Item C03BOARD OF COUNTY COMMISSIONERS
AGENDA ITEM SUMMARY
Meeting Date:
October 17, 2007
Division: Employee
Services
Bulk Item: Yes
X No _
Department: Employee
Benefits Office
Staff Contact Person/Phone #:
Maria Z. Fernandez -Gonzalez x4448
AGENDA ITEM WORDING: Approval for final payment in the amount of $6,553.80 for legal
services provided by the firm of Charouhis, Fandino, Lopez & Wright, P.A. for representing the
County in two workers' compensation claims filed by the same employee/claimant.
ITEM BACKGROUND: The above named law firm was retained by the former Workers'
Compensation Administrator and although section 2-359 of the County Code requires Board approval
for retaining any outside counsel, no previous approval was sought. There are two separate invoices,
#11744 & 11745, totaling $9553.80 due to the employee/claimant filing two separate workers'
compensation claims. Charouhis, Fandino, Lopez & Wright, P.A. have agreed to a full and final
settlement of both named invoices in the amount of $6,553.80. Any future cases referred to this firm
would be done pursuant to a contract approval by the Board.
PREVIOUS RELEVANT BOCC ACTION: BOCC approval on 06/21/06 for payment of invoice
#11194 which at the time was thought to be the final invoice.
CONTRACT/AGREEMENT CHANGES: None.
STAFF RECOMMENDATIONS: Approval.
TOTAL COST: $6,553.80 BUDGETED: Yes X No
COST TO COUNTY: $6,553.80 SOURCE OF FUNDS:
REVENUE PRODUCING: Yes —No X AMOUNT PER MONTH Year
gh-7A7 -
APPROVED BY: Count _ MB chasing Risk Management
1
DOCUMENTATION:
DISPOSITION:
Revised 8/06
Included Yes Not Required
AGENDA ITEM #
C
UNTY jo'�MONROE
KEY WESTLORIDA 33040
(305)294-4641
Office of the Employee Services Division Director
The Historic Gato Cigar Factory
1100 Simonton Street, Suite 268
Key West, FL 33040
(305) 2924458 — Phone
(305) 2924564 - Fax
•47
TO: Board of County Commissioners
FROM: Teresa E. Aguiar,
Employee Services Dd*Q-'
SUBJ: Payment for Legal Services
Workers' Compensation
BOARD OF COUNTY COMMISSIONERS
Mayor Mario Di Gennaro, District 4
Mayor Pro Tern Dixie M. Spehar, District 1
George Neugent, District 2
Charles "Sonny" McCoy, District 3
Sylvia I Murphy, District 5
DATE: September 26, 2007
This item requests approval for final payment in the amount of $6,553.80 for legal services provided for
the representation of the County in two workers' compensation claims. This Attorney was retained by
the former Workers' Compensation Administrator to represent the County's interest in this employee's
workers compensation cases. Section 2-359 of the County Code requires that previous approval be
obtained before retaining outside counsel, however this was not done.
In June, 2006, we brought to the BOCC an invoice, which we believed was the only payment for services
due to this law firm, however, shortly after we received approval to pay the invoice we received two other
invoices for services for cases involving the same employee which totaled $9,553.80. It is now
understood that this is the last and final payment to this law firm and have received a letter from the
outside counsel stating that the two invoices are the final invoices and that they would accept $6,553.80
as full and final satisfaction for the charges on both cases.
It is the recommendation that the Board approve the payment to the law firm of Charouhis, Fandino,
Lopez & Wright, P.A. in the amount of $6,553.80 for representation of the County in the workers
compensation claims. If you have any questions on this item, please do not hesitate to contact me at
X445 8.
Charouhis & Associates, P.A.
Attorneys at Law
Miami - Nest Palm Beach
80 Southwest 8th Street
Suite 1750
Miami, Florida 33130
Telephone: (786) 279-5708
TAX ID NO. 65-0910939
August 07, 2006
Mary Rodriguez
Preferred Governmental Claims Solutions
PO Box 958456
Lake Mary FL 32795-8456
In Reference To: A�v. Monroe County Board of County Commissioners
Claim No. WCM0084516
D/A: 10-26-04
Our File No. 3636-0001
Professional Services
Invoice No. 11744
Hours Amount
9/14/2005 Receipt and review of new file materials and suit transmittal and instructions for handling
1.30 162.50
(1.30).
9/16/2005 Plan & Prepare correspondence to adjuster regarding state mediation (20).
0.20 25.00
9/28/2005 Verify if state mediation is set (10); verify if private mediation is set (10); review initial
1.90 237.50
order of assignment (20); prepare agreed Motion to Substitute Private for State Mediation
(.50); prepare proposed Agreed Order (.30); t/call to opposing counsel re same (.20);
prepare correspondence to JCC re same, with original attachments (20); transmittal of same
to opposing counsel re same, with attachments (10); prepare exhibits including Notice of
Private Mediation attached (20).
10/4/2005 Review/analyze response from Office of Data Quality and Collection (.10); t/call to
0.70 87.50
Rebecca Ardley regarding prior claim records? (10); Division of Administrative Hearings
research regarding pleadings filed to date (.30)?; Several telephone calls to and from
opposing counsel regarding pretrial hearing (.30-.10 written off); several telephone calls to
and from judge regarding pretrial hearing (.30-.10 written off).
10/6/2005 Verify on Division of Administrative Hearings if state mediation has been substituted for
0.20 25.00
private mediation (.20).
10/9/2005 Determine if all production in, prior claims report in, mmi, medicals in, and any demand or
0.50 62.50
settlement authority and any offers yet in order to be certain we are ready for mediation in
30 days (50).
10/ 12/2005 T/call to the judge regarding substitution of state mediation for private mediation (20);
1.00 125.00
prepare email to adjuster advising that state mediation has been cancelled and substituted
for private mediation (20); prepare correspondence regarding same to the state mediator
(20); and opposing counsel (20); update calendar to reflect same (20).
10/17/2005 Receipt/review Agreed Order Granting Employer/Carrier's Motion to Substitute State
0.40 50.00
Mediation for Private Mediation (20); and updated same on the calendar (20).
10/ 18/2005 Telephone conference with opposing counsel regarding claimant's deposition (20).
0.20 25.00
10/ 19/2005 Detailed review of file in preparation for Claimant's deposition - time split with 3636-0000
2.50 312.50
(50) Appear/attend deposition of Claimant and post -deposition conference with opposing
counsel regarding settlement and neurologist -time split with 3600-0000 (1.00) Review of
detailed notes and preparation of summary of Claimant's deposition -time split with
3600-0000 (1.00)
10/21/2005 Review of Division of Administrative Hearings website to determine if ar(Da io
Petitions S S.
. 0.10 12.50
were filed (.10). -
_ FEB 15 2W
Received
Mary Rodriguez
Page 2
Hours Amount
10/21/2005 Review and analyze file for preparation of Employer/Carrier's response to Claimant's
4.20 525.00
Request to Produce, redact work product or otherwise privileged information, assert
appropriate objections to Claimant's request (1.00); Receipt and review claims file,
including medicals, bills, correspondence, pleadings, and miscellaneous claims documents
(1.00); organize, dedact duplicates, identify, mark and label and place in chronological
order in appropriate subfiles (n/c); remove all work product including faxes and
correspondence to/from employer/carrier and reserve information and bills/correspondence
from defense counsel and place in claims diary folder (.20); Receipt and review claims
diary (.30); Determine date of accident and 13 weeks prior to accident (.20); Prepare Initial
Case Evaluation letter to adjuster (1.50).
11/l/2005 Preparation of Response to Claimant's Request to Produce (.50); review of file regarding
1.90 237.50
private mediation conference (.20); review of file regarding Claimant's deposition (.20);
preparation of amendments to initial case evaluation (1.0).
1 1 /3/2005 Preparation on amendment to initial case evaluation (.20).
0.20 25.00
1 1;4/2005 Division of Administrative Hearings research regarding state mediation and initial
0.80 100.00
assignment (.2Q); Mel one conference with Claimant's counsel, Attorney Hack, regarding
private mediation conference (.20); telephone call to Adjuster, Maryann DeRosa, regarding
private mediation conference (.20); preparation of correspondence to Adjuster regarding
private mediation conference (.20).
Analyze file to determine discovery still outstanding for private mediation (.50); t/call from
0.70 87.50
opposing counsel regarding private mediation (.20).
Follow up AGAIN with opposing counsel regarding we really need demand before
0.20 25.00
mediation (.20).
1 1/6/2005 Preparation for mediation (1.00).
1.00 125.00
1 1/7/2005 Telephone conference with Claimant's counsel, Attorney Hack, regarding private mediation
0.40 50.00
conference (.20); telephone call to Adjuste regarding private mediation conference (.20).
1 1/8/2005 Telephone conference with Mediator regarding private mediation conference (.20);
0.60 75.00
preparation of Notice of (Reconvene) Private Mediation Conference (.20); preparation of
letter to Adjuster, Maryann DeRosa, regarding private mediation conference (.20).
1 1/13/2005 Several emails from employer on termination issues, reasons, and documentation (.20).
0.20 25.00
11/16/2005 Telephone call from Mediator regarding private mediation conference (.20).
0.20 25.00
Telephone call from Mediator regarding private mediation conference (.10); telephone call
0.20 25.00
to opposing counsel regarding same (A0).
11/30/2005 Review of file regarding private mediation conference and whether there is court order for
0.20 25.00
both dates of accident to mediate and court requirements on same (.20).
T/call to the mediator's office regarding reconvene private mediation (.20); prepare
0.40 50.00
amendment to Notice of Reconvene Private Mediation and attachments and copies for all
parties as required listing both dates of accident (.20).
12/3/2005 Receipt and review letter from O/C and releases executed by Claimant (.20); prepare letter
1.30 162.50
to SSA and complete E/C's portion of release and all information required to determine if
SSD application yet (.20); prepare letter to Dept. of Labor and complete E/C's portion of
release and all information required to determine if UE application filed by Claimant and if
UE received (.20); prepare letters to all medical providers with copies of medical
authorizations executed and completed (.20); prepare letter to SS office re: prior employers
of Claimant and prior addresses and earnings so that they can be contacted to ascertain if
any of them have prior WC claims on record (.20); research to determine appropriate SS
office address to direct inquiry for SS disability benefits (.10); preparation of
correspondence to Attorney Conahan requesting correct sion release form for
unemployment information, enclosing new release form for same (.20)
12/21 /2005 Review of DWC 25 and recommendations by Dr. Gran (10); file regarding what else needs
1.20 150.00
to be completed before mediation in 60 days for this date of accident and whether further
discovery is needed and what other medical records we need and whether any issues remain
pending that must be resolved at mediation and/or prior to mediation in order to secure an
overall settlement for this date of accident and brain MRI and ENG recommended b y Dr.
Gran and whether same completed and TP stopped (.50); lengthy conference with opposing
counsel regarding Holdiay break
P, G C
and request that opposing counsel please use the next few
_ _ .
weeks to contact claimant on settlement and secure fair demand and advise of same and
claimant for
FEB 15 2007
prepare mediation (.20); determine pfbs for this date of accident remaining
outstanding (.10); interoffice conference regarding same (no charge); telephone call to Dr.
Gran to see if any updated reports from testing (.20); prepare email to adjuster regarding
Received
testing recommended by Dr. Gran (.10).
Mary Rodriguez Page
Hours Amount
1/3/2006 Review of file regarding private mediation conference (20); prepare application to Division
1.20 150.00
of Administrative Hearings for ojcc information (1.00).
1 /5/2006 Follow up regarding ojcc information nedded for case and for washout if we settle (.20).
0.20 25.00
1 /9/2006 Preparation of amendment to pleading style regarding new firm address (.20); preparation
0.40 50.00
of Notice of Change of Firm Address (.20).
1 /12/2006 Follow up with opposing counsel regarding case value and demand (.20).
0.20 25.00
1 /16/2006 Review and analysis of Amended Notice of Private Mediation Conference (.20);
0.40 50.00
preparation of letter to Adjuster, Maryann DeRosa, regarding private mediation conference
(.20).
1 /29/2006 Preparation for mediation in this claim and review of Division of Administrative Hearings
1.00 125.00
regarding all pfbs and prepare opening argument (1.00).
Attend pre -mediation conference with adjuster; attend mediation; assist in preparation of
2.60 325.00
mediation agreement (time split with other claim) (2.60).
2/3/2006 Analyze file to determine discovery still outstanding for private mediation (.50).
0.50 62.50
Review of file regarding private mediation conference (.20); telephone conference with
1.40 175.00
Mediator regarding private mediation conference (.20); telephone conference with
Claimant's counsel, Attorney Hack, regarding private mediation conference (.20); telephone
calls to Adjuster, Mary Ann DeRosa, regarding private mediation conference (.20);
telephone conference with new Adjuster, Mary Rodriguez, regarding private mediation
conference (.20); review of file regarding settlement evaluation for mediation (.20);
preparation of letter to new adjuster, Mary Rodriguez, regarding case evaluation (.20).
Review/analyze updated child support (.10); t/call to opposing counsel regarding child
0.90 112.50
support (.10); draft amendment to motion for approval to include requisite child support
(.20); draft amendment to proposed order to include requisite child support (.20); t/call to
opposing counsel regarding same (A 0); draft correspondence with orginals for filing as
required (.20).
2/4/2006 Detailed research regarding child support payments and carrier's responsibility for payment
1.00 125.00
of same verses claimant's responsibility, pursuant to order received (1.00-time split with
other file).
2/6/2006 Preparation of amendment to file regarding new adjuster, Mary Rodriguez (.20).
0.20 25.00
2/7/2006 Telephone conference with opposing counsel regarding status of Child Support (.20); t/call
0.40 50.00
to clerk of court regarding updated child support (.20).
Review of correspondence from opposing counsel to adjuster on payment requests and
0.30 37.50
isntructions (.10); t/conference with him regarding two separate files so two separate
washouts but totals are the same (.20).
2/13/2006 T/c to Dr. Rivera's office cancelling t/c due to settlement of case (A0); t/call to Judge of
0.40 50.00
Compensation Claims regarding same (.10); three way conference with opposing counsel
and Judge of Compensation Claims announcing settlement as required (20).
2/15/2006 Receipt/review of correspondence from opposing counsel regarding payout for washout
1.00 125.00
(.20); prepare same to opposing counsel with attachments (.20); t/call to opposing counsel
regarding same (.20); t/call to Judge of Compensation Claims regarding washout order
(.20); prepare response regarding payouts to Judge of Compensation Claims (.20).
2/16/2006 T/call from opposing counsel regarding settlement documents (.20).
0.20 25.00
Receipt/review of updated child support letter with attachments (.20); prepare amendment
1.00 125.00
to motion for approval to include requisitechild support information (.20); prepare
amendment to proposed order to include child support information required (.20); t/call to
opposing counsel regarding washouts (.20); prepare correspondence to Judge of
Compensation Claims with orignals and notice of filing as required (.20).
2/21/2006 Discuss division of fees, costs, separate stip, back fees, fees from washout, and breakdown
5.40 675.00
of indemnity and medical with opposing counsel who will advise re: exact taxable
costs
(.20); prepare letter to O/C re: child support, liens if any, and other info re: washout, and all
settlement documents (.20); prepare full release (1.00) and proposed washout order (.20);
review employment documents re: date of termination to determine if general release is
needed (.10);prepare fee affidavit for washout (.20); prepare attorney fee data sheet for
washout (20); prepare Child Support documents required for washout (.20); prepare letter
to Clerk Court
�?
G G S
of Depository as required by JCC (.10); prepare proposed separate
P , • • _
stipulation re: back benefits obtained and fees and costs for same (.50); prepare proposed
fee
FEB 15 2007
order on same (.20); prepare affidavit required to be signed by Claimant regarding
washout and separate fees (20); t/call to Claimant's attorney re: costs to be included in
washout documents fee
Received
(.10); prepare affidavit for separate stipulation on fees (.20);
prepare attorney fee data sheet for separate stipulation on fees (.20); prepare tabs for all
Mary Rodriguez
Page 4
Hours Amount
t
documents in washout as required by the Division of WC (.20); prepare motion for approval
for settlement (.50); prepare addendum release in support of order approving settlement
(.20); Preparation and assembly of child support form for DOR (.20); Preparation and
assembly of correspondence to DOR regarding same (. 20); Preparation and assembly of
Affidavit of Claimant regarding Child Support and Alimony (.30).
3/2/2006 Numerous t/calls to/from opposing counsel regarding washout status and terms (.30).
0.30 37.50
3/3/2006 Telephone conference with opposing counsel office regarding settlement documents (.20).
0.20 25.00
3/7/2006 Receipureview of correspondence from Dade County Clerk of Court regarding Child
0.20 25.00
support (.20).
3/14/2006 Review and organize all washout documents, including settlement documents, child support
0.20 25.00
forms, etc. (.20).
3/17/2006 Amend settlement documents (.20).
0.20 25.00
Telephone conference with opposing counsel office regarding settlement documents, child
0.30 37.50
support and Department of Revenue forms (.30).
3/28/2006 Telephone conference with opposing counsel office regarding settlement documents (.20);
0.30 37.50
Preparation and assembly of correspondence to adjuster regarding same (.10).
Follow up to ensure all bills paid prior to closing (.40).
0.40 50.00
Prepare amended genreral document filing forms for washouts (.20).
0.20 25.00
3/30/2006 Review regarding two dates of accident and consoldation for washout (.20).
0.20 25.00
4/5/2006 Telephone conference with opposing counsel office regarding settlement documents and
0.80 100.00
status conference (.20); Preparation and assembly of correspondence to Miami Dade Child
support requesting updated child support (.20); Preparation and assembly of
correspondence to Department of revenue requesting updated child support (.20);
Preparation and assembly of correspondence to adjuster regarding same (.20).
4/17/2006 Receipt/review of correspondence from Florida Department of Revenue regarding Child
0.20 25.00
Support outstanding (.20).
4/24/2006 Receipt and review executed Washout Full Release from O/C, and attachments, and
1.70 212.50
correspondence from O/C re: same (.20); review all proposed additions/changes to Washout
Full Release and proposed Washout Order and prepare amendments and initial same and
execute on E/C's behalf (.20); receipt and review executed separate Fee Stipulation from
O/C, and fee affidavit, and completed attorney fee data sheet (.20); review all proposed
additions/changes to Fee Stipulation
r ,
and proposed Fee Order and prepare amendments and
initial same and execute on E/C's behalf (.20); receipt and review executed Severance
Agreement, ADA Release, confidentiality agreement, and voluntary resignation and witness
2
and execute on E/C's behalf (.20); prepare letter to employer regarding termination and
attachments including general releases and resignation (.20); prepare letter to JCC and
v, Q d
complete washout package including all proposed Orders and required attachments,
affidavits, child support documentation (.30); prepare correspondence to DOAH Clerk
regarding: same in compliance with the Rules (.10); prepare Order on disk as required by
the Division of Workers Compensation (.10).
5/4/2006 Telephone conference with opposing counsel regarding Release (.20).
0.20 25.00
5/ 13/2006 Review/analyze correspondence from central clerking office of Judge of Compensation
0.20 25.00
Claims regarding filing of pleadings, with attachments (.20).
5/ 15/2006 Follow up regarding affidavit for fees (.20); review of mediation agreement and whether we
0.60 75.00
have right to file motion to enforce since opposing counsel is not timely returning washouts
(.20); determine whether we are still paying any benefits at this time (.20).
5/23/2006 Receipt/review of correspondence from Judge of Compensation Claims regarding
0.30 37.50
settlement documents (.20); telephone conference with Judge of Compensation Claims
regarding same (.10).
5/26/2006 Several t/calls regarding status of washout and medical care post -settlement (20).
020 25.00
Review of correspondence from Judge of Compensation Claims indicating original
0.40 50.00
stipulation for substitution has been filed (.20); request Order closing file (.20).
5/31/2006 Research and pull Wood v. File Rock Industries, Florida Statute 440.34(1) and Florida
0.20 25.00
Statute 440.105(3)(c) - time split with file 3636-0000 (.20).
Review of notary documentation required and prepare certificate of notary and notarize
0.20 30.00
same (.20).
6/ 16/2006 Determine what if anything we can do at this juncture to bring washout to closure (.10);
0.20 25.00
review of correspondence from opposing counsel on case (.10).
6/20/2006 Research and review of Division of Administrative Hearings website for settlement status of
0.40 50.00
approval from Judge of Compensation Claims (.20); telephone conference with opposing
counsel regarding approval (.20).
Mary Rodriguez Page
Hours __Amount
6/20/2006 Amend all settlement documents per the Judge of Compensation Claims request pertaining
0.70 87.50
to child support (.50); Preparation and assembly of correspondence to Judge of
Compensation Claims enclosing same with self address stamped envelopes (.20).
6/22/2006 Telephone call from opposing counsel regarding washout status (.10); telephone call to
0.30 37.50
Judge of Compensation Claims regarding washotu status and documents received (.10);
telephone cal lto opposing counsel regarding judge's advise (.10).
6/27/2006 T/call from O/C' regarding status of case (.30)
0.30 37.50
T/call from Attorney James E. Hack's office regarding settlement papers (.20)
0.20 25.00
Telephone conference from Judge of Compensation Claims regarding settlement documents
0.40 50.00
(.20); telephone conference from opposing counsel office regarding same (.20).
6/28/2006 Receipt and review signed washout order from JCC (.20); review complete washout
0.80 100.00
package including the Separate Stip for Attorney Hack and his Tax ID number (.20);
prepare correspondence to adjuster attaching signed washout document and requesting same
to be processed for payment (.20); t/call to O/C re: we are in receipt of washout package
and same has been requested to be paid as agreed on the washout stipulation (.20).
7/5/2006 Telephone conference with adjuster regarding settlement checks (.20).
0.20 25.00
7/11/2006 Telephone conference with adjuster regarding address verification of location the settlement
0.60 75.00
checks were sent to (.20); Preparation and assembly of correspondence to adjuster regarding
same (.20); telephone conference with opposing counsel office regarding same (.20).
7/13/2006 Preparation of correspondence to adjuster regarding settlement checks (.20).
0.20 25.00
7/25/2006 Telephone call to opposing counsel regarding settlement draft and if same was timely
2.20 275.00
received -- confirm checks received and total amount received (.20); prepare
correspondence to adjuster regarding settlement drafts were timely received and we will
close our file at this time and prepare all closing documents (.60); notify all providers file
settled and claimant must self -pay for care on own or through health insurance (.60); strip
and close file (.50); t/call to JCC regarding Order to close file(.20); t/call to O/C regarding
closing of file(. I0).
For professional services rendered
55.40 $6,930.00
Additional Charges
2/21/2006 Photocopies for washouts
24.00
Excess postage required by Judge of Compensation Claims for washouts
41.65
Total costs
$65.65
Total amount of this bill
$6,995.65
Balance due
$6,995.65
.�.c 9,
FEB 15 2007
Received
� � I
Charouhis & Associates, P.A. (_
Attorneys at Law
Miami - West Palm Beach
1
80 Southwest 8th Street
Suite 1750
M1tiami, Florida 33130
Telephone: (786) 279-5708
TAX ID NO. 65-0910939
August 07, 2006
Mary Rodriguez
Preferred Governmental Claims Solutions
PO Box 958456
Lake Mary FL 32795-8456
Invoice No. 11745
In Reference To: 408�v. Monoroe County Board of County Commissioners
Claim No. WCLT078459
D/A: 12-21-04
Our File No. 3636-0000
Professional Services
Hours Amount
2/3/2006 Review/analyze updated child support (.10); t/call to opposing counsel regarding child
0.90 112.50
support (.10); draft amendment to motion for approval to include requisite child support
(.20); draft amendment to proposed order to include requisite child support (.20); t/call to
opposing counsel regarding same (.10); draft correspondence with orginals for filing as
required (.20).
Receipt and review letter from O/C and releases executed by Claimant (.20); prepare letter
1.30 162.50
to SSA and complete E/C's portion of release and all information required to determine if
SSD application yet (.20); prepare letter to Dept. of Labor and complete E/C's portion of
release and all information required to determine if UE application filed by Claimant and if
UE received (.20); prepare letters to all medical providers with copies of medical
authorizations executed and completed (.20); prepare letter to SS office re: prior employers
of Claimant and prior addresses and earnings so that they can be contacted to ascertain if
any of them have prior WC claims on record (.20); research to determine appropriate SS
office address to direct inquiry for SS disability benefits (.10); preparation of
correspondence to Attorney Conahan requesting correct sion release form for
unemployment information, enclosing new release form for same (.20)
2/6/2006 Preparation of amendment to file regarding new adjuster, Mary Rodriguez (.20).
0.20 25.00
2/7/2006 Review of correspondence from opposing counsel regarding confirmation of settlement
0.70 87.50
(.10); t/call to him regarding two separate washouts and discussed washout for this case
separately (.20); t/call to Judge of Compensation Claims regarding settlement and
cancellation of all events and no need for pretrial hearing (.20); three way t/call to state
mediator regarding settlement at private mediaiton and no need for state mediation to be set
(.20).
2/ 13, 2006 T/c to Dr. Rivera's office cancelling t/c due to settlement of case (.10); t/call to Judge of
0A0 50r00
Compensation Claims regarding same (.10); three way conference with opposing counsel
and Judge of Compensation Claims announcing settlement as required (.20).
2! 16,2006 T/call from opposing counsel regarding settlement documents --second review of separate
0.20 25.00
documents (.20).
2/21/2006 Discuss division of fees, costs, separate stip, back fees, fees from washout, and breakdown
4.70 587.50
of indemnity and medical with opposing counsel who will advise re: exact ta.cable com
(.20); prepare letter to O/C re: child support, liens if any, and other info re: washout, and all
settlement documents
G C S
(.20); prepare full release (1.00) and proposed washout order (.20); ..
° s ,
,
review employment documents re: date of termination to determine if general release is
needed (. I0);prepare fee
FEB 15 2007
affidavit for washout (.20); prepare attorney fee data sheet for
, .
washout (20); prepare Child Support documents required for washout (.20); prepare letter
Mary Rodriguez o Page
C
Hours Amount
to Clerk of Court Depository as required by JCC (10); prepare proposed separate
stipulation re: back benefits obtained and fees and costs for same (50); prepare proposed
fee order on same (20); prepare affidavit required to be signed by Claimant regarding
washout and separate fees (20); t/call to Claimant's attorney re: costs to be included in
washout documents (10); prepare fee affidavit for separate stipulation on fees (20);
prepare attorney fee data sheet for separate stipulation on fees (20); prepare tabs for all
documents in washout as required by the Division of WC (20); prepare motion for approval
for settlement (50); prepare addendum release in support of order approving settlement
(20).
3/7/2006 Receipt/review of correspondence from Dade County Clerk of Court regarding Child
0.60 75.00
Support (20); prepare amendment to motion for approval to include child support
information (20); prepare email correspondence regarding settlement (.20).
3/14/2006 Review and organize all washout documents, including settlement documents, child support
0.20 25.00
forms, etc. (20).
3/23/2006 Receipt/review correspondence from opposing counsel regarding revised attorney fee data
0.30 37.50
sheet (10); ReceiptireviejV�copy of correspondence to Judge of Compensation Claims from
opposing counsel enclosing revised attorney fee data sheet (10); Receipt/review revised
Attorney fee data sheet (.10)
3/28/2006 Telephone conference with opposing counsel office regarding settlement documents (.20);
0.50 62.50
Preparation and assembly of correspondence to adjuster regarding same (10); telephone
conference with the Judge of Compensation Claims regarding same (20).
4/3/2006 Telephone conference with opposing counsel office regarding settlement documents, child
0.20 25.00
support, and status conference (20).
4/1 1/2006 T/call to Clerk of Court regarding child support (.20).
0.20 25.00
4/19/2006 Receipt/review of correspondence from Miami -Dade County regarding outstanding child
0.20 25.00
support (20).
4/21/2006 Telephone conference with opposing counsel office regarding Claimant Affidavit regarding
0.20 25.00
child support and alimony, Child support forms from the DOR and Cleark of Court and the
Motion for Approval of Attorney fees (20).
4/24/2006 Receipt and review executed Washout Full Release from O/C, and attachments, and
1.70 212.50
correspondence from O/C re: same (20); review all proposed additions/changes to Washout
Full Release and proposed Washout Order and prepare amendments and initial same and
execute on E/C's behalf (.20); receipt and review executed separate Fee Stipulation from
O/C, and fee affidavit, and completed attorney fee data sheet (.20); review all proposed
additions/changes to Fee Stipulation and proposed Fee Order and prepare amendments and
P S
initial same and execute on E/C's behalf (.20); receipt and review executed Severance
Agreement, ADA Release, confidentiality agreement, and voluntary resignation and witness
F 28 15 2W7
and execute on E/C's behalf (.20); prepare letter to employer regarding termination and
attachments including general releases and resignation (.20); prepare letter to JCC and
Received
complete washout package including all proposed Orders and required attachments,
affidavits, child support documentation (.30); prepare correspondence to DOAH Clerk
regarding: same in compliance with the Rules (.10); prepare Order on disk as required by
the Division of Workers Compensation (10).
Preparation and assembly of correspondence to adjuster enclosing full release and separate
0.20 25.00
agreement (20).
5/ 13/2006 Review/ analyze correspondence from central clerking office of Judge of Compensation
0.20 25.00
Claims regarding filing of pleadings, with attachments (20).
5/23/2006 Receipt/review of correspondence from Judge of Compensation Claims regarding
0.30 37.50
settlement documents (20); telephone conference with Judge of Compensation Claims
regarding same (10).
5/31 /2006 Research and pull Wood v. File Rock Industries, Florida Statute 440.34(1) and Florida
0.20 25.00
Statute 440.105(3)(c) - time split with file 3636-0000 (20)
Review of notary documentation required and prepare certificate of notary and notarize
0.20 30.00
same (20).
6/16/2006 Determine what if anything we can do at this juncture to bring washout to closure (10);
0.20 25.00
t/call to opposing counsel regarding two files (10).
6/20/2006 Amend all settlement documents per the Judge of Compensation Claims request pertaining
0.70 87.50
to child support (50); Preparation and assembly of correspondence to Judge of
Compensation Claims enclosing same with self address stamped envelopes (20).
Mary Rodriguez Page 3
Hours Amount
6/28/2006 Receipt and review signed washout order from JCC (.20); review complete washout
0.80 100.00
package including the Separate Stip for Attorney Hack and his Tax ID number (.20);
prepare correspondence to adjuster attaching signed washout document and requesting same
to be processed for payment (.20); t/call to O/C re: we are in receipt of washout package
and same has been requested to be paid as agreed on the washout stipulation (.20).
7/ 12; 2006 telephone conference from adjuster regarding settlement checks (.20); telephone conference
0.40 50.00
with opposing counsel office regarding same (.20).
7/13/2006 Preparation and assembly of correspondence to adjuster regarding settlement checks (.20).
0.20 25.00
7/14/2006 Telephone conference from adjuster regarding settlement checks (.20); telephone
0.40 50.00
conference with opposing counsel office regarding same (.20).
7/18/2006 Telephone conference with adjuster regarding settlement checks (.20); telephone conference
0.20 25.00
with Opposing counsel office regarding same (.20).
7/19/2006 Telephone conference with opposing counsel office regarding settlement checks (.20);
0.40 50.00
Preparation and assembly of correspondence to adjuster regarding same (.20).
7/24/2006 Receipt/review settlement checks (.40); prepare correspondence regarding same to opposing
counsel, with attachment (.20); t/call to
0.80 100.00
opposing counsel regarding same (.20).
7/25/2006 Telephone call to opposing counsel regarding settlement draft and if same was timely
received -- confirm checks received and total amount received (.20); prepare
2.20 275.00
correspondence to adjuster regarding settlement drafts were timely received and we will
close our file at this time and prepare all closing documents (.60); notify all providers file
settled and claimant must self -pay for care on own or through health insurance (.60); strip
and close file (.50); t/call to JCC regarding Order to close file(.20); t/call to O/C regarding
closing of file(. I0).
For professional services rendered
19.90 $2,492.50
Additional Charges
2/21/2006 Excess postage for washouts
24.00
Photocopies of postage
41.65
Total costs
$65.65
Total amount of this bill
$2,558.15
Previous balance
$6,037.50
Balance due
$8,595.65
'- G.
FEB 15 2007
ReCeivect