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HomeMy WebLinkAboutInv# 57588 - ROBERTS, REYNOLDS, BEDARD & TUZZIO, PLLC - 05/17/2021ROBERTS, 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 04/30/21 May 17, 2021 Bill No. 57588 HoursDateAttorneyServices PROFESSIONAL SERVICES 04/01/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re: upcoming mediation with Mediator John Marion. 0.10AGA 04/01/21 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, re: upcoming Mediation with Mediator, John Marion. 0.10AGA 04/01/21 Preparation of master trial checklist in accordance with Order Granting Joint Motion to Extend Deadlines entered by Judge Singer on March 29, 2021. 1.00RKD 04/05/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re: the deposition of William Telli. 0.20AGA 04/05/21 Receipt and review of correspondence from Plaintiff's Counsel, re: the deposition of William Telli. 0.10AGA 04/05/21 Receipt and review of correspondence from Kyle Roberts, Counsel for Plaintiff, re: deposition of Tom Schneider. 0.20AGA 04/06/21 Telephone conference with Marc LaFerrier regarding upcoming trial, his knowledge of the case, and his agreement to be a witness for the City. 0.30AGA 04/06/21 Preparation of Defendant, City of Dania Beach's Amended Witness List. 1.20AGA 04/06/21 Telephone conference with Paula Giordano regarding her knowledge of the public hearing notices on the amendment to the development agreement and confirming her agreement to be a witness for the City at trial. 0.30AGA 04/06/21 Correspondence to Tom Ansbro, and Tom Schneider, City of Dania Beach, re: deposition of Tom Schneider. 0.10AGA Preferred Governmental Insurance Trust Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 2 May 17, 2021Client: HoursDateAttorneyServices PROFESSIONAL SERVICES 04/06/21 Correspondence to Tom Anbsro, City Attorney for City of Dania Beach, re: inquiring on contact information for Walter Duke, Judy Felicetty, and Louise Stilson. 0.10AGA 04/06/21 Receipt and review of correspondence from Tom Ansbro, City Attorney for City of Dania Beach, re: correspondence from CGA, and request to speak with Hoyt Holden. 0.10AGA 04/06/21 Correspondence to Tom Ansbro, City Attorney for City of Dania Beach, re: correspondence from CGA, and request to speak with Hoyt Holden. 0.10AGA 04/06/21 Correspondence to Tom Ansbro, City Attorney for City of Dania Beach, re: inquring on the Declaration of Jessica Kopas. 0.10AGA 04/06/21 Correspondence to Tom Ansbro, City Attorney for City of Dania Beach, re: Amended Witness List for review and input. 0.10AGA 04/06/21 Preparation of Notice of Taking Deposition Duces Tecum of William Telli. 0.40AGA 04/06/21 Telephone conference with former Mayor Walter Duke regarding his knowledge of the public records requests in 2014 and the Plaintiff’s allegations in the 2014 public records lawsuit against the City. 0.30AGA 04/06/21 Telephone conference with Janna Lhota, Esq., counsel for Dania Entertainment Center, LLC, regarding notices of public hearings in 2014 and her knowledge regarding the same. 0.30AGA 04/06/21 Correspondence to second correspondence to Tom Schneider, City of Dania Beach, re: deposition of Tom Schneider. 0.10AGA 04/06/21 Receipt and review of correspondence from Tom Schneider, City of Dania Beach, re: deposition of Tom Schneider and inquiring if it will be zoom conference or in person. 0.10AGA 04/06/21 Correspondence to Tom Schneider, City of Dania Beach, re: deposition of Tom Schneider and advising it can be zoom conference. 0.10AGA 04/06/21 Correspondence to Tom Schneider, City of Dania Beach, re: pre-deposition meeting of Tom Schneider and providing Zoom Information. 0.10AGA 04/06/21 Receipt and review of correspondence from Kyle Roberts, Counsel for Plaintiff, re: second correspondence on the deposition of Tom Schneider. 0.10AGA 04/06/21 Correspondence to Kyle Roberts, Counsel for Plaintiff, re: advising on the status of the deposition of Tom Schneider. 0.10AGA 04/06/21 Receipt and review of Notice of Taking Video Deposition of Tom Schneider. 0.10AGA 04/07/21 Correspondence to Tom Ansbro, City Attorney for City of Dania Beach, re: Plaintiff's claim injunctive relief and authorization to prepare and file a motion for leave to amend the City’s Answer and Defenses 0.10AGA Preferred Governmental Insurance Trust Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 3 May 17, 2021Client: HoursDateAttorneyServices PROFESSIONAL SERVICES 04/07/21 Receipt and review of correspondence from Tom Ansbro, City Attorney for City of Dania Beach, re: authorization to prepare and file a motion for leave to amend the City’s Answer and Defenses. 0.10AGA 04/07/21 Research FL Rules of Civil Procedure and cases regarding leave to amend pleadings in preparation of City’s Motion for Leave to File Amended Defenses. 1.80AGA 04/07/21 Preparation of e-mail to City's Record Specialist, Erica Clayton, re published notices for City Commission Meetings in 2014. 0.20AGA 04/07/21 Receipt, review and response to City's Record Specialist, Erica Clayton re published notices for City Commission Meetings and response acknowledging same. 0.30AGA 04/08/21 Correspondence to Tom Ansbro, City Attorney for City of Dania Beach, and Tom Schneider, City of Dania Beach, re: Notice of Taking Video Deposition of Tom Schneider. 0.10AGA 04/08/21 Preparation of Amended Answer and Defenses.1.00AGA 04/08/21 Preparation of Motion for Leave to File Amended Defenses.1.20AGA 04/08/21 Correspondence to Tom Ansbro, City Attorney for City of Dania Beach, re: draft Motion for Leave to File Amended Defenses and proposed Amended Answer and Defenses for review and input. 0.20AGA 04/08/21 Receipt and review of correspondence from Tom Ansbro, City Attorney for City of Dania Beach, re: approval of the draft Motion for Leave to File Amended Defenses and proposed Amended Answer and Defenses. 0.10AGA 04/08/21 Correspondence to Tom Ansbro, City Attorney for City of Dania Beach, re: inquiring on preference for Mediation whether in person or via zoom. 0.10AGA 04/08/21 Receipt and review of correspondence from Tom Ansbro, City Attorney for City of Dania Beach, re: advising on preference for Mediation via zoom. 0.10AGA 04/08/21 Preparation of correspondence to Michael Dutko, Counsel for Plaintiff, re: City of Dania Beach’s Motion for Leave to File Amended Defenses. 0.30AGA 04/12/21 Correspondence to Hoyt Holden,CGA, and Tom Ansbro, City Attorney for City of Dania Beach, re: second correspondence re telephone conference with Hoyt Holden. 0.10AGA 04/12/21 Receipt and review of correspondence from Hoyt Holden,CGA, re: telephone conference. 0.10AGA 04/12/21 Telephone conference with Hoyt Holden of Calvin Giordano & Associates regarding notices of public hearings in 2014 and his knowledge of the same. 0.50AGA 04/12/21 Receipt and review of correspondence from Thomas Schneider, City of Dania Beach, re: duces tecum documents related to his upcoming deposition. 0.20AGA Preferred Governmental Insurance Trust Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 4 May 17, 2021Client: HoursDateAttorneyServices PROFESSIONAL SERVICES 04/12/21 Receipt and review of duces tecum documents (8 separate email chains) regarding Thomas Schneider, City of Dania Beach's deposition. 0.20AGA 04/12/21 Receipt and review of correspondence from John Marion, Mediator, re: mediation letter. 0.20AGA 04/12/21 Receipt and review of Notice of Mediation filed on behalf of Mediator. 0.10AGA 04/13/21 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, re: re-noticing the deposition of William Telli to be held via zoom conference. 0.10AGA 04/13/21 Receipt and review of correspondence from Hoyt Holden, CGA, re: email correspondence that was sent to Chris Giordano and Jenna Martinetti that had all the 2014 emails sent to Janna in an email back in September 2020. 0.10AGA 04/13/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re: setting Motion for Leave to File Amended Defenses for UMC hearing. 0.20AGA 04/13/21 Receipt and review of Notice of Withdrawal filed by Albert Frevola. 0.10AGA 04/13/21 Preparation of Notice of Hearing on Defendant, City of Dania Beach’s Motion for Leave to File Amended Defenses. 0.20AGA 04/13/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re: UMC Hearing on Defendant, City of Dania Beach’s Motion for Leave to File Amended Defenses. 0.10AGA 04/13/21 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, re: UMC Hearing on Defendant, City of Dania Beach’s Motion for Leave to File Amended Defenses. 0.10AGA 04/13/21 Preparation of Amended Notice of Taking Deposition of William Telli. 0.20AGA 04/14/21 Receipt and review of multiple email correspondences from Hoyt Holden of CGA Solutions, re: 2014 DEC Notices and correspondences between Janna Lhota (12 emails total). 0.60AGA 04/15/21 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, re: Tom Schneider zoom deposition information. 0.10AGA 04/15/21 Correspondence to Tom Schneider, City of Dania Beach and Tom Ansbro, City Attorney for City of Dania Beach, re: zoom deposition information. 0.10AGA 04/16/21 Receipt and review of Non-Party Simpson's Responses and Objections to City's Notice of Taking Deposition Duces Tecum of Herbert Simpson. 0.30AGA 04/17/21 Detailed analysis of file materials in preparation of upcoming deposition of Herbert Simpson. 3.90AGA 04/19/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re: deposition of Herbert Simpson. 0.10AGA Preferred Governmental Insurance Trust Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 5 May 17, 2021Client: HoursDateAttorneyServices PROFESSIONAL SERVICES 04/19/21 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, re: deposition of Herbert Simpson. 0.10AGA 04/19/21 Attendance at the Zoom deposition of Witness, Herbert Simpson. 1.90AGA 04/19/21 Review/Analyze detailed analysis of file materials in preparation of the upcoming deposition of Herbert Simpson via Zoom. 3.90AGA 04/20/21 Telephone conference with Plaintiff’s counsel, Mike Dutko, regarding upcoming hearing on City’s Motion for Leave to Amend Defenses; good faith attempt to resolve issues; confirming Plaintiff objects in part to motion and hearing will go forward. 0.30AGA 04/20/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re: inquiring on upcoming hearing on City’s Motion for Leave to Amend Defenses and good faith attempt to resolve issues. 0.10AGA 04/20/21 Review/Analyze detailed analysis of file materials including Motion for Leave to Amend Defenses and case law in preparation for upcoming hearing. 1.50AGA 04/21/21 Attendance at hearing on City’s MFL to Amend Defenses before Judge Towbin Singer via Zoom. 0.50AGA 04/21/21 Correspondence to John Mullin, Counsel for DEC, re: Plaintiff’s Amended Complaint, the City’s Answer and Defenses, the City’s Motion for Leave, and the Grapski case Plaintiff is relying on. 0.20AGA 04/21/21 Telephone conferences with John Mullin, counsel for DEC, regarding City’s Motion for Leave to Amend Defenses and Court’s directives at hearing this morning and DEC's position regarding the same. 0.60AGA 04/21/21 Correspondence to Judge Singer, re: requesting special set hearing on Defendant, City of Dania Beach’s Motion for Leave to File Amended Defenses as directed by court. 0.20AGA 04/21/21 Preparation of correspondence to Tom Ansbro, City Attorney for City of Dania Beach, re: outcome of hearing on Defendant, City of Dania Beach’s Motion for Leave to File Amended Defenses before Judge Towbin Singer. 0.60AGA 04/22/21 Preparation of correspondence to Michael Dutko, Counsel for Plaintiff, re: proposed Agreed Order Granting in part Defendant, City of Dania Beach’s, Motion For Leave to File Amended Defenses. 0.30AGA 04/22/21 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, re: approval of proposed Agreed Order Granting in part Defendant, City of Dania Beach’s, Motion For Leave to File Amended Defenses. 0.10AGA 04/22/21 Correspondence to John Mullin, Counsel for DEC, re: special set hearing on City’s Motion for Leave to File Amended Defenses. 0.10AGA Preferred Governmental Insurance Trust Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 6 May 17, 2021Client: HoursDateAttorneyServices PROFESSIONAL SERVICES 04/22/21 Receipt and review of correspondence from John Mullin, Counsel for DEC, re: special set hearing on City’s Motion for Leave to File Amended Defenses. 0.10AGA 04/22/21 Preparation of Amended Notice of Hearing on Defendant, City of Dania Beach’s Motion for Leave to File Amended Defenses. 0.30AGA 04/22/21 Receipt and review of Court's Executed Agreed Order in Part Defendant, City of Dania Beach's Motion for Leave to File Amended Defenses. 0.10AGA 04/22/21 Research relevant caselaw pertaining to whether a judge has discretion to decline to add an indispensable party to a lawsuit with a focus on property cases in advance of the upcoming hearing on the Motion for Leave to File Amended Defenses. 2.50SHP 04/22/21 Correspondence to Judge Towbin Singer, re: requesting special set hearing dates and times for Defendant, City of Dania Beach’s Motion for Leave to File Amended Defenses. 0.10AGA 04/22/21 Receipt and review of correspondence from Judge Towbin Singer, re: special set hearing dates and times for Defendant, City of Dania Beach’s Motion for Leave to File Amended Defenses. 0.10AGA 04/22/21 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, to Judge Towbin Singer, re: special set hearing dates and times for Defendant, City of Dania Beach’s Motion for Leave to File Amended Defenses. 0.10AGA 04/23/21 Correspondence to Judge Towbin Singer, re: enclosing Motion on Defendant, City of Dania Beach’s Motion for Leave to File Amended Defenses. 0.10AGA 04/23/21 Research Florida cases regarding indispensable parties, injunctive relief, court’s discretion to proceed with trial without adding indispensable party in preparation for upcoming Court-Ordered special set hearing on City’s Motion for Leave to File Amended Defenses. 2.90AGA 04/25/21 Detailed analysis of file materials and perform additional legal research in preparation for upcoming Court-Ordered special set hearing on City’s Motion for Leave to File Amended Defenses. 2.30AGA 04/26/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re: the deposition of William Telli. 0.10AGA 04/26/21 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, re: the deposition of William Telli. 0.10AGA 04/26/21 Preparation of Supplemental Authority to City’s Motion for Leave to File Amended Defenses. 0.60AGA 04/26/21 Attendance at Court-Ordered special set hearing on City’s Motion for Leave to File Amended Defenses before Judge Singer via Zoom. 0.90AGA Preferred Governmental Insurance Trust Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 7 May 17, 2021Client: HoursDateAttorneyServices PROFESSIONAL SERVICES 04/26/21 Telephone conference with Plaintiff’s counsel Mike Dutko regarding Plaintiff’s plan to amend the complaint to add Dania Entertainment Center as a party and request to postpone the upcoming deposition of William Telli. 0.20AGA 04/26/21 Preparation of Notice of Postponement of Deposition of William Telli. 0.30AGA 04/26/21 Preparation of correspondence to Tom Ansbro, City Attorney for City of Dania Beach, re: outcome of hearing on City’s Motion for Leave to File Amended Defenses before Judge Michele Towbin Singer. 0.70AGA 04/26/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re: agreement to postponement of the deposition of William Telli. 0.10AGA 04/26/21 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, re: agreement to anticipated motion to amend the complaint to add DEC as a party. 0.10AGA 04/26/21 Preparation of Order Granting Defendant's Motion for Leave to File Amended Defenses. 0.40AGA 04/27/21 Review/Analyze lengthy litigation file, including pleadings, motions, items of correspondence, and discovery to date in preparation for drafting pre-mediation evaluation to be sent to claims adjuster, per client guidelines. 1.00AGA 04/27/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re: proposed Order Granting Defendant's Motion for Leave to File Amended Defenses for review and input. 0.20AGA 04/28/21 Receipt and review of Plaintiff's Answers to Defendant, City of Dania Beach's First set of Interrogatories. 0.20AGA 04/28/21 Preparation of correspondence to Tom Ansbro, City Attorney for City of Dania Beach, re: pre-mediation case evaluation. 3.30AGA 04/28/21 Correspondence to Tom Schneider, City of Dania Beach, re: Tom Schneider's deposition in regards to Plaintiff's Motion for Leave to Add Dania Entertainment Center (DEC) as a party defendant. 0.10AGA 04/28/21 Receipt and review of correspondence from Tom Schneider, City of Dania Beach, re: Tom Schneider's deposition in regards to Plaintiff's Motion for Leave to Add Dania Entertainment Center (DEC) as a party defendant. 0.10AGA 04/28/21 Receipt and review of Plaintiff's Response to City of Dania Beach's Request to Produce. 0.20AGA 04/28/21 Receipt and review of Plaintiff, Citizens for Responsible Development's, Motion for Leave to Amend Complaint and proposed Second Amended Complaint. 0.40AGA 04/28/21 Receipt and review of correspondence from Kyle Roberts, Counsel for Plaintiff, re: postponement of the deposition of Tom Schneider, until other issues with Motion are resolved. 0.20AGA Preferred Governmental Insurance Trust Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 8 May 17, 2021Client: HoursDateAttorneyServices PROFESSIONAL SERVICES 04/28/21 Correspondence to Kyle Roberts, Counsel for Plaintiff, re: advising we will get with the City re: postponement of the deposition of Tom Schneider, until other issues with Motion are resolved. 0.20AGA 04/28/21 Receipt and review of correspondence from Kyle Roberts, Counsel for Plaintiff, re: proposed revisions to the proposed Order Granting Defendant's Motion for Leave to File Amended Defenses. 0.20AGA 04/29/21 Correspondence to Kyle Roberts, Counsel for Plaintiff, re: advising we can postpone the deposition of Tom Schneider, until other issues with Motion are resolved. 0.20AGA 04/29/21 Receipt and review of correspondence from Kyle Roberts, Counsel for Plaintiff, re: advising they will be filing and setting their motion for hearing today. 0.20AGA 04/29/21 Preparation of correspondence to Tom Ansbro, City Attorney for City of Dania Beach, re: Plaintiff, Citizens for Responsible Development’s Motion for Leave to File Amended Complaint to add Dania Entertainment Center, LLC (DEC) as a party defendant. 0.30AGA 04/29/21 Attendance at pre-deposition conference with Thomas Schneider, City Clerk via Zoom. 1.00AGA 04/29/21 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, re: approval of revised proposed Order Granting Defendant's Motion for Leave to File Amended Defenses. 0.10AGA 04/30/21 Receipt and review of Notice of Postponement of the deposition for Tom Schneider. 0.10AGA 04/30/21 Receipt and review of Notice of Hearing on Citizens for Responsible Development, Inc's Motion for Leave to Amend Complaint. 0.10AGA 04/30/21 Receipt and review of correspondence from Judge Towbin Singer, re: hearing on Plaintiffs’ Motion for Leave to Amend Complaint. 0.20AGA 04/30/21 Receipt and review of correspondence from John Mullin, Counsel for DEC, re: Plaintiff approved draft Order and Cost Judgment and upcoming hearing. 0.10AGA 04/30/21 Correspondence to John Mullin, Counsel for DEC, re: Plaintiff approved draft Order and Cost Judgment and upcoming hearing. 0.10AGA 04/30/21 Telephone conference with Tom Ansbro, City Attorney for City of Dania Beach, re: regarding Plaintiff’s motion to amend complaint to add DEC as party, upcoming mediation, need for executive session, and defense strategies. 0.20AGA Preferred Governmental Insurance Trust Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 9 May 17, 2021Client: HoursDateAttorneyServices PROFESSIONAL SERVICES 04/30/21 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, re: dates for UMC hearing on Citizens for Responsible Development, Inc's Motion for Leave to Amend Complaint. 0.10AGA 04/30/21 Correspondence to Michael Dutko, Counsel for Plaintiff, re: dates for UMC hearing on Citizens for Responsible Development, Inc's Motion for Leave to Amend Complaint. 0.10AGA 04/30/21 Receipt and review of Court's Executed Order Granting Defendant, City of Dania Beach’s, Motion for Leave to File Amended Defenses. 0.10AGA Code AmountHoursRateName PROFESSIONAL SERVICES SUMMARY 8,460.00180.0047.00AGAAndrea G. Amigo, Partner 85.0085.001.00RKDRebecca K. Davis, Paralegal 362.50145.002.50SHPSara H. Ptachik, Associate Total Professional Services $8,907.5050.50 Date AmountDescription DISBURSEMENTS 100.00Deposition Transcripts #184166;hearing attendance before Judge Singer - Florida Court Reporting 04/22/21 95.00Deposition Transcripts #184207;Hearing before Judge Singer - Florida Court Reporting 04/26/21 433.00Deposition Transcripts #184202;deposition of Herbert Simpson - Florida Court Reporting 04/26/21 Total Disbursements $628.00 97,957.00 101,393.59 3,436.59 Fees Billed to Date Costs Billed to Date Total Billed to Date Bill History for this Matter Case to DateYear to Date 12,219.00 628.00 12,847.00 Preferred Governmental Insurance Trust Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 10 May 17, 2021Client: CURRENT BILL TOTAL AMOUNT DUE $9,535.50 Balance Forward: Payments & Adjustments:-3,311.50 3,311.50 9,535.50Total Due:$ Please return this page with remittance to Roberts, Reynolds, Bedard & Tuzzio, PLLC 470 Columbia Drive, Suite C-101 West Palm Beach, Florida 33409 57588Bill Number: Client Code:155 Client Name:Preferred Governmental Insurance Trust Bill Date:May 17, 2021 14358 Citizens (2) v. Dania Beach/Mayor Duke Matter Code: Matter Name: CURRENT BILL TOTAL AMOUNT DUE $9,535.50 0.00Past Due Balance TOTAL AMOUNT DUE $9,535.50 Balance Forward: Payments & Adjustments:-3,311.50 3,311.50 9,535.50Total Due:$ Total Professional Services Total Disbursements 628.00 8,907.50