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HomeMy WebLinkAboutItem P07 P7 BOARD OF COUNTY COMMISSIONERS COUNTY of MONROE Mayor James K.Scholl,District 3 The Florida Keys Mayor Pro Tern Michelle Lincoln,District 2 Craig Cates,District 1 David Rice,District 4 Holly Merrill Raschein,District 5 Board of County Commissioners Meeting April 16, 2025 Agenda Item Number: P7 2023-3886 BULK ITEM: No DEPARTMENT: County Attorney TIME APPROXIMATE: STAFF CONTACT: Bob Shillinger no. AGENDA ITEM WORDING: Approval of a resolution authorizing the waiver of the attorney client and work product privileges and the duty of confidentiality with respect to qualifying confidential communications with retired Senior Assistant County Attorney to allow her to testify in the matter of State of Florida v. Roman Gastesi, 24-CF-917-K. ITEM BACKGROUND: Ramon de la Cabada, the attorney defending former County Administrator Roman Gastesi, subpoenaed retired Senior Assistant County Attorney Cynthia Hall to testify at a deposition regarding her knowledge regarding the underlying facts of the employment investigation arising from the diversion of drugs from the Trauma Star program. Mr. Gastesi's handling of that investigation led the Grand Jury to indict him on one count of official misconduct. Mr. Gastesi has pled not guilty to the charge. His counsel is conducting discovery to prepare his defense. Ms. Hall testified regarding unprivileged matters during her deposition but asserted the attorney-client privilege as to certain qualifying communications. Mr. de la Cabada has requested that the attorney client and work product privileges be waived so he can finish Ms. Hall's deposition. Under the attorney-client privilege, conversations between a client or clients and their attorney are privileged in certain circumstances. The privilege belongs to the client, not the attorney so the attorney must assert it unless and until the client(s)waive the privilege. The work product privilege is related but distinct from the attorney client privilege. The work product privilege protects from disclosure information that is gathered in anticipation of litigation, as well as mental impressions, conclusions, opinions, and theories of counsel. The resolution also authorizes a waiver of Ms. Hall's duty of confidentiality under Rule 4-1.6 of the Florida Rules of Professional Conduct, which requires attorneys to keep the confidences of their clients. Ms. Hall participated in a conversation with Mr. Gastesi and county staff as part of the investigation into the theft of drugs from Trauma Star. She also participated in a separate conversation on the same 2646 topic with Commissioner Lincoln and Mr. Gastesi. As an organizational entity, the privilege is held by the organization as well as the individual participants. As the governing body for the organization, the BOCC is the entity which must waive the privilege to the extent it extends to the County as an entity. Each individual participating in the conversations will need to or has already waived the privilege with respect to himself or herself. The proposed resolution would, if passed, waive the attorney client privilege, the work product privilege, and release Ms. Hall from her duty of confidentiality with respect to matters related to Mr. Gastesi's criminal case. The waiver would permit Ms. Hall to testify at her continued deposition and at trial if called by either the prosecution or the defense. Counsel for prosecution and the defense have reviewed the draft resolution and been provided with an opportunity for input on its content. PREVIOUS RELEVANT BOCC ACTION: None. INSURANCE REQUIRED: No CONTRACT/AGREEMENT CHANGES: n/a STAFF RECOMMENDATION: Approval. DOCUMENTATION: Resolution authorizing the waiver of the attorney client and work product privileges and duty of confidentiality in Gastesi criminal case final ver.pdf FINANCIAL IMPACT: n/a 2647 MA� MONROE COUNTY, FLORIDA BOARD OF COUNTY COMMISSIONERS RESOLUTION NO. -2025 A RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA AUTHORIZING THE WAIVER OF THE ATTORNEY CLIENT AND WORK PRODUCT PRIVILEGES AND DUTY OF CONFIDENTIALITY ON BEHALF OF THE COUNTY AS AN ENTITY , WITH RESPECT TO CONFIDENTIAL COMMUNICATIONS WITH RETIRED SENIOR ASSISTANT COUNTY ATTORNEY CYNTHIA HALL TO ALLOW HER TO TESTIFY IN THE MATTER OF STATE OF FLORIDA V. ROMAN GASTESI, 24 - CF - 917 - K . WHEREAS, the County Commission, the County Administrator, and county staff are represented on county business by the Monroe County Attorney and the Assistant County Attorneys employed by the County Attorney's Office pursuant to Section 2-179(a) of the Monroe County Code; and WHEREAS, former County Administrator Roman Gastesi is the defendant in the matter of State of Florida v. Roman Gastesi, 24-CF-917-K which is pending in the 16t" Judicial Circuit of Florida; and WHEREAS, Mr. Gastesi, through counsel, is seeking to depose retired Senior Assistant County Attorney Cynthia Hall regarding conversations she participated in with Commissioner Michelle Lincoln, Mr. Gastesi, and county staff which are relevant to Mr. Gastesi's case, but which also qualify for protections under the attorney client privilege, work product doctrine, and confidentiality rules in the Florida Rules of Professional Conduct applicable to attorneys; and WHEREAS, during her initial deposition, Ms. Hall asserted the attorney- client privilege, work product doctrine, and confidentiality rules with respect to those conversations and declined to answer questions related to those conversations; and WHEREAS, Ms. Hall's deposition was continued so that the question of privilege could be resolved; and i 2648 WHEREAS, under F.S. 90.502, the attorney-client privilege belongs to the client, not the attorney, and WHEREAS, the "privilege extends not only to communications from a client, but also to statements made by an attorney to a client, because disclosure of an attorney's communications or advice to a client will effectively reveal the substance of the client's confidential communication." Cunningham v. Appel, 831 So.2d 214, 216 (Fla. 5t" DCA 2002); and WHEREAS, it is well settled that the attorney-client privilege exists for organizational clients such as the County Commission; see, Rogan v. Oliver, 110 So.3d 980, 983 (Fla. 2013), citing Upjohn Co. v. United States, 449 U.S. 383, 101 S.Ct. 677, 66 L.Ed.2d 584 (1981 ); and WHEREAS, the waiver of the attorney-client privilege for organizational clients requires the consent of that entity's governing body, i.e., the Board of County Commissioners; see Rogan, 110 So.3d at 983; and WHEREAS, because multiple people participated in the subject conversations, each party to those conversations must waive the attorney-client privilege; see, Cone v. Culverhouse, 687 So.2d 888, 889 (Fla. 2d DCA 1997) and Cunningham, 831 So.2d at 216; and WHEREAS, Rule 4-1 .6 of the Florida Rules of Professional Conduct, "a lawyer must not reveal information relating to a client's representation . . . unless the client gives informed consent"; see, Coffey-Garcia v. South Miami Hosp., Inc.,. 194 So.3d 533, 536 (2016); see also, Comment to Rule 4-1.6, R. Reg. The Fla. Bar; and WHEREAS, the work product doctrine protects information that is gathered in anticipation of litigation, as well as mental impressions, conclusions, opinions, and theories of counsel; and WHEREAS, under the work product doctrine, materials prepared in anticipation of litigation by or for a party or its attorney are protected from disclosure unless a party seeking disclosure demonstrates a need for the material and an inability to object to the substantial equivalent without undue hardship; and z 2649 WHEREAS, Mr. Gastesi's counsel has presented to the County Attorney that Ms. Hall's work product is necessary for him to prepare a proper defense of his client; and WHEREAS, the Board finds that waiving the attorney client privilege, the work product privilege, and releasing Ms. Hall from her duty of confidentiality serves the paramount public importance of transparency in County government; and WHEREAS, by adopting this resolution, the Board waives the attorney- client privilege, authorizes Ms. Hall to discuss matters covered by the work product doctrine, and also consents to releasing Ms. Hall from her duty of confidentiality with respect to her representation of the County as an entity to the extent necessary to answer counsels' questions at her deposition, at trial, and any related proceedings in 24-CF-917-K; and WHEREAS, the waivers of the attorney client privilege, work product privilege, and duty of confidentiality effectuated by this resolution shall be limited to Monroe County as an entity, and that individual participants in the subject conversations either have or will have to waive the privilege individually in addition to the Board's waivers. NOW THEREFORE, BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA THAT: 1. The above-stated recitations are incorporated as factual findings of the Board. 2. The Board expressly waives the attorney client privilege and work product privilege on behalf of Monroe County to the extent that those privileges extend to the County government as an entity. 3. The Board expressly releases retired Senior Assistant County Attorney Cynthia Hall from her duty of confidentiality under Rule 4-1.6 of the Florida Rules of Professional Conduct with respect to her representation of the County as an entity to the extent necessary to answer counsels' questions at her deposition, at trial, and any related proceedings in 24-CF-917-K. 4. The Clerk is directed to email a copy of this resolution to: • Assistant State Attorney Colleen Dunne via .cdur�ir�.�:�.. yea ssao.oirq. • Ramon de la Cabada, Counsel for Defendant Roman Gastesi, via : . ,araiiTy,rioinidcllacalk�ada.coiiTT'ri. 3 2650 PASSED AND ADOPTED at a regular meeting held on the 161h day of April, 2025 in Marathon, Florida. Mayor James K. Scholl Mayor Pro Tem Michelle Lincoln Commissioner Craig Cates Commissioner David Rice Commissioner Holly Merrill Raschein ATTEST: KEVIN MADOK, CLERK BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA By: As Deputy Clerk Mayor James K. Scholl Approved for form and legal sufficiency: Robert B. Shillinger, Jr. Monroe County Attorney 4 2651