Item K1County �� Mo
G
�' '
BOARD OF COUNTY COMMISSIONERS
� s
Mayor David Rice, District 4
T he Fl orida Keys
M,'� °
M ayor Pro Tern Syl v i a J. M u rphy, D i stri ct 5
Danny L. Kolhage, District 1
Gorge Neugent, District 2
Heather Carruthers, District 3
County Commission Meeting
May 16, 2018
Agenda Item Number: K.1
Agenda Item Summary #4048
BULK ITEM: No DEPARTMENT: County Attorney's Office
TIME APPROXIMATE: STAFF CONTACT: Bob Shillinger (305) 292 -3470
1:30 P.M. CLOSED SESSION
AGENDA ITEM WORDING: An Attorney- Client Closed Session in the matters of AshBritt, Inc.
v. Monroe County, FL and Florida Department of Transportation, Case No. CA -K -17 -802.
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 Christine Limb ert-B arrows, special
litigation counsel Jeff Hochman and a certified court reporter.
PREVIOUS RELEVANT BOCC ACTION:
4/19/18 (P2) BOCC scheduled a closed session for May 16, 2018 in Key West, FL at 1:30 p.m. or as
soon thereafter as may be heard
CONTRACT /AGREEMENT CHANGES:
N/A
STAFF RECOMMENDATION: N/A
DOCUMENTATION:
Closed Session Script AshBritt BOCC 5 16 18
FINANCIAL IMPACT:
Effective Date: N/A
Expiration Date:
Total Dollar Value of Contract: N/A
Total Cost to County: Court Reporter Costs
Current Year Portion:
Budgeted: Yes
Source of Funds: 67501 - 530330
CPI: N/A
Indirect Costs: N/A
Estimated Ongoing Costs Not Included in above dollar amounts:
Revenue Producing:
Grant:
County Match:
Insurance Required:
Additional Details:
If yes, amount:
N/A
REVIEWED BY:
Chris Ambrosio
Bob Shillinger
Kathy Peters
Board of County Commissioners
Completed
Completed
Completed
Pending
04/20/2018 9:02 AM
04/30/2018 5:05 PM
04/30/2018 6:07 PM
05/16/2018 9:00 AM
Mayor's Script
For the day of Closed Session
The following should be read at the appropriate point during the day of the closed session.
1. Prior to going into closed session.
A closed attorney - client session pursuant to Section 286.011(8), Florida Statutes, will now be held. It is
estimated that this meeting will take approximately thirty (30) minutes. The persons attending the meeting will
be the County Commissioners, County Administrator Roman Gastesi, County Attorney Bob Shillinger,
Assistant County Attorneys Chris Ambrosio and Christine Limb ert-B arrows, special litigation counsel Jeff
Hochman, Esq, and a certified court reporter.
Since the law prohibits any other person from being present at the closed session, the commissioners, the
County Administrator, the attorneys for the County and the court reporter will now remain in this meeting
room, and all other persons are required to leave the room. When the closed session is over, we will re- convene
and re -open the public meeting. This public meeting is now closed.
2. At the beginning of the closed session.
I now call this closed session to order. For the record, this meeting is being held upon the request of the County
Attorney Bob Shillinger who announced at a prior BOCC Meeting held on 4/19/2018 that he needed advice in
the matter of AshBritt, Inc. v. Monroe County, FL and Florida Department of Transportation, Case No. CA -K-
17 -802. At that meeting, the Board approved holding a closed session and public notice was given through
public announcement of the meeting at the 4/19/18 BOCC meeting and through publication of the 5/16/18
BOCC meeting agenda on the County's website.
For the record, and the benefit of the court reporter, each of us will state our name and position starting
with the commission.
(After all have identified themselves) — Thank you.
Just as a reminder, we will only be discussing settlement negotiations and strategy relating to litigation
expenditures. We cannot 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 open
to the public.
Let's start our discussion with the County Attorney.
3. At the end of the closed session, prior to going into open session.
This closed session is now terminated and we will not reconvene in the public meeting.
4. After the public session has been re- opened.
The attorney — client session has been terminated, and we are now re- opening this public meeting.
' W, BOARD OF COUNTY COMMISSIONERS
County of Monroe + � Ifu�� �, Mayor Craig Cates,District 1
ti Mayor Pro Tem Holly Merrill Raschein,District 5
The Florida Keys ra Michelle Lincoln,District 2
James K.Scholl,District
Robert B.Shillinger,County Attorney** tdw David Rice,District 4
Pedro J.Mercado,Sr.Assistant County Attorney**
Cynthia L.Hall,Sr.Assistant County Attorney**
Christine Limbert-Barrows,Assistant County Attorney** Office of the County Attorney
Derek V.Howard,Assistant County Attorney** I I11 12'Street,Suite 408
Peter H.Morris,Assistant County Attorney ** Key West,FL 33040
Patricia Fables,Assistant County Attorney (305)292-3470 Office
Joseph X.DiNovo,Assistant County Attorney** (305)292-3516 Fax
Kelly Dugan,Assistant County Attorney
Christina Cory,Assistant County Attorney
Nathalia Archer,Assistant County Attorney
**Board Certified in City,County&Local Govt.Law
April 28, 2023
Kevin Madok, CPA
Clerk of the Court, 16'Judicial Circuit
500 Whitehead Street
Key West, FL 33040
In Re: Ashbritt, Inc. v. Monroe County, Case No.: 17-CA-802-K
Dear Mr.Madok:
Please find attached scans of transcripts of six (6) closed attorney-client sessions of the Monroe County Board
of County Commissioners, with regard to the above-entitled civil matter. The closed sessions occurred on:
05/16/2018; 02/20/2019; 05/08/2020; 05/25/2021; 09/12/2022; and, 02/13/2023. Under F.S. 286.011(8), these
transcripts may be made part of the public record, as the litigation has concluded.
Thank you for your assistance in this matter. Please contact me should you have any questions.
Sincerely
Digitally signed by Robert B.Shillinger
Robert B. Shillinger ou cn=Robert B.Shillinger, ,Monroe County BOCC,
ou=Monroe County Attorney,email=shillinger-
bob@monroecounty-fl.gov,c=uS
Date:2023.04.28 15:04:07-04'00'
Robert B. Shillinger
Monroe County Attorney
Attachments: Six closed session transcripts dated 05/16/2018;02/20/2019;05/08/2020;05/25/2021;09/12/2022,02/13/2023
Confidential Closed Session Work Product
May 16 , 2018
MONROE COUNTY
BOARD OF COUNTY COMMISSIONERS
CLOSED SESSION
ASHBRITT, INC.
VS .
MONROE COUNTY, FLORIDA
CASE NO. CA-K-17-802
APPEARANCES :
Mayor David Rice
Mayor Pro-Tem Sylvia J. Murphy
Commissioner George Neugent
Commissioner Heather Carruthers
Commissioner Danny L. Kolhage
Roman Gastesi , County Administrator
Robert B. Shillinger, County Attorney
Jeff Hochman, Esquire, Special Litigation Counsel
Harvey Government Center
Commission Chambers
1200 Truman Avenue
Key West, Florida 33040
Wednesday, May 16 , 2018
1 : 30 p .m. - 1 : 47 p .m.
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1 (WHEREUPON, the following proceedings were
2 had on May 16 , 2018 , at 1 : 30 p.m. , with all parties
3 present : )
4 THE CLERK: The next item is K-1 , an
5 Attorney-Client Closed Session in the matters of
6 Ashbritt , Inc . vs . Monroe County, Florida and
7 Florida Department of Transportation, Case Number
8 CA-K-17-802 .
9 MR. SHILLINGER: All right . We ' re getting
10 ready to proceed to an attorney-client Closed
11 Session that will be held pursuant to Florida
12 Statute Section 286 . 011 (8) . It ' s estimated this
13 meeting will take approximately thirty minutes .
14 The persons attending the meeting will be the
15 County Commissioners , County Administrator Roman
16 Gastesi , myself , Bob Shillinger, County Attorney.
17 None of my Assistant County Attorneys are here at
18 this moment , but we do have special litigation
19 counsel , Jeff Hochman, and a certified court
20 reporter.
21 Since the law prohibits any other person from
22 being present at the closed session, the
23 Commissioners , the attorney, the administrator for
24 the County and the court reporter will now remain
25 in the meeting, and all other persons are required
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1 to leave the room. When the session is over, we
2 will reconvene and reopen the public meeting.
3 Mr. Mayor, are you going to declare the open
4 session closed?
5 MAYOR RICE : I do so declare .
6 (Brief pause . )
7 MR. SHILLINGER: All right . Mr. Mayor - -
8 COMMISSIONER NEUGENT : You don ' t have to
9 leave, Sylvia .
10 MR. SHILLINGER: She ' s closing the door.
11 MAYOR RICE : She ' s got to close the door.
12 MR. SHILLINGER: Mr. Mayor, are you calling
13 the closed session to order.
14 MAYOR RICE : I am.
15 (Beginning of closed session. )
16 MR. SHILLINGER: All right . For the record,
17 this is being held at my request . I announced at
18 a prior BOCC meeting held on April 19, 2018 , that
19 I needed your advice in the matter of Ashbritt vs .
20 Monroe County, CA-K-17-802 . At that meeting, the
21 Board approved holding a Closed Session. Public
22 notice was given through public announcement at
23 that meeting, at that April 19th BOCC meeting, and
24 through publication of the agenda for today' s
25 date, today' s meeting, held on May 16th, 2018 , on
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1 the County' s website .
2 For the record and benefit of the court
3 reporter, each of us will state our names and
4 positions starting with the Commission.
5 COMMISSIONER CARRUTHERS : Commissioner
6 Carruthers, District 3 .
7 COMMISSIONER NEUGENT : Commissioner Neugent ,
8 District 2 .
9 MAYOR RICE : Commissioner Rice, District 4 .
10 COMMISSIONER MURPHY: Commissioner Murphy,
11 District 5 .
12 COMMISSIONER KOLHAGE : Commissioner Kolhage,
13 District 1 .
14 MR. GASTESI : Roman Gastesi , County
15 Administrator.
16 MR. SHILLINGER: Bob Shillinger, County
17 Attorney.
18 MR. HOCHMAN: And Jeff Hochman, Special
19 Litigation Counsel .
20 MR. SHILLINGER: Just for the record and
21 benefit of the court reporter, each of us - - well ,
22 we will only be discussing settlement negotiations
23 and strategy related to litigation expenditures .
24 We can ' t take any decisive action at this meeting.
25 We can only provide information and direction to
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1 the attorneys . Any decisions this Board makes
2 concerning this case must be done in a meeting
3 that ' s open to the public .
4 So I ' m going to turn it over to Jeff . He ' s
5 going to update us on where we are in the
6 litigation right now.
7 MR. HOCHMAN: Good afternoon. This case is
8 now in a posture where a complaint was filed by
9 the Plaintiff AshBritt , and Monroe County has
10 filed an answer and multiple defenses .
11 Basically, the case involves whether AshBritt
12 has been properly paid under the contract for
13 disaster recovery services . Monroe County' s
14 position is it has been paid on everything to the
15 extent that AshBritt submitted a proper invoice
16 that was properly backed up with the information
17 required by the contractor, and also to allow for
18 FEMA reimbursement . The contract and Florida law
19 provides very specific kinds of information that
20 they' re supposed to provide and they just haven ' t
21 done that quite yet . On things that they have
22 provided all the information, they' ve been paid.
23 On things that the information is still
24 outstanding, Monroe County has asked for
25 clarifications , additional work, additional
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1 information. Once that information is received,
2 we ' ll process the payment . There are some
3 disputes as to substantive matters about whether
4 they performed services which are contemplated by
5 the contract and there will be a dispute about
6 that going forward.
7 It looks like Monroe County is in a good
8 position to prevail on the case . The contract
9 language is good for Monroe County, the statutes
10 that apply are good for Monroe County, and we
11 believe that there is a better than fifty-percent
12 chance that we ' ll prevail on the currently-pled
13 claims .
14 Right now, a couple of people have been
15 deposed. Judy Clarke was deposed. Your Assistant
16 County Administrator Kevin Wilson was deposed.
17 And, the Emergency Operations Manager Kevin [sic]
18 Senterfitt was also deposed. They' re looking to
19 depose two more people in the next couple of weeks
20 which will be the County Administrator and former
21 Mayor George Neugent . Those are going to be
22 scheduled in probably the middle of June . So far,
23 there is no information we ' ve received so far that
24 looks like it is a problem that cannot be resolved
25 for Monroe County.
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1 The reason we ' re here today is because on
2 May 14 , we received a letter that , as a
3 theoretical matter, was some sort of settlement
4 proposal . And they basically - - received from
5 AshBritt ' s attorney saying that they would like to
6 kind of negotiate and create good feelings with
7 Monroe County, and they would waive their claim
8 for what they claim is lost profits associated
9 with a portion of the contract which they did not
10 perform from mile marker 16 through 40 .
11 COMMISSIONER CARRUTHERS : How can they claim
12 lost profits if they didn ' t do the job?
13 MR. HOCHMAN: Well , it is a - - it ' s a legal
14 idea that they have offered to the Court . We have
15 responded saying that the contract doesn ' t allow
16 for it , it doesn ' t allow under Florida law for it ,
17 and the Court will have to resolve that . We plan
18 to file a motion for summary judgment where the
19 Court can look at the undisputed facts in the
20 case, apply Florida law, and make a determination
21 as to whether that theory of liability is valid
22 under Florida law. So we ' re not quite there at
23 the motion for summary judgment stage yet . We
24 need to complete discovery. And once we get there
25 we ' ll be asserting the idea that a lost profits
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1 claim is not a valid claim in the first instance .
2 Right now, the issue is Monroe County, today,
3 has indicated they were going to issue a notice to
4 AshBritt indicating that their contract , which was
5 in place, will be terminated for convenience .
6 That will be effective in ninety days . We expect
7 AshBritt to try to either avoid that or negotiate
8 with Monroe County to get back into a contract
9 status with Monroe County. We believe they' re
10 willing to do that because their having a status
11 with Monroe County of a valid enforceable contract
12 rather than a terminated contract may have a
13 negative impact on them when they contract with
14 other municipalities and respond to requests for
15 proposal . Meaning that they want to have a good
16 reputation of not having been a terminated
17 contractor with respect to another governmental
18 agency in the State of Florida.
19 So it is possible that they will now come
20 back and say, we ' d like to get back in your good
21 graces . And today' s discussion is really to get a
22 consensus , not a decision, as to whether, if that
23 were to be offered back to Monroe County, we will
24 either dismiss claims or try to resolve claims if
25 you ' ll put us back into a contract status . And
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1 that is something which is for you to consider.
2 I would suggest that your comments , remember
3 we are on an Executive Session, but if the
4 litigation were to conclude, the transcript of
5 this meeting would be available to both AshBritt
6 and the public . And so the issue really needs to
7 be focused on if there ' s a willingness by Monroe
8 County to kind of entertain the notion that a
9 partnership could go forward at some point in the
10 future with AshBritt .
11 MAYOR RICE : If it could go forward.
12 MR. HOCHMAN: Right . The idea, would they be
13 offering some sort of litigation accommodation,
14 either to dismiss their lawsuit or to resolve some
15 of the invoices --
16 COMMISSIONER CARRUTHERS : If we give them a
17 new contract?
18 MR. SHILLINGER: Or if we don ' t . We rescind
19 our termination for convenience, allow them to be
20 a terminated - - either a mutual termination or
21 active contractor status, but we don ' t necessarily
22 have to activate them because we have other
23 contractors as well .
24 MAYOR RICE : And your recommendation is?
25 COMMISSIONER CARRUTHERS : Well , how do we do
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1 that now? We just - - we just did the termination
2 earlier this morning.
3 MR. SHILLINGER: Right . So our
4 recommendation isn ' t to do it unless it ' s a way of
5 solving the suit , and they haven ' t pitched that
6 yet .
7 MR. GASETSI : I would say if it includes
8 paying this guy' s bill and whatever other expense
9 that you ' ve had, maybe .
10 MR. SHILLINGER: Right .
11 COMMISSIONER CARRUTHERS : Maybe .
12 MR. GASETSI : Maybe . I don ' t know how much
13 we ' re into this .
14 COMMISSIONER CARRUTHERS : I ' m don ' t - - I ' m
15 not - -
16 MR. GASETSI : Yeah, I ' m not crazy about it
17 either but, I mean, it has to be a total clean
18 slate, you know.
19 COMMISSIONER CARRUTHERS : And no liability on
20 our part .
21 MR. GASETSI : Exactly. And no promises on
22 our part .
23 COMMISSIONER CARRUTHERS : Right .
24 MAYOR RICE : I like that .
25 MR. SHILLINGER: And, again, we ' re not asking
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1 you to vote on anything right now. That hasn ' t
2 been proposed yet . We just anticipate that might
3 be where this is going and wanted to take your
4 temperature on that so we would know how to
5 negotiate .
6 MR. HOCHMAN: Right . As you know, we
7 negotiate on behalf of our client going forward.
8 It ' s easier, easier for the lawyers to negotiate
9 when they know approximately what the consensus is
10 more likely to be like on certain issues .
11 It seems to us that they' re - - one of the
12 primary issues for them is their status , their
13 status and reputation as being a contractor that
14 has not been terminated from a government
15 contract . Right now, what happened today, puts
16 that status in jeopardy for them. And the
17 question then is , how valuable is their status to
18 them.
19 We believe, if it is valuable to them,
20 they' ll come back to us and say, we ' d like you to
21 do something to restore our status . And we ' re
22 here today asking you, if they come back and ask
23 us to restore their status , what are we going to
24 negotiate with back and say, we will consider it
25 but you have to offer me A, B or C .
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1 And right now, from what I ' ve heard so far,
2 is they would have to dismiss the lawsuit with
3 prejudice, they' d have to pay attorneys fees .
4 COMMISSIONER CARRUTHERS : All attorneys fees .
5 MR. HOCHMAN: Are there any other
6 considerations that you would like to explore or
7 discuss just so I have a good sense of how to
8 evaluate their negotiation and possibly come back
9 to you with a solid offer.
10 COMMISSIONER CARRUTHERS : Pain and suffering.
11 MR. SHILLINGER: Mints on the pillow.
12 COMMISSIONER KOLHAGE : What gives you the
13 impression that they really care about their
14 status?
15 MR. HOCHMAN: The only basis I have, quite
16 frankly, is they sent me a letter on - - actually,
17 they sent it to Bob Shillinger on March 14 ,
18 suggesting that --
19 MR. SHILLINGER: May. May 14 .
20 MR. HOCHMAN: I ' m sorry.
21 MR. SHILLINGER: May.
22 MR. HOCHMAN: I ' m sorry. The date of the
23 letter, I apologize, is May 14 , 2018 . The letter
24 indicates that there is an incentive in their
25 mind, there ' s an incentive in their mind to
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1 preserve their status as a contractor for Monroe
2 County.
3 COMMISSIONER KOLHAGE : Did they say that?
4 MR. HOCHMAN: Yes .
5 COMMISSIONER KOLHAGE : Okay. That ' s all I
6 want to know. The reason I ask that , because it
7 seems contrary to the way they have behaved up to
8 now.
9 COMMISSIONER CARRUTHERS : Yeah, I was going
10 to say the same . And certainly, that behavior is
11 public record.
12 COMMISSIONER KOLHAGE : Yeah.
13 MR. GASETSI : And, Jeff , with everybody
14 listening, I ' d like to say something.
15 MR. HOCHMAN: A quote from the second page of
16 the letter, "The County' s unilateral decision to
17 terminate the agreement is unnecessarily hostile
18 to a resolution of this dispute and eliminates the
19 incentive for AshBritt to resolve this matter,
20 short of trial . " So their idea of this being an
21 incentive to maintain their status is really what
22 leads me to the conclusion that they believe it ' s
23 valuable .
24 MR. SHILLINGER: Yeah. And they mentioned as
25 much. Prior to the letter of May 14th, we had a
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1 phone conversation. May 14th was a Monday, so it
2 was the preceding Friday, so that would have been
3 the llth, where they explicit - - with Jared
4 Moskowitz , the general counsel for AshBritt , said
5 that their concern is that when they' re responding
6 to future RFPs , having a terminated status affects
7 the way they may have to answer those . So they - -
8 and I said, all right . Well , put it in writing
9 and send us an offer.
10 COMMISSIONER KOLHAGE : But they sued us ,
11 right?
12 MR. SHILLINGER: Yeah. I mean, it ' s - - we ' re
13 not - - we ' re not vouching for the validity of
14 their position. We ' re just conveying.
15 COMMISSIONER KOLHAGE : Yeah, I understand.
16 I ' m just , I ' m questioning the credibility of that
17 offer.
18 MR. SHILLINGER: Understood.
19 MR. HOCHMAN: And there ' s two ways that
20 theoretically we could preserve their status . One
21 would be to actually restore them to their primary
22 role, theoretically, with a contract that if
23 there ' s a storm and Monroe County needs disaster
24 recovery services, AshBritt would be called upon
25 under the terms of the contract to provide certain
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1 services .
2 The other idea would be that they would
3 simply have that status , the contract would be in
4 place, but they would acknowledge that there is an
5 accommodation going on where they don' t have this
6 terminated status but also, Monroe County would
7 not be relying on them to perform any services
8 based upon certain dissatisfaction with the way
9 they billed for the past services , a lack of
10 paperwork, some of the more administrative
11 problems that have arisen since their services
12 were provided.
13 MR. SHILLINGER: Roman, you had a question?
14 MR. GASETSI : Yeah. And one of the
15 Commissioners reacted to this too when you said
16 something about claims , lost profits , whatever,
17 between mile marker 16 and 40 . Yet Randy got up
18 there at the same podium you ' re standing at right
19 now and while everything was going on with DOT and
20 DOT had claimed that area, he was the one that
21 said, let DOT do it .
22 So, I mean, do you know that? I mean, I
23 don ' t know if you actually know that but I think
24 that ' s important to express that to them. if
25 they' re going to have any claims , they understood
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1 at the time, they tried to get the rates changed.
2 They were going to change the rates and that ' s
3 when he said, well , let DOT do it .
4 MR. HOCHMAN: I have seen the video of his
5 testimony. It is an important piece of evidence
6 in the case . I do know that AshBritt has legal
7 arguments to support their notion that what was
8 said was either not very important to the case or
9 not legally binding on AshBritt , and they' re still
10 pursuing their claims under the contract .
11 MR. GASETSI : So is that - - so when I go do
12 my deposition, when I say it doesn ' t matter
13 anyways , I should show up?
14 MR. HOCHMAN: I would suggest that truthful
15 testimony will set you free .
16 COMMISSIONER NEUGENT : Well , he also claimed
17 he wasn ' t going to sue us , so .
18 COMMISSIONER CARRUTHERS : Yeah, exactly.
19 MR. HOCHMAN: That is also part of the
20 videotape and it is , again, important evidence in
21 the case .
22 COMMISSIONER NEUGENT : Well , he can probably
23 say, " I didn ' t mean that, either. "
24 COMMISSIONER CARRUTHERS : Well , clearly he
25 didn' t .
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1 MR. HOCHMAN: It does sound like I have a
2 general consensus at this point , which is that if
3 AshBritt were to submit some sort of request to
4 preserve its status , I , from what you have told me
5 so far, I think I understand what the terms of
6 what they would also have to offer Monroe County
7 as preliminary negotiations before I come back and
8 ask you to actually consider the precise word-for-
9 word offer provided by them.
10 Is there anything else you would like me to
11 know before I conclude today?
12 MAYOR RICE : Not here .
13 COMMISSIONER NEUGENT : You ' d be the only one
14 that didn ' t know my feelings .
15 MR. HOCHMAN: I also watched the videotape of
16 that expression as well .
17 MR. SHILLINGER: All right . So --
18 MR. HOCHMAN: Thank you very much for your
19 time this afternoon.
20 MR. SHILLINGER: Mr. Mayor, are you going to
21 declare the closed session closed?
22 MAYOR RICE : I do.
23 MR. SHILLINGER: All right . We ' ll get the
24 public back in here .
25 (Closed session concluded at 1 : 47 p .m. )
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1 CERTIFICATE OF REPORTER
2
3 STATE OF FLORIDA )
4 COUNTY OF MONROE )
5
6 I , Suzanne Ex, Certified Verbatim Reporter
7 and Florida Professional Reporter, do HEREBY CERTIFY
8 that I was authorized to and did report the foregoing
9 proceedings ; and that the transcript , pages 1 through
10 17 are a true and correct record of my notes .
11
12 I further certify that I am not a relative,
13 employee, attorney, or counsel of any of the parties ,
14 nor am I a relative or employee of any of the parties '
15 attorneys or counsel connected with the action, nor am
16 I financially interested in the action .
17
18 Dated this 24th day of May, 2018 .
19 '
20 rui
21
22 Suzanne E�; CVR-M, FPR
23 Certified Verbatim Reporter
24 Florida Professional Reporter
25
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May 16 , 2018 1
9 : 6 , 24 10 : 5 , available 9 : 5 13 : 9
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17 , 18 , 20 6 : 5 , 9 : 9 CARRUTHERS 11, 19 : 17 11 , 2
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8 : 14 , 20 , 21, 25 12 : 3 , 4 23 12 : 4 , 10 9 : 21 11 : 13
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May 16 , 2018 2
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contractors 9 : 14 12 : 2 fees 12 : 3 , 4 8 : 17
9 : 23 dispute 6 : 5 FEMA 5 : 18 graces 8 : 21
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days 8 : 6 8 : 11 here 7 : 1
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May 16 , 2018 3
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24 9 : 3 , 7 , 11 , 10 : 4 , 7 , 16 , 17 7 : 21 10 : 19 mile 7 : 10
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6 : 7 , 24 7 : 13 , 13 : 16125 no 6 : 23
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May 16 , 2018 4
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8 : 1 , 16 , 22 outstanding 10 : 21 resolution
10 : 15 , 16 , 25 5 : 24 proper 5 : 15 13 : 18
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primary 11 : 12 Session 9 : 3
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May 16 , 2018 5
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sic 6 : 17 13 : 17 they' d 12 : 3 7 : 19
slate 10 : 18 terminated they' ll 11 : 20 unilateral
so 5 : 4 6 : 22 , 8 : 5 , 12 , 16 they' re 5 : 20 13 : 16
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solid 12 : 9 than 6 : 11 things 5 : 21, up 5 : 16 13 : 7
solving 10 : 5 8 : 12 23 update 5 : 5
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submitted 13 : 1, 20 , 21 23 , 25 12 : 2 , 3 , 13 : 6
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substantive 9 : 16 , 19 , 22 13 : 6 , 7 , 10 , 14 , was 5 : 8 , 16
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summary 7 : 18 , 11, 23 7 : 22 , 24 9 : 4 22 , 25 10 : 1
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supposed 5 : 20 there ' s 9 : 7 try 8 : 7 , 24 23 , 24 13 : 25
12 : 25 turn 5 : 4 we ' d 8 : 20
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9 : 12 10 : 5 10 : 13 , 25
11 : 4 11 : 9 , 22 12 : 2 , under 5 : 12 11 : 21
13 , 16 , 17 7 : 16 , 22
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May 16 , 2018 6
we 've 6 : 23 you've 10 : 9
weeks 6 : 19 your 6 : 15
well 7 : 13 8 : 20 9 : 2 , 24
9 : 2 3 , 2 5 11 : 3
were 8 : 3 , 23
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