HomeMy WebLinkAboutInv# 62814 - ROBERTS, REYNOLDS, BEDARD & TUZZIO, PLLC - 01/20/2022ROBERTS, 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: Eve Boutsis
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 12/31/21
January 20, 2022
Bill No. 62814
HoursDateAttorneyServices
PROFESSIONAL SERVICES
12/01/21 Receipt and review of correspondence from John Marion,
Mediator, re: invoice for services from mediation conference.
0.10AGA
12/01/21 Receipt and review of invoice for services from mediation
conference.
0.10AGA
12/01/21 Receipt and review of Mediation Report from Mediator, John
Marion.
0.10AGA
12/01/21 Preparation of correspondence to Tom Ansbro, City Attorney,
re: mediation outcome.
0.90AGA
12/01/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: second inquiry as to the depositions of
multiple City employees.
0.10AGA
12/01/21 Receipt and review of correspondence from Hoyt Holden, re:
the deposition request by Plaintiff's counsel for his deposition.
0.10AGA
12/01/21 Receipt and review of multiple correspondences to and from
Michael Dutko, Counsel for Plaintiff, re: the depositions of Judy
Felicetty.
0.20AGA
12/01/21 Receipt and review of multiple correspondences to and from
Michael Dutko, Counsel for Plaintiff, re: the depositions of
Paula Giordano and Hoyt Holden.
0.20AGA
12/01/21 Receipt and review of Plaintiff's Objection to the Notice of
Taking Deposition Duces Tecum of William Telli.
0.20AGA
12/02/21 Receipt and review of correspondence to and from Paula
Giordano, Witness and Hoyt Holden, Witness, re: Plaintiff's
Request for their depositions and pre-deposition meetings.
0.20AGA
12/06/21 Receipt and review of correspondence to and from John Mullin,
Counsel for DEC, re: inquiry as to Plaintiff's latest demand.
0.20AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 2
January 20, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
12/06/21 Preparation of Amended Notice of Taking Deposition of William
Telli.
0.20AGA
12/06/21 Receipt and review of Zoom Information for the deposition of
Thomas Schneider.
0.20AGA
12/06/21 Receipt and review of multiple correspondences from all
counsels, re: the depositions of Hoyt Holden, Paula Giordano,
and Judy Felcitty.
0.20AGA
12/06/21 Receipt and review of Notice of Taking Video Deposition of
Hoyt Holden.
0.20AGA
12/06/21 Receipt and review of Notice of Taking Video Deposition of
Paula Giordano.
0.20AGA
12/06/21 Receipt and review of Notice of Taking Video Deposition of
Judy Felicetty.
0.20AGA
12/06/21 Correspondence to Hoyt Holden, and Paula Giordano,
Witnesses, re: Notice of Taking Video Deposition of Paula
Giordano and Hoyt Holden.
0.20AGA
12/06/21 Receipt and review of Re-Notice of Taking Deposition of
Thomas Schneider.
0.20AGA
12/06/21 Receipt and review of correspondence to and from Thomas
Schneider, City of Dania Beach, re: time change for upcoming
deposition.
0.20AGA
12/06/21 Receipt and review of multiple correspondences to and from
John Mullin, Counsel for DEC, and Michael Dutko, Counsel for
Plaintiff, re: the upcoming deposition of Thomas Schneider.
0.20AGA
12/07/21 Receipt and review of correspondence from Michael Dtuko,
Counsel for Plaintiff, re: zoom information for the depositions of
Paula Giordano and Hoyt Holden.
0.20AGA
12/07/21 Correspondence to Paula Girodano and Hoyt Holden,
Witnesses, re: zoom information for upcoming depositions.
0.10AGA
12/08/21 Attendance at pre-deposition conference with Judy Felicetty,
former City employee with knowledge of public records
requests from Plaintiff’s counsel and City’s responses.
0.90AGA
12/08/21 Receipt and review of correspondence to and from Michael
Dutko, Counsel for Plaintiff, and John Mullin, Counsel for DEC,
re: upcoming deposition of William Telli.
0.20AGA
12/08/21 Review/Analyze detailed analysis of file materials including prior
deposition transcript of Mr. Telli taken in companion 2011
lawsuit (103 pages), Plaintiff’s original and second amended
complaint, Plaintiff’s answers to interrogatories, Plaintiff’s
response to City’s Request to Produce in preparation for
upcoming deposition of CFRD President William Telli.
3.20AGA
12/09/21 Correspondence to Thomas Schneider, City of Dania Beach,
re: upcoming Zoom pre-deposition meeting.
0.10AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 3
January 20, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
12/09/21 Receipt and review of correspondence from Thomas
Schneider, City of Dania Beach, re: upcoming Zoom
pre-deposition meeting.
0.10AGA
12/09/21 Attendance at deposition of CFRD President, William Telli, via
ZOOM
1.60AGA
12/10/21 Correspondence to Hoyt Holden, and Paula Giordano,
Witnesses, re: upcoming pre-deposition meeting.
0.20AGA
12/10/21 Correspondence to Corrine Lajoie, City of Dania Beach, re:
inquiry as to requested deposition.
0.10AGA
12/10/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: second correspondence regarding the
requested depositions of Joe Husosky, Louise Stilson, Marc
Laferrier and Corrine Lajoie.
0.10AGA
12/10/21 Preparation of Defendant, City of Dania Beach's and
Non-Party's Thomas Schneider's Responses and Objections to
Notice of Taking Deposition Duces Tecum.
1.20AGA
12/10/21 Attendance at pre-deposition conference with Thomas
Schneider City Clerk via Zoom.
1.00AGA
12/10/21 Receipt and review of Notice of Taking Video Deposition of
Corrine Lajoie.
0.20AGA
12/12/21 Review/Analyze detailed analysis of file materials including
emails and notices of public hearings in 2014 in preparation for
upcoming predepo conferences with Paula Giordano and Hoyt
Holden.
0.90AGA
12/13/21 Receipt and review of multiple correspondences to and from
Corrine Lajoie, City of Dania Beach, re: Notice of Taking
Deposition of Corrine Lajoie.
0.20AGA
12/13/21 Correspondence to Paula Giordano, Witness, re: zoom
information for upcoming deposition.
0.10AGA
12/13/21 Correspondence to Hoyt Holden, Witness, re: zoom information
for upcoming deposition.
0.10AGA
12/13/21 Receipt and review of City of Dania Beach Audit Letter.0.20LHR
12/13/21 Attendance at predeposition conference with Paula Giordano
via ZOOM.
0.80AGA
12/13/21 Attendance at predeposition conference with Hoyt Holden of
Calvin Giordano & Associates via Zoom
0.90AGA
12/14/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: Zoom information for the deposition of
Corrine Lajioe.
0.20AGA
12/14/21 Correspondence to Corrine Lajioe, Ciry of Dania Beach, re:
Zoom information for the deposition of Corrine Lajioe.
0.10AGA
12/14/21 Correspondence to all counsel, re: the upcoming depositions of
Paula Giordano and Hoyt Holden.
0.20AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 4
January 20, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
12/14/21 Receipt and review of correspondence from all counsel, re: the
upcoming depositions of Paula Giordano and Hoyt Holden.
0.20AGA
12/15/21 Receipt and review of correspondence from John Mullin,
Counsel for DEC , re: exhibits to be used for the deposition of
Paula Giordano and Hoyt Holden.
0.20AGA
12/15/21 Receipt and review of exhibits to be used for the deposition of
Paula Giordano and Hoyt Holden.
0.20AGA
12/15/21 Receipt and review of correspondence to and from Kyle
Roberts, Counsel for Plaintiff, re: the deposition of Hoyt Holden.
0.20AGA
12/15/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: Zoom information for the deposition of
Judy Felicetty.
0.20AGA
12/15/21 Correspondence to Judy Felicetty, Witness, re: Zoom
information for the deposition of Judy Felicetty.
0.20AGA
12/15/21 Receipt and review of correspondence to and from Kyle
Roberts, Counsel for Plaintiff, re: the deposition of Paula
Giordano.
0.20AGA
12/15/21 Attendance at Plaintiff’s deposition of Hoyt Holden of Calvin
Giordano & Associates via Zoom.
1.00AGA
12/15/21 Attendance at Plaintiff’s deposition of Paula Giordano via
Zoom.
1.00AGA
12/16/21 Correspondence to Tom Schneider, City of Dania Beach, re:
upcoming deposition of Tom Schneider.
0.10AGA
12/16/21 Correspondence to Corrine Lajoie, City of Dania Beach, re:
upcoming pre-deposition meeting.
0.10AGA
12/16/21 Receipt and review of correspondence from Tom Schneider,
City of Dania Beach, re: upcoming deposition of Tom
Schneider.
0.10AGA
12/16/21 Receipt and review of correspondence from Eve Boutsis, City
of Dania Beach, re: inquiry as to request for update budgets on
all City of Dania Beach.
0.20AGA
12/17/21 Receipt and review of correspondence from Michel Dutko,
Counsel for Plaintiff, re: exhibits to be used for the deposition of
Thomas Schneider, City of Dania Beach.
0.20AGA
12/17/21 Receipt and review of multiple correspondences to and from all
counsel, re: the revised Motion to update Pretrial Deadlines.
0.20AGA
12/17/21 Attendance at Plaintiff’s deposition of Tom Schneider, City
Clerk, via Zoom.
1.50AGA
12/17/21 Telephone conference with City Clerk Tom Schneider regarding
outcome of his deposition and answering his questions
regarding the same.
0.20AGA
12/17/21 Receipt and review of additional correspondence to and from
Eve Boutsis, City of Dania Beach, re: request for updated
budgets on City cases.
0.20AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 5
January 20, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
12/17/21 Telephone conference with Eve Boutsis, Assistant City
Attorney, regarding conference with DEC.
0.20AGA
12/17/21 Correspondence to Tom Ansbro, City Attorney, and Eve
Boutsis, City of Dania Beach, re: request for telephone
conference to discuss case strategy.
0.20AGA
12/17/21 Correspondence to John Mullin, Counsel for DEC, re: request
for telephone conference to discuss case strategy.
0.20AGA
12/17/21 Receipt and review of correspondence from Tom Ansbro, City
Attorney, and Eve Boutsis, City of Dania Beach, re: request for
telephone conference to discuss case strategy.
0.20AGA
12/17/21 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: exhibits for the deposition of Tom
Schneider and the motion to extend discovery and dispositive
motion deadlines.
0.20AGA
12/17/21 Receipt and review of exhibits for the deposition of Tom
Schneider.
0.20AGA
12/17/21 Correspondence to Corrine LaJoie, City of Dania Beach, re:
deposition transcript of Corrine Lajoie.
0.10AGA
12/17/21 Attendance at predeposition conference with Corrine Lajoie via
Zoom.
1.20AGA
12/17/21 Receipt and review of correspondence from Kyle Roberts,
Counsel for Plaintiff, re: proposed Motion to extend deadlines
for review.
0.20AGA
12/17/21 Receipt and review of correspondence from John Mullin,
Counsel for DEC, re: proposed Motion to extend deadlines for
review.
0.20AGA
12/17/21 Receipt and review of correspondence to and from Tom
Ansbro, City of Dania Beach, re: proposed motion asking the
Court to extend deadlines for discovery and dispositive motions.
0.20AGA
12/17/21 Correspondence to Kyle Roberts, Counsel for Plaintiff, re:
proposed Motion to extend deadlines.
0.20AGA
12/17/21 Receipt and review of correspondence to and from Eve Boutsis,
City of Dania Beach, re: telephone conference to discuss case
strategy.
0.20AGA
12/17/21 Receipt and review of correspondence from Eve Boutsis, City
of Dania Beach, re: proposed motion asking the Court to
extend deadlines for discovery and dispositive motions.
0.20AGA
12/17/21 Correspondence to all counsel, re: time change of the
deposition for Judy Felicetty.
0.10AGA
12/20/21 Receipt and review of multiple correspondences to and from
Michael Dutko, Counsel for Plaintiff, and John Mullin, Counsel
for DEC, re: the deposition of Judy Felicetty.
0.20AGA
12/20/21 Receipt and review of multiple correspondences to and from
Tom Ansbro, City of Dania Beach, re: telephone conference to
discuss case.
0.20AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 6
January 20, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
12/20/21 Attendance at Plaintiff’s deposition of Corinne Lajoie via Zoom.1.00AGA
12/20/21 Receipt and review of Joint Motion to Extend Trial Deadlines.0.20AGA
12/20/21 Receipt and review of multiple correspondences to and from
John Mullin, Counsel for DEC, re: proposed Order regarding
Motion to Extend deadlines.
0.20AGA
12/20/21 Receipt and review of correspondences to and from John
Mullin, Counsel for DEC and Kyle Roberts, Counsel for Plaintiff,
re: proposed Order regarding Motion to Extend deadlines.
0.20AGA
12/21/21 Receipt and review of correspondence to and from Michael
Dutko, Counsel for Plaintiff, re: no objection to the draft
Proposed Order Granting Joint Motion to Extend Deadlines.
0.20AGA
12/22/21 Attendance at Plaintiff’s deposition of Judy Felicetty, former City
Records Clerk, via Zoom.
1.00AGA
12/22/21 Telephone conference with John Mullin, counsel for DEC
regarding defense strategies.
0.30AGA
12/27/21 Receipt and review of Court's Executed Order Granting Motion
to Extend Trial Deadlines.
0.20AGA
12/30/21 Preparation of correspondence to Tom Ansbro, City of Dania
Beach, re: deposition summary of William Telli, Tom Schneider,
Hoy Holden, Corrine Lajoie, and Paula Giordano.
3.00AGA
12/30/21 Extensive telephone conference with City Attorney Tom Ansbro
and Assistant City Attorney Eve Boutsis regarding upcoming
conference with DEC and DEC’s counsel, potential resolution of
cases, and defense strategies.
0.50AGA
12/30/21 Extensive telephone conference with City Attorney Tom Ansbro,
Assistant City Attorney Eve Boutsis, DEC’s counsel John
Mullin, and DEC representative Mr. Suarez regarding Dania Jai
Alai project, potential settlement, and defense strategies.
0.80AGA
12/30/21 Receipt and review of correspondence to and from Eve Boutsis,
City of Dania Beach, re: inquiry on the Chapter 163
requirement.
0.20AGA
Code AmountHoursRateName
PROFESSIONAL SERVICES SUMMARY
6,354.00180.0035.30AGAAndrea G. Amigo, Partner
36.00180.000.20LHRLyman H. Reynolds, Jr., Partner
Total Professional Services $6,390.0035.50
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 7
January 20, 2022Client:
114,224.00
117,660.59
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
6,390.00
0.00
6,390.00
CURRENT BILL TOTAL AMOUNT DUE $6,390.00
Balance Forward:
Payments & Adjustments:-4,279.00
4,279.00
6,390.00Total Due:$
Please return this page with remittance
to
Roberts, Reynolds, Bedard & Tuzzio, PLLC
470 Columbia Drive, Suite C-101
West Palm Beach, Florida 33409
62814Bill Number:
Client Code:155
Client Name:Preferred Governmental Insurance Trust
Bill Date:January 20, 2022
14358
Citizens (2) v. Dania Beach/Mayor Duke
Matter Code:
Matter Name:
CURRENT BILL TOTAL AMOUNT DUE $6,390.00
0.00Past Due Balance
TOTAL AMOUNT DUE
$6,390.00
Balance Forward:
Payments & Adjustments:-4,279.00
4,279.00
6,390.00Total Due:$
Total Professional Services
Total Disbursements 0.00
6,390.00