HomeMy WebLinkAboutInv# 57155 - 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: Tom Ansbro
100 W. Dania Beach Blvd.
Dania Beach, FL 33004
CLIENT:Summit Risk Services SUMMIT
MATTER:Citizens for Responsible Development v. Dania Beach 12120
Claim #GO-0675; EV2012-208179
BILL FOR FEES AND COSTS THROUGH 03/31/21
April 16, 2021
Bill No. 57155
HoursDateAttorneyServices
PROFESSIONAL SERVICES
03/03/21 Correspondence to John Mullin, Counsel for DEC, and Scott
Andron, Counsel for Broward County, re: Plaintiff's proposed
Motion for Leave to Provide Findings of Fact and Conclusions
of Law.
0.10AGA
03/03/21 Receipt and review of correspondence from John Mullin,
Counsel for DEC, re: Plaintiff's proposed Motion for Leave to
Provide Findings of Fact and Conclusions of Law.
0.10AGA
03/03/21 Correspondence to Tom Ansbro, City Attorney for City of Dania
Beach, re: Plaintiff's proposed Motion for Leave to Provide
Findings of Fact and Conclusions of Law and inquiring if they
are in agreement to object to same.
0.10AGA
03/03/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: advising the City is
agreement to object to Plaintiff's proposed Motion for Leave to
Provide Findings of Fact and Conclusions of Law.
0.10AGA
03/03/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: proposed Motion for Leave to Provide
Findings of Fact and Conclusions of Law for review.
0.20AGA
03/03/21 Receipt and review of correspondence from John Mullin,
Counsel for DEC, to Michael Dutko, Counsel for Plaintiff, re:
proposed Motion for Leave to Provide Findings of Fact and
Conclusions of Law.
0.10AGA
03/03/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, to John Mullin, Counsel for DEC, re:
proposed Motion for Leave to Provide Findings of Fact and
Conclusions of Law and advising this will may affect them going
forward for a case management conference.
0.20AGA
Summit Risk Services
Matter: 12120 - Citizens for Responsible Development v. Dania Beach Page 2
April 16, 2021Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
03/03/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re:
advising the City objects to the proposed Motion for Leave to
Provide Findings of Fact and Conclusions of Law.
0.10AGA
03/03/21 Receipt and review of correspondence from Scott Andron,
Counsel for Broward County, to Michael Dutko, Counsel for
Plaintiff, re: advising they object to the proposed Motion for
Leave to Provide Findings of Fact and Conclusions of Law.
0.10AGA
03/03/21 Receipt and review of Plaintiff's Motion for Leave to Provide
Proposed Findings of Fact and Conclusions of Law.
0.40AGA
03/03/21 Preparation of correspondence to Tom Anbsro, City Attorney
for City of Dania Beach, re: Plaintiff's Motion for Leave to
Provide Proposed Findings of Fact and Conclusions of Law,
impact on the case, and our recommendations on the same.
0.40AGA
03/03/21 Receipt and review of correspondence from Scott Andron,
Counsel for Broward County, re: inquiring on response to
Plaintiffs' Motion for Leave to Provide Proposed Findings of
Fact and Conclusions of Law.
0.10AGA
03/03/21 Correspondence to Scott Andron, Counsel for Broward County,
re: advising we will be responding Plaintiffs' Motion for Leave to
Provide Proposed Findings of Fact and Conclusions of Law.
0.10AGA
03/03/21 Receipt and review of correspondence from John Mullin,
Counsel for DEC, to Scott Andron, Counsel for Broward
County, re: response to Plaintiffs' Motion for Leave to Provide
Proposed Findings of Fact and Conclusions of Law.
0.10AGA
03/03/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re:
Plaintiff's Motion for Leave to Provide Findings of Fact and
Conclusions of Law erroneously states City's position.
0.10AGA
03/03/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: revising the language pertaining to
City's position on Plaintiff's Motion for Leave to Provide
Findings of Fact and Conclusions of Law.
0.10AGA
03/04/21 Receipt and review of Plaintiffs' Amended Motion for Leave to
Provide Proposed Findings of Fact and Conclusions of Law.
0.20AGA
03/04/21 Preparation of City’s Response in Opposition to Plaintiffs’
Amended Motion for Leave to File Proposed Findings of Fact
and Conclusions of Law.
1.50AGA
03/04/21 Review/Analyze detailed analysis of file materials including
Plaintiffs’ Motion for Leave to File Proposed Findings of Fact
and Conclusions of Law filed on 3/3/21 and Plaintiffs’ Amended
Motion filed 3/4/21 in preparation of City’s Response in
Opposition.
0.50AGA
03/04/21 Correspondence to Tom Ansbro, City Attorney for City of Dania
Beach, re: draft response in opposition to Plaintiffs’ Motion for
Leave to File Proposed Findings of Fact and Conclusions of
Law.
0.10AGA
Summit Risk Services
Matter: 12120 - Citizens for Responsible Development v. Dania Beach Page 3
April 16, 2021Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
03/04/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: approval of draft response
in opposition to Plaintiffs’ Motion for Leave to File Proposed
Findings of Fact and Conclusions of Law.
0.10AGA
03/05/21 Preparation of emails correspondence to Tom Ansbro, City of
Dania Beach, re: Response to Plaintiffs’ Motion for Leave to
Provide Findings of Fact and Conclusions of Law.
0.40AGA
03/05/21 Preparation of multiple emails to Scott Andron, Broward City
Attorney, and John Mullin, Counsel for Dania Entertainment re:
revisions to Defendant's Response in Opposition to Plaintiffs'
Amended Motion for Leave to Provide Proposed Findings of
Fact and Conlusions of Law
0.80AGA
03/05/21 Receipt and review of multiple emails from Scott Andron,
Broward City Attorney, and John Mullin, Counsel for Dania
Entertainment re: revisions to the City of Dania Beach's
Response in Opposition to Plaintiffs' Amended Motion for Leave
to Provide Proposed Findings of Fact and Conlusions of Law
0.70AGA
03/08/21 Receipt and review of Court's Executed Order on all parties
Motion for Summary Judgement.
0.40AGA
03/08/21 Preparation of correspondence to Tom Ansbro, City Attorney
for City of Dania Beach, re: Court’s Order on Parties’ Cross
Motions for Summary Judgment and Defendants’ Joint
Response in Opposition to Plaintiffs’ Amended Motion for
Leave to Provide Proposed Findings of Fact and Conclusion of
Law.
0.30AGA
03/08/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: Court's Order on Parties'
Motions for Summary Judgment.
0.10AGA
03/08/21 Telephone conference with City Attorney Tom Ansbro regarding
Court’s ruling granting City’s Motion for Summary Judgment,
denying Plaintiffs’ motion for summary judgment, and
answering his questions regarding the same.
0.20AGA
03/08/21 Receipt and review of correspondence from Scott Andron,
Counsel for Broward County, re: draft Final Judgment and
offering any changes needed for the County.
0.10AGA
03/08/21 Receipt and review of correspondence from John Mullin,
Counsel for DEC, to Scott Andron, Counsel for Broward
County, re: draft Final Judgment.
0.10AGA
03/10/21 Preparation of proposed Final Judgment.0.90AGA
03/10/21 Receipt and review of correspondence from John Mullin,
Counsel for DEC, re: proposed draft of the Final Judgment.
0.10AGA
03/10/21 Correspondence to John Mullin, Counsel for DEC, re: advising
the proposed draft of the final judgment is prepared and being
reviewed by the City.
0.10AGA
Summit Risk Services
Matter: 12120 - Citizens for Responsible Development v. Dania Beach Page 4
April 16, 2021Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
03/10/21 Correspondence to John Mullin, Counsel for DEC, and Scott
Andron, Counsel for Broward County, re: draft motion for final
judgment and proposed final judgment for review and input.
0.10AGA
03/10/21 Correspondence to Michele Mellgren, Defense Expert, re:
Order granting Defendants’ motions for summary judgment and
denying Plaintiffs’ motion for summary judgment.
0.10AGA
03/10/21 Telephone conference with Michele Mellgren, Defense Expert,
regarding Court’s Order granting Defendants’ motions for
summary judgment and answering her questions regarding the
same.
0.20AGA
03/10/21 Correspondence to Tom Ansbro, City Attorney for City of Dania
Beach, re: draft motion for final judgment and proposed final
judgment for review and input.
0.10AGA
03/10/21 Receipt and review of correspondence from Eve Boutsis,
Assistant City Attorney for City of Dania Beach, re: approval of
draft motion for final judgment and proposed final judgment.
0.10AGA
03/10/21 Receipt and review of correspondence from John Mullin,
Counsel for DEC, re: inquiring if just the Final Judgment should
be submitted to the court or if the motion should be included
too.
0.10AGA
03/10/21 Correspondence to John Mullin, Counsel for DEC, re: advising
we can submit just the final judgment.
0.10AGA
03/10/21 Receipt and review of correspondence from Scott Andron,
Counsel for Broward County, re: he is agreeable to submit just
the final judgment.
0.10AGA
03/10/21 Receipt and review of correspondence from John Mullin,
Counsel for DEC, re: he is agreeable to submit just the final
judgment.
0.10AGA
03/11/21 Receipt and review of correspondence from John Mullin,
Counsel for DEC, and Scott Andron, Counsel for Broward
County, re: approval of proposed final judgment.
0.10AGA
03/11/21 Receipt and review of City of Dania Beach Code of Ordinances,
deed page.
0.20AGA
03/11/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: City of Dania Beach Code
of Ordinances, deed page.
0.10AGA
03/11/21 Receipt and review of Invoice for $31.25 from expert, Michele
Mellgren.
0.10AGA
03/11/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: approval of draft motion
for final judgment and proposed final judgment.
0.10AGA
03/11/21 Correspondence to Tom Ansbro, City of Dania Beach, re: only
submitting proposed Final Judgment to court and holding off on
filing motion.
0.10AGA
Summit Risk Services
Matter: 12120 - Citizens for Responsible Development v. Dania Beach Page 5
April 16, 2021Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
03/11/21 Receipt and review of correspondence from Tom Ansbro, City
of Dania Beach, re: approval on only submitting proposed Final
Judgment to court and holding off on filing motion.
0.10AGA
03/11/21 Correspondence to Tom Ansbro, City Attorney for City of Dania
Beach, re: invoice for payment from defense expert Michele
Mellgren.
0.10AGA
03/11/21 Correspondence to John Mullin, Counsel for DEC, and Scott
Andron, Counsel for Broward County, re: proposed Final
Judgment and hold off on filing the motion.
0.10AGA
03/11/21 Receipt and review of correspondence from John Mullin,
Counsel for DEC, and Scott Andron, Counsel for Broward
County, re: approval of proposed Final Judgment and hold off
on filing the motion.
0.10AGA
03/12/21 Receipt and review of Court's Executed Final Judgment.0.20AGA
03/12/21 Preparation of correspondence to Tom Ansbro, City Attorney
for City of Dania Beach, re: Final Judgment executed by the
Court.
0.20AGA
03/12/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: Final Judgment executed
by the Court.
0.10AGA
03/15/21 Receipt and review of correspondence from Michele Mellgren,
Defense Expert, re: final invoices for payment.
0.10AGA
03/24/21 Receipt and review of Co-Defendant DEC's Motion to Tax
Costs.
0.20AGA
03/25/21 Correspondence to Tom Ansbro, City Attorney for City of Dania
Beach, re: payment for the deposition of Ralph Aronberg.
0.10AGA
03/25/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: payment for the deposition
of Ralph Aronberg.
0.10AGA
03/25/21 Preparation of Affidavit of Andrea Amigo in Support of
Defendant, City of Dania Beach's Motion to Tax Costs.
0.90AGA
03/25/21 Research Florida cases, statutes, Rules of Civil Procedure, and
Guidelines for Taxation of Costs in preparation of City’s Motion
to Tax Costs.
1.60AGA
03/26/21 Preparation of correspondence to Tom Ansbro, City Attorney
for City of Dania Beach, re: Motion to Tax Costs and Affidavit of
Andrea Amigo in Support of the Motion to Tax Costs and
Co-Defendant, Dania Entertainment Center’s LLC, (DEC)
Motion to Tax Costs.
0.30AGA
03/26/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney for City of Dania Beach, re: approval of Motion to Tax
Costs and Affidavit of Andrea Amigo in Support of the Motion to
Tax Costs for submission to the court.
0.20AGA
03/26/21 Preparation of City’s Motion to Tax Costs.0.90AGA
Summit Risk Services
Matter: 12120 - Citizens for Responsible Development v. Dania Beach Page 6
April 16, 2021Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
03/30/21 Receipt and review of correspondence from John Mullin,
Counsel for DEC, to Michael Dutko, Counsel for Plaintiff, re:
pending motions to tax costs.
0.10AGA
03/30/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, to John Mullin, Counsel for DEC, re:
pending motions to tax costs.
0.10AGA
03/30/21 Receipt and review of correspondence from Scott Andron,
Counsel for Broward County, to Michael Dutko, Counsel for
Plaintiff, and John Mullin, Counsel for DEC, re: pending
motions to tax costs.
0.10AGA
Code AmountHoursRateName
PROFESSIONAL SERVICES SUMMARY
2,934.00180.0016.30AGAAndrea G. Amigo, Partner
Total Professional Services $2,934.0016.30
Date AmountDescription
DISBURSEMENTS
1,425.00Expert Witness Fees #0021642;Expert services January -
SEPI Engineering & Construction, Inc.
03/19/21
1,006.25Expert Witness Fees #0021856;Expert services February -
SEPI Engineering & Construction, Inc.
03/19/21
50.00Expert Witness Fees #0022020;Expert services March -
SEPI Engineering & Construction, Inc.
03/19/21
Total Disbursements $2,481.25
400,347.00
436,292.39
35,945.39
Fees Billed to Date
Costs Billed to Date
Total Billed to Date
Bill History for this Matter
Case to DateYear to Date
43,616.50
13,203.25
56,819.75
CURRENT BILL TOTAL AMOUNT DUE $5,415.25
Balance Forward:
Payments & Adjustments:-4,243.25
4,243.25
5,415.25Total Due:$
Please return this page with remittance
to
Roberts, Reynolds, Bedard & Tuzzio, PLLC
470 Columbia Drive, Suite C-101
West Palm Beach, Florida 33409
57155Bill Number:
Client Code:SUMMIT
Client Name:Summit Risk Services
Bill Date:April 16, 2021
12120
Citizens for Responsible Development v. Dania Beach
Matter Code:
Matter Name:
CURRENT BILL TOTAL AMOUNT DUE $5,415.25
0.00Past Due Balance
TOTAL AMOUNT DUE
$5,415.25
Balance Forward:
Payments & Adjustments:-4,243.25
4,243.25
5,415.25Total Due:$
Total Professional Services
Total Disbursements 2,481.25
2,934.00