HomeMy Public PortalAboutDepo-Transcript-William Thrasher1
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO. 502014CA007516 AD
CHRISTOPHER F. O'HARE,
Plaintiff,
v.
TOWN OF GULF STREAM,
Defendant.
- - - - - - - - - - - - - - - x
DEPOSITION OF WILLIAM THRASHER
TAKEN ON BEHALF OF THE PLAINTIFF
Wednesday, February 1, 2017
Gulf Stream Town Hall
100 Sea Road
Gulf Stream, Florida
2:20 p.m. - 3:10 p.m.
Reported by Felecia Curreri, RPR
Notary Public, State of Florida
2
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 APPEARANCES ON BEHALF OF THE PLAINTIFF
2 Louis Roeder, P.A.
7414 Sparkling Lake Road
3 Orlando, Florida 32819
BY: LOUIS ROEDER, ESQUIRE
4 Tel: 407-758-4194
Email: lou@louroeder.com
5
6
7
8
9 APPEARANCES ON BEHALF OF THE DEFENDANT
10 Johnson, Anselmo, Murdoch,
Burke, Piper & Hochman, P.A.
11 2455 E. Sunrise Boulevard
Suite 1000
12 Fort Lauderdale, Florida 33304
BY: HUDSON C. GILL, ESQUIRE
13 Tel: 954-463-0100
Email: hgill@jambg.com
14
15 Edward C. Nazzaro, Esquire
Town of Gulf Stream
16 100 Sea Road
Gulf Stream, Florida 33483
17 Tel: 561-221-9008
Email: tnazzaro@gulf-stream.org
18
19
20
21
22
23 _____________________________
24
25
3
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 I N D E X
2 TESTIMONY OF WILLIAM THRASHER Page
3 Direct Examination by Mr. Roeder 4
4
5
6
7 * * * * *
8
9 E X H I B I T S
10
11
No. Description Page
12
1 (Urban Design Invoices) 13
13
2 (Green Group Invoices) 27
14
15
16
17 (Exhibits Attached)
18
* * * * *
19
S T I P U L A T I O N S
20
It is hereby stipulated and agreed by and
21 between counsel present for the respective parties,
and the deponent, that the reading and signing of
22 the deposition are hereby reserved.
23
24
25
4
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
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 WILLIAM THRASHER
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. ROEDER:
12 Q. Can you give me your name for the record?
13 A. William Harrison Thrasher, Jr.
14 Q. And your job here at the Town of Gulf
15 Stream?
16 A. Town manager.
17 Q. Do you know who Urban Design Kilday
18 Studios is?
19 A. I know them as a firm, yes.
20 MR. GILL: Before we get started, are you
21 doing one transcript for both cases or how are
22 you going to do it? Just so we know.
23 MR. ROEDER: We'll probably do the same
24 thing, one transcript. He was separated out
25 in two transcripts.
5
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 MR. GILL: However you want to do it just
2 I know in my head.
3 MR. ROEDER: That's knew for me. He has
4 two separate transcripts.
5 MR. GILL: You want to do one, that's
6 fine.
7 MR. ROEDER: I could do one.
8 MR. GILL: It's your discretion.
9 Madam court reporter, is that better to do
10 one transcript?
11 THE COURT REPORTER: Sure.
12 BY MR. ROEDER:
13 Q. Well, let me see if I can refresh your
14 memory, Bill.
15 Did Urban Design Kilday create the Chapter
16 70 to the Town Code known as the design manual?
17 A. That firm did, yes.
18 Q. And does Marty Minor work for Urban Design
19 Kilday?
20 A. He does.
21 Q. How is he connected to the Town?
22 A. He is a consultant for the Town.
23 Q. Through Urban Design?
24 A. Through Urban Design Kilday.
25 Q. How long is Urban Design and Marty Minor
6
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 provided services to the Town?
2 A. I can't be for sure. Several years.
3 Q. Is there a difference -- Urban Design
4 Kilday been involved with the Town as long as Marty
5 Minor has been involved with the Town or synonymous
6 or what?
7 A. I believe technically Marty Minor has been
8 involved with the firm longer than the firm has
9 been Urban Design Kilday. Does that make sense?
10 Q. Well, let me just clarify. In your
11 experience with Urban Design Kilday, is there ever
12 been a representative representing the firm other
13 than Marty Minor?
14 A. Yes.
15 Q. Okay. So he's not the first
16 representative from Urban Design Kilday?
17 A. He would be my principal contact.
18 Q. Okay. That's good.
19 Does he do all the zoning applications for
20 the Town?
21 A. Are you referring to ARPB applications?
22 Q. Yes. Did he review all those
23 applications?
24 A. No, he does not do them all.
25 Q. Does he do most of them?
7
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A. No.
2 Q. So when does he get involved in any of
3 those applications?
4 A. Whenever there is a disagreement between
5 the Town representatives and the owner's agent in
6 regards to developing applications. That's one
7 example. It could be where something that I feel I
8 need additional assistance in where perhaps my
9 technical skills aren't as advanced as they should
10 be or -- there are several reasons why he would be
11 engaged.
12 Q. Let me just back up here. I just want to
13 make sure, number one, you're comfortable, Chris is
14 setting up the video --
15 A. I had heard it was a video.
16 MR. GILL: I know it's been noticed as a
17 video depo, so we don't object to it being
18 videotaped, but we would like to receive a
19 copy.
20 MR. ROEDER: That's why we have, since it
21 was one of the parties doing it, that's why we
22 have a request for it, we get one done, we'll
23 gladly provide it to you.
24 MR. GILL: So long as you are good with
25 that.
8
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 BY MR. ROEDER:
2 Q. But I just want to -- some basics here.
3 If you have any question at all, Bill, we've been
4 through this before, if you have any question at
5 all about a question, you know, just tell me you
6 are confused about it, what you want me to clarify
7 and I'll be happy to do that.
8 A. Okay.
9 Q. So we can move it along.
10 I guess what you are saying is that he
11 offers advice whenever there's a disagreement, so
12 he's like the Town expert?
13 A. He gets involved at my request. That
14 request could be a varied purpose.
15 Q. And that has to do with applications?
16 A. Could be.
17 Q. Code enforcement?
18 A. Could be anything.
19 Q. Code enforcement?
20 A. He has been involved in the -- a witness
21 in code enforcement proceedings, special magistrate
22 proceedings.
23 Q. Thank you. And then he also was involved
24 in putting together the Town's comprehensive land
25 use report to the state?
9
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A. Exactly what his original involvement was,
2 I really can't tell you. I know that recently we
3 had to do an update to our comprehensive plan and
4 we made an amendment, went through that process
5 with the state and he was our lead.
6 Q. He would be lead liaison with Design
7 Kilday?
8 A. Yes.
9 Q. Does he provide any services regarding
10 annexations, most recent annexations?
11 A. In regards to the only annexation I know
12 of, he did offer some assistance as well as one of
13 my associates in the firm.
14 Q. Does he provide any services regarding the
15 recent straw ballot regarding the underground
16 project?
17 A. A straw ballot?
18 Q. Yes, there was a straw ballot that --
19 A. I know that. But in regards to the straw
20 ballot, are you talking about the actual counting
21 of the ballot?
22 Q. Sending out the notices. Did he
23 participate at all in any of that?
24 A. I don't think he participated in it.
25 Q. In doing all the things we talked about,
10
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 does he on a -- as a matter of course, does he
2 furnish you reports or opinions, photos or exchange
3 emails with the Town staff?
4 A. Typically, he would respond in emails to
5 either Rita or myself and he does provide various
6 communications. Once I ask him to engage in a
7 project, I do ask for a final report.
8 Q. How about any photos, has he been
9 responsible for securing any photos for the Town?
10 A. He would be involved -- well, I don't know
11 that he, himself, would be. I know that recently I
12 asked him to -- I'm sorry, I asked his firm to take
13 photos of all homes, all homes within the Town of
14 Gulf Stream, both east and west. I haven't seen
15 that product yet, but I know they are working on
16 it.
17 Q. It has to the with the architectural
18 design?
19 A. It has to do with the manual, that's
20 correct, the Chapter 70.
21 Q. As far as taking photos of, pictures of
22 any property or for any other purpose of the Town,
23 has he been involved at all with?
24 A. Yes, I can't recall specifically but the
25 answer is yes.
11
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q. This is all related to any of these
2 reports, photos, emails, anything he may provide
3 the Town as far as an opinion, that's as far as the
4 official capacity with the Town?
5 MR. GILL: Object to the form.
6 You can answer.
7 THE WITNESS: I would like you to -- could
8 you just maybe simplify the question?
9 BY MR. ROEDER:
10 Q. Sure.
11 A. One of those things at a time.
12 Q. I think you mentioned that he's your
13 primary -- I don't want to mis-phrase it.
14 A. Contact.
15 Q. Primary contact with Kilday, which is
16 basically for planning purposes?
17 A. Not exclusively planning, but planning is
18 one of the areas.
19 Q. Primarily because you're talking about
20 code enforcement, any kind of applications. We
21 talk about annexations, all of those have to do
22 with planning issues, so he's basically a planning
23 expert?
24 A. I don't know how to classify him. I don't
25 believe that the bulk of his time is involved in
12
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 planning as it relates to services provided to the
2 Town.
3 Q. Was he involved with the initial creation
4 of the website for Gulf Stream?
5 A. His involvement -- he had involvement in
6 the initial creation, not direct, however.
7 Q. Do you know what his involvement was to
8 the extent of his involvement?
9 A. He was asked by me to help in the
10 development of the website and to find an
11 appropriate material for that website. He utilized
12 additional outside assistance, but just generally
13 turned that project over to him in regards to the
14 website for the purpose of making sure that the
15 character of the website matched the character of
16 the Town and I felt he had a better knowledge of
17 that than myself.
18 Q. That assistance with the website, did that
19 include getting photos for the website?
20 A. He contracted or he found a -- not
21 contracted, but he found a photographer that
22 assisted in the town's development of the website.
23 Q. And what year approximately was that?
24 A. I do not know for sure.
25 Q. I want to show you here a document, I'm
13
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 going to ask you to take a look at it.
2 (Plaintiff's Exhibit No. 1, Urban Design
3 Invoices, was marked for Identification.)
4 THE WITNESS: You want me to look at this
5 document; is that right?
6 BY MR. ROEDER:
7 Q. Yes. Tell me if you recognize that
8 document.
9 A. Well, I recognize it as a typical document
10 from Urban Design Kilday. I do not recall
11 specifically the components of it. It's 2012.
12 Q. And those are your initials on the stamp,
13 the payment approval stamp?
14 A. It is. It is.
15 Q. And the date, too, that's your writing of
16 the date?
17 A. That's my writing, 11-19-12.
18 Q. Is that normally the way it is? It gets
19 prepared for you and then you approve them by
20 putting in your initials and the date?
21 A. Generally that's the process. Sometimes
22 in my absence or if I feel I might be contagious
23 with an illness, I ask Rita to handle that part of
24 it.
25 Q. I would ask you to turn to Page 4.
14
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A. I'm not -- I think you might have to
2 describe Page 4 to me.
3 Q. I think the invoice has --
4 A. It stops at Page 3.
5 Q. I think there's one after Page 3. That's
6 Page 4 and then Page 5. It's not marked there.
7 A. Okay. All right. Yes, there's five pages
8 to this document. The last two pages are not page
9 numbered.
10 Q. Thank you. I appreciate that you make
11 life easy.
12 Can you look at the bottom of the page and
13 see what that -- what describes there? Does it
14 describe the three photos at the bottom of the
15 page?
16 A. I really don't know the answer to that
17 question. This reads three days shooting at $400
18 per day for $1200. One day edit, crop, tone,
19 caption 29 images at $400. Total due 1600.
20 Q. So he does reference there 29 images?
21 A. That's what's written on this page.
22 Q. Can you describe what those images are?
23 Can you recognize them?
24 A. Well, I can't be for sure. I didn't have
25 personal knowledge of these, the taking of these
15
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 photos.
2 The bottom right is Town Hall. The left
3 one, I do not recognize from this document, and I
4 can't be for sure the top one either.
5 Q. So you don't recognize that as Ocean
6 Boulevard at all?
7 A. I think it could be, but I can't be --
8 since I don't have personal knowledge, I didn't
9 have personal taking of these photos, I cannot say
10 for sure.
11 Q. I apologize for the quality, but do you
12 recognize, do you see any bicycle riders in that
13 picture?
14 A. Not really.
15 Q. Okay. Turn to Page 3.
16 A. Three?
17 Q. You see there's a -- next to the last item
18 on that page is -- it's called Phase 103; do you
19 see that?
20 A. Could you ask me that again?
21 Q. Yes.
22 Page 3, you see the next to last item,
23 there's some horizontal lines, the next to last
24 item says Phase 103?
25 A. Oh, okay. Got it. Yes.
16
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q. Can you describe for me what that's
2 talking about there?
3 A. Other consultant, Peter W. Cross.
4 Q. And what was his involvement? Do you
5 recognize the name Peter Cross?
6 A. I now know it, but I can't say I did at
7 the time that I approved this invoice.
8 Q. Does it match up to the $1600 that's on
9 Page 4?
10 A. It's the same amount, yes.
11 Q. So, in your opinion, does it look to be
12 the photographer who provided services on Page 4 as
13 what's being billed on that line item Phase 103?
14 A. In looking at it at this time, I would say
15 yes.
16 Q. Turn to Page 5. Can you please describe
17 what this is.
18 A. This is a -- well, it appears to be a copy
19 of a check, obviously reduced in size. It looks
20 like it's been redacted. It's from the Town of
21 Gulf Stream, Mercantile Bank, and it has a check
22 number 10555 with an amount of $6,312.30. It has
23 no signature. It's made out to Urban Design Kilday
24 Studio dated 11-19-2012.
25 Q. So would it be safe to assume, given the
17
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 6312.30 amount of that check, since it matches the
2 invoice by Design Kilday, that that's payment for
3 that invoice?
4 A. It appears it is.
5 Q. And so it would be safe to assume that the
6 Town having paid that invoice pays for everything
7 marked on the invoice?
8 A. It appears that it is.
9 Q. Which would include the 1600 for the
10 services of Peter Cross; is that correct?
11 A. Yes.
12 Q. Which would then include what's on Page 4
13 which are the 29 images, correct?
14 MR. GILL: Object to form.
15 THE WITNESS: I can't -- I don't know the
16 29 images. I cannot verify that. I can
17 verify I signed the check. I mean, I approved
18 for payment in this document.
19 BY MR. ROEDER:
20 Q. I think you see an invoice from Design
21 Kilday, correct?
22 A. I do.
23 Q. And in it they reference an invoice from
24 Peter Cross, correct?
25 A. Yes.
18
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q. And attached is an actual invoice from
2 Peter Cross for the exact amount that's in the
3 Kilday invoice, correct?
4 A. Repeat that, please.
5 Q. Page 4 is an invoice for the exact amount
6 that is listed on Page 3 in the Kilday invoice,
7 correct?
8 A. Yes.
9 Q. So it would be safe to assume that the
10 payment of the 1600 on Page 3 is for the invoice
11 shown on Page 4?
12 A. Payment for the invoice, yes.
13 Q. And since it is payment for that invoice,
14 it's safe to assume that the payment and the Town
15 and the payment of the check in Page 5, that they
16 paid for the photos that were invoiced by Mr. Cross
17 on Page 4?
18 MR. GILL: Object to form of the question.
19 THE WITNESS: I cannot verify that
20 involved 29 images.
21 BY MR. ROEDER:
22 Q. We assume it invoiced --
23 A. Assume, but I cannot verify that it's
24 involving specifically 29 photos.
25 Q. But the only evidence you have to go that
19
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 it involves 29, 5, 10 photos, whatever, how many
2 photos, the only evidence you have to go to a
3 certain how many photos it covers is by the Cross
4 invoice, correct?
5 MR. GILL: Object to form.
6 THE WITNESS: Yes. I did not see the
7 photos.
8 BY MR. ROEDER:
9 Q. Just one second here.
10 I think I would like to take you to
11 Page 2, next to last item at the bottom where it
12 refers to follow-up with the Cross on photos.
13 A. Again, I'm going to --
14 Q. Can you read that whole entry for me?
15 A. I'm on Page 2.
16 Q. Yes.
17 A. At the bottom of the page? And how far
18 from the bottom of the page up?
19 Q. The next to the last entry on Page 2.
20 A. "Assemble and transmit documents regarding
21 comp plan" --
22 Q. Excuse me. I thought it would be the
23 second from the last. It would be the third from
24 the last. I thought it was -- there's item 33 and
25 then 32 and 32.
20
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A. Okay. The third item from the top --
2 Q. From the bottom.
3 A. "Review historical photos and new photos
4 for website. Discuss home additional request with
5 Bill Thrasher."
6 Q. Now, just one second here.
7 Now, what I'm referring to, I think, I'm
8 sorry you went to the top, but what I'm referring
9 to is the second from the bottom line item.
10 There's one that says Broadnix, Shayne. Broadnix.
11 The line item above that where it says Marty Minor.
12 Could you read me what that line item says? I
13 think it's this one right here.
14 A. At the very bottom, Shayne Broadnix.
15 Q. The one above it.
16 A. The one above it?
17 Q. Yes.
18 A. My apologies.
19 Q. That's kind of hard to make out.
20 A. "Begin review of addition in Place Au
21 Soleil. Follow up with Pete Cross on photos and
22 Sandy Megrew on history photos."
23 Q. This basically shows that Marty Minor with
24 Design Kilday was the one who was following up with
25 Pete Cross or dealing with Peter Cross on
21
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 production of the photos?
2 A. Yeah, I assume. I mean, I didn't deal
3 with Peter Cross. I don't have personal knowledge
4 of that. You may have to ask Marty, but I -- to my
5 knowledge, I have had no dealings with Peter Cross.
6 Q. Okay. I just want to hem down that when
7 you approved a payment of the 6312.30, it was your
8 understanding that it included the $1600 to Cross
9 which, according to Page 4, was for the photos
10 that's been referenced there?
11 MR. GILL: Object to the form of the
12 question.
13 THE WITNESS: I did not. I cannot give
14 you personal knowledge verifying any answer to
15 that question.
16 BY MR. ROEDER:
17 Q. So what is your understanding what the
18 6312.30 paid for?
19 A. It paid for Invoice Number 49199 dated
20 November 12, 2012.
21 Q. Which included what?
22 A. Well, those items which appear on Pages 1
23 through 2.
24 Q. It did not include any of the items on
25 Page 3?
22
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A. I'm sorry, 1 through 3, yes.
2 Q. And included on Page 3 is the money for
3 Peter Cross?
4 A. Yes.
5 Q. And it's for $1600, correct?
6 A. Yes.
7 Q. And since this was attached to the
8 invoice, the Peter Cross invoice for $1600, would
9 you assume that what's on Page 4 was the detail for
10 the amount that's itemized on Page 3?
11 A. No.
12 Q. Then what is the amount on Page 3, $1600
13 for?
14 A. Those are for -- it's for other
15 consultant, Peter W. Cross for $1600.
16 Q. And then you have a Page 4 which is
17 attached to the Kilday invoice?
18 A. Yes.
19 Q. And it's for $1600?
20 A. Yes.
21 Q. If not for that line item. What is this
22 invoice attached to the Kilday invoice for?
23 A. I guess the difficulty I am having in
24 answering that question is that Page 4 refers to 29
25 images which I haven't -- I was not personally
23
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 engaged or involved or have personal knowledge of
2 what those 29 images ism are or were or are.
3 Q. Whether or not you have knowledge of the
4 specific 29 images --
5 A. Pardon me?
6 Q. Whether or not you have knowledge --
7 A. Whether?
8 Q. Yes. Whether or not you have personal
9 knowledge of the 29 images --
10 A. Right.
11 Q. -- specifically what images those might
12 be --
13 A. Right.
14 Q. -- you do have an invoice from Peter Cross
15 for $1600 that references 29 photos, correct?
16 A. It lists in that regard one day edit,
17 crop, tone, caption 29 images, $400.
18 Q. So it does reference 29 images?
19 A. It has listed here 29 images, yes.
20 Q. So if the $1600 is paying for a certain
21 number of items, including 29 images, is that the
22 same $1600 that's paid, itemized in the Kilday
23 invoice?
24 MR. GILL: Object to the form of the
25 question.
24
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 THE WITNESS: I don't have personal
2 knowledge of 29 photos, so I cannot say yes to
3 that, but I say yes to the fact that I
4 approved the invoice and it was paid.
5 BY MR. ROEDER:
6 Q. That's good. I think you really actually
7 already answered the question, but I was just
8 asking you to be a little bit more specific.
9 A. Well, I'm having trouble going with you in
10 that direction, sir.
11 Q. Okay. So you may not have any personal
12 knowledge about these 29 photos in this invoice
13 from Cross, but did you have knowledge that Cross
14 was being hired to take photos?
15 A. Yes. I knew that it was recommended by
16 Marty Minor that we have a photographer assist with
17 photos that would go on the website.
18 Q. That was my next question.
19 So the purpose of that was to get photos
20 for the website?
21 A. Yes.
22 Q. Did Marty Minor report to you at all about
23 the progress regarding those photos?
24 A. Don't recall any updates.
25 Q. Did he report to you about the progress of
25
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 the website?
2 A. At one stage, his involvement, direct
3 involvement was reduced and we referred the website
4 development -- he referred the website development
5 to, I think, Green Group, but the actual -- I do
6 not believe that Marty was involved with the actual
7 design of the website. His primary purpose was to
8 gather elements that were typical in character to
9 the character of the Town of Gulf Stream.
10 Q. Now, Green Group, you have a separate
11 contract with Green Group?
12 A. I'm not sure what their name is but --
13 Q. But you had a separate contract with the
14 website developer, correct?
15 A. We had a separate contract for that, yes.
16 Q. With the photos?
17 A. That's my recollection.
18 Q. What is your recollection about Cross?
19 A. As far as I know, that's all I know is
20 what's on this invoice. I don't think I've ever
21 met the man.
22 Q. But as far as Marty Minor, he was
23 basically -- let me step back.
24 From what you've testified, Marty Minor
25 did not have any direct effort in creating the
26
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 website, but he was like an overall liaison? What
2 was his involvement exactly?
3 A. That's generally my understanding what you
4 just said, general liaison, that primary purpose
5 was to coordinate efforts and to make sure that the
6 website hopefully was typical in character to the
7 character of the Town.
8 Q. Let me just ask you right here. Who did
9 you get normal updates from, from Mr. Minor at
10 Kilday or from Green Group?
11 A. I just don't recall specifically.
12 Q. Let's see. Here we go.
13 A. Let me ask you, are we finished with this
14 document?
15 Q. Yes. I think we're finished with that one
16 for now, but I have a question.
17 Again, did you say -- did I ask you a few
18 moments ago what year that website went on?
19 A. I don't think you did. You asked me --
20 Q. Do you know when the website went live?
21 A. I'm going to say -- I can't be for sure,
22 no.
23 Q. When these photos were paid for back in, I
24 think this is 2012, who had custody of the photos?
25 MR. GILL: Object to the form.
27
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 THE WITNESS: I don't know.
2 BY MR. ROEDER:
3 Q. So as far as you knew at this point, you
4 paid for the photos, but you don't know whether the
5 Town had actual custody of them or whether the
6 vendor had custody of them?
7 MR. GILL: Object to form.
8 THE WITNESS: I do not recall.
9 (Plaintiff's Exhibit No. 2, Green Group
10 Invoices, was marked for Identification.)
11 BY MR. ROEDER:
12 Q. Can you describe to me what this is?
13 A. Just generally what this is?
14 Q. Yes, generally.
15 A. There are two invoices from Green Group
16 and a copy of a check.
17 Q. And similar to the last exhibit, there's
18 an approval box on each one of these invoices. Is
19 that your initial and dates inside each one of
20 those approval boxes?
21 A. Yes.
22 Q. And what's the date next to your initials
23 on there?
24 A. February 14, 2013 on one. Same on the
25 other. On both invoices, that's the date.
28
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q. Valentine's Day. We'll go back and look
2 at the transcript and we'll remember it now.
3 Let me see here where I need to go to.
4 There you go, it's the first item on the first
5 invoice.
6 On invoice 872, can you go to the first
7 item there?
8 A. "Additional services, 11-26. RH. Revised
9 existing (previously approved) images on homepage."
10 Q. So it says it is previously approved.
11 Approved by whom?
12 MR. GILL: Object to the form of the
13 question.
14 THE WITNESS: I couldn't answer. I don't
15 know the answer.
16 BY MR. ROEDER:
17 Q. So you don't know whether Kilday approved
18 those images or whether or not the photos or
19 whether or not somebody at the Town approved the
20 photos?
21 A. That's correct.
22 Q. But whatever regards, it was for the Town
23 of Gulf Stream, correct? The bill here was sent to
24 the Town of Gulf Stream?
25 A. Yes.
29
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q. So their images on the homepage, that
2 refers to the Gulf Stream homepage?
3 MR. GILL: Object to the form of the
4 question.
5 THE WITNESS: Yes.
6 BY MR. ROEDER:
7 Q. Okay. It wouldn't refer to any other
8 homepage.
9 Do you know whether you -- did you
10 personally or anybody you know at the Town approve
11 any of the pages before they went on the web page?
12 A. I believe that we did through a consensus,
13 but I'm not sure. I don't specifically remember.
14 Q. When you say we, is that --
15 A. I would say Rita and I, but I couldn't
16 answer for Rita, but I do remember being asked to
17 pass on the web page.
18 Q. Was anybody else in the Town besides you
19 and Rita, any of the commissioners involved in that
20 process?
21 A. Not that I can recall.
22 Q. And, again, you don't know when exactly
23 the website was activated online?
24 A. I could not specifically tell you. I
25 would say at this stage we're pretty close.
30
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q. So you think it's really close to actually
2 going online?
3 A. Somewhere in 2013, yes. Where, I don't
4 know. I mean, what month.
5 Q. Do you know if Commissioner Ganger was
6 involved specifically with the production of the
7 web page?
8 A. Specifically involved with the production
9 of the web page? I would say he was not.
10 Q. Or in the approval or overview of the web
11 page being done?
12 A. I cannot recall.
13 Q. And when it was activated in 2013, did you
14 review those pages of the website?
15 A. I did an cursory review. I don't recall
16 real in-depth review.
17 Q. Do you know whether any of those pages
18 included photos taken by Mr. Cross?
19 A. I cannot verify that.
20 Q. Who would be able to verify that?
21 A. I would suppose that Mr. Cross would be
22 the person having knowledge of photos he took and
23 then looking on the website to see if they
24 appeared.
25 Q. So Mr. Cross has familiarity with the
31
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 photos, but he was not involved with the creation
2 of the website?
3 A. I believe the answer to that is no, he was
4 not involved with the creation.
5 Q. And you have Green Group, is it, involved
6 with the creation of the website but were not
7 involved with the creation of the photos?
8 A. Yes, they didn't create the photos, to my
9 knowledge. I think we paid for and verified that
10 that activity was a consultant hired by Urban
11 Design Kilday and that those services were paid for
12 by the Town to Urban Design Kilday.
13 Q. You have Green Group doing the site, not
14 the photos. Cross doing the photos, not the site.
15 What you are saying is that Design Kilday or
16 someone with Design Kilday basically had oversight
17 to help coordinate the two?
18 A. That's my understanding, yes.
19 Q. Would that person be Marty Minor?
20 A. Yes.
21 Q. Okay.
22 A. That's my understanding.
23 Q. Now, you don't know whether any of the
24 photos on the website were taken by Cross
25 specifically?
32
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A. No, I cannot verify that.
2 Q. But on the original website that was
3 created, do you remember seeing a picture of a
4 bicycle rider?
5 A. I do not recall that.
6 Q. So you don't have any idea if the specific
7 photos taken by Mr. Cross, so you wouldn't know if
8 they included bicycle riders on Ocean Boulevard?
9 A. I have no personal knowledge of taking
10 photos or photos that were taken.
11 Q. I guess what we're talking about, as I
12 referred to a moment ago, website, no photos,
13 photos, no website, Kilday overseeing or
14 coordinating both. Kilday would be the one who
15 would have that knowledge?
16 A. Possibly.
17 Q. Hopefully somebody did, because otherwise
18 Green Group is putting photos on the website
19 without Town approval.
20 A. Yes.
21 Q. Could we just step back here a little bit
22 with Cross's invoice.
23 If you pay Kilday, who pays Cross, is it
24 your opinion that those are now the Town's photos?
25 MR. GILL: Object to form of the question.
33
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 THE WITNESS: I think that's a legal
2 question and I'm not able to answer that for
3 you, sir.
4 BY MR. ROEDER:
5 Q. Well, beyond a legal question, a public
6 records question, this may be something more
7 appropriate. I'll be honest with you, it might be
8 more appropriate for me. But if you pay for
9 photos, whoever possesses the photos, are those
10 photos Town records?
11 MR. GILL: Object to the form of the
12 question.
13 THE WITNESS: I, again, believe it's a
14 legal question that I am unable to answer for
15 you.
16 BY MR. ROEDER:
17 Q. Assuming you know that Cross took photos.
18 Assume for the moment these parameters. Cross
19 takes photos. Photos are included on the web page.
20 Web page belongs to the Town. Are those pictures
21 on the website then Town records?
22 MR. GILL: Object to the form of the
23 question.
24 THE WITNESS: Again, I will refer to my
25 earlier answer. I believe in my
34
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 interpretation of your question it's a legal
2 question and it is beyond my scope of
3 knowledge.
4 BY MR. ROEDER:
5 Q. This is a little bit -- Bill, just getting
6 back to your job as the town manager.
7 A. Sure.
8 Q. Is it your job to determine if more staff
9 is needed to fulfill any administrative obligations
10 that the Town may have?
11 A. Repeat the question.
12 Q. As far as what administrative obligations
13 the Town has, is it your job to make decisions
14 regarding the personnel necessary to fulfill those
15 obligations?
16 A. As long as that responsibility has been
17 identified in a budget document.
18 Q. So in other words, if you see a need for a
19 certain obligation, it's your responsibility first
20 to go get a budget approved that would allow you to
21 then fulfill that need and then it's your
22 responsibility to make sure that need is filled?
23 A. Yes, that's my understanding.
24 Q. Has there ever been a period of time since
25 2013 where you felt you had sufficient personnel
35
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 and resources to adequately respond to incoming
2 public records requests?
3 A. Please repeat.
4 Q. Has there ever been a period of time since
5 January of 2013 -- I say January 2013 because I
6 think that's when the law starts. So has there
7 been a time, any time, any period since
8 January 2013 when you felt you had sufficient
9 personnel and resources to adequately respond to
10 all incoming public records requests?
11 A. I would say that the answer is no.
12 MR. ROEDER: Let's take a break.
13 (A brief recess was taken, after which the
14 following proceedings were had:)
15 BY MR. ROEDER:
16 Q. One last question. If he doesn't object,
17 we'll be finished with you in two seconds. I just
18 want to ask just for clarification ask it one more
19 time. So you are saying as the Town manager there
20 hasn't been -- in your opinion has been a time
21 since January 2013 when you felt that you've had
22 sufficient personnel resources to adequately
23 respond to all incoming public records requests?
24 It's not a trick question, I just want to verify
25 one last time.
36
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A. It's a complicated answer, but I'm going
2 to say no.
3 MR. ROEDER: We're finished.
4 MR. GILL: We will read and take a copy if
5 it's ordered.
6 MR. ROEDER: Yes, I think we're going to.
7 (The deposition concluded at 3:10 p.m.)
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
37
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 CERTIFICATE OF OATH
2
3 THE STATE OF FLORIDA
4 COUNTY OF PALM BEACH
5
6 I, Felecia Curreri, Registered
7 Professional Reporter, Notary Public, State of
8 Florida, certify that WILLIAM THRASHER personally
9 appeared before me on the 1st day of February, 2017
10 and was duly sworn.
11
12
13 Signed this 8th day of February, 2017.
14
15
16
FELECIA CURRERI, RPR
17 Notary Public - State of Florida
18
19
20
21
22
23
24
25
38
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
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 WILLIAM THRASHER; that a review of
the transcript was requested; and that the
7 foregoing transcript, pages 4 through 36, 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
Dated this 8th day of February, 2017.
17
18
19
Felecia Curreri, RPR
20 Registered Professional Reporter
21
22
23
24
25
39
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 PLEASE ATTACH TO THE DEPOSITION OF: WILLIAM
2 THRASHER
3 IN THE CASE OF: O'HARE vs. TOWN OF GULF STREAM,
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
40
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 February 8, 2017
2 Johnson, Anselmo, Murdoch,
Burke, Piper & Hochman, P.A.
3 2455 E. Sunrise Boulevard
Suite 1000
4 Fort Lauderdale, Florida 33304
ATTN: HUDSON GILL, ESQ.
5
Re: O'HARE vs. TOWN OF GULF STREAM
6 Deposition of: WILLIAM THRASHER, taken February 1, 2017
7 Dear Mr. Gill:
8 Please take notice that on the 1st day of
February, 2017, your client gave his deposition in
9 the above referred matter. At that time, he did
not waive his signature. It is now necessary that
10 he sign her 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.
18
Very truly yours,
19
20
FELECIA CURRERI, RPR
21 Daughters Reporting, Inc.
954-755-6401
22
I do hereby waive my signature:
23
24 _______________________
WILLIAM THRASHER
25
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
A
a.m 40:12
able 30:20 33:2
absence 13:22
action 38:11,11
activated 29:23
30:13
activity 31:10
actual 9:20 18:1
25:5,6 27:5
AD 1:4
addition 20:20
additional 7:8
12:12 20:4
28:8
adequately 35:1
35:9,22
administrative
34:9,12
advanced 7:9
advice 8:11
affirm 4:2
agent 7:5
ago 26:18 32:12
agreed 3:20
allow 34:20
amendment 9:4
39:8
amendments
39:6
amount 16:10
16:22 17:1
18:2,5 22:10
22:12
and/or 38:14
annexation 9:11
annexations
9:10,10 11:21
Anselmo 2:10
40:2
answer 10:25
11:6 14:16
21:14 28:14,15
29:16 31:3
33:2,14,25
35:11 36:1
answered 24:7
answering 22:24
anybody 29:10
29:18
apologies 20:18
apologize 15:11
appear 21:22
APPEARANC...
2:1,9
appeared 30:24
37:9
appears 16:18
17:4,8
applications
6:19,21,23 7:3
7:6 8:15 11:20
apply 38:13
appointment
40:12
appreciate 14:10
appropriate
12:11 33:7,8
approval 13:13
27:18,20 30:10
32:19
approve 13:19
29:10
approved 16:7
17:17 21:7
24:4 28:9,10
28:11,17,19
34:20
approximately
12:23
architectural
10:17
areas 11:18
ARPB 6:21
asked 10:12,12
12:9 26:19
29:16
asking 24:8
Assemble 19:20
assist 24:16
assistance 7:8
9:12 12:12,18
assisted 12:22
associates 9:13
assume 16:25
17:5 18:9,14
18:22,23 21:2
22:9 33:18
Assuming 33:17
ATTACH 39:1
attached 3:17
18:1 22:7,17
22:22
ATTN 40:4
attorney 38:9,10
40:15
Au 20:20
authorized 38:5
B
B 3:9
back 7:12 25:23
26:23 28:1
32:21 34:6
ballot 9:15,17,18
9:20,21
Bank 16:21
basically 11:16
11:22 20:23
25:23 31:16
basics 8:2
BEACH 1:2
37:4 38:2
BEHALF 1:13
2:1,9
believe 6:7 11:25
25:6 29:12
31:3 33:13,25
belongs 33:20
below-listed
40:12
better 5:9 12:16
beyond 33:5
34:2
bicycle 15:12
32:4,8
bill 5:14 8:3 20:5
28:23 34:5
billed 16:13
bit 24:8 32:21
34:5
blank 40:16
bottom 14:12,14
15:2 19:11,17
19:18 20:2,9
20:14 40:16
Boulevard 2:11
15:6 32:8 40:3
box 27:18
boxes 27:20
break 35:12
brief 35:13
Broadnix 20:10
20:10,14
budget 34:17,20
bulk 11:25
Burke 2:10 40:2
C
C 2:12,15
call 40:11
called 4:8 15:18
capacity 11:4
caption 14:19
23:17
CASE 1:4 39:3
cases 4:21
certain 19:3
23:20 34:19
CERTIFICATE
37:1 38:1
certification
38:13
certify 37:8 38:5
38:9
certifying 38:14
CHANGE 39:8
Chapter 5:15
10:20
character 12:15
12:15 25:8,9
26:6,7
check 16:19,21
17:1,17 18:15
27:16
Chris 7:13
CHRISTOPH...
1:6
CIRCUIT 1:1,1
clarification
35:18
clarify 6:10 8:6
classify 11:24
Clerk 40:15
client 40:8
close 29:25 30:1
code 5:16 8:17
8:19,21 11:20
comfortable
7:13
Commissioner
30:5
commissioners
29:19
communications
10:6
comp 19:21
complete 38:7
complicated
36:1
components
13:11
comprehensive
8:24 9:3
concluded 36:7
confused 8:6
connected 5:21
38:10
consensus 29:12
consultant 5:22
16:3 22:15
31:10
contact 6:17
11:14,15
contagious
13:22
contract 25:11
25:13,15
contracted
12:20,21
control 38:14
coordinate 26:5
31:17
coordinating
32:14
2
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
copy 7:19 16:18
27:16 36:4
correct 10:20
17:10,13,21,24
18:3,7 19:4
22:5 23:15
25:14 28:21,23
counsel 3:21
38:9,10
counting 9:20
COUNTY 1:2
37:4 38:2
course 10:1
court 1:1 4:1 5:9
5:11 40:15
covers 19:3
create 5:15 31:8
created 32:3
creating 25:25
creation 12:3,6
31:1,4,6,7
crop 14:18 23:17
Cross 16:3,5
17:10,24 18:2
18:16 19:3,12
20:21,25,25
21:3,5,8 22:3,8
22:15 23:14
24:13,13 25:18
30:18,21,25
31:14,24 32:7
32:23 33:17,18
Cross's 32:22
Curreri 1:21
37:6,16 38:4
38:19 40:20
cursory 30:15
custody 26:24
27:5,6
D
D 3:1
date 13:15,16,20
27:22,25 39:7
39:24
dated 16:24
21:19 38:16
dates 27:19
Daughters 40:21
day 14:18,18
23:16 28:1
37:9,13 38:16
40:8
days 14:17
deal 21:2
dealing 20:25
dealings 21:5
Dear 40:7
decisions 34:13
declare 39:21
Defendant 1:10
2:9
depo 7:17
deponent 3:21
39:23
deposition 1:13
3:22 36:7 38:6
39:1,5 40:6,8
40:10,14
describe 14:2,14
14:22 16:1,16
27:12
describes 14:13
Description 3:11
design 3:12 4:17
5:15,16,18,23
5:24,25 6:3,9
6:11,16 9:6
10:18 13:2,10
16:23 17:2,20
20:24 25:7
31:11,12,15,16
detail 22:9
determine 34:8
developer 25:14
developing 7:6
development
12:10,22 25:4
25:4
difference 6:3
difficulty 22:23
direct 3:3 4:10
12:6 25:2,25
38:14
direction 24:10
38:14
disagreement
7:4 8:11
discretion 5:8
Discuss 20:4
document 12:25
13:5,8,9 14:8
15:3 17:18
26:14 34:17
39:22
documents
19:20
doing 4:21 7:21
9:25 31:13,14
due 14:19
duly 4:9 37:10
E
E 2:11 3:1,9 40:3
earlier 33:25
east 10:14
easy 14:11
edit 14:18 23:16
Edward 2:15
effort 25:25
efforts 26:5
either 10:5 15:4
elements 25:8
Email 2:4,13,17
emails 10:3,4
11:2
employee 38:9
38:10
enforcement
8:17,19,21
11:20
engage 10:6
engaged 7:11
23:1
entry 19:14,19
ERRATA 39:4
ERROR 39:8
errors 39:5
ESQ 40:4
Esquire 2:3,12
2:15
evidence 18:25
19:2
exact 18:2,5
exactly 9:1 26:2
29:22
Examination 3:3
4:10
example 7:7
exchange 10:2
exclusively
11:17
Excuse 19:22
exhibit 13:2 27:9
27:17
Exhibits 3:17
existing 28:9
experience 6:11
expert 8:12
11:23
extent 12:8
F
F 1:6
fact 24:3
facts 39:22
familiarity 30:25
far 10:21 11:3,3
19:17 25:19,22
27:3 34:12
February 1:14
27:24 37:9,13
38:16 40:1,6,8
feel 7:7 13:22
Felecia 1:21 37:6
37:16 38:4,19
40:20
felt 12:16 34:25
35:8,21
FIFTEENTH
1:1
filed 40:15
filled 34:22
final 10:7
financially 38:11
find 12:10
fine 5:6
finished 26:13
26:15 35:17
36:3
firm 4:19 5:17
6:8,8,12 9:13
10:12
first 4:9 6:15
28:4,4,6 34:19
five 14:7
Florida 1:2,16
1:22 2:3,12,16
37:3,8,17 38:2
40:4
Follow 20:21
follow-up 19:12
following 20:24
35:14
follows 4:9
foregoing 38:7
38:13 39:22
form 11:5 17:14
18:18 19:5
21:11 23:24
26:25 27:7
28:12 29:3
32:25 33:11,22
Fort 2:12 40:4
forwarded 40:15
found 12:20,21
Friday 40:13
fulfill 34:9,14,21
furnish 10:2
further 38:9
G
Ganger 30:5
gather 25:8
general 26:4
generally 12:12
13:21 26:3
27:13,14
getting 12:19
34:5
Gill 2:12 4:20
5:1,5,8 7:16,24
11:5 17:14
18:18 19:5
21:11 23:24
3
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
26:25 27:7
28:12 29:3
32:25 33:11,22
36:4 40:4,7
give 4:3,12 21:13
given 16:25
gladly 7:23
go 18:25 19:2
24:17 26:12
28:1,3,4,6
34:20
going 4:22 13:1
19:13 24:9
26:21 30:2
36:1,6
good 6:18 7:24
24:6
Green 3:13 25:5
25:10,11 26:10
27:9,15 31:5
31:13 32:18
Group 3:13 25:5
25:10,11 26:10
27:9,15 31:5
31:13 32:18
guess 8:10 22:23
32:11
Gulf 1:9,15,16
2:15,16 4:14
10:14 12:4
16:21 25:9
28:23,24 29:2
39:3 40:5
H
H 3:9
Hall 1:15 15:2
handle 13:23
happy 8:7
hard 20:19
Harrison 4:13
head 5:2
heard 7:15
help 12:9 31:17
hem 21:6
hgill@jambg....
2:13
hired 24:14
31:10
historical 20:3
history 20:22
Hochman 2:10
40:2
home 20:4
homepage 28:9
29:1,2,8
homes 10:13,13
honest 33:7
hopefully 26:6
32:17
horizontal 15:23
hours 40:12
HUDSON 2:12
40:4
I
idea 32:6
Identification
13:3 27:10
identified 34:17
illness 13:23
images 14:19,20
14:22 17:13,16
18:20 22:25
23:2,4,9,11,17
23:18,19,21
28:9,18 29:1
in-depth 30:16
include 12:19
17:9,12 21:24
included 21:8,21
22:2 30:18
32:8 33:19
including 23:21
incoming 35:1
35:10,23
initial 12:3,6
27:19
initials 13:12,20
27:22
inside 27:19
INSTRUCTI...
39:5
interested 38:11
interpretation
34:1
invoice 14:3
16:7 17:2,3,6,7
17:20,23 18:1
18:3,5,6,10,12
18:13 19:4
21:19 22:8,8
22:17,22,22
23:14,23 24:4
24:12 25:20
28:5,6 32:22
invoiced 18:16
18:22
invoices 3:12,13
13:3 27:10,15
27:18,25
involved 6:4,5,8
7:2 8:13,20,23
10:10,23 11:25
12:3 18:20
23:1 25:6
29:19 30:6,8
31:1,4,5,7
involvement 9:1
12:5,5,7,8 16:4
25:2,3 26:2
involves 19:1
involving 18:24
ism 23:2
issues 11:22
item 15:17,22,24
16:13 19:11,24
20:1,9,11,12
22:21 28:4,7
itemized 22:10
23:22
items 21:22,24
23:21
J
January 35:5,5
35:8,21
job 4:14 34:6,8
34:13
Johnson 2:10
40:2
Jr 4:13
JUDICIAL 1:1
K
Kilday 4:17 5:15
5:19,24 6:4,9
6:11,16 9:7
11:15 13:10
16:23 17:2,21
18:3,6 20:24
22:17,22 23:22
26:10 28:17
31:11,12,15,16
32:13,14,23
kind 11:20 20:19
knew 5:3 24:15
27:3
know 4:17,19,22
5:2 7:16 8:5
9:2,11,19
10:10,11,15
11:24 12:7,24
14:16 16:6
17:15 25:19,19
26:20 27:1,4
28:15,17 29:9
29:10,22 30:4
30:5,17 31:23
32:7 33:17
knowledge 12:16
14:25 15:8
21:3,5,14 23:1
23:3,6,9 24:2
24:12,13 30:22
31:9 32:9,15
34:3
known 5:16
L
L 3:19
Lake 2:2
land 8:24
Lauderdale 2:12
40:4
law 35:6
lead 9:5,6
left 15:2
legal 33:1,5,14
34:1
Let's 26:12
35:12
letter 40:16
liaison 9:6 26:1
26:4
life 14:11
line 16:13 20:9
20:11,12 22:21
39:8
lines 15:23
listed 18:6 23:19
lists 23:16
little 24:8 32:21
34:5
live 26:20
long 5:25 6:4
7:24 34:16
longer 6:8
look 13:1,4
14:12 16:11
28:1
looking 16:14
30:23
looks 16:19
lou@louroede...
2:4
Louis 2:2,3
M
Madam 5:9
magistrate 8:21
making 12:14
man 25:21
manager 4:16
34:6 35:19
manual 5:16
10:19
MARK 39:6
marked 13:3
14:6 17:7
27:10
Marty 5:18,25
6:4,7,13 20:11
20:23 21:4
24:16,22 25:6
4
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
25:22,24 31:19
match 16:8
matched 12:15
matches 17:1
material 12:11
matter 10:1 40:9
mean 17:17 21:2
30:4
means 38:14
Megrew 20:22
memory 5:14
mentioned 11:12
Mercantile
16:21
met 25:21
Minor 5:18,25
6:5,7,13 20:11
20:23 24:16,22
25:22,24 26:9
31:19
mis-phrase
11:13
moment 32:12
33:18
moments 26:18
Monday 40:13
money 22:2
month 30:4
move 8:9
Murdoch 2:10
40:2
N
N 3:1,19
name 4:12 16:5
25:12 40:16
Nazzaro 2:15
necessary 34:14
40:9
need 7:8 28:3
34:18,21,22
needed 34:9
new 20:3
normal 26:9
normally 13:18
Notary 1:22 37:7
37:17
note 39:5
notes 38:7
notice 40:8
noticed 7:16
notices 9:22
November 21:20
number 7:13
16:22 21:19
23:21 40:12
numbered 14:9
O
O 3:19
O'HARE 1:6
39:3 40:5
OATH 37:1
object 7:17 11:5
17:14 18:18
19:5 21:11
23:24 26:25
27:7 28:12
29:3 32:25
33:11,22 35:16
obligation 34:19
obligations 34:9
34:12,15
obviously 16:19
Ocean 15:5 32:8
offer 9:12
offers 8:11
office 40:11
official 11:4
Oh 15:25
okay 6:15,18 8:8
14:7 15:15,25
20:1 21:6
24:11 29:7
31:21
Once 10:6
online 29:23
30:2
opinion 11:3
16:11 32:24
35:20
opinions 10:2
ordered 36:5
ordering 40:15
original 9:1 32:2
39:5,6 40:14
Orlando 2:3
outside 12:12
overall 26:1
overseeing 32:13
oversight 31:16
overview 30:10
owner's 7:5
P
P 3:19
P.A 2:2,10 40:2
p.m 1:17,17 36:7
40:12
page 3:2,11
13:25 14:2,4,5
14:6,6,8,12,15
14:21 15:15,18
15:22 16:9,12
16:16 17:12
18:5,6,10,11
18:15,17 19:11
19:15,17,18,19
21:9,25 22:2,9
22:10,12,16,24
29:11,17 30:7
30:9,11 33:19
33:20 39:6,8
pages 14:7,8
21:22 29:11
30:14,17 38:7
paid 17:6 18:16
21:18,19 23:22
24:4 26:23
27:4 31:9,11
PALM 1:2 37:4
38:2
parameters
33:18
Pardon 23:5
part 13:23
participate 9:23
participated
9:24
parties 3:21 7:21
38:10,10
pass 29:17
pay 32:23 33:8
paying 23:20
payment 13:13
17:2,18 18:10
18:12,13,14,15
21:7
pays 17:6 32:23
penalties 39:21
period 34:24
35:4,7
perjury 39:21
person 30:22
31:19
personal 14:25
15:8,9 21:3,14
23:1,8 24:1,11
32:9
personally 22:25
29:10 37:8
personnel 34:14
34:25 35:9,22
Pete 20:21,25
Peter 16:3,5
17:10,24 18:2
20:25 21:3,5
22:3,8,15
23:14
Phase 15:18,24
16:13
photographer
12:21 16:12
24:16
photos 10:2,8,9
10:13,21 11:2
12:19 14:14
15:1,9 18:16
18:24 19:1,2,3
19:7,12 20:3,3
20:21,22 21:1
21:9 23:15
24:2,12,14,17
24:19,23 25:16
26:23,24 27:4
28:18,20 30:18
30:22 31:1,7,8
31:14,14,24
32:7,10,10,12
32:13,18,24
33:9,9,10,17
33:19,19
picture 15:13
32:3
pictures 10:21
33:20
Piper 2:10 40:2
Place 20:20
Plaintiff 1:7,13
2:1 4:8
Plaintiff's 13:2
27:9
plan 9:3 19:21
planning 11:16
11:17,17,22,22
12:1
please 16:16
18:4 35:3 39:1
39:5,6 40:8,11
point 27:3
possesses 33:9
Possibly 32:16
prepared 13:19
present 3:21
pretty 29:25
previously 28:9
28:10
Primarily 11:19
primary 11:13
11:15 25:7
26:4
principal 6:17
probably 4:23
proceedings
8:21,22 35:14
process 9:4
13:21 29:20
product 10:15
production 21:1
30:6,8
Professional
37:7 38:5,20
progress 24:23
24:25
project 9:16
5
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
10:7 12:13
property 10:22
provide 7:23 9:9
9:14 10:5 11:2
provided 6:1
12:1 16:12
public 1:22 33:5
35:2,10,23
37:7,17
purpose 8:14
10:22 12:14
24:19 25:7
26:4
purposes 11:16
putting 8:24
13:20 32:18
Q
quality 15:11
question 8:3,4,5
11:8 14:17
18:18 21:12,15
22:24 23:25
24:7,18 26:16
28:13 29:4
32:25 33:2,5,6
33:12,14,23
34:1,2,11
35:16,24
R
read 19:14 20:12
36:4 39:5,22
40:14
reading 3:21
reads 14:17
real 30:16
really 9:2 14:16
15:14 24:6
30:1
REASON 39:8
reasonable
40:14
reasons 7:10
recall 10:24
13:10 24:24
26:11 27:8
29:21 30:12,15
32:5
receive 7:18
recess 35:13
recognize 13:7,9
14:23 15:3,5
15:12 16:5
recollection
25:17,18
recommended
24:15
record 4:12 38:7
records 33:6,10
33:21 35:2,10
35:23
redacted 16:20
reduced 16:19
25:3
refer 29:7 33:24
reference 14:20
17:23 23:18
referenced 21:10
references 23:15
referred 25:3,4
32:12 40:9
referring 6:21
20:7,8
refers 19:12
22:24 29:2
refresh 5:13
regard 23:16
regarding 9:9,14
9:15 19:20
24:23 34:14
regards 7:6 9:11
9:19 12:13
28:22
Registered 37:6
38:4,20
related 11:1
relates 12:1
relative 38:9,10
remember 28:2
29:13,16 32:3
repeat 18:4
34:11 35:3
report 8:25 10:7
24:22,25 38:5
Reported 1:21
reporter 4:1 5:9
5:11 37:7 38:1
38:5,15,20
Reporting 40:21
reports 10:2
11:2
representative
6:12,16
representatives
7:5
representing
6:12
reproduction
38:13
request 7:22
8:13,14 20:4
requested 38:6
requests 35:2,10
35:23
reserved 3:22
resources 35:1,9
35:22
respective 3:21
respond 10:4
35:1,9,23
responsibility
34:16,19,22
responsible 10:9
return 40:17
review 6:22 20:3
20:20 30:14,15
30:16 38:6
Revised 28:8
RH 28:8
rider 32:4
riders 15:12
32:8
right 13:5 14:7
15:2 20:13
23:10,13 26:8
Rita 10:5 13:23
29:15,16,19
Road 1:16 2:2
2:16
Roeder 2:2,3 3:3
4:11,23 5:3,7
5:12 7:20 8:1
11:9 13:6
17:19 18:21
19:8 21:16
24:5 27:2,11
28:16 29:6
33:4,16 34:4
35:12,15 36:3
36:6
RPR 1:21 37:16
38:19 40:20
S
S 3:9,19,19
safe 16:25 17:5
18:9,14
Sandy 20:22
saying 8:10
31:15 35:19
says 15:24 20:10
20:11,12 28:10
schedule 40:12
scope 34:2
Sea 1:16 2:16
second 19:9,23
20:6,9
seconds 35:17
securing 10:9
see 5:13 14:13
15:12,17,19,22
17:20 19:6
26:12 28:3
30:23 34:18
seeing 32:3
seen 10:14
Sending 9:22
sense 6:9
sent 28:23
separate 5:4
25:10,13,15
separated 4:24
services 6:1 9:9
9:14 12:1
16:12 17:10
28:8 31:11
setting 7:14
Shayne 20:10,14
sheet 39:4,7
shooting 14:17
show 12:25
shown 18:11
shows 20:23
sign 39:6 40:10
40:14,16
signature 16:23
39:23 40:9,16
40:22
signed 17:17
37:13
signing 3:21
similar 27:17
simplify 11:8
sir 24:10 33:3
site 31:13,14
size 16:19
skills 7:9
Soleil 20:21
somebody 28:19
32:17
sorry 10:12 20:8
22:1
Sparkling 2:2
special 8:21
specific 23:4
24:8 32:6
specifically
10:24 13:11
18:24 23:11
26:11 29:13,24
30:6,8 31:25
staff 10:3 34:8
stage 25:2 29:25
stamp 13:12,13
started 4:20
starts 35:6
state 1:22 8:25
9:5 37:3,7,17
38:2
stated 39:22
stenographic
38:7
stenographica...
38:5
6
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
step 25:23 32:21
stipulated 3:20
stops 14:4
straw 9:15,17,18
9:19
Stream 1:9,15
1:16 2:15,16
4:15 10:14
12:4 16:21
25:9 28:23,24
29:2 39:3 40:5
Studio 16:24
Studios 4:18
sufficient 34:25
35:8,22
Suite 2:11 40:3
Sunrise 2:11
40:3
suppose 30:21
sure 5:11 6:2
7:13 11:10
12:14,24 14:24
15:4,10 25:12
26:5,21 29:13
34:7,22
swear 4:1
sworn 4:9 37:10
synonymous 6:5
T
T 3:9,19,19
take 10:12 13:1
19:10 24:14
35:12 36:4
40:8
taken 1:13 30:18
31:24 32:7,10
35:13 40:6
takes 33:19
talk 11:21
talked 9:25
talking 9:20
11:19 16:2
32:11
technical 7:9
technically 6:7
Tel 2:4,13,17
tell 8:5 9:2 13:7
29:24
testified 4:9
25:24
testimony 3:2
4:2
Thank 8:23
14:10
Thereupon--4:6
thing 4:24
things 9:25
11:11
think 9:24 11:12
14:1,3,5 15:7
17:20 19:10
20:7,13 24:6
25:5,20 26:15
26:19,24 30:1
31:9 33:1 35:6
36:6
third 19:23 20:1
thought 19:22
19:24
Thrasher 1:13
3:2 4:7,13 20:5
37:8 38:6 39:2
40:6,24
three 14:14,17
15:16
time 11:11,25
16:7,14 34:24
35:4,7,7,19,20
35:25 40:9,14
tnazzaro@gul...
2:17
tone 14:18 23:17
top 15:4 20:1,8
Total 14:19
town 1:9,15 2:15
4:14,16 5:16
5:21,22 6:1,4,5
6:20 7:5 8:12
10:3,9,13,22
11:3,4 12:2,16
15:2 16:20
17:6 18:14
25:9 26:7 27:5
28:19,22,24
29:10,18 31:12
32:19 33:10,20
33:21 34:6,10
34:13 35:19
39:3 40:5
town's 8:24
12:22 32:24
transcript 4:21
4:24 5:10 28:2
38:6,7,13 39:5
39:6,6
transcripts 4:25
5:4
transmit 19:20
trick 35:24
trouble 24:9
true 38:7 39:22
truly 40:18
truth 4:3,3,4
turn 13:25 15:15
16:16
turned 12:13
two 4:25 5:4
14:8 27:15
31:17 35:17
typical 13:9 25:8
26:6
Typically 10:4
U
U 3:19
unable 33:14
underground
9:15
understanding
21:8,17 26:3
31:18,22 34:23
update 9:3
updates 24:24
26:9
Urban 3:12 4:17
5:15,18,23,24
5:25 6:3,9,11
6:16 13:2,10
16:23 31:10,12
use 8:25
utilized 12:11
V
v 1:8
Valentine's 28:1
varied 8:14
various 10:5
vendor 27:6
verified 31:9
verify 17:16,17
18:19,23 30:19
30:20 32:1
35:24
verifying 21:14
video 7:14,15,17
videotaped 7:18
vs 39:3 40:5
W
W 16:3 22:15
waive 40:9,16,22
want 5:1,5 7:12
8:2,6 11:13
12:25 13:4
21:6 35:18,24
way 13:18
we'll 4:23 7:22
28:1,2 35:17
we're 26:15
29:25 32:11
36:3,6
we've 8:3
web 29:11,17
30:7,9,10
33:19,20
website 12:4,10
12:11,14,15,18
12:19,22 20:4
24:17,20 25:1
25:3,4,7,14
26:1,6,18,20
29:23 30:14,23
31:2,6,24 32:2
32:12,13,18
33:21
Wednesday 1:14
went 9:4 20:8
26:18,20 29:11
west 10:14
William 1:13 3:2
4:7,13 37:8
38:6 39:1 40:6
40:24
wish 40:16
witness 4:5,8
8:20 11:7 13:4
17:15 18:19
19:6 21:13
24:1 27:1,8
28:14 29:5
33:1,13,24
words 34:18
work 5:18
working 10:15
wouldn't 29:7
32:7
writing 13:15,17
written 14:21
X
x 1:11 3:1,9
Y
Yeah 21:2
year 12:23 26:18
years 6:2
Z
zoning 6:19
0
1
1 1:14 3:12 13:2
21:22 22:1
40:6
10 19:1
100 1:16 2:16
1000 2:11 40:3
103 15:18,24
16:13
10555 16:22
11-19-12 13:17
11-19-2012
16:24
7
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
11-26 28:8
12 21:20
1200 14:18
13 3:12
14 27:24
1600 14:19 16:8
17:9 18:10
21:8 22:5,8,12
22:15,19 23:15
23:20,22
1st 37:9 40:8
2
2 3:13 19:11,15
19:19 21:23
27:9
2:20 1:17
2012 13:11
21:20 26:24
2013 27:24 30:3
30:13 34:25
35:5,5,8,21
2017 1:14 37:9
37:13 38:16
40:1,6,8
2455 2:11 40:3
27 3:13
29 14:19,20
17:13,16 18:20
18:24 19:1
22:24 23:2,4,9
23:15,17,18,19
23:21 24:2,12
3
3 14:4,5 15:15
15:22 18:6,10
21:25 22:1,2
22:10,12
3:10 1:17 36:7
32 19:25,25
32819 2:3
33 19:24
33304 2:12 40:4
33483 2:16
36 38:7
4
4 3:3 13:25 14:2
14:6 16:9,12
17:12 18:5,11
18:17 21:9
22:9,16,24
38:7
4:30 40:12
400 14:17,19
23:17
407-758-4194
2:4
49199 21:19
5
5 14:6 16:16
18:15 19:1
502014CA007...
1:4
561-221-9008
2:17
6
6,312.30 16:22
6312.30 17:1
21:7,18
7
70 5:16 10:20
7414 2:2
8
8 40:1
872 28:6
8th 37:13 38:16
9
9:00 40:12
954-463-0100
2:13
954-755-6401
40:21