Item R1County of Monroe
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BOARD OF COUNTY COMMISSIONERS
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Mayor David Rice, District 4
IleOI1da Keys
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Mayor Pro Tem Sylvia J. Murphy, District 5
Danny L. Kolhage, District I
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George Neugent, District 2
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Heather Carruthers, District 3
County Commission Meeting
March 21, 2018
Agenda Item Number: R.1
Agenda Item Summary #3958
BULK ITEM: No DEPARTMENT: County Attorney's Office
TIME APPROXIMATE: STAFF CONTACT: Bob Shillinger (305) 292 -3470
N/A
AGENDA ITEM WORDING: County Attorney Report for March 2018.
ITEM BACKGROUND: See attached.
PREVIOUS RELEVANT BOCC ACTION: N/A
CONTRACT /AGREEMENT CHANGES:
N/A
STAFF RECOMMENDATION: N/A
DOCUMENTATION:
County Attorney Report March 2018 UPDATED
Script Request for April 19, 2018 Closed Session (Denenberg v MMC)
Script Request for April 19, 2018 Closed Session (KWRU)
FINANCIAL IMPACT:
Effective Date: N/A
Expiration Date:
Total Dollar Value of Contract:
Total Cost to County:
Current Year Portion:
Budgeted:
Source of Funds:
CPI:
Indirect Costs:
Estimated Ongoing Costs Not Included in above dollar amounts:
Revenue Producing:
Grant:
County Match:
Insurance Required:
Additional Details:
If yes, amount:
REVIEWED BY:
Bob Shillinger Completed 03/06/2018 3:29 PM
Kathy Peters Completed 03/06/2018 3:31 PM
Board of County Commissioners Pending 03/21/2018 9:00 AM
County of Monroe
nie 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 Fables, Assistant County Attorney
Chris Ambrosio, Assistant County Attorney
** Board Certified in City, County & Local Govt. Law
To: Mayor Neugent & Commissioners
From: Bob Shillinger, County Attorney
Date: March 6, 2018 (Updated 311112018)
Re: March 2018 County Attorney Report
Office of the County Attorney
1111 12 Street, Suite 408
Key West, FL 33040
(305) 292 -3470 —Phone
(305) 292 -3516 — Fax
1. AshBritt, Inc. v. Monroe County & FDOT, CAK17 -802. County's hurricane debris
contractor filed suit against the County and FDOT for breach of contract and
declaratory relief. On 1/30/18, the County appealed to the Third DCA an order
denying a motion for protective order for the depositions of senior county officials.
A closed session is scheduled for the 3/21/18 BOCC meeting. Several motions
scheduled for 3/29/18 and 4/25/18.
2. Galleon Bay Corp. v. Monroe County and State of Florida — 3d16 -1502. The
developer /property owner appealed a final judgment in the amount of $480,511 in
her favor to the Third DCA; the County and State cross appealed. Briefing is
complete. Oral argument held 2/14/18. Opinion expected to be released as early
at 3/7/18.
3. Keith & Cheri Cohen v. Monroe County, 15- 10167 -CIV /USCA 17- 15552 -G — On
7/28/17, U.S. District Judge Jose Martinez entered summary judgment in favor of
the County, ruling that the County's workforce housing requirement that income
must be earned in the County did not discriminate against the Cohens due to their
asserted disabilities. The Court ordered the Cohens to sell their property to a
qualified buyer within 6 months and vacant the premises. The Court awarded the
County's claim for costs of $1,900. On 12/6/17, the Cohens appealed the decision
to the 11 Circuit Court of Appeals and requested a stay of the order compelling
sale of the property. The 11 Circuit has denied the Cohen's motion for stay
without prejudice, allowing for the District Court to rule on it first.
4. Monroe County & State of Florida v. Donald Davis (Collins) — 3D17 -500. On
2/15/17, Judge Jones entered a final judgment in favor of Mr. Davis in the amount
of $347,475. The County and State filed their initial joint brief on 7/17/17. Davis
moved to dismiss the appeal. On 2/2/18, the Third DCA denied Davis' motion to
dismiss the appeal. Davis filed his brief on 3/7/18. the County's reply brief is due
3/19/18.
BOARD OF COUNTY COMMISSIONERS
Mayor David Rice, District 4
Mayor Pro Tem Sylvia J. Murphy, District 5
1/
Danny L. Kolhage, District 1
George Neugent, District 2
Heather Carruthers, District 3
5. Monroe County v. Sugarloaf Volunteer Fire Department, Inc. and Sugarloaf
WiFi, Inc. — CA K 17 — 631 — This suits seeks to void a contract between the
SVFD and Sugarloaf WiFi on the grounds that SFVD did not approve that contact
in a public meeting. WiFi has filed a motion to consolidate its Declaratory
Judgment action against SVFD with the case filed the County. The court granted
the County's motion to strike WiFi's affirmative defenses and found that the SVFD
is subject to F.S. 286.011, the Sunshine Law.
6. In re: Energy3, LLC, 17- 18986, (Bankruptcy S.D. Florida). County's yard waste
vendor filed for Chapter 11 protections after judgment in the amount of $377,873
was entered against them on 7/11/17 as a result of a breach of contract suit filed
by a former partner in the Circuit Court for Miami -Dade County. On 9/27/17, the
Court granted the County's motion for relief from stay which enabled the County to
terminate the underlying waste supply agreement irrespective of the automatic
stay. The County sent E3 a termination letter on 10/20/17. On 2/20/18, the Court
approved a settlement agreement whereby E3 paid off its principal creditor, a
former partner and dismissed the case.
7. Delaney v. FKAA & Monroe County — CAK 16 -439 - Grinder pump easement
litigation — A property owner in the CRWS service area sued the County and
FKAA seeking a judicial declaration that she is not obligated under to connect to
the system unless the grinder pump is located in the public right of way. The
parties are now starting to engage in discovery.
8. Monroe County v. Atlantic Trash & Transfer, LLC /Magnolia 101, LLC. 3D17-
1312. (LT number CAP 13 -945). This code lien is a collection and injunction case
that the Court entered a judgment in favor of the County on 5/2/17. The property
owner has appealed this decision to the Third District Court of Appeal. The
property owner filed its initial brief on 12/31/17. The County has until 3/23/18 to
file its brief.
9. Conover v. Monroe County and Maverick United Elevator, LLC. Case no. CA P
15 -425. The Conovers claim they were injured when the PK Courthouse elevator
malfunctioned and suddenly dropped while they were in the elevator on 11/18/14.
Maverick's insurer recently accepted tender. Maverick's insurer is providing
insurance defense counsel to the County. Discovery is ongoing.
10. Jonathan Sattele v. AAA Auto Club, Monroe County, MCSO, et. al. CA K 17-
457. The Plaintiff was injured in an auto accident while in a car purchased at
auction from MCSO over a decade ago. The County's fleet department maintained
that vehicle. County will be filing a motion for summary judgment.
11. Kelaris v. County, et. al., Case # 17 -CA- 561 -P: The plaintiff drove her vehicle into
a County vehicle being driven by employee. Discovery is just beginning.
12. McDonough v. County, et. al., Case # 17 -CV- 23227: McDonough recently re -filed
this action in Federal court against multiple South Florida governmental agencies
and officials and law enforcement officers. The complaint contains 32 counts and
alleges multiple violations of his Federally protected rights. The action is still
pending and motions to dismiss are filed.
13.Vacation Rental Prosecutions. In January, 17 vacation rental cases appeared on
the agenda; 15 resulted in findings of violation including 6 by stipulation and 2
cases were continued. The Special Magistrate imposed fines of $89,050. In
February, 23 vacation rental cases appeared on the agenda; 18 resulted in findings
of violation, including 3 stipulations. The Special Magistrate imposed fines of
$157,800.
14. Code Compliance Lien Collection cases. For the first 3 months of FY17/18,
county staff with the assistance of legal has collected $413,654.36 in fines and
costs.
Request for Closed Session by County Attorney
For the record, Bob Shillinger, in my capacity as County Attorney for the Board of County
Commissioners of Monroe County.
As you are aware, the County is currently in litigation in the matter of In Re: Marine
Mammal Conservancy, Inc., Case No. 18- 10594 -LMI, United States Bankruptcy Court, Southern
District of Florida, Miami Division. I need your advice concerning the litigation and request that
you schedule at least one private meeting.
The subject matter of this meeting will be confined to settlement negotiations and strategy
sessions related to litigation expenditures.
The persons to be in attendance at this closed meeting will be the County Commissioners,
County Administrator Roman Gastesi, County Attorney Bob Shillinger; Assistant County
Attorneys Derek Howard, Peter Morris, Steve Williams, special litigation counsel Drew Dillworth,
Esq. and a certified court reporter. By law, no other persons are permitted to be present at this
meeting. It is estimated this meeting will take approximately thirty (30) minutes.
As required by law, the court reporter shall record the times of commencement and
termination of the meeting, all discussions and proceedings, the names of all persons present at any
time, and the names of all persons speaking. No portion of the meeting will be "off the record ".
The court reporter's notes will be fully transcribed, sealed, and then filed with Kevin Madok, as
Clerk. The transcript shall be made part of the public record upon conclusion of the litigation.
It is requested that you schedule a closed meeting of the Board to be held at the regularly
scheduled meeting on April 19, 2018 in Marathon, FL at 1:30 p.m. or as soon thereafter as may be
heard.
Request for Closed Session by County Attorney
For the record, Bob Shillinger, in my capacity as County Attorney for the Board of County
Commissioners of Monroe County.
As you are aware, the County is currently in litigation in the matter of KW Resort Utilities
Rate Application, Florida Public Service Commission Docket No. 20170141 -SU. I need your
advice concerning the litigation and request that you schedule a private meeting.
The subject matter of this meeting will be confined to settlement negotiations and strategy
sessions related to litigation expenditures.
The persons to be in attendance at this closed meeting will be the County Commissioners,
County Administrator Roman Gastesi, County Attorney Bob Shillinger; Assistant County Attorney
Cynthia Hall, special litigation counsel John T. LaVia and Robert Scheffel Wright of the law firm
of Gardner Bist, and a certified court reporter. By law, no other persons are permitted to be present
at this meeting. It is estimated this meeting will take approximately thirty (30) minutes.
As required by law, the court reporter shall record the times of commencement and
termination of the meeting, all discussions and proceedings, the names of all persons present at any
time, and the names of all persons speaking. No portion of the meeting will be "off the record"
The court reporter's notes will be fully transcribed, sealed, and then filed with Kevin Madok, as
Clerk. The transcript shall be made part of the public record upon conclusion of the litigation
It is requested that you schedule the closed meeting of the Board to be held at the regularly
scheduled meeting on April 19, 2018 in Marathon, FL at 1:30 p.m. or as soon thereafter as may be
heard.