HomeMy WebLinkAboutInv# 66403 - ROBERTS, REYNOLDS, BEDARD & TUZZIO, PLLC - 07/14/2022ROBERTS, 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 06/30/22
July 14, 2022
Bill No. 66403
HoursDateAttorneyServices
PROFESSIONAL SERVICES
06/02/22 Receipt and review of correspondence to and from John Mullin,
Counsel for DEC, re: inquiry as to Motion in Limine.
0.20AGA
06/06/22 Review/Analyze Review of May 16, 2022 public records request
and documents produced in prior litigation, and subsequent
compilation of responsive documents to current public records
request
1.60AGA
06/06/22 Receipt and review of correspondence to and from Thomas
Schneider, City of Dania Beach and Erika Clayton, City of
Dania Beach, re: video of the August 26, 2014 City Commission
Meeting.
0.20AGA
06/06/22 Receipt and review of video of the August 26, 2014 City
Commission Meeting.
0.50AGA
06/06/22 Receipt and review of multiple correspondences to and from
Erika Clayton, City of Dania Beach, re: executed 9/9/2014
meeting minutes and City commission meeting video.
0.30AGA
06/06/22 Receipt and review of executed 9/9/2014 meeting minutes and
City commission meeting video.
0.40AGA
06/06/22 Receipt and review of multiple correspondences to and from
Eve Boutsis, City Attorney, re: documents being sent to
opposing counsel per their public records request.
0.30AGA
06/06/22 Preparation of correspondence to Michael Dutko, Counsel for
Plaintiff, re: response to public records request to the City of
Dania Beach along with the Sharefile link below with the
responsive documents.
0.40AGA
06/07/22 Correspondence to Michael Dutko, Counsel for Plaintiff and
John Mullin, Counsel for DEC, re: Joint PreTrial Stipulation and
Exhibit Exchange zoom conference.
0.20AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 2
July 14, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
06/07/22 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: Joint PreTrial Stipulation and Exhibit
Exchange zoom conference.
0.20AGA
06/07/22 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: receipt of response to public records
request.
0.10AGA
06/07/22 Receipt and review of multiple correspondences to and from
John Mullin, Counsel for DEC, re: hearing on Motion's for
Summary Judgment.
0.30AGA
06/07/22 Correspondence to Ms. Bordy, City of Dania Beach, re: link to
agendas with backup for the public hearings before the City
Commission on 8/26/14, 9/23/14, and 10/14/14.
0.20AGA
06/07/22 Correspondence to Thomas Schneider, City of Dania Beach,
re: PDF versions of the agendas for the 8/26/14 and 10/14/14
meetings.
0.20AGA
06/07/22 Receipt and review of correspondence to and from Michael
Dutko, Counsel for Plaintiff, re: correspondence to judge re:
Defendant's Motions for Summary Judgment.
0.20AGA
06/07/22 Correspondence to Michael Dutko, Counsel for Plaintiff, re:
response to public records request directed to Thomas
Schneider, City of Dania Beach.
0.20AGA
06/07/22 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: response to public records request
directed to Thomas Schneider, City of Dania Beach.
0.20AGA
06/07/22 Receipt and review of correspondence from Thomas
Schneider, City of Dania Beach, re: 2014 meetings and
documents referring to same.
0.20AGA
06/08/22 Correspondence to Hoyt Holden, and Paula Giordano,
Witnesses, re: inquiry on email correspondence containing
documents from March 2021.
0.20AGA
06/08/22 Attendance at pre-trial meeting with Plaintiff’s counsel, Michael
Dutko, and Co-Defendant’s counsel, John Mullin, via ZOOM.
1.00AGA
06/08/22 Receipt and review of multiple correspondences to and from
Hoyt Holden, and Paula Giordano, Witnesses, re: inquiry on
email correspondence containing documents from March 2021.
0.20AGA
06/08/22 Receipt and review of correspondence to and from John Mullin,
Counsel for DEC, re: any documents showing the thousands of
mailed notices sent to City residents.
0.20AGA
06/08/22 Correspondence to John Mullin, Counsel for DEC, re:
documents for review relating to 2014 Public Records Request
case.
0.20AGA
06/08/22 Receipt and review of correspondence from John Mullin,
Counsel for DEC, re: documents for review relating to 2014
Public Records Request case.
0.20AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 3
July 14, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
06/08/22 Correspondence to Thomas Schneider, and Erika Clayton, City
of Dania Beach, re: request for audio or video fro the August
2011 hearing.
0.20AGA
06/08/22 Receipt and review of correspondence from Thomas
Schneider, and Erika Clayton, City of Dania Beach, re: request
for audio or video fro the August 2011 hearing.
0.20AGA
06/08/22 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: link to exhibits for trial.
0.20AGA
06/08/22 Receipt and review of Plaintiff's exhibits for trial (36 items).5.20AGA
06/08/22 Preparation of Defendant, City of Dania Beach's Exhibit List.3.00AGA
06/09/22 Receipt and review of correspondence to and from John Mullin,
Counsel for DEC, re: public records request 2014 in response
to public records requests.
0.20AGA
06/10/22 Correspondence to Hoyt Holden, Witness for City, re: request
for similar screenshot or records showing the total # of notices
and cost of the notices sent out for the 9/23/14 hearing
0.20AGA
06/10/22 Correspondence to John Mullin, Counsel for DEC, re: addition
to City's exhibits for trial.
0.20AGA
06/10/22 Extensive telephone conference with Co-Defendant’s counsel,
John Mullin, regarding exhibits for trial and defense strategies.
0.40AGA
06/10/22 Correspondence to Michael Dutko, Counsel for Plaintiff, re:
request to circulate draft of Joint Pre Trial Stipulation to all
parties for review.
0.20AGA
06/10/22 Receipt and review of multiple correspondences to and from
Hoyt Holden, Witness for City, re: huge mailout undertaking for
the Dania Entertainment Center (DEC) project and recoup the
postage and records relating to same.
0.30AGA
06/13/22 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: proposed joint pre-trial stipulation for
review.
0.20AGA
06/13/22 Receipt and review of proposed joint pre-trial stipulation.0.20AGA
06/16/22 Correspondence to Marc LaFerrier, Witness, re: Pre-trial zoom
meeting.
0.20AGA
06/16/22 Receipt and review of correspondence from Marc LaFerrier,
Witness, re: Pre-trial zoom meeting.
0.20AGA
06/16/22 Receipt and review of correspondence to and from Erika
Clayton, City of Dania Beach, re: link to the video of the
8/23/2011 City Commission Meeting.
0.20AGA
06/16/22 Receipt and review of link to the video of the 8/23/2011 City
Commission Meeting.
1.50AGA
06/17/22 Receipt and review of correspondence to and from Erika
Clayton, City of Dania Beach, re: lobbyist forms being posted
on the City’s website.
0.20AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 4
July 14, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
06/17/22 Attendance at pretrial meeting with Marc Laferrier, former
Community Development Director, via ZOOM.
1.20AGA
06/17/22 Receipt and review of correspondence from Erika Clayton, City
of Dania Beach, re: request for record showing what
documents were produced to Conrad & Scherer on 8/25/14.
0.20AGA
06/17/22 Receipt and review of correspondence from Erika Clayton, City
of Dania Beach, re: request for record showing what
documents were produced to Conrad & Scherer on 8/25/14.
0.20AGA
06/17/22 Receipt and review of record showing what documents were
produced to Conrad & Scherer on 8/25/14.
0.80AGA
06/17/22 Receipt and review of additional correspondence to and from
Erika Clayton, City of Dania Beach, re: copy of what was
produced to Conrad & Scherer on 8/25/14.
0.20AGA
06/21/22 Receipt and review of correspondence from Erika Clayton, City
of Dania Beach, re: dates the lobbyist forms were posted on the
City’s website and data sheets for review.
0.20AGA
06/21/22 Receipt and review of dates the lobbyist forms were posted on
the City’s website and data sheets.
0.70AGA
06/22/22 Correspondence to Joe Husosky, Witness, re: Pre-Trial zoom
conference.
0.10AGA
06/22/22 Receipt and review of correspondence to and from Joe
Husosky, Witness, re: pre-trial zoom conference.
0.10AGA
06/22/22 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: additional correspondence relating to
proposed Joint Pre-Trial Stipulation and exhibits for trial.
0.20AGA
06/22/22 Correspondence to Michael Dutko, Counsel for Plaintiff, re:
advising as to status of proposed Joint Pre-Trial Stipulation and
exhibits for trial.
0.20AGA
06/23/22 Correspondence to Thomas Schneider, City of Dania Beach,
re: pre-trial zoom meeting.
0.10AGA
06/23/22 Correspondence to Corrine LaJoie, City of Dania Beach, re:
pre-trial zoom meeting.
0.10AGA
06/23/22 Receipt and review of Motion to Appear Pro Hac Vice for Eric
Hager.
0.20AGA
06/23/22 Receipt and review of correspondence from Thomas
Schneider, City of Dania Beach, re: pre-trial zoom meeting.
0.10AGA
06/23/22 Preparation of correspondence to Eve Boutsis, City Attorney,
re: Motion for Admission to Appear Pro Hac Vice Pursuant to
Florida Rule of Judicial Administration 2.510.
0.30AGA
06/23/22 Review of file materials and revisions to proposed Joint Pretrial
Stipulation.
2.20AGA
06/23/22 Correspondence to John Mullin, Counsel for DEC, re: proposed
revisions to the Joint Pretrial Stipulation for review and input.
0.20AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 5
July 14, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
06/23/22 Receipt and review of correspondence from John Mullin,
Counsel for DEC, re: receipt of proposed revisions to the Joint
Pretrial Stipulation for review and input.
0.20AGA
06/23/22 Correspondence to John Mullin, Counsel for DEC, re: proposed
trial exhibit list and exhibits for review and input.
0.20AGA
06/23/22 Receipt and review of correspondence to and from Eve Boutsis,
City Attorney, re: trial docket appearance and discussion of
calendar call.
0.20AGA
06/23/22 Receipt and review of multiple correspondences to and from
John Mullin, Counsel for DEC, re: proposed joint pretrial
stipulation and exhibit list for review and approval.
0.30AGA
06/23/22 Receipt and review of Court's Executed Order on Plaintiff's
Motion for Admission to Appear Pro Hac Vice Pursuant to
Florida Rule of Judicial Administration 2.510.
0.20AGA
06/24/22 Correspondence to Thomas Schneider, City of Dania Beach,
re: exhibits to deposition of Thomas Schneider.
0.20AGA
06/24/22 Receipt and review of correspondence to and from John Mullin,
Counsel for DEC, re: two declarations contained in the 2 boxes
that Frevola presented to the City Commission at the 10-14-14
public hearing as exhibits.
0.20AGA
06/24/22 Correspondence to Thomas Schneider, City of Dania Beach,
re: Declarations and Affidavits executed by Thomas Schneider.
0.20AGA
06/24/22 Correspondence to John Mullin, Counsel for DEC, re: additional
revisions to the Joint PTS.
0.20AGA
06/24/22 Attendance at pretrial meeting with Thomas Schneider, City
Clerk, via ZOOM.
1.00AGA
06/24/22 Draft/Revise additional revisions to Joint Pretrial Stipulation and
exhibit list to incorporate proposed revisions of Co-Defendant
DEC and additional exhibits and City’s statement of facts.
2.90AGA
06/24/22 Continued receipt and review of correspondence to and from
John Mullin, Counsel for DEC, re: advising as to additional
review and revisions to the Joint Pre-Trial Stipulation.
0.20AGA
06/25/22 Review/Analyze detailed analysis and line-by-line comparison
of draft Second Amended and Restated Development
Agreement published on City’s website prior to 8/26/14, 9/9/14,
9/23/14 and 10/14/14 public hearings.
4.80AGA
06/26/22 Research City’s Code of Ordinances and download City Code
Sections 725-30 and 115-60 referenced in 2014 development
agreement.
0.30AGA
06/26/22 Review/Analyze detailed analysis and line-by-line comparison
of draft Second Amended and Restated Development
Agreement published online prior to 10/14/14 public hearing
and the development agreement approved and recorded on
11/6/14.
1.90AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 6
July 14, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
06/26/22 Review/Analyze detailed analysis of file materials including the
deposition transcripts of Corrine Lajoie in 2011 and 2014 cases
in preparation of upcoming pretrial meeting with Connie Lajoie.
2.80AGA
06/26/22 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: advising as to proposed issues to
exhibits for trial.
0.20AGA
06/27/22 Correspondence to Hoyt Holden, and Paula Giordano,
Witnesses, re: pre-trial zoom conferences.
0.20AGA
06/27/22 Preparation of Defendant, City of Dania Beach's, Subpoena for
Trial pertaining to Plaintiff, Citizens for Responsible
Development, directed to Louise Stilson.
0.60AGA
06/27/22 Preparation of Defendant, City of Dania Beach's, Subpoena for
Trial pertaining to Plaintiff, Citizens for Responsible
Development, directed to Paula Giordano.
0.60AGA
06/27/22 Preparation of Defendant, City of Dania Beach's, Subpoena for
Trial pertaining to Plaintiff, Citizens for Responsible
Development, directed to Hoyt Holden.
0.60AGA
06/27/22 Receipt and review of correspondence from Hoyt Holden,
Witness, re: pre-trial zoom conferences.
0.20AGA
06/27/22 Attendance at pretrial meeting via ZOOM with Corrine Lajoie,
City Planner.
1.00AGA
06/27/22 Correspondence to Corinne Lajoie, City of Dania Beach, re:
documents for review for upcoming trial.
0.20AGA
06/27/22 Continued receipt and review of correspondence from Hoyt
Holden, Witness, re: pre-trial zoom conferences.
0.20AGA
06/27/22 Preparation of correspondence to Eve Boutsis, City Attorney,
re: Court's Executed Order Granting Plaintiff's Motion for
Admission to Appear Pro Hac Vice Pursuant to Florida Rule of
Judicial Administration 2.510.
0.30AGA
06/27/22 Receipt and review of correspondence from Corinne Lajoie,
City of Dania Beach, re: documents for review for upcoming
trial and continued conference.
0.20AGA
06/27/22 Receipt and review of multiple correspondences to and from
John Mullin, Counsel for DEC, and Michael Dutko, Counsel for
Plaintiff, re: motion for extension of time for exhibit list and joint
pre trial stipulation.
0.20AGA
06/27/22 Continued receipt and review of multiple correspondences to
and from John Mullin, Counsel for DEC, and Michael Dutko,
Counsel for Plaintiff, re: motion for extension of time for exhibit
list and joint pre trial stipulation.
0.20AGA
06/27/22 Receipt and review of Joint Motion for Extension of Time of
Trial Deadlines.
0.20AGA
06/27/22 Review/Analyze detailed analysis of file materials in preparation
for upcoming pretrial meetings with Hoyt Holden and Paula
Giordano.
2.30AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 7
July 14, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
06/28/22 Correspondence to Judy Felicetty, City Witness, re: pre-trial
zoom conference,
0.20AGA
06/28/22 Correspondence to Michael Dutko, Counsel for Plaintiff, and
John Mullin, Counsel for DEC, re: exhibits for trial and
enclosing exhibit 28.
0.20AGA
06/28/22 Receipt and review of correspondence to and from Paula
Giordano, Witness, re: zoom link for meeting.
0.10AGA
06/28/22 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: calendar call and potential setting
hearing on motion calendar.
0.20AGA
06/28/22 Receipt and review of Judge Towbin Singer's Calendar Call
form.
0.20AGA
06/28/22 Correspondence to Michael Dutko, Counsel for Plaintiff, re:
calendar call and potential setting hearing on motion calendar.
0.20AGA
06/28/22 Receipt and review of correspondence from Judy Felicetty, City
Witness, re: pre-trial zoom conference.
0.10AGA
06/28/22 Receipt and review of correspondence from Hoyt Holden, City
Witness, to Jesus Cruz, Accounting for Broward County, re:
record of mailing for the May 14, 2014, Community Meeting at
Frost Park.
0.20AGA
06/28/22 Receipt and review of correspondence from Jesus Cruz,
Accounting for Broward County, re: record of mailing for the
May 14, 2014, Community Meeting at Frost Park.
0.20AGA
06/28/22 Correspondence to Hoyt Holden, City Witness, to Jesus Cruz,
Accounting for Broward County, re: record of mailing for the
May 14, 2014, Community Meeting at Frost Park.
0.20AGA
06/28/22 Receipt and review of record of mailing for the May 14, 2014,
Community Meeting at Frost Park.
0.60AGA
06/28/22 Attendance at pretrial meeting with Hoyt Holden, with Calvin
Giordano & Associates, via ZOOM.
1.40AGA
06/28/22 Attendance at pretrial meeting with Paula Giordano, with CGA,
via ZOOM.
1.20AGA
06/28/22 Receipt and review of Notice of Hearing on Case Status for July
5, 2022.
0.20AGA
06/28/22 Preparation of correspondence to Eve Boutsis, City Attorney,
re: Notice of Hearing for Case Status.
0.60AGA
06/28/22 Review/Analyze detailed analysis of file materials including
public records requests, City's responses, notices of public
hearings in 2014 in preparation for upcoming pretrial meeting
with Judy Felicetty, former City Records Clerk.
1.00AGA
06/29/22 Receipt and review of correspondence from Michael Dutko,
Counsel for Plaintiff, re: inquiry as to hearing for case status
conference.
0.20AGA
Preferred Governmental Insurance Trust
Matter: 14358 - Citizens (2) v. Dania Beach/Mayor Duke Page 8
July 14, 2022Client:
HoursDateAttorneyServices
PROFESSIONAL SERVICES
06/29/22 Continued multiple correspondences from Michael Dutko,
Counsel for Plaintiff, and John Mullin, Counsel for DEC, re:
hearing for case status conference.
0.30AGA
06/29/22 Attendance at pretrial meeting with Judy Felicetty, former City
Records Clerk, via zoom.
1.40AGA
Code AmountHoursRateName
PROFESSIONAL SERVICES SUMMARY
136.0085.001.60AGAAndrea G. Amigo, Partner
10,494.00180.0058.30AGAAndrea G. Amigo, Partner
Total Professional Services $10,630.0059.90
Date AmountDescription
DISBURSEMENTS
35.12Witness Fees Witness fee. - Louise Stilson06/24/22
7.50Witness Fees Witness Fee. - Hoyt Holden06/24/22
7.50Witness Fees Witness fee. - Paula Giordano06/24/22
Total Disbursements $50.12
138,240.50
143,027.21
4,786.71
Fees Billed to Date
Costs Billed to Date
Total Billed to Date
Bill History for this Matter
Case to DateYear to Date
30,406.50
1,350.12
31,756.62
CURRENT BILL TOTAL AMOUNT DUE $10,680.12
Balance Forward:
Payments & Adjustments:-450.00
450.00
10,680.12Total Due:$
Please return this page with remittance
to
Roberts, Reynolds, Bedard & Tuzzio, PLLC
470 Columbia Drive, Suite C-101
West Palm Beach, Florida 33409
66403Bill Number:
Client Code:155
Client Name:Preferred Governmental Insurance Trust
Bill Date:July 14, 2022
14358
Citizens (2) v. Dania Beach/Mayor Duke
Matter Code:
Matter Name:
CURRENT BILL TOTAL AMOUNT DUE $10,680.12
0.00Past Due Balance
TOTAL AMOUNT DUE
$10,680.12
Balance Forward:
Payments & Adjustments:-450.00
450.00
10,680.12Total Due:$
Total Professional Services
Total Disbursements 50.12
10,630.00