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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