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Item L2CLOSED SESSION 2:45 P.M. TIME CERTAIN BOARD OF COUNTY COMMISSIONERS AGENDA ITEM SUMMARY Meeting Date: 6/18/2008 - MAR Bulk Item: Yes No xx Division: County Attorney Staff Contact Person: Bob Shl;linger x3470 AGENDA ITEM WORDING: A closed executive session of the Board of County Commissioners in the matter of Celeste Bruno v. Monroe County, CV 07-10117. ITEM BACKGROUND: On May 30, 2008, staff attended mediation which had been ordered by the Court in the above - referenced matter. As a result of that mediation, Iegal staff desires direction from the Board on the case. 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 Suzanne Hutton, Assistant County Attorney Bob Shillinger, Mike Burke as special litigation counsel in the pending litigation, and a certified court reporter. PREVIOUS RELEVANT BOCC ACTION: 5/21/08 BOCC approved Closed Session for 6/18/08 a 3:00 p.m. 523/08 BOCC approved rescheduling Closed Session for 6/18/08 @ 2:45 p.m. CONTRACT/AGREEMENT CHANGES: N/A STAFF RECOMMENDATIONS: n/a TOTAL COST: a,$100.00 BUDGETED: Yes xx No COST TO COUNTY: @$1.00.00 SOURCE OF FUNDS: REVENUE PRODUCING: Yes _ No xx AMOUNT PER MONTH Year APPROVED BY: County Atty xx OMB/Purchasing n/a Risk Management n/a DOCUMENTATION: Included DISPOSITION: Revised 2/05 Not Required X AGENDA )ITEM # County of Monroe The Florida Keys Robert B. Shillinger, County Attorney** Pedro J. Mercado, Assistant County Attorney ** Susan M. Grimsley, Assistant County Attorney** Natileene W. Cassel, Assistant County Attorney** Cynthia L. Hall, Assistant County Attorney ** Christine Limbert-Barrows, Assistant County Attorney ** Derek V. Howard, Assistant County Attorney** Lisa Granger, Assistant County Attorney Steven T. Williams, Assistant County Attorney ** Board Certified in City, County & Local Govt. Law January 9, 2014 Amy Heavilin, Clerk of the Circuit Court Sixteenth Judicial Circuit, State of Florida Monroe County Courthouse 500 Whitehead Street Key West FL 33040 In Re: Bruno v. Monroe County, Case No.: 07-CV-10117 Dear Ms. Heavilin: BOARD OF COUNTY COMMISSIONERS Mayor Sylvia J. Murphy, District 5 Mayor Pro Tern, Danny L. Kolhage, District 1 George Neugent, District 2 Heather Carruthers, District 3 David Rice, District 4 Office of the County Attorney 1111 ffh Street, Suite 408 Key West, FL 33040 (305) 292-3470 — Phone (305) 292-3516 — Fax Please find enclosed herewith the transcript of the June 18, 2008 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 made 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 . Shillinger Monroe County Attorney Enclosure 1 2 3 4 rl 9 i0 12 3 L� BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY ATTORNEY -CLIENT CLOSED SESSION WEDNESDAY, JUNE 18, 2008 Re: Celeste Bruno v. Monroe County CV 07-10117 COUNTY COMMISSIONERS: Mario DiGennaro, Mayor Dixie M. Spehar, County Commissioner Charles McCoy, County Commissioner George Neugent, County Commissioner Sylvia J. Murphy, County Commissioner STAFF: Suzanne Hutton, County Attorney Robert B. Shillinger, Chief Assistant County Attorney Roman Gastesi, County Administrator TRANSCRIPT OF PROCEEDINGS Proceedings of the Board of County Commissioners of Monroe County Attorney -Client Closed Session, at the Marathon Government Center, 2798 Overseas Highway, Marathon, Monroe County, Florida, on the 18th day of June 2008, commencing at approximately 2:58 p.m. and concluding at approximately 3:18 p.m., as reported by Susan L. McTaggart, Court Reporter and Notary Public, State of Florida at Large. All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West 2 1 2 3 9 5 6 7 8 9 10 i1 12 13 16 17 �8 i9 20 21 22 3 29 MS. HUTTON: A closed attorney -client session pursuant to Section 286.011, Subsection (8), needs to be held at this point in time. The meeting will take approximately 30 minutes. It is in the matter of Celeste Bruno v. Monroe County, CV 07-10117. The persons attending the meeting will be the County Commissioners, County Administrator Roman Gastesi, County Attorney Suzanne Hutton, Assistant County Attorney Bob Shillinger, and a certified court reporter. Since the law prohibits any other person from being present at the closed session -- I wanted to make sure the PowerPoint was ready before I said everybody had to get out of here. The persons I've already mentioned will remain in the meeting, and all other persons are required to leave the room. When the closed session is over we will reconvene and reopen the public meeting. If the Mayor will now close the public meeting. MAYOR DiGENNARO: The public meeting is closed. The closed session is open. MS. HUTTON: Thank you. For the record, this meeting is being held upon the request of the County Attorney, who announced at a prior public meeting on 5/21 that I needed advice concerning the pending lawsuit, Bruno v. Monroe County, CV 07-10117. At All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West 3 1 that meeting the Board approved holding today's 2 closed session. Public notice was given at the 5/21 3 I meeting and at the 5/23 special meeting and through 4 publication of the agenda for the 6/18 BOCC regular i 5 meeting. For the record and the benefit of the i 6 court reporter each of us will state our name and 7 position, starting with the Commission. 8 COMMISSIONER SPEHAR: Dixie Spehar, District 1. 9 COMMISSIONER McCOY: Charles McCoy, District 3. 10 MAYOR DiGENNARO: Mario DiGennaro, District 4. 11 COMMISSIONER NEUGENT: George Neugent, District 12 2. 13 COMMISSIONER MURPHY: Sylvia Murphy, District 14 5. 15 MS. HUTTON: Suzanne Hutton, County Attorney. 16 ADMINISTRATOR GASTESI: Roman Gastesi, County 17 Administrator. 18 MR. SHILLINGER: Bob Shillinger, Assistant 19 County Attorney. 20 MS. HUTTON: Just as a reminder, we will only 21 be discussing settlement negotiations and strategy 22 relating to litigation expenditures. We cannot take 23 decisive action. If there is any decision to be 24 made it would have to be made at an open meeting. 25 And I'm going to turn this over to Bob, who has All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West II 4, 1 i prepared a PowerPoint for you. 2 MR. SHILLINGER: Good afternoon. We're having j 3 a little technical difficulty with the PowerPoint, 4 but we'll get our way through it. The federal court 5 whenever a case is filed will order parties to go to 6 mediation. The federal courts want to get their 7 cases solved, so they do that. They ordered us to 8 go to mediation in this case. We had mediation on i 9 Friday, May 30, in Fort Lauderdale. So we're here 10 today to communicate the settlement offer that was 11 i tendered by Ms. Bruno and through her attorneys and 12 i I to receive some sort of direction from you. 13 Before we go further, though, I want to give 14 the background on the case a little bit. Before we 15 get to there, we're in an attorney -client session, 16 so I've got to remind you that anything we say here 17 is protected under the attorney -client privilege, so 18 it's not admissible in court if I have this 19 conversation with you. We need to, so you're 20 reminded to keep things confidential here and that 21 preserves the privilege. If you don't we may harm 22 our position. 23 Ms. Bruno's filed a two-part claim. The first 24 part of her claim is a hostile environment, sexual r 25 harassment claim. All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West 5 1 COMMISSIONER NEUGENT: Bob, I'm sorry, is this 2 a federal or a state? 3 MR. SHILLINGER: She filed it in state court. 4 The County as our defendant's right elected to I 5 remove it to federal court because she alleged a 6 federal claim. She sued under a federal statute and 7 a state statute, so that gave us the right to remove 8 it to federal court and we figured we would get a 9 quicker and better disposition in federal court than 10 we would in front of a state court judge. 11 COMMISSIONER NEUGENT: Are those federal trials 12 held here in Monroe County? 13 MR. SHILLINGER: Yes, they are. 14 COMMISSIONER NEUGENT: We can't request a 15 different venue? 16 MR. SHILLINGER: We could if we can't pick, if 17 a jury can't be selected here. 1_8 Her claim, first claim is the sexual harassment 19 claim. She claims that while she was working for 20 Commissioner McCoy he made statements to her that 21 included some offensive details. She also claimed 22 that he made other sexually inappropriate comments 23 to her. But she acknowledges that at no time did he 24 ever touch her or make any advances to her. So it's 25 just a comment case. The County's defenses, All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West 1 2 3 4 5 6 7 8 9 10 1 1 12 13 14 15 16 17 18 19 20 21 �2 23 24 25 6' obviously our first one is he denies making these statements. She never complained or requested that Mr. McCoy alter his conduct. And this is important to understand, that even if what she says is true, assuming, we're not acknowledging it, but if you assume it, it doesn't rise to the level of sexual harassment. Fourthly, she failed to use the i complaint procedures, and thus didn't give the County an opportunity to provide her with a safe working environment. And fifthly, once she did tell us of a problem we gave her an alternate employment that was free of that type of harassment and then she provided no complaints regarding her treatment after that point. So that's our defense to the first claim. It doesn't rise to the level of sexual harassment. Her second claim is a retaliation and constructive discharge claim. Basically she's i saying that we retaliated against her and forced her to leave her job. It has two components. Prior to her leaving Commissioner McCoy's office she's saying that the Commissioner treated her in a demeaning manner because she had told him to stop telling her these stories and he was, this was his way, he was frustrated with her and he was treating her in a All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West 7! 1 demeaning manner. Obviously we deny that 2 allegation. After that she left the Commissioner's i 3 office. She's saying that we retaliated against her i 4 in two ways. One, by taking away her supplemental 5 pay that she had received because she was the 6 Mayor's aide. Each of you have an aide. When it's I 7 your turn to be the mayor and your aide gets a lot I 8 more paperwork you get a five percent supplemental 9 pay. When she walked away from that position that 10 supplemental piece of pay was taken away from her. i i 11 So that wasn't done in retaliation. It was done 12 because she was no longer working as the Mayor's 13 aide. 14 Our other defense is, or her other allegation 15 is that we failed to protect her from John Milo 16 Reese. That's the famed pizza pilot, the lunatic 17 that read something in the paper and kept trying to 18 communicate with her about the claim. So those are i 19 her allegations. j I 20 Our defenses to the second claim, obviously she 21 was not subjected to any adverse personnel action 22 while she worked for Commissioner McCoy. He didn't 23 treat her in a demeaning manner. In fact, he gave 24 her outstanding reviews. The loss of pay, as I 25 said, occurred because she was no longer the Mayor's All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 -)0 L 21 22 23 L 25 aide. She, and the County took reasonable means to protect her from Mr. Reese and to provide her with a safe working environment. We went to extraordinary measures. Commissioner Spehar even offered, when she was placed in her office even offered to have a security door put in that would allow her to buzz people in and out. And nothing was good enough for Ms. Bruno. And it's important to know that during her deposition she acknowledged that there probably wasn't anything the County could do to make her feel safe. MAYOR DiGENNARO: I have a question to ask you in the meantime. MR. SHILLINGER: Sure. MAYOR DiGENNARO: Was Commissioner Spehar deposed in this case? MR. SHILLINGER: No. Mike Burke has been representing the County in this case. He has represented the County and other local governments through the Florida League of Cities, their I� Municipal Insurance Trust Fund, for over 20 years. He's board certified in appellate practice and civil i trial law. He's given us some estimates and percentages, but I want you to understand, that's I what they are. They're estimates. They're not All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West 9 1 mathematical certainties. This information I'm 2 giving you is based on Mike's assessment of the 3 case. 4 Our first step that we're going to file, we're 5 i about ready to file it, is a motion for summary 6 judgment, and that argues that even if you assume 7 i what she's saying is true, she's not entitled to 8 victory as a matter of law. On the first claim Mike 9 estimates that we have a 60 to 70 percent chance of 10 winning on summary judgment. On the retaliation 11 claim he's estimating even higher, 80 percent chance 12 of winning on summary judgment. 13 If we get beyond summary judgment obviously 24 those numbers start going down, and this second 15 slide assumes that we've gone beyond summary 16 judgment, it's been denied, and that a jury panel's 17 i been empaneled. I 18 And this gets back to what you were asking, Mr. 19 Neugent. In federal court the jury panel is 20 selected county -wide. We're in the Key West 21 division of the Southern District Court, so they 22 will pick their jury county -wide, as opposed to 23 state court they divide it up into the three areas 24 that we have. And you won't know until you actually 25 get that panel in there, you would be able to get a All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West i to 1 better understanding once you know who your jurors 2 are, at least what the potential panel are, what 3 kind of chances you have. But even so, Mike places 4 the hostile workforce claim at 50 percent and the 5 retaliation claim our chances of victory at 80 6 percent. So we'd still have very good arguments and 7 very good chances of prevailing at trial, especially i 8 j on the retaliation claim. 9 COMMISSIONER NEUGENT: Back up a second on the, 10 explain the hostile, I understand the hostile 11 environment part, but explain the retaliation part 12 of that, the component to that. I 13 MR. SHILLINGER: Which one don't you �I 14 understand? 15 COMMISSIONER NEUGENT: Retaliation claim. i 16 MR. SHILLINGER: The retaliation claim is he 17 treated her demeaning while she was working for him i8 and we took away her supplemental pay and we didn't 19 adequately protect her from the pizza pilot. That's 20 what her retaliation claim is. And our defenses are I 21 obviously we didn't treat her in a demeaning way, i 22 the five percent pay came about because of the 23 policies when she changed positions, and we provided i 24 as much security, we provided more than reasonable I 25 measures to keep her safe. All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West 11 I COMMISSIONER NEUGENT: Okay. I 2 MR. SHILLINGER: So the next slide -- 3 MAYOR DiGENNARO: Commissioner Spehar? 4 COMMISSIONER SPEHAR: You also gave her 5 assistance through medical mental. 6 MR. SHILLINGER: Absolutely. She went through 7 the employee assistance program. And we'll get into j 8 a little bit of that with the damages. But there 9 was a lot of efforts made. At some point whenever i 10 she had a problem she would pick up the phone, she 11 would call our office, Ms. Hutton and I responded on 12 more than a couple of occasions to the office. She i 13 had the assistance of the buzzer that she had under 14 her desk which summoned the deputies at the 15 courthouse next -door, she had the ability to access 16 911. There was extraordinary measures taken to make i 17 her feel comfortable in this position, and yet her 18 own testimony is nothing would make her feel safe. 19 The next slide, assuming, this next slide 20 assumes we lost on summary judgment and the jury 21 ruled in her favor on at least one of her two 22 claims. You're getting farther out from where you 23 are right now and the projections get even more 24 speculative. But Mike put a number on it for us. 25 He says it's about a 25 percent chance if we found All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West i 12 1 ourselves in this position of prevailing on appeal. 2 So obviously if you lost at summary judgment and you 3 lost at trial you're not standing very good when you 4 go up on appeal. But we wanted to give you those 5 projections. 6 Her claim, this is what she's asking for. This 7 is an overview. Her claim ranges in value from 8 about 155 to about 580, and that's based on what 9 we've been able to determine from her damages. Her 10 economic damages, lost wages, range between five and i 11 45,000. Her non -economic damages, pain and 12 suffering, that's capped at 300,000 by federal law. 13 Her attorney's fees and costs if she prevailed all 14 the way through h and we were ordered to pay we figure 15 would be between 150 and 235. 16 And I've broken these down. Again, the 17 economic damages, lost wages. The 2,000 is the lost 18 five percent pay bump that she had. The 40,000 is 19 if she was able to recover wages from the time she 20 left Monroe County until she started her new job in 21 Massachusetts, which incidentally pays more than she 22 was making for us, so she's going to have a very i 23 difficult time proving to a court that she was 24 damaged by the job change. She had some healthcare 25 expenses, minimal amount, $600. Out-of-pocket I All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 10 21 22 23 24 25 expenses for moving expenses, she's attributing about 2,500. So that's where we came up with that. The non -economic damages, the pain and suffering, there's really no way to quantify it other than to tell you it's capped at law at 300,000. Attorney's fees, this again is an estimate on where her range would be, 150 to 200 after trial and you add another 20 to 35 on an appeal. So there's, and that's how we got down to our ranges to the total claim. The County's exposure is limited to $100,000. We're insured through the Florida League of Cities, so they have an insurance policy that we participate in. It's the Florida Municipal Insurance Trust. The first $100,000 the County pays. Everything i beyond that gets reimbursed by the Florida League. Now, that includes the County's own defense costs and fees that we've incurred so far, so whatever we spend on the case, whether it's a judgment, whether it's her attorney's fees, whether it's ours, once you meet that hundred -thousand -dollar threshold it's the League's money that's getting spent, not the County's. We've been billed roughly $42,000 for the attorney's fees and costs by our firm and by Mike All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West 14 1 Burke's firm working through May. It's probably a 2 little bit more than that here in June. i 3 COMMISSIONER NEUGENT: Bob, have we been, are 4 we obligated to talk to the League and say, look, 5 we're in this? 6 MR. SHILLINGER: We've notified the League. 7 The League is fully aware of every material stage in 8 the event. We've had a couple of conversations with 9 the adjuster. The first thing you do in risk 10 management when you get a claim is notify your 11 insurance carrier. Obviously these are hard costs 12 at 42,000. That excludes the staff costs and time 13 from our folks. It's funded out of the risk 14 management budget. 15 Future expenditures. To get ready to go to 16 trial and to try the case, we're probably looking at 17 another 50 to 75,000. 18 MAYOR DiGENNARO: But our maximum is only a 19 hundred thousand? 20 MR. SHILLINGER: Right. 21 MAYOR DiGENNARO: So -- 22 MR. SHILLINGER: I know. That would get us up 23 to the limit. 24 MAYOR DiGENNARO: Why are we even discussing i 25 that? All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West I 15 1 MR. SHILLINGER: Well, I at least need to give 2 you where we are. 3 An appeal would cost another 20 to 35. Again, i 4 once we reach the hundred it becomes the League's 5 money. Now, the important thing to understand, 6 though, is once it becomes the League's money they 7 have the right to settle the claim even without our 8 consent. 9 MAYOR DiGENNARO: I have one question, though. 10 Do they have the right to settle it except that we 11 would refuse to but then we're on our own? They'll i 12 only go to a certain amount? 13 MR. SHILLINGER: They will pay something to get 14 out of the claim. 15 MAYOR DiGENNARO: Pay to get out of the claim, I 16 but it doesn't stop us from going forward? 17 MR. SHILLINGER: If we wanted to fund it on our 18 own. They have the right to buy their way out of 19 the claim. 20 MAYOR DiGENNARO: To buy their way out of the I 21 claim. Okay. i 22 COMMISSIONER NEUGENT: And the other thing that 23 was pointed out was that you go on appeal to a 25 24 percent. 25 MR. SHILLINGER: If you've lost all the way and All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West 16 1 you get it on appeal you obviously are standing in a 2 much worse position than if you won earlier in the 3 case. 4 The League is made up of members of local 5 government, so they are very adaptive and respectful 6 of the wishes of a commission. I don't think that 7 for this type of case they're going to take over the 8 claim and settle it out from under you. But you 9 just need to know that that is a potential if things 10 continue to, if things look like they're going to II 11 get out of control. j 12 MAYOR DiGENNARO: Let me ask you this question. 13 If she was to settle tomorrow for $50,000 or $20,000 14 above our hundred, is this a decision that they i 15 would make, or would they still stand up for what's 16 right? i 17 MR. SHILLINGER: I'm sorry? I don't 18 understand. Back it up a second. 19 MAYOR DiGENNARO: If there was a settlement 20 negotiation. I, 21 MR. SHILLINGER: Okay. 22 MAYOR DiGENNARO: In the settlement negotiation 23 let's say we're responsible for the first hundred 24 thousand and she reduced her settlement -- i 25 MR. SHILLINGER: Down to 120? i All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West 17 1 MAYOR DiGENNARO: To 120, and they're saying, 2 well, 20,000 for us to get out of it is a good 3 business decision, would they do that, or would they 4 still stand up for what's right? 5 MR. SHILLINGER: They would stand up until the 6 County wanted to -- for something small like that 7 they wouldn't cut the County loose. 8 MAYOR DiGENNARO: Okay. Thank you. 9 MR. SHILLINGER: And that's my understanding 10 based on my experience and conversations. 11 MAYOR DiGENNARO: Okay. 12 MR. SHILLINGER: Now, her settlement proposal, 13 at mediation she made an offer of $200,000. That's 14 everything. Taxes, tag, title, drive the car off l 15 the lot, even the floor mats, okay? Based on what i 16 we've spent so far we'd have to kick in about 55 for 17 that, and the balance would come from the Florida I 18 League. She also, as part of her settlement 19 proposal the Board would have to adopt a resolution 20 applying the County's existing sexual harassment 21 policy, making sure that it applies to the 22 Commissioners. We say it already does, they say 23 there's nothing explicit that says that, but that's 24 what she's asked that she's conditioned a settlement 25 on. Our recommendation, and this is in concurrence All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West 1 2 3 4 5 6 7 8 9 10 11 i i 12 13 14 15 16 17 18 19 20 21 22 23 24 25 18 with Mr. Burke's, is that we reject the proposal, we defend the case, we know where we're going on summary judgment, we think we have a good chance on that, and so we continue to defend the case and reject her offer. We could always come back and reassess our position after summary judgment is i ruled on and prior to going to trial, which is currently set to go to trial in the first week in October. So any questions? MAYOR DiGENNARO: Just the one. Our exposure right now would be another $45,000 and that's it? MR. SHILLINGER: Yeah. Or 55. MAYOR DiGENNARO: Whatever it is. Let's move on. MR. SHILLINGER: Okay. I have the direction I need now. If somebody wants to do something different I can, you know, we'd have to do that in an open session, but I think we're good. MAYOR DiGENNARO: Okay. Then we'll close the session? MR. SHILLINGER: Yes. MAYOR DiGENNARO: The session is closed. (This concludes the closed session.) All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West 19 1 C E R T I F I C A T E 2 STATE OF FLORIDA ) 3 COUNTY OF MONROE ) 4 I, Susan I L. McTaggart, Court Reporter and Notary 5 Public, State of Florida at Large, do hereby certify that I 6 was authorized to and did report by stenotype the proceedings in the above -entitled matter, and that the j 8 transcript is a true record of said proceedings. 9 Dated this 15th day of July 2008. 0 Susan L. McTaggart, Court Reporter �13 I li 14 i5 I' _6 i8 19 n' �l 2 23 24 All Keys Reporting - Court Reporters - (305) 289-1201 Locations in Key Largo, Marathon & Key West