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HomeMy WebLinkAboutAttorney/Client Session - May 10, 2011 MINUTES OF ATTORNEY/CLIENT SESSION DANIA BEACH CITY COMMISSION TUESDAY, MAY 10, 2011 — 6:00 P.M. 1. Call to Order/Call to Order Mayor Flury called the meeting to order at 6:00 p.m. Present: Mayor: Patricia A. Flury Vice-Mayor: Bobbie Grace—Arrived at 6:30 p.m. Commissioners: Anne Castro Walter Duke C. K. "Mac" McElyea City Manager: Robert Baldwin City Attorney:: Thomas Ansbro City Clerk: Louise Stilson 2. Attorney/Client Session Mayor Flury announced: "We are about to have an attorney/client session in accordance with Florida Statute 286.011(8) regarding the litigation styled as follows: IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA Sven H. Jutz, CASE NO.: 09-051261 (04) Plaintiff, VS. City of Dania Beach, Florida, a Municipal corporation under the laws of the State of Florida, Defendant. City of Dania Beach, Florida, a Municipal corporation under the laws of the State of Florida, Counter-Plaintiff, Sven H. Jutz a/k/a Ben R. Gluck, Counter-Defendant, and Allegria Entertainment, Inc. d/b/a Beach Watch Restaurant, Third-Party Defendant The session is estimated to last approximately one (1) hour and the following people will be in attendance at this meeting: (a) Mayor Pat Flury; Vice-Mayor Bobbie Grace; Commissioner Anne Castro; Commissioner Walter Duke and Commissioner C. K. McElyea (b) City Attorney, Tom Ansbro and Special Counsel, Jamie Cole and Dan Abbott (c) City Manager, Robert Baldwin. These proceedings will be recorded by a certified court reporter and, at the conclusion of all litigation,the transcript will be made part of the public record. We will now temporarily adjourn this meeting and proceed to have an Attorney/Client session in the City Manager's conference room on the second floor. At the conclusion of that meeting, we will return to re-open the public meeting." Mayor Flury temporarily adjourned the meeting at 6:01 p.m. Mayor Flury re-opened the meeting at 6:42 p.m. She announced the attorney/client session was terminated and members of the general public were now invited to return for any further proceedings or matters. Minutes of Attorney/Client Session 2 Dania Beach City Commission Tuesday,May 10,2011 —6:00 p.m. 3. Adj ournment Mayor Flury adjourned the meeting at 6:42 p.m. ATTEST: CITY OF DANIA BEACH LOUISE STILSON, CMC PATRICIA A. FLURY CITY CLERK P�Flft., � MAYOR—COMMISSIONER Approved: May 24, 2011 1 � 1 Minutes of Attorney/Client Session 3 Dania Beach City Commission Tuesday,May 10,2011 —6:00 p.m. ` CITY COMMISSION OF DANIA BEACH, FLORIDA IN RE: SVEN H. JUTZ, Plaintiff, IN N -vs wKIGINAL - CITY OF DANIA BEACH, FLORIDA, a Municipal corporation under the laws of the State of Florida, Defendant. CITY OF DANIA BEACH, FLORIDA, a Municipal corporation under the laws of the State of Florida, Counter-Plaintiff, -vs- a Sven H. Jutz a/k/a Ben R. Gluck, f Counter-Defendant and Allegria Entertainment, Inc. d/b/a Beach Watch Restaurant, Third-Party Defendant . ATTORNEY/CLIENT SESSION Date Taken: May 10, 2011 Time : 6 : 00 p.m. Place : 100 W. Dania Beach Blvd. Dania Beach, Florida Taken by Emily Scott, stenographic reporter United Reporting, Inc. 1218 SE 3rd Avenue b.� Fort Lauderdale, Florida 33316 a United Reporting, Inc. (954) 525- 2221 Page 2 1 APPEARANCES : 2 Mayor Pat Flury 3 Vice Mayor Bobbie Grace 4 Commissioner Anne Castro 5 Commissioner Walter Duke 6 Commissioner C.K. "Mac" McElyea 7 City Manager Robert Baldwin 8 City Attorney Tom Ansbro, Esq. 9 Special Counsel Daniel L. Abbott, Esq. 10 Special Counsel Jamie A. Cole, Esq. 11 12 13 14 15 16 17 18 a 19 20 21 22 23 24 25 United Reporting, Inc. (954) 525- 2221 Page 3 1 Thereupon, the following proceedings were had: 2 MAYOR FLURY: Okay. It is 6 o' clock, and 3 I am calling this public meeting to order. 4 Roll call, please? 5 CITY CLERK: Mayor Flury? 6 MAYOR FLURY: Here . 7 CITY CLERK: Commissioner Castro? 8 COMMISSIONER CASTRO: Here . 9 CITY CLERK: Commissioner Duke? 10 COMMISSIONER DUKE : Here . 11 CITY CLERK: Commissioner McElyea? 12 COMMISSIONER McELYEA: Present . 13 CITY CLERK: City Manager Baldwin? 14 CITY MANAGER BALDWIN: Here . 15 CITY CLERK: City Attorney Ansbro? 16 CITY ATTORNEY ANSBRO: Here . 17 CITY CLERK: Thank you. 18 MAYOR FLURY: Thank you. 19 The time is now 6 p.m. We are about to 20 have an attorney-client session in accordance 21 with Florida Statute 286 . 011 (8) regarding the r 22 litigation styled as follows : In the Circuit 23 Court of the 17th Judicial Circuit in and for 24 Broward County, Florida; Case Number 09-051261 25 (04) . United Reporting, Inc. (954) 525- 2221 Page 4 1 That ' s Sven H. Jutz v. the City of Dania 2 Beach, Florida, municipal corporation under 3 the laws of the State of Florida; City of 4 Dania Beach, Florida, municipal corporation 5 under the laws of the State of Florida, 6 Counter-Plaintiff, Sven Jutz and Ben Gluck, 7 Counter-Defendant, and Allegria Entertainment 8 doing business as Beach Watch Restautrant . 9 This session is estimated to last 10 approximately one hour. The following people 11 will be in attendance at this meeting: Mayor 12 Pat Flurry, Commissioner Anne Castro, 13 Commissioner Walter Duke, and Commissioner 14 C.K. McElyea, City Attorney Tom Ansbro, a 15 Special Counsels Jamie Cole and Dan Abbott, 16 City Manager Robert Baldwin. 17 These proceedings will be recorded by a 18 certified court reporter, and at the 19 conclusion of all litigation, the transcript 20 will be made part of the public record. 21 We will now temporarily adjourn this 22 meeting and proceed to have an Attorney/Client 23 session in the City Manager' s conference room 24 on the second floor. At the conclusion of 25 that meeting, we will return to re-open the X United Reporting, Inc. (954) 525- 2221 Page 5 1 public meeting. 2 I just want to ask -- do we know -- Ms . 3 Bobbie Grace is not here at this time . She 4 may join us . 5 CITY CLERK: If she does, please note the 6 time . 7 MAYOR FLURY: Okay. Thank you. 8 (Whereupon, the proceedings were temporarily 9 adjourned and relocated to the City Manager' s conference 10 room, where they were reopened and proceeded as 11 follows : ) 12 MAYOR FLURY: Okay. We have 50 minutes . 13 CITY ATTORNEY ANSBRO: We are waiting on 14 Bob Baldwin. He is coming. We have got time . 15 MAYOR FLURY: Why don't we get started. 16 CITY ATTORNEY ANSBRO: All right . We 17 will do that. 18 Dan Abbott and Jamie Cole, special 19 counsel, I am going to have Mr. Abbott -- even 20 though Mayor Flury was not here at the time, 21 we met in executive session in June of last 22 year -- is that correct? 23 MR. ABBOTT : Yes . 24 CITY ATTORNEY ANSBRO: -- and at that 25 time -- go back, if you could, and give the United Reporting, Inc. (954) 525- 2221 Page 6 1 Mayor a current update of what we summarized 2 and talked about at that time -- 3 MR. ABBOTT: Sure . 4 CITY ATTORNEY ANSBRO: -- as a 5 commission. 6 MR. ABBOTT : Sure . 7 The Allegria Entertainment lawsuit is g litigation with your lessee of your pier for 9 the Beach Watch Restaurant, for the bait shop 10 and for the pier admission fees . 11 It is a lease that was entered into back 12 in 2003 for operations that began in 2007 ; and 13 the initial complaint was filed by Allegria in 14 2009, and you filed a counterclaim very 15 shortly thereafter in 2009 . 16 The complaint, at this point, now 17 contains 21 counts, 21 counts that your lessee 18 has sought recovery against the City; and 19 rather than talking about all 21 of those 20 counts, I am going to group them together. 21 Several of the counts allege a breach of 22 contract -- 23 (City Manager Baldwin enters the proceedings 24 at 6 : 09 p.m. ) 25 MR. ABBOTT: -- for duties that simply do United Reporting, Inc. (954) 525- 2221 Page 7 1 not exist in the lease, things like : you 2 should have built us a two-story restaurant or 3 you have made us pay property taxes for the 4 building and the City should pay those . 5 Those are obligations that simply do not 6 exist in the lease, and we have moved for 7 summary judgment on those counts . That ' s a 8 procedural motion that says, we shouldn' t even 9 have to try the case in front of a jury, those 10 counts just don' t have any legal merit . 11 Some of the counts allege breach of 12 duties that are contained in the lease : When 13 you built the building, you provided the g'. 14 air-conditioning, for instance, and the fire 15 alarm system that Allegria alleges are not r 16 functioning properly. Those claims are not 17 subject to summary judgment because we 18 can' t -- we can' t unprove the facts . When 19 Allegria says, those things aren' t working 20 properly, those things are going to be subject 21 to a trial . 22 There are a couple of counts on what the 23 law calls quasicontractual theories . They 24 seek a reformation of the contract . In other 25 words, they say that the contract was not United Reporting, Inc. (954) 525- 2221 Page 8 g 1 written properly, that the actual agreement is 2 different than what was written down; and they 3 have got a claim of fraud in the inducement, 4 that we tricked them into entering into the 5 lease . We have a motion for summary judgment 6 on those claims, as well . 7 And, lastly, there are a couple of 8 noncontractual claims . There is a -- what 9 used to be labelled as a defamation action; it 10 has been refiled as a civil rights action now, 11 and we have a motion for summary judgment on 12 those claims, as well . 13 So, in essence, a number of allegations 14 against the City that we have not complied 15 with the lease for and have, otherwise, 16 adversely affected the business that ' s going 17 on on your pier attorney. 18 CITY ATTORNEY ANSBRO: One thing, for 19 Pat, a little bit more of a go-back. 20 The catalyst for why we are in court is 21 that when we found out they had essentially 22 subleased or assigned the lease to somebody 23 else without advance City approval, that was 24 the catalyst so say, now, you have done it, 25 you have done that; and they lied to us, in United Reporting, Inc. (954) 525- 2221 Page 9 1 this room, that they had not done that . We 2 proved that they had done it, and we found a 3 number of nasty things they were trying to 4 pull with these people to lie to us . 5 We said, that ' s it. I sent them a 6 default letter with that issue and a couple 7 other things that they cured, minor things; 8 but that one, to us, was uncurable . It ' s 9 like, you broke it, the marriage is over. 10 Before we could file the eviction suit on 11 that claim, they countersued with the first of 12 four lawyers to say -- like five days before 13 we could get our case heard, with this jury 14 trial suit against it. It was their measure 15 to slap us back and try to force us into a 16 settlement, and early on they talked about 17 settlement. That ' s why we are in this . It ' s 18 heightened into a nuclear war now. 19 MR. ABBOTT: Yeah, Tom is exactly right, y 20 and that was the basis of the counterclaim, as 21 initially alleged, that your lessee had 22 subleased the premises, without your approval, 23 which is contrary to the terms of the lease . 24 Pursuant to some direction we got the 25 last time we were in executive session, we TM MA United Reporting, Inc. (954) 525- 2221 Page 10 1 have since amended that counterclaim to allege 2 additional breaches of the lease by your 3 tenant . One of the claims is that they are 4 not maintaining proper financial records, so 5 you can' t determine what is due to you for 6 things like pier admission and for percentage 7 rent if sales of the restaurant pass a certain 8 threshold. 9 We have a claim that the restaurant is 10 supposed to be run as a first-class 11 restaurant . We have alleged breach of that 12 provision, and we intend to show the 13 restaurant is not being run as the sort of 14 establishment that you envisioned; and we have 15 a claim that they haven' t procured the sort of 16 the insurance that is required under the terms 17 of the lease . 18 One thing that is not currently in the 19 counterclaim, because it has just happened, 20 your lessee has breached its obligation to pay 21 property taxes for the leased premises for 22 this calendar year. That just came to our 23 attention in the last couple of weeks . 24 We have sent a notice of default but we 25 have not -- we cannot amend the counterclaim United Reporting, Inc. (954) 525- 2221 Page 11 1 until their time to cure that has passed. 2 It ' s about $21, 000 in property taxes that they 3 haven' t paid. 4 Since last we met about a year ago, the 5 case has heated up, and we are getting ready 6 for trial, and trial is coming up in less than 7 a month now. There have been a number of 8 depositions taken of fact witnesses . Both 9 parties have retained expert witnesses, and 10 some of those experts have been deposed. 11 The experts fall into three main areas . 12 The first is both sides have air-conditioning 13 experts, since your lessee has alleged that 14 the air-conditioning system that was installed 15 in the restaurant isn' t sufficient to cool the 16 restaurant . We have both hired experts in 17 terms of the quality of that, of that system. 18 Both parties have hired restaurant 19 experts : us, to provide testimony that the 20 restaurant is not being run as a first-class 21 establishment; their expert will presumably 22 say it is . 23 And, lastly, both sides retained 24 accountants to deal with Allegria ' s claim that 25 certain actions of the City have cost them United Reporting, Inc. (954) 525- 2221 Page 12 1 money in the form of lost profits that they 2 would have made under the lease, or so they 3 allege . 4 As Tom has pointed out, we met in 5 executive session almost a year ago. At that 6 time, certain estimates of your likelihood of 7 success were provided to the Commission. 8 Here is what we said, generally speaking: 9 We think have a relatively small, perhaps a 10 15% chance or so, that you will suffer a 11 significant adverse monetary judgment. In 12 other words, there are claims against the City 13 that you have breached the lease, that you 14 haven' t provided the parking that is required, 15 that the air-conditioning is not as good as it 16 should have been, that you should have allowed 17 some parties that you didn' t allow. 18 We think we have good defenses to most of 19 those claims, and so we think there is only 20 about a 15% chance you will suffer a 21 significant monetary judgment . 22 On the other hand, we didn' t give an 23 especially high likelihood of success on our 24 eviction action. I think the estimate we 25 provided was about 30 or 35% . That ' s because, United Reporting, Inc. (954) 525- 2221 Page 13 1 while we contend that Allegria breached a 2 number of provisions in the lease, usually, 3 somebody that tries to foreclose on a 4 commercial lease is because the tenant stopped 5 paying, has stopped paying their rent . That 6 is the typical basis of an eviction action, 7 and your tenant has been paying the rent. 8 So, these claims that we have of breach 9 of a lease are a little bit of a difficult row 10 to hoe, especially when your tenant has 11 initially paid a substantial amount of 12 build-out cost. They put hundreds of 13 thousands of dollars, allegedly, into the 14 build-out of building; and to try to end that 15 tenancy 10 to 15 years before the lease is due 16 to expire is a difficult case to prove . 17 That ' s why we have given you a relatively low 18 estimate of the chances of success . 19 The most likely outcome, I think we said, 20 was about a 50% chance that the jury is going 21 to just tell everybody to go back and abide by 22 the terms of the agreement, that Allegria can 23 stay but they don' t get any money, and people 24 should just proceed under the terms of the 25 lease and into future . United Reporting, Inc. (954) 525- 2221 Page 14 1 We haven' t substantially changed those 2 estimates . There has been discovery. There 3 have been a lot more witnesses, but we think, 4 generally speaking, that is still a pretty 5 good estimate your chance of success or lack 6 of success in the litigation. 7 Also, since last we met, we were ordered 8 to go to mediation that is a Court-ordered 9 process, to see if the case can be settled. 10 Your City Attorney, Tom Ansbro and others were 11 there . I think Tom wanted to share a thought 12 or two with you about the mediation before I 13 moved on. 14 CITY ATTORNEY ANSBRO: Well, the mediator 15 was a fellow named Howard Jaffe, a long-time 16 litigator, 35, 40 years as a civil trial 17 litigator, jury trials, since he has been 18 retired several years, he has done a thousand 19 mediations and successfully mediated 800 of 20 those, so that ' s an 80% success rate . 21 He came into the mediation, the opening 22 statements to lay out the facts, he read 23 everything, very thorough, very competent, big 24 bear of a guy, 614" , 280-pound guy, very -- 25 almost intimidating, deep voice . h United Reporting, Inc. (954) 525- 2221 Page 15 1 He takes the other side in to start the 2 talk. Twenty minutes later he comes back to 3 us . He is visibly agitated. His hands are 4 shaking. He takes his old briefcase that he 5 used to use in trial and starts putting papers 6 away and says, I am done here . 7 I said, what is that about? g I have done ten mediations of my own. I 9 have been in 40 of them, probably, in my 10 career. I have never seen the mediator give 11 up, ever, much less in 20 minutes . 12 I asked, please, sit down, what happened. 13 He wouldn' t precisely tell us . We found 14 out later. What had happened is they impugned 15 his integrity, saying you are in their pocket, 16 saying are you a Dania Beach resident, are you 17 hired by them -- they attacked his integrity 18 to where he just lost it. 19 We persuaded him, please, stay, let ' s 20 just -- and make sure we go through the 21 process of mediation so we can report to the 5;. 22 judge that we tried. 23 COMMISSIONER CASTRO: Can I interrupt you 24 for a second? 25 They were represented by counsel at United Reporting, Inc. (954) 525- 2221 Page 16 1 mediation? 2 CITY ATTORNEY ANSBRO: Yes . 3 COMMISSIONER CASTRO: And counsel 4 participated in that? 5 CITY ATTORNEY ANSBRO: Yes . 6 COMMISSIONER CASTRO: Seriously? 7 CITY ATTORNEY ANSBRO: Oh, yes . 8 COMMISSIONER CASTRO: Wasn' t counsel part 9 of selecting the mediator? 10 CITY ATTORNEY ANSBRO: Yes, mutually 11 selected. We proposed, and he accepted our 12 offer of this particular guy; but, you know, I 13 had never heard of the guy before . 14 COMMISSIONER CASTRO: I don't care . I 15 think some action should be taken against that 16 attorney, is what I think. 17 CITY ATTORNEY ANSBRO: Well, and I can e 18 tell you what he -- something funny, I heard 19 him say -- he said, oh, I can tell you this, 20 they are, quote, bad actors, nasty, nasty 21 people; which is no surprise to me, much less 22 to any of you. 23 But go ahead and tell us, if you can, to 24 the extent we have to report what happened at 25 the mediation. United Reporting, Inc. (954) 525- 2221 Page 17 1 MR. ABBOTT : Yes, the mediator was 2 eventually convinced to return to the 3 mediation. 4 At the mediation, we received a 5 settlement demand from Allegria in the amount 6 of $5 . 272 million. So, if you were to pay 7 them that amount of money, they would agree to 8 the cancellation of the lease . 9 I don' t know where exactly that number 10 comes from. The plaintiff' s expert accountant 11 has testified that damages to Allegria are in 12 the rough amount of $7 million. That ' s an 13 awfully big number. Let me tell you, 14 generally, where those numbers come from. 15 About 3 million of those $7 million are 16 based upon profits that would have been 17 recovered if there were a second floor to the 18 restaurant, an obligation that you simply 19 didn' t have under the terms of the lease; and 20 he essentially said, well, if you doubled the 21 floor area by having a second floor and you 22 assume that they would double their business, 23 they would make a lot more money. 24 We don' t take that as an especially 25 serious claim, but that is where about United Reporting, Inc. (954) 525- 2221 Page 18 1 3 million of the 7 million comes from. 2 About 2 million of the remaining money is 3 purported lost profits based upon -- premised 4 upon the following: That the first year of 5 operation, Allegria made some money in their 6 business operations . Since then, the business 7 has been gradually failing, profits have 8 fallen from year to year. 9 The expert said, well, if they would have 10 continued to make the same profits they did 11 the first year and even made greater profits 12 over the life of the lease, they would have 13 made a lot more money; and I assume that the 14 reason they are making less money now than 15 they used to is because the City breached its 16 obligations . It was not especially powerful 17 testimony, so I don' t want you to be scared. 18 I mean, it is a $7-million claim. I 19 believe that ' s what they are asking the jury 20 for . It ' s an inflated claim, though, and we 21 have some awfully good arguments against it . 22 I don' t know where the $5 million came from, 23 but that was the demand at mediation. 24 There was one other relatively brief 25 exchange after that demand was received. The United Reporting, Inc. (954) 525- 2221 Page 19 1 mediator didn' t suspect you were in a big 2 hurry to cut a $5-million check, so he had 3 initially contacted the attorney for Allegria 4 and said, we are going to have to think of a 5 different framework, would you be interested 6 in a framework that included the following: A s 7 set departure date, in other words, sometime 8 in the future that you would leave the 9 premises; in addition to that, an opportunity 10 to assign the lease to somebody who the City 11 would approve, so they could presumably make 12 some money in transferring the lease to a 13 third party and, lastly, maybe some money to 14 supplement that. 15 The attorney said that that framework 16 might very well be acceptable, and the 17 mediator asked your team, if that framework 18 might be acceptable; and we said, sure, we 19 would be happy to hear what they have to say. 20 Then the mediator went to talk to your 21 plaintiffs and returned to say, Allegria is 22 not interested in a framework like that . 23 $5 million was the demand, and the mediation 24 ended shortly after that . J. 25 We are set for trial . We have those United Reporting, Inc. (954) 525- 2221 Page 20 1 motions for summary judgment set and coming 2 up. We are specially set for trial, which 3 means we will begin trial on this date, unless 4 something unusual happens, on June 13th, so in 5 less than a month now. We are ready to go . 6 So, what are those -- what options do you 7 have at this point? You can settle the case 8 for $5 million. You could reinitiate 9 settlement discussions and see if their y 10 settlement position has changed since the 11 mediation, although the mediation was just 12 this past Monday. I am not sure that their 13 position will have changed substantially; or 14 you can prepare to try the case, which, 15 candidly, seems to be your most viable option 16 at this point . 17 But we are here to take direction from 18 you and to answer any questions you might 19 have . Having said that, I will open the floor 20 and do my best to answer any questions . 21 COMMISSIONER DUKE: What ' s the source of 22 payment for a monetary loss? 23 MR. ABBOTT : For the City? 24 COMMISSIONER DUKE : Uh-huh, are we 25 insured? United Reporting, Inc. (954) 525- 2221 Page 21 1 CITY ATTORNEY ANSBRO: No. 2 MR. ABBOTT: I would suspect not . 3 CITY ATTORNEY ANSBRO: I tendered this 4 for insurance, as I always do whenever a claim 5 comes in. They say this is a contract dispute 6 and there is not coverage -- 7 COMMISSIONER DUKE: Okay. 8 CITY ATTORNEY ANSBRO: -- unlike a 9 slip-and-fall or a PI, personal injury type of 10 case, so there is no coverage . 11 COMMISSIONER DUKE: And you had described 12 some sort of ratio percentage for a 13 significant monetary loss . What is that to 14 you, the 5 million you are talking about? 15 MR. ABBOTT : You know, there is quibbling 16 about the -- about the quality of the 17 air-conditioning system. The air-conditioning 18 system, a brand-new one up to their specs, 19 would be $100, 000 . 20 They do say the air-conditioning system 21 isn' t working that well . We have some 22 contrary testimony. Maybe a claim like that 23 can go either way, but this 24 multi-million-dollar claim is what I mean to 25 suggest is a very unlikely outcome . United Reporting, Inc. (954) 525- 2221 Page 22 1 MAYOR FLURY: Do we remember exactly what 2 they put into that -- into the build-out? 3 CITY ATTORNEY ANSBRO: The claim is 150 . 4 MR. ABBOTT: That ' s what -- 5 CITY ATTORNEY ANSBRO: 122 for build-out; 6 and then, at the end of the day, when they 7 say -- it was supposed to be 850 they kept 5 8 talking about . 9 MR. ABBOTT : Well, that ' s in the 10 complaint . The complaint has made the 11 representation that between the build-out and 12 the restaurant equipment was $850, 000 . They 13 were even only able to get their expert to 14 purportedly verify a little over $100, 000 . 15 MAYOR FLURY: I would believe the 800, 000 16 in a heartbeat, because they had to put in the 17 walls . They had to put in the kitchen, all 18 that equipment . They had to put in the 19 ceiling. They -- we gave them the shell . 20 CITY ATTORNEY ANSBRO: I will tell you 21 this . It is my clear recollection they came 22 in and were going to do it first class, 23 everything was going to be brand-new. s 24 Then they came in and went, this is not 25 going to work. They went and bought used United Reporting, Inc. (954) 525- 2221 Page 23 1 equipment, used coolers . 2 Now, the kitchen stuff had to be new. 3 That is correct . They had to be fabricated. 4 MAYOR FLURY: Yes . 5 CITY ATTORNEY ANSBRO: And they are being 6 sued by the fellow that put the work in there . 7 MR. ABBOTT : They have not paid a number g of their contractors, which is making them, 9 generally, willing witnesses . 10 I mean, oftentimes, if I were to call the ' 11 other side ' s contractor, they are not in a 12 hurry to talk to me . These people are talking 13 to us . I think they haven' t been paid. 14 MAYOR FLURY: Even if it was eight or 15 nine hundred thousand, whatever, they are not 16 going to accept anything but their five . 17 Do you feel pretty comfortable about 18 that? 19 CITY ATTORNEY ANSBRO: They seem 20 extremely stubborn about it . They were 21 willing to call impasse, which means we don' t 22 talk anymore . 23 Now, I was interested in the idea they 24 get to stay for a certain period of time and 25 we give them more opportunity to try to sell United Reporting, Inc. (954) 525- 2221 Page 24 1 it . At some point -- you may not know this, 2 but Bea Morley, who used to own a lot of 3 nightclubs, came around here . I met her about 4 three months ago. 5 She said, I have a number of people from 6 Russia and all these weird places over there 7 that want to invest in this kind of thing, and 8 if I bring that here, will you do it? 9 I said, you can' t talk to me, talk to 10 them, get them to sell off, give us a 11 reasonable person that can run a restaurant 12 that is not a criminal, and we ' ll approve 13 them. We will take whoever you can if it is a 14 viable person who can run a restaurant . 15 She has been on that track to try to work 16 something out, and nothing has worked out, 17 partly because, she said, they are so 18 difficult to deal with. 19 Myself and Colin Donnelly have lived and 20 breathed this, and I have found them to be 21 extremely untruthful; and I think, if we --we 22 have this opportunity, if you want to give it 23 to us, to paint the picture of who they are, 24 they are awful people . 25 I went back onto the website last week to United Reporting, Inc. (954) 525- 2221 Page 25 1 read all the stuff from Trip Advisors, the v 2 people who go as customers; and the one 3 comment word you see -- I must have seen it 75 4 times -- is "rude . " There is one thing in 5 there from the guy who went two or three 6 months into the restaurant being brand-new, 7 opened, six months later he said, I take it 8 all back, it was me that went there, they are 9 completely different, I don' t know what 10 happened. 11 You read it, and it ' s horrible reading to 12 read this about our place that we wanted to be 13 a signature place . The people hate it. They 14 hate it. E 15 MAYOR FLURY: How long do you estimate a 16 trial would be? 17 CITY ATTORNEY ANSBRO: A week, five days . 18 COMMISSIONER CASTRO: Just out of 19 curiosity, once again, if we prevail, they are 20 off the restaurant and the pier, right? 21 MR. ABBOTT : If we prevail in our 22 counterclaim, yes, they would be evicted from 23 the entire premises . 24 COMMISSIONER CASTRO: And, to me, that ' s 25 the key, because, remember -- and I don' t know United Reporting, Inc. (954) 525- 2221 Page 26 1 how this plays into the case, because here 2 they are coming and saying we interfered with 3 the restaurant operations, yet they had the 4 restaurant for sale before we even got here . 5 So, they had already made a mind to exit, but 6 what they want to do is keep the pier. 7 Now, that doesn' t help the case in any 8 way? 9 MR. ABBOTT : Well, it ' s interesting you 10 should mention that . When we deposed the 11 expert, the entire claim for damages is on the 12 restaurant part of the operations . 13 So, remember, we have been naturally 14 suspicious, because they haven' t kept very 15 good records, for how much money they are 16 making in the bait shop and are they 17 delivering to you your proper share of the 18 pier entry fees . They have continued to hide 19 that information from me by not providing it 20 to their experts so I could ask some 21 questions . The only thing they want to talk 22 about is the restaurant . 23 COMMISSIONER DUKE : Have they paid the 24 income taxes? Is the Internal Revenue Service 25 after them for any reason? United Reporting, Inc. (954) 525- 2221 Page 27 1 MR. ABBOTT: I am not aware of any 2 Internal Revenue Service claim, but that ' s a 3 good point . I can certainly find that out . 4 COMMISSIONER CASTRO: We did an audit -- 5 we tried to do an audit . 6 MR. ABBOTT : Yes . 7 COMMISSIONER CASTRO: That ' s part of the 8 evidence, I assume? 9 MR. ABBOTT : Yes . 10 COMMISSIONER CASTRO: When the -- 11 CITY ATTORNEY ANSBRO: Don' t forget, by 12 the way, your recollection of that, say, four- 13 or five-page report where the guy concluded 14 that, even had they -- people were not 15 skimming off the top and cashiers taking money 16 and bartenders taking money, they couldn' t 17 have possibly made $1 . 2 gross, just because it 18 wasn' t -- the numbers weren' t there to support 19 it . 20 They couldn' t even show 800 as a gross 21 revenue, and the guy said, they just don' t 22 make the nuts to get to the -- 23 COMMISSIONER CASTRO: And to this point, 24 they are trying to get out of the revenue 25 figure because they' re saying the first few United Reporting, Inc. (954) 525- 2221 Page 28 1 months were profitable and after that, it 2 wasn' t. It is our fault that it wasn' t, which 3 supports them making a minimum payment, which 4 is what they want to do, even though they may 5 have owed us more money, which I believe they 6 did, because of the pier operation, but they 7 didn' t keep the records . 8 But to your point about painting who they 9 are, I assume you are going to call them to 10 testify? 11 MR. ABBOTT: Of course . 12 COMMISSIONER CASTRO: And I assume you 13 are going to push their buttons, because they 14 are easy to push, because they are nasty, mean 15 people; and I hope a jury sees that because 16 that ' s where it all, like you said, comes 17 down. 18 Secondly, I think the honesty will come 19 out -- or dishonesty or lack of honesty, 20 either through the audit, perception or 21 whatever and that -- 22 COMMISSIONER DUKE : The parties and all 23 that . 24 CITY ATTORNEY ANSBRO: It ' s everything. 25 I keep saying, in my mind, it ' s painting United Reporting, Inc. (954) 525-2221 Page 29 1 a picture stroke by stroke until the jury 2 goes, oh, my God, I get it . It ' s like the 3 Caylee Anthony case: I get it, you must have 4 killed her; I get it, you are bad people, look 5 what you did. _ 6 We are trying to show as many people as 7 we can, like your story the other day, going 8 there to have a glass of wine, the experiences 9 of real people and how they were treated over a 10 there : Pregnant women whose cars were towed. 4 11 COMMISSIONER DUKE: But does the very 12 fact that they are bad people mean they are in 13 default of the lease? 14 COMMISSIONER CASTRO: No. 15 CITY ATTORNEY ANSBRO: It ' s part of 16 running a first-class operation. 17 COMMISSIONER CASTRO: Right . 18 CITY ATTORNEY ANSBRO: The people we 19 hired, by the way, are the Maersks, the people 20 who bought the Maerssk boat line . 21 COMMISSIONER CASTRO: The other thing I 22 will do is -- 23 (Vice Mayor Grace joined the proceedings at 24 6 : 30 p.m. ) 25 CITY ATTORNEY ANSBRO: Vice Mayor Grace United Reporting, Inc. (954) 525- 2221 Page 30 1 joined us at 6 : 30 . 2 COMMISSIONER CASTRO: The other thing I 3 will do is go to character and possibly 4 honesty, which is where you want to start 5 spreading it, because that ' s where it is going 6 to come out . 7 The other thing is, did you interview or 8 talk to any of their former employees? 9 MR. ABBOTT: Yes, we have, primarily in 10 connection with the sublease issue . We have 11 found a former server there who supports our a 12 thought that this was really a turnkey 13 operation. In other words, Allegria ' s 14 contention now is, that was never really a 15 sublease, we just brought in a manager to help 16 with the work, but we were involved the whole 17 time; the server says that is not the case. 18 CITY ATTORNEY ANSBRO: The evidence is 19 such that, what they were doing -- they turned 20 it over to these other people . It was three 21 people, a husband, wife and a cook. 22 They began to cook in the bait shop. 23 They put little stuff in there to make 24 smoothies and cook Jamaican patties, and it 25 outraged the guy to whom they had just United Reporting, Inc. (954) 525- 2221 Page 31 1 subleased the restaurant that they are 2 competing with him. 3 That started to come up in his 4 deposition. They didn' t want to go too far 5 into it . I said, wait for the jury trial for 6 that . 7 More importantly, to me, is that the week 8 we found out they were lying to us and the 9 people came in to Colin and me on a Friday 10 night to say, we are the tenant . 11 We said, who are you? 12 When they told us the story, I had BSO 13 take a complete report, and we found out the 14 fraud they did to these people and us . 15 That following Sunday, the wife calls the 16 guy, says I need to meet with you and we need 17 to change some papers in the documents, we 18 need to show that you were an employee . 19 He said, I am not going to -- my lawyer 20 is not around, that doesn' t do it . 21 That ' s going to come out . If I can paint 22 this, through these guys, paint every stroke 23 of the lying, the deceit . I have got to get 24 it because the concern is, it ' s just not 25 enough to say, well, you lied to us but we United Reporting, Inc. (954) 525- 2221 Page 32 1 cured it, what ' s the big deal . They were 2 worried a jury is not going to like that, 3 because of the investment in that . I want to 4 show the lies, you know. If you show the 5 deceit, I think you can get them. 6 COMMISSIONER CASTRO: I think, first of 7 all, what you have to do is connect the lying 8 to the fact they didn' t invest that much into 9 it . As a matter of fact, they were subleasing 10 to people who had no experience, so they 11 weren' t trying to maintain a first -- you 12 know, they wanted the pier. That ' s what they 13 ended up coming out of. That ' s what they 14 wanted. 15 There are some other employees you might 16 want to talk to because there were issues when 17 the restaurant first opened, and even months 18 into the opening. 19 I have a friend who worked there, and she 20 told me they were washing dishes in the 21 bathroom. I mean, there is a lot of stuff, 22 really crazy. That ' s why I never went there . 23 Never did I go there to eat because I wasn' t 24 going to go there . 25 I can give you a name later if you could United Reporting, Inc. (954) 525- 2221 Page 33 1 check the employee stuff, you can find it. 2 She actually, I think, worked in the bait shop 3 and the restaurant but mostly in the bait 4 shop. 5 There is a lot of weird stuff there, 6 which, again, will tell you, these people were 7 not only not running a first-class operation, 8 they weren' t managing it adequately. That ' s 9 the bargain of the deal . That ' s their 10 problem; that ' s not our problem. 11 I assume you have all the records of the 12 air-conditioning fixes? We went out 52 times, 13 all that stuff, so -- 14 CITY ATTORNEY ANSBRO: I will tell you 15 one of the best parts is they talked about it 16 was our fault the alarm kept going off. We 17 had the alarm company come in. They testified 18 beautifully for the City. They said they r 19 didn' t know how to set the alarm. They were 20 sleeping. 21 Guess what they did with the 22 air-conditioning? We finally got the truth 23 out of them. They didn' t change the filters 24 on them; they were black. They didn' t tighten 25 the belts to the fan, so the thing is not even United Reporting, Inc. (954) 525- 2221 Page 34 1 working efficiently. Guess what, people get 2 it in a jury box like, I have been stupid 3 before and didn' t change the oil or I didn' t 4 change the AC filter. 5 COMMISSIONER CASTRO: It ' s Florida, of 6 course, you have to maintain. 7 CITY ATTORNEY ANSBRO: It ' s one thing to 8 maintain it, but then to say it ' s a blowback 9 to us, that we did it, is really bad. 10 I tell you one thing that happened is 11 that apparently a key employee that runs the 12 bait shop and very important to them, lives 13 here nearby. In one of the depositions, they 14 got spooked about something that came out, and 15 they called her immediately to say, that 16 better not be you that said that to them. She 17 is terrified for her job. I can' t use her as 18 a witness because she wants her job. 19 COMMISSIONER CASTRO: You will have to 20 tell me her name later. 21 CITY ATTORNEY ANSBRO: We will deal 22 with -- 23 COMMISSIONER CASTRO: The bottom line, so 24 I am clear, again, I don' t want them to stay; 25 and you know what, I have never done anything United Reporting, Inc. (954) 525- 2221 Page 35 1 with them or against them. 2 I have kind of -- they sent me emails 3 early on that were just atrocious about what 4 kind of clientele they wanted and didn' t want 5 and who wanted on the pier; and just, at that 6 point, I realized they weren' t the right 7 people, especially for marketing our city and 8 portraying our city for what it is . 9 And I don' t care about that if they ran a 10 successful restaurant, I would be hanging out 11 with them and doing the right thing as far as 12 the honoring the agreement . 13 I think they dishonored the agreement 14 every opportunity they had. Just because we 15 cure it now, I don't think it makes a 16 difference going forward, so I don' t think we 17 should have to do business with them anymore . 18 So, if anything comes up with any more 19 settlement framework, if you are looking for 20 votes, I am not voting for that . I want them 21 gone, out, go do whatever they want . I want 22 the pier and the restaurant back and whatever 23 happens . 24 COMMISSIONER McELYEA: I have heard 25 nothing but bad news from the Mayor and United Reporting, Inc. (954) 525- 2221 Page 36 1 commissioners and from other tenants and 2 employees, as well . I know the employee you 3 are speaking about . She has been around a 4 long time . 5 CITY ATTORNEY ANSBRO: And I can' t use 6 her. 7 COMMISSIONER McELYEA: I know you can' t. 8 Also, I have been in the towing business 9 for 50-some years and I have never towed a 10 car, to my knowledge, from the pier. The 11 company -- he has had three companies in 12 there . He gets $20 . From each one of them, 13 he gets the $20 . The tow truck runs Aboy and 14 Chief. That ' s two that I know of. 15 CITY ATTORNEY ANSBRO: This came up 16 recently when we had the deposition -- I 17 forget who it was; but Colin had found out 18 they are closed on Monday all day, and Colin 19 said, you know what, they are towing on Monday 20 when there is nobody there . 21 I said, let ' s bring it up at a deposition 22 and see if they stop. 23 We brought it up, and Elizabeth says, are 24 you saying we should let people park there for 25 free? United Reporting, Inc. (954) 525- 2221 Page 37 1 I went, don' t say another word. That ' s 2 it . That ' s just what I want to paint for the 3 jury. It ' s a dog in a manger, okay, you are 4 closed and you are towing people when you are 5 closed. 6 COMMISSIONER CASTRO: That ' s because they 7 are getting 20 bucks a car. 8 CITY ATTORNEY ANSBRO: These guys are 9 telling me, don' t get angry. I am angry at 10 these people because I am the one -- 11 COMMISSIONER McELYEA: Or you pay $5 and 12 park all day with a slip from them. 13 CITY ATTORNEY ANSBRO: It ' s just the 14 betrayal of it all . 15 MAYOR FLURY: Tom, the -- this issue of a 16 first-class restaurant, I think it ' s very 17 important that we elaborate on why the 18 first-class restaurant is there . I mean, this 19 was designed to be a destination place for our 20 City. You know that whole story, so I -- 21 CITY ATTORNEY ANSBRO: I think -- you are 22 probably the one I am going to want up there 23 to say that because you are the one that 24 really was the catalyst to try to get it done . 25 He was nervous about it, but you said, we can United Reporting, Inc. (954) 525- 2221 Page 38 1 do this and we can do it right. 2 And we did want a two-storey restaurant 3 there . That was the deal . We worked really 4 hard; nice, fine dining at night and a casual 5 place in the daytime . 6 I remember sitting in a Planning and 7 Zoning Board meeting where one board member 8 said, I don' t think it can support two 9 storeys; it will compromise the structure . 10 I thought, oh, my God, what if that ' s 11 true . 12 And I got Ken Cook, the building official 13 at that time, to run the research. I think we 14 determined it would cost us another 500, 000, 15 and even if we could do it, even if we could 16 permit it, it wouldn' t hold. 17 MAYOR FLURY: The pier wouldn' t hold it . 18 The pier, as it existed today, would not hold 19 a two-storey structure . 20 CITY ATTORNEY ANSBRO: Correct . So, then 21 the thing was, we told them that, they were 22 notified of it . What do they do? Do they 23 seek reformation? 24 MAYOR FLURY: Well, they won' t sign the L. 25 lease or whatever. United Reporting, Inc. (954) 525- 2221 Page 39 1 CITY ATTORNEY ANSBRO: No, the lease was 2 signed. Don' t forget, that' s odd. The lease 3 was signed. Ivan brought it to us before we 4 even knew what we were doing. They signed the 5 lease and took the old Tarpon Bend lease that 6 I brought and made very few changes, didn't 7 use a lawyer. g I kept saying, you should really get a 9 lawyer to read your side of this thing. 10 We don' t need no stinking lawyer. 11 So, they didn't use a lawyer, and three 12 years later, a year and a half later, we begin 13 the design and are like, wow, you can' t do two 14 storeys . 15 They knew about it, and we have to show 16 that they knew about it, and they participated 17 in the design of the structure . They were 18 there for every meeting when the kitchen is 19 being designed. 20 Now, here they are trying to say, you 21 lied to us, you committed fraud, you induced 22 us into this; and here they are lying about 23 the property taxes . They paid the taxes for 24 the last two years and now they are not paying 25 this year. I am done with them. United Reporting, Inc. (954) 525- 2221 Page 40 1 MAYOR FLURY: Why do you think they 2 cancelled our deposition? 3 CITY ATTORNEY ANSBRO: We don't know. I 4 think they want to resume Walter' s, but they 5 haven' t talked about you. I don' t know if 6 they are saving expenses or what . 7 COMMISSIONER CASTRO: They didn' t call 8 me . 9 MAYOR FLURY: Generally consensus here, 10 if I am reading everybody right, is that we 11 want to proceed; is that correct? 12 COMMISSIONER CASTRO: Yes . 13 MAYOR FLURY: This is what it ' s all 14 about . 15 COMMISSIONER DUKE : It sounds like our 16 only option. 17 CITY ATTORNEY ANSBRO: I do want to point 18 out, Walter brought it up and it is extremely 19 important to know, that we have $105, 000 in 20 this today, plus more that has to be billed, 21 and it ' s going to be very costly to take this 22 out to jury trial . It could be another month 23 and a half to do it . I don' t like it, but now 24 we are in it to win it . 25 COMMISSIONER CASTRO: The alternative is United Reporting, Inc. (954) 525- 2221 Page 41 1 $5 million, so, I mean, what are you -- 2 CITY ATTORNEY ANSBRO: Yeah, like Abbott 3 said, what ' s that movie "I want 6 million" -- 4 you can see him doing that . How stupid. 5 COMMISSIONER CASTRO: Just real quick, 6 too, so you all know, they wrote a letter to 7 the company I work for. Their allegation was 8 that I somehow interfered with their credit 9 relationship with my company, which I have 10 nothing to do with, don' t even have access to 11 the system. If you can use that in any way -- 12 I actually told our counsel, you know, as 13 a public figure, I know there is a higher 14 level for defamation and slander; but they are 15 coming at me in my personal environment now. 16 If we can use that in any way, I am happy to 17 do that, because it obviously ticked me off. 18 There is no basis for it . It is easy to 19 prove, anything, you know. So, if that works 20 for you, let me know. Y' 21 MR. ABBOTT : Do you have a copy of that 22 letter? 23 COMMISSIONER CASTRO: No. 24 Counsel would have a copy of that, but 25 you know counsel for the company, I believe, Imm 777 United Reporting, Inc. (954) 525- 2221 Page 42 1 Larry Joplin (phonetic) . He called me to ask 2 me about it, and he was laughing; but he wrote 3 them a nice letter back saying he will take it 4 under serious advisement and research it or 5 investigate it or get back to it and the 6 Southern Wine takes these things seriously, 7 blah, blah, blah -- and they do. They take 8 them very seriously, but at the same time, it 9 was just bogus . 10 MR. ABBOTT : I ' ll find it . Thank you. 11 CITY ATTORNEY ANSBRO: I haven' t heard 12 back from them whether or not we can do this, 13 but I asked the other fellow working with you, 14 if we can get some of these people who have 15 written these reviews and are so angry, I want 16 them on the stand. I want to trot twenty 17 people up there for five minutes : Tell me 18 about your experience there . 19 People know what it is like to have a 20 crap time in a restaurant . They know how 21 angry it is, and the last thing I saw was four 22 entries in March, alone, on Trip Advisor, 23 where they say, you' ll know from the day you 24 walk up to the door -- just like he said, you 25 walk up to the door, here are the rules of United Reporting, Inc. (954) 525- 2221 Page 43 1 what you will do. They warn you. 2 The man will walk you in. It doesn' t 3 matter where you want to sit; they will tell 4 you where you are going to sit. If you say, I 5 am here for a glass of wine, he goes like this 6 (indicating) and walks you over to the bar, if 7 they even let you do that. 8 We have a case, a young woman came up and 9 her little daughter had to go to the bathroom: 10 Can she use the bathroom? 11 No, she can' t . Go down there . 12 She has to go right now. 13 No, she can' t. 14 I want that woman on the stand. Anybody 15 who sits in the jury box with a kid that has 16 to go to the bathroom, paint the picture, you 17 know. They are nasty. 18 MAYOR FLURY: Okay. We know they are 19 nasty. I mean, is the direction -- you know, 20 they are here for direction. 21 CITY ATTORNEY ANSBRO: Well, what I am 22 telling you is -- F 23 MAYOR FLURY: Calm down, Tom. Calm down. 24 COMMISSIONER CASTRO: Breathe . 25 CITY ATTORNEY ANSBRO: I know. United Reporting, Inc. (954) 525- 2221 Page 44 1 MAYOR FLURY: Mac, are you okay going 2 forward? 3 COMMISSIONER McELYEA: I go for broke . 4 MAYOR FLURY: Anne? 5 COMMISSIONER CASTRO: I am with Mac. 6 COMMISSIONER DUKE: Me, too. 7 MAYOR FLURY: Bobbie hadn' t heard it, but 8 we went to mediation -- 9 VICE MAYOR GRACE : I know what it is all 10 about . 11 CITY ATTORNEY ANSBRO: Okay. Well, the 12 mediation was -- their demand was, you pay us 13 $6 million and we will go away. I don' t know 14 where that came from -- 15 COMMISSIONER McELYEA: 60 cents . 16 MAYOR FLURY: Okay. Anything else you 17 need from us? 18 MR. ABBOTT : No, ma ' am, I think that was 19 very clear. Thank you for your time . 20 MAYOR FLURY: We thank you. Good luck. 21 COMMISSIONER CASTRO: Thank you, 22 gentlemen. 23 (Whereupon, the proceedings were temporarily 24 adjourned and relocated to the City Commission Meeting 25 Room, where they were reopened and proceeded as United Reporting, Inc. (954) 525- 2221 Page 45 1 follows : ) 2 MAYOR FLURY: I will now re-open the 3 public meeting. 4 The attorney-client session was 5 terminated, and members of the general public 6 are now invited to return for further 7 proceedings or matters . Thank you. 8 CITY ATTORNEY ANSBRO: We just had an 9 executive session on the Beach Watch pier 10 restaurant, and it was with regard to the law, 11 a private session. We are going to take a 12 15-minute break, and we will come back for the 13 regular commission meeting. 14 (Whereupon, the proceeding was concluded at 15 6 : 51 p.m. ) 16 17 18 19 20 21 22 23 24 25 United Reporting, Inc. (954) 525- 2221 Page 46 1 2 C E R T I F I C A T E 3 4 THE STATE OF FLORIDA) COUNTY OF BROWARD) 5 6 7 I, EMILY SCOTT, certify that I was 8 authorized to and did stenographically report the 9 foregoing proceedings and that the transcript is a 10 true and complete record of my stenographic notes . 11 Dated this 1st day of June, 2011 . F 12 13 14 15 16 EMILY SCOTT 17 18 19 20 21 22 23 24 25 United Reporting, Inc. (954) 525-2221 Page 47 A alleges 7:15 attention 10:23 belts 33:25 called 34:15 42:1 Abbott 2:9 4:15 Allegria 1:16 4:7 attorney 2:8 3:15 Ben 1:13 4:6 calling 3:3 5:18,19,23 6:3,6 6:7,13 7:15,19 3:16 4:14 5:13,16 Bend 39:5 calls 7:23 31:15 6:25 9:19 17:1 13:1,22 17:5,11 5:24 6:4 8:17,18 best 20:20 33:15 Calm 43:23,23 20:23 21:2,15 18:5 19:3,21 14:10,14 16:2,5,7 betrayal 37:14 cancellation 17:8 22:4,9 23:7 25:21 Allegria's 11:24 16:10,16,17 19:3 better 34:16 cancelled 40:2 26:9 27:1,6,9 30:13 19:15 21:1,3,8 big 14:23 17:13 candidly 20:15 28:11 30:9 41:2 allow 12:17 22:3,5,20 23:5,19 19:1 32:1 car 36:10 37:7 41:21 42:10 44:18 allowed 12:16 25:17 27:11 28:24 billed 40:20 care 16:14 35:9 abide 13:21 alternative 40:25 29:15,18,25 30:18 bit 8:19 13:9 career 15:10 able 22:13 amend 10:25 33:14 34:7,21 black 33:24 cars 29:10 Aboy 36:13 amended 10:1 36:5,15 37:8,13 blah 42:7,7,7 case 3:24 7:9 9:13 AC 34:4 amount 13:11 17:5 37:21 38:20 39:1 blowback34:8 11:5 13:16 14:9 accept 23:16 17:7,12 40:3,17 41:2 Blvd 1:22 20:7,14 21:10 acceptable 19:16,18 angry 37:9,9 42:15 42:11 43:21,25 board 38:7,7 26:1,7 29:3 30:17 accepted 16:11 42:21 44:11 45:8 boat 29:20 43:8 access 4 1:10 Anne 2:4 4:12 44:4 attorney-client 3:20 Bob 5:14 cashiers 27:15 accountant 17:10 Ansbro 2:8 3:15,16 45:4 Bobbie 2:3 5:3 44:7 Castro 2:4 3:7,8 accountants 11:24 4:14 5:13,16,24 Attorney/Client bogus 42:9 4:12 15:23 16:3,6 action 8:9,10 12:24 6:4 8:18 14:10,14 1:19 4:22 bottom 34:23 16:8,14 25:18,24 s 13:6 16:15 16:2,5,7,10,17 audit 27:4,5 28:20 bought 22:25 29:20 27:4,7,10,23 actions 11:25 21:1,3,8 22:3,5,20 authorized 46:8 box 34:2 43:15 28:12 29:14,17,21 actors 16:20 23:5,19 25:17 Avenue 1:24 brand-new 21:18 30:2 32:6 34:5,19 actual 8:1 27:11 28:24 29:15 aware 27:1 22:23 25:6 34:23 37:6 40:7 addition 19:9 29:18,25 30:18 awful 24:24 breach 6:21 7:11 40:12,25 41:5,23 additional 10:2 33:14 34:7,21 awfully 17:13 18:21 10:11 13:8 43:24 44:5,21 adequately 33:8 36:5,15 37:8,13 a/k/a 1:13 breached 10:20 casual 38:4 adjourn 4:21 37:21 38:20 39:1 12:13 13:1 18:15 catalyst 8:20,24 adjourned 5:9 40:3,17 41:2 B breaches 10:2 37:24 44:24 42:11 43:21,25 back 5:25 6:11 9:15 break 45:12 Caylee 29:3 admission 6:10 10:6 44:11 45:8 13:21 15:2 24:25 Breathe 43:24 ceiling 22:19 advance 8:23 answer 20:18,20 25:8 35:22 42:3,5 breathed 24:20 cents 44:15 adverse12:11 Anthony 29:3 42:12 45:12 brief 18:24 certain 10:7 11:25 adversely 8:16 Anybody 43:14 bad 16:20 29:4,12 briefcase 15:4 12:6 23:24 advisement 42:4 anymore 23:22 34:9 35:25 bring 24:8 36:21 certainly 27:3 Advisor 42:22 35:17 bait 6:9 26:16 30:22 broke 9:9 44:3 certified 4:18 Advisors 25:1 apparently 34:11 33:2,3 34:12 brought 30:15 certify 46:7 agitated 15:3 APPEARANCES Baldwin 2:7 3:13 36:23 39:3,6 chance 12:10,20 ago 11:4 12:5 24:4 2:1 3:14 4:16 5:14 40:18 13:20 14:5 agree 17:7 approval 8:23 9:22 6:23 Broward 3:24 46:4 chances 13:18 agreement 8:1 approve 19:11 bar 43:6 BSO 31:12 change 31:17 33:23 13:22 35:12,13 24:12 bargain 33:9 bucks 37:7 34:3,4 ahead 16:23 approximately 4:10 bartenders 27:16 building 7:4,13 changed 14:1 20:10 air-conditioning area 17:21 based 17:16 18:3 13:14 38:12 20:13 7:14 11:12,14 areas 11:11 basis 9:20 13:6 build-out 13:12,14 changes 39:6 12:15 21:17,17,20 arguments 18:21 41:18 22:2,5,11 character 30:3 33:12,22 asked 15:12 19:17 bathroom 32:21 built 7:2,13 check 19:2 33:1 alarm 7:15 33:16 42:13 43:9,10,16 business 4:8 8:16 Chief 36:14 33:17,19 asking 18:19 Bea 24:2 17:22 18:6,6 Circuit 3:22,23 allegation 41:7 assign 19:10 Beach 1:1,5,9,16,22 35:17 36:8 city 1:1,5,9 2:7,8 allegations 8:13 assigned 8:22 1:22 4:2,4,8 6:9 buttons 28:13 3:5,7,9,11,13,13 allege 6:21 7:11 assume 17:22 18:13 15:16 45:9 3:14,15,15,16,17 10:1 12:3 27:8 28:9,12 bear 14:24 C 4:1,3,14,16,23 5:5 v alleged 9:21 10:11 33:11 beautifully 33:18 C 46:2,2 5:9,13,16,24 6:4 11:13 atrocious 35:3 began 6:12 30:22 calendar 10:22 6:18,23 7:4 8:14 allegedly 13:13 attacked 15:17 believe 18:19 22:15 call 3:4 23:10,21 8:18,23 11:25 attendance 4:11 28:5 41:25 28:9 40:7 12:12 14:10,14 United Reporting, Inc. 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