Additional Information concerning Mr. Manos’ case files and experiences expressly requested by client:

Undefeated in Trial

Mr. Manos’ personalized and moral approach to practicing law has led to an undefeated trial record. He has significant experience in jury and non-jury trials and court proceedings, and he has negotiated favorable settlements for clients in several cases in excess of $1 million, and was named in Verdict Search’s Top 100 Verdicts in the United States in 2006. His noteworthy verdicts and settlements include:

  • $5.4 million against a major aircraft company
  • $33 million verdict against a leading oil company
  • $37.2 million in a large defamation suit
  • $24 million+ settlement in a class action settlement against a major national HMO
  • $1.01 billion+ settlement in a class certification of 600,000 physicians against several national HMOs

Successfully Defending a Client From a $60 Million Lawsuit

Tom J. Manos, representing a Miami defendant who was doing business with a failed stock brokerage in Venezuela, won an appeal affirming the dismissal of a case in Miami-Dade Circuit Court alleging a $60 million fraud, civil theft and conspiracy against his client in favor of litigation in the courts of Venezuela on forum non conveniens grounds.

The doctrine of forum non conveniens permits defendants to move to dismiss cases filed in Florida where a foreign forum would be more convenient for the defendant and the court finds the alternative forum to be available and adequate to hear the case.

In this case, Manos obtained a dismissal in the trial court for his client in favor of litigating in the courts of Venezuela, arguing at an evidentiary hearing that Venezuela’s court system was an adequate alternative forum for the litigation and that other factors also favored Venezuela’s courts over Miami’s courts. On appeal of the dismissal order, and after oral argument, the Third District Court of Appeal affirmed without opinion on February 26, 2014, and on March 31, 2014 denied a motion by the plaintiff for rehearing and rehearing en banc, or in the alternative for a written opinion. See, Vasquez-Estrella v. Camperos, Case No. 11-035080, Miami-Dade Circuit Court, Third District Court of Appeal case No. 13-2342. The appllate court’s order is now final.

Succeeding Where Others Failed

A client came to the firm for bankruptcy advice after their previous law firm lost a motion for a summary judgment for $2.5 million. Mr. Manos assessed the client’s legal position and came up with a new angle. He convinced the judge to set aside the prior judgment and dismiss the case with prejudice. As a result, Mr. Manos was able to save the client from a $2.5 million judgment and from bankruptcy.

Winning a Record Defamation Award

Mr. Manos represented a Nicaraguan banker libeled in financial publications and newspapers by another banker who was trying to gain leverage in a contract dispute. Despite the absence of any economic damages, Mr. Manos developed a successful approach to proving damage to his client’s reputation. That resulted in a jury verdict of $37.2 million for the client – the largest defamation award in Florida history.

Saving a Home from an Unscrupulous Lender

While attending a hearing on another matter, Mr. Manos overheard a case where two elderly handicapped women were being evicted from their home by an unscrupulous and predatory lender. The ladies were crying and told the judge that they couldn’t afford an attorney. The judge said that, unfortunately, his hands were tied. Mr. Manos immediately volunteered to represent the ladies pro bono and obtained a continuance. Subsequently he found irregularities in the lender’s practices, succeeded in defeating the lender’s motion for writ of possession, and forced the lender to dismiss its case, resulting in the women keeping their home.