HomeMy WebLinkAboutInv# 65228 - ROBERTS, REYNOLDS, BEDARD & TUZZIO, PLLC - 05/12/2022ROBERTS, 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 04/30/22
May 12, 2022
Bill No. 65228
HoursDateAttorneyServices
PROFESSIONAL SERVICES
04/01/22 Preparation of correspondence to Eve Boutsis, City, re:
Defendant, City of Dania Beach’s Reply to Plaintiff’s
Consolidated Response to City’s Motions for Summary
Judgment.
0.30AGA
04/05/22 Preparation of correspondence to Eve Boutsis, City, re:
deposition summary of Joe Husosky.
1.20AGA
04/05/22 Correspondence to all counsel, re: inquiry as to conference for
Joint PTS and exhibit exchange for trial.
0.20AGA
04/05/22 Receipt and review of multiple correspondences to and from
John Mullin, Counsel for DEC, and Michael Dutko, Counsel for
Plaintiff, re: discussion of pre trial exhibit exchange and joint
pretrial stipulation, and discussion of hearing on Motions for
Summary Judgments.
0.30AGA
04/06/22 Preparation of correspondence to Eve Boutsis, City Attorney,
re: the deposition summary of Joe Husosky.
1.20AGA
04/06/22 Attendance at Plaintiff’s depo of DEC CEO Arnaldo Suarez via
Zoom.
1.00AGA
04/06/22 Correspondence to Judge Towbin Singer, re: inquiry as to
hearing information on Motions for Summary Judgment, zoom
or call in information.
0.20AGA
04/06/22 Receipt and review of correspondence from Judge Towbin
Singer, re: inquiry as to hearing information on Motions for
Summary Judgment, zoom or call in information.
0.20AGA
04/07/22 Attendance at Court ordered hearing before Judge Towbin
Singer via Zoom re: Defendants' motions for summary
judgment and status of case.
2.10AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 2
May 12, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
04/07/22 Preparation of correspondence to Eve Boutsis, City Attorney,
re: outcome of hearing on Defendants' Motion for Summary
Judgment.
0.40AGA
04/07/22 Receipt and review of Defendant, Dania Entertainment's Notice
of Joinder with Defendant, City of Dania Beach’s Reply to
Plaintiff’s Consolidated Response to Defendants’ Motions for
Summary Judgment.
0.20AGA
04/08/22 Preparation of correspondence to Eve Boutsis, City, re:
Co-Defendant, Dania Entertainment Center, LLC’s, Notice of
Joinder in Defendant, City of Dania Beach’s, Reply to Plaintiff’s
Consolidated Response to Defendants’ Motions For Summary
Judgment.
0.30AGA
04/08/22 Communicate/Other External correspondence to Joe Husosky,
regarding his deposition transcript and request to review and
sign errata sheet.
0.40AGA
04/11/22 Correspondence to Corrine LaJoie, City, re: inquiry as to
Pre-Trial meeting taking place in June.
0.20AGA
04/11/22 Correspondence to Joe Husosky, Witness, re: inquiry as to
Pre-Trial meeting taking place in June.
0.20AGA
04/11/22 Receipt and review of correspondence from Corrine LaJoie,
City, re: inquiry as to Pre-Trial meeting taking place in June.
0.20AGA
04/11/22 Correspondence to Hoyt Holden, Witness, and Paula Giordano,
Witness, re: inquiry as to Pre-Trial meeting taking place in
June.
0.20AGA
04/11/22 Correspondence to Tom Schneider, City, re: inquiry as to
Pre-Trial meeting taking place in June.
0.20AGA
04/11/22 Correspondence to Judy Felicetty, Witness, re: inquiry as to
Pre-Trial meeting taking place in June.
0.20AGA
04/11/22 Correspondence to Marc LaFerrier, Witness, re: inquiry as to
Pre-Trial meeting taking place in June.
0.20AGA
04/11/22 Receipt and review of correspondence from Joe Husosky,
Witness, re: inquiry as to Pre-Trial meeting taking place in
June.
0.20AGA
04/11/22 Receipt and review of multiple correspondences to and from
Michael Dutko, Counsel for Plaintiff and John Mullin, Counel for
DEC, re: proposed agreed order indicating trial moving to an
alternate date.
0.30AGA
04/11/22 Receipt and review of correspondence to and from Thomas
Schneider, City, re: pre-trial meeting June prior to trial.
0.30AGA
04/12/22 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: proposed agreed order indicating trial
moving to an alternate date.
0.20AGA
04/12/22 Receipt and review of correspondence to and from Hoyt
Holden, Witness, re: Pre-Trial meeting to discuss case closer to
trial in June.
0.20AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 3
May 12, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
04/12/22 Receipt and review of correspondence from Marc LaFerrier,
Witness, re: advising as to Pre-Trial meeting prior to Trial.
0.20AGA
04/12/22 Correspondence to Marc LaFerrier, Witness, re: additional
inquiry as to Pre-Trial meeting prior to Trial.
0.20AGA
04/13/22 Receipt and review of multiple correspondences to and from
Michael Dutko, Counsel for Plaintiff, and John Mullin, Counsel
for DEC, re: pre trial meeting to discuss case, joint pre trial
stipulation and exhibit exchange.
0.30AGA
04/13/22 Receipt and review of multiple correspondences to and from
Michael Dutko, Counsel for Plaintiff, and John Mullin, Counsel
for DEC, re: advising as to agreement of proposed agreed
order for submission to the court regarding previous hearing to
extend trial.
0.30AGA
04/13/22 Preparation of correspondence to Eve Boutsis, City Attorney,
re: the deposition summary of Arnaldo Suarez.
1.20AGA
04/13/22 Receipt and review of correspondence to and from John Mullin,
Counsel for DEC, re: telephone conference to discuss standing
issue.
0.30AGA
04/14/22 Telephone conference with John Mullin, counsel for DEC,
regarding standing issue and defense strategies.
0.30AGA
04/18/22 Correspondence to Judy Felicetty, Witness, re second
correspondence regarding Pre-Trial meeting to discuss case.
0.20AGA
04/18/22 Correspondence to Eve Boutsis, City, re: inquiry regarding
drafts and final approved 2014 development agreement.
0.20AGA
04/18/22 Receipt and review of correspondence from Eve Boutsis, City,
re: inquiry regarding drafts and final approved 2014
development agreement.
0.20AGA
04/18/22 Receipt and review of multiple documents and emails from Eve
Boutsis, City, re: drafts and final approved 2014 development
agreement (12 total).
1.20AGA
04/18/22 Correspondence to John Mullin, Counsel for DEC, re: inquiry as
to 2014 development agreement with DEC.
0.20AGA
04/18/22 Receipt and review of correspondence from John Mullin,
Counsel for DEC, re: inquiry as to 2014 development
agreement with DEC.
0.20AGA
04/18/22 Correspondence to all counsel, re: inquiry as to proposed order
on trial date being submitted to court.
0.20AGA
04/18/22 Receipt and review of correspondence from Judy Felicetty,
Witness, re: advising as to pre-trial conference prior to trial.
0.20AGA
04/19/22 Receipt and review of Agreed Order on the Continuation of
Trial.
0.20AGA
04/19/22 Preparation of correspondence to Eve Boutsis, City Attorney,
re: executed Agreed Order for the Continuation of Trial.
0.30AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 4
May 12, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
04/19/22 Correspondence to Marc LaFerrier, Witness, re: third inquiry as
to Pre-Trial meeting prior to Trial.
0.20AGA
04/20/22 Correspondence to Paula Giordano, Witness, re: second
correspondence regarding the pre-trial meeting with Paula
Giordano.
0.20AGA
04/20/22 Receipt and review of correspondence from John Mullin,
Counsel for DEC, re: the deposition transcript of Arnaldo
Suarez,DEC representative.
0.20AGA
04/20/22 Receipt and review of the deposition transcript of Arnaldo
Suarez,
0.20AGA
04/20/22 Correspondence to Judge Towbin Singer, re: inquiry as to
Motion for Summary Judgment hearing on Judge's docket.
0.20AGA
04/20/22 Receipt and review of multiple correspondences to and from
John Mullin, Counsel for DEC, and Michael Dutko, Counsel for
Plaintiff, re: corresponding to Judge regarding Defendants
Motions for Summary Judgment.
0.30AGA
04/20/22 Receipt and review of correspondence to and from Marc
LaFerrier, Witness, re: pre-trial meeting to discuss case prior to
trial.
0.20AGA
04/20/22 Receipt and review of Plaintiff's second Notice of Unavailability.0.20AGA
04/20/22 Receipt and review of correspondence from Paula Giordano,
Witness, re: advising as to pre-trial meeting to discuss case
prior to trial.
0.20AGA
04/21/22 Receipt and review of correspondence from Joe Husosky,
Witness, re: executed errata sheet for deposition.
0.20AGA
04/21/22 Correspondence to Joe Husosky, Witness, re: executed errata
sheet for deposition.
0.20AGA
04/22/22 Receipt and review of correspondence to and from John Mullin,
Counsel for DEC, re: inquiry as to timing for a Motion for
Summary Judgment Special Set Hearing.
0.20AGA
04/22/22 Receipt and review of correspondence from Judge Towbin
Singer, re: inquiry as to time request for Motion for summary
Judgment hearing.
0.20AGA
04/22/22 Correspondence to Judge Towbin Singer, re: inquiry as to time
request for Motion for summary Judgment hearing.
0.20AGA
04/22/22 Receipt and review of Court's Order Resetting Trial.0.20AGA
04/25/22 Preparation of correspondence to Eve Boutsis, City re:
executed Order Resetting Trial.
0.30AGA
04/25/22 Receipt and review of correspondence from Eve Boutsis, City
Attorney, re: advising as to attendance for trial.
0.20AGA
04/27/22 Receipt and review of correspondence from Judge Towbin
Singer, re: advising the court is putting all parties on 2 hour
notice for the month of May for the Motion for Summary
Judgment hearings.
0.20AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 5
May 12, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
04/27/22 Receipt and review of correspondence from John Mullin,
Counsel for DEC, to Judge Towbin Singer, re: court is putting
all parties on 2 hour notice for the month of May for the Motion
for Summary Judgment hearings.
0.20AGA
Code AmountHoursRateName
PROFESSIONAL SERVICES SUMMARY
3,690.00180.0020.50AGAAndrea G. Amigo, Partner
Total Professional Services $3,690.0020.50
Date AmountDescription
DISBURSEMENTS
154.60Deposition Transcripts #295869;Joe Husosky video
deposition - United Reporting, Inc.
04/15/22
Total Disbursements $154.60
127,160.50
131,897.09
4,736.59
Fees Billed to Date
Costs Billed to Date
Total Billed to Date
Bill History for this Matter
Case to DateYear to Date
19,326.50
1,300.00
20,626.50
CURRENT BILL TOTAL AMOUNT DUE $3,844.60
Balance Forward:
Payments & Adjustments:-2,949.50
2,949.50
3,844.60Total Due:$
Please return this page with remittance
to
Roberts, Reynolds, Bedard & Tuzzio, PLLC
470 Columbia Drive, Suite C-101
West Palm Beach, Florida 33409
65228Bill Number:
Client Code:155
Client Name:Preferred Governmental Insurance Trust
Bill Date:May 12, 2022
14358
Citizens (2) v. Dania Beach/Mayor Duke
Matter Code:
Matter Name:
CURRENT BILL TOTAL AMOUNT DUE $3,844.60
0.00Past Due Balance
TOTAL AMOUNT DUE
$3,844.60
Balance Forward:
Payments & Adjustments:-2,949.50
2,949.50
3,844.60Total Due:$
Total Professional Services
Total Disbursements 154.60
3,690.00