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Item I1* 1:30 P.M. CLOSED SESSION * BOARD OF COUNTY COMMISSIONERS AGENDA ITEM SUMMARY Meeting Date: 5/20/15 — KL Bulk Item: Yes _ No XX Division: _County Attorney Staff Contact: Chris Ambrosio, 292-3470 AGENDA ITEM WORDING: An Attorney -Client Closed Session in the matter of Blake Russell Hill v. Monroe County, Case No. CA-K-15-278. ITEM BACKGROUND: Per F.S. 286.011(8), the subject matter of the meeting shall be confined to settlement negotiations or strategy sessions related to litigation expenditures. Present at the meeting will be the Commissioners, County Administrator Roman Gastesi, County Attorney Bob Shillinger, Assistant County Attorneys Chris Ambrosio and Steve Williams and a certified court reporter. PREVIOUS RELEVANT BOCC ACTION: 4/15/15 (N-1) BOCC scheduled Closed Session for 5/20/15 at 1:30 p.m. in Key Largo, FL CONTRACT/AGREEMENT CHANGES: N/A STAFF RECOMMENDATIONS: N/A TOTAL COST: Court Reporter costs INDIRECT COST: BUDGETED: Yes No DIFFERENTIAL OF LOCAL PREFERENCE: COST TO COUNTY: Court Reporter costs SOURCE OF FUNDS: REVENUE PRODUCING: Yes — No xx AMOUNT PER MONTH Year APPROVED BY: County Atty X OMB/Purchasing Risk Management DOCUMENTATION: Included Not Required X DISPOSITION• AGENDA ITEM # Revised 7Y09 County of Monroe The Florida Keys Robert B. Shillinger, County Attorney** Pedro J. Mercado, Assistant County Attorney ** Cynthia L. Hall, Assistant County Attorney ** Christine Limbert-Barrows, Assistant County Attorney ** Derek V. Howard, Assistant County Attorney** Steven T. Williams, Assistant County Attorney** Peter H. Morris, Assistant County Attorney Patricia Eables, Assistant County Attorney Chris Ambrosio, Assistant County Attorney ** Board Certified in City, County & Local Govt. Law June 6, 2017 Kevin Madok, Clerk of the Circuit Court Sixteenth Judicial Circuit, State of Florida Monroe County Courthouse 500 Whitehead Street Key West, FL 33040 BOARD OF COUNTY COMMISSIONERS Mayor George Neugent, District 2 Mayor Pro Tern David Rice, District 4 Danny L. Kolhage, District 1 Heather Carruthers, District 3 Sylvia J. Murphy, District 5 Office of the County Attorney 1111 121h Street, Suite 408 Key West, FL 33040 (305) 292-3470 — Phone (305) 292-3516 — Fax In Re: Blake Russell Hill v. Monroe County, Case No.: CA-K-15-278 Dear Mr. Madok: Please find enclosed herewith the transcript of the May 29, 2015 closed attorney/client session of the Monroe County Board of County Commissioners regarding the above - referenced matter. Under F.S. 286.011(8), the transcript may be part of the public record because the litigation has concluded. Thank you for your assistance with this matter. Please contact me should you have any questions. Sincerely, obert . Shill' ger Monroe County Attorney Enclosure CONFIDENTIAL A MEETING OF THE MONROE COUNTY BOARD OF COUNTY COMMISSIONERS ATTORNEY -CLIENT CLOSED SESSION RE: BLAKE RUSSELL HILL V. MONROE COUNTY, CASE NO. CA-K-15-278 OR GI NAL HELD AT THE I COMMISSION CHAMBERS 102050 OVERSEAS HIGHWAY KEY LARGO, FLORIDA 33037 MAY 29, 2015 2:20 P.M. - 2:38 P.M. Commissioners Present: COMMISSIONER SYLVIA MURPHY COMMISSIONER HEATHER CARRUTHERS MAYOR DANNY KOHLAGE COMMISSIONER DAVID RICE COMMISSIONER GEORGE NUGENT COUNTY ATTORNEY BOB SHILLINGER, ESQ. ASSISTANT COUNTY ATTORNEY STEVE WILLIAMS, ESQ. and ASSISTANT COUNTY ATTORNEY CHRIS AMBROSIO, ESQ. COUNTY ADMINISTRATOR ROMAN GASTESI I WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 pq 2 MAYOR KOHLAGE: The closed session is now being closed. MR. SHILLINGER: For the record, this meeting is being held at my request, who announced at a prior meeting on April 15th, 2015, that I needed your advice in the matter of Blake Russell Hill versus Monroe County, Case Number CA-K15-278. At the meeting, the Board approved holding today's closed session and public notice was given through public announcement of the meeting at that date on April 15th, 2015, BOCC meeting and through publication of today's agenda. For the record, and the benefit of the court reporter, each of us will state our name and position starting with the commissioners. COMMISSIONER MURPHY: Sylvia Murphy, District Five, County Commissioner. COMMISSIONER CARRUTHERS: Heather Carruthers, District Three, County Commissioner. MAYOR KOHLAGE: Dan Kolhage, County Commissioner, District One. COMMISSIONER RICE: Dave Rice, County Commissioner, District Four. COMMISSIONER NUGENT: George Nugent, County Commissioner, District Two. MR. GASTESI: Roman Gastesi, County WWW.USLEGALSUPPORT.COM CONFIDENTIAL 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I Administrator. MR. SHILLINGER: Bob Shillinger, County Attorney. MR. WILLIAMS: Steve Williams, Assistant County Attorney. MR. AMBROSIO: Chris Ambrosio, Assistant County Attorney. THE COURT: All right. And madam court reporter. Just as a reminder, we'll only be discussing settlement negotiations and strategy relating to litigation expenditures. You can't take any decisive action at this meeting. We can only provide information and direction to the attorneys. Any decisions this Board makes concerning this case must be done in a meeting that's open to the public. And I'll start our discussion. This is a quiet title action involving a road, ironically, Ed Swift Road, which is no longer in the room. The gentleman who lives at the far end of the street, the one farthest away from US 1, has filed this suit. Essentially, it's almost a road abandonment. He's seeking a road abandonment. But, for some reasons Mr. Ambrosio will explain, he just -- Mr. Blake Russell Hill decided to file this quiet title action. We're looking to get some direction on how vigorously you want us to defend it, or seek a WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q resolution through a settlement negotiation. On this, I'll turn it over to Chris. COMMISSIONER MURPHY: What's quiet title? MR. SHILLINGER: Quiet title is when you have a dispute as to ownership over something. You get a court to declare who owns the -- COMMISSIONER MURPHY: Oh. MR. SHILLINGER: -- property and quiets the cloud on the title. COMMISSIONER MURPHY: Okay. All right. MR. AMBROSIO: Right. It currently stands in the circuit court filed as a Petition for Declaratory Judgment and Quiet Title. It's not exactly the right path to follow for this type of situation. The only reason they did that is because he happens to be represented by an attorney who believes that he understands the law as it relates to midpoint ownership from an abutting lot. Meaning, his attorney believes that as an abutting lot owner, Mr. Hill rightfully owns to the center points of the roadway. And because Mr. Hill owns the lots at the end of Ed Swift Road, on both sides, his argument is, because I own the three lots that are on both sides of the end of the roadway, I own to the middle. So, therefore, I own everything. And because there is no one else at WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 s 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 5 the end of my road, of course, no one else is affected beyond me. So that's the path and argument that they're taking with this petition, in the form of this litigation. Prior to filing this litigation Mr. Hill went through the Petition for Road Abandonment process with US. It was ultimately denied. His petition was ultimately denied. And reason being, from the Growth Management Office was, because the petition lacked letters from the utility departments that were clear without any sort of restrictions or exceptions or additional requirements, as opposed to just a flat, no objection. Essentially -- MR. SHILLINGER: Just to clarify. It was not brought to the Board for a denial -- or for a hearing. It was determined to be incomplete, prior to that point in the process. MR. AMBROSIO: That's right. Determined to be incomplete. And, then, I think what happened was, Mr. Hill initially made overtures that he was going to pay the utilities whatever was necessary to comply with their requirements, or it wasn't going to be too difficult to comply, but he was going to follow through, and it seems like he didn't follow through. WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 s 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 G And, then, maybe the file just died and eventually they closed it because he was no longer making efforts, or it seemed like he abandoned his effort for the road abandonment. Then, eventually, he learned that the road -- the petition was denied, as Bob said, or the road wasn't abandoned in his favor. And then they came through with this litigation. So that's where we are. Recently, we've had the suggestion from Mr. Hill's attorney that he would be willing to enter into a settlement. His concept is, going through this litigation path is a quicker, more simpler, easier way for the County, and for Mr. Hill to resolve the issue, as opposed to potentially, Mr. Hill going through a road abandonment petition process again. And, Bob and I -- I believe Bob and I both feel the normal process would have been what Mr. Hill did, which was the petition for the road abandonment, and then it goes through its course there. However, I think that there is a way to resolve this in a settlement agreement, in the form of this litigation. If we don't want to defend vigorously, we want to hang on to the end of Ed Swift Road, for some reason, but if you do not mind abandoning it, I think we can arrange that in a settlement agreement, in WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 s 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 7 terms of this litigation, where the County will agree to abandon the road, but there's going to be a list of conditions that fall upon Mr. Hill to meet that the County doesn't have any responsibility to meet. And that would be, Mr. Hill, of course, would need to get proper permits to comply with any of the utilities' requirements. He would have to even bear the burden of the financial costs of accommodating the utilities, either through easement or relocating their easement, or their utilities, whatever -- whichever method he and the utilities agree to. He would need to make the proper coordinated efforts to arrange for a cul-de-sac or a T turn -around, however the fire marshal would want it to be. Because, currently, as it stands, there is neither at the end of Ed Swift Road. So it would, technically, according to our engineering department, technically, it could be a benefit for the other residents on that road. And it could be considered an improvement on that road if Mr. Hill were to be required to build a cul-de-sac, as a turn -around, according to whatever the fire marshal's plan would call for. Also included in that settlement, Mr. Hill and his attorney are going to be required to notify the WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 other residents. And I believe, he said 300 feet. Mr. Greenman, the attorney for Mr. Hill, stated that he promised the three of us that he would notify all residents within 300 feet that would be affected by that area. Am I missing any other conditions? MR. SHILLINGER: Not that I can think of. So, the basic issue is, do you want us to, A, just fight to maintain the end of the road? Do we care? COMMISSIONER MURPHY: Can we just ask questions first? MR. SHILLINGER: Yes, yes. And for, B, do we want to work towards -- see, that's the -- I'm trying to frame the issue of what we're going to ask you ultimately, or B, get to the -- work towards a resolution of the case even through the abandonment process, if there's a settlement agreement. That's the outline of what we're asking. Yes, your questions. COMMISSIONER MURPHY: Okay. Beyond this picture, it looks like beyond that chain -link fence are mangroves and a basin, a boat basin. Am I correct? MR. WILLIAMS: Yes, there's a boat launch, boat parking. COMMISSIONER MURPHY: A what? MR. WILLIAMS: Yes, there's a boat ramp, boat WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 s 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I launch that's on Mr. Hill's property, on the left side. COMMISSIONER MURPHY: I see a boat ramp. COMMISSIONER NUGENT: Where is there a boat ramp? MR. WILLIAMS: On the left side. COMMISSIONER MURPHY: On the left side. COMMISSIONER CARRUTHERS: Across the road. COMMISSIONER NUGENT: Might have to point it out to me, I don't see -- COMMISSIONER CARRUTHERS: His house is the one with all the solar panels, right? COMMISSIONER MURPHY: Yes. MAYOR KOHLAGE: Right. COMMISSIONER CARRUTHERS: So that lot across the road is the boat launch? COMMISSIONER MURPHY: No, the one right -- the orange. Right -- COMMISSIONER CARRUTHERS: On the side of it. COMMISSIONER MURPHY: Heather. COMMISSIONER CARRUTHERS: Yeah. That's a boat launch? Boat launch into what? MR. SHILLINGER: All right. MR. WILLIAMS: He owns both sides of the road. COMMISSIONER CARRUTHERS: So the boat launch is here? WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 s 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A 10 MR. WILLIAMS: Yes. Correct. COMMISSIONER MURPHY: This is the boat launch. MR. WILLIAMS: He owns both sides -- COMMISSIONER NUGENT: But that's his boat ramp. MR. SHILLINGER: For the benefit of the court reporter, it would be helpful if we spoke one at time. MR. WILLIAMS: Madam Court Reporter -- let me get to the podium. For purposes of the record, Mr. Hill owns both sides of the road. And what Mr. Greenman had indicated to me in person is the boat ramp is on the scarified -- on the photo that you're shown, for the record, will be on the left side of the road, and opposite the house with the solar panels. COMMISSIONER MURPHY: And he has access to that boat ramp? MR. AMBROSIO: Right. COMMISSIONER MURPHY: And he has access in the front of his property to a boat basin. It's deeper than in the surrounding area. Okay. But does that belong to him? MR. WILLIAMS: Yes. He actually has -- he actually has deeded bay bottom, and showed it to Bob and I at a meeting a couple days ago. COMMISSIONER MURPHY: Then people coming down that street, Ed Swift Road, all of the people that WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 11 live on that street can come to that chain -link fence and that's as far as they can go? MR. WILLIAMS: Yes. He owns both sides. Currently, it's not -- COMMISSIONER MURPHY: That's fine, but who put the chain -link fence up there? MR. WILLIAMS: This is not one, traditionally, we come before you. The big question you all talk about is abandoning roads that are waterfront or to open water. COMMISSIONER MURPHY: Right. MR. WILLIAMS: This is not. This is one of the few that is not ending in open water. This ends in private property. And we -- well, actually I do have a photo of it here. That the plat map shows that there is a parcel, separate from the housing parcel that contains those waters and separately, legally identified as a completely different parcel and he owns it as well. COMMISSIONER MURPHY: And he owns it as well? MR. WILLIAMS: Yes. COMMISSIONER MURPHY: So when you come -- do you see the body of water, the boat basin? And then to the right, what looks like a path with mangroves, I guess, along the side. WWW.USLEGALSUPPORT.COM CONFIDENTIAL 7 1 2 3 4 5 6 7 s 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 12 MR. WILLIAMS: Yep. COMMISSIONER MURPHY: Is that also his? MR. WILLIAMS: Yes. All of that is his. I'm trying to pull up the survey. I apologize. COMMISSIONER MURPHY: Okay. So he's not going to -- by doing this, by abandoning this road, he's not going to impact the neighbors at all, since they have no right to get to that -- MR. WILLIAMS: Yeah. COMMISSIONER MURPHY: -- in the first place? MR. SHILLINGER: That's our observation, yes. COMMISSIONER NUGENT: And that would beg the question of why would we want to make him put a cul-de-sac in. COMMISSIONER MURPHY: So they can -- MR. SHILLINGER: Fire safety. COMMISSIONER NUGENT: None of the other roads have cul-de-sacs. MR. SHILLINGER: Fire safety. It's a very narrow road. MAYOR KOHLAGE: We're talking a bunch of people at one time. The court reporter is not going to be able to figure this out. Let me ask a couple of questions. Bob, how could we agree to abandon without going through a public hearing? WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A 13 COMMISSIONER MURPHY: We can't. MR. SHILLINGER: In the quiet title that would be -- you get a court order that would adjust the title to that. Our rights would be extinguished that way. Now, the thought about having it be a public hearing so public input would be granted, you know, you would have an opportunity to be heard on that. We thought about that. The best we can identify is, we could give notice to the public to come and speak as to when the settlement agreement is considered by you. And that would be an opportunity for the public to give input. But that's not the same as a public hearing. MAYOR KOHLAGE: That sounds a little unorthodox to me. COMMISSIONER MURPHY: It certainly does. MAYOR KOHLAGE: Let me go on. COMMISSIONER MURPHY: Sneaky. MAYOR KOHLAGE: When they go through the quiet title suit, the title is going to be whatever it is. And if we have the title, we would be entitled -- and -- and -- MR. SHILLINGER: So if we litigate it to its conclusion, if we have the title, we have it and if we don't, we don't. WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A 14 MAYOR KOHLAGE: Well, that's what I'm saying. In other words, if it's determined, I mean, how could we agree -- I want to, you know, pursue this settlement because, you know, it looks like it's appropriate for abandonment anyway. But, how could we agree in the suit to pass our title to him if we don't know if we have it in the first place? MR. SHILLINGER: Well, because the other claim is a claim for Declaratory Judgment and that would -- if you had an agree on judgment, you would then agree to the declaration of rights as it's spelled out in the settlement agreement. MAYOR KOHLAGE: So you're going to be asking the court, in spite of what the record says, to declare it to be his? MR. SHILLINGER: That -- MAYOR KOHLAGE: Isn't that a little unusual? MR. SHILLINGER: It's not the normal process. The normal process is a road abandonment. And that's what we told him is, you have a road abandonment process and that's -- COMMISSIONER MURPHY: But isn't that easier and less expensive, the road abandonment? MAYOR KOHLAGE: Yeah, I'd rather see -- COMMISSIONER MURPHY: See, he files. It comes WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 s 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 15 before us. It's a public hearing. COMMISSIONER CARRUTHERS: We're transparent. COMMISSIONER MURPHY: And everybody in the world can see it. MR. SHILLINGER: It is -- MAYOR KOHLAGE: One more question, please. I don't understand, you know, you're asking for the cul-de-sac, or the T, or whatever. Why would this gentleman want title to the road if he's going to continue to use it as a road? COMMISSIONER MURPHY: No, the cul-de-sac would be on the other side of it. COMMISSIONER CARRUTHERS: Well, he's got so much property -- MR. WILLIAMS: All right. His current plan, my understanding from speaking with his counsel is, this gentleman is acquiring those parcels on that end for a large personal estate. Going to fence off the road at the end of the entrance to his estate. Put the turn -around, cul-de-sac there for fire emergency vehicles. MAYOR KOHLAGE: Put the cul-de-sac where? Where? MR. WILLIAMS: Before his fence. Before his parcels. COMMISSIONER MURPHY: But will he have enough WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 room because that's privately owned? MR. SHILLINGER: He's going to acquire -- MR. WILLIAMS: He is currently -- we had this discussion. And -- before we got here today. He has, under contract, the next available lot, prior to the ones he currently owns. Lot 56 he has under contract and will build a T turn -around on it for public benefit. What's currently happening, if anyone's driven down this road, and Chris' pictures show it's extremely narrow. COMMISSIONER MURPHY: Yeah. MR. WILLIAMS: I mean, you almost have to back out to get back out of it. This gentleman owns all the properties on both sides anyway. He's relatively tired of everyone going down to the end of the road, turning around on his land, on his property that he owns, tearing those up and then trying to leave. So, he provides this. I mean, it is not exactly altruistic, but it does keep people from turning around on his property. If he's allowed to turn -around, before they get to the end of the road. MAYOR KOHLAGE: Steve, his ability to agree to this condition about the T, or cul-de-sac, is dependent on him acquiring additional property? MR. WILLIAMS: Yes. And -- WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 17 MAYOR KOHLAGE: Has he done that? MR. WILLIAMS: -- contract. Not done yet. He doesn't know how this meeting is going to go. MAYOR KOHLAGE: This is premature. MR. WILLIAMS: It happens -- you guys -- I agree completely. This is different than we normally do. He's alleged that there is question as to the ownership of the lands under the road. I think Bob, Chris, and I are all pretty clear that there's not much real question there. But you're within your rights to bring it back to road abandonment. We'll just be doing the same process over again on the road abandonment. And, then, it will be up to him whether or not he wants to build a cul-de-sac, or a turn -around, out of his own pocket. COMMISSIONER MURPHY: Well, if he doesn't, can people turn -around down there now, or does he have the whole thing fenced? That's not -- MR. WILLIAMS: No. I mean, you can sort of do it, but you're pulling into -- off the road. I mean, if you're doing it -- people do do it, as Counsel even pointed out. COMMISSIONER MURPHY: In other words, it's not fenced off? MR. WILLIAMS: No, there is. You can pull into a WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 s 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A lot and turn -around. You can turn -around on the empty, vacant scrub lot. COMMISSIONER MURPHY: The fence does not go all the way? MR. WILLIAMS: Right. You're not driving through a tunnel. MAYOR KOHLAGE: Let's try to bring this to some conclusion. MR. SHILLINGER: All right. I'm thinking I'm getting the direction that you would rather go through the normal road abandonment process than entertain any out -- unusual processes in this matter. Is that -- this is your first exposure to this case. We wanted to get the flavor for it. And we have to decide, are we going to aggressively defend it, move to dismiss? We also wanted to get a sense of where can we go from here. I don't -- I'm not anticipating, or I'm not sensing that there is a burning desire to hold onto the road -- COMMISSIONER MURPHY: No. MR. SHILLINGER: -- necessarily, but you want to go through the normal process. MAYOR KOHLAGE: That's my feeling. COMMISSIONER MURPHY: Mine, too. MR. SHILLINGER: Right. And we're not here to WWW.USLEGALSUPPORT.COM CONFIDENTIAL 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 19 take a vote. I'm just here to get your sense and I've got that. So, thank you. Mr. Mayor, unless there's other questions, if you would like to close the closed session, we can move on. MAYOR KOHLAGE: I very much would like to do that. Okay. The closed session is now ended. (The attorney/client session was concluded at 2:38 p.m.) WWW.USLEGALSUPPORT.COM CONFIDENTIAL A CERTIFICATE STATE OF FLORIDA, COUNTY OF MONROE I, Patricia A. Zischka, Florida Professional Reporter, do hereby certify that I was authorized to and did stenographically report the foregoing proceedings; and that the transcript, pages 2 through 19 are a true and correct record of my notes. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. Dated this 11th day of June, 2015. Patricia A. Zischka 20 WWW.USLEGALSUPPORT.COM CONFIDENTIAL Page 1 A abandon7:2 12:24 abandoned 6: 3, 7 abandoning 6: 2 4 11:9 12:6 abandonment 3: 2 0 3:21 5:7 6:4,15 6:18 8:15 14:5 14:19,20,23 17:11,13 18:11 ability 16:22 able12:23 abutting 4: 18, 19 access 10: 14, 17 accommodating 7: 8 acquire 16:2 acquiring 15: 17 16:24 action 3:11,16,24 20:14,15 additional5:13 16:24 adjust 13:3 Administrator 1: 22 3:1 advice 2:5 agenda2:11 aggressively18:15 ago10:23 agree7:1,11 12:24 14:3,5,10,10 16:22 17:5 agreement 6: 2 1, 2 5 8:16 13:10 14:12 alleged17:7 allowed 16:20 altruistic16:19 Ambrosiol:21 3:5 3:5,22 4:11 5:19 10:16 announced 2:4 announcement 2: 9 anticipating18:17 anyone Is16:8 anyway14:5 16:14 apologize12:4 appropriate 14: 4 approved 2:8 April 2:5,10 area 8:5 10:19 argument 4:22 5:3 arrange6:25 7:13 asking8:17 14:13 15:7 Assistant 1: 20, 21 3:3,5 attorney 1: 19, 2 0 1:21 3:2,4,6 4:16,18 6:10 7:25 8:2 20:11 ATTORNEY -CLIENT 1:3 attorney/client 19:8 attorneys3:12 20:13 authorized 2 0: 5 available 16: 5 B B8:11, 14 back 16:12,13 17:11 basic 8:7 basin8:21,21 10:18 11:23 bay 10:22 bear 7:7 beg 12:12 believe 6:16 8:1 believes 4:16, 19 belong10:20 benefit 2 : 12 7 : 18 10:5 16:8 best13:8 beyond5:2 8:19,20 big11:8 Blakel:4 2:6 3:23 Board1:2 2:8 3:13 5:16 boat8:21,22,22,25 8 : 2 5 9:3,4,15,20 9:21,24 10:2,4 10:10,15,18 11:23 Bobl:19 3:2 6:6 6:16,16 10:22 12:24 17:8 BOCC2:10 bodyll:23 bottom10:22 bring17:11 18:7 brought 5:16 build7:21 16:7 17:14 bunch12:21 burden7:7 burning18:18 C CA-K-15-2781:5 CA-K15-278 2: 7 call 7:23 care 8:8 Carruthers 1: 15 2:17,17 9:7,10 9:14,18,20,24 15:2,13 casel:5 2:7 3:13 8:15 18:13 center4:20 certainly13:16 CERTIFICATE 20:1 certify 2 0 : 5, 10 chain- link 8: 2 0 11:1,6 CHAFERS 1 : 7 Chris1:21 3:5 4:2 16:9 17:9 circuit4:12 claim 14 : 8, 9 clarify 5 : 15 clear 5:11 17:9 close 19:4 closed 1:3 2:1,2,8 6:2 19:4,7 cloud 4:8 comel1:1,8,22 13:9 comes14:25 coming10:24 COMMISSION 1 : 7 Commissioner 1: 14 1:15,17,18 2:15 2:16,17,18,19,21 2:22,23,24 4:3,7 4:10 8:9,19,24 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