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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.
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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
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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.
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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