Abandonment of Post-Trial Motions through Notice of Appeal

Posted by David Adelstein on September 23, 2017
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In an earlier posting, I discussed the difference between a motion for rehearing and motion for reconsideration.  

From that posting, you know that a motion for rehearing is a post-trial motion and, in particular, a motion that applies post-judgment. A properly filed motion for rehearing will toll the time to file an appeal. 

There are times where a party after a judgment is entered will file a motion for rehearing. Then, before that motion is ruled on, will file a notice of appeal. Why? The party is not appealing the order on the motion for rehearing because such an order has not been issued. Thus, the party is filing a notice of appeal of the judgment – yes, the same judgment that prompted the motion for rehearing.

In this case, the law states that the party abandoned its post-trial motion for rehearing. “[B]y filing a notice of appeal prior to obtaining a ruling on the motion for rehearing, Appellant abandoned its motion.” Dep’t of Revenue v. Vanamburg, 174 So.3d 640, 642 (Fla. 1st DCA 2015) (“Florida Rule of Appellate Procedure 9.020(i)(3) provided that if a motion for hearing or a motion to alter or amend, among other post-judgment motions, is filed ‘and a notice of appeal is filed before the filing of a signed, written order disposing of all such motions, all motions filed by the appealing party that are pending at the time shall be deemed abandoned, and the final order shall be deemed rendered by the filing of the notice of appeal.’”). See also Kee v. Bailey, 634 So.2d 654 (Fla. 3d DCA 1994) (“The Florida Supreme Court has clearly stated that a party abandons previously filed post-judgment motions when he files a notice of appeal of that judgment.”).

Now, what if the party filed a motion for rehearing, but then withdrew the motion for rehearing and filed a notice of appeal? In this scenario, “the rendition of the final judgment in this circumstance occurs at the time the notice of appeal is filed, not at the earlier time when the final judgment is entered.” Rice v. 1989 Ford Bronco, 609 So.2d 639, 640 (Fla. 2d DCA 1992).   In other words, when a party abandons its timely filed post-trial motion, the abandonment occurs when the notice of appeal is filed. And, thus, the time to file the notice of appeal is not initiated when the final judgment is entered, but when the post-trial motion is abandoned such as through the filing of the notice of appeal. See Rice, supra, (denying motion to dismiss appeal as untimely due to post-trial motion being abandoned by party filing notice of appeal).

 

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Referral Sources can be a Protected Legitimate Business Interest

Posted by David Adelstein on September 16, 2017
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In a big case for employers that rely on referrals for the viability of their business, the Florida Supreme Court held that referral sources may be a protected legitimate business interest under Florida Statute s. 542.335 based on the context and proof.  Hence, referral sources can be protected under a non-compete / non-solicitation agreement that prohibits the employee, upon leaving, from soliciting referrals for a period of time.   White v. Mederi Caretenders Visiting Services of Southeast Florida, LLC, 42 Fla. L. Weekly S803a (Fla. 2017) (holding that referral sources for a home health care company may be a protected legitimate business interest depending on the context and proof).

This is a big win for employers that have employees sign non-compete and non-solicitation agreements as a condition of employment to safeguard referral lists and sources.   Notably, the term “referral sources” is not specifically called out in Florida Statute s. 542.335, which is a statute that deals with valid restraints on trade (or restrictive covenants in employment agreements such as non-compete or non-solicitation-type agreements). However, the Florida Supreme Court confirmed that the specific legitimate business interests called out in the statute are non-exhaustive meaning other interests, such as referral sources, can constitute a legitimate business interest of an employer.   The context and proof is important, however, with respect to any business interest to establish it is actually a legitimate business interest that should be protected in a restrictive covenant (such as a non-compete or non-solicitation-type agreement).

In language that I find to be extremely germane, the Florida Supreme Court stated:

However, the statute ameliorates any concern regarding overly restrictive covenants. Section 542.335 commands courts to modify, or blue pencil, a non-competition agreement that is “overbroad, overlong, or otherwise not reasonably necessary to protect the legitimate business interest,” instructing courts to “grant only the relief reasonably necessary to protect such interest.” Thus, section 542.335’s phrasing of the business interests that may be protected in broad terms and its restricting courts from applying certain rules of contract construction, the statute grants trial courts fairly wide discretion to fashion the appropriate context-dependent remedy

White, supra, (internal citations omitted).

This language is germane because it reaffirms a trial court’s wide discretion to modify or blue-pencil (red-line) a non-compete or non-solicitation agreement that may be overly broad to protect only those business interests the court deems legitimate. Thus, the trial court does not have to deem the agreement unenforceable, but can modify the terms of the restrictive covenant language and fashion the appropriate remedy to protect the true, legitimate business interests of an employer.

 

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Motion for Rehearing or Reconsideration: What is the Difference?

Posted by David Adelstein on September 03, 2017
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Motions titled rehearing and reconsideration are routinely used interchangeably, as if there is no difference between the name “rehearing” and the name “reconsideration. There is a difference though. A motion for a rehearing is distinct from a motion for reconsideration and this distinction is key. Not understanding the difference between a motion for rehearing and motion for reconsideration can result in an untimely appeal.

Motions for rehearing apply to final judgments. They are filed pursuant to Florida Rule of Civil Procedure 1.530 because they “only apply to final judgments and ‘those orders that partake of the character of a final judgment, i.e., orders that complete the judicial labor on a portion of the cause.’” Seigler v. Bell, 148 So.3d 473, 478 (Fla. 5th DCA 2014) quoting Francisco v. Victoria Marine Shipping, Inc., 486 So.2d 1386, 1290, n.6 (Fla. 3d DCA 1986).

Motions for reconsideration, on the other hand, apply to non-final, interlocutory orders prior to final judgment. Helmich v. Wells Fargo Bank, N.A., 136 So.3d 763, 765 (Fla. 1st DCA 2014). These motions are based on the trial court’s “‘inherent authority to reconsider and, if deemed appropriate, alter or retract any of its nonfinal rulings prior to entry of the final judgment or order terminating an action.’” Seigler, 148 So.3d at 478 quoting Silverstrone v. Edell, 721 So.2d 1173, 1175 (Fla. 1998).

Although a motion for rehearing and motion for reconsideration are oftentimes mistitled, a court will treat a mistitled motion for reconsideration as a motion for rehearing and vice-versa. Seigler, 148 So.3d at 479. Mistitling or not understanding the distinction between the two motions can be problematic since “[a] motion for reconsideration does not toll the time to file an appeal from a non-final order.Agere Systems, Inc. v. All American Crating, Inc., 931 So.2d 244 (Fla. 5th DCA 2006). Conversely, a properly filed motion for rehearing will toll the time to file an appeal. Remington v. Remington, 705 So.2d 920, 922 (Fla. 4th DCA 1997); But see E-Z Marine Supply, Inc. v. Wachovia Commercial Mortgage, Inc., 875 So.2d 279 (Fla. 4th DCA 2004 (improperly filed motion for rehearing will not toll time to file appeal).

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Collateral Source Rule – Prohibiting an Injured Plaintiff from having Its Cake and Eating It too

Posted by David Adelstein on August 27, 2017
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The collateral source rule is the source of unnecessary confusion. This rule is aimed at preventing an injured-plaintiff from having its cake and eating it too – from receiving a windfall from the defendant-tortfeasor based on compensation the plaintiff received from collateral sources.

The collateral source rule allows an injured plaintiff to present all of its damages to the trier of fact (jury) irrespective of payment the injured party received from a collateral source (e.g., insurance, social security, etc.).  Evidence of payments the injured plaintiff received from a collateral source is inadmissible at trial due to the confusion that could result from the introduction of such evidence. However, the court must later reduce the amount of awarded damages by the amount the injured plaintiff received from collateral sources. The point is to prevent the injured-plaintiff from receiving a windfall.

The collateral source rule is embodied in Florida Statute s. 768.76.  Check out this link for this statute in detail, a relevant portion which is identified below.  “This section abrogated the common law rule prohibiting reduction of damages from collateral source payments in an effort to ‘reduce insurance costs and prevent plaintiffs from receiving windfalls.’” Rasinski v. McCoy, 42 Fla.L.Weekly D1711a (Fla. 5th DCA 2017) citing Joerg v. State Farm Mut. Auto. Ins. Co., 176 So. 3d 1247, 1249 (Fla. 2015).

 

Florida Statute s. 768.76

(1) In any action to which this part applies in which liability is admitted or is determined by the trier of fact and in which damages are awarded to compensate the claimant for losses sustained, the court shall reduce the amount of such award by the total of all amounts which have been paid for the benefit of the claimant, or which are otherwise available to the claimant, from all collateral sources; however, there shall be no reduction for collateral sources for which a subrogation or reimbursement right exists. Such reduction shall be offset to the extent of any amount which has been paid, contributed, or forfeited by, or on behalf of, the claimant or members of the claimant’s immediate family to secure her or his right to any collateral source benefit which the claimant is receiving as a result of her or his injury.

(2) For purposes of this section:

(a) “Collateral sources” means any payments made to the claimant, or made on the claimant’s behalf, by or pursuant to:

1. The United States Social Security Act,except Title XVIII and Title XIX; any federal, state, or local income disability act; or any other public programs providing medical expenses, disability payments, or other similar benefits, except those prohibited by federal law and those expressly excluded by law as collateral sources.

2. Any health, sickness, or income disability insurance; automobile accident insurance that provides health benefits or income disability coverage; and any other similar insurance benefits, except life insurance benefits available to the claimant, whether purchased by her or him or provided by others.

3. Any contract or agreement of any group, organization, partnership, or corporation to provide, pay for, or reimburse the costs of hospital, medical, dental, or other health care services.

4. Any contractual or voluntary wage continuation plan provided by employers or by any other system intended to provide wages during a period of disability.

 

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Caveat Emptor = Buyer Beware = Watch Out!

Posted by David Adelstein on August 18, 2017
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Caveat Emptor.  Buyer Beware!!!! This is a doctrine that applies to commercial property transactions. Watch out and do your due diligence when entering into a commercial real estate transaction. If you do not, the doctrine of caveat emptor will apply which puts the onus on you, the buyer, to discover material facts relating to the property.

In Transcapital Bank v. Shadowbrook at Vero, LLC, 42 Fla.L.Weekly D1657b (Fla. 4th DCA 2017), a bulk buyer purchased 123 out of 164 condominium units for approximately $11 Million.   The buyer, thereafter, sued the seller / lender for fraud, among other counts, claiming it was misled about the value of the property and, particularly, each of the condominium units.

Post-trial, the seller / lender appealed claiming the trial court erred in denying its motion for directed verdict at trial. The appellate court agreed that the trial court erred. Why?

The doctrine of caveat emptor applied to this commercial transaction where the buyer purchased 123 condominium units. “This doctrine places the duty to examine and judge the value and condition of the [commercial] property solely on the buyer and protects the seller from liability for any defects.” Transcapital Bank, supra, quoting Turnberry Court Corp. v. Bellini, 962 So.2d 1006, 1007 (Fla. 3d DCA 2007).

There are three exceptions to the applicability of caveat emptor: 1) where the buyer has been prevented from making an independent inquiry regarding the property due to a trick from the buyer; 2) where the buyer does not have equal opportunity to become apprised of a material fact; and 3) where the seller discloses some facts but not the whole truth regarding those facts. Transcapital Bank, supra citing Turnberry Court Corp. v. Bellini, 962 So.2d 1006, 1007 (Fla. 3d DCA 2007).   None of the exceptions, however, applied to this transaction. “Even if any of the defendants [seller / lender] had misrepresented the property’s appraised value, such a misrepresentation would not be actionable under the doctrine of caveat emptor in the absence of evidence that the defendants resorted ‘to some fraudulent means in preventing a prospective purchaser from making an examination of the property under consideration.’Transcapital Bank, supra, citing Farnham v. Blount, 11 So.2d 785, 790 (Fla. 1942).

 

 

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Writ of Certiorari to Remedy Pre-Trial Discovery Order

Posted by David Adelstein on August 12, 2017
Discovery, Standard of Review / Comments Off on Writ of Certiorari to Remedy Pre-Trial Discovery Order

Sometimes, a trial court issues a pre-trial order on a discovery issue that a party claims causes it irreparable harm.   In this situation, the only basis to appeal the pre-trial discovery order is through a petition for writ of certiorari, as recently explained by the Second District Court of Appeal:

A party seeking review of a pretrial discovery order must show that the trial court’s order departed from the essential requirements of law and caused material injury to the petitioner throughout the remainder of the proceedings below, effectively leaving no adequate remedy on appeal.  Generally, certiorari is not available to review orders denying discovery because in most cases the harm can be corrected on appeal. But certiorari relief may be appropriate when the requested discovery is relevant or is reasonably calculated to lead to the discovery of admissible evidence and the order denying that discovery effectively eviscerates a party’s claim, defense, or counterclaim.  The harm in such cases is not remediable on appeal because there is no practical way to determine after judgment how the requested discovery would have affected the outcome of the proceedings.

Westerbeke Corp. v. Atherton, 42 Fla.L.Weekly D1741c (Fla. 2d DCA 2017) (internal quotations and citations omitted).

In this recent opinion (discussed in more detail here), the trial court in a product liability case denied a defendant’s right to perform destructive testing of a boat’s gas generator that caused an explosion. The defendant claimed the destructive testing was necessary to determine the cause of the explosion and prepare a defense. In other words, the harm imposed on the defendant could not be corrected on a final appeal since the harm prevented it from generating a sufficient defense. Here, the Second District granted the writ of certiorari because the trial court applied the wrong legal standard in denying the defendant’s request to perform destructive testing. The take-away is the Second District’s explanation as to when certiorari relief is appropriate to remedy a pre-trial discovery order.

 

 

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

Florida Statutory Cause of Action for Misleading Advertisement

Posted by David Adelstein on August 06, 2017
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Have you been duped into procuring something through misleading advertising? There is a Florida Statute that provides a civil cause of action for misleading advertising. Florida Statute s. 817.41 provides a statutory cause of action for misleading advertising that gives the prevailing party a basis to recover their attorney’s fees in addition to a potential claim for punitive damages.  This is probably a less known statutory cause of action, but it is a particularized statutory fraud claim that is available.

Additionally, the statute maintains that, “There shall be a rebuttable presumption that the person named in or obtaining the benefits of any misleading advertisement or any such sale [i.e, party making misleading advertisement] is responsible for such misleading advertisement or unlawful sale.”  Florida Statute s. 817.41(4).  This is favorable language for a party asserting a claim.

Florida Statute s. 817.40(5) defines misleading advertising as follows:

(5) The phrase “misleading advertising” includes any statements made, or disseminated, in oral, written, electronic, or printed form or otherwise, to or before the public, or any portion thereof, which are known, or through the exercise of reasonable care or investigation could or might have been ascertained, to be untrue or misleading, and which are or were so made or disseminated with the intent or purpose, either directly or indirectly, of selling or disposing of real or personal property, services of any nature whatever, professional or otherwise, or to induce the public to enter into any obligation relating to such property or services.

Importantly, the misleading advertising MUST be made “with the intent or purpose, either directly or indirectly, of selling or disposing of real or personal property, services of any nature whatever, professional or otherwise, or to induce the public to enter into any obligation relating to such property or services.” Fla.Stat. s. 817.40(5); Samuels v. King Motor Co. of Fort Lauderdale, 782 So.2d 489, 496 (Fla. 5th DCA 2001). Since a civil cause of action for misleading advertising is a specialized type of fraud claim, the person asserting the claim MUST allege and support other elements of fraudulent inducement. See Third Party Verification, Inc. v. Signaturelink, Inc., 492 F.Supp.2d 1314, 1322 (M.D.Fla. 2007) (explaining that party asserting misleading advertising claim must also allege: “(a) the representor made a misrepresentation of a material fact; (b) the representor knew or should have known of the falsity of the statement; (c) the representor intended that the representation would induce another to rely and act on it; and (d) the plaintiff suffered injury in justifiable reliance on the representation.”).  

Conversely, if the misleading advertising claim is made by a competitor, then reliance element–that the party asserting the claim relied on the misrepresentation–does not have to be alleged and proven. See id.

 

 

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Not All Non-Final Orders are Immediately Appealable

Posted by David Adelstein on July 30, 2017
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Many non-final orders are NOT immediately appealable. The immediate right to appeal non-final orders are enumerated in Florida Rule of Appellate Procedure 9.130. (And, prior postings have discussed the burden in moving for a writ of certiorari based on a non-final order.) Fair or unfair. These are the rules that govern appellate proceedings. When you receive a non-final order that you believe impacts rights and decisions moving forward, make sure to review Florida Rule of Appellate Procedure 9.130 regarding those immediately appealable non-final orders.

 

In a recent insurance coverage dispute (discussed here), the trial court declared that the insurer had a duty to defend its insured in a personal injury lawsuit.   This declaration was issued in response to a motion for summary judgment. But, the order granting the summary judgment was a non-final order. The trial court did not enter a judgment against the insurer and did not declare the insurer was obligated to indemnify its insurer. Instead, the trial court simply declared that the insurer had an obligation to defend its insured in the lawsuit based on the underlying allegations in the lawsuit. The insurer did not like this declaration from the trial court and appealed.

 

The Third District dismissed the appeal holding that the trial court’s order was not an appealable non-final order.   Just because the trial court issued an order granting an insured’s summary judgment does not in of itself make that an appealable final order. If there are no words of finality concluding the dispute, the order granting summary judgment is simply a non-final order.   In this case, all the trial court declared was that the insurer had a duty to defend – but there was no declaration regarding the duty to indemnify or regarding potential damages.  Hence, the appellate court did not have jurisdiction to entertain the immediate appeal of the non-final order.

 

 

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Properly Pleading the Affirmative Defense of the Nonperformance or Nonoccurrence of Conditions Precedent

Posted by David Adelstein on July 22, 2017
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The nonperformance of conditions precedent must be pled with particularity. Florida Rule of Civil Procedure 1.120(c) provides:

Conditions Precedent. In pleading the performance or occurrence of conditions precedent, it is sufficient to aver generally that all conditions precedent have been performed or occurred. A denial of performance or occurrence shall be made specifically and with particularity.

It is common for a plaintiff to generally plead in its complaint, “All conditions precedent have been performed or have occurred.”   A defendant may want to assert an affirmative defense attacking or denying this allegation relating to the plaintiff’s failure to satisfy certain conditions precedent.   In doing so, a defendant must identify the nonperformance or nonoccurrence of conditions precedent with specificity. Any generality in this regard could end up hurting the defendant, especially if the defendant has a legitimate defense based on the plaintiff failing to comply with conditions precedent.  Hence, make sure to consider applicable conditions precedent and identify those with particularity that deny the plaintiff’s allegation that all conditions precedent have been performed or have occurred.

In a construction dispute, a contractor argued that the subcontractor failed to comply with conditions precedent. However, the contractor’s affirmative defense was general in nature – no particularity.   This may have been a legitimate defense supported by facts since the contractor argued the subcontractor’s failure to comply with conditions precedent to payment meant that the contractor was not obligated to pay the subcontractor. But, based on the generality of the contractor’s affirmative defense, the appellate court held that the contractor failed to property preserve the defense in its affirmative defenses:

In its amended answer, DFI [contractor] asserted, as an affirmative defense, that HRI [subcontractor] “has failed to allege, nor can it establish that it had meet [sic] each and every condition precedent to recovering payment in this cause pursuant to its Complaint.” Contrary to the requirements in Florida Rule of Civil Procedure 1.120(c), DFI did not specify which conditions precedents HRI did not comply with or how HRI failed to comply with them. Consequently, DFI’s answer to the complaint failed to preserve its right to demand proof that HRI complied with the conditions precedent to progress payments and final payment. See Fla. R. Civ. P. 1.120(c); Deutsche Bank Nat’l Tr. Co. v. Quinion, 198 So. 3d 701, 703-04 (Fla. 2d DCA 2016) (“[T]o construct a proper denial under the rule, a defendant must, at a minimum, identify both the nature of the condition precedent and the nature of the alleged noncompliance or nonoccurrence.”); Bank of Am., Nat’l Ass’n v. Asbury, 165 So. 3d 808, 810-11 (Fla. 2d DCA 2015); Cooke v. Ins. Co. of N. Am., 652 So. 2d 1154, 1156 (Fla. 2d DCA 1995); Paulk v. Peyton, 648 So. 2d 772, 774 (Fla. 1st DCA 1994).

 

 

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Insurance Policy Construction is a Question of Law

Posted by David Adelstein on July 15, 2017
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I am sure you have an insurance policy…some type of policy. An automobile liability policy. A commercial general liability policy. A professional liability policy. A property insurance policy.   A directors and officers liability policy. A workers compensation insurance policy. There are many types of insurance policies. I am sure you have some insurance policy to protect you or your business’s needs or risks.   You may have even been involved in an insurance coverage dispute or have had issues dealing with insurance coverage.

If you read any one of your insurance policies, you will probably be left with more questions than answers. You will be asking yourself “what does this mean?” or “what does this say?” and will often be left bemoaning “huh!?!” with every other sentence you read.  This is the exact reason why there are insurance coverage disputes.

When it comes to insurance coverage disputes and the interpretation of the language in an insurance policy, the Florida Supreme Court importantly explained:

Insurance policy construction is a question of law subject to de novo review.  Courts construe insurance contracts according to their plain language.  However, “any ambiguity which remains after reading each policy as a whole and endeavoring to give every provision its full meaning and operative effect must be liberally construed in favor of coverage and strictly against the insurer.”  A provision is ambiguous if it is “susceptible to two reasonable interpretations, one providing coverage and the other excluding coverage.”  The ambiguity must be genuine, and the lack of a definition for an operative term “does not, by itself, create an ambiguity “When a term in an insurance policy is undefined, it should be given its plain and ordinary meaning, and courts may look to legal and non-legal dictionary definitions to determine such a meaning.” 

Government Employees Insurance Co. v. Macedo, 42 Fla. L. Weekly S731a (Fla. 2017) (internal citations omitted).

Obviously, if you have an insurance coverage dispute, you want to make sure you are represented by an attorney that understands the complexities of insurance coverage.  Nonetheless, it is imperative that you understand that insurance policy construction is a question of law for the Court with a de novo standard of appellate review.

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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