Item T01
Memorandum
To: Richard Collins, County Attorney
From: Bob Shillinger, Asst. County Attorney
Date: November 18, 2003
Re: November 2003 litigation report
GENERAL LITIGATION
D&J Industries v. Monroe County CA P 99-543
Circuit Court 16th Judge Garcia Date Filed: 10/12/99
Cert. review of the BOCC's decision to award contract for roofing contract for the
Marathon Government Annex to another bidder.
Status:
Closed. Dismissed for lack of prosecution.
Next Activity:
Hearing on BOCC's Motion for Attorney Fees tba.
Time: $5,160.00 Costs: unknown
Hinote Construction v. Monroe County CA P 03-344
Circuit Court (16th) Judge Garcia Date Filed: 6/18/2003
This is a 9 1983 action arising out of a denial by the Planning Commission of a
transfer of commercial square footage to the proposed Walgreen's in Key Largo
against the advise and recommendation of staff.
Current Status: Court granted County an indefinite extension to file an
Answer due to Plaintiff's settlement offer. Court denied Smart Growth Coalition's
motion to intervene.
Next Activity:
BOCC to consider settlement offer at 11/19/2003 meeting.
Time: 19.4 hours
Costs: $50.46
'f. l
Loose. Karl eta/v. Monroe County Case No.: 03-10019-CIV-Highsmith
U.S. Dist. S.D.Fla.: Judge: Highsmith Date Filed: March 4, 2003
This federal ADA case, in which a professional Plaintiff complains of deficiencies
for handicap access in the Key West Court House complex. The CAY engaged
the firm Vernis & Bowling to serve as co-counsel because the matter is in federal
court.
Current Status: The case is in the discovery process.
Next Activity: BOCC executive session scheduled for 11/19/03.
Time: 37.4 hours by CAY Costs: $795.36
V & B has billed for $11,546.14 (Not audited yet.)
Monroe County v. Jerry Cross CAP 03-445
Circuit Court (16th) Judge: Luis Garcia Date Filed: 8/15/03
This is an action for ejectment that was filed against a person who has built a
portion of his home on County right-of-way.
Current Status:
Closed.
Next Activity: Substitute Mark Fraleigh as a party and serve him.
Time: 4.5 hours
Costs: $221.50
Monroe County v. Mark Fraleigh CAP
Circuit Court (16th) Judge: Date Filed:
This is an action for ejectment that will be filed against a person who owns
structures located on County right-of-way. Case against prior owner dismissed
after he sold structures to Fraleigh.
Current Status: Awaiting response from demand letter.
Next Activity: File suit by 12/1/03 if action not taken to remove structures.
Time: Costs:
Monroe County v. Ana M. Martinez CA K 03 - TBA
Circuit Court (16th or 11th) (no judge assigned yet)
Action to foreclose or seek declaration of rights on lien against Cuban biplane.
Current Status: Reached tentative agreement to jointly auction plane on E-Bay.
Next Activity: File declaratory judgment action to determine validity of the lien if
auction falls through.
Time: 15 hours
Costs: $200.00
Moro, Giuseppe v. Monroe County CAM 03-170
Circuit Court (16th) Judge: Jones Date Filed: 6/18/03
Defense of an action to quiet title brought by tax deed purchaser.
Current Status: Amended answer filed October 8, 2003 conceding that County's
interest was properly extinguished by tax deed.
Next Activity: Trial scheduled for 12/2/03 at 4:15 pm in Marathon.
Time: 1.4 hours
Costs: none to date
Oasis Travel v. Monroe County SC K 03-445
County Court (16th) Judge: Miller Date Filed: 10/3/03
Small claims collection action filed against the County by a travel agency that
contends that it is owed money for plane tickets issued to, but unused by, County
employees.
Current Status: Proposed settlement agreement before SOCC on 11/19/03.
Next Activity: Trial 12/29/03 at 1 :30 pm.
Time: 2.6
Costs:
none to date
pep Marina, Inc. v. Monroe County CA K 02-561
Circuit Court (16th) Judge: Payne Date Filed: May 2002
Cert. Petition appeal from denial of change of FLUM and rezoning. This case
had been referred to M&H though that firm took no action because of a conflict.
No notice of said conflict was provided to this office.
Current Status: Parties have moved Court to hold case in abeyance while
differences between PSP, County, and others including US Navy are resolved.
Next Activity: If Court grants motion to hold in abeyance, planning review
of proposed settlement.
Time: 1.0 hour
Costs :
none to date
ARTICLE V APPEALS
Monroe County Bail Bonds v. State ex rei. Monroe County CF K 03
Circuit Court (16th) Judge: Date Filed: 8/11/03
This is an appeal of a County Court decision to deny a bail bondsman's motion to
set aside a bond forfeiture. Bond amount is $2500.00. Lower Court case is
styled State v. James Thomas Hastings, 2003 MM 1845 K.
Current Status: Awaiting Appellant's initial brief.
Next Activity:
File Answer brief 20 days after initial brief is served.
Time: .1 hour
Costs: none to date
Monroe County Bail Bonds v. State ex rei. Monroe County CF K 03
Circuit Court (16th) Judge: Date Filed: 7/29/03
This is an appeal of a County Court decision to deny a bail bondsman's motion to
set aside a bond forfeiture. Bond amount is $10,000.00. Lower Court case is
styled State v. David Paul Saunders, 2002 MM 2083 K.
Current Status: Awaiting Appellant's initial brief.
Next Activity:
File Answer brief 20 days after initial brief is served.
Time: .6 hour
Costs: none to date
CODE ENFORCEMENT APPEALS
Decker. Harry v. Monroe County CA K 01-1252
Circuit Court 16th Judge Payne Date Filed: 10/5/01
This is an appeal of a code enforcement OSTDS case. The County's Answer
brief has been drafted and is undergoing the revision process.
Current Status: County's brief has been drafted, needs revisions
Next Activity: File County's brief.
Time: 6 hours
Costs: none
Eads. Barbara v. Monroe County CAP 03-117
Circuit Court 16th Judge Garcia.:. Date Filed: 2/27/03
This is a code enforcement appeal of the special master's order finding the Lowe
House to be in unsafe condition and setting forth a compliance schedule. The
SM had vacated his prior order, which had imposed fines in excess of
$300,000.00 to address concerns set forth by Ms. Eads. Dissatisfied with the
compliance schedule, Ms. Eads took the current appeal. CAY staff filed a cross
appeal of the 8M's order vacating the fines. Barbara Eads has also filed a cert.
Petition for review the BOCC's denial of her request to de-designate this
property as an historic structure. That case is being handled by K.
Cabanas.
Status:
County prevailed in cert. Case.
Next Activity: Appellant's brief is due.
Time: 2 hours
Costs: none
Fuchs. Walburaa v. Monroe County CA K 01-1251
Circuit Court (16th) Judge Vernon Date Filed: 10/5/01
This is a code enforcement appeal of an 08TD8 case.
Current Status: The County's Answer brief has been drafted and is currently
being revised. The Appellant has consented to an extension.
Next Activity:
File brief.
Time: 8 hours
Costs: none
Klopp. Michael v. Monroe County
Circuit Court 16th Judge Garcia Date Filed: 10/2/02
CAP 02-522
This is a code enforcement appeal of a trash and debris dumping case
Status:
Court upheld ruling by dismissing appeal.
Next Activity:
CLOSE FILE.
Time: 26 hours
Costs: $50.46.
Stevenson. MK v. Monroe County CA K 02-257
Circuit Court 16th Judge Payne Filed: 2/26/02
Appeal of a finding that Caribbean Village storage sign was an off premises sign.
Current Status: All brief have been filed. Oral argument has not been
requested.
Next Activity: Court decision.
Time: 27.6 hours Costs: none
CODE ENFORCEMENT FORECLOSURES/COLLECTIONS
Monroe County v. Mario Alfonso CA K 03 (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed:
This will be a code enforcement foreclosure action that was authorized by the
SOCC on 6/18/03.
Current Status: Property owner has until November 19, 2003 to bring property
into compliance or foreclosure action to be filed.
Next Activity: File complaint if compliance & settlement not reached.
Time: 1.4 hour
Costs: none to date
Monroe County v. Mary Boza. CA K 03 (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action authorized by the SOCC on 4/18/03.
Current Status: Referred to outside counsel on 11/3/3 for further work.
Next Activity: File complaint.
Time: 1.0 hour
Costs: none to date
Monroe County v. Robert Brown & Marie Drisse. CA K 03-1036
Circuit Court (16th) Judge: Payne Date Filed: 9/3/3
Action to foreclosure on the "Stairway to Heaven" authorized 4/03.
Current Status: Both Defendants served a pro se "answer" and what looks to be
a counterclaim.
Next Activity:
County's motions set for December 29, 2003.
Time: 6.7 hours
Costs: $192.00
Monroe County v. David Cole (Estate)
Circuit Court (16th) Judge: (none yet) Date Filed:
This will be a code enforcement foreclosure action that was authorized by the
BaCC 6/18/03.
CA K 03 (TBA)
Current Status: File sent to outside counsel on 11/3/3 for further work.
Next Activity: File complaint.
Time: 1.0 hour
Costs: $150.00
Monroe County v. Dirk Damrau
Circuit Court (16th) Judge: (none yet) Date Filed:
This will be a code enforcement foreclosure action that was authorized by the
BaCC 6/18/03.
CA K 03 (TBA)
Current Status: Negotiating with owner to achieve compliance before
negotiating settlement offer.
Next Activity: File complaint if no settlement reached.
Time: 1.0 hour
Costs: none to date
Monroe County v. Alain Y. Depierrefeu. CA K 03-(TBA)
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action authorized by the BaCC on 4/18/03.
Current Status: File sent to outside counsel on 11/3/3 to file complaint.
Next Activity: File complaint.
Time: 1.0 hour
Costs: $150
Monroe County v. Daniel & Svlvia Fuller CA P 03 (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action that was authorized by the sacc 6/18/03.
Current Status: Negotiating settlement.
Next Activity: Present offer to sacc if proposed settlement is reached.
Time: 2.0 hour
Costs: none to date
Monroe County v. Daniel Ganim
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action that was authorized by the SOCC 6/18/03.
CA P 03 (TBA)
Current Status: In negotiations with owner.
Next Activity:
File complaint if no agreement reached by 12/1/03.
Time: 1.2 hour
Costs: none to date
Monroe County v. Dan Gleason. SC p 03 -165
Count Court (16th) Judge: ptomey Date Filed: 8/5/03
Small claims action for a money judgment to collect $520.00 in unpaid code
enforcement fines and costs authorized by the SOCC in April of 2003.
Current Status: Default Judgment entered on 9/11/03 for $1335.92
Next Activity: File final judgment with Dept. of State & begin enforcement
proceedings.
Time: 8.9 hours
Costs: $65.92
Monroe County v. Lawrence Graves, CA K (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action authorized by the SOCC in April of 2003.
Current Status: File sent to outside counsel on 11/3/3 for further work.
Next Activity: File complaint.
Time: 1.5 hour
Costs: $150
Monroe County v. Jack Haaopian. CA P 03-529
Circuit Court (16th) Judge: GARCIA Date Filed: 10/1/03
Code enforcement collection action authorized by SOCC on 8/20/03.
Current Status: Owner filed answer and Third Party Complaint against
contractor who failed to pull permits for installation of elevator.
Next Activity: DF/3PL filing motion for summary judgment against 3DF.
Time: 1.8
Costs:
$20.00.
Monroe County v. Dorothv Houah
Circuit Court (16th) Judge:
Code enforcement collection action authorized
9/25/3 lien valued at $25,050.00.
CA P 03 (TBA)
Date Filed:
by SOCC on 9/17/03. As of
Current Status: Negotiating with owner via her son.
Next Activity: Title search if payment not made.
Time: .5
Costs :
none
Monroe County v. Chris Johnson CA K 03-1173
Circuit Court (16th) Judge: Payne Date Filed: 10/7/03
Code enforcement foreclosure action that was authorized by the SOCC 7/15/03.
Current Status: Defendant's answer filed.
Next Activity: County's Motion for judgment set for 12/30/03.
Time: 1.7 hour
Costs: $170.00
Monroe County v. Kev Larao Ocean Resorts CooP. Inc. CA P 96-260
Circuit Court (16th) Judge Garcia Date Filed: 5/20/96
This is an action to foreclose a code enforcement lien.
Current Status: Case has been removed from Court's docket due to
settlement agreement which the SOCC approved on 6/18/03.
Next Activity: Joint status report to Court due 01/01/04. On Planning
Commission agenda for November.
Time: 30.6 hours Costs: $340.00
Monroe County v. Larao Coin Laundry. Inc.
Circuit Court (16th) Judge: (none yet) Date Filed:
Action to foreclosure 2 code enforcement liens authorized by the SOCC 4/2003..
CA P 03(TBA)
Current Status: Owner has offered to settle for $2000.00. CAY has asked for
$5000.00.
Next Activity: Present offer to SOCC at November 2003 meeting.
Time: 2.5 hour
Costs: none to date
Monroe County v. Pedro Liz (Bakery)
Circuit Court (16th) Judge: Date Filed:
Code enforcement collection action authorized by SOCC on 7/1703.
CA K 03 (TBA)
Current Status: Negotiating with owner.
Next Activity: Title search, then file suit if not successful.
Time: 1.0
Costs :
none
Monroe County v. Pedro Liz (Trailer) CA K 03 (TBA)
Circuit Court (16th) Judge: Date Filed:
Code enforcement collection action authorized by sacc on 9/17/03. As of
9/25/3 lien valued at $133,300.00.
Current Status: Payment demanded on 9/25/03.
Next Activity: Title search if payment not made.
Time: .5
Costs :
none
Monroe County v. Mary Ellen Llovd.
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action authorized by the sacc 4/18/03,
CAM
(TBA)
Current Status: File sent to outside counsel on 11/3/3 for further work.
Next Activity: File complaint.
Time: .5 hour
Costs: none to date
Monroe County v. Lilv Marks. CA K 03-1152
Circuit Court (16th) Judge: Payne Date Filed: 10/2/3
Code enforcement collection action authorized by sacc on 8/20/03.
Current Status: Defendant served her answer on County 10/21/03.
Next Activity: Negotiating with owner to permit her to obtain financing for
aSTDS so she can cure violation. If not cured, move for summary judgment.
Time: 1.0
Costs:
$20.00
Monroe County v. Arthur Mehr CA K 03 (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action that was authorized by the sacc 6/18/03.
Current Status: Negotiating with owner's attorney.
Next Activity: Send to outside counsel if not successful.
Time: 1.2 hour
Costs: $150.00
Monroe County v. James Messera, et al CA K 03- (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action authorized by the SOCC 4/18/03.
Current Status: Sent to outside counsel on 11/3/3 for further work.
Next Activity:
File suit.
Time: 1.7 hour
Costs: $165.00
Monroe County v. Armanda Perez, CA K 03- (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed:
Code Enforcement collection action authorized by SOCC on 4/18/03. Property
is homesteaded which limits enforcement options to money judgment for fines
accruing after 10/1/00 and/or petition for writ of execution,
Current Status: Property owner working to achieve compliance.
Next Activity: Set for status review on 2/2/4.
Time: 1.5 hour
Costs: none to date
Monroe County v. Joe Posada, III CA K 03- (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action authorized by the SOCC 4/18/03.
Current Status: File sent to outside counsel on 11/3/3 for further work.
Next Activity: File suit.
Time: 1.8 hour
Costs: $150.00
Monroe County v. Ernest Richardson CA K 03 (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action that was authorized by the SOCC 6/18/03.
Current Status: Tentative agreement to settle for $500.00 due to communication
issues with inspector.
Next Activity: SOCC to consider settlement on 11/19/03.
Time: 1.3 hour
Costs: none to date
Monroe County v. Safe Harbor Marine Railway Corp.
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action that was authorized by the sacc 6/18/03.
CA K 03 (TBA)
Current Status: Negotiating with owner.
Next Activity: File complaint if no settlement reached.
Time: 1.3 hour
Costs: none to date
Monroe County v. Virainia SaWYer & Tony Welters
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action that was authorized by the sace 7/15/03..
CA K 03 (TBA)
Current Status: File sent to outside counsel on 11/3/3 for foreclosure.
Next Activity: File complaint.
Time: 1.1 hour
Costs: $150.00.
Monroe County v. Virainia Sawyer
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action that was authorized by the sacc 7/15/03..
CA K 03 (TBA)
Current Status: File sent to outside counsel on 11/3/3 for foreclosure.
Next Activity: File complaint.
Time: 1.1 hour
Costs: $150.00.
Monroe County v. Lyle Starr SC K 03 (TBA)
County Court (16th) Judge: Date Filed:
Code enforcement collection action authorized by sacc on 8/20/03.
Current Status: Settlement agreement reached.
Next Activity: Awaiting payment. Deadline 12/1/03.
Time: 1.8
Costs:
none
Monroe County v. Eduard Stefani. CA K 03- (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action authorized by the SDCC 4/18/03.
Current Status: Property in compliance. Negotiating settlement.
Next Activity: File complaint if not settlement reached.
Time: 1.5 hour
Costs: $150.00
Monroe County v. Joseph Sutton CA K 03 (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action that was authorized by the SDCC 6/18/03..
Current Status: Negotiating with owner over compliance before settlement offer.
Next Activity: File complaint if no settlement reached.
Time: 1.3 hour
Costs: none
Monroe County v. Dorothv Tinslev nka Matthies CA K 03 (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action that was authorized by the SDCC 6/18/03..
Current Status: SETTLED.
Next Activity: Second payment due 11/1/03 - overdue.
Time: 2.5 Costs: none
Monroe County v. Frank Vastano CA M 03- (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed: 11/4103
Code enforcement foreclosure action authorized by the SOCC 4/18/03.
Current Status: Efforts to collect on title policy for defect in title have not been
successful. Complaint filed on 11/4/03.
Next Activity: Serve Defendant.
Time: 2.5 hour
Costs: none to date
Monroe County v. Gertrude Waters
Circuit Court (16th) Judge:
Code enforcement collection action authorized
9/25/3 lien valued at $79,300.00.
CA M 03 (TBA)
Date Filed:
by BaCC on 9/17/03. As of
Current Status: Negotiating w/ son.
Next Activity: File suit if settlement not reached.
Time: .7
Costs:
none
Monroe County v. Louis Welters CA K 03 (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action that was authorized by the BaCC 7/15/03.
Current Status: Due to concerns of BaCC, I'm researching the requirements for
filing a guardianship petition with the Court before proceeding with foreclosure.
Next Activity: File petition.
Time: 1.0 hour
Costs: none
Monroe County v. Gary Yaworski/Anita Fox CA P 03- (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed:
Code enforcement foreclosure action authorized by the BaCC 4/18/03.
Current Status: Settlement discussions with owner.
Next Activity: Compliance inspection, then negotiate settlement.
Time: 1.1 hour
Costs: none to date
Monroe County v. Frank Vastano CA M 03- (TBA)
Circuit Court (16th) Judge: (none yet) Date Filed: 11/4103
Code enforcement foreclosure action authorized by the BaCC 4/18/03.
Current Status: Efforts to collect on title policy for defect in title have not been
successful. Complaint filed on 11/4/03.
Next Activity: Serve Defendant.
Time: 2.5 hour
Costs: none to date
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