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Item O1 November 2005 Litigation Report To: Mayor Spehar & County Commissioners From: Bob Shillinger, Asst. County Attorney Date: November 14, 2005 cc: Tom Willi, County Administrator Richard Collins, County Attorney Summary Number of Cases New cases filed against County 3 Cases closed since last report 0 CAY Trial level casesi 38 CAY Post Judgment cases 4 CAY Appeals 5 Potential cases to be filed 6 Outside Counsel Cases 48 Total Cases pending 78 Airports Community Services Engineering Growth Management M iscellaneousii MCSO Personnel Public Works Risk Management New Cases Cases Closed CAY Litigation Cases Trial Level CAY Post Judgment Cases CAY Appeals Potential Cases Outside Counsel Cases Ferencik, Libanoff (Ira Libanoff) Johnson, Anselmo, (Bruce Johnson & Michael Burke) Morgan & Hendrick (Derek Howard) Paul, Hastings (Bob Freilich) Purdy, Jolly (Mike Stephson) The Smith Law Firm (Wayne Smith) Vernis & Bowling (Dirk Smits, Kerry Willis & Scott Black) White & Smith (Tyson Smith & Steve Moore) 2 3 5 57 3 7 4 5 4 Page 2 2 3 8 9 10 12 12 13 16 20 20 21 22 20 CASES FILED AGAINST THE COUNTY SINCE LAST MONTH'S REPORT Gap Properteies v. Monroe County 3D05-2413 Third DCA Judges: TBA Date Filed: 10/14/5 Second tier certiorari appeal of denial of petition challenging County's plat approval rules for dockominiums, see CA K 04-1321 below. Growth Management/Planning Current Status: County ordered to respond by Court. Next Activity: County's brief due 12/03/05. Billing to Date: None Vernis & Bowling handling appeal. In re: Birch Telecom. Inc. 05-12237 PJW U.S.Bnktcy.Delaware Judge: Walsh Date Filed: 8/12/05 Bankruptcy action by pay phone vendor which claims it owes County $4.15 for providing pay phones on County property. Administrative Services/Technical Services Current Status: Claim deadline passed 11/4/05. County's interest $4.15. Next Activity: None. Time: .5 Costs: 0.00 Trov. Daniel Scott v. Monroe County Third DCA Judges: TBA Appeal of denial of writ of mandamus in CA K 05-856. Growth Management/Planning 3D 05-2419 Date Filed: 10/7/05 Current Status: Preparing record. Next Activity: Troy's brief due 12/16/05 Time: .3 Costs: 0.00 CASES CLOSED SINCE LAST MONTH'S REPORT -- None 2 CAY LITIGATION - Trial Level See Outside Counsel Section for Cases being Handled Jointly Collins. C. & Sum Air Services v. Monroe County. et al CAM-05-146 Circuit Court 16th Judge: Payne Date Filed: 6/1/05 Declaratory judgment action regarding lease with FBO at Marathon Airport. Airports. Filed but not served. Current Status: Awaiting service of complaint. Next Activity: Once served, determine if outside counsel should be retained. Time: 0.3 hours Costs: 0.00 Cutaia. Thomas v. Monroe County. MCSO. Pretrial Services CAK-05-617 Circuit Court 16th Judge: Jones Date Filed: 6/21/05 Complaint for unspecified damages. Mayor not served yet. MCSO Current Status: Awaiting service. Next Activity: Once served, determine if outside counsel should be retained. Time: 0.6 hours Costs: 0.00 Drewina. Janice v. James Roberts as County Administrator CAK-04-686 Circuit Court 16th Judge: Jones Date Filed: 6/25/04 Mandamus action seeking hearing in personnel dispute between plaintiff and her supervisor Louis Latorre. Community Services/Social Services/Personnel Current Status: Drewing appealed Circuit's denial of writ to Third DCA. Next Activity: Stayed pending appeal. Time: 20.0 hours Costs: 0.00 EEOC v. Monroe County EEOC - Miami Judge: N/A Charge of disability discrimination filed by an employee. Public Works/Personnel 150-2005-03773 Date Filed: 9/7/05 Current Status: Response filed by ACA Mercado. Next Activity: Await response from EEOC. Time: 15.5 hours Costs: 0.00 3 Fed. Nat'l Morta. Assn. v. M. Coleman. Monroe County. et al CAK-05-171 Circuit Court 16th Judge: Jones Date Filed: 2/18/05 Mortgage foreclosure case where County holds an inferior interest to bank due to $1,928.00 in Article V liens. Current Status: Motion's pending. Next Activity: 11/30/05, hearing on objection to foreclosure sale, motion to rescind certificate of sale and motion to vacate final summary judgment. Time: 2.9 hours Costs: 0.00 LaSalle Bank. N.A. v. Alexis & Jesus Victores & Monroe County CAP 05-373 Circuit Court 16th Judge: Garcia Date Filed: 8/29/05 Mortgage foreclosure action where County holds an inferior $100.00 code enforcement lien. Mayor served September 8,2005. Growth Management/Code Enforcement Current Status: Answer filed. Next Activity: None. Time: 0.9 hours Costs: 0.00 Monroe County v. R. Bernstein/Safe Harbor Marine Railwav CAK-05-732 Circuit Court 16th Judge: Miller Date Filed: 7/26/05 Code enforcement lien foreclosure. Over $221,800.00. Growth Management/Code Enforcement Current Status: Negotiations ongoing. Next Activity: OF given till 11/30/5 to file responsive pleading. Time: 7.1 hours Costs: $576.00 Monroe County v. Matthew Bonnett CAK-05-911 Circuit Court 16th Judge: TBA Date Filed: 9/9/5 Code enforcement lien collection action authorized 10/17/04, $78,000. PJM Growth Management/Code Enforcement Current Status: OF served 11/3/05. Next Activity: Defendant's answer due 11/28/05. Time: 3.1 hours Costs: $295.00 4 Monroe County v. Dirk W. Damrau CAK-05-667 Circuit Court 16th Judge: Miller Date Filed: 7/11/05 Action to collect $206,100.00 fine authorized by the sacc 6/18/03. Growth Management/Code Enforcement Current Status: Settled for $4748.00 and check received. Next Activity: Mayor to sign settlement agreement. Time: 5.3 hours Costs: $568.05 Monroe County v. Mark FraleiQh CAP-03-647 Circuit Court 16th Judge: Garcia Date Filed: 12/8/03 Ejectment action against owner of structures located on County right-of-way. Public Works/Roads and Bridges. Current Status: Settled, most of structures removed from right of way. Next Activity: Dismiss after verify status of 2 remaining structures. Time: 33.6 hours Costs: $256.80. Monroe County v. Jack HaQopian CAP-03-529 Circuit Court 16th Judge: Garcia Date Filed: 10/1/03 Code enforcement collection action authorized by sacc on 8/20/03. Fine was $203,100.00 as of 9/30/03 and accruing at $250.00 per day. Growth Management/Code Enforcement Current Status: Discovery. Next Activity: Re set mediation. Time: 25.3 hours Costs: $20.00 Monroe County v. Dorothv HOUQh. et al CAP-05-160 Circuit Court 16th Judge: Garcia Date Filed: 4/6/05 Code enforcement collection action authorized by sacc on 9/17/03. As of 9/25/3 lien valued at $25,050.00 and accruing at $50.00 per day. Growth Management/Code Enforcement Current Status: sacc rejected offer to settle for $2,500. Now compliant Next Activity: Discovery & negotiations. Time: 9.6 hours Costs: $596.00 5 Monroe County v. James JeanQuenat Circuit Court 16th Judge: Garcia Collection action authorized by BaCC on 4/21/04. Growth M anagementlCode Enforcement CAP-OS 317 Date Filed: 7/18/05 Fine exceeds 136,100.00. Current Status: Motion for Dismiss filed. Next Activity: Motion hearing TBA. Time: 3.7 hours Costs: $275.00 Monroe County v. Kev LarQo Ocean Resorts CooP. Inc. Circuit Court 16th Judge: Garcia Action to foreclose a code enforcement lien. Growth M anagementlCode Enforcement CAP-96-260 Date Filed: 5/20/96 Current Status: Development agreement application being reviewed. Next Activity: Status report due with the Court 1/1/06. Time: 41.0 hours Costs: $340.00 Monroe County v. Pedro Liz CAK-05-420 Circuit Court 16th Judge: Jones Date Filed: 4/22/05 Collection action authorized by BaCC on 7/17/03; fines exceed $816,300.00. Growth M anagementlCode Enforcement Current Status: Default set aside. Next Activity: Answer by OF due 11/21/05. Time: 8.0 hours Costs: $555.00 Monroe County v. Arthur Mehr Circuit Court 16th Judge: Garcia Code fine collection action. Fine exceeds $42,000.00. Growth M anagementlCode Enforcement CAP-05-348 Date Filed: 8/5/05 Current Status: OF served answer 9/15/05. Next Activity: Discovery due 11/21/05. Time: 7.2 hours Costs: $850.00. 6 Monroe County v. Outland Properties CAP-05-400 Circuit Court 16th Judge: Garcia Date Filed: 9/9/5 Collection action authorized by BOCC on 10/17/04. Fine over $225,000.00. Growth Management/Code Enforcement PJM Current Status: Defendant served. Next Activity: Discovery. Time: 1.1 hours Costs: 300.00 Nunziante. Maril~n v. Monroe County CAK-04-1227 Circuit Court 16t Judge: Jones Date Filed: 11/18/04 Suit challenging Bayshore's rule requiring family members to subsidize residents. Community Services/Social Services Current Status: PL has been moved to nursing home due to declining health. Next Activity: Discovery and/or settlement, TBA. Time: 76.1 hours Costs: 0.00 Teal. Kimberlv & Keith v. Michael Anael. Monroe County. et al CAM-04-404 Circuit Court 16th Judge: Payne Date Filed: 12/16/04 Declaratory judgment action by property owners seeking half of a road PJM purportedly abandoned by County and then quitclaimed to City of Marathon. Public Works/Roads and Bridges Current Status: Discovery. Settlement negotiations ongoing. Next Activity: County's motion to dismiss TBA pending negotiations. Time: 9.4 hours Costs: $133.00 Trov. Daniel Scott v. Monroe County CAK 05-856 Circuit Court 16th Judge: Jones Date Filed: 8/24/05 Mandamus action seeking after the fact building permits for structures erected on Cooks Island in violation of the County Code. Growth Management/Planning Current Status: On appeal in 3D 05-2419. Next Activity: None while on appeal. Time: 2.0 hours Costs: 0.00 7 WalQreens & Gadinsky v. Monroe County CAK-05-266 Circuit Court 16th Judge: Taylor Date Filed: 3/11/05 Cert. review of DOAH order upholding 1/6 findings supporting denial of major conditional use application for Big Pine Walgreens. Growth Management/Planning Current Status: Negotiations ongoing. Next Activity: Final hearing 1/30106. Time: 17.8 hours Costs: 0.00 In re: Winn Dixie Stores. Inc. 05-03817-3F1 U.S. Bankruptcy Ct., M.D.Fla. Judge: Jerry Funk Date Filed: 2/25/05 Voluntary Chapter 11 reorganization case where County might have a claim against the estate. Current Status: Could find no basis for filing proof of claim. Next Activity: None needed. Time: 0.9 hours Costs: 0.00 CAY POST JUDGMENT CASES Monroe County v. William L. Davis CAP-04-181 Circuit Court 16th Judge: Garcia Date Filed: 4/15/04 Money judgment of $27,600.00 for unpaid code enforcement fines and costs. Growth Management/Code Enforcement Current Status: Final judgment of $28,431.00 recorded wi Dept. of State. Next Activity: Collection. Time: 6.2 hours Costs: $56.00 Monroe County v. Dan Gleason SCP-03-165 County Court (Sm. Claims) Judge: ptomey Date Filed: 8/5/03 Money judgment of $520.00 for unpaid code enforcement fines and costs. Growth Management/Code Enforcement Current Status: Final judgment recorded wi Dept. of State. Next Activity: Collection. Time: 9.5 hours Costs: $65.92 8 Monroe County v. Lilv Marks CAK-03-1152 Circuit Court 16th Judge: Jones Date Filed: 10/2/03 Money judgment of $795,270.00 for unpaid code enforcement fines and costs. Growth Management/Code Enforcement Current Status: Final judgment entered for $795,270.00 on 5/9/05. Next Activity: Collection. Time: 8.5 hours Costs: $55.00 CAY APPEALS Drewina. Janice v. Monroe County Third DCA Judges: Levy, Ramirez & Rothenberg Appeal of denial of writ of mandamus in personnel matter. Community Services/Social Services/Personnel 3D 04-3044 Date Filed: 11/29/04 Current Status: 10/14/05. County prevailed, trial court affirmed; mandate issued Next Activity: Close file if no certiorari petition filed by 11/15. Time: 32.4 hours Costs: $15.00 Eads. Barbara v. Monroe County CAP-03-117 Circuit Court 16th Judge: Garcia Date Filed: 2/27/03 Appeal of order finding the Lowe House to be in unsafe condition. Growth Management/Code Enforcement Current Status: Appeal stayed pending application for variance and building permit. Next Activity: None scheduled. Time: 3.6 hours Costs: 0.00 9 Fuchs. WalburQa v. Monroe County Circuit Court 16th Judge: Payne This is a code enforcement appeal of an OSTDS case. Growth Management/Code Enforcement CAK-01-1251 Date Filed: 10/5/01 Current Status: The County's brief filed; case reassigned to Judge Payne. Next Activity: Await Court's decision. Time: 11.5 hours Costs: 0.00 Hardin. Michelle v. Monroe County Circuit Court 16th Judge: Miller Appeal of code enforcement decision. Growth Management/Code Enforcement CA K 99-1046 Date Filed: 9/3/99 Current Status: CAY motion to replace Derek Howard as counsel pending. Next Activity: Status review on pending motions. M&H Billing to date:$10,241.57 thru 8/31/05. CAY Time: 0.5 POTENTIAL CASES THAT HAVE NOT YET BEEN FILED Good. L10vd v. Monroe County CAK-05-TBA Circuit Court (16th) Judge: Date Filed: Bert J. Harris Act claim regarding two parcels of property owned by Lloyd Good. Growth Management/Planning Current Status: Settlement discussions underway. Next Activity: None. Stayed during Good's application for major conditional use. Time: 8.6 hours Costs: $5.56 10 Hamelton. Charles v. KWRU & Monroe County CA K 04-740 Circuit Court (16th) Judge: Miller Date Filed: 7/6/04 Potential personal injury claim by scooter accident victim and/or utility seeking damages from the County. Handled jointly with Johnson, Anselmo. Public Works/Roads and Bridges/Risk Management Current Status: County not a party at this time. Next Activity: 11/18/05 County to produce documents to DFs. Fees Billed to Date: 0.00 CAY Time: 6.7 Costs: 0.00 Harum. James v. Monroe County. DOH. & Z. Krstic CAP-05-TBA Circuit Court 16th Judge: Date Filed: Threatened action to compel County to prosecute code enforcement violation. Growth Management/Code Enforcement Current Status: Underlying code case held 5/26/05, mitigation plan in effect. Next Activity: Move to dismiss and for sanctions if filed since w/o merit. Time: 2.4 hours Costs: 0.00 Monroe County v. Jean M. Louis & Itnor Corp. CAK-05-TBA Circuit Court 16th Judge: TBA Date Filed: Code fine collection action authorized by SOCC on 10/17/04. $34,200.00. Growth Management/Code Enforcement PJM Current Status: Owners not complying with settlement agreement approved by SOCC on 4/20/05. Next Activity: File foreclosure action if not resolved. Time: 1.5 hours Costs: 0.00 Monroe County v. Blair & Althea Moonev CAK-05-TBA Circuit Court 16th Judge: TBA Date Filed: Code lien collection action authorized by SOCC on 10/17/04. $146,100.00. Growth Management/Code Enforcement PJM Current Status: Fine of $7,305.00 paid. Next Activity: Finalize settlement agreement. Time: .5 hours Costs: 0.00 11 State of Florida v. Monroe County TBA TBA Judge: TBA Date Filed: n/a Threatened action by AG's Medicaid Fraud unit regarding alleged over billings for ambulance services. Public Safety/Fire Rescue Current Status: Waiting for AG's office to set up conference. Next Activity: Settlement conference with State. Time: 9.2 hours Costs: 0.00 CASES BEING LITIGATED BY OUTSIDE COUNSEL Ferencik, Libanoff, Brandt, Bustamante and Williams, P.A. Monroe County v. Bender & Associates. et al CAK-03-915 Circuit Court 16th Judge: Jones Date Filed: 8/4/03 Breach of contract and negligent misrepresentation action arising from the defective windows in the Gato building. Engineering/Construction Management Current Status: Discovery ongoing. Next Activity: Discovery ongoing. Fees billed to date: $62.442.25 Costs: $6,838.29 Monroe County v. Lodae Construction. et al CAK-00-617 Circuit Court 16th Judge: Payne Date Filed: 5/11/00 Suit filed against general contractor Lodge Construction & its surety for breach of contract to build Gato Building. Engi neeri ng/Construction Management Current Status: Reserved on appeal November 24,2004. New trial granted. Mandate issued 2/16/05. Next Activity: Set for trial. Fees billed to date: $298,015.25 Costs: $71,523.31 12 Johnson, Anselmo, Murdoch, Burke, Piper, & McDuff, P.A. BaukniQht. Ska~s & Rockett v. Monroe County CAP-04-451 Circuit Court 16 Judge: Garcia Date Filed: 9/24/04 Inverse condemnation/takings case filed by Jimmy & Nancy Bauknight, Teague Skaggs, & Kathleen Rockett for three lots on Big Pine Key. Mayor served 10/4/4. Growth Management/Planning Current Status: Discovery. Next Activity: Discovery. Fees billed to date: $832.24 Costs: 0.00 BaukniQht. SkaQQs & Rockett v. Monroe County 04-CV-10105 U.S. D.C. S.Fla. Judge: Moore Date Filed: 11/1/04 Inverse condemnation/takings case by owners of 3 Big Pine lots. Growth Management/Planning Current Status: Federal Court remanded to State Court. Attorney's fee motion appealed to 11th Circuit. Next Activity: None. Fees billed to date: None Costs: 0.00 BaukniQht. et al. v. Monroe County 05-10868-F 11th Cir. Ct. of Appeals Judge: TBA Date Filed: 2/11/05 Appeal of denial of attorney's fees motion filed against the County by takings case plaintiffs. County had removed the case to Federal Court; plaintiffs sought remand and attorneys fees. Case was remanded to state court but fees denied. Plaintiffs are seeking between $15,000 and $18,000 in fees. Growth Management/Planning Current Status: Briefs completed. Next Activity: Oral Argument 12/9/05 in Miami, 10:30 a.m. Fees billed to date: None. Costs: 0.00 13 Florida Kev Deer v. Michael Brown & Gale Norton 90-10037-CIV-Moore U.S. Dist. Ct., SD Fla. Judge: Moore Date Filed: 4/2/90 Endangered Species Act case that resulted in permanent injunction barring FEMA from backing flood insurance for 49,000 parcels in County. Growth Management/Planning Current Status: Court extended appellate deadline to 12/15/05 to give time to rule on County's motion to intervene. Next Activity: Negotiating partial settlement, ruling on intervention. Billing to Date: none CAY Time: 13.5 Costs: 0.00 Florida Kev Deer. et al v. Gale Norton (Sec. of Interior) 05-10063-CIV-KING U.S.D.C. S.D.Fla. Judge: King Date Filed: 6/15/05 Endangered Species Act challenge to Fish & Wildlife Service's review of County's application to construct park on Big Pine Key. Engi neeri ng/Construction Management Current Status: Case stayed while F&WS revises biological opinion. Next Activity: Stayed until January 2006. Fees billed to date: $612.50 CAY Time: 6.3 Costs: 0.00 FKCC & Last Stand v. FL Admin. Comm.. Monroe County DOAH 04-2756 DOAH Judge: Carolyn Holifield Date Filed: 08/05/04 Administrative Rule challenge to partnership agreement with State. Growth Management/Planning Current Status: Final Order in County's favor issued 6/29/05. Next Activity: None pending appeal. Fees billed to date: $59,464.92 CAY Time: 190.1 hours Costs: 0.00 14 FKCC & Last Stand v. FL Admin. Comm.. Monroe County. et al 3D05-1800 Third DCA Judges: TBA Date Filed: 7/28/05 Appeal of ALJ's decision denying rule challenge in DOAH 04-2756. Current Status: Appellant's brief filed. Next Activity: County & DCA's brief due 12/15/05. Fees billed to date: none CAY Time: 0.5 hours Costs: 0.00 Hardee. Evelvn v. Monroe County Circuit Court 16th Judge: Garcia Tort action arising from alleged fall at PK Court house. Risk Management/Public Works CAP-05-255 Date Filed: 6/3/05 Current Status: Discovery. Next Activity: Discovery motion phone hearing 11/16/05. Fees billed to date: $660.20 CAY Time: 2.4 hours Costs: 0.00 Kessler. Stuart v. Monroe County & Tom Willi CA K 05-1006 Circuit Court 16th Judge: Jones Date Filed: 10/11/2005 Complaint for injunctive relief and damages under Whistle-Blower Act, Civil Rights Act, defamation and interference with business relationship. Personnel/Risk Management Current Status: Ct. denied temporary reinstatement on 10/31/05. Motion to Dismiss pending. Next Activity: Hearing on Motion to Dismiss, to be set. Billing to date: 0.00 CAY Time: 23.4 Costs: 0.00 15 Neuman. Kenneth v. Monroe County CAK-04-663 Circuit Court 16th Judge: Jones Date Filed: 6/21/04 Action for damages and to compel County to issue building permits. Growth Management/Planning CAY co-counsel. Current Status: Discovery. Next Activity: Deposition of 11/2/05 to be reset. Fees billed to date: $2,326.92 CAY Time: 5.8 hours Costs: 0.00 Riverview Consultants. Inc. v. Monroe County CAK-05-373 Circuit Court 16th Judge: Jones Date Filed: 4/13/05 Tortious interference with contract case. League of City's carrier counsel. Risk Management/Airport/MCSO PJM Current Status: Pleadings complete. Next Activity: Motions and discovery. Fees billed to date: $743.86 CAY Time: 4.0 hours Costs: 0.00 Morgan & Hendrick Ambrose. Thora et al v. Monroe County CA P 97-636 Circuit Court 16th Judge: Garcia Date Filed:12/11/97 Declaratory Judgment action claiming vested rights due to subdivision plats. Subsequent appeal of summary judgment order reversed and remanded. Growth Management/Planning Current Status: Plaintiff's voluntarily dismissed without prejudice 9/14/05. Next Activity: None. Wait to see if refile. Billing to date: $30,960.98 as of 7/31/05. 16 Emmert. Helen & GreQ v. Monroe County Circuit Court 16th Judge: Garcia Inverse condemnation and vested rights action. Growth Management/Planning CA P 02-520 Date Filed: 10/2/02 Current Status: Court denies PL's partial summary judgment motion. Next Activity: Tri~ December 19, 2005. Billing to date: $90,727.95 as of August 31,2005. Galleon Bav v. Monroe County v. State of Florida Circuit Court 16th Judge: Payne Inverse condemnation and vested rights action. Growth Management/Planning CA K 02-595 Date Filed: 5/21/02 Current Status: Summary judgment motions pending. Next Activity: Motions hearing 10/24/05 to be reset. M & H Billing to date: $209,495.65 thru 8/31/05. *** Robert Freilich is serving as co-counsel Paul Hastings Billing to date: to be provided. Good. L10vd v. Monroe County CA K 01-977 Circuit Court 16th Judge: Payne Date Filed: 8/9/01 Inverse condemnation action based on NROGO and declaratory judgment that owner be awarded permits for properties. Growth Management/Planning Current Status: Plaintiff motion to amend complaint filed. Next Activity: Respond to amended complaint. Billing to date: CAY Time: $16,378.03 as of 8/31/05. 2.5 17 I.C. & E. v. Monroe County 01-CV-10105 U.S. Dist. Ct. Judge: King Date Filed: 10/4/01 Declaratory judgment action regarding wireless tower moratoria. Growth Management/Planning Current Status: 11th Circuit directed District Court to dismiss case. Next Activity: Awaiting order of dismissal. Billing to date: $18,966.92 as of 8/31/05. Johnson. L10vd v. Monroe County CA K 02-1248 Circuit Court 16th Judge: Payne Date Filed: 10/30/02 Writ of Mandamus challenging Planning Director's determination that boundary determination by alleged error requires zoning map amendment. Growth Management/Planning Current Status: Agreement reached. Next Activity: Proposed final judgment pending. Billing to date: $2,219.62 as of 8/31/05. Kalan. Suzanne v. Monroe County Circuit Court 16th Judge: Garcia Inverse condemnation action. Growth Management/Code Enforcement CA P 03-155 Date Filed: 3/11/03 Current Status: Held in abeyance pending BUD hearing. Next Activity: none. Billing to date: $2,855.77 as of 8/31/05. Neumont. Elizabeth et al. v. Monroe County 99-10054-CV U.S. Dist. Ct., S.D. Fla. Judge: Paine Date Filed: 5/21/99 Cass action challenging enactment of vacation rental ordinance. Growth Management/Planning Current Status: Briefs completed. Next Activity: None pending appeal. Billing to date: $123,563.24 18 Neumont. Elizabeth et al. v. Monroe County 11th Circuit Court of Appeals Judges: TBA Appeal of 99-1 0054-CV above. Growth Management/Planning 04-13610-X Date Filed: 7/15/04 Current Status: Briefs completed. Next Activity: Oral argument to be rescheduled to 11/18/05. Billing to date: $123,565.49 as of 8/31/05. O'Daniel. John & Theresa Hill v. Monroe County Circuit Court 16th Judge: Garcia Appeal of code enforcement action and vested rights claim. Growth Management/Code Enforcement/Planning CA P 02-141 Date Filed: 3/13/02 Current Status: Complete, on appeal. Next Activity: None pending appeal. Billing to date: $40,710.63 as of 8/31/05. O'Daniel & Hill v. Monroe County Third DCA Judges: TBA Appeal of circuit court decision in CA P 02-141. Growth Management/Code Enforcement/Planning 3D-05-583 Date Filed: 3/18/05 Current Status: Oral argument held 10/19/05. Next Activity: Await decision of Court. Billing to date: See previous case. Sierra Club. et al v. DCA. Miami Dade & City of Homestead 03-150-GM DOAH Judge: Maloney Date Filed: 1/17/03 Court intervened in administrative challenge to amendment of Miami-Dade's compo plan redesignating Krome Avenue to a major roadway. Growth Management/Planning Current Status: Final hearing suspended by Hurricane Rita. Next Activity: To resume at a date to be announced. Billing to date: None, pro bono. 19 Paul, Hastings (Bob Freilich) White & Smith (Tyson Smith) Collins. Thomash et al v. Monroe County Circuit Court 16t Judge: Payne Takings action brought by 11 groups of plaintiffs. Growth Management/Planning CAM -04-379 Date Filed: 11/22/04 Current Status: Discovery ongoing. Next Activity: Motions hearing 11/28/05; Motion to continue trial 11/29/05 pending. Total Fees billed to date: $554,169.12 CAY Time: 109.7 hours Costs: $56,194.21 See also Galleon Bay v. Monroe County - Morgan & Hendrick. Purdy, Jolly & Giuffreda, P.A. Evans. Brian v. Monroe County 04-CIV-10033-JLK U.S.Dist.,S.D.Fla. (Miami)Judge: King Date Filed: 5/6/04 Civil action against the County, and others, arising from actions of Sheriff's office in publicizing the rescission of a warrant it had obtained for his arrest. MCSO Current Status: Award to County & Sheriff of $4,579.00 in attorney's fees against Evans for filing frivolous suit affirmed by 11th Circuit on 9/20/05. Next Activity: Collection. Fees billed to date: None CAY Time: 9.5 hours Costs: 0.00 Evans. Brian v. MCSO. Monroe County. et al 05-10077-B 11th Circuit Judges: Edmondson, Tjoflat & Dubina Date Filed: 1/5/05 Appeal of award of attorney's fees against Evans in 04-CIV-10033. MCSO Current Status: Fee award affirmed 9/20/05; Mandate issued 10/19/05. Next Activity: None. Decision becomes final 1/9/6. Fees billed to date: None Costs: 0.00 20 Evans. Brian v. Monroe County. et al CIV S 04-1042 LRH U.S.D.C. Nevada Judge: Jones Date Filed: 7/28/04 Same allegations as Florida case 04-CIV-10033 that were dismissed. MCSO Current Status: Final Judgment entered 9/15/05. Next Activity: None unless files cert. petition (12115/05 close). Fees billed to date: None Costs: 0.00 Evans. Brian v. MCSO. Monroe County. et al 04-17429 9th Circuit Judges: O'Scannlain, Callahan & Beach Date Filed: 12/09/04 Appeal of Nevada Court's dismissal of suit in CIV S 04-1042 LRH. MCSO Current Status: 9/7/5, Mandate issued. Next Activity: None. Becomes final 12/15105. Fees billed to date: None Costs: 0.00 Evans. Brian v. KW Citizen. Monroe County. et al CV S 04-1742-KJD-LRL U.S.D.C. Nevada Judge: Dawson Date Filed: 1/6/05 Defamation suit over alleged misstatements by Mark Willis in the Citizen. MCSO Current Status: Evans dismissed case on 2/11/05; threatened to refile. Next Activity: Await service. Fees billed to date: None Costs: 0.00 The Smith Law Firm Monroe County v. Post Buckley. Schuh. and Jerniaan CAK-95-402 Circuit Court 16th Judge: Payne Date Filed: 3/30/95 Malpractice claim against the County's former engineering firm for miscalculation of bonds necessary to finance improvements to Card Sound Road. Engineering Current Status: Defense verdict 6/14/05. Next Activity: Finalize attorney's fees. Fees billed to date: $630,311.78 Costs: 0.00 21 Monroe County v. Post Buckley. Schuh. and Jerniaan Third DCA Judges: TBA Appeal of judgment in the above case. Engineering 3D05-1822 Date Filed: 8/1/05. Current Status: Organizing record. Next Activity: County's brief deadline extended to 12/15/05. Fees billed to date: none Costs: 0.00 Vernis & Bowling of the Florida Keys, P.A. GAP Properties of SW Florida-I. Inc. v. Monroe County CAK-04-1321 Circuit Court 16th Judge: Jones Date Filed: 12/10/04 Cert. review of action involving failure to obtain plat approval of dock subdivision and an improper change of use without a major or minor conditional use permit. Growth Management/Planning Current Status: Certiorari denied, rehearing motion denied. Next Activity: Order becomes final 10/14/05. Fees billed to date: $26,875.00 Costs: $306.43 Key Tex S. D. Condo Assoc. v. Monroe County & T. McGarry CAK-04-224 Circuit Court 16th Judge: Jones Date Filed: 3/2/04 Action to prevent County from denying permits because of ownership conversion to condominiums and compel County to accept permit applications that have been rejected MCC 9.5-49. Growth Management/Planning Current Status: Third Amended petition pending. Next Activity: Respond to Third Amended petition. Fees billed to date: $32,290.50 Costs: $2,540.84 22 Monroe County v. Mary Boza CAK-03-1508 Circuit Court 16th Judge: Jones Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the SOCC on 4/18/03. Growth Management/Code Enforcement Current Status: Settled. Lien release issued. Next Activity: File satisfaction of judgment, pay V&S's bill. Fees billed to date: $7,300.00 CAY Time: 6.0 hours Costs: 0.00 Monroe County v. Alain Y. Depierrefeu CAK-03-1504 Circuit Court 16th Judge: Jones Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the SOCC on 4/18/03. Growth Management/Code Enforcement Current Status: Final default judgment entered on 6/21/05 for $144,505.03. Next Activity: Auction to be scheduled. Fees billed to date: None Costs: 0.00 Monroe County v. Alain Y. Depierrefeu CAK-03-1507 Circuit Court 16th Judge: Jones Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the SOCC on 4/18/03. Growth Management/Code Enforcement Current Status: Final default judgment entered on 6/21/05 for $616,555.03. Next Activity: Auction to be scheduled. Fees billed to date: None CAY Time: 3.5 hours (both cases) Costs: 0.00 Monroe County v. Marv Ellen L10vd CAM-03-362 Circuit Court 16th Judge: Jones Date Filed: 12/19/03 Code enforcement foreclosure action authorized by the SOCC 4/18/03. The total amount of the lien owed to the County is $143,500.00. Growth Management/Code Enforcement Current Status: Compliance achieved 8/31/04. Next Activity: Settlement offer to be presented at October SOCC meeting. Fees billed to date: None CAY Time: 2.3 hours Costs: 0.00 23 Monroe County v. James Messera. et al CAK-03-1509 Circuit Court 16th Judge: Payne Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the SOCC 4/18/03. Growth Management/Code Enforcement Current Status: Owners working on compliance. Next Activity: Settlement discussions ongoing. Fees billed to date: None Costs: 0.00 Monroe County v. Joe Posada. III CAK-03-1503 Circuit Court 16th Judge: Payne Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the SOCC 4/18/03. Growth Management/Code Enforcement Current Status: Settlement unproductive. Next Activity: Proceed with foreclosure. Fees billed to date: None CAY Time: 3.5 hours Costs: 0.00 Monroe County v. Virainia Sawyer & Tony Welters CAK-03-1505 Circuit Court 16th Judge: Payne Date Filed: 12/18/03 Code enforcement foreclosure action that was authorized by the SOCC 7/15/03. Growth Management/Code Enforcement Current Status: DFs answered. Next Activity: Discovery. Fees billed to date: None Costs: 0.00 Monroe County v. Virainia Sawyer CAK-03-1506 Circuit Court 16th Judge: Payne Date Filed: 12/18/03 Code enforcement foreclosure action that was authorized by the SOCC 7/15/03. Growth Management/Code Enforcement Current Status: DFs answered. Next Activity: Discovery. Fees billed to date: None Costs: 0.00 24 Monroe County v. Louis Welters CAK-04-639 Circuit Court 16th Judge: Jones Date Filed: 6/14/04 Code enforcement foreclosure action that was authorized by the SOCC 7/15/03. Growth Management/Code Enforcement Current Status: OF answered. Next Activity: Discovery. Fees billed to date: None Costs: 0.00 Osborn. Jeff v. Monroe County CAP-04-564 Circuit Court 16th Judge: Garcia Date Filed: 11/24/04 1 of 2 certiorari petitions challenging development approval of Northstar project. Growth Management/Planning Current Status: Pleadings complete. Next Activity: Oral argument set for 9/29/05. Fees billed to date: $14,039.50 Costs: $261.49 Osborn. Jeff v. Monroe County CAP-04-565 Circuit Court 16th Judge: Garcia Date Filed: 11/24/04 2 of 2 certiorari petitions challenging development approval of Northstar project. Growth Management/Planning Current Status: Pleadings complete. Next Activity: Oral argument set for 9/29/05. Fees billed to date: $3,920.50 Costs: $146.93 i Includes cases listed under outside counsel. ii Article V issue, bankruptcy claim, and Fire Rescue. 25