Preview
Filing# 142410221 E-Filed 01/21/2022 12:21:47 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE: CACE18-000943 (14)
LAWRENCE HERZOG,
PLAINTIFF(s)
V
SEQUOIA GARDENS CONDOMINIUM ASSOCIATION, INC., CITY OF DEERFIELD BEACH, a
politicalsubdivision of the State of Florida, and DAVENPORT PROFESSIONAL PROPERTY
MANAGEMENT, LLC,
DEFENDANT(s)
i
Robert E. Collier,II,Esquire
Sanaz Alempour, Esquire
Frank J. Taddeo, Esquire
Kdran J. Billaud, Esquire
Collier & Associates
Cole, Scott & Kissane, P.A.
7390 N.W. 5th Street,Suite 10
600 N. Pine Island Road, Suite 500
Plantation,FL 33317-1610
Plantation,FL 33324-1324
Email:
Email: sanaz.alempour@csklegal.com;
fjtaddeo@bellsouth.net;
keran.billaud@csklegal.com;
whitney@flaattorneys.com
mayra.chiplock@csklegal.com;
toni.ortiz@csklegal.com
Matthew H. Mandel, Esquire
Justin D. Luger, Esquire
Weiss Serota Helfman Cole & Bierman, P.L.
200 E. Broward Blvd., Suite 1900
Ft. Lauderdale, FL 33301
Email:
jluger@wsh-law.com;
lbrewley@wsh-law.com;
szavala@wsh-law.com
NOTICE OF NON-BINDING ARBITRATION
YOU ARE HEREBY NOTIFIED, pursuant to the agreement of the parties and the provisions of Florida
Statutes Chapter 44, that an Arbitration Conference has been scheduled as follows:
Arbitrator:
Arthur Garcia Jr.
Arbitranon Date: April 29,2022
Arbitration Time: 2:30 p.m.
Arbitranon Locanon: Zoom Video Conference Platform
Time Reserved:
1.00 Hours
Cancellation: It is the equal responsibilityofALL parties to advise ofcancellations and settlement to
avoid a cancellation fee being charged. Unless directed otherwise by the parties agreement, cancellation
feeswill be assessed equally between the parties. Ifat any time the arbitration is cancelled, the materials
that have been submitted and reviewed will be billed at the arbitrator's usual rate. In addition, we must
receive at least a ten (10) day notice ofcancellation/rescheduling
to avoid a disruptioncharge. These
charges also apply to settled cases. Please factorthis in when settlingyour case within the cancellation
period.
The terms and provisionsof the confirmation letter accompanying this Notice of Arbitration are hereby incorporated
by reference into this Notice of Arbitration.
If you are a person with a disabilitywho needs any accommodation in order to participatein this proceeding, you are
entitled to the provisionof certain assistance at no cost to you. Please contact the ADA Coordinator in the
ORMOND BEACH 0 MAITLAND/ORLANDO 0 OCALA 0 JACKSONVILLE 0 FORT LAUDERDALE 0 WEST PALM BEACH 0 MIAMI 0 B IRMINGHAM
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/21/2022 12:21:47 PM.****
Administrative office of Upchurch Watson White & Max, 1400 Hand Avenue, Ormond Beach, FL 32174.
Telephone 386-253-1560 or 800-264-2622, within two (2) working days of receiptof this Notice of Arbitration.
I HEREBY CERTIFY that a true and correct copy of the foregoing Notice ofNon-Binding Arbitration
has been served by e-mail to the above named addressees on Friday, January 21, 2022.
UPCHURCH WATSON WHITE & MAX
One Biscayne Tower
2 S. Biscayne Blvd, Suite 2030
Miami, FL 33131
Phone: 305-266-1224 / Fax: 305-640-8447
Toll Free: 800-264-2622
Website: www.uww-adr.com
BY: /s/ Arthur Garcia, Jr.,Esquire
FL Bar No. 897515
Florida Supreme Court Qualified Arbitrator
ORMOND BEACH 0 MAITLAND/ORLANDO 0 OCALA 0 JACKSONVILLE 0 FORT LAUDERDALE 0 WEST PALM BEACH 0 MIAMI 0 B IRMINGHAM
One Biscayne Tower
2 S. Biscayne Blvd
Suite 2030
Miami, FL 33131
Upchurch NVatson NVhite & Max
Telephone: 305-266-1224
Toll Free: 800-264-2622
MEDIATION GROUP
Facsimile: 305-640-8447
Website: www.uww-adr.com
VIA EMAIL
January 21, 2022
RE HERZOG VS. SEQUIOA GARDENS CONDOMINIUM ASSOCIATION, INC., ET AL
Case #: CACE18-000943 (14)
FILE #: 22AGJR-170
Dear Counsel:
We greatlyappreciateyour confidence and trust in choosing Arthur Garcia, Jr. as your arbitrator.
To address your anticipated
questionsand to avoid any possiblemisunderstandings,
we are
writingto confirm and clearlyset forth the terms and conditions of Mr. Garcia's engagement and
the manner in which the arbitration shall be conducted.
Schedule: The arbitration has been scheduled as set out in the Notice ofNon-Binding
Arbitration.
Interpreter: Pursuant to the Florida arbitration rules and ethics opinions,Mr. Garcia cannot act
as both arbitrator and interpreter.
Should your client or any arbitration participant
requirean
interpreter,
pleasemake the necessary arrangements in advance for an interpreter'
s presence at
the time of the arbitration.
Arbitration Fee: There is a two hour minimum chargefor this matter. The arbitration fee is
calculated at Mr. Garcia's billingrate, the time reserved and pre-arbitration
or post arbitration
time he spends in this matter. There is NO administrative charge.Further,there is NO charge for
travel time and expenses unless specifically
mutually agreedupon.
Allocation of Fees & Payment: Unless otherwise agreed,the arbitration fees and costs shall be
divided equallyamong the partiesparticipating
in the arbitration. Payment is due upon your
rece*t of our bill. While our bill may be subjectto reimbursement from your client to you, or
even forwarded to your client for direct payment, pleaseunderstand that our relationsh*is with
you and that we will ultimatelylook to you to secure payment.
Hourly BillingRate: All services rendered shall be billed at $600.00 per hour.
Arbitration Summaries and Submission of Materials: Mr. Garcia will review any documents
and materials you may regard as relevant. Case summaries must be emailed to agarcia@uww-
adr.com and cgalvez@uww-adr.com at least ten (10)days priorto the arbitration.
Cancellation: It is the equal responsibility
of ALL partiesto advise of cancellations and
settlement to avoid a cancellation fee being charged.Unless directed otherwise by the parties
agreement, cancellation fees will be assessed equallybetween the parties.
If at any time the
arbitration is cancelled,the materials that have been submitted and reviewed will be billed at the
arbitrator's usual rate. In addition,we must receive at least a ten (10)day notice of
cancellation/rescheduling
to avoid a disruptioncharge.These charges also apply to settled
cases. Please factor this in when settlingyour case within the cancellation period.
Please call me at the number above if you have any questions,or you may contact Mr. Garcia
directlyat 305-458-1299.
We appreciateyour bringingthis matter to us and we look forward to working with you to
satisfactorily
settle the dispute.
Cordially,
Cristal L. Galvez
/s/ Cristal L. Galvez
Case Manager
Upchurch Watson White & Max
cgalvez@uww-adr. com
ORMOND BEACH 0 MAITLAND/ORLANDO 0 OCALA 0 JACKSONVILLE 0 FORT LAUDERDALE 0 WEST PALM BEACH 0 MIAMI 0 BIRMINGHAM
Preview
Filing# 142410221 E-Filed 01/21/2022 12:21:47 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE: CACE18-000943 (14) LAWRENCE HERZOG, PLAINTIFF(s) V SEQUOIA GARDENS CONDOMINIUM ASSOCIATION, INC., CITY OF DEERFIELD BEACH, a politicalsubdivision of the State of Florida, and DAVENPORT PROFESSIONAL PROPERTY MANAGEMENT, LLC, DEFENDANT(s) i Robert E. Collier,II,Esquire Sanaz Alempour, Esquire Frank J. Taddeo, Esquire Kdran J. Billaud, Esquire Collier & Associates Cole, Scott & Kissane, P.A. 7390 N.W. 5th Street,Suite 10 600 N. Pine Island Road, Suite 500 Plantation,FL 33317-1610 Plantation,FL 33324-1324 Email: Email: sanaz.alempour@csklegal.com; fjtaddeo@bellsouth.net; keran.billaud@csklegal.com; whitney@flaattorneys.com mayra.chiplock@csklegal.com; toni.ortiz@csklegal.com Matthew H. Mandel, Esquire Justin D. Luger, Esquire Weiss Serota Helfman Cole & Bierman, P.L. 200 E. Broward Blvd., Suite 1900 Ft. Lauderdale, FL 33301 Email: jluger@wsh-law.com; lbrewley@wsh-law.com; szavala@wsh-law.com NOTICE OF NON-BINDING ARBITRATION YOU ARE HEREBY NOTIFIED, pursuant to the agreement of the parties and the provisions of Florida Statutes Chapter 44, that an Arbitration Conference has been scheduled as follows: Arbitrator: Arthur Garcia Jr. Arbitranon Date: April 29,2022 Arbitration Time: 2:30 p.m. Arbitranon Locanon: Zoom Video Conference Platform Time Reserved: 1.00 Hours Cancellation: It is the equal responsibilityofALL parties to advise ofcancellations and settlement to avoid a cancellation fee being charged. Unless directed otherwise by the parties agreement, cancellation feeswill be assessed equally between the parties. Ifat any time the arbitration is cancelled, the materials that have been submitted and reviewed will be billed at the arbitrator's usual rate. In addition, we must receive at least a ten (10) day notice ofcancellation/rescheduling to avoid a disruptioncharge. These charges also apply to settled cases. Please factorthis in when settlingyour case within the cancellation period. The terms and provisionsof the confirmation letter accompanying this Notice of Arbitration are hereby incorporated by reference into this Notice of Arbitration. If you are a person with a disabilitywho needs any accommodation in order to participatein this proceeding, you are entitled to the provisionof certain assistance at no cost to you. Please contact the ADA Coordinator in the ORMOND BEACH 0 MAITLAND/ORLANDO 0 OCALA 0 JACKSONVILLE 0 FORT LAUDERDALE 0 WEST PALM BEACH 0 MIAMI 0 B IRMINGHAM *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/21/2022 12:21:47 PM.**** Administrative office of Upchurch Watson White & Max, 1400 Hand Avenue, Ormond Beach, FL 32174. Telephone 386-253-1560 or 800-264-2622, within two (2) working days of receiptof this Notice of Arbitration. I HEREBY CERTIFY that a true and correct copy of the foregoing Notice ofNon-Binding Arbitration has been served by e-mail to the above named addressees on Friday, January 21, 2022. UPCHURCH WATSON WHITE & MAX One Biscayne Tower 2 S. Biscayne Blvd, Suite 2030 Miami, FL 33131 Phone: 305-266-1224 / Fax: 305-640-8447 Toll Free: 800-264-2622 Website: www.uww-adr.com BY: /s/ Arthur Garcia, Jr.,Esquire FL Bar No. 897515 Florida Supreme Court Qualified Arbitrator ORMOND BEACH 0 MAITLAND/ORLANDO 0 OCALA 0 JACKSONVILLE 0 FORT LAUDERDALE 0 WEST PALM BEACH 0 MIAMI 0 B IRMINGHAM One Biscayne Tower 2 S. Biscayne Blvd Suite 2030 Miami, FL 33131 Upchurch NVatson NVhite & Max Telephone: 305-266-1224 Toll Free: 800-264-2622 MEDIATION GROUP Facsimile: 305-640-8447 Website: www.uww-adr.com VIA EMAIL January 21, 2022 RE HERZOG VS. SEQUIOA GARDENS CONDOMINIUM ASSOCIATION, INC., ET AL Case #: CACE18-000943 (14) FILE #: 22AGJR-170 Dear Counsel: We greatlyappreciateyour confidence and trust in choosing Arthur Garcia, Jr. as your arbitrator. To address your anticipated questionsand to avoid any possiblemisunderstandings, we are writingto confirm and clearlyset forth the terms and conditions of Mr. Garcia's engagement and the manner in which the arbitration shall be conducted. Schedule: The arbitration has been scheduled as set out in the Notice ofNon-Binding Arbitration. Interpreter: Pursuant to the Florida arbitration rules and ethics opinions,Mr. Garcia cannot act as both arbitrator and interpreter. Should your client or any arbitration participant requirean interpreter, pleasemake the necessary arrangements in advance for an interpreter' s presence at the time of the arbitration. Arbitration Fee: There is a two hour minimum chargefor this matter. The arbitration fee is calculated at Mr. Garcia's billingrate, the time reserved and pre-arbitration or post arbitration time he spends in this matter. There is NO administrative charge.Further,there is NO charge for travel time and expenses unless specifically mutually agreedupon. Allocation of Fees & Payment: Unless otherwise agreed,the arbitration fees and costs shall be divided equallyamong the partiesparticipating in the arbitration. Payment is due upon your rece*t of our bill. While our bill may be subjectto reimbursement from your client to you, or even forwarded to your client for direct payment, pleaseunderstand that our relationsh*is with you and that we will ultimatelylook to you to secure payment. Hourly BillingRate: All services rendered shall be billed at $600.00 per hour. Arbitration Summaries and Submission of Materials: Mr. Garcia will review any documents and materials you may regard as relevant. Case summaries must be emailed to agarcia@uww- adr.com and cgalvez@uww-adr.com at least ten (10)days priorto the arbitration. Cancellation: It is the equal responsibility of ALL partiesto advise of cancellations and settlement to avoid a cancellation fee being charged.Unless directed otherwise by the parties agreement, cancellation fees will be assessed equallybetween the parties. If at any time the arbitration is cancelled,the materials that have been submitted and reviewed will be billed at the arbitrator's usual rate. In addition,we must receive at least a ten (10)day notice of cancellation/rescheduling to avoid a disruptioncharge.These charges also apply to settled cases. Please factor this in when settlingyour case within the cancellation period. Please call me at the number above if you have any questions,or you may contact Mr. Garcia directlyat 305-458-1299. We appreciateyour bringingthis matter to us and we look forward to working with you to satisfactorily settle the dispute. Cordially, Cristal L. Galvez /s/ Cristal L. Galvez Case Manager Upchurch Watson White & Max cgalvez@uww-adr. com ORMOND BEACH 0 MAITLAND/ORLANDO 0 OCALA 0 JACKSONVILLE 0 FORT LAUDERDALE 0 WEST PALM BEACH 0 MIAMI 0 BIRMINGHAM