Petition for Division of Fees

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR MIAMI DADE COUNTY, FLORIDA

CASE NO.:

PERSONAL INJURY VICTIM

Plaintiff,

vs.

WEST GARDENS VILLAGE CONDOMINIUM

Defendant.

__________________________________________/

VERIFIED PETITION FOR DIVISION OF ATTORNEYS' FEES

COME NOW Justin Ziegler, Esquire, of Justin Ziegler, P.L. and Joseph Glick, of Joseph A Glick, P.A., as co-counsel for the Plaintiff, PERSONAL INJURY VICTIM, and pursuant to Rule 4-1.5(f)(4)(D)(iii), Florida Rules of Professional Conduct, move this Honorable Court for the entry of an Order authorizing their law firms to divide any contingent attorneys' fees earned in the above-styled case on a 50/50 basis, and as grounds therefore would show:

1. That Plaintiff, PERSONAL INJURY VICTIM, was injured in a slip/trip and fall accident that occurred at Miami, Florida on or about October 1, 2006. The Plaintiff, PERSONAL INJURY VICTIM, initially engaged attorney Justin Ziegler to represent his interests in a claim against the condominium involved in the accident. Mr. Ziegler is a personal injury lawyer licensed to practice law in Florida, whose principal office is located in Miami, Florida.

2. That the Plaintiff, through Justin Ziegler, Attorney at Law, has engaged Joseph Glick, Esquire of Joseph A. Glick, P.A., to serve as trial counsel and to work with Mr. Ziegler in the litigation of the above-styled case.

3. That Justin Ziegler has had primary contact with the Plaintiff since the accident, and has been responsible, along with Mr. Glick, for the investigation and preparation of the case pre-suit. Mr. Ziegler and Mr. Glick have conducted investigation and contacted fact witnesses, obtained damages documentation and consulted with potential expert witnesses, and have otherwise provided joint legal counsel to the point that the above-captioned lawsuit was filed. Mr. Ziegler and Mr. Glick will share the duties in the prosecution of the lawsuit, and will be jointly be responsible. Both lawyers have and will be responsible for :

(a) Maintaining communications with the client at all times.

(b) Obtaining all medical records.

(c) Obtaining an expert review of the medical records.

(d) Obtaining opinions of all treating and expert doctors.

(e) Drafting the summons and complaint along with request for production, request for admissions, and interrogatories.

(f) Preparing and responding to all production requests and interrogatories propounded on the plaintiff.

(e) Meeting with all the non-expert and expert damage witnesses.

(k) Attending all discovery depositions.

(l) Preparing all closing documents at conclusion of the case.

(m) Participate in mediation and attend motion hearings and the pre-trial conference as practicable.

(n) Participate in the trial of this case.

4. That the undersigned counsel propose to have substantially equal active participation in providing legal services to the Plaintiff and in bringing about the ultimate result, and request that the Court enter an Order authorizing them to divide the contingent attorneys' fees earned in the above-styled case on a 50/50 basis.

Under penalties of perjury, we declare that we have read the foregoing Petition and that the facts stated therein are true and correct.

______________________________

JUSTIN ZIEGLER, Attorney at Law JOSEPH A. GLICK, Attorney at Law

JUSTIN ZIEGLER, P.L. JOSEPH A GLICK, PA

9100 S. Dadeland Blvd. Suite 908 7300 N Kendall Dr Ste 380

Miami, Florida 33156 Miami, Florida 33156 7839

(305) 403-7506 (305) 668-8311

Florida Bar No.:662305 Florida Bar No.: 356433

Date: 6/26/07 Date:____________________

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to the Plaintiff, PERSONAL INJURY VICTIM, Miami, Florida XXXXX, and to The Florida Bar, 650 Apalachee Parkway, Tallahassee, Florida 32399, this _____ day of June , 2007.

______________________________

Justin Ziegler, Esquire