Item R1 R.1
Coty f � ,�� ,' BOARD OF COUNTY COMMISSIONERS
�� Mayor David Rice,District 4
The Florida Keys � Mayor Pro Tem Craig Cates,District 1
y Michelle Coldiron,District 2
James K.Scholl,District 3
Ij Holly Merrill Raschein,District 5
County Commission Meeting
November 15, 2022
Agenda Item Number: R.1
Agenda Item Summary #10024
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 November 2022.
ITEM BACKGROUND: Monthly report is attached.
PREVIOUS RELEVANT BOCC ACTION:
CONTRACT/AGREEMENT CHANGES:
n/a
STAFF RECOMMENDATION: Report.
DOCUMENTATION:
CAY report November 2022
MASTER FINES AND COSTS SPREADSHEET AS OF OCTOBER 2022
FINANCIAL IMPACT:
Effective Date:
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:
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Revenue Producing: If yes, amount:
Grant:
County Match:
Insurance Required:
Additional Details:
n/a
REVIEWED BY:
Cynthia Hall Completed 11/01/2022 8:46 AM
Bob Shillinger Completed 11/01/2022 2:53 PM
Lindsey Ballard Completed 11/01/2022 3:17 PM
Board of County Commissioners Pending 11/15/2022 9:00 AM
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BOARD OF COUNTY COMMISSIONERS
County of Monroe Mayor David Rice,District 4
Mayor Pro Tern Craig Cates,District 1
y
�' Michelle Coldiron,District 2
a
The Florida Keys � � � �
James K.Scholl,District 3
Holly Merrill Raschein,District 5
Robert B.Shillinger,County Attorney— Office of the County Attorney
Pedro J.Mercado,Senior Assistant County Attorney** 1111 12'Street,Suite 408
Cynthia L.Hall,Assistant County Attorney** Key West,FL 33040
Christine Lirnbert-Barrows,Assistant County Attorney** Phone(305)292-3470
Derek V.Howard,Assistant County Attorney** Fax (305)292-3516
Peter H.Morris,Assistant County Attorney*
Patricia Fables,Assistant County Attorney
Joseph X.DiNovo,Assistant County Attorney*
James Molenaar,Assistant County Attorney t^d
Kelly M.Dugan,Assistant County Attorney C14
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**Board Certified in City,County&Local Government Law qp
To: Mayor & Commissioners
From: Bob Shillinger, County Attorney 0
Date: November 1, 2022
Re: November 2022 County Attorney Report CL
Cases of Interest at Trial Court Level
0
1. Burke Construction Group, Inc. v. Monroe County, CA-M 19-80 (state court case).
On 7/11/19, Burke Construction Group sued to challenge the County's bid protest
procedure and decisions to award contracts for the Marathon Library and Cudjoe
Fire Station projects to other contractors. The County answered and is engaged in �?
discovery. N
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2. Burke Construction Group v. Monroe County, U.S.D.C. S.D. of FL, 4:22-cv-10017-
DPG (federal case). On 3/24/22, Burke, a disappointed bidder and plaintiff in Circuit
Case CAM19-80 (see above), filed a second suit against the County, alleging federal
claims. Burke complains that it was deprived of a property interest when it failed to
get the award of the contracts to build the Marathon Library and the Cudjoe Fire
Station. The County filed a motion to dismiss on 4/28/2022. On 6/8/22, Burke filed
a Second Amended Complaint. On 7/15/22, Burke filed a motion to stay or abate
the federal court case pending resolution of the state court case. On 7/19/22, the U
County filed another motion to dismiss. Plaintiff voluntarily dismissed on
10/31/22.
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3. AshBritt, Inc. v. Monroe County & FDOT 16t" Cir. 17-CA-802-K. AshBritt sued the
County for breach of contract and for breach of implied covenant of good faith and
fair dealing. The County answered and moved for summary judgment (MSJ). On
2/24/20, Judge Koenig denied the County's MSJ and the County appealed. On
3/9/22, the Third DCA affirmed the denial of the County's MSJ, on the grounds that
there were triable issues of fact in the case and therefore summary judgment could
not be issued, and the case was remanded to the trial court. On 7/25/22, AshBritt
issued a settlement offer. On 8/31/22, AshBritt issued a revised settlement offer,
which was discussed with the BOCC in closed session. Another closed session
will be held on 12/7/22.
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4. Roy's Trailer Park v. Noel & Monroe County, 19-CA-175-K. Declaratory Judgment
suit filed by Roy's against County as part of its eviction suit against its tenant. On
10/4/18, the County countersued the trailer park and the park residents, seeking an
injunction prohibiting occupancy at the park until serious fire and life safety issues
have been addressed, and for appointment of a receiver, and a declaratory relief
cause of action to determine whether the owner or tenants are responsible for the
code violations. The park owner has submitted an application to the Planning
Department to redevelop the park for affordable housing.
5. Monroe County v. Sugarloaf VFD, Inc. & Sugarloaf Wi-Fi, Inc., 17-CA-631-K. The
County sued both SVFD and Wi-Fi to invalidate a lease between SVFD and Wi-Fi
on the grounds that SVFD had not approved the lease in an open meeting. The trial
court ruled in favor of the County and voided the lease. Wi-Fi appealed and lost. N
On 1/31/21, the County filed a motion for attorneys' fees to recover attorneys' fees
and costs from SVFD as the prevailing party. Mediation between Wi-Fi, the SVFD,
and the County is ongoing. On 11/22/2021, the Court entered a judgment for
attorneys' fees and costs in favor of the County in the amount of $217,159.86. The 8
parties are still in mediation. At Wi-Fi's request, Fortress Secured LLC submitted a It
public private partnership (P3) proposal that would serve as the basis for settlement.
At the 4/20/22 meeting, the Board approved beginning the P3 process. No
competing proposals were submitted by the 6/28/22 deadline to build a new fire
station. On 7/20/22, the BOCC authorized Assistant County Administrator Kevin 0
Wilson to negotiate agreements with Fortress Secured, LLC to design, build and
finance a replacement fire station on Sugarloaf Key at the current location of the
Sugarloaf Volunteer Fire Department Station #10.
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6. Gregory Burkhardt v. Monroe County, No. 22-cv-10041 (S.D. Fla.). On 4/28/22, N
Plaintiff filed a Complaint for Declaratory and Injunctive Relief in state court seeking N
to declare whether Plaintiff has a right to engage in commercial fishing uses on his
Big Pine Key property. The complaint also seeks to invalidate the Habitat
Conservation Plan and Incidental Take Permit issued by USFWS. On 5/25/22, the
County removed the action to federal court because the litigation presents a federal
question. On 7/12/22, the County filed its motion to dismiss and in the alternative,
motion for a more definite statement. On 7/26/22, Plaintiff filed its response to that
motion and a motion to remand back to state court for lack of a substantial federal
question. The motions are set for zoom hearings on 11/29/22. U
7. Galleon Bay Corp. v. Monroe County and State of Florida — 02-CA-595-K. This
takings case resulted in a final judgment in the amount of $480,511. A Satisfaction
of Judgment was issued. The parties are engaged in discovery on the only
remaining issue of attorneys' fees.
8. Monroe County v. Villalobos, 16t" Cir. 21-CA-257-P. Lien foreclosure case. The
parties are in the process of attempting to settle the case.
9. Tommy Alfonso on behalf of T.A., a Minor, v. Monroe County, Florida, 16th Cir.
22-CA-108-K. Parent of minor sues alleging that child was injured on an
observation deck at the back of Bernstein Park. Discovery is ongoing.
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10.Manuel Melo v. Monroe County, 16t" Cir. 22-CA-091-P. On 2/24/22, Plaintiff
filed a complaint against the County relating to a Final Order of the Code
Compliance Special Magistrate that was entered in CE17110041 on 4/19/19.
The order found Plaintiff in violation for clearing his property, which is
endangered species habitat, without a permit. The complaint, inter alia, seeks
to invalidate the Final Order. On 3/17/22, the County filed its motion to dismiss
the complaint. On 7/26/22, the Court entered an order giving the Plaintiff twenty
(20) days to file the amended complaint. On 9/12/22, Plaintiff filed an amended
complaint. The County filed another motion to dismiss on 9/20, which is set for
hearing on 12/9/22.
11.Mark Thompson v. Monroe County and City of Key West, 16t" Cir. No. 22-CA-
113-K. On 2/24/22, Plaintiff, a former pumpout boat employee, filed a complaint N
suing Monroe County under the Jones Act for injuries arising during his
employment. On 6/1/22, Plaintiff filed an amended complaint, adding the City
of Key West as a party. The County has requested defense and indemnification
from the City pursuant to the terms of an interlocal agreement. On 8/5/22, the 0
City filed an answer. On 8/22/22, the Court assigned a projected trial date of It
12/6/23. All parties are now engaged in discovery. CL
12.Monroe County v. Kenneth & Anita Buirley, 19-CA-565-K. This is a code lien
enforcement action where the fines exceed $700,000.00. The property is located
on El Monte Lane on Big Coppitt Key. The Court authorized the County to demolish
and clear the property of the unsafe structures. After suit was filed, the Buirleys sold
the property to Jay Archbell, P.A., which demolished the structures and brought the
property into compliance. The Archbell company was added into the lawsuit as a U
defendant on 8/5/22. Mr. Archbell offered to resolve the case for $16,500.00, which N
the BOCC rejected. On 8/9/22, Archbell was added to the lawsuit as a defendant. Q
On 9/21/2022, the BOCC rejected a settlement offer by Archbell. Litigation is
proceeding.
13.Monroe County v. Sosa, 16t" Cir. 22-CA-517-K. For injunctive relief and money Z
judgment following code compliance lien for unsafe structures. Complaint was filed
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on 7/26/22. The parties are in settlement discussions.
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Appellate Cases of Interest
1. Parrot Fish Bay, LLC v. Monroe County, 20-AP-2-P/3D22-411. On 2/27/20, the
property owner filed a notice of appeal of the 1/30/20 Final Order of the Special
Magistrate finding the subject property in violation of multiple land clearing and
environmental violations (LDC 110-140(a), 118-7, 118-11(a)(b), 118-13, and 122-
8(d)(3)). Briefing is complete. Oral argument was held on 10/15/21. On 2/3/22, the
Circuit Court issued an opinion reversing the Special Magistrate's final order and
remanded the case back to the Special Magistrate. On 7/7/22, the County filed a
petition for writ of certiorari in the Third District Court of Appeal. The property owner
filed a response on 9/12/22. On 10/27/22, the Third DCA denied the County's
petition.
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2. Maschal et al. v. Monroe County and FKAA(now known as Crawford et al. v. Monroe
County and FKAA), CA K 19-186 (Third DCA Case No. 22-754) — Suit against
Monroe County and FKAA by Banks Prevatt and 11 other individuals seeking similar
relief to the Delaney lawsuit, which the County won. On 9/30/21, the Court
dismissed the Plaintiffs' Second Amended Complaint, but also granted the Plaintiffs'
motion to file a supplementary complaint. On 10/11/21, Plaintiffs filed a different
supplementary complaint. On 10/12/21, Plaintiffs filed a Motion to Disqualify the trial
judge; the Court granted the order on 10/14/21 and the case was reassigned to
Judge Jones. On 10/15/21, Plaintiffs filed a motion to reconsider the 9/30/21 order
granting the County's Motion to Dismiss. The County and FKAA filed a Motion to
Strike the supplementary complaint and also a Motion for Reconsideration of the
Court's 9/30/21 order granting leave to file the supplementary complaint. On 4/4/22,
the Court denied the Plaintiff's motion for reconsideration and granted the County a
and FKAA's motion for reconsideration, thus denying the Plaintiff's motion to file a
supplementary complaint. On 5/3/22, the Plaintiffs appealed to the Third DCA.
Appellants filed their initial brief on 9/8/22. Answer brief for County and FKAA
is due on 11/21/22. 0
3. Joeandy Herrera & Jessica Herrera v. Monroe County, 21-AP-0007-P. On 9/2/21, CL
the property owners filed a notice of appeal of the Final Order of the Special
Magistrate that found them in violation for building activity without a permit. The
initial brief was filed on 7/20/22. The County's answer brief was due on 10/29/22. 0
However, on 10/24/22, the County filed an unopposed motion to stay the
appeal. Awaiting a hearing or ruling on the motion.
4. Steve Stone v. Monroe County, 21-AP-8-P. On 9/2/217 the property owner filed a U
notice of appeal of the Final Order of the Special Magistrate that found him in N
violation for building activity without a permit. The initial brief was filed on 1/24/22. Q
The County filed its answer brief on 3/25/22. On 5/31/22, the property owner filed
his reply brief. On 6/8/22, the court denied the motion of Keyw Kiwi Corp., appellant
in the appeal listed below, seeking leave to file an amicus brief in the Stone case.
Oral argument was held on 7/25/22. Awaiting a ruling from the Court.
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5. Keyw Kiwi Corp. v. Monroe County, 22-AP-2-K. On 3/1/22, the owner filed a notice
of appeal of the Final Order of the Special Magistrate that found it in violation of
building activity without a permit. On 3/16/22, the Court entered an order staying U
the appeal pending the outcome in Stone v. Monroe County (#23 above) because
that appeal also involves a similar statute of limitations issue. On 6/8/22, the court
denied the motion of Keyw Kiwi Corp. seeking leave to file an amicus brief in the
Stone case.
6. Ray Rey & Ramille Rey v. Monroe County, 22-AP-2-P. On 3/1/22, the owners filed
a notice of appeal of the Final Order of the Special Magistrate that found them in
violation due to improvements to a nonconforming lower enclosure. The County
filed its answer brief on 6/16/22. A reply brief was filed on 7/21/22. Awaiting
scheduling of oral argument.
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Administrative Cases of Interest
7. Diane Beruldsen, et al v. Monroe County, DOAH 21-1657GM. Administrative petition
challenging Ordinance 05-2021, amending Comp Plan to authorize 300 early
evacuation ROGOs that are to be used as exchange for existing affordable ROGOs
was filed on 5/21/21. The reclaimed ROGOs would be used for administrative relief.
The challenge is being held in abeyance until the related Cities' challenge is resolved
by the Third District in Case No. 3D20-1921, Mattino et al. v. City of Marathon, et al.
On 8/3/22, the Third District issued its decision reversing the DEO order approving
the comprehensive plan amendments as to Marathon and Islamorada but affirming
as to the City of Key West. It is expected that review of that decision will be sought
in the Florida Supreme Court following the Third District's denial of motions for N
rehearing on 9/20/22. The DOAH challenge is being held in abeyance until N
resolution of the Mattino appeal.
8. Lower Density for Lower Sugarloaf, LLC, et al. v. Monroe County Planning
Commission, DOAH 21-494/21-CA-574-K. On 2/5/21 , a group of property owners
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neighboring the proposed affordable-employee housing development filed an appeal
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to DOAH, seeking to quash or reverse the Planning Commission's granting of a
Major Conditional Use permit to applicant Lower Keys Community Center Corp., and
also on 2/5/21, filed a parallel appeal of Resolution No. P36-20 to the BOCC sitting
as an appellate body under Chapter 139 of the Land Development Code. On
3/22/21, the developers intervened. The appellants on 4/6/21 filed a motion for the
DOAH ALJ to stay the DOAH proceeding, which the DOAH ALJ denied on 4/26/21.
After argument on 7/13/21, the ALJ issued a final order on 7/22/21, upholding the U
Planning Commission's decision to approve the project's major conditional use
permit. On 8/23/21, the property owners filed a petition for writ of certiorari in Circuit Q
Court. On 9/24/21, Lower Keys Community Center filed a response to the petition,
in which the Monroe County Planning Commission joined. Petitioners' reply brief
is due on 11/18/22.
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9. 6-7-8 US 1, LLC v. Monroe County Planning Department. On 5/7/21, the property
owner filed an appeal to the Planning Commission of the Department's 4/7/21 letter CL
of understanding regarding the attempted use of storage/shipping containers at its
Key Largo property in the SC land use district (Property Identification No. 00149430-
000000). The Department determined that the storage/shipping containers used for
commercial storage at the property were not subject to the property owner's
conditional use approval or building permit for the parcel, are structures that require
a permit and compliance with the Comprehensive Plan, LDC, Chapter 6 of the
County Code, the Florida Building Code, local and FEMA flood regulations, and
constitute non-residential floor area as defined in the LDC and are subject to
NROGO. The owner's appeal of the Department's analysis and conclusions
will be heard at the Planning Commission's November meeting.
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Vacation Rental Cases
10.Coral Hammock Rental, et al. v. Monroe County, 20-AP-11-K. On 10/29/20, the
Special Magistrate heard 47 vacation rental violation cases arising from Coral
Hammock, found 45 properties in violation, and assessed fines of $224,329, plus
costs. Twenty-Six of the 45 property owners found in violation appealed the final
order to the Circuit Court. The appeals were consolidated for purposes of briefing
common issues of law. Appellants filed their brief on 6/4/21. The County filed its
brief on 10/22/21. Appellants' reply brief was filed on 1/28/22. Oral argument was
held on 10/13/22 before Sr. Judge James M. Barton II. Awaiting a ruling.
Class Action Lawsuits where Monroe County is a party Q
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11. Monroe County v. Purdue Pharma L.P. et al., No. 4:19-cv-10049. This case was
filed by Monroe County against opioid manufacturers/marketers and distributors on
4/3/19. The complaint seeks damages including punitive damages, attorneys' fees, 0
costs, and injunctive relief. The case is part of multi-district litigation under a judge
in Cleveland, Ohio. On 9/15/21, the BOCC approved a resolution that expressed CL
approval for a settlement formula. On 12/8/21, the BOCC approved a settlement
agreement with three Distributors and one Manufacturer (J&J) under which the
County is estimated to receive approximately $200K/year for 18 years beginning in 0
April 2022 if the settlement is finalized by the court. At the 3/16/22 meeting, the
BOCC approved settlement with another defendant manufacturer (Endo) and
authorized the County Attorney's Office to enter into further settlement with other
defendants as they become available. On 4/12/22, the County Attorney (on behalf �?
of the BOCC) approved settlements with Teva, Allergan, and CVS. On 5/9/22, the N
County Attorney (on behalf of the BOCC) approved a settlement with Walgreens. N
The County expects payouts to begin during fall 2022 or winter 2023.
12.Monroe County v. 3M, et al., 16t" Jud. Cir. Case No. 22-CA-618-K/2:22-cv-03680-
RMG, consolidated into 2:18-mn-02873-RMG: On 9/9/2022, Monroe County filed
suit against manufacturers of aqueous film-forming foam (AFFF) containing per-and
polyfluoroalkyl substances (PFAS) to recover damages for investigation,
remediation, removal, disposal, treatment and monitoring of water and soil created
by defendants' products. PFAS had been detected at the Monroe County Fire U
Training Academy on Grassy Key. At present, the lawsuit only involves the Fire
Training Academy, although AFFF has also been used at the Key West International
Airport and the Marathon Florida Keys International Airport. On 10/7/22,
defendants removed the case to the U.S. District Court for the Southern
District of Florida. On 10/26/22, the County's case was transferred and
consolidated with other similar cases in the Multi District Litigation (MDL) case
pending in the District of South Carolina before Hon. Richard M. Gergel.
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Constitutional Officer Cases
13.Supervisor of Elections v. My Pillow, Inc.: Response to subpoena issued in
Dominion Voting Systems v. My Pillow, Inc. and Lindell, 1-21-cv-00445-CJN (D.D.C.
2021) and Case No. 4:22-me-10086 (S.D. Fla.). On 9/7/22, the Supervisor of
Elections (SOE) was served with a subpoena from Defendants, My Pillow and
Lindell, seeking forensic images of the County's voting system; access information
including MAC and IP addresses, user names and passwords; documentation
regarding that system; and other documents. The County Attorney's Office served
objections on 9/20/22 and filed a motion to quash in the Southern District of Florida
on 9/30/22. My Pillow filed an opposition. The motion will be heard on 11/2/22.
14.League of Women Voters of FL v. Sec'y of State Lee, Joyce Griffin, et al, 4:21-cv- N
00186, USDC/NDFL, 11t" Cir. Ct. App. Case No. 22-11143, Suit against the State CIN
and the Supervisors of Election for all 67 counties challenging SIB 90, elections
legislation enacted in 2021. Griffin and other SOEs retained outside counsel. The
County Attorney's Office is assisting in the defense. The other cases shown below 0
raise similar challenges to SIB 90. Supervisor Griffin has also been specifically It
named as a defendant in those cases. All cases were consolidated and tried earlier
this year. The Court entered a 288-page Final Order on 3/31/22 for all cases. The
Secretary of State and several other defendants filed an appeal of this Order on
4/7/22. The appeal of the four cases (case listed above, and three cases listed
below) was consolidated under the case of League of Women Voters et al. v. Florida
Secretary of State et al., 11t" Cir. Case no. 22-11143. On 5/6/22, the appellate court
stayed Judge Walker's final Order. For now, the provisions that Judge Walker had
0
invalidated are again in effect and will remain so through the 2022 election. The �?
Secretary of State filed its initial brief on 7/11/22. Oral argument was held on N
9/15/22. The parties are still awaiting a decision from the Court. Consolidated
with NAACP of FL v. Sec'y of State Lee, Joyce Griffin, et al, 4:21-cv-00187,
USDC/NDFL, 11t" Cir. Ct. App. Case No. 22-1114; Florida Rising Together, v. Sec'y
of State Lee, Joyce Griffin, et al, 4:21-cv-201, USDC/NDFL, 11t" Cir. Ct. App. Case
No. 22-11143;. Harriet Tubman Freedom Fighters, et al v. Laurel M. Lee, et al, No.
4-21-cv-00-242-MW-MAF, 11 t" Cir. Ct. App. 22-11133.
Tort and/or Employment Law Cases
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15.The County Attorney's Office is currently representing the County in the following
other personal injury, property damage and employment law cases not referenced
above:
Katzenstein v. Monroe County, 20-CA-177-P Personal injury
Barter v. Monroe County, 16th Cir. 21-CA-418-K Personal injury
Lien Foreclosure and Mortgage Foreclosure Cases
16.The County Attorney's Office is currently prosecuting a total of 31 cases to foreclose
on County code compliance liens. The Office is also currently representing the
County as a defendant in 7 mortgage foreclosure cases, where the County holds an
interest in the property, usually as a result of an inferior code compliance lien.
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Other Matters of Interest
17.Code Collections. During October 2022, County Attorney and Code Compliance
staff collected $65,822.73 in code compliance fines and costs. Cumulatively
through the first month of FY23, staff has collected $86,212.73 in fines and costs,
including after-the-fact permit fees. A chart showing code collections is attached.
18.Vacation Rental Prosecutions. No vacation rental cases were heard at the
October code hearing.
19.Miscellaneous. The Florida Association of County Attorneys requested that
County Attorney Bob Shillinger to serve on the committee assisting the Hendry N
County BOCC to select its next County Attorney following the retirement of the �
incumbent.
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Risk Management
It
20.Risk Management activity in October 2022 was as follows:
Claims:
County Property (CP) 6
Auto Physical (AP) 9
General Liability (GL) 0
Auto Liability (AL) 3
Flood policy renewals: 5 policies t0
Insurance Policy renewals: 3 policies U
Vehicle/Equipment addition and deletion: 33 vehicles/equipment added or N
deleted N
Open Pending Risk claims over past 5 years
(including claims being monitored and/or E
handled by Risk Management and claims being >
litigated by Monroe County Attorney's Office): z
AP claims 58
CP claims 83
AL claims 1 >-
GL claims 58 <
Large Dollar Amount Claims:
Current GL above $10,000 1
Current AL above $3,000 1
Past AP and CP above $3,000 going back 5 14
years
Agenda Items Reviewed past month 72
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Packet Pg.4122
Public Records
2 1.The County Attorney's Office serves as the coordinator of public records requests
for the County. During the month of October 2022, the office processed a total of
140 requests and assisted other departments with fulfilling an additional 107
requests for a total of 247 public records requests. Please see below for further
details:
("omiity, Recor(,,,,Is r)erIc,,,rimarjce Report
October 1, to Oictobeir 31, 1211),22 Afl Departments
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Packet Pg.4123
Mar-23 0.00 0.00 0.00
Apr-23 0.00 0.00 0.00
May-23 0.00 0.00 0.00
Jun-23 0.00 0.00 0.00
Jul-23 0.00 0.00 0.00
Aug-23 0.00 0.00 0.00
Sep-23 0.00 0.00 0.00
DIALS 57,214.27 8,608.46 65,822.73 20,390.00 0.00 86,212.73
Oct-21 59,912.50 13,524.56 73,437.06 11,040.00 0.00 84,477.06
Nov-21 83,787.50 13,669.88 97,457.38 12,800.00 0.00 110,257.38
Dec-21 105,174.62 13,502.76 118,677.38 35,500.00 0.00 154,177.38
Jan-22 72,278.49 13,805.11 86,083.60 11,550.00 0.00 97,633.60
Feb-22 78,520.00 17,783.03 96,303.03 9,500.00 0.00 105,803.03
Mar-22 62,252.42 25,894.51 88,146.93 9,755.00 0.00 97,901.93
Apr-22 48,475.30 15,095.90 63,571.20 8,700.00 0.00 72,271.20
May-22 83,298.34 21,472.82 104,771.16 16,608.00 0.00 121,379.16
Jun-22 131,099.35 18,733.10 149,832.45 14,395.00 0.00 164,227.45
Jul-22 1447915.38 127783.99 1577699.37 127850.00 0.00 1707549.37
Aug-22 567577.48 97334.51 657911.99 107739.75 0.00 767651.74
Sep-22 1057788.10 117963.67 1177751.77 47910.00 0.00 1227661.77
DIALS 1,032,079.48 187,563.84 1,219,643.32 158,347.75 0.00 1,377,991.07
Oct-20 1107118.18 87468.94 1187587.12 127000.00 0.00 1307587.12
Nov-20 2747496.96 187626.30 2937123.26 127049.00 0.00 3057172.26
Dec-20 3717537.44 217711.75 3937249.19 247465.50 0.00 4177714.69
Jan-21 407231.44 67155.62 467387.06 177477.00 0.00 637864.06
Feb-21 827488.84 77119.61 897608.45 167802.40 0.00 1067410.85
Mar-21 1537210.14 117740.03 1647950.17 137289.33 0.00 1787239.50
Apr-21 547765.14 107410.67 657175.81 227361.00 0.00 877536.81
May-21 1337087.50 137693.82 1467781.32 387452.50 0.00 1857233.82
Jun-21 1087284.38 117984.20 1207268.58 147324.80 0.00 1347593.38
Jul-21 487132.91 127330.99 607463.90 167705.00 0.00 777168.90
Aug-21 957416.47 177905.63 1137322.10 167500.00 0.00 1297822.10
Sep-21 8347980.91 347127.76 8697108.67 177715.00 0.00 8867823.67
DIALS 2,306,750.31 174,275.32 2,481,025.63 222,141.53 0.00 2,703,167.16
Oct-19 2147502.00 237106.65 2377608.65 147184.24 0.00 2517792.89
Nov-19 1067074.69 137167.07 1197241.76 387919.00 0.00 1587160.76
Dec-19 937199.37 287049.18 1217248.55 277080.00 0.00 1487328.55
Jan-20 797016.84 97927.40 887944.24 267054.50 0.00 1147998.74
Feb-20 1057812.50 127011.18 1177823.68 137738.00 0.00 1317561.68
Mar-20 977165.30 57403.80 1027569.10 57000.00 0.00 1077569.10
Apr-20 607448.51 147526.09 747974.60 77000.00 0.00 817974.60
May-20 297800.00 27856.07 327656.07 37834.00 0.00 367490.07
Jun-20 507271.07 107607.60 607878.67 207400.00 0.00 817278.67
Jul-20 627323.66 57395.02 677718.68 107612.42 0.00 787331.10
Aug-20 1247395.25 127106.57 1367501.82 187872.50 0.00 1557374.32
Sep-20 1557989.83 137770.09 1697759.92 87368.52 0.00 1787128.44
ITALS 1.178.99-9 n9 150.926.72 1.329.925.74 194.063.18 0.00 1.523.988.92
Sep-19 142,855.12 21,742.25 164,597.37 18,699.76 0.00 183,297.13
DIALS 1,672,813.56 182,529.73 1,855,343.29 270,162.70 0.00 2,125,505.99
Oct-17 91,400.00 5,555.74 96,955.74 0.00 0.00 96,955.74
Nov-17 82,378.03 2,081.75 84,459.78 1,000.00 0.00 85,459.78
Dec-17 221,965.50 10,273.34 232,238.84 2,500.00 0.00 234,738.84
Jan-18 12,258.00 2,411.06 14,669.06 2,549.00 0.00 17,218.06
Feb-18 117,628.00 9,725.40 127,353.40 4,527.00 0.00 131,880.40
Mar-18 131,855.80 5,855.52 137,711.32 8,198.00 0.00 145,909.32
A r-18 102,294.74 9,032.96 111,327.70 18,776.00 0.00 130,103.70
May-1 8 234,644.55 12,005.31 246,649.86 12,963.00 0.00 259,612.86
Jun-18 159,579.18 15,627.12 175,206.30 7,000.00 0.00 182,206.30
Jul-18 178,590.00 12,735.62 191,325.62 9,100.00 0.00 200,425.62
Aug-1 8 305,175.19 25,319.00 330,494.19 8,500.00 0.00 338,994.19
Sep-1 8 194,858.92 11,751.09 206,610.01 10,500.00 0.00 217,110.01
DIALS 1,832,627.91 122,373.91 1,955,001.82 85,613.00 0.00 2,040,614.82
Oct-16 217,650.79 13,725.86 231,376.65 4,400.00 0.00 235,776.65
Nov-16 227,785.20 19,645.28 247,430.48 5,000.00 0.00 252,430.48
Dec-16 265,695.00 17,792.51 283,487.51 9,614.00 0.00 293,101.51
Jan-17 20,211.00 4,373.92 24,584.92 1,000.00 0.00 25,584.92
Feb-17 75,765.37 8,548.48 84,313.85 0.00 0.00 84,313.85
Mar-17 148,287.86 12,850.64 161,138.50 5,430.00 0.00 166,568.50
Apr-17 44,886.86 8,739.36 53,626.22 6,500.00 0.00 60,126.22
May-17 99,402.60 12,369.67 111,772.27 5,850.00 0.00 117,622.27
Jun-17 78,697.00 9,474.69 88,171.69 8,402.00 0.00 96,573.69
Jul-17 89,965.00 12,458.67 102,423.67 2,000.00 0.00 104,423.67
Aug-17 216,371.93 10,646.72 227,018.65 5,781.00 0.00 232,799.65
Sep-17 0.00 0.00 0.00 0.00 0.00 0.00
31S 1,484,718.61 130,625.80 1,615,344.41 53,977.00 0.00 1,669,321.41
Oct-15 61,426.72 10,511.57 71,938.29 7,750.00 0.00 79,688.29
Nov-15 48,354.30 11,793.36 60,147.66 4,973.00 0.00 65,120.66
Dec-15 62,632.50 6,632.92 69,265.42 2,000.00 0.00 71,265.42
Jan-16 107,268.81 9,832.65 117,101.46 3,950.00 0.00 121,051.46
Feb-16 51,280.56 4,053.38 55,333.94 5,700.00 0.00 61,033.94
Mar-16 90,377.88 9,444.40 99,822.28 3,500.00 0.00 103,322.28
Apr-16 195,134.49 9,909.37 205,043.86 11,950.00 0.00 216,993.86
May-16 116,788.89 10,038.53 126,827.42 5,750.00 0.00 132,577.42
Jun-16 76,766.16 15,398.33 92,164.49 5,450.00 0.00 97,614.49
Jul-16 55,079.02 7,142.74 62,221.76 3,000.00 0.00 65,221.76
Aug-16 56,431.52 8,022.33 64,453.85 2,255.00 0.00 66,708.85
Sep-16 76,726.41 9,679.07 86,405.48 8,400.00 0.00 94,805.48
31S 998,267.26 112,458.65 1,110,725.91 64,678.00 0.00 1,175,403.91
Oct-14 54,290.83 10,089.61 64,380.44 2,000.00 0.00 66,380.44
Nov-14 6,937.50 2,320.91 9,258.41 5,293.00 0.00 14,551.41
Dec-14 32,966.67 5,214.20 38,180.87 8,604.00 0.00 46,784.87
Jan-15 3,591.67 1,707.54 5,299.21 4,500.00 0.00 9,799.21
Feb-15 57,802.61 9,142.24 66,944.85 5,537.40 0.00 72,482.25
Mar-15 68,916.67 6,091.97 75,008.64 8,060.00 0.00 83,068.64
A r-15 50,862.50 3,932.05 54,794.55 8,665.00 0.00 63,459.55
May-1 5 38,366.66 5,229.36 43,596.02 9,666.30 0.00 53,262.32
Jun-15 25,259.58 7,955.08 33,214.66 4,830.00 0.00 38,044.66
May-14 8,691.99 3,152.10 11,844.09 10,558.00 0.00 22,402.09
Jun-14 79,184.00 14,272.72 93,456.72 7,000.00 0.00 100,456.72
Jul-14 12,108.94 6,453.84 18,562.78 7,500.00 0.00 26,062.78
Aug-14 11,275.03 2,842.32 14,117.35 4,994.00 0.00 19,111.35
Sep-14 53,768.00 8,782.68 62,550.68 8,196.40 0.00 70,747.08
31s 403,993.14 65,682.90 469,676.04 74,673.40 0.00 544,349.44
Oct-12 39,950.54 6,278.67 46,229.21 7,250.00 990.00 54,469.21
Nov-12 17,416.97 1,461.55 18,878.52 3,700.00 720.00 23,298.52
Dec-12 56,966.98 9,203.80 66,170.78 3,500.00 270.00 69,940.78
Jan-13 30,599.96 7,206.40 37,806.36 3,880.00 450.00 42,136.36
Feb-13 29,600.30 6,145.60 35,745.90 3,500.00 270.00 39,515.90
Mar-13 15,821.30 4,406.98 20,228.28 5,200.00 270.00 25,698.28
Apr-13 27,074.31 3,678.13 30,752.44 3,000.00 810.00 34,562.44
May-13 32,386.69 5,795.00 38,181.69 4,000.00 450.00 42,631.69
Jun-13 14,466.64 2,912.69 17,379.33 3,000.00 360.00 20,739.33
Jul-13 25,166.66 2,245.54 27,412.20 6,313.60 90.00 33,815.80
Aug-13 32,566.64 1,450.56 34,017.20 5,800.00 0.00 39,817.20
Sep-13 51,324.96 3,330.80 54,655.76 3,750.00 0.00 58,405.76
31s 373,341.95 54,115.72 427,457.67 52,893.60 4,680.00 485,031.27
Oct-11 64,020.50 6,892.20 70,912.70 3,500.00 2,430.00 76,842.70
Nov-11 8,800.00 3,386.36 12,186.36 2,000.00 1,170.00 15,356.36
Dec-11 3,550.00 2,635.70 6,185.70 2,500.00 1,800.00 10,485.70
Jan-12 21,300.00 4,725.41 26,025.41 3,000.00 1,620.00 30,645.41
Feb-12 28,546.66 3,695.38 32,242.04 1,800.00 1,440.00 35,482.04
Mar-12 31,925.00 5,516.99 37,441.99 3,500.00 1,620.00 42,561.99
Apr-12 36,696.66 2,693.08 39,389.74 4,000.00 1,800.00 45,189.74
May-12 65,617.33 6,176.11 71,793.44 4,060.00 1,530.00 77,383.44
Jun-12 5,217.00 667.39 5,884.39 2,000.00 810.00 8,694.39
Jul-12 28,433.32 6,782.45 35,215.77 1,590.00 1,080.00 37,885.77
Aug-12 7,917.30 9,126.20 17,043.50 4,745.00 630.00 22,418.50
Sep-12 15,350.00 600.79 15,950.79 2,000.00 720.00 18,670.79
31s 317,373.77 52,898.06 370,271.83 34,695.00 16,650.00 421,616.83
Oct-10 28,433.00 5,430.21 33,863.21 0.00 0.00 33,863.21
Nov-10 28,234.78 4,972.51 33,207.29 1,000.00 2,070.00 36,277.29
Dec-10 36,730.68 3,159.63 39,890.31 9,800.00 2,160.00 51,850.31
Jan-11 42,444.08 5,188.79 47,632.87 5,405.00 1,980.00 55,017.87
Feb-11 26,727.00 5,126.63 31,853.63 3,220.00 2,060.00 37,133.63
Mar-11 55,517.56 9,022.78 64,540.34 14,283.00 3,240.00 82,063.34
Apr-11 20,201.00 5,076.11 25,277.11 1,500.00 2,340.00 29,117.11
May-11 19,470.50 5,792.91 25,263.41 27500.00 37960.00 31,723.41
Jun-11 197154.96 67489.46 257644.42 37000.00 27880.00 317524.42
Jul-11 177625.00 27691.82 207316.82 17500.00 17710.00 237526.82
Aug-11 587432.00 57282.78 637714.78 37000.00 37330.00 707044.78
Sep-11 207700.00 47253.46 247953.46 27000.00 27340.00 297293.46
31s 373,670.56 62,487.09 436,157.65 47,208.00 28,070.00 511,435.65
Oct-09 27605.25 27197.76 47803.01 0.00 17950.00 67753.01
Nov-09 247337.98 27518.11 267856.09 0.00 17620.00 287476.09
Dec-09 177897.58 27459.761 207357.34 0.00 27320.00 227677.34
Jan-10 247351.33 17929.511 267280.84 0.00 17800.00 287080.84
Feb-10 1.191.33 1.368.20 2.559.53 0.00 1.260.00 3.819.53
Jan-09 1,000.00 667.86 1,667.86 0.00 2,770.00 4,437.86
Feb-09 31,413.26 1,493.71 32,906.97 0.00 2,070.00 34,976.97
Mar-09 21,275.00 1,082.51 22,357.51 0.00 2,770.00 25,127.51
Apr-09 7,996.37 531.28 8,527.65 0.00 27830.00 11,357.65
May-09 1017604.72 57039.96 1067644.68 0.00 27170.00 1087814.68
Jun-09 157682.82 47887.75 207570.57 0.00 17980.00 227550.57
Jul-09 257378.25 17999.07 277377.32 0.00 17710.00 297087.32
Aug-09 217447.00 37303.99 247750.99 0.00 17610.00 267360.99
Sep-09 127252.82 27744.00 147996.82 0.00 17440.00 167436.82
31s 257,093.11 24,888.85 281,981.96 0.00 27,000.00 308,981.96
Oct-07 77570.00 725.00 87295.00 0.00 50.00 87345.00
Nov-07 67500.50 500.00 77000.50 0.00 17350.00 87350.50
Dec-07 17660.35 618.50 27278.85 0.00 17980.00 47258.85
Jan-08 17657.00 100.00 17757.00 0.00 27610.00 47367.00
Feb-08 97000.00 300.00 97300.00 0.00 27250.00 117550.00
Mar-08 337105.50 400.00 337505.50 0.00 27880.00 367385.50
Apr-08 37118.50 738.53 37857.03 0.00 37510.00 77367.03
May-08 87425.00 526.04 87951.04 0.00 37140.00 127091.04
Jun-08 147100.00 170.71 147270.71 0.00 37960.00 187230.71
Jul-08 17350.00 135.02 17485.02 0.00 27230.00 37715.02
Aug-08 87000.00 600.00 87600.00 0.00 27980.00 117580.00
Sep-08 67212.50 200.83 67413.33 0.00 27250.00 87663.33
31s 100,699.35 5,014.63 105,713.98 0.00 29,190.00 134,903.98
Oct-06 0.00 0.00 0.00 0.00 0.00 0.00
Nov-06 0.00 0.00 0.00 0.00 0.00 0.00
Dec-06 0.00 0.00 0.00 0.00 0.00 0.00
Jan-07 107918.00 17500.00 127418.00 0.00 0.00 127418.00
Feb-07 17500.00 17823.55 37323.55 0.00 0.00 37323.55
Mar-07 27150.00 17001.95 37151.95 0.00 0.00 37151.95
Apr-07 47017.70 902.70 47920.40 0.00 0.00 47920.40
May-07 217060.00 900.00 217960.00 0.00 0.00 217960.00
Jun-07 17250.00 37585.00 47835.00 0.00 0.00 47835.00
Jul-07 87399.98 17207.50 97607.48 0.00 0.00 97607.48
Aug-07 77640.00 17600.00 97240.00 0.00 0.00 97240.00
Sep-07 127157.00 17000.001 137157.00 0.001 0.00 137157.00
69,092.68 13,520.701 82,613.38 0.001 0.00 82,613.38