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Item P01 February 2007 litigation Report To: Mayor DiGennaro & County Commissioners Tom Willi, County Administrator From: Suzanne Hutton, County Attorney Date: February 14, 2007 Summary Number of Cases New cases opened in last month 1 Cases closed since last report 2 CAY active cases 37 Potential cases not yet filed 12 Outside Counsel Cases 30 Constitutional Officers Engineering Growth Management Miscellaneous Public Works Risk {Vlanagement Total Cases pending 68 Index New Cases Cases Closed CAY Litigation Cases Trial & Appellate Level Potential Cases Outside Counsel Cases Aronovitz, T od (1 case) 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 (17 cases) Paul, Hastings (Bob Freilich & Derek Howard) (4 cases) Purdy, Jolly (Summer Baranco) (1 case) 9 7 49 10 3 10 Page 2 2 3 13 16 16 17 17 18 19 , 25 26 CASES OPENED SINCE LAST MONTH'S REPORT D.L.Porter Constrcutors. Inc. v. Monroe County CA K 07-155 Circuit Court (16th) Judge: Jones Date Filed: 2/5/2007 Breach of contract action filed by general contractor for KWIA hanger project. Airports/Engineering PJM Currrent Status: Awaiting service. Will be handled jointly by CAY & Ira Libanoff Next Activity: None until served. Fees: $5,950.00 CAY Time: 10.5 Costs: 319.16 CASES CLOSED SINCE LAST MONTH'S REPORT Graves. Frank III v. Monroe County Circuit Court 16th Judge: Garcia Code Enforcement appeal Growth Management/Code Enforcement CA P 06R154 Date Filed: 417/06 PJM Current Status: County's motion to dismiss granted. Next Activity: Close file. Time: 2.5 Costs: 0.00 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: Received $500.00 payment per Settlement Agreement. Next Activity: Close file. Time: 3.6 Costs: 0.00 2 CAY UTIGA TION - Trial & Appellate level See Outside Counsel Section for Cases being Handled Jointly Acredited Home lenders. Inc. v. Olga Ruiz & Monroe County CA K 06R543 Circuit Court 16th Judge: Jones Date Filed: 5/25/06 Mortgage foreclosure action on property County holds $36k SHIP mortgage on. Monroe County Housing Authority RBS Current Status: Action in abeyance while Ruiz makes payments. Next Activity: None. Time: 5.7 Costs: 8.68 Aguiar, Alexander & Elizabeth Ginart v. Monroe County CA P 06-189 Circuit Court 16th Judge: Garcia Date Filed: 5/5/06 Appeal from decision of Code Enforcement Special Magistrate Growth Management/Code Enforcement PJM Current Status: Motion to dismiss pending. Next Activity: Hearing to be set. Time: 1.7 Costs: 0.00 Bank of New York et. al. v. Williams et. al. CARKR 06-1345 Circuit Court 16th Judge: Audlin Filed: 12/21/06 Mortgage foreclosure action. County holds @$950.00 junior lien imposed for fines, court costs, and fees imposed in misdemeanor case. Lien is defective so County's interest is void Article V. RBS Current Status: County filed answer conceding its interest is void. Next Activity: No further action until final judgment entered. Time: 2.5 Costs: 0.00 3 Bankunited v. M. & J. Jordan & Monroe County et at CA K 06R862 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: Motion for summary judgment granted to Plaintiff. Next Activity: Monroe County filing Statement of Claim. Time: .5 Costs: 0.00 D.S. Key largo, llC v. Monroe County Planning Comm'n DOAH 06R484 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 4/30/07. Time: 3.3 hours Costs: 26.60 Dorn, Kenneth & Katie Pearce v. Monroe County CA P 06R203 16th Circuit Judge: Garcia Date Filed: 5/15/06 Quiet title action challenging imposition of conservation easement. Growth Management/Planning RBS Current Status: County filed answer. Next Activity: Discovery. Time: 9.3 Costs: 0.00 Eads. Barbara v. Monroe County CAP-03R117 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 4 Evans, Ronald & Marvanna v. Monroe County & K.L.O.R. CA P 06R206 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 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: Writ of prohibition granted 2/2/07. Next Activity: None. Close file in 30 days if no motion for costs filed. Time: 8.9 Costs: 328.50 Fuchs, Walburga v. Monroe County Circuit Court 16th Judge: Audlin This is a code enforcement appeal of an OSTDS case. Growth Management/Code Enforcement CAKR01 R1251 Date Filed: 10/5/01 RBS Current Status: The Court sua sponte scheduled oral argument. Next Activity: Oral argument scheduled for 3/1/06. Time: 12.9 hours Costs: 0.00 Good, Lloyd v. Monroe County Circuit Court 16th Judge: Audlin Inverse condemnation action based on NROGO. Growth Management/Planning CA K 01-977 Date Filed: 8/9/01 RBS Current Status: Held in abeyance while Good goes thru BUD process. ' " Next Activity: CAY asking for closed session in March to discuss settlement. M&H Billing to date: $18,526.41 as of 10/31/05. CAY Time: 2925 COST: $144.45 5 Hardin, Michelle v. Monroe County Circuit Court 16th Judge: Miller Appeal of code enforcement decision. Growth Management/Code Enforcement CA K 99R1 046 Date Filed: 9/3/99 RBS Current Status: Appellant's brief complete. Next Activity: Status conference 3/1/07. M&H Billing to date:$10,241.57 thru 8/31/05. CAY Time: 6.5 Johnson. Lloyd v. Marlene Conaway Circuit Court 16th Judge: Audlin 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 qn 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. ladd. lucy v. Monroe County Circuit Court 16th Judge: Miller Mandamus action on building permit allocation issue. Growth Management/Planning CA K 06R952 Date Filed: 9/12/2006 RBS , Current Status: Settlement reached and approved by BOCC 12/20/06. Next Activity: Finalize documents and close file. Time: 12.0 Costs: 0.00 6 Lee, Vera Estate of CP K 02R112 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 appointed 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. SOFia. Judge: Hoeveler Civil Rights action filed in 1980 over old jail facilities. Constitutional Officer/MCSO 80-1721 RCIV-WM H 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 CAKR05-911 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 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 Coppitt. Growth Management/Code Enforcement PJM Current Status: Answer filed. Next Activity: Discovery. Time: 0.6 Costs: $255.00 7 Monroe County v. DeDi. of Community Affairs DOAH 06R2856 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 until 6/1/7. Next Activity: Status report due 6/1/07. Time: 62.2 Costs: $262.50 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-03R1507 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: 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 Monroe County v. James Jeanquenat Circuit Court 16th Judge: Garcia Collection action authorized by BOCC on 4/21/04. Growth Management/Code Enforcement CAPR05317 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 8 Monroe County v. Key largo Ocean Resorts CooP. Inc. 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 4/1/07. 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 CApR05-348 Date Filed: 8/5/05 RBS Current Status: Discovery. Next Activity: Discovery. Time: 13.7 hours Costs: $850.00. Monroe County v. James Messera, et al CAK~03-1509 Circuit Court 16th Judge: Audlin Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the BOCC 4/18/03. Growth Management/Code Enforcement RBS Current Status: Settled & dismissed. Next Activity: Resolve fees with former counsel before closing. V & B Fees billed to date: 67.3 CAY Time: 3.0 Costs: $1029.03 9 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. Virginia Sawyer & Tony Welters CAK-03R1505 Circuit Court 16th Judge: Audlin 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 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 10 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 02R141 Date Filed: 3/13/02 RBS Current Status: Mandate from Third DCA received 1/13/06. Next Activity: None scheduled. M&H Billing to date: CAY Time: 2.5 $42,782.73 as of 10/31/05 Neumont. Elizabeth et al. v. Monroe County 99-10054RCV 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 al. v. Monroe County 11th Circuit Court of Appeals Judges: TBA Appeal of 99-1 0054-CV above. Growth Management/Planni ng 04-13610RX Date Filed: 7/15/04 RBS Current Status: Court certified question to Florida Supreme Court. Next Activity: None in 11th Circuit until certified question answered. CAY Time: 4.5 Nicholson, Delaine v. Monroe County Circuit Court 16th Judge: Garcia Code enforcement appeal. Growth Management/Code Enforcement CA P 07-17 Date Filed: 1/8/07 PJM Current Status: Appellant compiling record. ~ Next Activity: Appellant's brief due 3/12/07. Time: 0.1 Costs: 0.00 11 Oliveros. Joseph v. Ana M. Velazquez & Monroe County Circuit Court 16th Judge: Garcia Quiet title action to property conveyed via tax deed. Constitutional Officer/Clerk/Tax 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 Sierra Club et al. v. DCA, Miami-Dade Co.. Monroe Co. et al 3D06-2544 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/Planning RBS Current Status: Briefing complete. County to,ok no action. Next Activity: Await decision of Court. Time: 0.5 Costs: 0.00 '0 12 POTENTIAL CASES THAT HAVE NOT YET BEEN FILED Aegis Factors, Inc. v. Monroe County v. Judy Bobic TBA Circuit Court Judge: TBA Date Filed: TBA Claim for payment of $35,546.01 made by assignee of airport's janitorial contractor who had assigned payment rights to lender. If sued, County would likely file a third party claim against contractor to recoup any judgment entered. Airports/Constitutional Officer Clerk RBS Current Status: Bobick agreement to make repayments secured by mortgage against her house. Next Activity: None. Time: 13.8 Costs: 0.00 Allison, Beverly 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 13 Bot!, Andrew & Donna v. City of Marathon CA M 05-267 Circuit Court (16th) Judge: Audlin 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: Third DCA affirmed 2/14/07. Next Activity: None. Time: 15.0 Costs: 0.00 Calusa Campground Condo v. Monroe County. et 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: 14.5 Costs: 0.00 Fulton. Charles et al v. Nat'l Gen. Assurance Co., et al. 00-7549-CARlG Circuit Court (20th) Judge: Steinbeck, M. Date Filed: 9/7/00 Class action suit by health care providers against insurance companies for late payment of PIP benefits w/o interest. EMS has been notified that it is a potential class member and of proposed settlement. Emergency Services/EMS RBS Current Status: Reviewing documents to determine County's interest. Next Activity: Opt out deadline October 31,2006. Time: 0.5 Costs: 0.00 14 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 Current Status: Presuit negotiations successful. Next Activity: None. Time: 8.6 hours Costs: $5.56 State of Florida v. Monroe County TBA TBA Judge: TBA Date Filed: nla AG's Medicaid Fraud unit alleges over billings for ambulance services. Public SafetylFire 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 Watts. Margaret. et al v. Michael Hunter, et 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 15 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 4:06Rcv-10043RKMM 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, COLlnty will be served. Time: 0.2 CASES BEING LITIGATED BY OUTSIDE COUNSEL T od Aronovitz Leon County, et al v. Hotels.com lP 06CV 21868CV U.S. Dist. Ct., S.D. Fla. Judge: Huck Date Filed: Class action against internet reservation entities to collect unpaid bed taxes. Constitutional Officer/Tax Collector RBS Current Status: Negotiating terms of representation with outside counsel. Next Activity: BOCC to confirm contract with counsel 2/21/07. Time: 3.5 Costs: 0.00 16 Ferencik, libanoff, Brandt, Bustamante and Williams, P.A. (Ira libanoff) Monroe County v. Bender & Associates. et al CAKR03R915 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. EngineeringlConstruction Management RBS Current Status: Discovery. Next Activity: Discovery. Fees billed to date: $140,100.50 Costs: $14,524.43 (thru 1/01/07) 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 untillicensil1g review completed. Next Activity: None pending. Fees billed to Date: CAY Time: 12.5 $10,320.00 Costs: $1,114.18 (thru 1/01/07) Monroe County v. lodge Construction. et al CAK-00-617 Circuit Court 16th Judge: Audlin 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: $307,540.75 Costs: $72,468.31 (thru 1/01/07). 17 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. Fees billed to date: $25,025.00 CAY Time: 2.1 Costs: Costs: $1,859.45 (thru 1/1/7) 0.00 Gray Robinson (Ed Scales & Monterery Campbell) Neumont, Elizabeth v. State & Monroe County SC 06R1204 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: Next Activity: Briefing complete. Oral argument 4/19/06. Billing Received to date: $10,319.06 CAY Time: 11.2 Costs: 0.00 Greenberg, Traurig (Dave Jordan) F.K.C.C. & last Stand v. D.C.A. & Monroe County DOAH AlJ: Alexander Administrative challenge to ordinances adopting Tier system. Growth Management/Planning DOAH 06-2449GM Date Filed: 7/7/6 RBS Current Status: Hearing started Feb. 6 thru 9, 2007. Next Activity: Hearing to be finished in March 2007, dates TBA CAY Time: 175.0 GreenbergTraurig Costs: $47,827.54 $44,626.19 18 Johnson, Anselmo, Murdoch, Burke, Piper, & McDuff, P.A. (Bruce Johnson, Mike Burke, Tammy Scrudders) Bauknight, Ska~qs & Rockett v. Monroe County CAP-04-451 Circuit Court 16 Judge: Garcia Date Filed: 9/24/04 Inverse condemnationltakings 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: Cross motions for summary judgment filed. Next Activity: Hearing scheduled for 3/7/07. Fees billed to date: $832.24 Costs: 0.00 Cormier, Leonard v. Monroe County dba HW Art & Hist. Soc. CA K 06-1363 Circuit Court (16th) Judge: Audlin Date Filed:12/20/06 Personal injury claim arising from alleged injuries sustained at East Martello. Risk Management/Public Works RBS Current Status: Plaintiff has filed a motion to amend the complaint without naming Monroe County as a defendant. Next Activity: Close file once amended complaint approved by Court. Time: 1.0 Costs: 0.00 Fees billed to date: 0.00 EEOC v. Monroe County EEOC Miami Sexual Harrassment claim by County employee. Employee Services 510-2006R04265 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: 28.8 Costs: 0.00 19 Florida Kev Deer v. Michael Brown & Gale Norton 90R10037-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 05-16374RII 11th Circuit Judges: TBA Date Filed: 11/10/05 Appeal of Southern District's injunction in 90-1 0037-CIV. County appeared as amicus curiae because denied intervention. See Case No.: 05-16990-11. Growth Management/Planning 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 Key Deer, et al 05-16990RII 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 20 Florida Key Deer, et al v. Gale Norton (Sec. of Interior) 05-10063RCIVRKING 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 04R2756 DOAH Judge: Carolyn Holifield Date Filed: 08/05/04 Administrative Rule challenge to partnership agreement with State. Growth Management/Planning RBS Current Status: Final Order in County's favor issued 6/29106. Next Activity: None pending appeal. 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 3D05R1800 Third DCA Judges: TBA Date Filed: 7/28/05 Appeal of ALJ's decision denying rule challenge in DOAH 04-2756. Growth Management/Planning RBS Current Status: 2/13/07 - motion for rehearing and certification denied. Next Activity: None. Fees billed to date: see DOAH case for fees. CAY Time: 1.5 hours Costs: 0.00 21 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-05R255 Date Filed: 6/3/05 Settled for $25,000.00. RBS Current Status: Dismissed 6/7/06. Re-opened 8/2/6 Next Activity: Evidentiary hearing on worker's compensation lien to be set. Fees billed to date: $28,333.39 (thru 6/16/06). CAY Time: 11.9 hours Howard, Carlton v. Monroe County Public Works 06RCV-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: Discovery Next Activity: Discovery. Johnson, Anselmo billing to date: $3, 824.11 CAY Time: 1.5 Costs: 0.00 Hyland, Thomas G. v. D. Kolhage & R. Thurston 04R10102-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 10/10/06. CAY Time: 9.0 Fees & Costs billed to date: $34,390.70 22 H~land, Thomas G. v. Danny L. Kolhage & Ruth Thurston 06R15372RA 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. ConstitutionalOfficer/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. Kessler, Stuart v. Monroe County & Tom Willi Circuit Court 16th Judge: Jones Whistle-Blower & Civil Rights claim by former employee. Human ResourceslRisk Management CA K 05R1006 Date Filed: 10/11/2005 RBS Current Status: Discovery. Next Activity: Discovery. Fees & Costs billed to date: CAY Time: 40.8 $19,535.67 (thru 10/18/06) li~htner, Nellie v. Monroe County 16 h Circuit Judge: Garcia Inverse condemnation action. Growth Management/Planning CA P 06-562 Date Filed: 12/12/06 RBS Current Status: 2/13107, Court granted County's motion to transfer case to correct location - Lower Keys Division. Next Activity: Hearing on motion to dismiss TBA. Fees & Costs billed to date: None. Time: 13.6 Costs: 0.00 23 Neuman, Kenneth v. Monroe County CAKR04R663 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: Summary judgment motions pending. Next Activity: Await ruling on summary judgment motions. Fees billed to date: $2,326.92 CAY Time: 8.8 hours Costs: 200.00 Riverview Consultants. Inc. v. Monroe County CAKR05R373 Circuit Court 16th Judge: Jones Date Filed: 4/13/05 Case alleging tortious interference with contract by airport DBE subcontractor. Risk Management/Airports/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 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: 2/12/07, County's brieffiled. Next Activity: Review's reply brief due 2/22/07. Fees billed to date: -- see trial level. CAY Time: 1.5 Costs: 0.00 24 Paul, Hastings (Bob Freilich & Derek Howard) & Stephen Moore, lLC Collins, Thomash et al v. Monroe County Circuit Court 16t Judge: Audlin Takings action brought by 11 groups of plaintiffs. Growth Management/Planni ng CAM-04-379 Date Filed: 11/22/04 RBS Current Status: Discovery. Next Activity: Discovery. Total Fees billed to date: $975,875.52 (thru 12/31/06) CAY Time: 158.8 hours Costs: $91,733.38 Emmert, Helen & Greg v. Monroe County Circuit Court 16th Judge: Garcia Inverse condemnation and vested rights action. Growth Management/Planning CA P 02R520 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 $50,515.65 as of November '06 $94,550.56 as of 10/31/05 Galleon Bay v. Monroe County v. State of Florida Circuit Court 16th Judge: Audlin Inverse condemnation and vested rights action. Growth Management/Planning CA K 02-595 Date Filed: 5/21/02 RBS Current Status: Appeal pending on order granting 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: $11,611.47 25 Monroe County & State v. Galleon Bav Third DCA Judges: TBA Appeal of Order granting new trial. Growth Management/Planning 3D06-2426 & 2427 Date Fi led: 9/29/06 Paul, Hasting lead counsel, CAY co-counsel. RBS Current Status: County's initial brief filed 1/2107. Next Activity: Appellee's reply brief due, extension granted. Paul, Hastings Billing: See trial level case. CAY TIME: 2.5 Purdy, Jolly (Summer Baranco) GEICO v. Monroe County CA M 06R270 Circuit Court 16th Judge: Audlin Date Filed: 11/22/06 Tort claim for property damage as a result of car accident against MCSO deputy. Sheriff's insurance fund's carrier defending at no cost to county. Constitutional Officer/Risk Management RBS Current Status: County filed motion to dismiss. Next Activity: Hearing on motion to be set. Time: 2.6 Costs: 0.00 No billing will be received; covered by MCSO insurance. Assigned Assistant County Attorney PJM = Pedro Mercado RBS = Bob Shillinger 26