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Item 22
Case 9:15-cv-80480-KAM Document 22 Entered on FLSD Docket 05/15/2015 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 9:15-CV-80480-KAM C.R.N.H., a minor, by and through his mother, guardian, and next friend HEATHER HIRONIMUS, Plaintiff v. DENNIS NEBUS, THE HONORABLE JEFFREY GILLEN AND ALL JUDGES OF THE FIFTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA, SHERIFF OF PALM BEACH COUNTY, FLORIDA RIC BRADSHAW AND ALL SHERIFFS OF THE STATE OF FLORIDA, Defendants _____________________________________________/ MOTION BY JUDGE GILLEN’S COUNSEL TO ATTEND HEARING BY TELEHONE (Unopposed) Counsel for Defendant The Honorable Jeffrey Gillen (Judge Gillen) requests leave of Court to attend by telephone the hearing scheduled for May 18, 2012 at 1:00 p.m., set by Order entered today at 11:19 a.m. CM/ECF 21. As grounds, I have a previously scheduling evidentiary hearing in Miami-Dade Circuit Court at 2:00 p.m. on the same date (copy attached). The hearing concerns a forfeiture case where I represent a Florida law enforcement agency. Law enforcement officers will be present to testify and counsel for a claimant to the property will also be present. The hearing is specially set. It would inconvenience the state court judge, the parties, and the law enforcement witnesses to cancel the hearing. Page 1 of 3 Case 9:15-cv-80480-KAM Document 22 Entered on FLSD Docket 05/15/2015 Page 2 of 6 Because the Order emphasizes the Court will hear legal argument only, I expect my remarks will be brief and along the lines of my pleadings (CM/ECF 11, CM/ECF 18). I respectfully suggest that my attendance by telephone will not impede a fair hearing before this Court, and will allow me to attend the hearing in Miami-Dade. I certify that I conferred with the parties who authorized me to represent as follows: Thomas Hunker, counsel for Plaintiff: Does not oppose this motion. Ira Marcus, counsel for Dennis Nebus: Do not oppose this motion. Deirdre Marroney, counsel for Sheriff of Palm Beach County: Does not oppose this motion. WHEREFORE, for the foregoing reasons, I request leave of Court to attend by telephone the hearing scheduled for May 18, 2012 at 1:00 p.m. I CERTIFY that on May 15, 2015, copies hereof were furnished via CMM/ECF to Thomas L. Hunker, attorney for Plaintiff, Ira Marcus and May Cain, attorney for Defendant Dennis Nebus, and Deirdre E. Marroney, attorney for Defendant Palm Beach County Sheriff’s Office. Respectfully submitted, PAMELA JO BONDI FLORIDA ATTORNEY GENERAL David J. Glantz, Assistant Attorney General Fla. Bar No. 504238 Attorney for Judge Gillen OFFICE OF ATTORNEY GENERAL Civil Litigation Division 110 SE 6th Street, 10th Floor Fort Lauderdale FL 33301-5001 Telephone: (954) 712-4608 Page 2 of 3 Case 9:15-cv-80480-KAM Document 22 Entered on FLSD Docket 05/15/2015 Page 3 of 6 Fax: E-mail: (954) 527-3703 [email protected] Page 3 of 3 Case 9:15-cv-80480-KAM Document 22 Entered on FLSD Docket 05/15/2015 Page 4 of 6 IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT MIAMI-DADE COUNTY, FLORIDA CASE NO. 2015-9289-CA-01 IN RE: FORFEITURE OF 2014 32’7” INTREPID FL 0318 PP and all other property HIN# IBW32686F314, 2 MERCURY VERADO OUTBOARD ENGINES (PORT SERIAL# 2B026718) (STARBOARD SERIAL# 2B026796) _______________________________________________/ NOTICE OF HEARING (30 minutes Special Set) PLEASE TAKE NOTICE that the Court will call up for hearing in the above styled cause the following request: ADVERSARIAL PERLIMINARY HEARING DATE: Monday, May 18, 2015 TIME: 2:00 p.m. JUDGE: Hon. William Thomas, Circuit Judge LOCATION: Miami Dade County Courthouse Court Room 1307 73 West Flagler Street Miami, FL 33130 Case 9:15-cv-80480-KAM Document 22 Entered on FLSD Docket 05/15/2015 Page 5 of 6 Respectfully submitted, PAMELA JO BONDI FLORIDA ATTORNEY GENERAL David J. Glantz Assistant Attorney General Florida Bar No. 504238 Attorney for Petitioner, Florida Fish and Wildlife Conservation Commission OFFICE OF THE ATTORNEY GENERAL 110 S.E. 6th Street, 10th Floor Ft. Lauderdale, Florida 33301 Telephone: 954-712-4608 Fax: 954-527-3702 [email protected] AMERICANS WITH DISABILITIES ACT OF 1990 If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator in the Administrative Office of the Court, Palm Beach County Courthouse, 205 North Dixie Highway, Room 5.2500, West Palm Beach, Florida 33401; telephone number (561)355-4380 within two (2) working days of your receipt of this [notice]; if you are hearing or voice impaired, call 1-800-955-8771. IF YOU ARE IN NEED OF AN INTERPRETER, please contact this office no later than 3 days prior to the scheduled hearing date. Case 9:15-cv-80480-KAM Document 22 Entered on FLSD Docket 05/15/2015 Page 6 of 6 CERTIFICATE OF SERVICE I CERTIFY that on May 6, 2015, a copy hereof furnished via E-Mail to Jeffrey S. Wiener and Annabelle H. Nahra, attorney for Tomas Esteban Cabrerizo, [email protected], [email protected]. David J. Glantz Assistant Attorney General