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Item P01 March 2006 Litigation Report To: Mayor McCoy & County Commissioners From: Bob Shillinger, Asst. County Attorney /J'?~ S" Date: March 10,2006 cc: Tom Willi, County Administrator Suzanne Hutton, Interim County Attorney Summary Number of Cases New cases filed since last month 0 Cases closed since last report 1 CAY active cases 60 CAY Post Judgment cases 4 Potential cases not yet filed 6 Outside Counsel Cases 30 Airports Community Services Constitutional Officers Engineering Growth Management Miscellaneous Personnel Public Works Risk Management Total Cases pending 72 New Cases Cases Closed CAY Litigation Cases Trial & Appellate Level CAY Post Judgment Cases Potential Cases Outside Counsel Cases Ferencik, Libanoff (Ira Libanoff) (4 cases) 2 1 4 7 57 4 3 4 6 Page 2 2 2 15 16 18 18 Johnson, Anselmo, (Bruce Johnson & Michael Burke) (14 cases) 19 Paul, Hastings (Bob Freilich & Derek Howard) (3 cases) 24 The Smith Law Firm (Wayne Smith) (2 cases) 25 Vernis & Bowling (D.Smits, K.Willis & S.Black) (5 cases) 26 CASES FILED SINCE LAST MONTH'S REPORT -- NONE CASES CLOSED SINCE LAST MONTH'S REPORT Rodriauez. Vivian v. Monroe County. Islamorada. & DOT CA P 05-526 Circuit Court 16th Judge: Garcia Date Filed: 11/30/05 Action for negligence due to injuries on DOT right of way. Public Works/Risk Management RBS Current Status: PL voluntarily dismissed County & Village on 2/7/06. Next Activity: Closed. CAY Time: 8.5 Costs: 0.00 CAY LITIGATION - Trial & Appellate Level See Outside Counsel Section for Cases being Handled Jointly Ambrose. Thora et al v. Monroe County et al CA P 97-636 Circuit Court 16th Judge: Garcia Date Filed:12/11/97 Declaratory Judgment action claiming vested rights due to subdivision plats. Subsequent appeal of summary judgment order reversed and remanded. Growth Management/Planning JOS Current Status: Status inquiry with Judge's chambers pending. Next Activity: If needed, schedule hearing on Motion to Dismiss. M&H Billing to date: CAY Time: 1.0 $30,960.98. In re: Birch Telecom. Inc. 05-12237 PJW U.S.Bnktcy.Delaware Judge: Walsh Date Filed: 8/12/05 Bankruptcy action by pay phone vendor which claims it owes County $4.15 for providing pay phones on County property. Administrative ServiceslTechnical Services RBS Current Status: Claim deadline passed 11/4/05. County's interest $4.15. Next Activity: None. Time: 1.0 Costs: 0.00 2 In re: Meahan Cole Bankrtcy. S.D.Fla. Judge: Mark Bankruptcy action by tenant of County property. Bankruptcy 05-43879 RAM Date Filed: 10/17/05 County owed $760.00 in rent. RBS Current Status: County's interest too minimal to take more than passive stance. Next Activity: Final approval of plan or discharge. Time: 1.0 Costs: 0.00 Collins. C. & Sum Air Services v. Monroe County. et al CAM-05-146 Circuit Court 16th Judge: Payne Date Filed: 6/1/05 Declaratory judgment action regarding lease with FBO at Marathon Airport. Airports PJM Current Status: Awaiting service of complaint. Next Activity: Voluntary dismissal by the Plaintiff after settlement of companion case is finalized. Time: 0.5 hours 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: Awaiting service. Next Activity: Once served, determine if insurance coverage requires retaining outside counsel. Time: 0.6 hours Costs: 0.00 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: Notice of compliance filed. Next Activity: None at this time. Time: 4.8 hours Costs: 0.00 3 EEOC v. Monroe County EEOC - Miami Judge: N/A Charge of disability discrimination filed by an employee. Public Works/Personnel 150-2005-03773 Date Filed: 9/7/05 PJM Current Status: Negotiating conciliation dates. Next Activity: Conciliation to be scheduled. Time: 16.6 hours 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 County's brieffiled; case reassigned to Judge Payne. Next Activity: Await Court's decision. Time: 11.5 hours Costs: 0.00 Good. Llovd 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: Amended case management order filed. Next Activity: Drafting response to case management order. M&H Billing to date: $18,526.41 as of 10/31/05. CAY Time: 16.2 4 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 PJM Current Status: Status review on pending motions. Next Activity: Hearing on Motion to Dismiss, tba. M&H Billing to date:$1 0,241.57 thru 8/31/05. CAY Time: 2.5 Johnson. Lloyd v. Marlene Conaway CA K 02-1248 Circuit Court 16th Judge: Payne Date Filed: 10/30/02 Writ of Mandamus challenging Planning Director's determination that boundary determination by alleged error requires zoning map amendment. Growth Management/Planning JDS 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: counsel. Finalize motion for substitution of counsel of CAY for former M&H Billing to date: CAY Time: 1.0 $2,855.77 as of 8/31/05. 5 LaSalle Bank. N.A. v. Alexis & Jesus Victores & Monroe County CAP 05-373 Circuit Court 16th Judge: Garcia Date Filed: 8/29/05 Mortgage foreclosure action where County holds an inferior $1 00.00 lien. Growth Management/Code Enforcement RBS Current Status: Sale cancelled by plaintiff. Next Activity: Await reset or dismissal. Time: 2.0 hours Costs: 0.00 Mcintyre, Edward v. Richard Roth & Monroe County 80-1721-CIV-WMH US Dist. SOFia. Judge: Hoeveler Date Filed: 7/8/80 Civil Rights action filed again then Sheriff Freeman and County for inadequate jail facilities. Consent decree signed December 1991. Constitutional Officer/MCSO Current Status: Status conference held 3/3/6; Next Activity: MCSO report on alleged deficiencies due 4/17/6. CAY Time: 13.0 Costs: $86.77 (since March 2005) Monroe County v. R. Bernstein/Safe Harbor Marine Railway CAK-05-732 Circuit Court 16th Judge: Miller Date Filed: 7/26/05 Code enforcement lien foreclosure. Over $221,800.00. Growth Management/Code Enforcement RBS Current Status: OF's answer overdue. Next Activity: Move for default if no responsive pleading by 2/28/06. Time: 8.6 hours Costs: $576.00 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: County's motion for summary judgment denied. OF's answer overdue. Next Activity: Negotiations ongoing, move for default judgment by 4/1/06 jf not successful. Time: 6.8 hours Costs: $295.00 6 Monroe County v. Boy Scouts of America Circuit Court 16th Judge: TBA Code fine collection action authorized on 9/28/05. Growth Management/Code Enforcement CA K 06~139 Date Filed: 2/10/6 Fine fixed at $408,000.00. PJM Current Status: Defendant served 3/1/06 Next Activity: Response due 3/21/6. Time: 1.9 hours Costs: $276.00 Monroe County v. Alain Y. Depierrefeu CAK~03~1504 Circuit Court 16th Judge: Jones Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the SOCC on 4/18/03. Growth Management/Code Enforcement RBS Current Status: Negotiations ongoing. Next Activity: If unsuccessful, move for auction date. V & B Fees billed to date: None CAY Time: 6.6 Costs: 0.00 Monroe County v. Alain Y. Depierrefeu CAK~03~1507 Circuit Court 16th Judge: Jones Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the SDCC on 4/18/03. Growth Management/Code Enforcement RBS Current Status: same as previous entry. Next Activity: If negotiations unsuccessful, move to schedule auction. V&B Fees billed to date: None CAY Time: 3.5 hours Costs: 0.00 7 Monroe County v. Jack HaaoDian CAP 03-529 Circuit Court 16tn Judge: Garcia Date Filed: 10/1/03 Code enforcement collection action authorized by SOCC on 8/20/03. Fine exceeds $300,000.00 as of 1/1/6 and accruing at $250.00 per day. Growth Management/Code Enforcement RBS Current Status: Settlement agreement and check received. Next Activity: Monitor status of compliance. Time: 42.5 hours Costs: $801.70 Monroe County v. Dorothy Houah. et al CAP-05-160 Circuit Court 16tn Judge: Garcia Date Filed: 4/6/05 Code enforcement collection action authorized by SOCC on 9/17/03. Fine fixed @ $61,000. Growth Management/Code Enforcement RBS Current Status: Motion to compel discovery. Next Activity: Hearing 4/5/6. Time: 12.1 hours Costs: $596.00 Monroe County v. James JeanQuenat Circuit Court 16th Judge: Garcia Collection action authorized by SOCC on 4/21/04. Growth Management/Code Enforcement CAP-05317 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. Key Larao Ocean Resorts COOD. 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 Current Status: Development agreement application being reviewed. Next Activity: Status report due with the Court 4/1/06. Time: 41.5 hours Costs: $340.00 8 Monroe County v. Pedro Liz CAK-05-420 Circuit Court 16th Judge: Jones Date Filed: 4/22/05 Collection action authorized by SDCC on 7/17/03; fines exceed $816,300.00. Growth Management/Code Enforcement RBS Current Status: Motion for default by court filed. Next Activity: Hearing on County's motion for default 4/12/06. Time: 9.0 hours Costs: $555.00 Monroe County v. Mary Ellen Lloyd CAM-03-362 Circuit Court 16th Judge: Jones Date Filed: 12/19/03 Code enforcement foreclosure action authorized by the SDCC 4/18/03. The total amount of the lien owed to the County is $143,500.00. Growth Management/Code Enforcement RBS Current Status: Clarifying double filing by prior counsel. Next Activity: Draft settlement agreement with Defendant. V&S Fees billed to date: None Costs: 0.00 CAY Time: 2.3 hours Monroe County v. Arthur Mehr CAP-05-348 Circuit Court 16th Judge: Garcia Date Filed: 8/5/05 Code fine collection action. Fine exceeds $42,000.00. Growth Management/Code Enforcement RBS Current Status: Motions to compel discovery filed. Next Activity: Hearing 4/5/6. Time: 8.1 hours Costs: $850.00. 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 SDCC 4/18/03. Growth Management/Code Enforcement RBS Current Status: Discovery process Next Activity: Discovery. V & B Fees billed to date: None CAY Time: 3.0 Costs: 0.00 9 Monroe County v. Outland Properties CAP-05.400 Circuit Court 16th Judge: Garcia Date Filed: 9/9/5 Collection action authorized by SDCC on 10/17/04. Fine over $225,000.00. Growth Management/Code Enforcement PJM Current Status: Defendant served. Next Activity: Discovery. Time: 1.6 hours Costs: 300.00 Monroe County v. Joe Posada. III CAK-03-1503 Circuit Court 16th Judge: Payne Date Filed: 12/18/03 Code enforcement foreclosure action authorized by the SDCC 4/18/03. Growth Management/Code Enforcement RBS Current Status: Settlement negotiations pending. Next Activity: If unsuccessful, April 2006 bench trial. V & B Fees & Costs billed to date: CAY Time: 4.6 hours None. Monroe County v. Virainia 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 SDCe 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 10 Monroe County v. Virainia Sawyer CAK-03-1506 Circuit Court 16tn Judge: Jones Date Filed: 12/18/03 Gode enforcement foreclosure action that was authorized by the SOGe 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 16tn Judge: Jones Date Filed: 6/14/04 Code enforcement foreclosure action that was authorized by the SOCC 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 CA P 02-141 Circuit Court 16tn Judge: Garcia Date Filed: 3/13/02 Appeal of code enforcement action and vested rights claim. Growth Management/Code Enforcement/Planning JDS 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 O'Oaniel & Hill v. Monroe County Third DCA Judges: TBA Appeal of circuit court decision in CA P 02-141. Growth Management/Code Enforcement/Planning 30-05-583 Date Filed: 3/18/05 JOS Current Status: Mandate issued 12/27/05. Next Activity: None. Close file. M&H Billing to date: CAY Time: 1.5 See tria/level report. 11 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: Briefs completed. Next Activity: counsel. Finalize motion for substitution of counsel of CAY for former M&H Billing to date: CAY Time: 0.5 $123,563.24. Neumont, Elizabeth et a!. 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 Current Status: Awaiting decision of the Court. Next Activity: Finalize motion for substitution of counsel of CAY for former counsel. Billing to date: $123,565.49 as of 8/31/05 (by former outside counsel). CAY Time: 0.5 Nunziante. Maril*n v. Monroe County CAK-04-1227 Circuit Court 16t Judge: Jones Date Filed: 11/18/04 Suit challenging Bayshore's rule requiring family members to subsidize residents. Community Services/Social Services RBS Current Status: PL has passed away. Next Activity: County's motion to dismiss to be heard 3/23/06 at 4:30 pm. Time: 76.7 hours Costs: 0.00 12 Sierra Club. et al v. DCA. Miami Dade & City of Homestead 03-150-GM DOAH Judge: Maloney Date Filed: 1/17/03 County intervened in administrative challenge to amendment of Miami-Dade's compo plan redesignating Krome Avenue to a major roadway (3 or more lanes). Growth Management/Planning JDS Current Status: Proposed Recommended Order filed 2/3/6. Next Activity: Await ruling by ALJ. Billing to date: None, pro bono. (by former outside counsel). CAY Time: 6.0 Teal. Kimberly & Keith v. Michael Angel. Monroe County. et al CAM-04-404 Circuit Court 16th Judge: Payne Date Filed: 12/16/04 Declaratory judgment action over road in City of Marathon. Public Works/Roads and Bridges PJM Current Status: Discovery. Settlement negotiations ongoing. Next Activity: County's motion to dismiss TBA pending negotiations. Time: 9.5 hours Costs: $133.00 Troy. Daniel Scott v. Monroe County Circuit Court 16th Judge: Jones Mandamus action seeking after the fact building permits. Growth Management/Planning CAK 05-856 Date Fi led: 8/24/05 RBS Current Status: On appeal in 3D 05-2419. Next Activity: None while on appeal. Time: 2.0 hours Costs: 0.00 Troy. Daniel Scott v. Monroe County Third DCA Judges: TBA Appeal of denial of writ of mandamus in CA K 05-856. Growth Management/Planning 3D 05-2419 Date Filed: 10/7/05 RBS Current Status: Troy given until 3/23/06 to file his brief. Next Activity: Draft reply to Troy's brief whenever it arrives. Time: .7 Costs: 0.00 13 Walareens & Gadinskv v. Monroe Countv CAK-05-266 Circuit Court 16th Judge: Taylor Date Filed: 3/11/05 Cert. review of DOAH order upholding 1/6 findings supporting denial of major conditional use application for Big Pine Walgreens. Growth Management/Planning RBS Current Status: Negotiations ongoing. Next Activity: Finalize agreement and present to BOCC & Court for OK. Time: 33.8 hours Costs: $318.57 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 Ch11 case where County might have a claim against the estate. Bankruptcy RBS Current Status: Could find no basis for filing proof of claim. Next Activity: None needed. Time: 0.9 hours Costs: 0.00 14 CAY POST JUDGMENT CASES Evans. Brian v. Monroe County. et al 04.CIV.10033~JLK U.S.Dist.,S.D.Fla. (Miami)Judge: King Date Filed: 5/6/04 Money Judgment of $4,579.00 in favor of County & MCSO for rule 11 sanctions. Constitutional Officer/MCSO RBS Current Status: $4,579.00 in fees awarded to County & MCSO. Next Activity: Collection. CAY Time: 9.5 hours Costs: 0.00 Monroe County v. William L. Davis CAP.04~181 Circuit Court 16tn Judge: Garcia Date Filed: 4/15/04 Money judgment of $27,600.00 for unpaid code enforcement fines and costs. Growth Management/Code Enforcement RBS Current Status: Final judgment of $28,431.00 recorded wi Dept. of State. Next Activity: Collection. Time: 6.2 hours Costs: $56.00 Monroe County v. Dan Gleason SCP~03.165 County Court (Sm. Claims) Judge: ptomey Date Filed: 8/5/03 Money judgment of $520.00 for unpaid code enforcement fines and costs. Growth Management/Code Enforcement RBS Current Status: Final judgment recorded wI Dept. of State. Next Activity: Collection. Time: 9.5 hours Costs: $65.92 Monroe County v. Lilv Marks CAK~03~1152 Circuit Court 16tn Judge: Jones Date Filed: 10/2/03 Money judgment of $795,270.00 for unpaid code enforcement fines and costs. Growth Management/Code Enforcement RBS Current Status: Final judgment entered for $795,270.00 on 5/9/05. Next Activity: Collection. Time: 8.5 hours Costs: $55.00 15 POTENTIAL CASES THAT HAVE NOT YET BEEN FILED 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: Seeking BOee authorization to intervene 3/15/06. Next Activity: If authorized, file motion to intervene and set for a hearing. Time: 1.1 Costs: 0.00 Calusa Campground Condo v. Monroe County. at al., CA P 06 TBA Circuit Court (16th) Judge: Date Filed: Threatened action by condominium resulting from statements regarding platting requirements by Growth Management personnel. Growth Management/Planning JDS Current Status: Investigating claim and assisting Growth Management Division in preparation of responses to claimant. Next Activity: Awaiting claimant's filing proper subdivision plat for approval. Time: 2.5 Costs: 0.00 Good. L10vd v. Monroe County CAK-05-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: Settlement discussions underway. Next Activity: None. Stayed during Good's application for major conditional use. Time: 8.6 hours Costs: $5.56 16 Hamelton. Charles v. KWRU & Monroe County CA K 04-740 Circuit Court (16th) Judge: Miller Date Filed: 7/6/04 Potential personal injury claim by scooter accident victim and/or utility seeking damages from the County. Handled jointly with Johnson, Anselmo. Public Works/Roads and Bridges/Risk Management RBS Current Status: County not a party at this time. Next Activity: Deposition of County witnesses 3/17/06. Fees Billed to Date: 0.00 CAY Time: 6.7 Costs: 0.00 Monroe County v. Estate of Thomas O'Brien SCK-05-TBA Small Claims Monroe Judge: TBA Date Filed: Action against estate to collect unpaid ambulance bill of $861.81. Probate case is CP K 05-164. Emergency Services/EMS RBS Current Status: Settlement agreement signed. Next Activity: Awaiting court approval and payment. Time: 3.2 Costs: 0.00 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. Public Safety/Fire Rescue RBS Current Status: Waiting for AG's office to set up conference. Next Activity: Settlement conference with State. Time: 9.2 hours Costs: 0.00 17 CASES BEING LITIGATED BY OUTSIDE COUNSEL Ferencik, Libanoff, Brandt, Bustamante and Williams, P .A. Monroe County v. Bender & Associates, et al CAK-03-915 Circuit Court 16tn 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: Discovery ongoing. Next Activity: Discovery ongoing. Fees billed to date: $89,487.00 Costs: $10,829.09 (thru 12/31/5) Monroe County v. Jose Gonzalez CA K TBA Circuit Court 16tn Judge: TBA Date Filed: TBA Possible breach of contract action against County's former architect. Engineering/Construction Management RBS Current Status: Discussions with Gonzalez Next Activity: Schedule meeting with staff & Gonzalez. Fees billed to Date: CAY Time: 12.5 $10,145.00 Costs: $872.33 (thru 12/31/05) Monroe County v. Lodae Construction, et 31 CAK-00-617 Circuit Court 16tn Judge: Payne Date Filed: 5/11/00 Suit filed against general contractor Lodge Construction & its surety for breach of contract to build Gato Building. Engineering/Construction Management RBS Current Status: Trial preparations. Next Activity: Trial reset from April 2006 until future date. Fees billed to date: $298,065.26 Costs: $71,523.31 (thru 12/31/05). 18 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: County filed motion to dismiss on 3/6/6. Next Activity: BDCC to approve Libanoff contract 3/15/6. Billing Received to date: none. CAY Time: 1.1 Costs: 0.00 Johnson, Anselmo, Murdoch, Burke, Piper, & McDuff, P.A. Bauknight. Ska~s & Rockett v. Monroe County CAP-04-451 Circuit Court 16tl 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 Bauknight. Skaggs & Rockett v. Monroe County 04-CV-1 01 05 U.S. D.C. S.Fla. Judge: Moore Date Filed: 11/1/04 Inverse condemnation/takings case by owners of 3 Big Pine lots. Growth Management/Planning RBS Current Status: All but fees remanded to State Court. Denial of fees motion appealed to 11th Circuit. Next Activity: None. Fees billed to date: None Costs: 0.00 19 Baukniaht. et al. v. Monroe County 05-10868-F 11th Cir. Ct. of Appeals Judge: 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/Planning RBS Current Status: Briefs completed; oral argument held 12/9/05. Next Activity: None; await decision of Court. Fees billed to date: None. Costs: 0.00 Florida Key Deer v. Michael Brown & Gale Norton 90-10037-CIV-Moore U.S. Dist. Ct., SO 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: Case closed: Dismissed with prejudice Next Activity: Billing to Date: none CAY Time: 33.8 Costs: 0.00 Florida Key Deer. et al v. R.D. Paulson. et al 11th Circuit Judges: TBA Appeal of Southern District's injunction in 90-10037-CIV. Growth Management/Planning 05-16374-11 Date Filed: 11/10/05 RBS Current Status: Jurisdiction briefs requested by Court. Next Activity: File jurisdiction briefs. Billing to date: CAY Time: none 0.5 Costs: 0.00 20 Monroe County v. Florida Key Deer. et al 05-16990-11 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: Preliminary jurisdiction questions pending. Next Activity: Draft briefs. Billing to Date: None CAY Time: 0.5 Florida Key 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 Hyland. Thomas G. v. D. Kolhage & R. Thurston 04-101 02-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: Kolhage filed motion to dismiss. Next Activity: Await ruling from Court on Kolhage's Motion to Dismiss. CAY Time: 2.8 Fees & Costs billed to date: $5,207.12 21 FKCC & Last Stand v. FL Admin. Comm.. Monroe County DOAH 04-2756 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 6/29/05. 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 Countv. et al 3005-1800 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: Appellant's brief filed. Next Activity: County & DCA's brief deadline extended until after disposition of Marathon's motion to dismiss. Fees billed to date: none CAY Time: 0.5 hours Costs: 0.00 Hardee. Evelvn 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 RBS Current Status: PL Deposition for 3/6/6 reset for May 2006. Next Activity: Depositions 4/25-6/06 Fees billed to date: $5694.33 (thru 1/31/06). CAY Time: 8.9 hours 22 Kessler. Stuart v. Monroe County & Tom Willi CA K 05.1006 Circuit Court 16th Judge: Jones Date Filed: 10/11/2005 Complaint for injunctive relief and damages under Whistle-Blower Act, Civil Rights Act, defamation and interference with business relationship. Personnel/Risk Management RBS Current Status: County moved to dismiss Kessler's second amended complaint 2/1/6. Next Activity: Hearing on motion to dismiss, 4/11/06. Fees & Costs billed to date: CAY Time: 28.6 $11,554.97 (thru 1/31/6) Kessler. Stuart v. Monroe Countv & Tom Willi 3005.2755 Third DCA Judges: TBA Date Filed: 11/28/05 Appeal of non-final order denying Kessler's petition for temporary reinstatement. Personnel/Risk Management RBS Current Status: County filed appellate brief 2/2/6. Next Activity: Kessler response brief due 2/13/06. Billing to date: see CA K 05-1006 CAY Time: 2.0 Costs: 0.00 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: Discovery. Next Activity: Discovery. Fees billed to date: $2,326.92 CAY Time: 5.8 hours Costs: 0.00 23 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 DSE subcontractor. Risk Management/Airport/MCSO PJM Current Status: Discovery. Next Activity: Discovery. Fees billed to date: $743.86 CAY Time: 4.5 hours Costs: 0.00 Paul, Hastings (Bob Freilich & Derek Howard) 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: Post summary judgment hearing briefs being completed. Next Activity: Court's ruling on County's motion for summary judgment. Total Fees billed to date: $830,901.46 (thru 1/18/06) CAY Time: 150.8 hours Costs: $87,482.06 Emmert. Helen & Grea v. Monroe County Circuit Court 16th Judge: Garcia Inverse condemnation and vested rights action. Growth Management/Planning CA P 02-520 Date Filed: 10/2/02 RBS/JDS Current Status: Motion to dismiss pending. Next Activity: Hearings on MC's Motion to Dismiss & PL M4 SJ 3/13/6; soce to hear settlement offer on 3/15/6. P, H Billing to date: M&H Billing to date: CAY Time: 10.5 None $94,550.56 as of 10/31/05 24 Galleon Bay Y. Monroe County Y. 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: Summary judgment as to liability granted 1/30/06. Next Activity: Await ruling on County's motion for rehearing. M & H Billing to date: Paul, Hastings Billing: CAY TIME: 56.5 $221,709.88 thru 10/31/05. $162,385.00 Costs: $1,009.16 The Smith Law Firm Monroe County v. Post Buckley. Schuh. and Jerniaan CAK-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. Engineering RBS Current Status: Settled remaining issue. Next Activity: Close file once dismissed by Court. Fees & Costs billed to date: $645,606.54 (doesn't include PBSJ fees paid of $282,745.01) Monroe County v. Post Buckley. Schuh. and Jerniaan 3005-1822 Third DCA Judges: TBA Date Filed: 8/1/05. Appeal of judgment in the above case. Engineering RBS Current Status: Dismissed by stipulation 3/8/6. Next Activity: Close file after final bill paid. Fees billed to date: see previous entry. 25 Vernis & Bowling of the Florida Keys, P.A. GAP Properties of SW Florida-I. Inc. v. Monroe County CAK-04-1321 Circuit Court 16th Judge: Jones Date Filed: 12/10/04 Cert. review of action involving failure to obtain plat approval of dock subdivision and an improper change of use without a major or minor conditional use permit. Growth Management/Planning RBS Current Status: Certiorari denied, rehearing motion denied. Settlement discussions ongoing. Next Activity: Present settlement proposal to SOCC on 3/15/6. Fees billed to date: $26,875.00 Costs: $306.43 Gap Properties of SW Florida-I, Inc. v. Monroe County 3005-2413 Third DCA Judges: TBA Date Filed: 10/14/5 Second tier certiorari appeal of denial of petition challenging County's plat approval rules for dockominiums, see CA K 04-1321 below. Growth Management/Planning RBS Current Status: County's amended motion to dismiss pending. Next Activity: Ruling on motion; settlement discussions pending. Fees billed to date: see trial level Costs = None Kev Tex S. D. Condo Assoc. v. Monroe County & T. McGarry CAK-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. Growth Management/Planning RBS Current Status: Motion to dismiss pending; settlement discussions ongoing. Next Activity: Settlement proposal to be presented to SOCC on 3/15/6; Hearing on motion to dismiss reset to 4/20/6. Fees billed to date: $32,290.50 Costs: $2,540.84 26 Osborn. Jeff v. Monroe County CAP-04-564 Circuit Court 16ln Judge: Garcia Date Filed: 11/24/04 1 of 2 certiorari petitions challenging development approval of Northstar project. Growth Management/Planning RBS Current Status: Court denied petition 12/14/05. Next Activity: None pending appeal. Fees billed to date: $14,039.50 Costs: $261.49 Osborn. Jeff v. Monroe County Third DCA Judges: TBA Certiorari appeal of CA P 04-564 on Northstar Project. Growth Management/Planning 3006-52 Date Filed: 1/11/06 V & B handling. RBS Current Status: Motion to dismiss filed. Next Activity: Await ruling on Motion to Dismiss Billing received to date: see billings for CA P 04-564. Osborn. Jeff v. Monroe County CAP-04.565 Circuit Court 16ln Judge: Garcia Date Filed: 11/24/04 2 of 2 certiorari petitions challenging development approval of Northstar project. Growth Management/Planning RBS Current Status: Oral argument held 12/15/05. Next Activity: Await decision of Court. Fees billed to date: $3,920.50 Costs: $146.93 Assigned Assistant County Attorney PJM = Pedro Mercado JDS = Jerry Sanders RBS = Bob Shillinger 27