Item R2
BOARD OF COUNTY COMMISSIONERS
AGENDA ITEM SUMMARY
Meeting Date:
December 15, 2003
Division: County Attorney
AGENDA ITEM WORDING:
Authorization for payment of invoice from Ferencik Libanoff Brandt Bustamante & Williams
in the amount of $44,384.96 for October, 2003, for the defense of the County in the
litigation of Lodge Construction.
ITEM BACKGROUND:
This law firm specializing in construction litigation, represents Monroe County in several
disputes related to County construction projects. This lawsuit was brought by the County's
initial contractor on the Gato Bldg. renovation; Lodge abandoned the job and then sued.
PREVIOUS RELEVANT BOCC ACTION:
N/A
CONTRACT I AGREEMENT CHANGES:
N/A
STAFF RECOMMENDATIONS:
Authorize payment,
TOTAL COST:
COST TO COUNTY:
BUDGETED: Yes 0
No 0
APPROVED BY: County Attorney _ OMB/Purchasing 0 Risk Management 0
DIVISION DIRECTOR APPROVAL:nOlft ~ 12-102-10;'
===r J.R.Collins
DOCUMENTATION:
Included D!J
To Follow 0
Not Required 0
AGENDA ITEM # --&2-
FERENCIK LIBANOFF BRANDT BUSTAMANTE & WILLIAMS, P.A.
Attorneys at Law
Federal Tax 1.0. #65-0193780
150 South Pine Island Road
Suite #400
Fort Lauderdale, Florida 33324
Dade (305) 949-8003
Broward (954) 474-8080
MONROE COUNTY
C/O JOHN R. COLLINS-COUNTY ATTORNEY
PO BOX 1026
KEY WEST FL 33041-1026
Page: 1
11/20/03
MATTER NO: 864-0002M
STATEMENT NO: 43
ATTN: JOHN R. COLLINS
LODGE CONSTRUCTION
PREVIOUS BALANCE
$21,284009
10/03/03
AVP CONFERENCE WITH JANET RITENBAUGH RE: TRIAL
PREPARATION - DOCUMENTS/MATERIALS TO BE SENT TO
MONROE COUNTY'S EXPERT WITNESSES
HOURS
1.00
75.00
10/07/03
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT _
MEET WITH IRA LIBANOFF AND JANET RITENBAUGH RE:
TRIAL PREPARATION, UPCOMING DEPOSITIONS, AND
DOCUMENT PRODUCTION 1.00
JER TELEPHONE CONFERENCE (X2)WITH BARRY BROWER, DELAY
EXPERT, RE: TESTIMONY .60
ILL DRAFT AND PREPARE LETTER TO ATTY DARYL BROWN RE
REVIEW OF D,L. PORTER DOCUMENTS AND NOTICE OF
DEPOSITION OF RECORDS CUSTODIAN ,30
75.00
120.00
67.50
10/08/03
HGS TELEPHONE CONFERENCE WITH JANET RITENBAUGH
REGARDING RESEARCH ON WHETHER ONE CAN DESIGNATE
CORPORATE REPRESENTATIVE FOR DEPOSITION ON LEGAL
AFFIRMATIVE DEFENSES OF ENTITY. .30
45.00
~
LODGE CONSTRUCTION
Page: 2
11/20/03
MATTER NO: 864-0002M
STATEMENT NO: 43
MONROE COUNTY
HGS RESEARCHED AND ANALYZED CASE LAW AND FLORIDA
RULES OF CIVIL PROCEDURE REGARDING WHETHER
CORPORATE REPRESENTATIVE CAN BE DESIGNATED FOR
DEPOSITION REGARDING LEGAL AFFIRMATIVE DEFENSES
OF CORPORATION, 2.40 360.00
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT _
ARRANGE FOR HOTEL ACCOMMODATIONS DURING THE TRIAL
IN THIS MATTER 1.00 75.00
JER DRAFT AND PREPARE MOTION FOR SUMMARY JUDGMENT 8.00 1,600.00
HOURS
10/09/03
AVP (A101) - PLAN AND PREPARE FOR DOCUMENT REVIEW AT
DL PORTER - SELECT AND REVIEW PERTINENT DOCUMENTS
TO ASSIST AT THE DOCUMENT REVIEW; ARRANGE TRAVEL
PLANS, CAR RENTAL, OBTAIN DIRECTIONS 2.50 187.50
AVP (A101) - PLAN AND PREPARE F9R FILING MONROE
COUNTY'S MOTION FOR SUMMARY JUDGMENT - REVIEW
PLEADINGS TO CONFIRM THAT DEPOSITION TRANSCRIPTS
WERE PREVIOUSLY FILED WITH THE COURT 1.00 75.00
JER COMPLETE MOTION FOR SUMMARY JUDGMENT; DRAFT AND
FINALIZE MOTION IN LIMINE 9.00 1,800.00
ILL TELEPHONE CONFERENCES WITH ATTY KASHTAN (BENDER)
RE HIS SETTLEMENT DISCUSSION WITH ATTY WOODSON,
AND WITH MEDIATOR FREUD RE HIS CONTINUING
CONVERSATIONS RE SETTLEMENT .50 112.50
10/10/03
AVP (A109) - APPEAR FOR / ATTEND DOCUMENT REVIEW AT
DL PORTER CONSTRUCTORS IN SARASOTA, FLORIDA;
REVIEW DOCUMENTS RE: MONROE COUNTY AND THE
DEPARTMENT OF HEALTH - TAG PERTINENT DOCUMENTS TO
BE COPIED FOR USE AT THE UPCOMING DL PORTER
DEPOSITIONS AND FOR USE AT TRIAL 12.00 900,00
JER CONFERENCES (2) WITH ANNA PETERSON RE TRIAL PREP .60 120.00
10/13/03
HGS REVIEW OF MONROE COUNTY'S MOTION FOR SUMMARY
JUDGMENT AND SUPPORTING DOCUMENTS IN PREPARATION
FOR DEPOSITION. .80 120,00
HGS CONFERENCE WITH JANET RITENBAUGH REGARDING
DOCUMENT AUTHENTICATION AT DEPOSITIONS OF JOHNNY
MONROE COUNTY
Page: 3
11/20/03
MATTER NO: 864-0002M
STATEMENT NO: 43
LODGE CONSTRUCTION
HOURS
RODRIGUEZ AND GARY LOER. .60 90.00
AVP (A101) - PLAN AND PREPARE FOR THE DEPOSITIONS OF
JOHNNY RODRIGUEZ AND GARY LOER (DL PORTER) -
CATEGORIZE DOCUMENTS PRODUCED BY DL PORTER AT THE
10/10/03 DOCUMENT REVIEW FOR USE BY HUDSON SAMSON
AT THE UPCOMING DEPOSITIONS AND FOR USE AT THE
TRIAL IN THIS MATTER; PREPARE GENERAL INDEX OF
DOCUMENTS PRODUCED 4,50 337,50
AVP (E114) - EXPERT WITNESS - COMPILE
DOCUMENTS/MATERIALS FOR JANET RITENBAUGH'S USE AT
HER MEETING WITH MONROE COUNTY'S EXPERT, JOE
MASULLO; COMPILE DOCUMENTS FOR REVIEW BY JOE
MASULLO TO ASSIST HIM IN PREPARING TO TESTIFY AT
HIS DEPOSITION AND THE TRIAL IN THIS MATTER 2.00 150,00
JER REVIEW DOCUMENTS PRODUCED BY DL PORTER 6,50 1,300,00
ILL TELEPHONE CONFERENCE WITH ATTY WOODSON RE
SETTLEMENT ISSUES .40 90.00
10/14/03
AVP TELEPHONE CONFERENCE WITH JANET RITENBAUGH RE:
PREPARATION OF MATERIALS FOR MONROE COUNTY'S
EXPERT WITNESSES .20 15.00
AVP TELEPHONE CONFERENCE WITH BARRY BROWER'S OFFICE
(LEAVE MESSAGE) RE: DOCUMENTS/MATERIALS TO BE
REVIEWED BY HIM IN ANTICIPATION OF THE UPCOMING
TRIAL .10 7.50
AVP TELEPHONE CONFERENCE WITH SANDY IN FRED
SALINERO'S OFFICE (MONROE COUNTY'S EXPERT
WITNESS) RE: THE UPCOMING TRIAL DATE, HIS
AVAILABILITY FOR DEPOSITION, AND HIS AVAILABILITY
FOR A PHONE CONFERENCE WITH IRA LIBANOFF AND
JANET RITENBAUGH .20 15,00
AVP (E114) - EXPERT WITNESS CONTINUE COMPILATION OF
DOCUMENTS/MATERIALS TO BE PROVIDED TO MONROE
COUNTY'S EXPERTS, BARRY BROWER, JOE MASULLO, AND
FRED SALINERO TO ASSIST THEM IN PREPARING FOR
THEIR UPCOMING DEPOSITIONS AND THE TRIAL IN THIS
MATTER 3.00 225,00
LJG REVIEW & OUTLINE DEPO OF STEPHEN W. PIAZZA TAKEN
ON 12/12/01 IN PREPARATION OF UPCOMING TRIAL, 3,00 225.00
AVP TELEPHONE CONFERENCE WITH JANET RITENBAUGH RE:
Page: 4
11/20/03
MATTER NO: 864-0002M
STATEMENT NO: 43
MONROE COUNTY
LODGE CONSTRUCTION
HOURS
STATUS OF DOCUMENTS FOR USE AT THE DL PORTER
DEPOSITIONS ,20
AVP (EI14) - EXPERT WITNESS - COMPILE MATERIALS TO BE
PROVIDED TO JANET RITENBAUGH - TO ASSIST HER IN
PREPARING A SPREADSHEET FOR MONROE COUNTY'S
EXPERT, FRED SALINERO 1,00
HGS DOCUMENT REVIEW IN PREPARATION FOR D,L, PORTER
DEPOSITIONS. 4.60
HGS TELEPHONE CONFERENCE WITH JANET RITENBAUGH
REGARDING DOCUMENTS TO BE AUTHENTICATED AT D,L
PORTER DEPOSITIONS, .40
AVP TELEPHONE CONFERENCE WITH BARRY BROWER RE:
DEPOSITION/TRIAL PREPARATION .20
HGS TRAVEL TO SARASOTA TO ATTEND D.L. PORTER
DEPOSITIONS. 3.20
JER DRAFT AND PREPARE EXCEL SP~EADSHEET OF COMPARISON
BETWEEN LODGE'S BUDGET AND ACTUAL JOB COSTS 1.00
JER TELEPHONE CONFERENCE WITH HUDSON SAMSON, ESQ. RE:
DEPOSITIONS OF DL PORTER .30
ILL TELEPHONE CONFERENCE WITH ATTY WOODSON RE
SETTLEMENT ISSUES AND RE JURY TRIAL .30
ILL CONFERENCE WITH ASSOCIATE RE PREPARATION FOR
DEPOS OF D,L, PORTER WITNESSES; REVIEW DOCUMENTS
TO BE IDENTIFIED BY D.L. PORTER REPRESENTATIVES;
REVIEW DOCUMENTS RE TRIAL EXHIBITS 1.50
10/15/03
LJG REVIEW & OUTLINE DEPO OF STEPHEN W. PIAZZA TAKEN
ON 12/12/01 IN PREPARATION OF UPCOMING TRIAL. 6,75
AVP (EI14) - EXPERT WITNESS - COMPILE
DOCUMENTS/MATERIALS FOR MONROE COUNTY'S EXPERT,
BARRY BROWER TO ASSIST HIM IN PREPARING FOR HIS
DEPOSITION AND THE UPCOMING TRIAL IN THIS MATTER 2.40
AVP (EI14) - EXPERT WITNESS - COMPILE
DOCUMENTS/MATERIALS FOR MONROE COUNTY'S EXPERT,
JOE MASULLO TO ASSIST HIM IN PREPARING FOR HIS
DEPOSITION AND THE UPCOMING TRIAL IN THIS MATTER 1,70
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT -
COMPILE DOCUMENTS/MATERIALS FOR USE AS TRIAL
EXHIBITS AND IN ANTICIPATION OF FILING MONROE
COUNTY'S TRIAL EXHIBIT LIST 2.00
15.00
75.00
690.00
60.00
15,00
480.00
200.00
60.00
67.50
337,50
506.25
180.00
127.50
150.00
MONROE COUNTY
Page: 5
11/20/03
MATTER NO: 864-0002M
STATEMENT NO: 43
LODGE CONSTRUCTION
AVP DRAFT AND PREPARE LETTER TO LETTER TO MONROE
COUNTY'S EXPERT, BARRY BROWER, OUTLINING THE
ENCLOSED DOCUMENTS/MATERIALS FOR HIS REVIEW ,20 15.00
AVP CONFERENCE WITH MONROE COUNTY'S EXPERT, BARRY
BROWER - PROVIDE HIM WITH DOCUMENTS/MATERIALS FOR
HIS REVIEW TO ASSIST HIM IN PREPARING FOR HIS
DEPOSITION AND TRIAL .30 22,50
HGS ATTENDED DEPOSITIONS OF JOHNNY RODRIGUEZ AND GARY
LOER. 6.80 1,020.00
HGS RETURN TRAVEL FROM SARASOTA, 3.20 480,00
JER TELEPHONE CONFERENCE WITH HUDSON SAMSON (X2) RE:
DEPOSITION OF DL PORTER REPRSENTATIVES .60 120,00
JER TELEPHONE CONFERENCE WITH LARRY MARGOLIES, ESQ.,
RE: DEPOSITIONS OF DL PORTER REPRESENTATIVES .40 80.00
HOURS
10/16/03
LJG REVIEW & OUTLINE DEPO OF STEPHEN PIAZZA IN
PREPARATION FOR UPCOMING TRIAL. 1.50 112.50
AVP TELEPHONE CONFERENCE WITH LARRY MARGOLIS RE:
PRE-TRIAL STATEMENT .10 7.50
AVP DRAFT AND PREPARE FACSIMILE TO LARRY MARGOLIS
FORWARDING THE PREVIOUSLY FILED PRE-TRIAL
STATEMENT .20 15.00
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT _
REVIEW TRIAL EXHIBIT LIST PREVIOUSLY FILED BY
MONROE COUNTY - DELETE "BLANKS" - INCORPORATE
EXHIBITS PREVIOUSLY LISTED ON MONROE'S
SUPPLEMENTAL EXHIBIT LIST (IN ANTICIPATION OF
FILING SAME WITH THE COURT) 5,70 427.50
ILL TELEPHONE CONFERENCES WITH STEVE PIAZZA RE
DEPOSITION AND RE TRIAL DATES AND TRIAL TESTIMONY .40 90.00
ILL RECEIPT/REVIEW LTR FROM ATTY WOODSON RE
DEPOSITIONS THAT NEED TO BE COMPLETED ,10 22.50
10/17/03
LJG REVIEW & OUTLINE DEPO OF STEPHEN PIAZZA IN
PREPARATION FOR UPCOMING TRIAL. 3.75 281.25
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT _
CONTINUE REVISIONS TO MONROE COUNTY'S TRIAL
EXHIBIT LIST - IN ANTICIPATION OF FILING SAME
WITH THE COURT 4.00 300.00
Page: 6
11/20/03
MATTER NO: 864-0002M
STATEMENT NO: 43
MONROE COUNTY
LODGE CONSTRUCTION
HOURS
10/18/03
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT _
CONTINUE MAKING REVISIONS TO MONROE COUNTY'S
TRIAL EXHIBIT LIST (AS PER JANET RITENBAUGH'S
NOTES) IN ANTICIPATION OF FILING SAME WITH THE
COURT 4,50
ADC (A101) - PLAN AND PREPARE FOR ORGANIZATION OF
REVISIONS TO TRIAL EXHIBIT LIST AND PROCESSING OF
NEW LABELS 2.00
ADC (L140) - DOCUMENT / FILE MANAGEMENT - COMPILING
OF DOCUMENTS FOR EXPERTS IN PREPARATION OF
UPCOMING TRIAL 2.00
JER TRIAL/HEARING PREPARATION : WORK ON EXHIBITS AND
TRIAL PREPARATION 4.00
10/20/03
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT _
CONTINUE PREPARATION OF MONROE COUNTY'S TRIAL
EXHIBIT LIST - AMEND LIST TO ADD ADDITIONAL
DOCUMENTS/MATERIALS (SPECIFICALLY DOCUMENTS
RECENTLY PRODUCED BY DL PORTER) 5.30
ADC (L140) - DOCUMENT / FILE MANAGEMENT - COMPILING
OF ADDITIONAL TRIAL EXHIBITS THAT WERE
SUPPLEMENTED TO THE ORIGINAL TRIAL EXHIBIT LIST 2.00
ILL TRIAL/HEARING PREPARATION - REVIEW PREVIOUSLY
PREPARED UNILATERAL PRETRIAL STIPULATION, REVIEW
NEW MOTION FOR SUMMARY JUDGMENT AND MOTION IN
LIMINE AND CORRELATE AND REVISE PRETRIAL STIP;
T/C/W/ATTY WOODSON RE JOINT OR UNILATERAL
PRETRIAL STIPULATIONS 1.00
ILL TELEPHONE CONFERENCE WITH STEPHANIE RE DEPOSITION
BY LODGE AND RE STATUS OF SETTLEMENT DISCUSSIONS .20
10/21/03
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT -
COMPLETE MONROE COUNTY'S EXHIBIT LIST (ADD
ADDITIONAL DOCUMENTS/MATERIALS TO LIST -
SPECIFICALLY ADDITIONAL DOCUMENTS REVIEWED BY
MONROE COUNTY'S EXPERTS)
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT -
REVIEW/REVISE MONROE COUNTY'S PREVIOUSLY FILED
5.00
337.50
100.00
100.00
800,00
397.50
100.00
225,00
45.00
375.00
Page: 7
11/20/03
MATTER NO: 864-0002M
STATEMENT NO: 43
MONROE COUNTY
LODGE CONSTRUCTION
HOURS
WITNESS LIST - IN ANTICIPATION OF FILING REVISED
LIST WITH THE COURT .40
ADC (L140) - DOCUMENT / FILE MANAGEMENT - CONTINUED
COMPILING OF ADDITIONAL TRIAL EXHIBITS THAT WERE
SUPPLEMENTED TO THE ORIGINAL TRIAL EXHIBIT LIST 2.00
ILL TELEPHONE CONFERENCE WITH ATTY WOODSON RE
PRETRIAL STIPULATION AND DRAFT AND PREPARE AND
FINALIZE PRETRIAL STIPULATION, WITNESS AND
EXHIBIT LISTS 1.00
10/22/03
AVP TELEPHONE CONFERENCE WITH MONROE COUNTY'S EXPERT,
BARRY BROWER - RE: THE STATUS OF HIS DEPOSITION .20
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT _
BEGIN REVIEW OF DOCUMENTS MARKED AS TRIAL
EXHIBITS - PREPARE IN CHRONOLOGICAL ORDER FOR
MARKING WITH TRIAL EXHIBIT LABELS (IN
ANTICIPATION OF THE UPCOMING TRIAL IN THIS
MATTER) 4.30
ADC (L140) - DOCUMENT / FILE MANAGEMENT - CONCLUDED
COMPILING OF ADDITIONAL TRIAL EXHIBITS THAT WERE
SUPPLEMENTED TO THE ORIGINAL TRIAL EXHIBIT LIST 3.00
10/23/03
ADC (L140) - DOCUMENT / FILE MANAGEMENT _
ORGANIZATION OF TRIAL EXHIBITS INTO PROPER ORDER
PER REVISIONS WITH NEW LABEL BY CROSS-REFERENCING
WITH PREVIOUS TRIAL EXHIBIT LIST AND EXHIBITS 7.00
JER TRIAL/HEARING PREPARATION 3.50
ILL TRIAL/HEARING PREPARATION - CONFERENCE WITH ATTY
RITENBAUGH RE TRIAL PREP,; T/C/W/JOE MASSULLO RE
TRIAL PREP.; 1.00
10/24/03
LJG TELEPHONE CONFERENCE WITH JANET RITENBAUGH, ESQ"
REGARDING FINDING' OUT ABOUT A NEW ELMO FOR OUR
OFFICE,
LJG TELEPHONE CONFERENCE WITH MARY LOU AT MR,
SIEGFRIED'S OFFICE REGARDING WHAT TYPE AND STYLE
OF ELMO DO THEY HAVE.
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT _
.10
.10
30.00
100.00
225.00
15.00
322.50
150.00
350.00
700.00
225,00
7,50
7,50
MONROE COUNTY
Page: 8
11/20/03
MATTER NO: 864-0002M
STATEMENT NO: 43
LODGE CONSTRUCTION
CONTINUE PREPARATION OF TRIAL EXHIBITS - CROSS
REFERENCE DOCUMENTS WITH MONROE COUNTY'S EXHIBIT
LIST, CHECK DOCUMENTS FOR COMPLETENESS - LABEL
EXHIBITS FOR USE AT TRIAL 5.00 375.00
AVP (E114) - EXPERT WITNESS - PREPARE DOCUMENTS TO BE
SENT TO MONROE COUNTY'S EXPERT, BARRY BROWER;
PREPARE BINDER OF DOCUMENTS/MATERIALS FOR HIS
REVIEW IN ANTICIPATION OF HIS UPCOMING DEPOSITION
AND THE TRIAL IN THIS MATTER 2,00 150.00
AVP (E114) - EXPERT WITNESS - COMPILE DOCUMENTS TO BE
SENT TO JOE MASULLO (MONROE COUNTY'S EXPERT
WITNESS) - PREPARE BINDER OF DOCUMENTS/MATERIALS
FOR HIS REVIEW IN ANTICIPATION OF HIS UPCOMING
DEPOSITION AND THE TRIAL IN THIS MATTER 2,00 150,00
ADC (L140) - DOCUMENT / FILE MANAGEMENT - CONTINUE
ORGANIZATION OF TRIAL EXHI~ITS INTO PROPER ORDER
PER REVISIONS WITH NEW LABEL BY CROSS-REFERENCING
WITH PREVIOUS TRIAL EXHIBIT LIST AND EXHIBITS 9.00 450.00
JER TRIAL/HEARING PREPARATION 4.00 800.00
HOURS
10/27/03
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT _
CONTINUE PREPARATION OF TRIAL EXHIBITS - CROSS
REFERENCE DOCUMENTS WITH MONROE COUNTY'S EXHIBIT
LIST, CHECK DOCUMENTS FOR COMPLETENESS - LABEL
EXHIBITS FOR USE AT TRIAL 4.50 337.50
AVP (E114) - EXPERT WITNESS - COMPILE DOCUMENTS FOR
FRED SALINERO (MONROE COUNTY'S EXPERT WITNESS) _
PREPARE 2 BINDERS OF DOCUMENTS/MATERIALS FOR HIS
USE IN ANTICIPATION OF HIS UPCOMING DEPOSITION
AND THE TRIAL IN THIS MATTER 3.50 262.50
AVP PREPARE FOR DEPO OF CABOT DUNN - COMPILE
DOCUMENTS FOR JANET RITENBAUGH'S USE AT THIS
DEPOSITION 1.00 75.00
ADC (L140) - DOCUMENT / FILE MANAGEMENT - CONTINUED
ORGANIZATION OF TRIAL EXHIBITS INTO PROPER ORDER
PER REVISIONS WITH NEW LABEL BY CROSS-REFERENCING
WITH PREVIOUS TRIAL EXHIBIT LIST AND EXHIBITS 8.00 400.00
JER DEPOSITION OF ROBERT CASTIGLIONE (POWER AIR)_,
PREPARE FOR DEPOSITION OF C.L. DUNN (LODGE
CONSTRUCTION), TRIAL PREPARATION 7.50 1,500.00
MONROE COUNTY
Page: 9
11/20/03
MATTER NO: 864-0002M
STATEMENT NO: 43
LODGE CONSTRUCTION
10/28/03
AVP TELEPHONE CONFERENCE WITH RICH AT OTTOGRAPHICS
RE: COPIES OF PLANS RECEIVED FROM BENDER .20 15.00
AVP TELEPHONE CONFERENCE WITH JOE MASULLO (LEAVE
MESSAGE) RE: MEETING WITH JANET RITENBAUGH ,10 7.50
AVP TELEPHONE CONFERENCE WITH FRED SALINERO (MONROE
COUNTY'S EXPERT) TO CONFIRM THAT HE RECEIVED THE
DOCUMENTS SENT BY JANET RITENBAUGH .10 7.50
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT _
CONTINUE PREPARING MONROE COUNTY'S TRIAL EXHIBITS
- CROSS REFERENCE WITH PREVIOUSLY FILED EXHIBIT
LIST, LABEL DOCUMENTS WITH THE APPROPRIATE
EXHIBIT NUMBER, CHECK DOCUMENTS FOR COMPLETENESS 4,00 300.00
ADC (L140) - DOCUMENT / FILE MANAGEMENT - CONTINUED
ORGANIZATION OF TRIAL EXHIBITS INTO PROPER ORDER
PER REVISIONS WITH NEW LABEL BY CROSS-REFERENCING
WITH PREVIOUS TRIAL EXHIBIT LIST AND EXHIBITS 5.00 250.00
JER ATTEND DEPOSITIONS OF C.L. DUNN (LODGE) AND DAVID
ROEPNACK (LODGE'S EXPERT) 8.00 1,600.00
ILL TELEPHONE CONFERENCE WITH ATTY SCHILLINGER RE
SETTLEMENT DISCUSSIONS AND RE TRIAL ISSUES .20 45,00
ILL RECEIPT/REVIEW NOTICES OF DEPO FOR MASSULO,
BROWER, SALINERO AND STEPHANIE COFFER .20 45.00
HOURS
10/29/03
HGS CONFERENCE WITH JORDANA GOLDSTEIN REGARDING
PREPARATION OF JURY INSTRUCTIONS. .30 45.00
HGS BEGAN REVIEW OF FLORIDA STANDARD JURY
INSTRUCTIONS AND MONROE PLEADINGS IN ORDER TO
PREPARE MONROE COUNTY'S PROPOSED JURY
INSTRUCTIONS. 1.90 285.00
LJG CONFERENCE WITH JANET RITENBAUGH, ESQ, REGARDING
CASE ASSIGNMENTS. .30 22.50
LJG REVIEW & OUTLINE DEPO OF DANIEL GERDES TAKEN ON
2/27/02 IN PREPARATION OF UPCOMING TRIAL. 1.00 75.00
LJG TELEPHONE CONFERENCE WITH LEGAL E'S REGARDING
INFORMATION ON PROJECTOR AND EQUIPMENT RENTAL FOR
UPCOMING TRIAL. .20 15,00
AVP TELEPHONE CONFERENCE WITH JOE MASULLO (MONROE
COUNTY'S EXPERT) RE: HIS MEETING WITH JANET
RITENBAUGH .20 15.00
MONROE COUNTY
Page: 10
11/20/03
MATTER NO: 864-0002M
STATEMENT NO: 43
LODGE CONSTRUCTION
AVP TELEPHONE CONFERENCE WITH RICH AT OTTOGRAPHICS
RE: STATUS OF COPYING PLANS RECEIVED FROM BENDER .10 7.50
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT _
BEGIN CATEGORIZATION OF ALL FILE MATERIALS TO BE
USED IN CONNECTION WITH MONROE COUNTY'S TRIAL
EXHIBITS (AND IN ANTICIPATION OF PREPARING INDEX
OF SAME) 4.50 337.50
AVP TELEPHONE CONFERENCE WITH SHEILA (MONROE COUNTY
ATTORNEYS' OFFICE) RE: STORAGE OF TRIAL
MATERIALS ,20 15.00
ADC (L140) - DOCUMENT / FILE MANAGEMENT - CONTINUED
ORGANIZATION OF TRIAL EXHIBITS INTO PROPER ORDER
PER REVISIONS WITH NEW LABEL BY CROSS-REFERENCING
WITH PREVIOUS TRIAL EXHIBIT LIST AND EXHIBITS, 3.00 150.00
JER TRIAL PREPARATION INCLUDING REVIEW OF DOCUMENTS
FOR EXPERTS & WITNESSES 6.00 1,200.00
ILL TELEPHONE CONFERENCE WITH STEVE PIAZZA RE
CANCELLATION OF DEPOSITION AND RE TRIAL
PREPARATION .20 45.00
ILL TELEPHONE CONFERENCE WITH JOHN FREUD, MEDIATOR,
RE LODGE'S POSITION AND POSSIBLE SETTLEMENT; WITH
BOB SCHILLINGER RE SETTLEMENT DISCUSSIONS AND RE
TRIAL STATUS .30 67.50
HOURS
10/30/03
HGS BEGAN PREPARATION OF MONROE COUNTY'S PROPOSED
JURY INSTRUCTIONS. 6.30 945.00
LJG REVIEW & OUTLINE DE PO OF DANIEL GERDES TAKEN ON
2/27/02 IN PREPARATION OF UPCOMING TRIAL. 3.50 262.50
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT -
SET UP TRAVEL ACCOMMODATIONS FOR STEVE PIAZZA
(DURING THE TRIAL IN THIS MATTER) .40 30.00
AVP TELEPHONE CONFERENCE WITH MICHELLE DOWD
(LEGAL-EZE) RE: SETTING UP MEETING WITH IRA
LIBANOFF AND JANET RITENBAUGH TO DISCUSS ENLARGED
TRIAL EXHIBITS .20 15.00
AVP TELEPHONE CONFERENCE WITH LOUISE DENT (ESQUIRE
REPORTING) RE: PRICES OF REAL-TIME REPORTING
(GET QUOTES OF REAL-TIME REPORTING FOR USE DURING
THE TRIAL IN THIS MATTER) ,20 15.00
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT -
MONROE COUNTY
Page: 11
11/20/03
MATTER NO: 864-0002M
STATEMENT NO: 43
LODGE CONSTRUCTION
CONTINUE CATEGORIZATION OF ALL FILE MATERIALS TO
BE USED IN CONNECTION WITH MONROE COUNTY'S TRIAL
EXHIBITS (AND IN ANTICIPATION OF PREPARING INDEX
OF SAME) 5.30 397.50
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT _
COMPILE MATERIALS TO BE SENT TO STEVE PIAZZA TO
ASSIST HIM IN PREPARING TO TESTIFY IN THE
UPCOMING TRIAL .20 15.00
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT _
COMPILE DOCUMENTS TO BE SENT TO STEPHANIE COFFER
TO ASSIST HER IN PREPARING FOR HER DEPOSITION AND
TO TESTIFY IN THE UPCOMING TRIAL .20 15.00
ADC (L140) - DOCUMENT / FILE MANAGEMENT - CONTINUED
ORGANIZATION OF TRIAL EXHIBITS INTO PROPER ORDER
PER REVISIONS WITH NEW LABEL BY CROSS-REFERENCING
WITH PREVIOUS TRIAL EXHIBIT LIST AND EXHIBITS 3.00 150,00
JER ATTEND DEPOSITION OF ERNEST HOLMES (LODGE'S
EXPERT); MEETING WITH BARRY BROWER RE:
PREPARATION OF EXPERT TESTIMONY 8.00 1,600.00
HOURS
10/31/03
LJG REVIEW & OUTLINE DEPO OF DANIEL GERDES TAKEN ON
2/27/02 IN PREPARATION OF UPCOMING TRIAL. 4.50 337.50
LJG (L140) - DOCUMENT / FILE MANAGEMENT; COPY COLOR
DOCUMENTS AND SKETCHES FOR JANET RITENBAUGH,
ESQ., IN PREPARATION OF UPCOMING TRIAL. ,50 37.50
HGS CONTINUED PREPARATION OF JURY INSTRUCTIONS. 5.90 885.00
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT _
CONTINUE PREPARATION OF TRIAL EXHIBITS - LABEL
DOCUMENTS ACCORDING TO MONROE COUNTY'S TRIAL
EXHIBIT LIST 5,50 412,50
AVP TELEPHONE CONFERENCE WITH MICHELLE DOWD AT
LEGAL-EZE RE: UPCOMING TRIAL PREPARATION MEETING .20 15,00
AVP (L440) - OTHER TRIAL PREPARATION AND SUPPORT _
COMPILE DOCUMENTS/MATERIALS FOR JOE MASULLO - IN
ANTICIPATION OF HIS MEETING WITH JANET RITENBAUGH 1.00 75.00
ADC (L140) - DOCUMENT / FILE MANAGEMENT _
ORGANIZATION OF BINDER/DOCUMENTS SELECTED BY
JANET RITENBAUGH FOR JOE MASULLO, EXPERT, TO BE
USED AT 11/1/03 MEETING 3,00 150.00
JER TRIAL/HEARING PREPARATION 5.00 1,000.00
LODGE CONSTRUCTION
Page: 12
11/20/03
MATTER NO: 864-0002M
STATEMENT NO: 43
MONROE COUNTY
ILL TELEPHONE CONFERENCE WITH CLIENT REPRESENTATIVES
RE STATUS OF SETTLEMENT DISCUSSIONS AND RE TRIAL
STATUS AND PREPARATION
HOURS
.80
180.00
FOR CURRENT SERVICES RENDERED
------ ---------
299.10 34,345.00
SUMMARY OF PROFESSIONAL TIME
TIMEKEEPER HOURS HOURLY RATE TOTAL
---------- ----- ----------- -----
IRA L. LIBANOFF 8.40 $225.00 $1,890.00
ANDREA D. CAMPOS 49.00 50.00 2,450.00
HUDSON G. SAMSON 36.70 150,00 5,505.00
JANET E, RITTENBAUGH 73.00 200.00 14,600.00
ANNA V. PETERSON 106.80 75,00 8,010.00
LAURA J. GERWENS 25,20 75,00 1,890.00
10/14/03
10/15/03
10/15/03
11/06/02 (E124) - CHECK PAYABLE TO SCLAFANI WILLIAMS COURT
REPORTERS FOR COPY OF PROCEEDINGS RE: ROBERT
CASTIGLIONE
10/01/03 (E124) - CHECK PAYABLE TO MEDIATION SOLUTIONS
INC FOR MEDIATION EXPENSE
10/07/03 (E124) - CHECK PAYABLE TO KRESSE, VALDES-PRIETO &
ASSOC. FOR DEPO TRANSCRIPT OF BARRY MCNUTT
10/07/03 (E124) - CHECK PAYABLE TO KRESSE, VALDES-PRIETO &
ASSOCIATES, INC. FOR DEPO OF MICHAEL DUNN COPY OF
TRANSCRIPT
10/09/03 (E107) - FEDERAL
10/09/03 (E107) - FEDERAL
10/09/03 (E107) - FEDERAL
10/09/03 (E107) - FEDERAL
10/09/03 (E107) - FEDERAL
10/13/03 (E108) - POSTAGE
10/13/03 (E124) - CHECK PAYABLE TO VAUGHN, WUNSCH, MASULLO
ARCHITECTS FOR ARCHITECTURAL ENGINEERING SERVICES
10/13/03 (E101) - IKON OFFICE SOLUTIONS - INVOICE NUMBER
FTL040824
(E101) - PHOTOCOPIES
(E101) - PHOTOCOPIES
(E124) - CHECK PAYABLE TO ALTERNATIVE LEGAL COPY
267.50
983.33
444.75
EXPRESS
EXPRESS
EXPRESS
EXPRESS
EXPRESS
TO JUDICIAL ASSISTANT
TO PAUL WOODSON
TO MICHAEL BROWNING
TO MICHAEL KASTAN
TO CLERK OF THE COURT
717,30
13.27
13.16
13.16
13,16
20.60
18.07
1,931.70
1,747,75
560.40
500.70
MONROE COUNTY
Page: 13
11/20/03
MATTER NO: 864-0002M
STATEMENT NO: 43
LODGE CONSTRUCTION
SERVICE FOR HEAVY LITIGATION COPYING
10/16/03 (E109; E110) - TRAVEL EXPENSE
10/18/03 (E105) - TELEPHONE
10/20/03 (E124) - CHECK PAYABLE TO D.L. PORTER
CONSTRUCTORS, INC, - INVOICE #03-10-006
10/21/03 (E107) - FEDERAL EXPRESS TO PAUL WOODSON
10/21/03 (E107) - FEDERAL EXPRESS TO MICHAEL BROWNING
10/21/03 (E107) - FEDERAL EXPRESS TO MICHAEL KASHTON
10/21/03 (E107) - FEDERAL EXPRESS TO CLERK OF THE COURT
10/22/03 (E124) - CHECK PAYABLE TO ALTERNATIVE LEGAL COpy
SERVICE, INC. - INVOICE #33615 - LITIGATION
COPYING
10/23/03 (E107) - FEDERAL EXPRESS TO LARRY MARGOLIS
10/24/03 (E107) - FEDERAL EXPRESS TO BARRY BROWER
10/27/03 (E124) - CHECK PAYABLE TO ALTERNATIVE LEGAL COpy
SERVICE FOR NORMAL COPYING, BLUEPRINTS, TRIAL
EXHIBITS
10/27/03 (E109; E110) - TRAVEL EXPENSE
10/27/03 (E107) - FEDERAL EXPRESS FROM LAWRENCE MARGOLIS
10/27/03 (E107) - FEDERAL EXPRESS TO OTTOGRAPHICS
10/27/03 (E107) - FEDERAL EXPRESS TO FRED SALINERO
10/27/03 (E107) - FEDERAL EXPRESS TO FRED SALINERO
10/29/03 (E124) - CHECK PAYABLE TO OTTOGRAPHICS FOR COPIES
10/29/03 (E124) - CHECK PAYABLE TO COPYSCAN FOR VIDEO
DUPLICATION
10/29/03 (E109; E110) - TRAVEL EXPENSE
10/29/03 (E107) - SUNSHINE STATE MESSENGER SERVICE - JOB
NO. - 592366
10/29/03 (E107) - FEDERAL EXPRESS TO FRED SALINERO
10/30/03 (E124) - CHECK PAYABLE TO COPYSCAN FOR VIDEO
DUPLICATION
10/30/03 (E107) - FEDERAL EXPRESS TO STEPHANIE COFFER
10/31/03 (E124) - CHECK PAYABLE TO KRESSE, VALDES-PRIETO &
ASSOCIATES, INC. - INVOICE #1010997 - DE PO OF
CABOT DODGE DUNN, JR, - TRANSCRIPT AND EXHIBITS
10/31/03 (E124) - CHECK PAYABLE TO KRESSE, VALDES-PRIETO &
ASSOCIATES, INC, - INVOICE #1010962 - DEPO OF
DAVID ROEPNACK - TRANSCRIPT
10/31/03 (E124) - CHECK PAYABLE TO ALTERNATIVE LEGAL COpy
SERVICE FOR NORMAL/OVERSIZE COPYING
10/31/03 (E107) - FEDERAL EXPRESS TO DANIEL S. KASHTAN
135.34
230.23
12.61
76,51
13.27
13.27
13.27
13.27
87.90
13.27
61,30
86.24
89.13
17.27
28.32
22.09
22.09
492.26
47.70
262.68
26.00
26.06
95.40
17,13
393.95
426.90
58,38
13,27
MONROE COUNTY
LODGE CONSTRUCTION
TOTAL EXPENSES
TOTAL CURRENT WORK
10/20/03 THANK YOU FOR YOUR PAYMENT
10/20/03 THANK YOU FOR YOUR PAYMENT
10/20/03 THANK YOU FOR YOUR PAYMENT
10/20/03 THANK YOU FOR YOUR PAYMENT
TOTAL PAYMENTS
BALANCE DUE
PAST DUE AMOUNTS
0-30 31-60 61-90 91-120
----- ----- ------
44,384,96 13,828.50 0.00 300.00
Page: 14
11/20/03
MATTER NO: 864-0002M
STATEMENT NO: 43
10,039,96
~~--,;~~l
-134.24
-982,50
-3,892.50
-271.26
-5,280.50
$60,388,55
---------
---------
121-180
181+
3.52 1,871.57
. "" ~
~\.J- \0 \ \ {) ')
\1-
Please call the attorney responsible for your case should
have any questions concerning this statement.
*STATEMENT REFLECTS ACTIVITY THROUGH THE END OF PRIOR MONTH*
**PLEASE INCLUDE YELLOW COPY OF STATEMENT WITH YOUR PAYMENT*