, P.A. COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O. BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-5300 - (305) 373-2294 FAXIN THE CIRCUIT COURT OF THE 17TH JUDICIAL, CIRCUIT IN. AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE 2018-001322 (12) KARMEL RUNCIE, Plaintiff, Vv. INTERNATIONAL VILLAGE ASSOCIATION, ING, and DOREEN. - SYRLIK Defendants. / AFFIDAVIT OF JOHN LABRIOLA BEFORE ME, the undersigned authority, personally appeared JOHN LABRIOLA, after being duly sworn upon oath, who deposes and says: 1. My name is JOHN LABRIOLA and | am over eighteen (18) years old and competent to make this affidavit. 2, lam currently a resident of Loudgrh | Flex ie 3. lam currently the President for the International Village Association,-Inc. 4, | have executed this affidavit in response to Plaintiff's Cross-Motion to Disqualify Defense Counsel. 5. On July 23, 2018, Plaintiff filed a Response in Opposition to Defendants’ Motion to Disqualify Plaintiffs Attorney and Cross-Motion to Disqualify Defense Counsel. 6. In Plaintiffs Cross-Motion to Disqualify Défense Counsel, Plaintiff alleges that “Defense Counsel should be disqualified because of the incompatibility in positionsin relation to IVA and Syrlik, and/or the fact that there are substantially different possibilities of settlement of ‘the claims or liabilities in question, given Syrlik’s admissions,” ifs Notwithstanding. Plaintiff's allegations that there could be “incompatibility in positions in relation to IVA and Syrlik,” the undersigned consents to Cole, Scott & Kissane, P.A. representing Doreen Syrlik and the. International Village Association, Inc. in the subject lawsuit, 8, There are-no legal conflicts of ‘interest in. Cole, Scott & Kissane, P.A’s representation of Doreen Syrlik and the International Village Association, Inc. FURTHER AFFIANT SAYETH NAUGHT. STATE OF __Floerha COUNTY OF Misti - DADE SWORN TO AND SUBSCRIBED before me on Th Sa of September, 2018. as Ze say oS eRromeh MY COMMISSION # GG 220648 __ EXPIRES: Adgust 22, 2022 Bonded They HOaly Public Underwiters NOTARY PUBLIC; State of Flogba + AT LARGE MY COMMISSION EXPIRES:IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE 2018-001322 (12) KARMEL RUNCIE, Plaintiff, v. INTERNATIONAL VILLAGE ASSOCIATION, INC, and DOREEN SYRLIK Defendants. / AFFIDAVIT OF DOREEN SYRLIK BEFORE ME, the undersigned authority, personally appeared DOREEN SYRLIK, after being duly sworn upon oath, who deposes and says: 1. My name is DOREEN SYRLIK and | am over eighteen (18) years old and competent to make this affidavit. Bes 2. | am currently a resident of Pemegurs , wh, state. F} 7 3. | am currently the Assistant Property Manager for International Village Association, Inc. 4. | have executed this affidavit in response to Plaintiff's Cross-Motion to Disqualify Defense Counsel. 5. On July 23, 2018, Plaintiff filed a Response in Opposition to Defendants’ Motion to Disqualify Plaintiffs Attorney and Cross-Motion to Disqualify Defense Counsel. 6. In Plaintiff's Cross-Motion to Disqualify Defense Counsel, Plaintiff allegesthat "Defense Counsel should be disqualified because of the incompatibility in positions in relation to (VA and Syrlik, and/or the fact that there are substantially different possibilities of settlement of the claims or liabilities in question, given Syrlik’s admissions.” 7. Notwithstanding Plaintiff's allegations that there could be “incompatibility in positions in relation to IVA and Syrlik,” the undersigned consents to Cole, Scott & Kissane, P.A. representing myself and the International Village Association, Inc. in the subject lawsuit, 8. There are no legal conflicts of interest in Cole, Scott & Kissane, P.A.’s representation of myself and the International Village Association, Inc. FURTHER AFFIANT SAYETH NAUGHT. Dr. Ly ld rhs HE Doreen Syrlik Date STATE OF ov COUNTY OF SWORN TO AND SUBSCRIBED before me This 22 day of September, 2018. NOTARY PUBLIC; State of Elovida AT LARGE MY COMMISSION EXPIRES: : ; Qujene 0 Pa, GIOVANNI REGINELLO ‘Commission # OG 156177 Expires October 90, 2024 SS Bens Ths Badge Notary Serene