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Item P01 Memorandum To: Mayor Spehar & County Commissioners From: Bob Shillinger, Asst. County Attorney Date: June 12, 2005 Re: June 2005 litigation report Cc: Tom Willi, County Administrator Richard Collins, County Attorney CASES FILED AGAINST THE COUNTY SINCE LAST MONTH'S REPORT Collins. C & Sum Air Services v. Monroe County et al CA M 05-146 Circuit Court 16th Judge: Payne Date Filed: 6/1/05 Declaratory Judgment action regarding lease with FBO at Marathon Airport. Not yet served. Airports Status: Awaiting service of complaint. Next Activity: Once served, determine if outside counsel should be retained. Time: 0.1 Costs: 0.00 Hardee. Evelyn v. Monroe County Circuit Court 16th Judge: Garcia Negligence action that has not been served yet. CA P 05-255 Date Filed: 6/3/05 Status: Awaiting service of complaint. Next Activity: Once served, determine if referral to insurance carrier counsel is appropriate. Time: 0.1 Costs: 0.00 Thomas. David v. Monroe County CA K 05-499 Circuit Court 16th Judge: Garcia Date Filed: 5/16/05 Appeal of Contractor's Examining Board decision that has not been served yet. Growth Management/Building Status: Awaiting service of complaint/petition/notice of appeal. Next Activity: File responsive pleading. Will be handled in house. Time: 0.1 Costs: 0.00 In re: Winn Dixie Stores. Inc. 05-03817 -3F1 U.S. Bankruptcy Ct., M.D.Fla. Judge: Jerry Funk Date Filed: 2/25/05 Voluntary Chapter 11 reorganization case where County might have a claim against the estate. Current Status: claim. Reviewing pleadings and investigating whether County has Next Activity: Proof of claim deadline 8/1/5. Time: 0.1 Costs: 0.00 CASES CLOSED SINCE LAST MONTH'S REPORT Moore. Russell v. Monroe County CA P 04-452 Circuit Court 16th Judge: Garcia Date Filed: 9/24/04 Mandamusllnverse condemnation/takings case filed for one lot on Big Pine. Mayor served on 10/4/4. Growth Management Status: Dismissed by Plaintiff with Prejudice. Next Activity: Close file. Total fees and costs paid: $2,304.29 Stevenson. MK v. Monroe County CA K 02-257 Circuit Court 16th Judge Payne Filed: 2/26/02 Appeal of a finding that Caribbean Village storage sign was an off premises sign. Current Status: Court issued Corrected Mandate May 26,2005, affirming most of Code Enforcement Special Magistrate's decision, reversing small portion. Next Activity: Close file. Time: 33.0 hours Costs: none 2 GENERAL LITIGATION Clay. Robert Leefi John & Li ChiunQ Moyant v. Monroe County CA M 04-05 Circuit Court 16t Judge: Jones Date Filed:01/05/04 Mandamus Petition/takings case regarding Big Pine properties. Mayor served 1/8/04. Growth Management. Status: Court approved settlement agreement. Next Activity: Awaiting dismissal by Petitioners. Time: 7.4 Costs: None Collins. Thomas et al v. Monroe County Circuit Court 16th Judge: Payne Takings action brought by 11 groups of plaintiffs. Growth Management; CAY co-counsel with Bob Freilich & Tyson Smith CA M 04-379 Date Filed: 11/22/04 Status: Discovery. Next Activity: Motion to compel discovery 6/21/05. Time: 74.5 Costs: 0.00 DrewinQ. Janice v. Monroe County Third DCA Judges: TBA Date Filed: Appeal of denial of writ of mandamus in personnel matter. Community Services/Social Services 3D 04-3044 11/29/04 Current Status: Awaiting decision by Court. Next Activity: Awaiting decision by Court. Time: 31.4 Costs: 15.00 DrewinQ. Janice v. James Roberts as County Administrator CA K 04-686 Circuit Court 16th Judge: Jones Date Filed: 6/25/04 Mandamus action seeking hearing in personnel dispute between plaintiff and her supervisor Louis Latorre. Community Affairs/Social Services Current Status: Drewing appealed Circuit's denial of writ to Third DCA. Next Activity: Stayed pending appeal. Time: 19.5 Costs: 0.00 3 Evans. Brian v. Monroe County 04-CIV-10033-JLK U.S.Dist.,S.D.Fla. (Key West) Judge: King Date Filed: 5/6/04 Civil action against the County, and others, arising from actions of Sheriff's office in publicizing the rescission of a warrant it had obtained for his arrest. MCSO Current Status: Evans appealed to 11 th Circuit Court's award to County & Sheriff of $4579.00 in attorney's fees for filing frivolous suit. Next Activity: Collection not stayed by appeal. Time: 9.5 Costs: 0.00 Fed. Nat'l MortQ. Assoc. v. M. Coleman. Monroe County. et al. CA K 05-171 16th Circuit Judge: Jones Date Filed: 2/18/05 Mortgage foreclosure case where County holds an inferior interest to bank due to $1928 in Article V liens imposed against a person claiming interest in the property. Mayor served 2/28/05. PJM Current Status: Bank's motion for summary judgment granted 4/25/05. County's answer filed @ 3/21/05. County's lien preserved. Next Activity: Sale set for mid June 2005. Time: 2.5 Costs: 0.00 Florida Keys Citizens Coalition v. State & Monroe County DOAH 04-2756 DOAH Judge: Carolyn Holifield Date Filed: 08/05/04 Administrative Rule challenge to agreement with State. Growth Management Current Status: Proposed final orders submitted 1/28/05. Next Activity: Awaiting decision by Administrative Law Judge. CAY Time: 178.6 See also entry under Johnson, Anselmo, et al. Monroe County v. Florida Detroit Diesel SC K 05 -60 County Court (Sm. Claims) Judge: Fowler Date Filed: 3/14/05 Collection action seeking reimbursement for $4,905.00 in clean up costs associated with improperly installed machinery. PJM Fleet management/Risk Management Current Status: Discovery. Next Activity: Trial July 18, 2005. Time: 5.8 Costs: $275.00 4 Monroe County v. Mark FraleiQh CAP 03-647 Circuit Court (16th) Judge: Garcia Date Filed: 12/8/3 Ejectment action against owner of structures located on County right-of-way. Public Works. Current Status: Discovery ongoing. Next Activity: Move for summary judgment. Time: 20.7 Costs: NONE Neuman. Kenneth v. Monroe County CA K 04-663 Circuit Court 16th Judge: Jones Date Filed: 6/21/04 Action for damages and to compel County to issue building permits for property on Big Pine. County settled similar suit in April. Mayor served 6/25/04. Growth Management CAY serving as co-counsel. Status: Discovery phase. Next Activity: Discovery. CAY Time: 5.8 See also entry under Johnson, Anselmo, et al. Nunziante. Maril*n v. Monroe County CA K 04-1227 Circuit Court 16t Judge: Jones Date Filed: 11/18/04 Suit over admission practices at Bayshore Manor seeking to invalidate practice of requiring family members to subsidize those who can't afford the full rate. Community Services/Social Services; Mayor served 11/19/04. Status: Answer filed, discovery. Next Activity: Depositions to be set. Time: 58.6 Costs: 0.00 PBP Marina. Inc. v. Monroe County CA K 02-561 Circuit Court (16th) Judge: Payne Date Filed: May 2002 Cert. Petition appeal from denial of rezoning on Geiger Key Marina. Growth Management Current Status: 4/20/05, BOCC granted rezoning request. Next Activity: Await dismissal by Plaintiff. Time: 29.0 Costs: none to date 5 Riverview Consultants. Inc. v. Monroe County CA K 05-373 Circuit Court 16th Judge: Jones Date Filed: 4/13/2005 Tortious interference with contract case arising from Airport security director's termination of a consultant subcontract. PJM Ai rport Status: Plaintiff gave mandatory 6 month notice of claim on April 8, 2005. Next Activity: File responsive pleading once served. Time: 3.0 Costs: 0.00 See also entry under Johnson, Anselmo, et al. Teal. Kimberly & Keith v. Michael AnQel. Monroe County. et al CA M 04404 Circuit Court (16th) Judge: Payne Date Filed: 12/16/04 Declaratory judgment action by property owners seeking half of a road purportedly abandoned by County and then quitclaimed to City of Marathon which was subject of litigation in 2002. Public Works Status: Depositions held 4/18/05. Next Activity: Hearing on County's motion to dismiss 6/28/05. Time: 9.2 Costs: $133.00 Tuttle. David. Peter Rosasco & Harley Evans v. Monroe County CAM 04-243 Circuit Court 16th Judge: Payne Date Filed: 6/30/04 Action for damages and to compel County to issue building permits for property on Big Pine. County settled similar suit in April. Growth Management Status: Settled; 3 of 4 releases issued. Next Activity: Dismissal if DCA doesn't object to permits. Time: 3.0 Costs: 0.00 6 WalQreens & Gadinsky v. Monroe County CA K 05-266 16th Circuit Judge: Taylor Date Filed: 3/11/05 Petition for certiorari review of DOAH administrative order upholding 1 of 6 findings supporting denial of major conditional use application for redevelopment of Big Pine Scotty's into Walgreens. Mayor served 5/2/05. Growth Management Current Status: Motion to Quash summons pending. Next Activity: Hearing set 8/1/05. Time: 7.3 Costs: 0.00 POTENTIAL CASES THAT HAVE NOT BEEN FILED Lloyd Good v. Monroe County CA K 05 ----- Circuit Court (16th) Judge: Date Filed: On 11/24/03, the County was served with notice of a claim under the Bert J. Harris Act regarding two parcels of property owned by Lloyd Good. Growth Management. Current Status: Settlement discussions underway. Next Activity: conditional use. None. Stayed during Good's application for major Time: 8.6 hours Costs: $5.56 Harum. James v. Monroe County. DOH. & Z. Krstic CA P 05 TBA Circuit Court (16th) Judge: Date Filed: Threatened action for injunctive relief to compel County to prosecute code enforcement violation against Zivadin Kristic by his neighbor James Harum. County had already scheduled the code enforcement hearing for May 2005 prior to receiving notice of suit. Statute requires 30 days notice prior to filing action. Current Status: Underlying code case held 5/26/05, mitigation plan in effect. Next Activity: Move to dismiss and for sanctions if filed since w/o merit. Time: 2.4 Costs: $0.00 7 State of Florida v. Monroe County TBA TBA Judge: TBA Date Filed: n/a Threatened action by AG's Medicaid Fraud unit regarding alleged over billings for ambulance services for advanced life support services vis a vis basic life support services. Current Status: After not hearing from state for over a year, AG is proposing negotiated agreement on how to bill future services in exchange for a dismissal of all prior disputed billings. Next Activity: Settlement conference with State. Time: 9.2 Costs: 0.00 CODE ENFORCEMENT APPEALS Decker. Harry v. Monroe County 3D05-305 Third DCA Judges: TBA Date Filed: 2/14/05 Appeal of circuit court's decision upholding Code Enforcement Special Magistrate's decision finding property owner in violation of OSTDS ordinance. Growth Management/Code Enforcement Status: Court denied Decker's Petition for Writ of Certiorari 5/17/05. Next Activity: None - remanded to Circuit Court. Time: 7.2 Costs: 15.00 Decker. Harry v. Monroe County Circuit Court 16th Judge Payne This is an appeal of a code enforcement OSTDS case. CA K 01-1252 Date Filed: 10/5/01 Current Status: Decision affirmed by Third DCA on 5/17/05. Next Activity: Issue mandate to Code Enforcement Special Magistrate. Time: 19.0 hours Costs: none 8 Eads. Barbara v. Monroe County CAP 03-117 Circuit Court 16th Judge Garcia Date Filed: 2/27/03 This is a code enforcement appeal of the special master's order finding the Lowe House to be in unsafe condition and setting forth a compliance schedule. Status: Appeal stayed pending review by HPC. Next Activity: Status check 6/1/05. Time: 3.6 hours Costs: none Fuchs. WalburQa v. Monroe County Circuit Court (16th) Judge Miller This is a code enforcement appeal of an OSTDS case. CA K 01-1251 Date Filed: 10/5/01 Current Status: The County's brief filed. Next Activity: Await Court's decision. Time: 11.5 hours Costs: none Monroe County v. Lanes. GeorQe & Denise CA M 04-310 Circuit Court (16th) Judge: Jones Date Filed: 9/15/04 Appeal of decision regarding elevation requirements for replacement structure. PJM Current Status: Oral argument and briefs completed. Next Activity: Awaiting decision by the Court. Time: 10.0 hours Costs: none 9 CODE ENFORCEMENT FORECLOSURES/COLLECTIONS Monroe County v. Mario Alfonso CA K 03-1458 Circuit Court (16th) Judge: Jones Date Filed: 12108/03 Code enforcement foreclosure action authorized by the BOCC on 6/18/03. Fine fixed at $91,450.00. Current Status: 6/2/05. Settlement check $15,920.55 sent to code enforcement Next Activity: File dismissal, then close file. Time: 25.7 hour Costs: $151.70 Monroe County v. Matthew Bonnett CA K 05 TBA Circuit Court (16th) Judge: TBA Date Filed: TBA Code enforcement lien collection action authorized 10/17/04. PJM As of 5/1/5, $150/day fine exceeded $78,000.00. Current Status: Demand letter prepared. Next Activity: Serve demand letter. Time: .5 Costs: 0.00 Monroe County v. Dirk Damrau CA K 05 (TBA) Circuit Court (16th) Judge: (none yet) Date Filed: Code enforcement foreclosure action authorized by the BOCC 6/18/03. Fine was $169,900.00 as of 7/18/03 and accruing at $200.00 per day. Current Status: Compliance achieved. Next Activity: File suit. Time: 2.2 hour Costs: none to date 10 Monroe County v. William L. Davis CA P 04-181 Circuit Court (16th) Judge: Garcia Date Filed: 4/15/04 Action to collect $27,600.00 code enforcement fine from former owner of property who fraudulently sold property to innocent owner. OF in Federal prison. Current Status: Final Judgment of $28,431.00 entered 4/13/05. Next Activity: Record Judgment with State, collection. Time: 6.2 hour Costs: $21 .00 Monroe County v. Reinaldo DelQado & Lourdes Nunez CA P 05 TBA County Court (Civil) Judge: ptomey Date Filed: TBA Collection action authorized by BOCC on 6/16/04. Fine set at $6600.00. Current Status: BOCC to consider releasing lien on 6/15/05. Next Activity: Status check 6/16/5. Time: 2.2 Costs: 0.00 Monroe County v. Dan Gleason SC P 03 - 165 Small Claims Court Judge: ptomey Date Filed: 8/5/03 Small claims action for a money judgment to collect $520.00 in unpaid code enforcement fines and costs authorized by the BOCC in April of 2003. Current Status: Final judgment registered w/ Dept. of State. Next Activity: Continue w/ enforcement proceedings. Time: 9.5 hours Costs: $65.92 Monroe County v. Marshall Golnick CC K 05-86 County Court Judge: Fowler Date Filed: 3/21/05 Collection action authorized by BOCC on 6/16/04. Fine set at $11,300.00. Current Status: Settled for $8000.00 in 3 monthly payments. First payment received on time. Next Activity: OF to make 2 more payments on 6/30, & 7/31/05. Time: 10.0 Costs: $575.00 11 Monroe County v. Jack HaQopian. CA P 03-529 Circuit Court (16th) Judge: GARCIA Date Filed: 10/1/03 Code enforcement collection action authorized by BOCC on 8/20/03. Fine was $203,100.00 as of 9/30/03 and accruing at $250.00 per day. Current Status: 3d Party OF motion to dismiss denied. Next Activity: Hearing on summary judgment motion. Time: 14.7 Costs: $20.00. Monroe County v. Dorothy HouQh. et al. CA P 05-160 Circuit Court (16th) Judge: Garcia Date Filed: 4/6/05 Code enforcement collection action authorized by BOCC on 9/17/03. As of 9/25/3 lien valued at $25,050.00 and accruing at $50.00 per day. Current Status: Two DFs served answer on 6/1/05; Discovery pending. Next Activity: Diane's Interrogatory Answers overdue. Time: 5.6 Costs: $330.00 Monroe County v. James JeanQuenat CA P 05 ------------ Circuit Court (16th) Judge: Date Filed: Code Enforcement collection action authorized by BOCC on 4/21/04. As of that date, the fine was $136,100.00 and accruing at $500.00 per day. Current Status: Negotiating with owner. Next Activity: Status check 6/1/05. Time: .7 Costs: none Monroe County v. Key LarQo Ocean Resorts CooP. Inc. CA P 96-260 Circuit Court (16th) Judge Garcia Date Filed: 5/20/96 This is an action to foreclose a code enforcement lien. Current Status: Revised development agreement application being reviewed by Growth Management. Next Activity: Status report due with the Court 7/1/05. Time: 36.6 hours Costs: $340.00 12 Monroe County v. Pedro Liz CA K 05 420 Circuit Court (16th) Judge: Jones Date Filed: 4/22/2005 Code enforcement collection action authorized by BOCC on 7/17/03 & 9/17/03. Total fines as of 4/27/05, $816,300.00. Current Status: Complaint filed. Next Activity: Serve OF. Time: 3.2 Costs: $555.00 Monroe County v. Jean M. Louis & Itnor Corp. CA K 05 TBA Circuit Court (16th) Judge: TBA Date Filed: TBA Code enforcement lien collection action authorized by BOCC on 10/17/04. Fine set at $34,200.00. PJM Current Status: Owners not complying with settlement agreement approved by BOCC on 4/20/05. Next Activity: File foreclosure action if not resolved. Time: 1.5 Costs: 0.00 Monroe County v. Lily Marks Circuit Court (16th) Judge: Jones Collection action of 2 code enforcement liens. amount of $795,270.00. CA K 03-1152 Date Filed: 10/2/3 Final Judgment entered in the Current Status: Final judgment entered for $795,270.005/9/05. Next Activity: Collection, if not appealed by 6/13/05. Time: 8.3 Costs: $20.00 Monroe County v. Arthur Mehr (TBA) Circuit Court (16th) Judge: (none yet) Date Filed: TBA Code enforcement foreclosure action that was authorized by the BOCC 6/18/03. Fine had reached $28,380 on 7/18/03 and continues to accrue at $20 per day. Current Status: Title search complete. Next Activity: File suit. Time: 2.1 hour Costs: $150.00 13 Monroe County v. Blair & Althea Mooney Circuit Court (16th) Judge: TBA Date Filed: Code lien collection action authorized by BOCC on 10/17/04. Fine fixed at $146,100.00. CA K TBA TBA PJM Current Status: Negotiating with owners' counsel. Next Activity: Presentation of settlement offer at June BOCC meeting. Time: .5 hour Costs: $0.00 Monroe County v. Outland Properties CA P 05 TBA Circuit Court (16th) Judge: Garcia Date Filed: TBA Code lien collection action authorized by BOCC on 10/17/04. As of 5/1/05, $500 daily fine exceeded $225,000.00. PJM Current Status: Demand letter drafted. Next Activity: Serve demand letter. Time: .5 hour Costs: 0.00 Monroe County v. RodriQuez. Federico et al CA K TBA Circuit Court (16th) Judge: TBA Date filed: TBA Code lien collection action authorized by BOCC on 10/17/04. PJM Current Status: $7,500 settlement approved by BOCC 4/20/05. Next Activity: Finalize paperwork, then close file. Time: 1.5 hours Costs: 0.00 Monroe County v. Safe Harbor Marine Railway Corp. CA K 05 (TBA) Circuit Court (16th) Judge: (none yet) Date Filed: Code enforcement foreclosure action that was authorized by the BOCC 6/18/03. As of 1/1/4, lien totaled $106,700.00. Current Status: Title search complete. Next Activity: Draft complaint. Time: 1.5 hour Costs: none to date 14 CASES BEING LITIGATED BY OUTSIDE COUNSEL (other than Morgan & Hendrick) Ferencik, Libanoff, Brandt, Bustamante and Williams, P.A. Monroe County v. Bender & Associates. et al CA K 03 915 Circuit 16th Judge: Jones Date Filed: 8/4/03 Suit filed against Bender & Associates, D.L. Porter Constructors, Inc., Security Impact Glass Holdings, L. L. C., and Preservation Services, Inc. for breach of contract and negligent misrepresentation arising from the defective design, fabrication, and/or installation of the windows in the Gato building. Status: Discovery ongoing. Next Activity: Hearing on motion to dismiss 6/29/05. Fees billed to date: $45,121.00 Costs: $5,675.68 Monroe County v. LodQe Construction. et al. CA K 00-617 Circuit 16th Judge: Payne Date Filed: 5/11/2000 Suit filed against general contractor Lodge Construction & its surety for breach of contract to build Gato Building. Status: Reserved on appeal November 24,2004. New trial granted. Mandate issued 2/16/05. Next Activity: Set for trial. Fees billed to date: $298,015.26 Costs: $71,523.81 Bob Freilich & Tyson Smith Collins. Thomas et al v. Monroe County Circuit Court 16th Judge: Payne Takings action brought by 11 groups of plaintiffs. Growth Management CA M 04-379 Date Filed: 11/22/04 Status: Discovery. Next Activity: Motion to compel discovery hearing 6/21/05. Fees billed to date: To be provided. 15 Johnson, Anselmo Murdoch Burke & George BaukniQht. Ska~s & Rockett v. Monroe County CA P 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 Status: Federal Court remanded to state court. Next Activity: Action on hold pending appeal in 11 th Circuit. Fees billed to date: $832.24 Costs: 0.00 BaukniQht. SkaQQs & Rockett v. Monroe County 04 CV 10105 U.S. D.C. S.Fla. Judge: Moore Date Filed: 11/1/04 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 Status: Federal Court remanded to state court. Attorney's fee motion appealed to 11th Circuit Next Activity: None. Fees billed to date: none Costs: 0.00 BaukniQht. et al. v. Monroe County TBA 11th Cir. Ct. of Appeals Judges: TBA Date Filed: 2/11/05 Appeal of denial of attorney's fees motion filed against the County by takings case plaintiffs. County had removed the case to Federal Court; plaintiffs sought remand and attorneys fees. Case was remanded to state court but fees denied. Plaintiffs are seeking between $15,000 and $18,000 in fees. Growth Management Status: Briefs completed. Next Activity: Awaiting Court's decision. Fees billed to date: None. 16 Florida Keys Citizens Coalition v. State & Monroe County DOAH 04-2756 DOAH Judge: Carolyn Holifield Date Filed: 08/05/04 Administrative Rule challenge to agreement with State to fund purchases of environmentally sensitive lands, provide permits for workforce housing, etc; CAY serving as co-counsel. Growth Management Status: Recommended final order filed 1/28/05. Next Activity: Awaiting decision of Court. Fees billed to date: $59,464.92 Neuman. Kenneth v. Monroe County CA K 04-663 Circuit Court 16th Judge: Jones Date Filed: 6/21/04 Action for damages and to compel County to issue building permits for property on Big Pine. CAY serving as co-counsel. Growth Management Status: Discovery. Next Activity: Discovery. Fees billed to date: $2,326.92 Riverview Consultants. Inc. v. Monroe County CA K 05-373 Circuit Court 16th Judge: Jones Date Filed: 4/13/2005 Tortious interference with contract case arising from Airport security director's termination of a consultant subcontract. League of City's carrier counsel. Ai rportlM CSO Status: Plaintiff gave mandatory 6 month notice of claim on April 8, 2005. Next Activity: File responsive pleading once served. Fees billed to date: none. 17 Purdy, Jolly & Giuffreda, P.A. Evans. Brian v. Monroe County 04-CIV-10033-JLK U.S.Dist.,S.D.Fla. (Miami) Judge: King Date Filed: 5/6/04 Civil action against the County, and others, arising from actions of Sheriff's office in publicizing the rescission of a warrant it had obtained for his arrest. MCSO Current Status: Court awarded County & Sheriff $4579.00 in attorney's fees against Evans for filing frivolous suit & denied Evan's motion to stay enforcement of judgment pending appeal. Next Activity: Collection. Fees billed to date: none Costs: 0.00 Evans. Brian v. Monroe County. et al. CIV S 04-1042 LRH U.S. D.C. Nevada Judge: Jones Date Filed: 7/28/04 Same allegations as prior case which were brought in Nevada. MCSO Current Status: Evans has appealed dism issal by Court. Next Activity: None while case is on appeal. Fees billed to date: none Costs: 0.00 Evans. Brian v. KW Citizen. Monroe County. et al CV S 04-1742-KJD-LRL U.S. D.C. Nevada Judge: Dawson Date Filed: 1/6/2005 Defamation suit over alleged misstatements by Mark Willis in the Citizen. MCSO Status: Evans dismissed case on 2/11/05. Evans states he will refile. Next Activity: Await service. Fees billed to date: none Costs: 0.00 Evans. Brian v. MCSO. Monroe County. et al. 04-17429 9th Circuit Court of Appeals Judges: TBA Date Filed: 12/09/2004 Appeal of Nevada Court's dismissal of suit in CIV S 04-1042 LRH. Status: Briefs completed. Next Activity: Await decision by Court. Fees billed to date: none Costs: 0.00 18 Evans. Brian v. MCSO. Monroe County. et al. 05-10077-B 11th Circuit Court of Appeals Judges: TBA Date Filed: 1/5/2005 Appeal of award of attorney's fees against Evans for filing a frivolous lawsuit. MCSO Status: Briefs completed. Next Activity: Await decision by Court. Fees billed to date: none Costs: 0.00 The Smith Law Firm Monroe County v. Post Buckley. Schuh. and JerniQan CA K 95-402 Circuit Court (16th) Judge: Payne Date Filed: 3/30/95 Malpractice claim against the County's former engineering firm for miscalculation of bonds necessary to finance improvements to Card Sound Road. Public Works Current Status: Trial began 6/6/05. Next Activity: Verdict. Fees billed to date: To be provided. Vernis & Bowling of the Florida Keys, P.A. GAP Properties of SW Florida-I. Inc. v. Monroe County CA K 04-1321 Circuit Court (16th) Judge: Payne Date Filed: 12/10/2004 Certiorari review of administrative action involving dock failure to obtain plat approval due to subdividing and an improper change of use without a major or minor conditional use permit. Growth Management Status: Pleadings completed. Next Activity: Oral argument 10/1/5 at 11 a. m. Fees billed to date: $25,595.00 Costs: $250.00 19 Key Tex S. D. Condo Assoc. v. Monroe County & T. McGarry CA K 04-224 Circuit Court (16th) Judge: Jones Date Filed: 3/2/04 Action to prevent County from denying permits because of ownership conversion to condominiums and compel County to accept permit applications that have been rejected MCC 9.5-49. Growth Management Status: Only 1 of 5 counts remain. Next Activity: Hearing for Motion for a More Definite Statement 6/21/5. Fees billed to date: $32,290.50 Costs: $1,831.69. Monroe County v. Mary Boza. CA K 03-1508 Circuit Court (16th) Judge: Jones Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the BOCC on 4/18/03. Current Status: Default judgment entered 5/11/05; owner to make presentation for settlement at June 15, 2005 BOCC meeting. Next Activity: Sale set for July 2005. Fees billed to date: none. Monroe County v. Alain Y. Depierrefeu. CA K 03-1504 Circuit Court (16th) Judge: Jones Date Filed: 12/18/2003 Code enforcement foreclosure action authorized by the BOCC on 4/18/03. Current Status: Clerk's default entered on 3/21/05. Next Activity: Hearing on final default judgment continued to 6/21/05. Fees billed to date: none. Monroe County v. Alain Y. Depierrefeu. CA K 03-1507 Circuit Court (16th) Judge: Jones Date Filed: 12/18/2003 Code enforcement foreclosure action authorized by the BOCC on 4/18/03. Current Status: Clerk's default entered on 3/21/05. Next Activity: Hearing on final default judgment continued to 6/21/05. Fees billed to date: none. 20 Monroe County v. Mary Ellen Lloyd. CA M 03-362 Circuit Court (16th) Judge: Jones Date Filed: 12/19/03 Code enforcement foreclosure action authorized by the BOCC 4/18/03. The total amount of the lien owed to the County is $143,500.00. Current Status: Compliance achieved 8/31/2004. Next Activity: Settlement negotiations complicated by OF's health issues. Fees billed to date: None. Monroe County v. James Messera. et al CA K 03-1509 Circuit Court (16th) Judge: Payne Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the BOCC 4/18/03. Current Status: Owners working on compliance. Next Activity: Moving forward with foreclosure. Fees billed to date: none. Monroe County v. Joe Posada. III CA K 03-1503 Circuit Court (16th) Judge: Payne Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the BOCC 4/18/03. Current Status: Settlement unproductive. Next Activity: Proceed with foreclosure. Fees billed to date: none. Monroe County v. VirQinia Sawyer & Tony Welters CA K 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. Current Status: Attorney for some of Defendant's negotiating settlement. Next Activity: Publication to serve remaining DFs. Fees billed to date: none. 21 Monroe County v. VirQinia Sawyer CA K 03-1506 Circuit Court (16th) Judge: Payne Date Filed: 12/18/03 Code enforcement foreclosure action that was authorized by the BOCC 7/15/03.. Current Status: Attorney for the defendants negotiating settlement. Next Activity: Publication to serve remaining DFs. Fees billed to date: none. Monroe County v. Louis Welters CA K 04-639 Circuit Court (16th) Judge: Jones Date Filed: 6/14/2004 Code enforcement foreclosure action that was authorized by the BOCC 7/15/03. Current Status: Attorney for the defendants negotiating settlement. Next Activity: Publication to serve remaining DFs. Fees billed to date: None. Osborn. Jeff v. Monroe County CAP 04-564 Circuit Court 16th Judge: Garcia Date Filed: 11/24/04 1 of 2 certiorari petitions challenging development approval of Northstar project. Growth Management. Status: Pleadings complete. Next Activity: Oral argument set for 9/12/05 @ 8:45 a.m. Fees billed to date: $10,013.50 Costs: $60.00 Osborn. Jeff v. Monroe County CAP 04-565 Circuit Court 16th Judge: Garcia Date Filed 11/24/04 2 of 2 certiorari petitions challenging development approval of Northstar project. Growth Management. Status: PLs granted leave to refile petition by 6/10105. Next Activity: Respond to amended petition, if filed. Fees billed to date: $1,932.00 Costs: 0.00. 22