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HomeMy WebLinkAboutInv# 63308 - ROBERTS, REYNOLDS, BEDARD & TUZZIO, PLLC - 02/15/2022ROBERTS, 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 01/31/22 February 15, 2022 Bill No. 63308 HoursDateAttorneyServices PROFESSIONAL SERVICES 01/03/22 Receipt and review of correspondence to and from Michael Dutko, Counsel for Plaintiff, re: the depositions of Joe Husosky, Louise Stilson, and Marc LaFerrier. 0.20AGA 01/05/22 Receipt and review of multiple correspondences to and from John Mullin, Counsel for DEC, re: meeting to discuss resolution of case and details for same. 0.20AGA 01/05/22 Receipt and review of correspondences from Arnaldo Suarez, DEC, re: meeting to discuss resolution of case and details for same. 0.20AGA 01/05/22 Receipt and review of correspondences from Corrine Lajoie, City of Dania Beach, re: meeting to discuss resolution of case and details for same. 0.20AGA 01/05/22 Telephone conference with City Attorney Eve Boutsis regarding upcoming meeting with DEC representatives and counsel. 0.20AGA 01/06/22 Receipt and review of multiple correspondences to and from City Attorney Eve Boutsis, City of Dania Beach, re: meeting with City and DEC to discuss case and strategy. 0.20AGA 01/06/22 Receipt and review of multiple correspondences to and from John Mulin, DEC, re: meeting with City and DEC to discuss case and strategy. 0.20AGA 01/07/22 Receipt and review of Defendant, Dania Entertainment Center's Fact Witness List. 0.20AGA 01/07/22 Receipt and review of Notice of Taking Zoom Deposition of Mark LaFerrier, Witness. 0.20AGA 01/07/22 Correspondence to Mark LaFerrier, Witness, re: Notice of Taking Zoom Deposition of Mark LaFerrier, Witness. 0.10AGA Preferred Governmental Insurance Trust Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 2 February 15, 2022Client: HoursDateAttorneyServices PROFESSIONAL SERVICES 01/07/22 Preparation of correspondence to Eve Boutsis, City of Dania Beach, re: Co-Defendant, Dania Entertainment Center, LLC’s (DEC) Witness List and Notice of Taking Deposition Duces Tecum received from Plaintiff’s counsel for the deposition of Mark LaFerrier. 0.30AGA 01/07/22 Receipt and review of Defendant, Dania Entertainment Center's Motion to Amend Answer to Complaint. 0.20AGA 01/10/22 Preparation of correspondence to Eve Boutsis, City of Dania Beach, re: Co-Defendant, Dania Entertainment Center, LLC’s (“DEC”) Agreed Motion to Amend Answer by Interlineation. 0.30AGA 01/10/22 Correspondence to Marc LaFerrier, Witness, re: request for mailing address. 0.10AGA 01/10/22 Receipt and review of correspondence from Marc LaFerrier, Witness, re: mailing address information. 0.10AGA 01/11/22 Preparation of correspondence to Thomas Schneider, City, re: deposition transcript and errata sheet for execution. 0.30AGA 01/11/22 Preparation of correspondence to Judy Felicetty, Witness, re: deposition transcript and errata sheet for execution. 0.30AGA 01/11/22 Preparation of correspondence to Corrine LaJoie, Witness, re: deposition transcript and errata sheet for execution. 0.30AGA 01/11/22 Correspondence to Eve Boutsis, City of Dania Beach, re: upcoming meeting with DEC. 0.10AGA 01/11/22 Correspondence to John Mullin, DEC, re: upcoming meeting with DEC. 0.10AGA 01/11/22 Receipt and review of correspondence from John Mullin, DEC, re: upcoming meeting with DEC. 0.10AGA 01/11/22 Receipt and review of correspondence from Eve Boutsis, City of Dania Beach, re: upcoming meeting with DEC. 0.10AGA 01/11/22 Receipt and review of correspondence from John Mullin, Counsel for DEC, re: upcoming meeting and discussion of proposed witnesses for deposition. 0.10AGA 01/12/22 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, re: zoom information for the deposition of Marc LaFerrier. 0.10AGA 01/12/22 Correspondence to Marc LaFerrier, Witness, re: zoom information for the deposition of Marc LaFerrier. 0.10AGA 01/12/22 Attendance at meeting with City Attorney Eve Boutsis, Corrine Lajoie, John Mullin, and Eleanor Norena in Dania Beach, FL regarding potential resolution of pending litigation and plans for future development. 4.00AGA 01/12/22 Receipt and review of Plaintiff's Motion to Compel Deposition Dates for Joe Husosky and Louise Stilson. 0.20AGA Preferred Governmental Insurance Trust Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 3 February 15, 2022Client: HoursDateAttorneyServices PROFESSIONAL SERVICES 01/12/22 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, re: deposition request for Janna Lhota, Corporate representative of F3 Architecture, Ronnie Navarro of the City of Dania Jenna Martinetti, P.E. from CGA, Corporate representatives of DEC: Arnaldo Suarez and Joaquin Labougle. 0.10AGA 01/12/22 Receipt and review of correspondence from John Mullin, DEC, to Michael Dutko, Counsel for Plaintiff, re: deposition request for Janna Lhota, Corporate representative of F3 Architecture, Ronnie Navarro of the City of Dania, Jenna Martinetti, P.E. from CGA, Corporate representatives of DEC: Arnaldo Suarez and Joaquin Labougle. 0.10AGA 01/12/22 Research of case law to determine whether notice requirement is waived under Fla.Stat. 163 and Florida Sunshine Law if the Plaintiff actually attended the subject meetings on the proposed amendments to the development agreements in 2014. 0.90AGA 01/13/22 Receipt and review of multiple correspondences to and from John Mullin, Counsel for DEC, re: discussion of trial, case strategy and depo transcripts. 0.20AGA 01/13/22 Correspondence to John Mullins, Counsel for DEC, re: all recent deposition transcripts for case. 0.20AGA 01/14/22 Correspondence to Marc LaFerrrier, Witness, re: upcoming pre-deposition meeting. 0.10AGA 01/14/22 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, re: inquiry as to hearing on CFRD’s Motion to Compel The City to Provide Deposition Dates for Husosky and Stilson. 0.10AGA 01/17/22 Correspondence to Marc LaFerrier, Witness, re: prior deposition transcript for review. 0.20AGA 01/17/22 Attendance at pre deposition conference with former City of Dania Beach Community Development Director Marc LaFerrier via Zoom. 1.50AGA 01/18/22 Telephone conference with Mr. Miranda counsel for Cap Government (Mr. LaFerrier's current employer) regarding Mark LaFerrier's deposition. 0.30AGA 01/18/22 Receipt and review of correspondence from Jose Miranda, CAP government, re: telephone conference to discuss matter. 0.10AGA 01/18/22 Receipt and review of correspondence from Marc LaFerrier, CAP government, re: Jose Miranda, CAP government, and telephone conference to discuss matter. 0.10AGA 01/19/22 Correspondence to Jose Miranda, counsel for CAP Government re: notice of taking deposition of Mark LaFerrier. 0.10AGA 01/19/22 Telephone conference with John Mullin, counsel for DEC, regarding outcome of conference with Plaintiff’s counsel regarding potential settlement and defense strategies. 0.30AGA Preferred Governmental Insurance Trust Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 4 February 15, 2022Client: HoursDateAttorneyServices PROFESSIONAL SERVICES 01/19/22 Correspondence to Michael Dutko, Counsel for Plaintiff, re: CFRD’s Motion to Compel The City to Provide Deposition Dates for Husosky and Stilson for motion calendar. 0.10AGA 01/19/22 Receipt and review of correspondence from John Mullin, Counsel for DEC, to Michael Dutko, Counsel for Plaintiff, re: CFRD’s Motion to Compel The City to Provide Deposition Dates for Husosky and Stilson for motion calendar. 0.10AGA 01/19/22 Telephone conference with City Attorney Boutsis regarding outcome of DEC’s counsel’s conference with Plaintiff’s counsel and defense strategies. 0.30AGA 01/19/22 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, re: CFRD’s Motion to Compel The City to Provide Deposition Dates for Husosky and Stilson for motion calendar. 0.10AGA 01/20/22 Receipt and review of correspondence from Jose Miranda, CAP government, re: advising as to the details for upcoming deposition of Marc LaFerrier. 0.10AGA 01/20/22 Correspondence to all counsel, re: the upcoming deposition of Marc LaFerrier. 0.10AGA 01/20/22 Receipt and review of correspondence from Kyle Roberts, Counsel for Plaintiff, re: the upcoming deposition of Marc LaFerrier. 0.10AGA 01/20/22 Receipt and review of correspondence to and from Kyle Roberts, Counsel for Plaintiff, re; the upcoming deposition of Marc LaFerrier. 0.20AGA 01/20/22 Receipt and review of correspondence to and from Lori Adams, City of Dania Beach, re: upcoming shade meeting and conference. 0.20AGA 01/20/22 Receipt and review of multiple correspondences to and from John Mullin, Counsel for DEC, re: the deposition of Marc LaFerrier. 0.20AGA 01/21/22 Correspondence to all counsel, re: late arrival of witness Marc LaFerrier. 0.10AGA 01/21/22 Telephone conference with Marc LaFerrier former City Community Development Director regarding outcome of his deposition. 0.30AGA 01/21/22 Attendance at Plaintiff’s deposition of Marc LaFerrier, former City Community Development Director via Zoom. 1.00AGA 01/21/22 Receipt and review of Defendant Dania Entertainment Center's Motion for Continuance. 0.20AGA 01/21/22 Receipt and review of multiple correspondences to and from John Mullin, Counsel for DEC and Michael Dutko, Counsel for Plaintiff, re: DEC's motion for continuance of trial. 0.20AGA Preferred Governmental Insurance Trust Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 5 February 15, 2022Client: HoursDateAttorneyServices PROFESSIONAL SERVICES 01/24/22 Preparation of correspondence to Eve Boutsis, City of Dania Beach, re: Co-Defendant, Dania Entertainment Center, LLC’s (DEC) Motion for Continuance. 0.30AGA 01/24/22 Receipt and review of Joint Motion to Extend Trial Deadlines.0.20AGA 01/26/22 Receipt and review of correspondence to and from Eve Boutsis, City of Dania Beach, re: changes to upcoming shade meeting. 0.20AGA 01/26/22 Preparation of Notice of Filing the Deposition Transcript of Marc LaFerrier. 0.30AGA 01/26/22 Preparation of Notice of Filing the Deposition Transcript of Herbert Simpson. 0.30AGA 01/26/22 Preparation of Notice of Filing the Deposition Transcript of Corrine LaJoie. 0.30AGA 01/26/22 Preparation of Notice of Filing the Deposition Transcript of Judy Felicetty. 0.30AGA 01/26/22 Preparation of Notice of Filing the Deposition Transcript of Tom Schneider. 0.30AGA 01/26/22 Preparation of Notice of Filing the Deposition Transcript of William Telli. 0.30AGA 01/27/22 Correspondence to Judy Felicetty, former City records specialist, re: inquiry as to meeting to discuss upcoming trial. 0.10AGA 01/27/22 Correspondence to John Mullin, Counsel DEC, re: the notice 0.20AGA 01/27/22 Receipt and review of correspondence from John Mullin, Counsel for DEC, re: proposed Agreed Order on Motion for Continuance. 0.20AGA 01/27/22 Correspondence to John Mullin, Counsel for DEC, re: no objection to proposed Agreed Order on Motion for Continuance. 0.10AGA 01/27/22 Receipt and review of correspondence from Michael Dutko, Counsel for Plaintiff, to John Mullin, Counsel for DEC, re: no objection to proposed Agreed Order on Motion for Continuance. 0.20AGA 01/27/22 Receipt and review of proposed Agreed Order on Motion for Continuance. 0.20AGA 01/27/22 Telephone conference with City Attorney Boutsis regarding DEC’s motion for continuance and proposed Agreed Order and confirming City has no objections to the same. 0.20AGA 01/27/22 Receipt and review of correspondence from DEC’s counsel John Mullin regarding notices of filing deposition transcripts. 0.20AGA 01/27/22 Preparation of correspondence to DEC’s counsel John Mulling advising deposition transcripts filed with the Court already. 0.20AGA 01/28/22 Receipt and review of correspondence to and from Judge Singer, re: inquiry on new trial dates. 0.20AGA 01/28/22 Preparation of correspondence to City of Dania Beach attorney, Eve Boutsis, re: dates for trial pertaining to Plaintiff, Citizens for Responsible Development. 0.30AGA Preferred Governmental Insurance Trust Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 6 February 15, 2022Client: HoursDateAttorneyServices PROFESSIONAL SERVICES 01/28/22 Preparation of correspondence to witness Joe Husosky re: dates for trial pertaining to Plaintiff, Citizens for Responsible Development. 0.30AGA 01/28/22 Preparation of correspondence to witness Louise Stilson re: dates for trial pertaining to Plaintiff, Citizens for Responsible Development. 0.30AGA 01/28/22 Preparation of correspondence to witness Judy Felicetty re: dates for trial pertaining to Plaintiff, Citizens for Responsible Development. 0.30AGA 01/28/22 Receipt and review of Court's Order on Joint Motion for Continuance. 0.20AGA 01/28/22 Receipt and review of Defendant, Dania Entertainment's Motion for Partial Summary Judgment. 0.20AGA 01/28/22 Receipt and review of Court's Order Resetting Trial.0.20AGA 01/31/22 Preparation of correspondence to Eve Boutsis, City of Dania Beach, re: Court’s new Trial Order. 0.30AGA 01/31/22 Preparation of Defendant,City of Dania Beach's, Subpoena for Trial directed to Hoyt Holden pertaining to Plaintiff, Citizens for Responsible Development, Inc. 0.60AGA 01/31/22 Preparation of Defendant,City of Dania Beach's, Subpoena for Trial directed to Paula Giordano pertaining to Plaintiff, Citizens for Responsible Development, Inc. 0.60AGA Code AmountHoursRateName PROFESSIONAL SERVICES SUMMARY 4,302.00180.0023.90AGAAndrea G. Amigo, Partner Total Professional Services $4,302.0023.90 Date AmountDescription DISBURSEMENTS 177.00Deposition Transcripts #291474;video deposition of Corrine Lajoie - United Reporting, Inc. 01/05/22 191.40Deposition Transcripts #291475;Video deposition of Judy Felicetty - United Reporting, Inc. 01/05/22 284.40Deposition Transcripts #291457;video deposition of Thomas Schneider - United Reporting, Inc. 01/05/22 492.60Deposition Transcripts #INV2091020;William Telli deposition - Esquire Deposition Solutions, LLC 01/31/22 7.50Witness Fees Hoyt Holden witness fee for trial subpoena. - Hoyt Holden 01/31/22 Preferred Governmental Insurance Trust Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 7 February 15, 2022Client: Date AmountDescription DISBURSEMENTS 7.50Witness Fees Paula Giordano witness fee for trial subpoena. - Paula Giordano 01/31/22 Total Disbursements $1,160.40 118,526.00 123,122.99 4,596.99 Fees Billed to Date Costs Billed to Date Total Billed to Date Bill History for this Matter Case to DateYear to Date 10,692.00 1,160.40 11,852.40 CURRENT BILL TOTAL AMOUNT DUE $5,462.40 Balance Forward: Payments & Adjustments:-6,390.00 6,390.00 5,462.40Total Due:$ Please return this page with remittance to Roberts, Reynolds, Bedard & Tuzzio, PLLC 470 Columbia Drive, Suite C-101 West Palm Beach, Florida 33409 63308Bill Number: Client Code:155 Client Name:Preferred Governmental Insurance Trust Bill Date:February 15, 2022 14358 Citizens (2) v. Dania Beach/Mayor Duke Matter Code: Matter Name: CURRENT BILL TOTAL AMOUNT DUE $5,462.40 0.00Past Due Balance TOTAL AMOUNT DUE $5,462.40 Balance Forward: Payments & Adjustments:-6,390.00 6,390.00 5,462.40Total Due:$ Total Professional Services Total Disbursements 1,160.40 4,302.00