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Item S01 September 2005 Litigation Report To: Mayor Spehar & County Commissioners From: Bob Shillinger, Asst. County Attorney Date: September 15, 2005 cc: Tom Willi, County Administrator Richard Collins, County Attorney Summary Number of Cases New cases filed against County 3 Cases closed since last report 5 CAY Trial level casesi 33 CAY Post Judgment cases 4 CAY Appeals 5 Potential cases to be filed 5 Outside Counsel Cases 44 Total Cases pending 75 Airports Community Services Engineering Growth Management M iscellaneousii MCSO Personnel Public Works Risk Management New Cases Closed Cases CAY Litigation Cases Trial Level CAY Post Judgment Cases CAY Appeals Potential Cases Outside Counsel Cases Ferencik, Libanoff (Ira Libanoff) Johnson, Anselmo, (Bruce Johnson & Michael Burke) Morgan & Hendrick (Derek Howard) Paul, Hastings (Bob Freilich) Purdy, Jolly (Mike Stephson) The Smith Law Firm (Wayne Smith) Vernis & Bowling (Dirk Smits, Kerry Willis & Scott Black) White & Smith (Tyson Smith & Steve Moore) 2 3 5 53 3 7 3 5 3 Page 2 3 4 9 10 11 13 13 13 16 19 20 21 22 19 CASES FILED AGAINST THE COUNTY SINCE LAST MONTH'S REPORT EEOC v. Monroe County 150-2005-03773 EEOC - Miami Judge: N/A Date Filed: 9/7/05 County served with a notice of charge of discrimination filed by an employee claiming discrimination due to his/her disability. Public Works/Personnel Current Status: Reviewing Complaint & gathering documentation; determining whether to handle in house or refer to outside counsel. Next Activity: Response is due 10/7/05. Time: 0.5 hours Costs: 0.00 LaSalle Bank. N.A. v. Alexis & Jesus Victores & Monroe County CAP 05-373 Circuit Court 16th Judge: Garcia Date Filed: 8/29/05 Mortgage foreclosure action where County holds an inferior $100.00 code enforcement lien. Mayor served September 8,2005. Growth Management/Code Enforcement Current Status: Reviewing complaint to determine if worth responding. Next Activity: Responsive pleading due 9/29/05. Time: 0.5 hours Costs: 0.00 Trov. Daniel Scott v. Monroe County CAK 05-856 Circuit Court 16th Judge: Jones Date Filed: 8/24/05 Mandamus action seeking after the fact building permits for structures erected on Cooks Island in violation of the County Code. Growth Management/Planning Current Status: Mayor has not been served yet. Next Activity: None until Mayor served. Time: 0.1 hours Costs: 0.00 2 CASES CLOSED SINCE LAST MONTH'S REPORT Clay. Robert Lee~ John & Li ChiunQ Moyant v. Monroe County CAM-04-05 Circuit Court 16t Judge: Jones Date Filed: 01/05/04 Mandamus Petition/takings case regarding Big Pine properties. Mayor served 1/8/04. Growth Management/Planning. Current Status: Plaintiffs voluntarily dismissed per settlement agreement. Next Activity: Closed. Time: 7.9 hours Costs: 0.00 Decker. Harry v. Monroe County Circuit Court 16th Judge: Payne This is an appeal of a code enforcement OSTDS case. Growth Management/Code Enforcement CAK-01-1252 Date Filed: 10/5/01 Current Status: County prevailed on both appeals, Mandate issued 8/16/05. Next Activity: Closed. Time: 21.5 hours Costs: 0.00 Thomas. David R. v. Monroe County Circuit Court 16th Judge: Garcia Appeal of Contractor's Examining Board decision. Growth Management/Building/Contractor's Examining Board CAK-05-499 Date Filed: 5/16/05 Current Status: Appellant voluntarily dismissed appeal 8/16/05. Next Activity: Closed. Time: 3.1 hours Costs: 0.00 Tuttle. David. Peter Rosasco & Harley Evans v. Monroe County CAM-04-243 Circuit Court 16th Judge: Payne Date Filed: 6/30/04 Action for damages and to compel County to issue building permits. Growth Management/Planning Current Status: Plaintiffs voluntarily dismissed per settlement agreement. Next Activity: Closed. Time: 3.5 hours Costs: 0.00 3 Wells FarQo v. Rickv & Barbara Allen & Monroe County CAM-05-177 Circuit Court 16th Judge: Payne Date Filed: 7/1/05 Mortgage foreclosure action, County has a $36,000.00 SHIP loan that is junior to the first mortgage. Mayor served 7/14/05. Housing Authority Current Status: Bank dismissed after owners redeemed mortgage. Next Activity: Closed. Time: 7.2 hours Costs: 0.00 CAY LITIGATION - Trial Level See Outside Counsel Section for Cases being Handled Jointly Collins. C. & Sum Air Services v. Monroe County. et al CAM-05-146 Circuit Court 16th Judge: Payne Date Filed: 6/1/05 Declaratory judgment action regarding lease with FBO at Marathon Airport. Airports. Filed but not served. Current Status: Awaiting service of complaint. Next Activity: Once served, determine if outside counsel should be retained. Time: 0.2 hours Costs: 0.00 Cutaia. Thomas v. Monroe County. MCSO. Pretrial Services CAK-05-617 Circuit Court 16th Judge: Jones Date Filed: 6/21/05 Complaint for unspecified damages. Mayor not served yet. MCSO Current Status: Awaiting service. Next Activity: Once served, determine if outside counsel should be retained. Time: 0.2 hours Costs: 0.00 DrewinQ. Janice v. James Roberts as County Administrator CAK-04-686 Circuit Court 16th Judge: Jones Date Filed: 6/25/04 Mandamus action seeking hearing in personnel dispute between plaintiff and her supervisor Louis Latorre. Community Services/Social Services Current Status: Drewing appealed Circuit's denial of writ to Third DCA. Next Activity: Stayed pending appeal. Time: 19.5 hours Costs: 0.00 4 Fed. Nat'l Morta. Assn. v. M. Coleman. Monroe County. et al CAK-05-171 Circuit Court 16th Judge: Jones Date Filed: 2/18/05 Mortgage foreclosure case where County holds an inferior interest to bank due to $1,928.00 in Article V liens. Current Status: Motion's pending. Next Activity: 10/19/05, hearing on objection to foreclosure sale, motion to rescind certificate of sale and motion to vacate final summary judgment. Time: 2.8 hours Costs: 0.00 Florida Key Deer. et al v. Gale Norton (Sec. of Interior) 05-10063-CIV-KING U.S.D.C. S.D.Fla. Judge: King Date Filed: 6/15/05 Endangered Species Act challenge to Fish & Wildlife Service's review of County's application to construct park on Big Pine Key. Engi neeri ng/Construction Management Current Status: Board authorized intervention by County on 8/17/05. Next Activity: File Motion to Intervene; retain outside counsel if necessary. Time: 3.8 hours Costs: 0.00 Monroe County v. R. Bernstein/Safe Harbor Marine Railway CAK-05-732 Circuit Court 16th Judge: Miller Date Filed: 7/26/05 Code enforcement lien foreclosure. Over $221,800.00. Growth Management/Code Enforcement Current Status: Defendant served 8/11/05. Next Activity: OF given till 10/10/5 to file responsive pleading. Time: 5.5 hours Costs: $576.00 Monroe County v. Matthew Bonnett CAK-05-911 Circuit Court 16th Judge: TBA Date Filed: 9/9/5 Code enforcement lien collection action authorized 10/17/04, $78,000. PJM Growth Management/Code Enforcement Current Status: Complaint filed. Next Activity: Serve Defendant. Time: 2.4 hours Costs: $255.00 5 Monroe County v. Dirk W. Damrau CAK-05-667 Circuit Court 16th Judge: Miller Date Filed: 7/11/05 Action to collect $206,100.00 fine authorized by the sacc 6/18/03. Growth Management/Code Enforcement Current Status: Defendant served. Next Activity: sacc to consider settlement offer on 9/21/05. Time: 4.6 hours Costs: $568.05 Monroe County v. Florida Detroit Diesel SCK-05-60 County Court (Sm. Claims) Judge: Fowler Date Filed: 3/14/05 Action seeking reimbursement for $4,905.00 in clean up costs. PJM Public Works/Fleet Management/Risk Management Current Status: Settled for $2452.50; waiting for check to clear. Next Activity: File dismissal once check clears. Time: 7.5 hours Costs: $275.00 Monroe County v. Mark FraleiQh CAP-03-647 Circuit Court 16th Judge: Garcia Date Filed: 12/8/03 Ejectment action against owner of structures located on County right-of-way. Public Works/Roads and Bridges. Current Status: sacc approved settlement 8/17/05. Next Activity: Fraleigh has to remove structures by 9/16/05. Pretrial Conference 10/14/05. Time: 31.7 hours Costs: $238.40 Monroe County v. Jack HaQopian CAP-03-529 Circuit Court 16th Judge: Garcia Date Filed: 10/1/03 Code enforcement collection action authorized by sacc on 8/20/03. Fine was $203,100.00 as of 9/30/03 and accruing at $250.00 per day. Growth Management/Code Enforcement Current Status: Discovery. Next Activity: Mediation by end of September 2005. Time: 18.2 hours Costs: $20.00 6 Monroe County v. Dorothv HouQh. et al CAP-05-160 Circuit Court 16th Judge: Garcia Date Filed: 4/6/05 Code enforcement collection action authorized by sacc on 9/17/03. As of 9/25/3 lien valued at $25,050.00 and accruing at $50.00 per day. Growth Management/Code Enforcement Current Status: Two DFs served answer on 6/1/05; Discovery pending. Next Activity: Settlement offer to be presented at September sacc meeting. Time: 8.7 hours Costs: $596.00 Monroe County v. James Jeanauenat Circuit Court 16th Judge: Garcia Collection action authorized by sacc on 4/21/04. Growth Management/Code Enforcement CAP-OS 317 Date Filed: 7/18/05 Fine exceeds 136,100.00. Current Status: Defendant response overdue as of 9/10/05. Next Activity: Default motion, discovery if denied. Time: 2.2 hours Costs: $275.00 Monroe County v. Kev LarQo Ocean Resorts CooP. Inc. Circuit Court 16th Judge: Garcia Action to foreclose a code enforcement lien. Growth Management/Code Enforcement CAP-96-260 Date Filed: 5/20/96 Current Status: Development agreement application being reviewed. Next Activity: Status report due with the Court 10/1/05. Time: 36.6 hours Costs: $340.00 Monroe County v. Pedro Liz CAK-05-420 Circuit Court 16th Judge: Jones Date Filed: 4/22/05 Collection action authorized by sacc on 7/17/03; fines exceed $816,300.00. Growth Management/Code Enforcement Current Status: Default issued 7/14/05. Next Activity: Move for final judgment. Time: 7.6 hours Costs: $555.00 7 Monroe County v. Arthur Mehr Circuit Court 16th Judge: Garcia Code fine collection action. Fine exceeds $42,000.00. Growth Management/Code Enforcement CAP-05-348 Date Filed: 8/5/05 Current Status: Complaint filed. Next Activity: Serve defendant. Time: 3.2 hours Costs: $405.00 Monroe County v. Outland Properties CAP-05-400 Circuit Court 16th Judge: Garcia Date Filed: 9/9/5 Collection action authorized by BaCC on 10/17/04. Fine over $225,000.00. Growth Management/Code Enforcement PJM Current Status: Complaint filed. Next Activity: Serve Defendant. Time: 1.1 hours Costs: 300.00 Nunziante. Maril~n v. Monroe County CAK-04-1227 Circuit Court 16t Judge: Jones Date Filed: 11/18/04 Suit over admission practices at Bayshore Manor seeking to invalidate practice of requiring family members to subsidize those who can't afford the full rate. Community Services/Social Services Current Status: Discovery ongoing. Next Activity: Document production. Time: 72.8 hours Costs: 0.00 Teal. Kimberly & Keith v. Michael AnQel. Monroe County. et al CAM-04-404 Circuit Court 16th Judge: Payne Date Filed: 12/16/04 Declaratory judgment action by property owners seeking half of a road PJM purportedly abandoned by County and then quitclaimed to City of Marathon. Public Works/Roads and Bridges Current Status: Discovery. Settlement negotiations ongoing. Next Activity: County's motion to dismiss TBA pending negotiations. Time: 9.4 hours Costs: $133.00 8 Walareens & Gadinsky v. Monroe County CAK-05-266 Circuit Court 16th Judge: Taylor Date Filed: 3/11/05 Cert. review of DOAH order upholding 1/6 findings supporting denial of major conditional use application for Big Pine Walgreens. Growth Management/Planning Current Status: Motion to Quash granted. Next Activity: None while awaiting Court's preliminary review of petition. Time: 10.2 hours Costs: 0.00 In re: Winn Dixie Stores. Inc. 05-03817-3F1 U.S. Bankruptcy Ct., M.D.Fla. Judge: Jerry Funk Date Filed: 2/25/05 Voluntary Chapter 11 reorganization case where County might have a claim against the estate. Current Status: Could find no basis for filing proof of claim. Next Activity: None needed. Time: 0.9 hours Costs: 0.00 CAY POST JUDGMENT CASES Monroe County v. William L. Davis CAP-04-181 Circuit Court 16th Judge: Garcia Date Filed: 4/15/04 Money judgment of $27,600.00 for unpaid code enforcement fines and costs. Growth Management/Code Enforcement Current Status: Final judgment of $28,431.00 recorded wi Dept. of State. Next Activity: Collection. Time: 6.2 hours Costs: $56.00 9 Monroe County v. Dan Gleason SCP-03-165 County Court (Sm. Claims) Judge: ptomey Date Filed: 8/5/03 Money judgment of $520.00 for unpaid code enforcement fines and costs. Growth Management/Code Enforcement Current Status: Final judgment recorded wi Dept. of State. Next Activity: Collection. Time: 9.5 hours Costs: $65.92 Monroe County v. Lilv Marks CAK-03-1152 Circuit Court 16th Judge: Jones Date Filed: 10/2/03 Money judgment of $795,270.00 for unpaid code enforcement fines and costs. Growth Management/Code Enforcement Current Status: Final judgment entered for $795,270.00 on 5/9/05. Next Activity: Collection. Time: 8.3 hours Costs: $55.00 CAY APPEALS Drewina. Janice v. Monroe County 3D 04-3044 Third DCA Judge: TBA Date Filed: 11/29/04 Appeal of denial of writ of mandamus in personnel matter. Community Services/Social Services Current Status: Awaiting decision by Court. Next Activity: Awaiting decision by Court. Time: 31.4 hours Costs: $15.00 Eads. Barbara v. Monroe County CAP-03-117 Circuit Court 16th Judge: Garcia Date Filed: 2/27/03 Appeal of order finding the Lowe House to be in unsafe condition. Growth Management/Code Enforcement Current Status: Appeal stayed pending application for variance and building permit. Next Activity: None scheduled. Time: 3.6 hours Costs: 0.00 10 Fuchs. WalburQa v. Monroe County Circuit Court 16th Judge: Payne This is a code enforcement appeal of an OSTDS case. Growth Management/Code Enforcement CAK-01-1251 Date Filed: 10/5/01 Current Status: The County's brief filed; case reassigned to Judge Payne. Next Activity: Await Court's decision. Time: 11.5 hours Costs: 0.00 Monroe County v. Lanes. GeorQe & Denise CAM-04-310 Circuit Court 16th Judge: Jones Date Filed: 9/15/04 Appeal of decision regarding elevation requirements for replacement structure. Growth Management/Code Enforcement PJM Current Status: County prevailed on appeal. Next Activity: When opinion final, remand to Special Magistrate. Time: 10.1 hours Costs: 0.00 POTENTIAL CASES THAT HAVE NOT BEEN FILED YET Good. L10vd v. Monroe County CAK-05-TBA Circuit Court (16th) Judge: Date Filed: Bert J. Harris Act claim regarding two parcels of property owned by Lloyd Good. Growth Management/Planning Current Status: Settlement discussions underway. Next Activity: None. Stayed during Good's application for major conditional use. Time: 8.6 hours Costs: $5.56 11 Harum. James v. Monroe County. DOH. & Z. Krstic CAP-05-TBA Circuit Court 16th Judge: Date Filed: Threatened action for injunctive relief to compel County to prosecute code enforcement violation against Zivadin Kristic by his neighbor James Harum. Growth Management/Code Enforcement Current Status: Underlying code case held 5/26/05, mitigation plan in effect. Next Activity: Move to dismiss and for sanctions if filed since w/o merit. Time: 2.4 hours Costs: 0.00 Monroe County v. Jean M. Louis & Itnor Corp. CAK-05-TBA Circuit Court 16th Judge: TBA Date Filed: Code fine collection action authorized by SOCC on 10/17/04. $34,200.00. Growth Management/Code Enforcement PJM Current Status: Owners not complying with settlement agreement approved by SOCC on 4/20/05. Next Activity: File foreclosure action if not resolved. Time: 1.5 hours Costs: 0.00 Monroe County v. Blair & Althea Moonev CAK-05- TBA Circuit Court 16th Judge: TBA Date Filed: Code lien collection action authorized by SOCC on 10/17/04. $146,100.00. Growth Management/Code Enforcement PJM Current Status: Fine of $7,305.00 paid. Next Activity: Finalize settlement agreement. Time: .5 hours Costs: 0.00 State of Florida v. Monroe County TBA TBA Judge: TBA Date Filed: n/a Threatened action by AG's Medicaid Fraud unit regarding alleged over billings for ambulance services. Public Safety/Fire Rescue Current Status: Waiting for AG's office to set up conference. Next Activity: Settlement conference with State. Time: 9.2 hours Costs: 0.00 12 CASES BEING LITIGATED BY OUTSIDE COUNSEL Ferencik, Libanoff, Brandt, Bustamante and Williams, P.A. Monroe County v. Bender & Associates. et al CAK-03-915 Circuit Court 16th Judge: Jones Date Filed: 8/4/03 Breach of contract and negligent misrepresentation action arising from the defective windows in the Gato building. Engi neeri ng/Construction Management Current Status: Discovery ongoing. Next Activity: Discovery ongoing. Fees billed to date: $55,121.00 Costs: $6,246.83 Monroe County v. Lodae Construction. et al CAK-00-617 Circuit Court 16th Judge: Payne Date Filed: 5/11/00 Suit filed against general contractor Lodge Construction & its surety for breach of contract to build Gato Building. Engi neeri ng/Construction Management Current Status: Reserved on appeal November 24,2004. New trial granted. Mandate issued 2/16/05. Next Activity: Set for trial. Fees billed to date: $298,015.25 Costs: $71,523.31 Johnson, Anselmo, Murdoch, Burke, Piper, & McDuff, P.A. Baukniaht. Ska~s & Rockett v. Monroe County CAP-04-451 Circuit Court 16 Judge: Garcia Date Filed: 9/24/04 Inverse condemnation/takings case filed by Jimmy & Nancy Bauknight, Teague Skaggs, & Kathleen Rockett for three lots on Big Pine Key. Mayor served 10/4/4. Growth Management/Planning Current Status: Discovery. Next Activity: Discovery. Fees billed to date: $832.24 Costs: 0.00 13 BaukniQht. SkaQQs & Rockett v. Monroe County 04-CV-10105 U.S. D.C. S.Fla. Judge: Moore Date Filed: 11/1/04 Inverse condemnation/takings case by owners of 3 Big Pine lots. Growth Management/Planning Current Status: Federal Court remanded to State Court. Attorney's fee motion appealed to 11th Circuit. Next Activity: None. Fees billed to date: None Costs: 0.00 BaukniQht. et al. v. Monroe County 05-10868-F 11th Cir. Ct. of Appeals Judge: TBA Date Filed: 2/11/05 Appeal of denial of attorney's fees motion filed against the County by takings case plaintiffs. County had removed the case to Federal Court; plaintiffs sought remand and attorneys fees. Case was remanded to state court but fees denied. Plaintiffs are seeking between $15,000 and $18,000 in fees. Growth Management/Planning Current Status: Briefs completed. Next Activity: Oral Argument 12/9/05 in Miami, 10:30 a.m. Fees billed to date: None. Costs: 0.00 FKCC & Last Stand v. FL Admin. Comm.. Monroe County DOAH 04-2756 DOAH Judge: Carolyn Holifield Date Filed: 08/05/04 Administrative Rule challenge to agreement with State to fund purchases of environmentally sensitive lands, provide permits for workforce housing, etc; CAY serving as co-counsel. Growth Management/Planning Current Status: Final Order in County's favor issued 6/29/05. Next Activity: None pending appeal. Fees billed to date: $59,464.92 CAY Time: 190.1 hours Costs: 0.00 14 FKCC & Last Stand v. FL Admin. Comm.. Monroe County. et al 3D05-1800 Third DCA Judges: TBA Date Filed: 7/28/05 Appeal of ALJ's decision denying rule challenge in DOAH 04-2756. Current Status: Record being prepared. Next Activity: Appellant's brief due 10/6/05. Fees billed to date: none CAY Time: 0.3 hours Costs: 0.00 Hardee. Evelvn v. Monroe County Circuit Court 16th Judge: Garcia Tort action arising from alleged fall at PK Court house. Risk Management/Public Works CAP-05-255 Date Filed: 6/3/05 Current Status: Discovery. Next Activity: Discovery. Fees billed to date: $660.20 CAY Time: 2.0 hours Costs: 0.00 Neuman. Kenneth v. Monroe County CAK-04-663 Circuit Court 16th Judge: Jones Date Filed: 6/21/04 Action for damages and to compel County to issue building permits. Growth Management/Planning CAY co-counsel. Current Status: Discovery. Next Activity: Discovery. Fees billed to date: $2,326.92 CAY Time: 5.8 hours Costs: 0.00 Riverview Consultants. Inc. v. Monroe County CAK-05-373 Circuit Court 16th Judge: Jones Date Filed: 4/13/05 Tortious interference with contract case. League of City's carrier counsel. Risk Management/Airport/MCSO PJM Current Status: Pleadings complete. Next Activity: Motions and discovery. Fees billed to date: $743.86 CAY Time: 4.0 hours Costs: 0.00 15 Morgan & Hendrick Ambrose. Thora et al v. Monroe County CA P 97-636 Circuit Court 16th Judge: Garcia Date Filed:12/11/97 Declaratory Judgment action claiming vested rights due to subdivision plats. Subsequent appeal of summary judgment order reversed and remanded. Growth Management/Planning Current Status: Motion to dismiss for failure to prosecute Next Activity: Hearing on motion to dismiss, to be scheduled. Billing to date: $30,960.98. Emmert. Helen & Grea v. Monroe County Circuit Court 16th Judge: Garcia Inverse condemnation and vested rights action. Growth Management/Planning CA P 02-520 Date Filed: 10/2/02 Current Status: PL's partial summary judgment motion heard 9/15/05. Next Activity: Ruling on summary judgment motion. Billing to date: $86,289.55 Galleon Bav v. Monroe County v. State of Florida Circuit Court 16th Judge: Payne Inverse condemnation and vested rights action. Growth Management/Planning CA K 02-595 Date Filed: 5/21/02 Current Status: Summary judgment motions pending. Next Activity: Motions hearing 10/24/05, 1 pm. Billing to date: $203,595.15 *** Robert Freilich is serving as co-counsel. 16 Good. L10vd v. Monroe County CA K 01-977 Circuit Court 16th Judge: Payne Date Filed: 8/9/01 Inverse condemnation action based on NROGO and declaratory judgment that owner be awarded permits for properties. Growth M anagement/Plann i ng Current Status: Plaintiff motion to amend complaint filed. Next Activity: Respond to amended complaint. Billing to date: CAY Time: $16,352.91 1.5 Hardin. Michelle v. Monroe County Circuit Court 16th Judge: Miller Appeal of code enforcement decision. Growth Management/Code Enforcement CA K 99-1046 Date Filed: 9/3/99 Current Status: Case being transferred back to CAY. Next Activity: Appellant must produce record per 8/1/5 order. Billing to date: $9,237.07 on this & related dismissed Federal case. I.C. & E. v. Monroe County 01-CV-10105 U.S. Dist. Ct. Judge: King Date Filed: 10/4/01 Declaratory judgment action regarding wireless tower moratoria. Growth Management/Planning Current Status: 11th Circuit directed District Court to dismiss case. Next Activity: Awaiting order of dismissal. Billing to date: $18,966.92. Johnson. L10vd v. Monroe County CA K 02-1248 Circuit Court 16th Judge: Payne Date Filed: 10/30/02 Writ of Mandamus challenging Planning Director's determination that boundary determination by alleged error requires zoning map amendment. Growth Management/Planning Current Status: Agreement reached. Next Activity: Proposed final judgment pending. Billing to date: $1,889.62 17 Kalan. Suzanne v. Monroe County Circuit Court 16th Judge: Garcia Inverse condemnation action. Growth Management/Code Enforcement CA P 03-155 Date Filed: 3/11/03 Current Status: Held in abeyance pending BUD hearing. Next Activity: none. Billing to date: $2,855.77. Neumont. Elizabeth et al. v. Monroe County 99-10054-CV 11th Circuit Court of Appeals Judge: Paine Date Filed: 5/21/99 Cass action challenging enactment of vacation rental ordinance. Growth Management/Planning Current Status: Briefs completed. Next Activity: Oral argument 10/26/05. Billing to date: $123,563.24 Neumont. Elizabeth et al. v. Monroe County 04-13610-X 11th Circuit Court of Appeals Judges: TBA Date Filed: 7/15/04 Appeal of dismissal of class action challenging enactment of vacation rental ordinance. Growth Management/Planning Current Status: Briefs completed. Next Activity: Oral argument 10/26/05. Billing to date: $123,563.24 Q'Daniel. John & Theresa Hill v. Monroe County Circuit Court 16th Judge: Garcia Appeal of code enforcement action and vested rights claim. Growth Management/Code Enforcement/Planning CA P 02-141 Date Filed: 3/13/02 Current Status: Complete, on appeal. Next Activity: None pending appeal. Billing to date: $32,705.49. 18 O'Daniel & Hill v. Monroe County Third DCA Judges: TBA Appeal of circuit court decision in CA P 02-141. Growth Management/Code Enforcement/Planning 3D-05-583 Date Filed: 3/18/05 Current Status: Briefs complete. Next Activity: Oral argument set for October. Billing to date: See previous case. Sierra Club. et al v. DCA. Miami Dade & City of Homestead 03-150-GM DOAH Judge: Maloney Date Filed: 1/17/03 Court intervened in administrative challenge to amendment of Miami-Dade's compo plan redesignating Krome Avenue to a major roadway. Growth Management/Planning Current Status: Trial preparation. Next Activity: Final hearing set for 9/19 through 9/30/05. Billing to date: None, pro bono. Paul, Hastings (Bob Freilich) White & Smith (Tyson Smith) Collins. Thomash et al v. Monroe County Circuit Court 16t Judge: Payne Takings action brought by 11 groups of plaintiffs. Growth Management/Planning CAM -04-379 Date Filed: 11/22/04 Current Status: Discovery ongoing. Next Activity: McGarry deposition 10/4/5. Fees billed to date: $280,057.42 CAY Time: 94.0 hours Costs: 0.00 See also Galleon Bay v. Monroe County - Morgan & Hendrick. 19 Purdy, Jolly & Giuffreda, P.A. Evans. Brian v. Monroe County 04-CIV-10033-JLK U.S.Dist.,S.D.Fla. (Miami)Judge: King Date Filed: 5/6/04 Civil action against the County, and others, arising from actions of Sheriff's office in publicizing the rescission of a warrant it had obtained for his arrest. MCSO Current Status: Court awarded County & Sheriff $4,579.00 in attorney's fees against Evans for filing frivolous suit & denied Evan's motion to stay enforcement of judgment pending appeal. Next Activity: Collection. Fees billed to date: None CAY Time: 9.5 hours Costs: 0.00 Evans. Brian v. MCSO. Monroe County. et al 05-10077-B 11th Circuit Court of Appeals Judge: TBA Date Filed: 1/5/05 Appeal of award of attorney's fees against Evans in 04-CIV-10033. MCSO Current Status: Briefs completed. Next Activity: Await decision by Court. Fees billed to date: None Costs: 0.00 Evans. Brian v. Monroe County. et al CIV S 04-1042 LRH U.S.D.C. Nevada Judge: Jones Date Filed: 7/28/04 Same allegations as Florida case 04-CIV-10033 that were dismissed. MCSO Current Status: Dismissal affirmed by the 9th Circuit, 04-17429. Next Activity: None while appellate decision becomes final. Fees billed to date: None Costs: 0.00 20 Evans. Brian v. MCSO. Monroe County. et al 04-17429 9th Circuit Judges: O'Scannlain, Callahan & Beach Date Filed: 12/09/04 Appeal of Nevada Court's dismissal of suit in CIV S 04-1042 LRH. MCSO Current Status: 8/15/05, County prevailed when Court affirmed dismissal of Evans' complaint in Nevada for lack of jurisdiction. Next Activity: Await 30 days for decision to become final. Fees billed to date: None Costs: 0.00 Evans. Brian v. KW Citizen. Monroe County. et al CV S 04-1742-KJD-LRL U.S.D.C. Nevada Judge: Dawson Date Filed: 1/6/05 Defamation suit over alleged misstatements by Mark Willis in the Citizen. MCSO Current Status: Evans dismissed case on 2/11/05; threatened to refile. Next Activity: Await service. Fees billed to date: None Costs: 0.00 The Smith Law Firm Monroe County v. Post Bucklev. Schuh. and Jerniaan CAK-95-402 Circuit Court 16th Judge: Payne Date Filed: 3/30/95 Malpractice claim against the County's former engineering firm for miscalculation of bonds necessary to finance improvements to Card Sound Road. Engineering Current Status: Defense verdict 6/14/05. Next Activity: Finalize attorney's fees. Fees billed to date: $630,311.78 Costs: 0.00 Monroe County v. Post Bucklev. Schuh. and Jerniaan Third DCA Judges: TBA Appeal of judgment in the above case. Engineering 3D05-1822 Date Filed: 8/1/05. Current Status: Organizing record. Next Activity: County's brief due November 10, 2005. Fees billed to date: none Costs: 0.00 21 Vernis & Bowling of the Florida Keys, P.A. GAP Properties of SW Florida-I. Inc. v. Monroe County CAK-04-1321 Circuit Court 16th Judge: Jones Date Filed: 12/10/04 Cert. review of action involving failure to obtain plat approval of dock subdivision and an improper change of use without a major or minor conditional use permit. Growth Management/Planning Current Status: Certiorari denied, rehearing motion pending. Next Activity: County's motions for attorney's fees & to strike. Fees billed to date: $26,875.00 Costs: $306.43 Kev Tex S. D. Condo Assoc. v. Monroe County & T. McGarrv CAK-04-224 Circuit Court 16th Judge: Jones Date Filed: 3/2/04 Action to prevent County from denying permits because of ownership conversion to condominiums and compel County to accept permit applications that have been rejected MCC 9.5-49. Growth Management/Planning Current Status: Amended petition pending. Next Activity: Petitioners counsel's motion to withdraw 9/27/05. Fees billed to date: $32,290.50 Costs: $2,540.84 Monroe County v. Mary Boza CAK-03-1508 Circuit Court 16th Judge: Jones Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the sacc on 4/18/03. Growth Management/Code Enforcement Current Status: $7,300.00 received 8/24/05. Next Activity: Finalize execution of settlement agreement. Fees billed to date: $7,300.00 CAY Time: 5.4 hours Costs: 0.00 22 Monroe County v. Alain Y. Depierrefeu CAK-03-1504 Circuit Court 16th Judge: Jones Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the SOCC on 4/18/03. Growth Management/Code Enforcement Current Status: Final default judgment entered on 6/21/05 for $144,505.03. Next Activity: Auction to be scheduled. Fees billed to date: None Costs: 0.00 Monroe County v. Alain Y. Depierrefeu CAK-03-1507 Circuit Court 16th Judge: Jones Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the SOCC on 4/18/03. Growth Management/Code Enforcement Current Status: Final default judgment entered on 6/21/05 for $616,555.03. Next Activity: Auction to be scheduled. Fees billed to date: None CAY Time: 3.5 hours (both cases) Costs: 0.00 Monroe County v. Marv Ellen L10vd CAM-03-362 Circuit Court 16th Judge: Jones Date Filed: 12/19/03 Code enforcement foreclosure action authorized by the SOCC 4/18/03. The total amount of the lien owed to the County is $143,500.00. Growth Management/Code Enforcement Current Status: Compliance achieved 8/31/04. Next Activity: Settlement offer to be presented at October SOCC meeting. Fees billed to date: None CAY Time: 2.3 hours Costs: 0.00 Monroe County v. James Messera. et al CAK-03-1509 Circuit Court 16th Judge: Payne Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the SOCC 4/18/03. Growth Management/Code Enforcement Current Status: Owners working on compliance. Next Activity: Settlement discussions ongoing. Fees billed to date: None Costs: 0.00 23 Monroe County v. Joe Posada. III CAK-03-1503 Circuit Court 16th Judge: Payne Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the BOCC 4/18/03. Growth Management/Code Enforcement Current Status: Settlement unproductive. Next Activity: Proceed with foreclosure. Fees billed to date: None CAY Time: 3.5 hours Costs: 0.00 Monroe County v. Virainia Sawyer & Tonv Welters CAK-03-1505 Circuit Court 16th Judge: Payne Date Filed: 12/18/03 Code enforcement foreclosure action that was authorized by the BOCC 7/15/03. Growth Management/Code Enforcement Current Status: DFs answered. Next Activity: Discovery. Fees billed to date: None Costs: 0.00 Monroe County v. Virainia Sawyer CAK-03-1506 Circuit Court 16th Judge: Payne Date Filed: 12/18/03 Code enforcement foreclosure action that was authorized by the BOCC 7/15/03. Growth Management/Code Enforcement Current Status: DFs answered. Next Activity: Discovery. Fees billed to date: None Costs: 0.00 Monroe County v. Louis Welters CAK-04-639 Circuit Court 16th Judge: Jones Date Filed: 6/14/04 Code enforcement foreclosure action that was authorized by the BOCC 7/15/03. Growth Management/Code Enforcement Current Status: OF answered. Next Activity: Discovery. Fees billed to date: None Costs: 0.00 24 Osborn. Jeff v. Monroe County CAP-04-564 Circuit Court 16th Judge: Garcia Date Filed: 11/24/04 1 of 2 certiorari petitions challenging development approval of Northstar project. Growth Management/Planning Current Status: Pleadings complete. Next Activity: Oral argument set for 9/29/05. Fees billed to date: $14,039.50 Costs: $261.49 Osborn. Jeff v. Monroe County CAP-04-565 Circuit Court 16th Judge: Garcia Date Filed: 11/24/04 2 of 2 certiorari petitions challenging development approval of Northstar project. Growth Management/Planning Current Status: Pleadings complete. Next Activity: Oral argument set for 9/29/05. Fees billed to date: $3,920.50 Costs: $146.93 'Includes cases listed under outside counsel if CAY has entered appearance as co-counsel. " Article V issue, bankruptcy claim, and Fire Rescue. 25