HomeMy WebLinkAboutInv# 57146 - ROBERTS, REYNOLDS, BEDARD & TUZZIO, PLLC - 04/16/2021ROBERTS, REYNOLDS, BEDARD & TUZZIO, PLLC
470 Columbia Drive, Suite C-101
West Palm Beach, Florida 33409
Telephone (561)688-6560
Tax ID No. 65-0004867
City of Dania Beach
Attn: Lori Adams
100 W. Dania Beach Blvd.
Dania Beach, FL 33004
CLIENT:Preferred Governmental Insurance Trust 155
MATTER:Citizens (2) v. Dania Beach/Mayor Duke 14358
PGCS Claim # 215157
BILL FOR FEES AND COSTS THROUGH 03/31/21
April 16, 2021
Bill No. 57146
HoursDateAttorneyServices
PROFESSIONAL SERVICES
02/22/21 Preparation of correspondence to Tom Ansbro, City Attorney
for City of Dania Beach, re: Court Order scheduling Case
Management Conference.
0.20AGA
03/15/21 Plan and Prepare for upcoming Case Management Conference
scheduled for March 16, 2021 before Judge Towbin Singer via
Zoom.
0.90SHP
03/16/21 Receipt and review of Court's Trial Order.0.20AGA
03/16/21 Preparation of correspondence to Tom Ansbro, City Attorney
for City of Dania Beach, re: outcome of Court Ordered Case
Management Conference before Judge Towbin Singer.
0.30SHP
03/17/21 Attendance at mandatory Case Management Conference
before Judge Towbin Singer via Zoom.
1.30SHP
03/18/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: approval to move forward
to file Motion for Extension of Time.
0.20LHR
03/22/21 Correspondence to all counsel, re: the depostitions of Jessica
Kopas and Herbert Simpson.
0.20AGA
03/23/21 Draft/Revise revisions to proposed Joint Motion to Extend
Deadlines prepared by Plaintiff's Counsel.
0.40AGA
03/23/21 Correspondence to Kyle Roberts, Counsel for Plaintiff, re:
status of draft the joint motion to extend deadlines.
0.20AGA
03/23/21 Receipt and review of correspondence from Kyle Roberts,
Counsel for Plaintiff, re draft of the joint motion to extend
deadlines for review and input.
0.10AGA
03/23/21 Correspondence to Kyle Roberts, Counsel for Plaintiff, re:
proposed revisions to draft of the joint motion to extend
deadlines.
0.20AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 2
April 16, 2021Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
03/23/21 Correspondence to Kyle Roberts, Counsel for Plaintiff, re:
inquiring on proposed mediators for upcoming mediation.
0.10AGA
03/23/21 Correspondence to Tom Ansbro, City Attorney for City of Dania
Beach, re: upcoming mediation conference deadline and
authorization to proceed with recommended Mediator, Rodney
Romano.
0.10AGA
03/23/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: approval of proposed and
recommended Mediator, Rodney Romano.
0.10AGA
03/23/21 Correspondence to Tom Ansbro, City Attorney for City of Dania
Beach, re: advising we also have the option to propose Charles
Tetunic for proposed mediatior, and inquiring on authorization
for same.
0.10AGA
03/23/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: approval to also proceed
to use Charles Tetunic for proposed mediatior.
0.10AGA
03/23/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: depositions of Jessica Kopas and
Herbert Simpson.
0.20AGA
03/24/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re:
Judge Singhal’s prior order on the motion to quash, and
depositions of Jessica Kopas and Herbert Simpson.
0.20AGA
03/25/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: objecting to the deposition of Jessica
Kopas and advising the deposition of Herbert Simpson must be
made in via Zoom conference.
0.20AGA
03/25/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: deposition of Herbert Simpson.
0.20AGA
03/25/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re:
finalizing deposition of Herbert Simpson.
0.20AGA
03/25/21 Correspondence to Kyle Roberts, Counsel for Plaintiff, re:
status of proposed Joint Motion to Extend Deadlines.
0.10AGA
03/25/21 Receipt and review of correspondence from Kyle Roberts,
Counsel for Plaintiff, re: advising and approving proposed Joint
Motion to Extend Deadlines.
0.10AGA
03/25/21 Preparation of correspondence to Tom Ansbro, City Attorney
for City of Dania Beach, re: Joint Motion to Extend Deadlines
and inquiring on upcoming Mediation.
0.30AGA
03/26/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: dates available for
mediation conference.
0.10AGA
03/26/21 Preparation of Notice of Appearance for Andrea Amigo to
represent the City of Dania Beach.
0.30AGA
03/26/21 Preparation of Notice of Taking Deposition Duces Tecum of
Herbert Simpson.
0.60AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 3
April 16, 2021Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
03/26/21 Correspondence to Kyle Roberts, Counsel for Plaintiff, re:
inquiring on dates available for mediation.
0.20AGA
03/26/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re:
inquiring on submitting a proposed Order on the Joint Motion to
Extend Deadlines or set this on the Court’s calendar.
0.20AGA
03/26/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: advising they are preparing a proposed
Order on the Joint Motion to Extend Deadlines or set this on the
Court’s calendar.
0.20AGA
03/26/21 Correspondence to Tom Ansbro, City Attorney for City of Dania
Beach, re: deadline for disclosure of experts.
0.20AGA
03/26/21 Review litigation file, including pleadings, motions, items of
correspondence, and other relevant file material
received/exchanged to date in preparation for drafting
Defendant, City's, Motion to Compel the Deposition of Attorney
Kopas or, Alternatively, to Disqualify Attorney Kopas as counsel
of record.
0.90SHP
03/26/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: advising they will be preparing a
proposed agreed order to submit for Motion to Extend
Deadlines.
0.20AGA
03/26/21 Preparation of City of Dania Beach's Witness List.0.90AGA
03/27/21 Research relevant case law and statutory authority to raise and
assert within Defendant, City's, Motion to Compel the
Deposition of Attorney Kopas or, Alternatively, to Disqualify
Attorney Kopas as counsel of record.
1.00SHP
03/28/21 Draft/Revise initial drafting of Defendant, City's, Motion to
Compel the Deposition of Attorney Kopas or, Alternatively, to
Disqualify Attorney Kopas as counsel of record.
2.30SHP
03/29/21 Preparation of Request to Produce directed to Plaintiff.0.90AGA
03/29/21 Preparation of First set of Interrogatories directed to Plaintiff.0.90AGA
03/29/21 Receipt and review of Notice of Withdrawal from Case by Albert
Frevola, Esq.
0.20AGA
03/29/21 Telephone conference with Paula Giordano regarding notices
sent in 2014 by Calvin Giordano & Associates of the hearings in
2014 on the amendments to the development agreement
between City of Dania Beach and DEC.
0.20AGA
03/29/21 Correspondence to Mr. Holden, CGA Solutions, re: inquiring on
notices of intent for consideration of the development
agreements in 2014.
0.20AGA
03/29/21 Draft/Revise revisions to Plaintiff counsel’s initial draft of
proposed Order on Joint Motion to Extend Deadlines.
0.30AGA
03/29/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: initial draft of proposed Order on Joint
Motion to Extend Deadlines.
0.20AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 4
April 16, 2021Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
03/29/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re:
following up on the proposed Order on the Joint Motion to
Extend Deadlines or set this on the Court’s calendar.
0.10AGA
03/29/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: advising they are preparing the
proposed Order on the Joint Motion to Extend Deadlines or set
this on the Court’s calendar for review.
0.10AGA
03/29/21 Correspondence to Tom Ansbro, City Attorney for City of Dania
Beach, re: inquiring on new proposed date for Mediation before
Mediator, Charles Tetunic.
0.10AGA
03/29/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: approval of new proposed
date for Mediation before Mediator, Charles Tetunic.
0.10AGA
03/29/21 Receipt and review of Court's Executed Order Granting the
Joint Motion to Extend Deadlines.
0.20AGA
03/29/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: the proposed order granting the Joint
Motion to Extend Deadlines for review and input.
0.20AGA
03/29/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re:
minor revisions to the proposed order granting the Joint Motion
to Extend Deadlines.
0.20AGA
03/29/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: witness disclosure date on agreed
order to submit for Motion to Extend Deadlines.
0.10AGA
03/29/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re:
witness disclosure date on agreed order to submit for Motion to
Extend Deadlines.
0.10AGA
03/29/21 Correspondence to Tom Ansbro, City Attorney for City of Dania
Beach, re: proposed witness list and input on same.
0.10AGA
03/29/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: proposed witness list and
PRR contact.
0.10AGA
03/29/21 Correspondence to Tom Ansbro, City Attorney for City of Dania
Beach, re: proposed witness list and dates provided for PRR
contact.
0.10AGA
03/29/21 Correspondence to Tom Ansbro, City Attorney for City of Dania
Beach, re: advising we can add Judy Felicetty and Erika
Clayton to the proposed witness list.
0.10AGA
03/29/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: advising to add Judy
Felicetty to the proposed witness list.
0.10AGA
03/29/21 Correspondence to Kyle Roberts, Counsel for Plaintiff, re:
second correspondence related to Mediation before Charles
Tetunic.
0.20AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 5
April 16, 2021Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
03/29/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re:advising they are open for Mediation on
April 29, 2021 but need to check with their client.
0.20AGA
03/30/21 Correspondence to Tom Ansbro, City Attorney for City of Dania
Beach, re: final revised witness list for review and input.
0.10AGA
03/30/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: agreement and approval
of final revised witness list.
0.10AGA
03/30/21 Correspondence to Tom Ansbro, City Attorney for City of Dania
Beach, re: inquiring on John Marion as proposed Mediator and
new proposed dates for same.
0.10AGA
03/30/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: inquiring on John Marion
as proposed Mediator and new proposed dates for same.
0.10AGA
03/30/21 Communicate/Other External correspondence to Mr. Holden,
re: second correspondence re notices of intent for
consideration of the development agreements in 2014.
0.10AGA
03/30/21 Preparation of correspondence to Tom Ansbro, City Attorney
for City of Dania Beach, re: Court’s Executed Order Granting
the parties’ Joint Motion to Extend Deadlines.
0.20AGA
03/30/21 Receipt and review of Plaintiff's Witness List.0.20AGA
03/30/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re:advising their client and themselves are
avaialble for Mediation on April 29, 2021.
0.10AGA
03/30/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re:
advising original Mediator, Charles Tetunic, is no longer
available for Mediation and proposing John Marion as new
proposed Mediator.
0.20AGA
03/31/21 Preparation of correspondence to Tom Ansbro, City Attorney
for City of Dania Beach, re: Plaintiff's Witness List.
0.20AGA
Code AmountHoursRateName
PROFESSIONAL SERVICES SUMMARY
2,304.00180.0012.80AGAAndrea G. Amigo, Partner
36.00180.000.20LHRLyman H. Reynolds, Jr., Partner
971.50145.006.70SHPSara H. Ptachik, Associate
Total Professional Services $3,311.5019.70
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 6
April 16, 2021Client:
89,049.50
91,858.09
2,808.59
Fees Billed to Date
Costs Billed to Date
Total Billed to Date
Bill History for this Matter
Case to DateYear to Date
3,311.50
0.00
3,311.50
CURRENT BILL TOTAL AMOUNT DUE $3,311.50
Balance Forward:
Payments & Adjustments:-54.00
54.00
3,311.50Total Due:$
Please return this page with remittance
to
Roberts, Reynolds, Bedard & Tuzzio, PLLC
470 Columbia Drive, Suite C-101
West Palm Beach, Florida 33409
57146Bill Number:
Client Code:155
Client Name:Preferred Governmental Insurance Trust
Bill Date:April 16, 2021
14358
Citizens (2) v. Dania Beach/Mayor Duke
Matter Code:
Matter Name:
CURRENT BILL TOTAL AMOUNT DUE $3,311.50
0.00Past Due Balance
TOTAL AMOUNT DUE
$3,311.50
Balance Forward:
Payments & Adjustments:-54.00
54.00
3,311.50Total Due:$
Total Professional Services
Total Disbursements 0.00
3,311.50