HomeMy Public PortalAboutBrannon Transcript 7/14/1611
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO. 2014 -CA -006112 -AG
CITIZENS AWARENESS FOUNDATION, INC.,
Plaintiff,
v.
THE TOWN OF GULF STREAM;
BRANNON & GILLESPIE, LLC,
Defendants.
- - - - - - - - - - - - - - - - - - x
DEPOSITION OF DANNY BRANNON
TAKEN ON BEHALF OF THE PLAINTIFF
Thursday, July 14, 2016
Town Hall
100 Sea Road
Gulf Stream, Florida
10:05 a.m. - 11:40 a.m.
Reported by Felecia Curreri, RPR
Notary Public, State of Florida
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 APPEARANCES ON BEHALF OF THE PLAINTIFF
2 The O'Boyle Law Firm, P.C.
1286 West Newport Center Drive
3 Deerfield Beach, Florida 33442
BY: JONATHAN O'BOYLE, ESQUIRE
4 Tel: (954)570-3501
Email: joboyle@oboylelawfirm.com
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APPEARANCES ON BEHALF OF THE DEFENDANTS
9
Jones Foster Johnston & Stubbs, P.A.
10 505 South Flagler Drive
Suite 1100
11 West Palm Beach, Florida 33401
BY: JOANNE M. O'CONNOR, ESQUIRE
12 Tel: 561-659-3000
Email: joconnor@jonesfoster.com
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 I N D E X
2 TESTIMONY OF DANNY BRANNON Page
3 Direct Examination by Mr. O'Boyle 4
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(No Exhibits Marked)
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S T I P U L A T I O N S
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It is hereby stipulated and agreed by and
11 between counsel present for the respective parties,
and the deponent, that the reading and signing of
12 the deposition are hereby reserved.
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 THE COURT REPORTER: Do you swear or
2 affirm that the testimony you are about to
3 give will be the truth, the whole truth, and
4 nothing but the truth?
5 THE WITNESS: Yes.
6 Thereupon --
7 DANNY BRANNON
8 was called as a witness by the Plaintiff and,
9 having been first duly sworn, testified as follows:
10 DIRECT EXAMINATION
11 BY MR. O'BOYLE:
12 Q. Mr. Brannon, good morning. My name is Jon
13 O'Boyle. This is a deposition in a case of
14 Citizens Awareness Foundation versus Town of Gulf
15 Stream and Brannon & Gillespie.
16 Have you ever been deposed before?
17 A. Yes.
18 Q. Okay. So I'll just run down a couple of
19 things and if I don't say anything that's clear,
20 you can ask me for clarification. If you need to
21 take a break at any time, just let me know. I
22 don't expect us to be here very long, so I'll just
23 let you keep that in mind.
24 Let's see here. For the record, since
25 this is being transcribed, answers like uh-huh or,
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1 you know, those sort of colloquial answers, that we
2 need something more clear for the record.
3
Okay. So let's just get right into it.
4
Tell me what you know about this case and
5
I can
let you look at the pleadings if you want.
6
A.
This case is pursuant to a request for
7
public
records.
8
Q.
Okay. And do you know if this -- let me
9
ask this.
Do you know why you are involved in this
10
case?
11
A.
We are a contract for the Town.
12
Q.
Okay.
13
A.
And as such, particularly have current
14
public
records.
15
Q.
And as a contractor, can you please, for
16
the record, just tell the record, I guess, what the
17
contract is for? It doesn't make sense when we
18
bring up the records request.
19
A.
We coordinate activities relative to the
20
undergrounding of the overhead utilities facilities
21
in the
Town.
22
Q.
Okay. Is that referred to as the
23
underground utility project?
24
A.
Correct.
25
Q.
Okay. And I've heard in Town meetings.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 All right.
2 Is that the only thing that Brannon &
3 Gillespie does for the Town?
4 A. We have done other projects for the Town.
5 Q. Okay. And just for the record, you're
6 Mr. Danny Brannon and I apologize if I'm using your
7 informal first name. I don't know you by any other
8 name. And your relationship?
9 A. Danny Brannon, managing member of Brannon
10 & Gillespie, LLC, 631 U.S. Highway 1, Suite 301,
11 North Palm Beach, Florida.
12 Q. And you are the Town's engineer?
13 A. We are the -- that coordinates the
14 project. We have professional engineers that do
15 various tasks. We have utility company engineers
16 that also work with us.
17 Q. Okay. So Brannon & Gillespie, do they
18 hold an appointed position or is it strictly by
19 contract?
20 A. Contract.
21 Q. Okay. Now, let me ask, can you tell me a
22 little bit about Brannon & Gillespie? I'm looking
23 for how big it is, the number of employees, the
24 staff, generally what the resources are.
25 A. We have a staff of one.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 Q. Okay.
2 A. We have two owners and a staff of one and
3 I'm the staff of one.
4 Q. Are you also an owner?
5 A. Yes.
6 Q. Okay. So are there three people?
7 A. No, two owners and I'm one of the owners
8 and I am also the only participating working person
9 in the company.
10 Q. Okay. And so is Brannon and Gillespie a
11 general contractor that subcontracts or are they a
12 manager of subcontractors?
13 A. We have some subcontractors on occasion
14 for specialty things, so we're both producers and
15 coordinators depending on what we have to do.
16 Q. Okay. So the underground electric
17 project, which has been referred to in Town
18 meetings and various Town documents, you are not
19 the only person out there performing that work,
20 there are other people and where I'm going with
21 this is, who are these other people? What is your
22 relationship to workers, because where I'm
23 ultimately going here is, I'm trying to figure out
24 where the public records come from.
25 A. We work with Florida Power and Light.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 my part. I can say that we do not keep
2 originals of any of the contracts or what the
3 records that they would need ongoing. As to
4 whether they keep those or what they do with
5 them, I couldn't say. I'm not the keeper of
6 their file.
7 BY MR. O'BOYLE:
8 Q. Sure. Sure.
9 Okay. But you send them copies of
10 important documents regarding this project?
11 A. I send them the originals.
12 Q. Okay. So you might not know whether they
13 have them or not, but you at some point send them a
14 majority of the responsive documents?
15 MS. O'CONNOR: Objection.
16 THE WITNESS: I send them everything that
17 is addressed to the Town. I don't know what
18 the majority of --
19 BY MR. O'BOYLE:
20 Q. Sure, sure. I'm talking about the
21 underground electric projects, so I don't want to
22 be confusing at all, but when I say the documents,
23 you made statements earlier that you send the --
24 A. Yes.
25 Q. -- copies or you forward them and I just,
Daughters Reporting, Inc.
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1 you know, wanted to get a sense for what was being
2 forwarded and what wasn't being forwarded.
3 A. In other jurisdictions we are involved in
4 more aspects and there are horrendous number of
5 aspects in those other jurisdictions that we are
6 involved in that we weren't here. So I could not
7 say what their volume of records would be. I can
8 only state that for those that we get, we forward
9 them to the Town with the exception of probably
10 some day-to-day emails with the utilities or the
11 contractors.
12 Q. So let me ask you this. For this project,
13 what type of email program do you use?
14 A. Use the Outlook.
15 Q. Okay. Do you have a folder for the emails
16 related to this underground electric project?
17 A. Yep.
18 Q. Okay. Is it possible or was it possible
19 back then to forward, to download that folder and
20 then just send it to the Town?
21 A. We couldn't do that. We would have to go
22 through and make sure that we were responsive to
23 the specificity of the request and there may be
24 communication in there that shouldn't have been put
25 into that folder, so we have to go through the
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Fort Lauderdale, Florida 954-755-6401
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1 folder and look at everything that we are sending.
2
Q.
Sure. Now, let me ask this. If you sent
3
the -- if
you downloaded the folder and sent it to
4
the Town,
couldn't the Town perform that work when
5
they go
through the box?
6
A.
No.
7
Q.
And why not?
8
A.
Because they would not the know the
9
context
of notes that has the specific information
10
and that
it tells you that this is about the
11
undergrounding
project or this is about going
12
fishing
next week, so we have to look at the notes
13
and see
what these notes were about.
14
Q.
Okay. Are there some that are on their
15
face referred
to the underground electric project?
16
A.
Sure.
17
Q.
Okay. And I'm asking, because this is a
18
particular
folder that you have just for this
19
project?
20
A.
No.
21
Q.
No, it isn't?
22
A.
I have a folder for the Town.
23
Q.
Okay.
24
A.
All projects done for the Town.
25
Q.
And I don't think I've asked you point
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1 blank, but what is the
complete
lists of projects
2 that were occurring in
2014 and
prior, not in the
3 last two years.
those have not
19
4 A. I can't tell you off the top of my head.
5 I have to go look.
6 Q. So they were not major projects?
7 A. Most of them were minor projects.
8 Q. Okay. Do you know generally what type of
9 work was being done or were you managing?
10 A. Example would be the ADA ramps in the
11 back. We did the design for those.
12 Q. Okay.
13 A. That was one project. I would have to go
14 through the folder and --
15 Q. Okay. But nothing as large as the
16 underground electric project?
17
A.
No.
18
Q.
And the hard files, could
those have not
19
just been
delivered to the Town for
them to sort
20
through?
21
A.
No. Like the request was
for not just the
22
documents
that are easy to find, what
the request
23
was for,
the documents.
24
Q.
Sure. And then I'm trying
to figure out
25
if there
were piles of okay, here is
a box full of
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1 things, I'm Mr. Brannon, I don't have, you know,
2 it's not worth my time, let me give it to the Town
3 and let them sort it out, I am just holding their
4 records.
5 A. Typically not. We may throw things in
6 there that are from, what I'll call, design
7 documents that really don't have anything to do
8 with the Town's project. But, for instance, if you
9 were doing something on ADA and you downloaded from
10 accessibility code from the state building codes
11 and you were looking at stuff and you threw this
12 copy of this manual in the box, because you were
13 just going through to check it and make sure your
14 design were compliant with the codes, but the code
15 really didn't have anything to do with the project.
16 Q. Right.
17 A. It's like throwing my national -- or like
18 an engineering code book in the box. It's really
19 not anything to do with the project, it's something
20 we kept together with that because we had
21 referenced it in what we were doing.
22 Q. Sure. And to sort of speed this process
23 up, I'm looking for what you could have given to
24 the Town and what you feel that you had to sort
25 through yourself. So in the form of a question;
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 what documents do you feel like or groups of
2 documents that you could have just given to the
3 Town for them to sort through to find which
4 documents were responsive?
5 A. None.
6 Q. None at all?
7 A. No.
8 I've had situations where people have had
9 piles of documents and I've sat in meetings and
10 have them go through these piles of documents and
11 90 percent of them had nothing to do with, but they
12 had no idea, so they were assuming everything had
13 something to do with what we were dealing with and
14 that is unacceptable, and the request asked for
15 certain documents to be delivered and we have to go
16 through and make sure we're complying with that
17 request and not the extraneous information and
18 unrelated information.
19 Q. Would it be easier to just include some of
20 the extraneous information?
21 A. No.
22 Q. How so?
23 A. Because by the time it gets misunderstood
24 and misused in trying to get it cleared up is an
25 intense, trying situation. So we need to comply
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 with the request as presented.
2 Q. Okay. So if there was just a clerical
3 error and a couple of emails relating to something,
4 I don't know, different, another one of the Town's
5 projects were produced, you're saying that that
6 would be problematic, that would be more work than
7 going through and being absolutely precise in
8 calling every single extraneous document?
9 A. We want to comply with the request. We
10 are of the opinion that the documents that we
11 provide are the documents that were compliant with
12 the request. Any document that is not compliant
13 with the request that gets stuck in the delivery is
14 misinformation, misleading. We don't want to do
15 that.
16 Q. Okay. And are you the person that would
17 make the call what is responsive and not
18 responsive?
19 A. Right.
20 Q. You would be?
21 A. Yes.
22 Q. Okay. Do you know who Rita Tailor is?
23 A. Town clerk.
24 Q. Okay. Would she be giving input at all to
25 what is responsive and what is not responsive?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1
A.
No.
2
Q.
Okay. So I just want to understand that
3
when this
request comes in, and it related to
4
records
that you had in your possession, as I
5
understand --
6
A.
(Nods head).
7
Q.
Is that a yes?
8
A.
Right. Correct.
9
Q.
And the Town told you in so many words or
10
you understood that the Town told you, here is the
11
request,
it's now Mr. Brannon, it's your
12
responsibility
to figure out what is responsive and
13
what's not
responsive?
14
A.
Correct.
15
Q.
Okay. And there was no conversation about
16
handing
over the documents in bulk and letting the
17
Town go
through the documents?
18
A.
I couldn't do that.
19
Q.
But the Town did already have some of the
20
documents
that were responsive?
21
MS. O'CONNOR: Objection.
22
THE WITNESS: I can't -- I can't tell you
23
what
the Town had or didn't have.
24
BY MR. O'BOYLE:
25
Q.
Sure. Sure. Sure. But you sent them --
Daughters Reporting, Inc.
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1 A. Right.
2 Q. -- at some point?
3 A. Right.
4 Q. Okay. So if you were on vacation, then
5 this request would be very difficult to fulfill, it
6 would be impossible; is that true?
7 A. I don't know. I haven't taken a vacation
8 in a number of years. When you are a one-man shop,
9 there's nobody to hand things off to, so you don't
10 go on vacation very much.
11 Q. Okay. Did the Town at all offer to send
12 any staffers over to help you sort through the
13 documents? Was there any plans or contingency?
14 A. No.
15 Q. So the entirety of the conversation was
16 here is the request, and I'm paraphrasing, but here
17 is the request, you have to respond to it and only
18 you have to respond to it, can you give us an
19 estimate?
20 MS. O'CONNOR: Objection.
21 THE WITNESS: The request was, here is the
22 request, please provide an estimate.
23 BY MR. O'BOYLE:
24 Q. Okay. So it was implied that you would be
25 the one responding to the request or did somebody
Daughters Reporting, Inc.
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1 tell you you need to respond to this request?
2 A. I have responded to these requests before,
3 so I am aware it's my responsibility.
4 Q. And that's just by a course of conduct,
5 custom, just how you operate, you and the Town?
6 A. No, that's a matter of doing business with
7 a governmental agency.
8 Q. Can you clarify that a little bit? What
9 do you mean by that?
10 A. The statutes indicate that a contractor
11 doing business with a governmental agency should
12 consider himself to be an arm of the agency and
13 responsive to all public records requests.
14 Q. Okay. So you understand then that you --
15 I'm sorry, that Brannon & Gillespie has to
16 independently respond to this request without the
17 help of the Town?
18 A. We are responding on our behalf to the
19 request. We are responsible for the response.
20 Q. Okay.
21 A. The Town is not capable of determining
22 what the context was for all the documents.
23 Q. When you say the context, can you tell me
24 a little bit more about that? Maybe an example if
25 you can think of one where the Town would not know
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Fort Lauderdale, Florida 954-755-6401
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1 that this document is responsive and that it would
2 require your assistance?
3 A. John Lear Communications relative to an
4 acceptance of a field change.
5 Q. Because the person involved, John Lear, is
6 involved in the underground electric and that would
7 be on the micro level that only you would know
8 about and nobody from the Town?
9 A. Right. Could be Hollywood, could be
10 Pompano, could be Gulf Stream, could be Palm Beach,
11 could be any number of projects.
12 Q. Okay. Because you -- let me back up here.
13 Do you perform engineering services for other
14 jurisdictions?
15 A. We perform these same kind of services
16 we're doing here in other municipalities.
17 Q. And when I said engineering, am I
18 misstating something, am I confused, do you not do
19 engineering or is it something more specific?
20 A. We do engineering and project management
21 type services for coordination of activities
22 relative to undergrounding projects.
23 Q. Okay. When you say relative to
24 underground projects, is that the specialty of the
25 firm?
Daughters Reporting, Inc.
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1 A. That's our predominant activity.
2 Q. So you're working with, I guess, the same
3 and I'll call them subcontractors or associates,
4 but you are working with the same affiliates from
5 project to project? And I'm sorry, that was a
6 question, so just for the record.
7 A. Typically, several projects, FPL has one
8 contact statewide. Comcast has Palm Beach County,
9 Martin County, St. Lucie County and then they have
10 others in Broward. ATT has different contacts, but
11 we would typically be working with these utilities
12 in multiple projects.
13 Q. So when you have a contact or
14 subcontractor or an affiliate in 2014, you had
15 contacts that were working on multiple projects for
16 you that did not involve the Town of Gulf Stream?
17 A. I will have to go through that particular
18 time frame to see exactly who was, what projects we
19 were working on in that time frame.
20 Q. Okay. So I guess what I'm saying, it's
21 possible that you had John Lear that was --
22 A. Right.
23 Q. -- working on this project and that
24 project and I guess my question would be, why
25 would, if you have a folder in Outlook, wouldn't
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Fort Lauderdale, Florida 954-755-6401
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1 that folder have everything related to the Town of
2 Gulf Stream?
3 A. It may have other emails that were swept
4 into that folder inadvertently.
5 Q. Okay. Just as a clerical --
6 A. Right.
7 Q. -- mishap perhaps?
8 Okay. We're all talking about the same
9 thing, that sometimes things get filed mistakenly?
10 A. Right.
11 Q. Okay. Now, I see here that there are
12 approximately 4,000 electronic project files and
13 some 3,500 emails. Do you remember ever saying
14 that that was responsive, that's the amount of
15 responsive documents?
16 MS. O'CONNOR: Objection.
17 Can you state for the record what you are
18 looking at when you say I see here?
19 MR. O'BOYLE: Oh, sure. This is the
20 answers to interrogatories of July 25th.
21 BY MR. O'BOYLE:
22 Q. I'll just show you here. I see about --
23 A. Yes, generally sounds correct as I
24 recollect it.
25 Q. Actually, if you don't mind, well, I can
Daughters Reporting, Inc.
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1 ask you a
2
So were there any hard files I guess that
3
needed --
because I'm seeing electronic files and
4
we were
talking about hard files and is everything
5
that's in
a hard file also in an electronic file?
6
A.
No.
7
Q.
Okay. Would there be hard files that
8
would be
responsive?
9
A.
I'm sure there would.
10
Q.
Okay. Now, do you know and this is, of
11
course,
in February 2014 time frame, but do you
12
know who
was working in the Town, who was
13
responding,
who was dealing with public records
14
requests?
15
A.
Today?
16
Q.
No, no, back in 2014.
17
A.
No.
18
Q.
Okay. And if I said Town clerk,
19
Ms. Tailor,
do you know if she was working on any
20
requests
--
21
A.
I don't know.
22
Q.
-- at the time?
23
Okay. So there was nobody -- a public
24
records
person from the Town that would contact you
25
and say
I'm responsible for public records?
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1 A. I don't know how the responsibilities here
2 are delegated. I got the email on this request
3 from one of the administrative people. I do not
4 know what the structure of responsibility was
5 within the Town. Typically, you get contacted by
6 people, you don't know if that's their
7 responsibility or something that's been handed to
8 them or somebody else is really in that position.
9 So I do not have a chart with responsibilities and
10 job descriptions.
11 Q. Okay. And let me ask this. Your hourly
12 rate in 2014, can you tell me what that was, with
13 regard to the Town of Gulf Stream?
14 A. I believe it was 185. I would have to
15 verify that, but I seem to recall that it was 185.
16 Q. Okay. Around that area. All right.
17 In your contracts with the Town, when I
18 say contracts, let me ask, are there -- are all
19 your contracts with the Town written or are there
20 unwritten modifications, like oral modifications?
21 A. They are written.
22 Q. Okay. So you don't do anything that's on
23 an oral contract basis?
24 A. No.
25 Q. In your contracts, do you contemplate
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 public
records responses? When
I say public
2 records
responses, your time for
responding to
3 public
records.
No. State contracts?
4
A.
No.
5
Q.
Okay. Do you have any state contracts?
6
A.
No. State contracts?
7
Q.
Yes, contracts with a state agency --
8
A.
No.
9
Q.
-- or a -- okay.
10
So you've never run into the law which for
11
the state
level which says there must be a public
12
records clause in the contract?
13
A.
No.
14
Q.
Okay. And you've never had any government
15
agency in
Florida on any level talk to you about a
16
public records
or put any sort of public records
17
provision
in any contracts?
18
A.
We have no public record provisions, but
19
we have a
compensation clause. We have some
20
contracts
that have advisories as to responsibility
21
for public
records compliance.
22
Q.
Okay. And I'm asking if there was
23
anything
that potentially either was discussed,
24
noted in
a contract about a duty to store public
25
records,
or a duty to provide public records, or in
Daughters Reporting, Inc.
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1 the event that you might have
to provide
public
2 records, would your rate stay
the same,
would your
3 compensation fluctuate, would
it change
based upon
4 the nature of the service?
5 A. The understanding of
using the
lowest rate
6 available to deliver the records, the understanding
7 of having the responsibility to deliver
the
8 records, the understanding of where the effort
9 required is extensive, the obligation to provide an
10 estimate of cost is provided in the statutes.
11 We've had some legislative changes that have gone
12 out, I guess, generated custodian function or to
13 enhance it, it appears, that I'm aware of and I've
14 seen copies of, but I note that through this
15 process dealing with attorneys that my
16 understanding of our responsibility is pretty much
17 what they indicate is the statutes call for.
18 Q. When you say the legislative change, is
19 there something -- well, let me ask this. Is there
20 a change in your understanding of what your
21 responsibilities have been or are? You just -- you
22 made me -- the way you said that, you made me think
23 that there might have been an old way of doing
24 things and then there's a new way of doing things.
25 A. As I recall it, there was an establishment
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1 of the custodian of the records.
2 The responsibility that I had not been
3 aware that any such position had been required
4 previously.
5 Q. And so who is the custodian with regard to
6 this request?
7 MS. O'CONNOR: Objection.
8 BY MR. O'BOYLE:
9 Q. Or who you understand the custodian to be?
10 A. I do not know who was assigned that
11 responsibility.
12 Q. Okay. So nobody from the Town said, and I
13 guess through -- from the day that this request was
14 made I guess until today, that they are from the
15 Town, they are responsible, they need to give you
16 all the help that you can get to make sure that
17 this -- that what can be done by the lowest paid
18 employee, will be done by the lowest paid employee?
19 A. Previously when I received a request from
20 the Town, it comes from the Town and I respond to
21 the Town. The Town cannot perform my
22 responsibilities for going through the records and
23 finding those records. Neither have I requested it
24 or have they suggested such a thing.
25 Q. Okay. So there's no difference in your
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 mind between when a request comes to you personally
2 or you personally to Brannon & Gillespie versus
3 when the request comes from the public agency, I'm
4 not just talking about the Town of Gulf Stream, but
5 any government that you work with, you don't
6 distinguish between the two?
7 A. No.
8 Q. Okay.
9 A. We respond. Whoever calls us from the
10 agency.
11 Q. Okay. But if it's directly to you, do you
12 see yourself as the custodian that needs to respond
13 as opposed to if it comes through, let's just say,
14 the city of West Palm Beach, where the city of West
15 Palm Beach says we're responsible, but we need you
16 to help us out?
17 A. For the records that I have, I am
18 responsible for responding.
19 Q. Okay. And that's even if the Town also
20 has records, duplicates?
21 A. Yes.
22 Q. Okay. Now, when you review the records,
23 when you are responding to them, what do you
24 generally review for? When you say you are looking
25 at the records, what are you looking for?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1
A.
Compliance with the requirements.
2
Q.
Of the Public Records Act?
3
A.
Compliance with the specifications in the
4
request.
5
Q.
Okay.
6
A.
And we are acting in compliance with the
7
statutes
to fulfill the request. But when I'm
8
looking
through the records, I'm looking for, does
9
this record
fit the request that's been made or is
10
it not.
11
Q.
Okay. So whether you think it's --
12
whether
the record is responsive to the request --
13
A.
Right.
14
Q.
Okay. Do you make any notes as to if
15
there's
something, if there's something that should
16
be redacted?
Are you making any notes and saying
17
this might
be exempt, this might be protected, I
18
shouldn't
release this, like if you see a record
19
with a Social
Security number on it, do you
20
generally
make any notes that, hey, public agency,
21
there's
a Social Security number on this one, you
22
need to
take a look at it?
23
A.
We've not had that situation arise to
24
date.
25
Q.
Okay. And I was talking more generally if
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 you saw -- if you are also looking at -- when you
2 are looking at these records if you are also
3 perhaps making a note or two that there might be
4 something that the Town or the government might
5 want to follow-up with a yellow flag, a red flag?
6 A. All requests that we've had in the past
7 we've not been in situations where we would run
S into things like you are suggesting.
9 Q. Okay. And that's just the nature of the
10 business that you are in?
11 A. Right.
12 Q. Okay. So when you said that you were the
13 only person at the company, is Mr. Gillespie just
14 an owner?
15 A. Right.
16 Q. Okay. So he just is, I guess, an
17 investor, he doesn't perform any of the work?
18 A. He retired.
19 Q. Okay. And did he retire before the
20 underground electric project with the Town of Gulf
21 Stream?
22 A. He retired January 2014, but he's never
23 worked on this project at all.
24 Q. Okay. So he would not have any records in
25 his --
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1
A.
No.
2
Q.
-- emails or anything that -- that you
3
wouldn't
already have?
4
A.
He wouldn't have any records on my
5
projects.
6
Q.
Okay. So when you said the staff of one,
7
do you use
any temporary employees, any contracting
8
services
for any clerical work whatsoever?
9
A.
No.
10
Q.
So when somebody picks up the phone and
11
they call
Brannon & Gillespie, they are speaking to
12
Mr. Danny
Brannon?
13
A.
Right.
14
Q.
And when there's a -- so even if there's a
15
big project
that comes through, you do not pull in
16
temporary
help or contract help at all?
17
A.
No.
18
Q.
That's pretty admirable.
19
A.
Too many years at the power company.
20
Q.
What do you mean by that?
21
A.
Our accounting systems and automation, so
22
we can do
everything ourselves faster than we can
23
tell somebody
else what to do.
24
Q.
Right. Okay.
25
Now, when you performed the estimate, you
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Fort Lauderdale, Florida 954-755-6401
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1 gave an estimate in this for this public records
2 request; is that correct?
3 A. Yes.
4 Q. Okay. And when you provided the estimate,
5 can you tell me a little bit about how you came
6 to -- well, can you tell me what your estimate was
7 just roughly and if you don't remember, just how
8 you came to it?
9 A. We took a rough count of the emails in the
10 Gulf Stream folder and looked at the volume of
11 paperwork in the box and made an estimate
12 particularly on how long it would take to take a
13 look at this many documents and figure out if they
14 were in or out of the request.
15 Q. Now, when you just said the word we, who
16 is we?
17 A. Me, myself and I.
18 Q. Okay.
19 A. Brannon & Gillespie.
20 Q. Sure. Sure. Sure. Okay. And let me ask
21 this. With so many or with a fair amount of
22 documents, was there any contemplation of perhaps
23 getting a temporary person to help respond?
24 A. No.
25 MS. O'CONNOR: Object; asked and answered.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 THE WITNESS: That would not have the
2 ability to do this.
3 They wouldn't have the knowledge.
4 BY MR. O'BOYLE:
5 Q. To identify every record?
6 A. Right.
7 Q. Is that correct?
8 A. To evaluate every record.
9 Q. Okay. What do you know or, I'm sorry, do
10 you know whether or not the Town has asserted any
11 affirmative defenses in this action?
12 A. I have -- I don't know what the Town is
13 doing. Couldn't speak for the Town.
14 Q. Okay. I'm just going to identify this and
15 this is the Town's affirmative defenses that were
16 filed not too long ago and I'm just going to ask,
17 have you ever seen this?
18 MR. O'BOYLE: And I'll show you as well,
19 Joanne.
20 THE WITNESS: I've not read this. I don't
21 know if -- it appears not to be something
22 that's addressing me. I couldn't say. Have I
23 seen it? I've gotten some documents that were
24 recently sent, but I don't know if this was
25 one of them or not.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 BY MR. O'BOYLE;
2 Q. Okay. Well, I mean, if you've seen it,
3 you have, if you haven't, you haven't. I just
4 wondered if you had. Okay. That's fine.
5 So just a little bit of context. These
6 are affirmative defenses that were asserted by the
7 Town which claim that the plaintiff in this case is
8 not the person who should be suing, they have no
9 authority to sue and that this request was made in
10 bad faith.
11 Have you ever heard anybody at the Town
12 make those allegations before?
13 A. No.
14 Q. Do you know who the plaintiff is in this
15 case? Who's doing the suing?
16 A. It's the Awareness Group.
17 Q. Okay. And what have you heard about them?
18 A. That they are a nonprofit group. Don't
19 really know anything about them.
20 Q. Was there anything that struck you as odd
21 with the request that we -- I'm pointing to here.
22 A. The records request?
23 Q. Yes, the original records request, yes.
24 MS. O'CONNOR: I'm going to put an
25 objection. I don't think we've established
Daughters Reporting, Inc.
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1 that he ever saw that at the time the request
2 was made.
3 BY MR. O'BOYLE:
4 Q. Okay. Then the records request of the
5 Town?
6 A. The records request of the Town made was a
7 records request.
8 Q. So there was nothing. I mean, let me back
9 up. So you have no opinion either way, it's just a
10 records request?
11 A. Right.
12 Q. Okay.
13 A. The public request records, some are very
14 narrow scope targeted and some are very broad and
15 we get the records request and it is what it is.
16 Q. Okay. Let me maybe ask in a different
17 way. There is nothing, I guess, mean-spirited or
18 malicious that comes across in the request as you
19 understand it, just a request for underground
20 electric records?
21 MS. O'CONNOR: Objection.
22 THE WITNESS: It's just a records request.
23 BY MR. O'BOYLE:
24 Q. I'm with you.
25 Now, when we talked about responding a
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1 little while ago and you said some records are thin
2 and some are not so thin. Did you ever indicate to
3 the Town or telling anybody from the Town to convey
4 a message and that message would be can the
5 requestor -- is there something that the requestor
6 is looking for, can they narrow their scope of
7 their request, is there anything we can do to make
8 this request a little bit more streamlined?
9 A. I respond to the request that I receive.
10 I don't try to get involved with the origin of the
11 request.
12 Q. Okay. So you're sort of a degree
13 separated?
14 A. Right.
15 Q. Okay. Now, when you get requests to
16 Brannon & Gillespie personally and you see that
17 somebody might be all over the place, when I say
18 all over the place, they are trying to look to put
19 into words something that they are looking for, but
20 they are just not -- it's just not appearing to you
21 that they are even successful. Do you ever pick up
22 the phone and call them and say what exactly are
23 you looking for here, can I help you out?
24 A. We almost always give the requests through
25 the government agency. So we typically do not deal
Daughters Reporting, Inc.
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1 with direct requests, we just don't get them.
2 Q. Okay. And when you deal with the
3 government, and I'm talking now about broader than
4 Gulf Stream, but have you ever had a circumstance
5 where either yourself, Brannon & Gillespie, or the
6 government maybe talked about if there's any way
7 they could maybe ask the requestor to narrow the
8 request if need be?
9 A. Not that I can recall.
10 Q. Okay. So from your recollection, it's
11 very mechanical?
12 A. Right.
13 Q. Request comes in, you respond to it?
14 A. (Nods head).
15 Q. You are nodding your head?
16 A. Correct.
17 Q. Correct. Fair enough.
18 Okay. Has your rate at all increased
19 since 2014?
20 A. Yes.
21 Q. What is the current rate?
22 A. $210 an hour.
23 Q. Okay. So if the requestor were to pay, I
24 think it was, 185, 195, would they today, would
25 they be able to get the records requested or would
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 they have to pay $210 an hour?
2
A.
Well, I would have to probably research
3
that.
I wouldn't want to respond without looking
4
into it.
5
Q.
Okay. And when you look into it, what
6
would
you look into? Would it be talking with the
7
Town?
8
A.
I would probably review the statutes,
9
maybe
talk to the attorneys.
10
Q.
Okay. And the 185, 195 or the 210 today,
11
210 an
hour, that is your contractual rate -- let
12
me back
up.
13
Are you billed on an hourly basis?
14
A.
Right.
15
Q.
Do you have any limit to how many hours
16
you are
supposed to hit before you have to ask for
17
permission
to bill more? Is the contract teared in
18
any way
or is it just as simple as Mr. Brannon
19
works
one hour, he gets paid this?
20
A.
Relative to where?
21
Q.
Oh, the Town of Gulf Stream and
22
underground
electric project.
23
A.
We have a rate and a cap on the billing.
24
Q.
Okay. And can you tell me about the cap
25
-- and
well, I'll ask later just to, you know,
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 where I'm going. I'm going to ask about the cap
2 and then how that would relate to a public records
3 request. So can you tell me a little bit about the
4 cap, how the billing works?
5 A. The cap on this project is a percent of
6 project cost. The public records activity is not
7 part of the project.
8 Q. So would that be -- so the public records
9 hourly rate, that would be separate from the
10 contract, the underground electric?
11 A. Probably.
12 Q. Okay. So you couldn't -- and here is what
13 I'm asking, this hourly rate for responding to
14 public records, that would not count towards the
15 cap or it would count towards the cap?
16 A. It's not within the scope of the contract.
17 Q. Okay. So the 195, or 85, I'm just going
18 to say your rate, so what is -- how do you arrive
19 at your rate then for responding to this request
20 when you made that estimate?
21 A. That's the rate that we charge for our
22 hourly services.
23 Q. Okay. So it's the rate of your contract,
24 and correct me if I'm wrong, please, it's the rate
25 of your contract for the underground electric, you
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 are just going to use that rate to do the
2 underground electric work to respond to public
3 records. But if you respond to public records,
4 it's not going to count towards a cap for the
5 underground electric contract itself?
6 A. The public records request would not
7 typically be part of the contract, it would be an
8 additional service at our current rate.
9 Q. Okay.
10 A. As to having provided an estimate, then
11 it's probable that we would honor the estimate,
12 even at this late date.
13 Q. Okay. And that reflects the -- whatever
14 the estimate is, either back then or today, it will
15 reflect a negotiated rate for the Town to complete
16 the particular project to which it relates the
17 underground electric?
18 A. Right.
19 Q. Okay.
20 A. Well --
21 Q. I'm sorry.
22 A. I need to be clear on whether you are
23 talking about the project or you are talking about
24 the public records request.
25 Q. Sure. Okay. So I'm talking about the
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 records request. And let me just ask it a
2 different way, which is, so there's no different
3 fees that you would charge for responding to this
4 request that are different from your contract for
5 the underground electric, your hourly rate? And
6 let me give you an example. Maybe this is helpful,
7 like, I'm responding to a public records request,
8 150 an hour versus 210 an hour, because it doesn't
9 represent the engineering work, my training
10 essentially. That's what I'm sort of looking to
11 explore. So I guess the question is, your rate to
12 respond to public records requests tracts your rate
13 for the project that you are doing for that
14 municipality for which the public records request
15 relates to?
16 A. We have an hourly rate for our time. Some
17 things are easier, some things are more difficult.
18 Our knowledge is a major component of our time
19 value.
20 Q. And then of course this is a contract that
21 does not reflect at cost, this is the rate of one,
22 let's just say today, 210 an hour, yesteryear it
23 was 185, 195, that's built in for profit margins,
24 for overhead, for regular business expenses; is
25 that correct?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 A. Right.
2 Q. So that's not an at cost expense, a salary
3 expense?
4 A. We have no salaries.
5 Q. Okay. All right. So tell me a little bit
6 I guess on how Brannon & Gillespie, I guess, gets
7 paid from the Town of Gulf Stream and how it pays
8 out its staff, which would be yourself?
9 A. The owners receive any profits that the
10 company generates.
11 Q. So everything goes into -- I want to say
12 everything, all the -- regardless of whether it's
13 public records or whether it's underground
14 electric, engineering, coordinating management
15 work, that goes into one, I'll call it pot, and
16 then the owners decide whether they are going to
17 draw from that pot or reinvest in the business or
18 do whatever they want with it?
19 A. Right.
20 Q. Okay. So nobody, and this is really what
21 I'm getting at, so neither you nor your partner
22 have agreed upon salaries?
23 A. Right.
24 Q. That you would take?
25 A. Right.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 Q. How many requests have you received from
2 the Town of Gulf Stream, regarding this -- well,
3 let me just ask you this. How many requests have
4 you received from the Town of Gulf Stream regarding
5 this -- well, I'll just ask in general since maybe
6 2013 or so?
7 A. I don't know. I recall this one. I
S believe we recently received another one for a
9 specific document, but I would have to look that
10 up. I'm not sure.
11 Q. I guess when I say generally, I don't want
12 you to necessarily guess, I want you to estimate,
13 and I'm talking since 2013, a hundred requests, 500
14 requests?
15 A. No, very few.
16 Q. Okay. To your knowledge, does the Town
17 have a town engineer position that's an official
18 position?
19 A. Not to my knowledge.
20 Q. Okay. So then are you authorized to make
21 decisions for the Town on the micro level to get
22 this underground electric project done? I mean,
23 you can either say generally, but specifically I'm
24 looking for 2014 and before.
25 A. The decisions have a broad range. If you
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 are talking about spending decisions, those go
2 through the Town. In coordinating activity of
3 utilities, they are usually facilitations as
4 opposed to decisions, things that they would do,
5 decisions of when a meeting will be held, to talk
6 about something. So when you say do I make
7 decisions, it's difficult to respond to.
8 Q. Sure. Sure. And I guess maybe let me
9 take this from a different angle which is, the Town
10 has instructed you with regard to this underground
11 electric to do what, in a very general sense? I
12 don't want to put words in your mouth, but I'm
13 going to start you off, install underground
14 electric or facilitate the installation?
15 A. We facilitate the installation, we monitor
16 the construction activities and we review the
17 contractors and the processes and advise the Town
18 as to our opinion as to if they are appropriate or
19 not.
20 Q. So the subcontractors or the affiliates,
21 they'll send Brannon & Gillespie bills and will you
22 either be the first tear of negotiating these bills
23 or do you just kick them right up to the Town?
24 A. On large bills, we will typically review
25 them. They may be sent directly to the Town or
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
50
1 they may
be sent to us to be
forwarded to the Town.
2 We will
review them and make
a recommendation to
3 the Town
from our perspective
of appropriateness.
4 Q. Okay. And for the project itself, do you
5 determine where the -- I guess the course of what
6 gets done first, where it gets done, how it gets
7 done, is that largely left up to you or are those
8 decisions made on the Town level of, I guess, how
9 the course of the --
10 MS. O'CONNOR: Can we go off the record?
11 (Discussion held off the record)
12 THE WITNESS: The contractors generally
13 will run their job. We don't tell the
14 contractors how to do it. We contract with
15 the contractors to perform certain
16 installation services and we look at their
17 plan and we may make comments about the plan
18 if we see it adversely affects aspects of the
19 Town. But the contractors supervisor their
20 own crews and run their own job, so...
21 BY MR. O'BOYLE:
22 Q. And you will be responsible for
23 determining who needs to -- which contractors need
24 to be selected, which contractors -- which persons
25 need to be doing, well, need to be selected for a
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 particular job?
2 A. Typically, the contractors are selected
3 through a competitive bidding process per statutes.
4 Q. Sure. And then for this --
5 A. We facilitate the process. We don't -- we
6 are not in charge of selecting the contractor, we
7 participate in the process with the Town.
8 Q. Okay. Then let me, I guess, get right to
9 the point here. Brannon & Gillespie, you know, to
10 your knowledge, they don't deny that they are in
11 any way responsible for these records that Brannon
12 & Gillespie asserts that they are in fact -- they
13 have to respond to these public records request per
14 statute?
15 A. Right. Right.
16 Q. Okay. Then actually that gets rid of a
17 lot of my questions.
18 When you send the records, when you send
19 things to the Town, do you have your own backup for
20 those or are those backed up separately?
21 MS. O'CONNOR: Objection.
22 THE WITNESS: When I forward records to
23 the Town, do I?
24 BY MR. O'BOYLE:
25 Q. Sure. Do you have some backup? I know
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
52
1 Microsoft Outlook is a
pretty good program
in
2 storing those records,
but what I'm asking
for is
3 if you were subject to
a computer virus or
if your
4 machine -- your computers were wiped out, do you
5 have backups?
6 A. No.
7 Q. Okay.
8 A. Not for Outlook.
9 Q. For any of the underground electric
10 documents, do you have any backups?
11 A. We have backups for CAD -type files.
12 Q. I'm sorry, what type?
13 A. Computer aided design. Auto CAD. So we
14 have backups for certain type files like Excel
15 files or CAD files.
16 Q. Okay. Now, your interaction with the
17 Town, do you interact -- let me ask. What level of
18 interactions do you have with the Town on a regular
19 basis? And when I say regular, do you call in and
20 talk to somebody everyday?
21 A. No. We typically advise the Town when
22 steps or actions occur on the project. We do not
23 interface with the Town other than on those
24 occurrences. If they have a need, they will
25 contact me with a need, we will respond. If we
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 have something going on, we will notify them.
2 Q. Okay. Is this done mostly through
3 writings or is this phone calls?
4 A. Phone calls or email. Yesterday we
5 provided an email response to the Town that the
6 meeting occurred.
7 Q. Okay. And do you -- well, I guess, are
8 you privy to or do you hear any of the scuttlebutt
9 or rumor or the water cooler talk?
10 A. No.
11 Q. I'm curious why you laugh. I mean, I'm
12 laughing now that you are laughing.
13 A. The less I hear, the better off I am.
14 Q. Fair enough.
15 Okay. So you've never heard anybody from
16 the Town, I guess, complain against -- about the
17 public records, anything to do with public records?
18 You never heard any complaints or any comments
19 related to any public records, I mean, outside of,
20 here is a request, can you please respond?
21 A. Well, recently, particularly I guess for
22 many months now, I'm not here very often, so I
23 don't talk much, I know that they've had ongoing
24 situations, but I don't take note of any details of
25 whatever. I'm not involved in it.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 Q. Okay. And when you say ongoing
2 situations -- well, let me ask this. You said you
3 haven't been here recently. Were there, and this
4 is, do you recall in February, January 2014 or
5 before perhaps in 2013, any complaints about public
6 records from the Town? When I say complaints, any
7 comments, any --
8 A. Heard they had a lot of them. I don't
9 recall who would have made such comments. I don't
10 know if that's continuing or not continuing.
11 Obviously this is kind of part of all that and this
12 has been going on since June of '14, so this is
13 certainly continuing.
14 Q. Okay. And when you -- I'm trying to be
15 somewhat specific, but so when you said you heard
16 that the Town has a lot of them, was that -- is
17 that knowledge gained after, let's say, the
18 beginning of June or January, February of 2014?
19 A. I don't -- I don't recall.
20 Q. I didn't know if you heard this recently
21 or if it was more in the distant past.
22 A. It was in the distant past. Recently I
23 have had no communication, conversation,
24 involvement in the status of how it's going.
25 Q. And when you said ongoing situation, I'm
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
55
1 just curious, what does that -- can you tell me a
2 little bit more about what you've heard about the
3 Town's ongoing situation with public records?
4 A. No. Well, my involvement in ongoing
5 situation is sitting in front of us. And from my
6 perspective, this is my ongoing situation.
7 Q. Okay. But the Town's ongoing situation?
8 A. I don't know how that's going.
9 Q. What do you generally understand that
10 ongoing situation to be?
11 A. From my perspective it is this.
12 Q. Okay.
13 A. Records request.
14 Q. So when you made reference to an ongoing
15 situation, it had nothing to do outside of --
16 A. No.
17 Q. -- this?
18 A. Don't know what's going on outside of
19 this.
20 Q. Okay. Well, I'll just ask, does Brannon &
21 Gillespie, are you required to undertake any public
22 records training by virtue of any contract with any
23 government agency and I'll ask from 2000 -- well, I
24 guess it's either yes or no.
25 A. No.
Daughters Reporting, Inc.
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1 Q. Okay. No.
2 So has any government agency offered any
3 training? I'm just wondering if you've had anybody
4 from the government, from really anywhere, give any
5 training for responding to public records requests
6 or handling public records requests?
7 A. I recall one communication from Gulf
8 Stream as to the custodian of records legislation
9 that was an advisory issued. Other than that, no.
10 Q. Okay. And that advisory issue, can you
11 tell me a little bit about what the advisory --
12 A. I believe it was a copy of the legislative
13 act.
14 Q. And I think I know what you are talking
15 about. I'm going to try and ask you if this is
16 what it is, but were you advised that all records
17 requests are now supposed to go through the public
18 agency and not to you directly?
19 A. I was advised that this was a change in
20 the legislation, that I should go through and read
21 it.
22 Q. Okay. I take it, did you read it or maybe
23 just skim through it a little bit?
24 A. I read it.
25 Q. Okay. So let me ask this. Does anybody
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
57
1 have access to your records besides -- and these
2 are the records that Brannon & Gillespie holds,
3 besides yourself and, I guess, Mr. Gillespie?
4 A. Yes. Depending on what you call access,
5 but nobody else uses the records or is involved
6 with the use of the records.
7 Q. Okay. And when I mean access, nowadays, a
8 lot of -- I'm sorry, have you ever heard the term
9 the cloud as it refers to the Internet?
10 A. Yep.
11 Q. Okay. Do you know what that means?
12 A. Yep.
13 Q. Okay.
14 A. I was the information technology account
15 manager for a distribution business at the energy
16 power company.
17 Q. So that's where files are shared, they are
18 stored on an online database and they can be shared
19 through multiple people; is that correct? And this
20 is for the record, too.
21 A. It's an environment that's an access, an
22 offsite environment that's accessible for running
23 applications and storing data and multiple IT
24 functions.
25 Q. Now, are any of these fees, records, and
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
M
1 when I say these records, records that are
2 potentially responsive to the request for the
3 underground utility records, are any of those
4 records stored, I guess, on the cloud? Are they
5 shared with the Town?
6 A. No.
7 Q. In an offsite server -- okay. So it's
8 Brannon & Gillespie's own servers, their own
9 hardware, software? They send things to the Town
10 and it's just as simple as that?
11 A. Right.
12 Q. Okay. The potential records that might be
13 responsive -- let me ask this. You have not
14 deleted anything that could potentially be
15 responsive?
16 A. We do not delete any of the files, emails
17 or other.
18 Q. Is there some kind of archiving process
19 where they are stored in some way or another?
20 A. We have multiple tarabites of draft space
21 that they are stored on, so we don't worry about
22 overloading the draft system.
23 Q. Okay.
24 A. The Outlook files would be in a folder
25 that you could call and archive a folder. That's
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
59
1 the Town folder separate from your typical personal
2 email inbox.
3 Q. Okay. So when you say you have onsite
4 tarabite backups, and here is, let me just get
5 right to the heart of it so we can probably move
6 this along a little quicker, and that is, however
7 this lawsuit works out, if the records are to be
8 turned over, I just want to make sure that, you
9 know, where they are being stored or if there's any
10 alternative places of storage just in case
11 something happens to their computers, your
12 computers or whatever, so can you be maybe just
13 tell me a little bit about where things are stored,
14 how things are stored, how they are backed up just
15 in case?
16 A. We have a backup work station that's got
17 four tarabites of hard drive storage in that pulls
18 things off the server and holds them in a separate
19 computer.
20 Q. Okay. And that separate computer would be
21 on site or off?
22 A. It's on site.
23 Q. Okay. And for the Outlook, are those
24 backed up by any off site?
25 A. No.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
M
1
Q.
Okay. So those are also backed up on
2
site?
3
A.
The Outlook is all on site.
4
Q.
Okay.
5
A.
The Outlook is on site on my machine.
6
Q.
Oh, wow.
7
Do you know if the Town of Gulf Stream has
8
any backup?
9
A.
I don't know.
10
Q.
Okay. Do you know if, I guess, I don't
11
know if
you -- have you given the documents to
12
Jones Foster
or somebody else, where they might
13
have a backup?
I didn't know if you had potential
14
documents
and you said okay?
15
A.
No.
16
Q.
Okay. So if your computers get wiped out,
17
it would
be very difficult to respond to this
18
request?
19
A.
Yes.
20
Q.
Okay. All right. Well, Mr. Brannon, I
21
really don't
have anything else for you today.
22
MS. O'CONNOR: I don't have any questions.
23
We'll read.
24
(The deposition concluded at 11:40 a.m.)
25
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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CERTIFICATE OF OATH
THE STATE OF FLORIDA
COUNTY OF PALM BEACH
I, Felecia Curreri, Registered
Professional Reporter, Notary Public, State of
Florida, certify that DANNY BRANNON personally
appeared before me on the 14th day of July, 2016
and was duly sworn.
Signed this 9th day of November, �.
Z� - - - -, I ;
FELECIA CURRERI, RPR
Notary Public - State of Florida
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
61
62
1 CERTIFICATE OF REPORTER
2 THE STATE OF FLORIDA
COUNTY OF PALM BEACH
3
4
I, Felecia Curreri, Registered
5 Professional Reporter, do hereby certify that I was
authorized to and did stenographically report the
6 deposition of DANNY BRANNON ; that a review of the
transcript was requested; and that the foregoing
7 transcript, pages 4 through 60, is a true and
complete record of my stenographic notes.
8
9 I further certify that I am not a
relative, employee, attorney, or counsel of any of
10 the parties, nor am I a relative or employee of any
of the parties; attorney or counsel connected with
11 the action, nor am I financially interested in the
action.
12
13 The foregoing certification of this
transcript does not apply to any reproduction of
14 the same by and means unless under the direct
control and/or direction of the certifying
15 reporter.
16
Date his 9th day of November, 2016.
17
18
19
Felecia Curreri, RPR
20 Registered Professional Reporter
21
22
23
24
25
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
63
1 PLEASE ATTACH TO THE DEPOSITION OF: DANNY BRANNON
2 IN THE CASE OF: Citizens Awareness vs. Town of
3 Gulf Stream, et al.
4 ERRATA SHEET
5 INSTRUCTIONS: Please read the original transcript
of your deposition and make note of errors or
6 amendments in transcript on this page. DO NOT MARK
on the original transcript itself. Please sign and
7 date this sheet.
8 PAGE LINE ERROR OR AMENDMENT REASON FOR CHANGE
9
10
11
12
13
14
15
16
17
18
19
20
21
Under penalties of perjury, I declare that I have
22 read the foregoing document and that the facts
stated in it are true.
23
Signature of Deponent:
24
Date:
25
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
F
1 November 9, 2016
2 Brannon & Gillespie, LLC
631 U.S. Highway 1
3 Suite 301
North Palm Beach, Florida
4
5 Re: Citizens Awareness vs. Town of Gulf Stream, et
al.
6 Deposition of: DANNY BRANNON , taken July 14, 2016
7
Dear
Mr. Brannon:
S
Please
take notice that on the
14th day of July,
2016,
you gave your deposition
in the above
9
referred matter. At that time,
you did not waive
your
signature. It is now necessary
that you sign
10
your
deposition.
11
Please call our office at the
12 below -listed number to schedule an appointment
between the hours of 9:00 a.m. and 4:30 p.m.,
13 Monday through Friday.
14 If you do not read and sign the
deposition within a reasonable time, the original,
15 which has already been forwarded to the ordering
attorney, may be filed with the Clerk of the Court.
16 If you wish to waive your signature, sign your name
in the blank at the bottom of this letter and
17 return it to us.
la
V y 1y rs
19
20
FELECIA CURRERI, RPR
21 Daughters Reporting, Inc.
954-755-6401
22
I do hereby waive my signature:
23
24
DANNY BRANNON
25
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
2
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
3
February 12:3
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
input 21:24
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Fort Lauderdale, Florida 954-755-6401
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
11
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39:22,23 40:4
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Fort Lauderdale, Florida 954-755-6401
53:19
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
training 46:9
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
10
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954-755-6401
64:21
954)570-3501
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