Item O03BOARD OF COUNTY COMMISSIONERS
AGENDA ITEM SUMMARY
Meeting Date: 10/17/2007 - KW Division: County Attorney
Bulk Item: Yes No xx Staff Contact Person: Bob ShillinRcr
AGENDA ITEM WORDING:
Approval of payment of $30,318.70 to Ferencik, Libanoff, Brandt, Bustamante & Williams, P.A. for
legal services provided on behalf of Monroe County in the matter of Monroe County v. Lodge
Construction. Case No. CA K-00-617.
ITEM BACKGROUND: In 1999, the County retained the services of Ira Libanoff to represent it in
its claim against Lodge Construction after Lodge abandoned its contract to renovate the Gato Building.
In August, Libanoff, along with in-house staff, negotiated a settlement in the Lodge case on the eve of
trial. This should be the last significant invoice for this case since the matter has now settled.
PREVIOUS RELEVANT BOCC ACTION: 1999, Board approved letter of engagement.
3/15/2006 BOCC approved an updated Agreement for Legal Services
3/21/2007 BOCC approved First Amendment to Agreement for Legal Services
CONTRACT/AGREEMENT CHANGES: N/A
STAFF RECOMMENDATIONS: Approval.
TOTAL COST: $30,318.70 BUDGETED: Yes xx No
COST TO COUNTY: $30,318.70 SOURCE OF FUNDS:
REVENUE PRODUCING: Yes No xx AMOUNT PER MONTH Year
APPROVED BY: County Atty X OMB/Purchasing Risk Management
DOCUMENTATION: Included Not Required X
DISPOSITION: AGENDA ITEM #
Revised 2/05
rC11GIY%-.If\ LID/'1lvvrr DRMI'4U I DU.71IAIVI/HIV I C Ck VVILLIAIVIJ, F.A.
Attorneys at Law
Federal Tax I.D. #65-0193780 RECEIVED
150 South Pine Island Road SEP ZOQl
Suite #400
Fort Lauderdale, Florida 33324 MONROE COUNTY ATTORNEY
Dade (305) 949-8003
Broward (954) 474-8080
Page: 1
MONROE COUNTY 09/12/2007
C/O COUNTYATTORNEY'S OFFICE MATTER NO: 864-0002M
PO BOX 1026 STATEMENT NO: 86
KEY WEST FL 33041-1026
ATTN: ROBERT SHILLINGER, ESQ.
LODGE CONSTRUCTION
PREVIOUS BALANCE $9,217.94
HOURS
08/01 /2007
LP DRAFT AND PREPARE (DRAFT) MONROE COUNTY'S
RESPONSE TO LODGE'S MOTION IN LIMINE RE DELAY
DAMAGES; AND MEMO TO JR RE LAW OF THE CASE
DOCTRINE APPLIES TO ISSUES ACTUALLY BROUGHT AND
DECIDED ON APPEAL, EITHER EXPRESSLY OR IMPLIEDLY;
AND REVIEW PRIOR TRIAL PLEADINGS RE DELAY DAMAGES
ISSUE; AND REVIEW TRIAL TRANSCRIPT RE COUNSEL'S
ARGUING PRIOR MOTION IN LIMINE; AND REVIEW APPEAL
COURT'S HOLDING; AND CONFERENCE WITH DW RE
PLEADINGS INDEX 3.50 577.50
08/02/2007
JER
TELEPHONE CONFERENCE WITH JUDGE AUDLINE'S
JUDICIAL ASSISTANT RE: DENIAL OF MOTION TO CONTINUE
& HEARING ON PENDING MOTIONS
0.20 45.00
JER
TELEPHONE CONFERENCE WITH COURT REPORTER
REGARDING ATTENDANCE AT HEARING ON 8/13/07 AND
TRIAL
0.20 45.00
JER
TELEPHONE CONFERENCES (X3) WITH NEIL ROBERTSON,
ESQ., COUNSEL FOR BENDER & ASSOCIATES RE: DENIAL
OF MOTION TO CONTINUE; PRETRIAL REQUIREMENTS,
MEDIATION &CHANGE IN PRETRIAL CONFERENCE
0.60 135.00
JER
REVIEW FILE RE: PRETRIAL REQUIREMENTS; DRAFT AND
PREPARE LETTER TO ALL COUNSEL RE: DENIAL OF MOTION
TO CONTINUE; PRETRIAL REQUIREMENTS & CHANGE IN
SCHEDULE OF PRETRIAL CONFERENCE '
0.40 90.00
LJG
CONFERENCES WITH JANET RITENBAUGH REGARDING
MOTION TO CONTINUE TRIAL WAS DENIED AND UPCOMING
TRIAL PREPARATIONS.
0.30 25.50
08/03/2007
LP FACTS INVESTIGATION: REVIEW PLEADINGS FOR
ARGUMENTS RELATING TO DELAY DAMAGES; AND REVIEW
APPELLANT'S BRIEF RE DELAY DAMAGES; AND PREPARE
DOCS FOR JR RE LAW OF CASE AND DELAY DAMAGES; AND
CONFERENCE WITH JR RE SAME 1.30 214.50
-yJ-
MONROE COUNTY 09/12/2007
MATTER NO: 864-0002M
STATEMENT NO: 86
LODGE CONSTRUCTION
HOURS
JER
TELEPHONE CONFERENCE WITH MIKE PISCATELLI, ESQ.,
RE: MEDIATION AND PRETRIAL CONFERENCE
'0.20
45.00
JER
TELEPHONE CONFERENCE WITH JOE MASULO REGARDING
PREPARATION FOR TRIAL
0.20
45.00
JER
REVIEW FILE RE: MOTIONS TO BE HEARD ON 8/13/07; DRAFT
AND PREPARE LETTER TO ALL COUNSEL RE: AMENDED
NOTICE OF HEARING
0.40
90.00
LJG
CONFERENCE WITH JANET RITENBAUGH REGARDING TRIAL
PREPARATIONS AND MEDIATION PREPARATIONS.
0.20
17.00
LJG
(L140) - DOCUMENT / FILE MANAGEMENT - COMPILE
PROJECT DOCUMENTS AS REQUESTED BY JANET
RITENBAUGH TO BE USED IN PREPARING FOR UPCOMING
MEDIATION.
0.40
34.00
LJG
(L140) - DOCUMENT / FILE MANAGEMENT - ORGANIZATION
OF PROJECT DOCUMENTS FOR JANET RITENBAUGH'S
REVIEW AND USE IN PREPARING FOR TRIAL.
0.50
42.50
08/06/2007
JER
TELEPHONE CONFERENCE WITH PAUL WOODSON, ESQ.,
RE: MEETING OF COUNSEL; PREPARE E-MAIL TO ALL
COUNSEL RE: SAME
0.30
67.50
JER
RECEIPT/REVIEW ORDER FROM COURT DENYING MOTION
TO CONTINUE & ORDER RE: CHANGE IN PRETRIAL
CONFERENCE SCHEDULE
0.10
22.50
JER
TELEPHONE CONFERENCE WITH CHERYL INGRAHAM RE:
COORDINATION FOR MEDIATION & INFORMATION RE: TRIAL
0.30
67.50
08/07/2007
ILL
CONFERENCE WITH JANET TO REVIEW PRETRIAL ORDER
REQUIREMENTS AND REVIEW INFORMATION FROM FIRST
TRIAL IN ORDER TO BEGIN TRIAL PREPARATION AND TO
PREPARE FOR PHONE CONFERENCE WITH ALL COUNSEL
RE PRETRIAL STIPULATION; T/C/W/ALL COUNSEL RE
REQUIREMENTS OF PRETRIAL STIP AND COMPLIANCE
2.00 500.00
JER
REVIEW PORTION OF TRIAL TRANSCRIPTS REGARDING
PREPARING ESTIMATE OF TIME FOR WITNESSES, OPENING,
CLOSING ETC., PREPARE FOR CONFERENCE CALL WITH
ALL COUNSEL IN ACCORDANCE WITH REQUIREMENTS OF
TRIAL ORDER; CONFERENCE CALL WITH ALL COUNSEL;
CONFERENCE WITH IRA LIBANOFF, ESQ., RE: TRIAL
PREPARATION
3.50 787.50
LJG
CONFERENCE WITH JANET RITENBAUGH REGARDING
BROWER AND ROEPNAK DEPOSITIONS:
0.10 8.50
LJG
(L140) - DOCUMENT / FILE MANAGEMENT- COMPILE
ROEPNAK DEPOSITION EXHIBITS FOR JANET
RITENBAUGH'S REVIEW.
0.10 8.50
T-3191:914116 rl
ILL TELEPHONE CONFERENCE WITH BOB SHILLINGER RE TRIAL
PREPARATION, MEDIATION, PRETRIAL CONFERENCE AND
RELATED ISSUES 0.30 75.00
ILL CONFERENCE WITH BARRY BROWER AND JANET RE TRIAL
PREPARATION; CONFERENCE WITH JANET RE
PREPARATION FOR MOTION IN LIMINE AND OTHER ISSUES
RE TRIAL PREPARATION 2.50 625.00
Page: 3
MONROE COUNTY 09/12/2007
MATTER NO: 864-0002M
STATEMENT NO: 86
LODGE CONSTRUCTION
HOURS
JER
CONFERENCE WITH IRA LIBANOFF, ESQ. & BARRY BROWER
RE: TRIAL PREPARATION & EXPERT WITNESS
PREPARATION
2.50 562.50
JER
COMMENCE REVIEW STEVE PIAZZA'S TRIAL TESTIMONY
0.80 180.00
LJG
CONFERENCE WITH JANET RITENBAUGH AND BARRY
BROWER REGARDING TRIAL PREPARATIONS.
0.20 17.00
LJG
(1_140) - DOCUMENT / FILE MANAGEMENT - COMPILE
PROJECT DOCUMENTS AND TRIAL EXHIBITS FOR MEETING
WITH IRA LIBANOFF, JANET RITENBAUGH AND BARRY
BROWER; ASSIST DURING MEETING WITH DOCUMENTS.
1.00 85.00
08/09/2007
ILL
RECEIPT/REVIEW CROSS -NOTICE OF HEARING AND
SURETY'S MOTION TO HAVE REPRESENTATIVE EXCUSED
FROM ATTENDANCE AT PRETRIAL CONFERENCE
0.20 50.00
LP
RESEARCH CASE LAW RE WHAT CIRCUMSTANCES MOTION
IN LIMINE IS APPROPRIATE; AND WHETHER CAN BRING
MOTION IN LIMINE TO LIMIT EVIDENCE MODIFYING
CONTRACT TERMS; AND CONFERENCE WITH IL AND JR RE
MOTION IN LIMINE AND PAROL EVIDENCE
2.80 462.00
ILL
TRIAL/HEARING PREPARATION; PREPARATION FOR
HEARING ON MOTIONS IN LIMINE; PREPARATION FOR
MEDIATION; PREPARATION FOR TRIAL
3.00 750.00
LJG
(A101) - PLAN AND PREPARE FOR TRIAL; COMPILE WORK
PRODUCT TRIAL EXHIBITS FOR JANET RITENBAUGH AND
IRA LIBANOFF'S USE IN PREPARING FOR TRIAL; ADD
ADDITIONAL DOCUMENTS TO WORK PRODUCT BINDERS;
CHECK FOR COMPLETENESS OF TRIAL DOCUMENTS;
CONFERENCES WITH JANET RITENBAUGH AND IRA
LIBANOFF; COMPILED PROJECT MEETING MINUTES AND
LODGE CORRESPONDENCE TO PREPARE FOR MOTIONS IN
LIMINE HEARING NEXT WEEK. ALSO REVIEWED BENDER &
ASSOCIATES CORRESPONDENCE/DOCUMENTS IN
PREPARATION FOR MOTIONS IN LIMINE HEARING.
6.00 510.00
SDK
RESEARCH ON USE OF DEPOSITION IF UNAVAILABLE OR
UNABLE TO SUBPOENA WITNESS
0.30 60.00
JER
REVIEW APPELLATE BRIEFS, PLEADINGS & CONTRACT
DOCUMENTS AND DRAFT AND PREPARE CONFIDENTIAL
MEMORANDA PERTAINING TO ISSUES RELATING TO
LODGE'S FAILURE TO COMPLY WITH TERMS AND
CONDITIONS OF THE CONTRACT
3.50 787.50
08/10/2007
LP
RESEARCH CASE LAW RE APPLICATION AND DEFINITION OF
PAROL EVIDENCE RULE; AND CANNOT ADMIT EVIDENCE TO
CONTRADICT OR VARY THE TERMS OF A CONTRACT
1.90 313.50
LP
CONFERENCE WITH LAURA GERWENS AND DW RE
OBTAINING DEPO TRANSCRIPT OF MICHAE.L DUNN/RECORD
ON APPEAL; AND PLEADINGS
0.20 33.00
LP
RESEARCH: REVIEW PRIOR MSJ(S) RE ARGUMENT RE
LODGE MUST CONTINUE WORKING; AND PREPARE CASES
CITED IN MSJ PER PARTNER REQUEST
0.30 49.50
LP
FACTS INVESTIGATION: REVIEW DEPO TRANSCRIPT,
EXHIBITS FOR ALLEGED NON CONSTRUCTABILITY ISSUE
0.40 66.00
ILL
TELEPHONE CONFERENCE WITH STEVE PIAZZA RE STATUS
I -age: 4
MONROE COUNTY 09/12/2007
MATTER NO: 864-0002M
STATEMENT NO: 86
LODGE CONSTRUCTION
OF CASE AND TESTIMONY NEEDED AT TRIAL
LJG
CONFERENCE WITH LAURA PAPAY REGARDING DUNN
TRANSCRIPT AND PORTIONS FROM APPELLATE RECORD.
LJG
(1-140) - DOCUMENT / FILE MANAGEMENT - REVIEW MIKE
DUNN'S DEPOSITION TRANSCRIPTS FOR PERTINENT
INFORMATION REQUESTED BY LAURA PAPAY TO PREPARE
FOR MOTIONS IN LIMINE HEARING; COMPILE AND COPY
SPECIFIC PAGES OF TESTIMONY AND ALSO THE COMPLETE
DEPOSITION TRANSCRIPT FOR LAURA PAPAY'S REVIEW
AND USE; REVIEW BENDER & ASSOCIATES
CORRESPONDENCE TO IDENTIFY AND SELECT PERTINENT
DOCUMENTS TO BE USED IN PREPARING FOR MOTIONS IN
LIMINE HEARING.
LJG
TELEPHONE CONFERENCE WITH JANET RITENBAUGH
REGARDING DOCUMENTS FOR IRA LIBANOFF'S REVIEW
AND USE IN PREPARING FOR UPCOMING MOTIONS IN
LIMINE HEARING.
LJG
CONFERENCE WITH IRA LIBANOFF REGARDING
DOCUMENTS NEEDED IN PREPARATIONS FOR UPCOMING
HEARING.
LJG
(1-140) - DOCUMENT / FILE MANAGEMENT - SCAN MIKE DUNN
DEPOSITION TRANSCRIPT PAGES AND SEND TO JANET
RITENBAUGH VIA E-MAIL FOR HER REVIEW AND USE.
JER
REVIEW ALL PLEADINGS & COMMENCE DRAFT OF JOINT
PRETRIAL STIPULATION
08/11 /2007
JER
COMPLETE DRAFT OF JOINT PRETRIAL STIPULATION FOR
DISTRIBUTION TO ALL COUNSEL
08/12/2007
LP RESEARCH CASE LAW RE WHAT CONSTITUTES MATERIAL
BREACH SUCH THAT CONTRACTOR MAY TERMINATE
PERFORMANCE; AND SPECIFIC CONDITIONS OF
CONSTRUCTION CONTRACT GOVERN GENERAL
CONDITIONS
LP TELEPHONE CONFERENCE WITH ILL RE RESEARCH
ASSIGNMENT RE MATERIAL BREACH AND SPECIFIC
CONDITIONS GOVERN GENERAL
08/13/2007
LP RESEARCH (CONTINUE) CASE LAW RE WHAT CONSTITUTES
MATERIAL BREACH SUCH THAT CONTRACTOR MAY
TERMINATE PERFORMANCE; AND LAW OF THE CASE
DOCTRINE APPLIES TO ISSUES DECIDED ON APPEAL; AND
PREPARE DOCS FOR PARTNER'S HEARING ON MOTIONS IN
LIMINE
LP CONFERENCE WITH JR RE RESEARCH ASSIGNMENTS FROM
IL AND JR IN PREPARATION FOR HEARING ON MOTIONS IN
LIMINE AND TRIAL
ILL COURT/AGENCY APPEARANCE FOR HEARING ON PRETRIAL
MOTIONS
LJG TELEPHONE CONFERENCE WITH JANET RITENBAUGH
REGARDING TRIAL EXHIBITS.
LJG TELEPHONE CONFERENCE WITH IRA LIBANOFF
HOURS
0.40
0.20
100.00
17.00
2.00 170.00
0.20 17.00
0.10
8.50
0.20
17.00
2.50
562.50
3.00 675.00
6.00 990.00
0.10 16.50
1.70
280.50
0.20
33.00
9.00
2,250.00
0.10 8.50
rayG. a
MONROE COUNTY 09/12/2007
MATTER NO: 864-0002M
STATEMENT NO: 86
LODGE CONSTRUCTION
HOURS
REGARDING CONTACTING JOE MASULLO.
0.10
8.50
LJG
TELEPHONE CONFERENCE WITH JOE MASULLO (LEFT
VOICE MAIL) REGARDING AVAILABILITY FOR UPCOMING
TRIAL.
0.10
8.50
LJG
(A103) - DRAFT / REVISE EXHIBIT LIST FOR TRIAL AS
REQUESTED BY JANET RITENBAUGH.
1.50
127.50
SDK
RESEARCH ON WHETHER 100 MILE RULE IS APPLICABLE IN
STATE COURT
0.70
140.00
JER
COMMENCE REVIEW OF ALL DEPOSITION TRANSCRIPTS &
TRIAL TRANSCRIPTS IN PREPARATION FOR TRIAL &
PREPARATION OF SUMMARY OF WITNESS TESTIMONY
REQUIRED TO BE SUBMITTED WITH PRETRIAL STIPULATION
4.50
1,012.50
08/14/2007
LP
RESEARCH CASE LAW AND CONSTRUCTION MANUAL RE
WHAT CONSTITUTES MATERIAL BREACH SUCH THAT
CONTRACTOR MAY TERMINATE/WALK OF JOB PER
RESEARCH ASSIGNMENT FROM IL; AND RESEARCH CASE
LAW RE WHETHER MAY RECOVER DELAY DAMAGES
AGAINST SURETY UNDER PERFORMANCE BOND; AND
WHETHER CAN RECOVER ATTORNEY'S FEES WHERE
ALLEGE THAT INDEBTED TO FIRM AND IN WHEREFORE
CLAUSE, BUT DO NOT ALLEGE ENTITLEMENT BY SPECIFIC
CONTRACT OR STATUTE PER RESEARCH ASSIGNMENT
FROM JR; AND PREPARE MEMO RE NEED NOT
SPECIFICALLY PLEAD ENTITLEMENT TO FEES
7.50 1,237.50
ILL
TRIAL/HEARING PREPARATION - PREPARE FOR
PRESENTATION TO COMMISSION RE STATUS AND RE
MEDIATION; PREPARE FOR MEDIATION CONFERENCE;
REVIEW PORTIONS OF PRETRIAL STIPULATION
1.50 375.00
LJG
RECEIPT/REVIEW E-MAIL FROM BARRY BROWER.
0.10 8.50
LJG
(1-140) - DOCUMENT / FILE MANAGEMENT - COMPILE
DOCUMENTS REQUESTED BY BARRY BROWER FOR USE IN
PREPARING AND RELYING ON AT TRIAL; CREATE WITNESS
FOLDER FOR TRIAL.
0.75 63.75
LJG
CONFERENCE WITH JANET RITENBAUGH REGARDING
DOCUMENTS FOR BARRY BROWER.
0.10 8.50
LJG
CONFERENCE WITH JANET RITENBAUGH REGARDING
CONTACTING MASULLO AND OBTAINING DOCUMENTS HE
WILL BE RELYING ON AT TRIAL.
0.20 17.00
LJG
TELEPHONE CONFERENCE WITH JANET RITENBAUGH AND
JOE MASULLO REGARDING DOCUMENTS HE WILL BE
RELYING UPON FOR TRIAL TESTIMONY.
0.20 17.00
LJG
DRAFT AND PREPARE PROPOSED STIPULATED EXHIBITS
CHART AS REQUESTED BY JANET RITENBAUGH; INCLUDES
REVISIONS TO CHART.
0.75 63.75
LJG
TELEPHONE CONFERENCE WITH PAULA AT WOODSON'S
OFFICE REGARDING RECEIPT OF E-MAILS.
0.10 8.50
LJG
TELEPHONE CONFERENCE WITH MARILU COFFMAN AT
WOODSON'S OFFICE REGARDING OBTAINING A COPY OF
THEIR EXHIBIT LIST.
0.10 8.50
LJG
DRAFT AND PREPARE CHART OF ANTICIPATED TRIAL TIME
AS REQUESTED BY JANET RITENBAUGH.
0.50 42.50
LJG
RECEIPT/REVIEW LODGE'S TRIAL EXHIBIT LIST; COMPILE /
PRINT COPY FOR JANET RITENBAUGH'S REVIEW.
0.20 17.00
Page: 6
MONROE COUNTY 09/12/2007
MATTER NO: 864-0002M
STATEMENT NO: 86
LODGE CONSTRUCTION
HOURS
LJG
TELEPHONE CONFERENCE WITH MARILU COFFMAN AT
WOODSON'S OFFICE REGARDING SCHEDULING TIME FOR
ME TO REVIEW THEIR TRIAL EXHIBITS.
0.10 8.50
LJG
MULTIPLE CONFERENCES WITH JANET RITENBAUGH AND
IRA LIBANOFF REGARDING LODGE'S TRIAL EXHIBITS AND
OBTAINING COPIES OF THEM; ALSO DISCUSSED WOODSON
WANTING TO REVIEW OUR TRIAL EXHIBITS PRIOR TO
MEDIATION.
0.40 34.00
LJG
RECEIPT/REVIEW E-MAIL FROM MARILU COFFMAN AT
WOODSON'S OFFICE REGARDING SCHEDULING TIME FOR
WOODSON TO REVIEW OUR TRIAL EXHIBITS.
0.10 8.50
LJG
DRAFT AND PREPARE LETTER TO PAUL WOODSON FOR
IRA'S SIGNATURE REGARDING WOODSON TO REVIEW OUR
TRIAL EXHIBITS CONDITIONAL UPON US REVIEWING
THEIRS.
0.30 25.50
LJG
(A101) - PLAN AND PREPARE FOR MEDIATION; COMPILE
ADDITIONAL COPIES OF DOCUMENTS REQUESTED BY
JANET RITENBAUGH FOR MEDIATION PREPARATIONS;
COMPILE ADDITIONAL COPIES OF ALL PARTIES TRIAL
EXHIBIT LISTS.
1.00 85.00
LJG
TELEPHONE CONFERENCE WITH ARI SWEETBAUM AT NEIL
ROBERTSON'S OFFICE REGARDING FRED SALINERO'S
DEPOSITION TRANSCRIPT.
0.10 8.50
LJG
(1-140) - DOCUMENT / FILE MANAGEMENT - REVIEW
PROJECT PLANS/ DRAWINGS WITH JANET RITENBAUGH;
DETERMINE DIFFERENT SETS OF DRAWINGS.
0.50 42.50
JER
CONTINUE REVIEW OF DEPOSITION TRANSCRIPTS IN
PREPARATION FOR WITNESS SUMMARY & TRIAL
PREPARATION
5.00 1,125.00
JER
REVIEW OF LODGE'S EXHIBIT LIST; CONFERENCE WITH
LAURA GERWENS REGARDING ARRANGEMENTS FOR
REVIEWING LODGE'S TRIAL EXHIBITS
0.40 90.00
JER
PREPARE LETTER TO DAVID KIRWAN, ESQ. AND ATTACHED
DOCUMENTS FOR DAVID KIRWAN'S REVIEW IN
PREPARATION FOR MEDIATION
0.70 157.50
08/15/2007
LP FACTS INVESTIGATION: REVIEW TIMELINE AND DAMAGES
REPORT; AND CALCULATE INTEREST ON COMPENSATORY
DAMAGES AND INTEREST ON DELAY DAMAGES SINCE THE
DATE OF BREACH UNTIL MEDIATION DATE, AND END TRIAL
DATE; AND EMAIL TO IL, JW RE SAME; AND PREPARE MEMO
CONTAINING CALCULATION OF ABOVE DAMAGES FOR
PURPOSES OF MEDIATION AND TRIAL 3.30 544.50
LP RESEARCH WHETHER CAN RECOVER DELAY DAMAGES
AGAINST SURETY UNDER THE LANGUAGE OF THE
PERFORMANCE BOND 2.00 330.00
LP DRAFT AND PREPARE MEMO TO IL AND JR RE SURETY MAY
BE LIABLE TO OWNER FOR DELAY DAMAGES WHERE BOND
INCORPORATES BY REFERENCE THE CONTRACT
PROVIDING FOR DELAY DAMAGES, AND DEPENDING ON
CONTRACT'S LANGUAGE; AND FURTHER REVIEW CASES
RELIED ON IN MEMO 1.30 214.50
LP CONFERENCE WITH IL RE RESEARCH ASSIGNMENT RE
WHETHER PUBLIC ENTITY MAY INCLUDE IN ITS CONTRACT
Page: 7
MONROE COUNTY
09/12/2007
MATTER NO: 864-0002M
STATEMENT NO: 86
LODGE CONSTRUCTION
HOURS
A WAIVER OF JURY TRIAL PROVISION; AND WHETHER
CONSTITUTIONAL
0.10 16.50
ILL
COURT/AGENCY APPEARANCE FOR BOCC CLOSED
MEETING TO DISCUSS CASE WITH COMMISSION RE
UPCOMING MEDIATION AND TRIAL
4.50 1,125.00
ILL
TRIAL/HEARING PREPARATION - REVIEW ADDITIONAL
PORTIONS OF DRAFT OF PRETRIAL STIPULATION,
COMMENTS FROM ATTY WOODSON AND JANET'S
PREPARATION OF WITNESS TESTIMONY SUMMARY;
CONFERENCE WITH JANET RE PRETRIAL STIP ISSUES
1.50 375.00
LJG
(1-140) - DOCUMENT / FILE MANAGEMENT - COMPILE
DEPOSITION TRANSCRIPT OF FRED SALINERO AND SCAN
INTO SYSTEM; FORWARD VIA E-MAIL TO NEIL
ROBERTSON'S OFFICE.
0.30 25.50
LJG
(1-140) - DOCUMENT / FILE MANAGEMENT - COMPILE COPY
OF PERFORMANCE BOND FOR LAURA PAPAY'S REVIEW
AND USE.
0.20 17.00
LJG
RECEIPT/REVIEW PROJECT DOCUMENTS FROM ZIGGY
CZARNIECKI.
0.10 8.50
LJG
TELEPHONE CONFERENCE WITH ALTERNATIVE LEGAL
REGARDING DUPLICATING ZIGGY'S FILE.
0.10 8.50
LJG
(1-140) - DOCUMENT / FILE MANAGEMENT - MOVE BOXES OF
TRIAL EXHIBITS TO CONFERENCE ROOM FOR DOCUMENT
REVIEW BY PAUL WOODSON, ESQ.
0.40 34.00
LJG
(A109) - APPEAR FOR / ATTEND / OVERSEE PAUL WOODSON
REVIEWING OUR TRIAL EXHIBITS.
2.00 170.00
LJG
CONFERENCE WITH IKON REPRESENTATIVE REGARDING
REPRODUCTION OF OUR TRIAL EXHIBITS TO PAUL
WOODSON'S OFFICE.
0.10 8.50
JER
TELEPHONE CONFERENCE WITH PAUL WOODSON, ESQ.,
RE: REQUESTED CHANGES TO PRETRIAL STIPULATION.
0.70 157.50
JER
PREPARE REVISIONS TO PRETRIAL STIPULATION
INCORPORATING CHANGES REQUESTED BY PAUL
WOODSON; E-MAILS IRA LIBANOFF & NEIL ROBERTSON RE:
SAME; RECEIVE E-MAIL FROM NEIL ROBERTSON WITH
ADDITIONAL CHANGES TO PRETRIAL STIPULATION;
INCORPORATE CHANGES; TELEPHONE CONFERENCE WITH
IRA LIBANOFF, ESQ. RE: CHANGES REQUESTED BY PAUL
WOODSON; FINALIZE PRETRIAL STIPULATION.
2.00 450.00
JER
PREPARE SUMMARY OF WITNESS TESTIMONY FOR
SUBMISSION TO COURT IN ACCORDANCE WITH PRETRIAL
ORDER; PREPARE OUTLINE OF ESTIMATE OF TESTIMONY
TIME TO BE ATTACHED TO PRETRIAL STIPULATION;
MULTIPLE TELEPHONE CALLS FROM NEIL ROBERTSON
4.50 1,012.50
JER
RECEIPT/REVIEW E-MAIL FROM NEIL ROBERTSON RE:
AUTHORITY FROM BENDER'S CARRIER; PREPARE E-MAIL
RESPONSE TO SAME
0.20 45.00
08/16/2007
LP RESEARCH FRCP 1.390, 1.330, 1.028 AND CASE LAW RE
WHETHER REDESINGATION OF EXPERT AS NONTESTIFYING
EXPERT PRECLUDES ADMISSION OF THAT EXPERT'S
DEPOSITION TESTIMONY BY THE OPPOSING PARTY AT
TRIAL PER ASSIGNMENT FROM JR; AND TELEPHONE
CONFERENCE WITH JR RE ASSIGNMENT 5.50 907.50
Page: 8
MONROE COUNTY 09/12/2007
MATTER NO: 864-0002M
STATEMENT NO: 86
LODGE CONSTRUCTION
HOURS
ILL
MEDIATION CONFERENCE IN KEY WEST
10.00 2,500.00
LJG
TELEPHONE CONFERENCE WITH JANET RITENBAUGH
REGARDING LODGE'S SUBCONTRACTORS AND CASE
ASSIGNMENT.
0.20 17.00
LJG
(1_140) - DOCUMENT / FILE MANAGEMENT - REVIEW
PROJECT DOCUMENTS TO IDENTIFY LODGE'S
SUBCONTRACTORS WHO WORKED ON THE PROJECT AS
REQUESTED BY JANET RITENBAUGH.
0.50 42.50
LJG
TELEPHONE CONFERENCE WITH JOE MASULLO
REGARDING DOCUMENTS HE WILL BE RELYING ON AT
TRIAL.
0.20 17.00
LJG
DRAFT AND PREPARE MEMORANDUM FOR JANET
RITENBAUGH CONCERNING MY TELEPHONE CONFERENCE
WITH JOE MASULLO AND DOCUMENTS HE WILL RELY ON AT
TRIAL.
0.30 25.50
LJG
TELEPHONE CONFERENCE WITH MARILU COFFMAN AT
WOODSONS' OFFICE REGARDING SCHEDULING TIME FOR
ME TO REVIEW LODGE'S TRIAL EXHIBITS.
0.10 8.50
JER
MEDIATION CONFERENCE IN KEY WEST
10.00 2,250.00
08/17/2007
LP
RESEARCH ISSUE OF REDESIGNATION OF EXPERT TO
NONTESTIFYING EXPERT PRECLUDES OPPOSING PARTY
FROM USING EXPERT'S DEPO TRANSCRIPT AT TRIAL
1.20 198.00
LP
TELEPHONE CONFERENCE WITH JR RE CASE STATUS,
MEDIATION, RESULTS OF RESEARCH ON REDESIGNATION
OF EXPERT
0.10 16.50
ILL
TRAVEL BACK FROM MEDIATION CONFERENCE IN KEY
WEST
3.00 750.00
JER
RETURN TRAVEL FROM KEY WEST AFTER MEDIATION
2.50 562.50
FOR CURRENT SERVICES RENDERED
150.80 29,226.50
SUMMARY OF PROFESSIONAL TIME
TIMEKEEPER HOURS HOURLY RATE TOTAL
IRA L. LIBANOFF 37.90
$250.00 $9,475.00
JANET E.
RITTENBAUGH 49.20
225.00 11,070.00
SANDRA D. KENNEDY 1.00
200.00 200.00
LAURA PAPAY 39.40
165.00 6,501.00
LAURA J.
GERWENS 23.30
85.00 1,980.50
07/31/2007
(El 05)-TELEPHONE
4.02
08/03/2007
(E107) - FEDERAL EXPRESS TO DANNY L. KOLHAGE
13.88
08/03/2007
(E107) - FEDERAL EXPRESS TO KATHY RUPP, J.A.
13.88
08/08/2007
(E124) - CHECK PAYABLE TO ALTERNATIVE LEGAL FOR
LITIGATION COPIES/VIDEO DUPLICATE
148.81
08/08/2007
(E124) - CHECK PAYABLE TO ALTERNATIVE LEGAL FOR
LITIGATION COPIES
31.55
08/09/2007
(E124) - CHECK PAYABLE TO ALTERNATIVE LEGAL FOR
LITIGATION COPIES
145.56
08/14/2007
(E124) - CHECK PAYABLE TO ALTERNATIVE LEGAL FOR
LITIGATION COPIES
139.67
MONROE COUNTY
MATTER NO:
STATEMENT NO:
rage: a
09/12/2007
864-0002M
86
LODGE CONSTRUCTION
08/14/2007 (E124) - CHECK PAYABLE TO MARTY LESHAW FOR COURT
REPORTER SERVICES
08/15/2007 (E124) - CHECK PAYABLE TO ALTERNATIVE LEGAL FOR
NORMAL/OVERSIZE COPYING
08/16/2007 (E109; E110) - TRAVEL EXPENSE - JER
08/31/2007 (E108) - POSTAGE
TOTALEXPENSES
TOTAL CURRENT WORK
08/20/2007
THANK YOU FOR YOUR PAYMENT - CK#520164
08/20/2007
THANK YOU FOR YOUR PAYMENT - CK#520164
09/04/2007
THANK YOU FOR YOUR PAYMENT - CK#520590
09/04/2007
THANK YOU FOR YOUR PAYMENT - CK#520590
TOTALPAYMENTS
BALANCE DUE
Please call the attorney responsible for your case should
have any questions concerning this statement.
*STATEMENT REFLECTS ACTIVITY THROUGH THE END OF PRIOR MONTH*
**PLEASE INCLUDE A COPY OF SUMMARY PAGE WITH YOUR PAYMENT*
:M
76.19
429.80
R Rd
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30,318.70
-373.24
-5,203.50
-3,014.50
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• ruel surcnarge - redtx has applied a fuel surcharge of 13.50% to this shipment
• Distance Based Pricing, Zone 2
• FedEx has audited this shipment for correct packages, weight and service. Any changes made are reflected in the invoice amount
Automation
USAB
Tracking ID
858693096512
Service Type
FedEx Standard Overnight
Package Type
FedEx Box
Zone
02
Packages
1
Rated Weight
3.0 ibs,1.4 kgs
Delivered
Aug 03, 200714:13
Svc Area
Al
Signed by
B.GAYLEN
FedEx Use
021408301/0001283/_
• Fuel Surcharge - FedEx has applied a fuel surchar
• Distance Based
Pricing, Zone 2
Automation
INET
Tracking lb
791734949246
Service Type
FedEx Standard Overnight
Package Type
FedEx Envelope
Zone
02
Packages
1
Rated Weight
N/A
Delivered
Aug 06, 200711:37
Svc Area
AM
Signed by
C_MURPHY
FedEx Use
000000000/0000200/
• Fuel Surcharge - FedEx has applied a fuel surcharge
• Distance Based
Pricing, Zone 2
Automation
]NET
Tracking ID
798733940431.
Service Type
FedEx Standard Overnight
Package Type
FedEx Envelope
Zone
02
Packages
1
Rated Weight
N/A
Delivered
Aug 06, 200711.46
Svc Area
AM
Signed by
KRUPP
FedEx Use
000000000/0000200/
Sender
LAURA GERWENS
FERENCIK LIBANOFF ET AL
150 S PINE ISLAND RD STE 400
PLANTATION FL 33324-2667 US
Recipient
BRETT DIVERS ESQ
MILLS PASKERT DIVERS P A
100 N TAMPA ST 2010
TAMPA FL 33602 US
Transportation Charge 16.45
Discount -0 8Y
Fuel Surcharge 2.65
Courier Pickup Charge 4.00
Total Charge USD $22.28
Sender
Janet E. Ritenbaugh Esquire
Ferencik, Libanoff, Brandt
150 South Pine Island Road
PLANTATION FL 33324 US.
Transportation Charge
Discount
Automation Bonus Discount
Fuel Surcharge
otal Charge
to this shipment
Sender
Janet E. Ritenbaugh Esquire
Ferencik, Libanoff, Brandt
150 South Pine Island Road
PLANTATION FL 33324 US
Transportation Charge
Automation Bonus Discount
Discount
Delivery Area Surcharge -Commercial
Recipient
Danny L Kolhage L Kolhage
Clerk of the Circuit Court
Monroe County Courthouse
KEY WEST FL 33040 US
USD
Recipient
Ms. Kathy Rupp, Judicial Assis
to The Honorable David J. Audi
Courthouse Annex
KEY WEST FL 33040 US
Fuel Surcharge - FedEx has applied a fuel surcharge of 13.50% to this shipment
Distance Based Pricing, Zone 8
FedEx has audited this shipmentfor correct packages, weight and service. Any changes made are reflected in the invoice amount
12.45
-1.06
-0.62
1.65
1.40
12.45
-0.62
-1.00
1.40
1.65
Automation
INET
Sender
Recipient
Tracking ID
799687237017
Sandra D. Kennedy Esquire
David Bartz
Service Type
FedEx Standard Overnight
Ferencik, Libanoff, Brandt
Schwabe Williamson & Wyatt
Package Type
FedEx Box
150 South Pine Island Road
Pacwest Center,1211 SW 5 Ave.
Zone
08
PLANTATION FL 33324 US
PORTLAND OR 97204 US
Packages
1
Rated Weight
1.0lbs, 0.5 kgs
Transportation Charge
31.25
Delivered
Aug 06, 2007 09:13
Discount
-1.56
Svc Area
Al
Fuel Surcharge
3.80
Signed by
J.PULLSON
Automation Bonus Discount
-1.56
FedEx Use
000000000/0001415L
Total Charge
USD
$31.93
103120 5/8
c
ALTERNATIVE LEGAL
Litigation "duction SpeciaCuts
Please remit from this invoice.
Payment Due within
30 Days of Invoice Date
Invoice #:00073046
Invoice Date: 8/8/07
Remit to:
Alternative Legal Copy Service, Inc.
1007 N. Federal Hwy. #123
Ft. Lauderdale, Florida 33304
Phone: (954)523-1852 Fax: (954)523-5084
Tax ID: 65-1044746
INVOICE
Bill To:
Ferencik Libanoff
150 S. Pine Island Road #400
Plantation, FL 33324, USA
Quantity
Code
Description
Unit Cost
Amount
587
NC
Normal Copying
$ 0.1 2
$ 7 0.44
1
VD
Video Duplicating
$19.95
$1 9.95
2
CD
Compact Disc
$25.00
$50.00
Acceptance Signa re:
The work des ribed_ . e
This invoice is ue within
Ordered by: Laura
Your Client/File #: #864/0002
Your account representative is:
Paul Hansen
_ Date:
Lw-horized, received, accepted and is complete and correct.
days from the party billed above; see "Terms of Sale" below.
Subtotal
Sales Tax 6%
Total
Amount Applied
Balance
Thank you for the opportunity to be of service!
$140.39
$8.42
$148.81
$0.00
TERMS OF SALE: Any payment or portion thereof such as are not paid within 30 days are subject to a SERVICE FEE of 1.5% per month (18% annual). In the event of any default in the payment
of the sums due here under the purchaser shall be liable for all cost of collection incurred including court cost and reasonable attorneys fees, whether suit be instituted or not.
The purchaser acknowledges and agrees to all the forgoing and accepts delivery subject to all of the same.
ALTERNATIVE LEGAL
Litigation 2igpmduction Spedafrsts
Please remit from this invoice.
Payment Due within
30 Days of Invoice Date
Invoice #:00073047
Invoice Date: 8/8/07
Remit to:
Alternative Legal Copy Service, Inc.
1007 N. Federal Hwy. #123
Ft. Lauderdale, Florida 33304
Phone: (954)523-1852 Fax: (954)523.-5084
Tax ID: 65-1044746
INVOICE
Bill To:
Ferencik Libanoff
150 S. Pine Island Road #400
Plantation, FL 33324, USA
sms:�:��
Quantity Code Description Unit Cost Amount
248 NC
Acceptance Signature:
The work described
This invoice is dub -
Ordered by: Laura
Your Client/File #:#864/0002
Normal Copying
Your account representative is:
Paul Hansen
$0.12 $29.76
t Date:
as been/ all"t-horized, received, accepted and is complete and correct.
30 days from the party billed above; see "Terms of Sale" below.
Subtotal $29.76
Sales Tax 6% $1 .7 9
Total
Amount Applied
Balance
$31 .55
$31.55
Thank you for the opportunity to be of service!
TERMS OF SALE: Any payment or portion thereof such as are not paid within 30 days are subject to a SERVICE FEE of 1.5% per month (18% annual). In the event of any default in the payment
of the sums due here under the purchaser shall be liable for all cost of collection incurred including courtcostand reasonable attorneys fees, whether suit be institutedor not.
The purchaser acknowledges and agrees to all the forgoing and accepts delivery subject to all of the same.
ALTERNATIVE LEGAL
Litigation "duction Specrarists
Please remit from this invoice.
Payment Due within
30 Days of Invoice Date
Invoice #:00073067
Invoice Date: 8/9/07
Remit to:
Alternative Legal Copy Service, Inc.
1007 N. Federal Hwy. #123
Ft. Lauderdale, Florida 33304
Phone: (954)523-1852 Fax: (954)523-5084
Tax ID: 65-1044746
INVOICE
Bill To:
Ferencik Libanoff
150 S. Pine Island Road #400
Plantation, FL 33324, USA
Quantity
Code
Description
Unit Cost
Amount
636
NC
Normal Copying
$0.12
$76.32
26
O C
Oversize Copying - 11 X 17
$ 0.3 5
$ 9.1 0
34
CC
Color Copies 8.5x11
$1.00
$34.00
2
BI-2
3-Ring Binder 2"
$8.95
$17.90
Acceptance SignatLe- C��--_Date: �o2
The work descra has been authorized, received, accepted and is complete and correct.
This invoice is due within 30 days from the party billed above; see "Terms of Sale" below.
Ordered by: Laura
Your Client/File #: # 8 6 4 /0 0 0 2
Your account representative is:
Paul Hansen
Subtotal
Sales Tax 6%
Total
Amount Applied
Balance
Thank you for the opportunity to be of service!
$137.32
$8.24
$145.56
$0.00
$1.45.56
TERMS OF SALE: Any payment or portion thereof such as are not paid within 30 days are subject to a SERVICE FEE of 1.5% per month (18% annual). In the event of any default in the payment
of the sums due here under the purchaser shall be liable for all cost of collection incurred including court cost and reasonable attorneys fees, whether suit be instituted or not.
The purchaser acknowledges and agrees to all the forgoing and accepts delivery subject to all of the same.
ALTERNATIVE LEGAL
Litigation ft-dacd-Spede-ts
Please remit from this invoice.
Payment Due within
30 Days of Invoice Date
Invoice #:000731 27
Invoice Date: 8/1 4/07
Remit to
Alternative Legal Copy Service, Inc.
1007 N. Federal Hwy. #123
Ft. Lauderdale, Florida 33304
Phone: (954)523-1852
Tax ID: 65-1044746
INVOICE
Bill To:
Fax: (954)523-5084
Ferencik Libanoff
150 S. Pine Island Road #400
Plantation, FL 33324, USA
Quantity Code Description Unit Cost Amount
1,098 NC Normal Copying $0.12 $131.76
1 ; ;
i
. � ( r
Acceptance Signafure: .� 1�--- Date:
The work deserrbed above has beon" authorized, received, accepted and is complete and correct.
This invoice is due within 30 days from the party billed above; see "Terms of Sale" below.
Ordered by: Laura
Your Client/File ## 8 6 4.0 0 0 2
Subtotal
Sales Tax 6%
$131 .76
$7.91
Total $13 9.6 7
Your account representative is:
Victor Warren Amount Applied $ o . o 0
Balance $139.67
Thank you for the opportunity to be of service!
TERMS OF SALE., Any payment or portion thereof such as are not paid within 30 days are subject to a SERVICE FEE of 1.5% per month (19% annual). In the event of any default in the payment
of the sums due here under the purchaser shall be liable for all cost of collection incurred including court cost and reasonable attorneys fees, whether suit be instituted or not
The purchaser acknowledges and agrees to all the forgoing and accepts delivery subject to all of the same.
You can doublespeak--I'll understand!
MARTV LESHAW
"A Key West Court Reporter & Videographer"
319 Duval Street,
Key West, Florida 33040
August 14, 2007
Invoice # 07-180 Cell: (305) 321-6996- (Preferred)
Tel. & Fax: (305) 293-9997
E-mail: Marty@Leshaw.net
Tax Id. #: 134-28-5030
- _ —.TOO: - -. FERENC—UK�LhBANOFF,_-BRANDT,
BUSTAMANTE & WILLIAMS, P.A.
150 South Pine Island Road,
Suite 400,
Fort Lauderdale, Florida 33324
ATTN: IRA LIBANOFF, ESQ.
Re: MONROE COUNTY, FLORIDA vs. LODGE
CONSTRUCTION, INC.
LODGE CONSTRUCTION, INC. vs.
MONROE COUNTY, FLORIDA, etc.
August 13, 2007
Appearance: Hearing before Judge David J. Audlin, Jr.
Total: $80.00
PLEASE RETURN ONE COPY OF BILL
THANK YOU
ALTERNATIVE LEGAL
Litigation 9Zgp-dwdon Sp dar-a
Please remit from this invoice.
Payment Due within
30 Days of Invoice Date
Invoice #:00073142
Invoice Date: 8/1 5/07
Remit to:
Alternative Legal Copy Service, Inc.
1007 N. Federal Hwy. #123
Ft. Lauderdale, Florida 33304
Phone: (954)523-1852 Fax: (954)523-5084
Tax ID: 65-1044746
INVOICE
Bill To:
Ferencik Libanoff
150 S. Pine Island Road #400
Plantation, FL 33324, USA
Quantity
Code
Description
Unit Cost
I Amount
574
NC
Normal Copying
$0.12
$68.88
12
O C
Oversize Copying - 11 X 17
$ 0.25
$ 3.00
���,, 1 3i 3 g
Acceptance "gnature: Date:
The w rk desc pilled above has been authorized, received, accepted and is complete and correct.
This in ce is due within 30 days from the party billed above; see "Terms of Sale" below.
Subtotal $71.88
Ordered by: Laura
Sales Tax 6% $ 4.31
Your Client/File #:#864/0002
Your account representative is:
Victor Warren
Total
Amount Applied
Balance
Thank you for the opportunity to be of service!
$76.19
$0.00
$76.19
TERMS OF SALE., Any payment or portion thereof such as are not paid within 30 days are subject to a SERVICE FEE of 1.5% per month (18% annual). In the event of any default in the payment
of the sums due here under the purchaser shall be liable for all cost of collection incurred including court cost and reasonable attorneys fees, whether suit be instituted or not.
The purchaser acknowledges and agrees to all the forgoing and accepts delivery subject to all of the same.
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the westin key west resort & marina
sunset key guest cottages, a westin resort
245 front street key west, florida 33040
phone 305.294.4000 fax 305.294.4086
westin.com/keywest
westin.com/sunsetkey
guest
travel agent/charge to
391
room
Mersch Travel Inc.
Janet
Ritenbaugh
279.00
rate
5931
Sw 199th Ave
1
37255
SW 214 Ave
no. pers.
folio 97571 EX -A
Fort
Lauderdal, FL 3333i
Homestead,
FL 33034
1
page
arrive 16-AUG-07 19:25
depart 17-AUG-07
payment VI
e-
me
- -
oom arge
7 0
16-AUG-07
RT391
Room Tax
20.93
16-AUG-07
RT391
Occupancy Tax
11.16
16-AUG-07
RT391
Valet Park
18.00
17-AUG-07
VI
Visa
329.09-
Total Charges
Total Credits
Balance Due
329.09
329.09-
0.00
For your convenience, we have prepared this zero -balance folio indicating a
$0 balance on your account. Please be advised that any charges not reflected
on this folio will be charged to the credit card on file with the hotel.
While this folio reflects a $0 balance, your credit card may not be charged
until after your departure. You are ultimately responsible for paying all of
your folio charges in full.
EXPENSE REPORT SUMMARY
Date Room & Tax Food & Bev Telephone Other Total Payment
16-AUG-07 311.09 0.00 0.00 18.00 329.09 0.00
Total 311.09 0.00 0.00 18.00 329.09 0.00
Thank you for choosing Starwood Hotels. We look forward to welcoming you back soon!
I agree to remain personally liable for the payment of this account if the
corporation or other third party billed fails to pay part or all of these charges. signature
As a Starwood Preferred Guest, you could have earned 558
Starpoints for this visit. Please provide your member number
or enroll today.
Janet Ritenbaugh
FOLIO 97571 16-AUG-07
E TI
HOTELS & RESORTS
Driving Directions from 37255 Sw 214th Ave, Homestead, FL to 1100 Simonton St, Key ... Page 1 of 2
r Sorry! When printing directly from thebrowser your map may be incorrectly cropped. To print the `
entire map, try clicking the "Printer -Friendly" link at the top of your results page.
Y
An AOL Company
37255 SW 214th Ave 1100 Simonton St
Homestead, FL 33034-6101; US Key West, FL 33040-3110, US
Total Est. Time: Total Est. Distance:
2 hours, 49 minutes 133.15 miles
Maneuvers Distance
1: Start out going NORTH on SW 214TH AVE toward SW 368TH ST. 0.2 miles
2: Turn LEFT onto SW 368TH ST. 0.2 miles
3: Turn RIGHT onto SW 217TH AVE / LOVELAND RD. 1.5 miles
4: Turn RIGHT onto SW 344TH ST / PALM DR. Continue to follow PALM 4.1 miles
DR.
„curd, 5: Turn RIGHT onto US-1 S / S DIXIE HWY / SE 1ST AVE. Continue to 126.8 miles
I follow US-1 S.
6: Turn LEFT onto SIMONTON ST.
7: End at 1100 Simonton St
--,------.—Key West, FL 33040-3110, US
Total Est. Time: 2 hours, 49 minutes Total Est. Distance: 133.15 miles
<0.1 miles
http://www.mapquest.com/directions/main. adp?go=l &do=nw&rmm=1 & 1 gi=0&un=m&l ... 8/22/2007
FERENCIK LIBANOFF BRANDT BUSTAMANTE AND WILLIAMS
PROFESSIONAL ASSOCIATION
ROBERT E. FERENCIK, JR. IRA LLIBANOFF ATTORNEYS AT LAW MELLON FINANCIAL CENTER
.
ALAN C. (PETER) BRANDT, JR
NESTOR BUSTAMANTE, III
ALEXANDER J. WILLIAMS, JR.
JORDANA L. GOLDSTEIN
SANDRA D.KENNEDY
GAVIN D. CADDY
USA K. NORTH
LORI R. SHAPIRO
.JASON L. MOLDER
ROBERT A. CEDENO
LAURA A. PAPAY
JANET E. RITENBAUGH, Of Counsel
COST RECOVERY BILLING
CLIENT/MATTER NO. 864. 0002-
150 S. PINE ISLAND ROAD, SUITE 400
FORT LAUDERDALE, FL 33324
BROWARD (954) 474-8080
DADE (305).949-8003
FAX (954) 474-7343
Email: @flbbwlaw.com
URL: http//www.flbbwlaw.com
a
C)7 Postage $ g
Photocopy (Copier #1) x $.15 $
/ / Photocopy (Copier #2) x $.15 $