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Item P01 December 2006 Litigation Report To: Mayor McCoy & County Commissioners Tom Willi, County Administrator From: Suzanne Hutton, County Attorney Date: December 14,2006 Summary Number of Cases New cases opened in last month 7 Cases closed since last report 3 CAY active cases 57 Potential cases not yet filed 15 Outside Counsel Cases 26 Constitutional Officers Engineering Growth Management Miscellaneous Public Works Risk Management Total Cases pending 78 Index New Cases Cases Closed CAY Litigation Cases Trial & Appellate Level Potential Cases Outside Counsel Cases Ferencik, Libanoff (Ira Libanoff) (4 cases) Gray Robinson (Ed Scales & M. Campbell) (1 case) Greenberg, Traurig (Dave Jordan) (1 case) Johnson, Anselmo, (Bruce Johnson & Mike Burke (13 cases) Paul, Hastings (Bob Freilich & Derek Howard) (4 cases) Page 2 4 5 14 18 18 20 20 20 25 8 6 51 6 4 10 CASES OPENED SINCE OCTOBER'S REPORT (No Report Submitted in November 2006) EEOC v. Monroe County EEOC Miami Sexual Harrassment claim by County employee. Employee Services 510-2006-04265 Date Filed: 10/13/06 RBS Current Status: County's response submitted. Next Activity: Await outcome of EEOC investigation. Johnson, Anselmo billing to date: 0.00 CAY Time: 24.8 Costs: 0.00 Franz, Jennifer v. Monroe County & J. Jefferson Overby CA P 06-475 Circuit Court (16th) Judge: Garcia. Date Filed: 12/7/06 Writ of Prohibition regarding Code Enforcement proceeding. Growth Management/Planning RBS Current Status: Reviewing petition and rule nisi. Next Activity: Monroe County's answer due 12/28/06. Time: 0.00 Costs: 0.00 GEICO v. Monroe county CA K 06-270 Circuit Court 16th Judge: Payne Date Filed: 11/22/06 Tort claim for property damage as a result of car accident. Risk Management RBS Current Status: Mayor served 11/30/06. Next Activity: County's responsive pleading due 12/30/06. Time: 2.6 Costs: 0.00 2 Howard. Carlton v. Monroe County Public Works 06-CV-10113 S.D.Fla. Judge: Moore Date Filed: 10/26/06 Employee ADA claim arising from alleged discrimination in promotion interview. Employee Services RBS Current Status: County's coverage counsel filed motion to dismiss; Plaintiff amended complaint to correct some defects raised in the County's motion. Next Activity: Ruling on motion to dismiss. Johnson, Anselmo billing to date: 0.00 CAY Time: 1.5 Costs: 0.00 ~htner. Nellie v. Monroe County 16 Circuit Judge: Garcia Inverse condemnation action. Growth Management/Planning CA P 06-562 Date Filed: 12/12/06 RBS Current Status: Complaint filed, Mayor not served. Next Activity: Await service, review complaint. Time: 0.1 Costs: 0.00 Riverview Consultants v. Monroe County 3D06-2811 Third DCA Judges: TBA Date Filed: 11/15/06 Appeal of summary judgment in favor of County on Airports' former DBE consultant's tortious interference with contract claim. PJM Airports/Risk Management Current Status: Notice of appeal filed; will be handled by Johnson, Anselmo. Next Activity: Record to be completed by January 5, 2007. Time: 0.1 Costs: 0.00 3 Sierra Club at al. v. DCA. Miami-Dade Co.. Monroe Co. et al 3 D06-2544 Third DCA Judges: TBA Date Filed: 10/12/06 Appeal of Final Administrative Order upholding amendment to Miami-Dade County's comprehensive plan converting Krome Avenue into a major roadway (3 or more lanes). Monroe had intervened below on side of challengers; BOCC gave direction to take no further action so named as Appellee in the appeal. Growth Management/Planni ng RBS Current Status: Index of Record Complete. Next Activity: Appellants' briefs due 12/21/06. Time: 0.5 Costs: 0.00 CASES CLOSED SINCE NOVEMBER'S REPORT Beyer. Gordon & Mollv v. Marathon v. Monroe County & State CA M 05-313 Circuit Court (16th) Judge: Payne Date Filed: 12/14/5 Third Party claim by Marathon for takings case brought by property owners. Growth Management/Planning RBS Current Status: Marathon voluntarily dismissed Third Party claims against County on 10/26/06. Next Activity: Closed. Time: 8.5 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. Constitutional Officer/MCSO RBS Current Status: Court dropped County as a party 1117/06. Next Activity: None, closed. Time: 2.2 hours Costs: 0.00 4 McCole. Jeanine v. City of Marathon v. Monroe County & State CA M 05-314 Circuit Court (16th) Judge: Payne Date Filed: 12/14/5 Third Party claim by Marathon for takings case brought by property owners. Growth Management/Planning RBS Current Statuts: Marathon voluntarily dismissed Third Party claims against County on 10/26/06. Next Activity: Closed. Time: 9.6 Costs: 0.00 CAY LITIGATION - Trial & Appellate Level See Outside Counsel Section for Cases being Handled Jointly Acredited Home Lenders. Inc. v. OIQa Ruiz & M.onroe County CA K 06-543 Circuit Court 16th Judge: Date Filed: 5/25/06 Mortgage foreclosure action on property County holds $36k SHIP mortgage on. Monroe County Housing Authority RBS Current Status: County's Answer, Cross & Counterclaims filed 6/15/6. Next Activity: Serve Olga Ruiz; Discovery. Time: 5.7 Costs: 8.68 Aauiar. Alexander & Elizabeth Ginart v. Monroe County CA P 06-189 Circuit Court 16th Judge: Garcia Date Filed: 5/5106 Appeal from decision of Code Enforcement Special Magistrate Growth Management/Code Enforcement PJM Current Status: Motion to dismiss pending. Next Activity: Attend hearing 1/10107 motion to dismiss. Time: 1.3 Costs: 0.00 5 Bankunited v. M. & J. Jordan & Monroe County et al. CA K 06-862 Circuit Court 16th Judge: Jones Date Filed: 8/22/06 Mortgage foreclosure action in which County holds inferior liens totaling $750.00. Article V PJM Current Status: Answer filed 9/11/06. Next Activity: Await ruling on Motion to dismiss. Time: Costs: D.B. Key Lan:lo. LLC v. Monroe County Planninq Comm'n DOAH 06-484 DOAH Judge: Johnston Date Filed: 2/10/06 Administrative appeal of planning commission denial of an application for amendment to a major conditional use permit. Growth Management/Planning RBS Current Status: Held in abeyance by agreement of the parties. Next Activity: Status report due 1/17/07. Time: 3.3 hours Costs: 26.60 Dorn. Kenneth & Katie Pearce v. Monroe County CA P 06-203 16th Circuit Judge: Garcia Date Filed: 5/15/06 Quiet title action challenging imposition of conservation easement. Growth Management/Planning RBS Current Status: Exploring settlement options with plaintiffs. Next Activity: Responsive pleading due 1/6/07. Time: 5.8 Costs: 0.00 6 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 RBS Current Status: Historic structure being renovated. Next Activity: None at this time. Time: 4.8 hours Costs: 0.00 Evans, Ronald & Marvanna v. Monroe County & K.LO.R. CA P 06-206 16th Circuit Judge: Garcia Date Filed: 05/15/6 Declaratory Judgment action seeking to enjoin entering into development agreement with Key Largo Ocean Resorts Co-Op, Inc. Growth Management/Planning RBS/RBS Current Status: Held in abeyance pending arbitration. Next Activity: None. Time: 14.2 Costs: 0.00 Fuchs. Walburga 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 RBS Current Status: The Court sua sponte scheduled oral argument. Next Activity: Oral argument to be rescheduled. Time: 12.9 hours Costs: 0.00 Good. Lloyd 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 RBS Current Status: County's motion to dismiss granted wI leave to refile. Next Activity: Property owner to go through BUD process. M&H Billing to date: $18,526.41 as of 10/31/05. CAY Time: 29.25 COST: $144.45 7 Graves, Frank III v. Monroe County Circuit Court 16th Judge: Garcia Code Enforcement appeal Growth Management/Code Enforcement CA P 06-154 Date Filed: 417/06 PJM Current Status: Motion to dismiss pending. Next Activity: Attend hearing on motion to dismiss 1/10/07. Time: 0.9 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 RBS Current Status: Status review on pending motions. Next Activity: File County's brief. M&H Billing to date:$1 0,241.57 thru 8/31/05. CAY Time: 6.5 Johnson. Lloyd v. Marlene Conaway Circuit Court 16th Judge: Payne Writ of Mandamus challenge to boundary determination. Growth Management/Planning CA K 02-1248 Date Filed: 10/30/02 RBS Current Status: Status report from Judge's chambers pending. Next Activity: If needed, schedule hearing on Motion to Dismiss. M&H Billing to date: CAY Time: 3.4 $2,219.62 through 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 RBS Current Status: Held in abeyance pending BUD hearing. Next Activity: None pending. M&H Billing to date: CAY Time: 1.0 $2,855.77 as of 8/31/05. 8 Ladd. Lucy v. Monroe County Circuit Court 16th Judge: Miller Mandamus action on building permit allocation issue. Growth Management/Planning CA K 06-952 Date Filed: 9/12/2006 RBS Current Status: Settlement negotiations. Next Activity: Present agreement to BOCC 12/20/06. Time: 12.0 Costs: 0.00 Lee. Vera Estate of CP K 02-112 Circuit Court 16th Judge: Taylor Date filed: 5/14/02 County has claim in probate case for an elderly home loan & unpaid taxes. Housing Authority & Constitutional Officer RBS Current Status: Estate re-opened, CAY appoitlted PR, property listed. Next Activity: Sell property to satisfy all liens, complete estate. Time: 9.9 Costs: Mcintyre. Edward v. Richard Roth & Monroe County US Dist. SDFla. Judge: Hoeveler Civil Rights action filed in 1980 over old jail facilities. Constitutional Officer/MCSO 80-1721-CIV-WMH Date Filed: 7/8/80 Settled 12/1991. RBS Current Status: Status report being finalized. Next Activity: Status conference to be scheduled. CAY Time: 13.0 Costs: $86.77 (since March 2005) 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. Growth Management/Code Enforcement PJM Current Status: Discovery. Next Activity: Bonnett's discovery responses overdue. Time: 6.8 hours Costs: $295.00 9 Monroe County v. Donald Brown CA K 06 953 Circuit Court 16th Judge: Jones Date Filed: 9/14/06 Code Enforcement Lien collection action for commercial property on Big Cop pitt. Growth Management/Code Enforcement PJM Current Status: Answer filed. Next Activity: Discovery. Time: 0.6 Costs: $255.00 Monroe County v. DeDi. of Community Affairs DOAH 06-2856 DOAH Judge: Alexander Date Filed: 7/21/06 Administrative challenge to DCA's rejection of County's ordinance establishing density bonus for affordable housing units measuring no more than 750 sq.ft. Growth Management/Planning RBS Current Status: Being held in abeyance. Next Activity: Status report due 6/1/07; closed session requested 1/07. Time: 60.25 Costs: 262.5 Monroe County v. Alain Y. DeDierrefeu CAK-03-1504 Circuit Court 16th Judge: Jones Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the BOCC on 4/18/03. Growth Management/Code Enforcement RBS Current Status: Discovery. Next Activity: Discovery. V & B Fees billed to date: None CAY Time: 6.7 Costs: 0.00 Monroe County v. Alain Y. DeDierrefeu CAK-03-1507 Circuit Court 16th Judge: Jones Date Filed: 12118/03 Code enforcement foreclosure action authorized by the BOCC on 4/18/03. Growth Management/Code Enforcement RBS Current Status: same as previous entry. Next Activity: Same as previous entry. V&B Fees billed to date: None CAY Time: 3.5 hours Costs: 0.00 10 Monroe County v. James JeanQuenat Circuit Court 16th Judge: Garcia Collection action authorized by BOCC on 4/21/04. Growth Management/Code Enforcement CAP-OS 317 Date Filed: 7/18/05 Fine exceeds 136,100.00. RBS 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,lnc. Circuit Court 16th Judge: Garcia Action to foreclose a code enforcement lien. Growth Management/Code Enforcement CAP-96-260 Date Filed: 5/20/96 RBS/RBS Current Status: Development agreement application being reviewed. Next Activity: Status report due with the Court 1/1/07. Time: 41.5 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 BOCC on 7/17/03; fines exceed $816,300.00. Growth Management/Code Enforcement RBS Current Status: Guardian appointed, Answer filed. Next Activity: Draft settlement agreement. Time: 11.0 hours Costs: $555.00 Monroe County v. Arthur Mehr Circuit Court 16th Judge: Garcia Code fine collection action. Fine exceeds $42,000.00. Growth Management/Code Enforcement CAP-05-348 Date Filed: 8/5/05 RBS Current Status: Discovery. Next Activity: Discovery. Time: 13.7 hours Costs: $850.00. 11 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 BOCC 4/18/03. Growth Management/Code Enforcement RBS Current Status: Settlement drafted. Next Activity: Finalize settlement. V & B Fees billed to date: 67.3 CAY Time: 3.0 Costs: $1029.03 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: Discovery responses overdue. Next Activity: Move to compel discovery. Time: 1.6 hours Costs: 300.00 Monroe County v. VirQinia 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 BOCC 7/15/03. Growth Management/Code Enforcement RBS Current Status: Settlement negotiations pending. Next Activity: If unsuccessful, move for summary judgment. V & B Fees billed to date: None CAY Time: 2.0 Costs: 0.00 Monroe County v. Virginia Sawyer CAK-03-1506 Circuit Court 16th Judge: Jones Date Filed: 12/18/03 Code enforcement foreclosure action that was authorized by the BOCC 7/15/03. Growth Management/Code Enforcement RBS Current Status: Court approved settlement agreement, injunction, lien. Next Activity: Enforcement if not compliance. V&B Fees & Costs billed to date: $11,745.44 CAY Time: 6.7 hours 12 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 BOCC 7/15/03. Growth Management/Code Enforcement RBS Current Status: Settlement negotiations pending. Next Activity: If unsuccessful, move for summary judgment. V&B Fees billed to date: None CAY Time: 2.5 Costs: 0.00 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 RBS Current Status: Mandate from Third DCA received 1/13/06. Next Activity: Status inquiry with chambers pending. M&H Billing to date: CAY Time: 2.5 $42,782.73 as of 10/31/05 Neumont. Elizabeth et at v. Monroe County 99-10054-CV U.S. Dist. Ct., S.D.Fla. Judge: Paine Date Filed: 5/21/99 Class action challenging enactment of vacation rental ordinance. Growth Management/Planning RBS Current Status: On appeal to 11 th Circuit which certified question. Next Activity: None, await ruling. M&H Billing to date: $123,563.24. CAY Time: 0.5 Neumont, Elizabeth et at 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 RBS Next Activity: Court certified question to Florida Supreme Court. None in 11th Circuit until certified question answered. Current Status: CAY Time: 4.5 13 Oliveros. Joseph v. Ana M. Velazquez & Monroe County Circuit Court 16th Judge: Garcia Quiet title action to property conveyed via tax deed. Constitutional Officer/ClerklTax Collector CA P 06-130 Date Filed: 3/20/06 RBS Current Status: County has no interest to defend in case. Next Activity: None. Time: 1.8 Costs: 0.00 POTENTIAL CASES THAT HAVE NOT YET BEEN FILED Allison, Dverly Delores and Carl Eldred and Monroe County TBA TBA Judge: TBA Date Filed: TBA Potential person injury action due to alleged slip and fall. Risk Management RBS Current Status: Reviewing claim and information provided. Next Activity: None until/unless suit is filed. Time: .2 Costs: 0.00 Ballard, Kandi v. Bergen Trust and Monroe County TBA TBA Judge: TBA Date Filed: TBA PI case arising from County's of Bergen property for hurricane debris. Risk Management/Engineering RBS Current Status: Reviewing claim and information provided. Next Activity: None until/unless suit is filed. Time: 7.1 Costs: $0.00 14 Bott. Andrew & Donna v. City of Marathon CA M 05-267 Circuit Court (16th) Judge: Payne Date Filed: 9/30/05 Declaratory Judgment action challenging validity of affordable housing deed restriction City of Marathon inherited from County at time of incorporation. Growth Management/Planning RBS Current Status: Appealed to 3rd DCA; Next Activity: None pending appeal. Time: 13.5 Costs: 0.00 Bott. Andrew & Donna v. City of Marathon Third DCA Judges: TBA Appeal of dismissal of CA M 05-267. Growth Management/Planni ng 3D06-1261 Date Filed: 5/24/6 RBS Current Status: City's brief served. County not serving amicus brief. Next Activity: Bott's reply brief due 12/22/06. Time: 2.0 Costs: 0.00 Calusa CampQround Condo v. Monroe County, at al.. TBA Circuit Court (16th) Judge: Date Filed: Threatened action by condominium resulting from statements regarding platting requirements by Growth Management personnel. Growth Management/Planning RBS Current Status: Settlement negotiated. Next Activity: Finalize agreement and present to BOCC. Time: 2.5 Costs: 0.00 Cormier. Leonard TBA Circuit Court (16th) Judge: TBA Date Filed: TBA Personal injury claim arising from alleged injuries at East Martello Risk Management/Public Works RBS Current Status: Assisting Risk with investigation of claim. Next Activity: Status review with Risk. Time: 0.2 Costs: 0.00 15 Fulton. Charles et al v. Nat'l Gen. Assurance Co., et al. 00-7549-CA-LG Circuit Court (20th) Judge: Steinbeck, M. Date Filed: 917/00 Class action suit by health care providers against insurance companies for late payment of PIP benefits wlo interest. EMS has been notified that it is a potential class member and of proposed settlement. Emergency ServiceslEMS RBS Current Status: Reviewing documents to determine County's interest. Next Activity: Opt out deadline October 31,2006. Time: 0.5 Costs: 0.00 Good. Lloyd v. Monroe County TBA Circuit Court (16th) Judge: Date Filed: Bert J. Harris Act claim regarding two parcels of property owned by Lloyd Good. Growth Management/Planning RBS/RBS Current Status: Settlement agreement drafted. Next Activity: Good reviewing draft settlement agreement. Time: 8.6 hours Costs: $5.56 Monroe County v. Estate of Thomas O'Brien CP K 05-164 Small Claims Monroe Judge: TBA Date Filed: Action against estate to collect unpaid ambulance bill of $861.81. Emergency Services/EMS RBS Current Status: Settlement agreement approved by the probate court. Next Activity: Inventory filed; Awaiting payment. Time: 3.6 Costs: 0.00 Monroe County & Danise HenriQuez v. Hotels.com LP 06~CV - TBA U.S. Dist. Ct., S.D.Fla. Judge: Huck Date Filed: Action against internet hotel reservation entities to collect unpaid bed taxes. Constitutional OfficerlTax Collector RBS Current Status: Negotiating terms of representation with outside counsel. Next Activity: None until due diligence completed. Time: 1.5 Costs: 0.00 16 State of Florida v. Monroe County TBA TBA Judge: TBA Date Filed: n/a AG's Medicaid Fraud unit alleges over billings for ambulance services. Public Safety/Fire Rescue RBS Current Status: Waiting over a year for AG's office to set up conference. Next Activity: None scheduled. Time: 9.2 hours Costs: 0.00 Stewart. Becky v. Monroe County TBA TBA Judge: TBA Date Filed: TBA Tort claim arising from accident involving County vehicle in Ocala. Risk Management RBS Current Status: Negotiations stalled due to offsetting claims. Next Activity: Defend suit if filed; file suit if appropriate. Time: 1.4 Costs: $0.00 TAMPOA v. City of Key West & Bahama VillageConsortium en CA K 06-55 16th Circuit Judge: Jones Date Filed: 1/17/06 Breach of contract action to enforce settlement agreement between T AMPOA and City over use of Southard Street. BVC intervened on side of City. Public Works/Facilities Maintenance RBS Current Status: Court denied County's motion to intervene. Next Activity: Decision on appeal w/in 30 days of rendering of order. Time: 10.5 Costs: 65.00 Watts, Margaret. et al v. Michael Hunter, at al. 372006 CA 1823 Circuit Court (2nd - Leon) Judge: TBA Date Filed: 7/20/06 Class action filed against Florida Medical Examiners' Commission and 17 appointed district medical examiners seeking a refund of cremation fees that were not authorized by statute. Dr. Hunter will be retaining his own counsel. Medical Examiner RBS Current Status: County not named as a party at this time. Next Activity: None unless & until County named. Time: 1.5 Costs: $0.00 17 Wells, David M. v. Monroe County CA K TBA Circuit Court (16th) Judge: TBA Date Filed: TBA Tort claim against Monroe County for alleged false statements made by employee to law enforcement officer that led to claimant's arrest. Risk Management/Emergency Services RBS Current Status: Claim filed 10/3/06 being reviewed. Next Action: County has 6 months to evaluate the claim. Time: 0.2 Williams. Charles v. Luis Garcia & Monroe County 4:06-cv-10043-KMM US S.D.Fla. Judge: Moore Date Filed: 5/16/06 Inmate civil rights action against Judge and "County as his employer". Constitutional Officer Current Status: Case screened by Court for sufficient cause to proceed. Next Action: If sufficient cause found, County will be served. Time: 0.2 CASES BEING LITIGATED BY OUTSIDE COUNSEL Ferencik, libanoff, Brandt, Bustamante and Williams, P.A. (Ira libanoff) 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 RBS Current Status: Complaint amended to add additional DF. Next Activity: Discovery. Fees billed to date: $115,090.50 Costs: $12,856.26 (thru 8/04/06) 18 Monroe County v. Jose Gonzalez CA K TBA Circuit Court 16th Judge: TBA Date Filed: TBA Possible breach of contract action against County's former architect. Engineering/Construction Management RBS Current Status: Nothing pending until licensing review completed. Next Activity: None pending. Fees billed to Date: CAY Time: 12.5 $10,245.00 Costs: $1,079.38 (thru 9/06/06) Monroe County v. LodQe Construction, et al CAK-00-617 Circuit Court 16th Judge: Payne Date Filed: 5/11/00 Suit against general contractor & its surety for breach of contract. Engineering/Construction Management RBS Current Status: Motion to set before Senior Judge pending. Next Activity: Ruling on Senior Judge motion pending & trial date to be set. Fees billed to date: $300,858.75 Costs: $71,530.01 (thru 8/04/06). Tropex Construction Service, Inc. v. Monroe County CA P 06-44 Circuit Court 16th Judge: Garcia Date Filed: 1/30/06 Breach of contract suit filed by contractor who terminated contract to build Tavernier Fire Station before commencement of construction. Engineering/Construction Management RBS Current Status: Discovery. Next Activity: Discovery. Billing Received to date: none. CAY Time: 1.1 Costs: 0.00 19 Gray Robinson (Ed Scales & Monterery Campbell) Neumont, Elizabeth v. State & Monroe County SC 06-1204 Fla. Supreme Court Judges: en bane Date Filed: 6/14/6 Certified question from the 11 th Circuit to the Florida Supreme Court seeking guidance on proper interpretation of F.S. 125.66(4), ordinance notice provision. Growth Management/Planning RBS Current Status: Briefing complete. Next Activity: Oral argument 4/19/06. Billing Received to date: $9,981.56 CAY Time: 11.2 Costs: 0.00 Greenberg, Traurig (Dave Jordan) F.K.C.C. & Last Stand v. D.C.A. & Monroe County DOAH 06~2449GM DOAH ALJ: Alexander Date Filed: 717/6 Administrative challenge to ordinances adopting Tier system. Growth Management/Planning RBS/RBS Current Status: Trial preparation Next Activity: Final hearing Feb. 6-9, 2006 CAY Time: 95.0 GreenbergTraurig Costs: $10,272.87 $4,485.00 Johnson, Anselmo, Murdoch, Burke, Piper, & McDuff, P.A. (Bruce Johnson, Mike Burke, Tammy Scrudders) BaukniQht. 5ka~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 RBS Current Status: Third party complaint against State filed 1/11/06. Next Activity: Discovery. Fees billed to date: $832.24 Costs: 0.00 20 Florida Key Deer v. Michael Brown & Gale Norton 90-10037-CIV-Moore U.S. Dist. Ct., SD Fla. Judge: Moore Date Filed: 4/2/90 ESA case that resulted in permanent injunction barring FEMA flood insurance. Growth Management/Planning RBS Current Status: Injunction in place. 6/9/6, Federal defendants moved for two month extension to produce revised biological opinion and new RPAs. Next Activity: On appeal, see 05-16374-11 Billing to Date: none CAY Time: 33.8 Costs: 0.00 Paulson. R.D. v. Florida Key Deer. et al 05-16374-11 11th Circuit Judges: TBA Date Filed: 11/10/05 Appeal of Southern District's injunction in 90-10037-CIV. County appeared as am;cus curiae because denied intervention. See Case No.: 05-16990-11. Growth Management/Planni ng RBS Current Status: Briefs complete. Next Activity: Awaiting decision by Court. Billing to date: CAY Time: none 0.5 Costs: 0.00 Monroe County v. Florida Kev Deer, et al 05R16990-11 11th Circuit Judges~ TBA Date Filed: 12/12/05 Appeal of denial of County's motion to intervene in 90-10037-CIV. Growth Management/Planning RBS Current Status: Briefs complete. Next Activity: Await decision by the Court. Billing to Date: None CAY Time: 1.0 21 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 ESA challenge to F&WS review of construction of park on Big Pine Key. Engineering/Construction Management RBS Current Status: Dismissed with prejudice by agreement on 2/13/06 because revised biological opinion satisfactory to Plaintiffs. Next Activity: Resolve any attorneys fees & costs motions. Fees billed to date: $612.50 CAY Time: 6.5 Costs: 0.00 FKCC & Last Stand v. FL Admin. Comm.. Monroe County DOAH 04-2756 DOAH Judge: Carolyn Holifield Date Filed: 08105/04 Administrative Rule challenge to partnership agreement with State. Growth Management/Planning RBS Current Status: Final Order in County's favor issued 6/29/06. Next Activity: None pending appea1. Fees billed to date: $59,464.92 CAY Time: 190.1 hours Costs: 0.00 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. Growth Management/Planni ng RBS Current Status: Affirmed 11/15/06. Next Activity: Motion for rehearing or clarification pending. Fees billed to date: see DOAH case for fees. CAY Time: 1.5 hours Costs: 0.00 22 Hardee, Evelyn 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 Settled for $25,000.00. RBS Current Status: Dismissed 617/06. Re-opened 8/2/6 Next Activity: Evidentiary hearing in January or February, no date yet Fees billed to date: $28,333.39 (thru 6/16/06). CAY Time: 11.9 hours Hyland. Thomas G. v. D. Kolhaae & R. Thurston 04-10102-CIV U.S.D.C.SD.Fla. Judge: Highsmith Date Filed: 10/21/04 Civil Rights action against Deputy Clerk of Court by inmate. Constitutional Officer/Clerk RBS Current Status: Dismissed by Court. Next Activity: Appeal filed 10/10106. CAY Time: 9.0 Fees & Costs billed to date: $34,390.70 Hxland. Thomas G. v. Danny L. Kolhaae & Ruth Thurston 06-15372-A 11 h Circuit (US) Judge: TBA Date Filed: 10/10/06 Third appeal arising from inmate civil rights action for alleged actions of deputy clerk. Johnson, Anselmo is coverage counsel & co-counsel to CAY. Constitutional Officer/Clerk RBS Current Status: Await briefing schedule. Next Activity: None until Hyland's brief is filed.. Time: .2 Costs: 0.00 Johnson, Anselmo, billing to Date: See District Court case. 23 Kessler. Stuart v. Monroe County & Tom Willi CA K 05-1006 Circuit Court 16th Judge: Jones Date Filed: 10/11/2005 Whistle-Blower & Civil Rights claim by former employee. Human Resources/Risk Management RBS Current Status: Discovery. Next Activity: Discovery. Fees & Costs billed to date: CAY Time: 40.8 $19,535.67 (thru 10/18/06) 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 RBS Current Status: Cross motions for summary judgment pending. Next Activity: Hearing on summary judgment motions 1/9/07. Fees billed to date: $2,326.92 CAY Time: 5.8 hours Costs: 200.00 Riverview Consultants, Inc. v. Monroe County CAK-05-373 Circuit Court 16th Judge: Jones Date Filed: 4/13/05 Case alleging tortious interference with contract by airport DBE subcontractor. Risk ManagementlAirports/MCSO PJM Current Status: Riverview appealed summary judgment in favor of County. Next Activity: None pending appeal. Fees billed to date: $743.86 CAY Time: 13.9 hours Costs: 0.00 24 Paul, Hastings (Bob Freilich & Derek Howard) & Stephen Moore, LLC 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 RBS Current Status: Discovery. Next Activity: Discovery. Total Fees billed to date: $907,553.84 (thru 8/9/06) CAY Time: 158.8 hours Costs: $90,979.63 Emmert. Helen & Greg v. Monroe County Circuit Court 16th Judge: Garcia Inverse condemnation and vested rights action. Growth Management/Planni ng CA P 02-520 Date Filed: 10/2/02 RBS Current Status: Motions for summary judgment pending denied. Next Activity: Trial April 2007. P, H Billing to date: M&H Billing to date: CAY Time: 15.5 None $94,550.56 as of 10/31/05 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 RBS Current Status: Appeal filed on order of Judge Payne for new trial. Next Activity: None pending outcome of appeal. M & H Billing to date: Paul, Hastings Billing: CAY TIME: 56.5 $54,322.5 thru 1/25/06. $245,016.00 Costs: $5,339.29 25 Monroe County & State v. Galleon Bay 3D06-2426 & 2421 Third DCA Judges: TBA Date Filed: 9/29/06 Appeal of Order granting new trial. Paul, Hasting lead counsel, CAY co-counsel. Growth Management/Planni ng RBS Current Status: Compiling record. Next Activity: County's brief due 117/07. Paul, Hastings Billing: See trial level case. CAY TIME: 2.5 Assigned Assistant County Attorney P JM = Pedro Mercado RBS = Bob Shillinger 26