HomeMy Public PortalAboutDepo-Transcript-Rita Taylor1
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 RITA TAYLOR
TAKEN ON BEHALF OF THE PLAINTIFF
Wednesday, February 1, 2017
Gulf Stream Town Hall
100 Sea Road
Gulf Stream, Florida
3:10 p.m. - 4:30 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
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Daughters Reporting, Inc.
1 I N D E X
2 TESTIMONY OF RITA TAYLOR Page
3 Direct Examination by Mr. Roeder 4
4
5 * * * * *
6
7 E X H I B I T S
8
9
No. Description Page
10
1 (Public Record Request) 5
11
2 (Photos) 6
12
3 (Public Record Request) 8
13
4 (Booklet) 30
14
5 (6-17-2014 Letter) 37
15
6 (Photo) 38
16
7 (Page from Code Book) 45
17
18
19
(Exhibits Attached)
20
21 * * * * *
22 S T I P U L A T I O N S
23 It is hereby stipulated and agreed by and
between counsel present for the respective parties,
24 and the deponent, that the reading and signing of
the deposition are hereby reserved.
25
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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 RITA TAYLOR
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. State your name for the record.
13 A. Rita L. Taylor.
14 Q. And your position here at Town of Gulf
15 Stream?
16 A. Town clerk.
17 Q. What specific duties does that entail?
18 A. Keeper of the records. Anything anybody
19 else doesn't want to do. Let's see. Issuing
20 permits and licenses. Swearing people in.
21 Q. What's left for Bill to do?
22 MR. THRASHER: I take notes.
23 MR. ROEDER: I'm sorry, I thought you
24 weren't here, Bill.
25 BY MR. ROEDER:
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1 Q. I'm going to show you here what -- since
2 it's all one transcript, we're going to go ahead
3 and call this 1.
4 (Plaintiff's Exhibit No. 1, Pubic Record
5 Request, was marked for Identification.)
6 BY MR. ROEDER:
7 Q. Can you please examine this document?
8 Take your time. Well, let me just back.
9 If you got any questions at all, if I'm
10 not clear on anything, just ask me to repeat it,
11 clarify it, I'll be more than happy to. I'll make
12 it as easy for you as possible to answer the
13 questions.
14 A. Thank you.
15 Q. Can you please describe for me what this
16 is?
17 A. It's a public records request.
18 Q. The date and who made the public records
19 request?
20 A. Chris O'Hare made the request and it is
21 dated Wednesday, December 28th, 2016, at 4:25 p.m.
22 Q. Fantastic.
23 Can you turn to Page 2 and read for me
24 specifically what is requested?
25 A. "As background to this request, I call
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1 your attention to Invoice Number 102612 from Peter
2 W. Cross dated October 26, 2012, which identifies
3 29 images for which the Town paid $1,600 as part of
4 a total Town payment of $6,312.30 made on
5 November 19, 2012 to Urban Design Kilday Studio for
6 their Invoice Number 49199. These invoices are
7 attached to this email for your reference and
8 convenience. I request to inspect the public
9 records in the custody of the Town of Gulf Stream
10 which are the 29 images referenced above. Please
11 produce these records in the original electronic
12 format in which they were created."
13 Q. Thank you.
14 (Plaintiff's Exhibit No. 2, Photos, was
15 marked for Identification.)
16 BY MR. ROEDER:
17 Q. Can you please look at that, Rita, and
18 familiarize yourself with it.
19 A. These are photographs of bicycle riders on
20 what appears to be North Ocean Boulevard in Gulf
21 Stream, at least some of them are on North Ocean, I
22 guess.
23 Q. These are photos certified by you?
24 A. Yes.
25 Q. That's your signature then at the bottom?
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1 A. It is.
2 Q. What's the date of the certification?
3 A. January the 5th, 2017.
4 Q. Just to back up for a second.
5 You said it appears to be Ocean Boulevard.
6 Why would you think that this is Ocean Boulevard?
7 A. Well, unless some other town has got
8 street markers that name their streets the same as
9 ours. This is one, just one of these pictures,
10 says Golfview Drive.
11 Q. And you recognize that as being the
12 intersection of Golfview and Ocean Boulevard?
13 A. I believe so.
14 Q. Do you recognize any type of trees that
15 are there in the pictures, basically in all the
16 pictures?
17 A. They appear to be Australian pines.
18 Q. Is there any location in Gulf Stream where
19 there are Australian pines?
20 A. Yes, there are a number of Australian
21 pines in Gulf Stream, Briny Breezes, a lot of other
22 towns.
23 Q. But as far as Australian pines, what
24 street are they located along?
25 A. North Ocean Boulevard.
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1 Q. Thank you.
2 Were these the photos that were produced
3 by you in response to the request that was
4 described in P-1, the exhibit you just looked over?
5 A. Well, I guess they could be. I can't say
6 for sure that they are the same ones, but --
7 Q. What's the date of -- I already asked you
8 the date of the certifications. I think that's
9 pretty -- let me see. Let me put these aside for
10 the moment now. All right.
11 This is going along faster than we
12 thought.
13 (Plaintiff's Exhibit No. 3, Pubic Record
14 Request, was marked for Identification.)
15 BY MR. ROEDER:
16 Q. Can you look at that and familiarize
17 yourself with it? Take your time.
18 Can you describe to me what this is?
19 A. It appears to be a bicycle rider somewhere
20 along North Ocean Boulevard, probably in Gulf
21 Stream, but I don't see any street marker or
22 anything to particularly indicate that.
23 Q. What's the cover letter?
24 A. The cover letter is a response, a
25 correction, actually, of -- it's a public record
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1 request entitled bicycles, however, I only see one.
2 "Any photos of people riding bicycles on
3 North Ocean Boulevard in the Town's public record"
4 and it is saying that we have recently discovered a
5 copy of the records that had been requested
6 previously has been discovered and that we are
7 supplying it and a small apology for the oversight.
8 Q. So just to summarize, though, that this is
9 a response from the Town regarding the
10 September 29, 2013, original public records
11 request?
12 A. Yes.
13 Q. And attached to it was the photo. So this
14 photo is in response to any bicycle riders along --
15 people riding bicycles on North Ocean Boulevard,
16 this was the photo produced by the Town in response
17 to that request?
18 A. Yes, it's one that was found, discovered
19 after the first request.
20 Q. It says in here "you recently discovered".
21 How did you recently discover it?
22 A. Well, there are more than one of us that
23 work on these things and when the request first
24 came in, my immediate thought was to look in an old
25 file that we had had, I don't remember what year it
10
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1 was, where there was a group of bicycles involved
2 in the Town in an accident and I immediately
3 thought that's what may be he was talking about.
4 So, I went to the file and looked and there were no
5 pictures in there.
6 So, I must confess that I have not been
7 very familiar with our website. I didn't even look
8 at what they had put on there for, I don't know how
9 many months, or years. Anyway, I had no occasion
10 to look at it. I didn't even know that there were
11 bicycles shown on our website. So I guess this was
12 discovered probably by somebody who was familiar
13 with the website.
14 Q. Somebody familiar with the website back in
15 2013 probably, correct?
16 A. I don't know. I don't even remember what
17 date the website went up.
18 Q. Do you know who that was, who the person
19 was?
20 A. It would have been one of the girls that
21 was working here with me. I don't know who it was
22 particularly.
23 Q. The reason I ask about 2013 is because
24 today, as you look at the site, there are no
25 pictures of bicycle riders along Ocean Boulevard,
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1 correct?
2 MR. GILL: Object to the form.
3 THE WITNESS: I have no idea. I don't
4 look at it.
5 MR. GILL: I object to the form.
6 BY MR. ROEDER:
7 Q. So you have no idea again because you are
8 not familiar with the website?
9 A. I don't bother to look at it. There's no
10 information on there that I use daily, so I don't
11 have occasion to look.
12 Q. But since this was done in January 8,
13 2014, do you know when it was actually discovered?
14 I mean, was it Renee or was it with Kelly who
15 probably discovered it? Do you know which one?
16 A. I don't know. I don't remember.
17 Q. You talk about we requested a third-party
18 vendor, that the pictures were in the custody of a
19 third-party vendor. Do you know who that vendor
20 was?
21 A. Well, the ones that were involved with the
22 website was this -- what was his name, Cross that I
23 saw, that you asked for those invoices, and the
24 Urban Design.
25 Q. Okay. But you don't know which one of
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1 those took the pictures, whether it was Cross or
2 Urban Design?
3 A. I would think it was Cross, but I don't
4 know for sure.
5 Q. And with Urban Design, that would be Marty
6 Minor who was coordinating that?
7 A. Yes.
8 Q. So do you know what prompted -- I mean,
9 this has been almost three years now since 2014.
10 In fact, it has been three years. Do you know what
11 prompted the response to this public records
12 request to this date?
13 A. No, I don't.
14 Q. I think I want to move along now. I'm
15 going to -- we'll stay on 18093.
16 Let me ask you this. This will go
17 quickly, too. Let me ask you some questions here,
18 Rita.
19 You mentioned Urban Design Kilday and with
20 Cross regarding the website pictures. Exactly who
21 is Urban Design Kilday?
22 A. They are a planning consultant that we
23 use. They were instrumental in our code after we
24 did the big revision and we use them as consultants
25 whenever we need one.
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1 Q. Who's your principal consultant at Urban
2 Design?
3 A. Marty Minor.
4 Q. And so he reviews zoning applications for
5 the Town?
6 A. Only if we send them to him.
7 Q. Does he participate in staff preparation
8 for code enforcement actions?
9 A. Only if we need him. It's not a general
10 thing.
11 Q. Does he provide services regarding the
12 Town's comprehensive land use plan or report to the
13 state?
14 A. Yes, he does.
15 Q. Did he actually create Chapter 70 of the
16 Town code known as the Design Manual?
17 A. He had a hand in it, but at that time he
18 was not the principal planner for that. That
19 planner was killed in an accident some time ago.
20 Q. Did he provide services to the Town
21 regarding the recent annexation?
22 A. Yes, he did.
23 Q. Did he provide services to the Town
24 regarding the recent straw ballot for the
25 underground project?
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1 A. I'm not sure how much involvement he had
2 in that, if any.
3 Q. It's not a trick question, but did he have
4 any involvement at all in that?
5 A. I'm -- I don't remember.
6 Q. If you don't know, don't want to --
7 A. No, I don't remember if he did or not.
8 Q. So all these things that he's involved
9 with at the Town, he, as a normal course of
10 business, will produce reports, exchange emails
11 with Town staff and like with the website, oversee
12 photos for the website?
13 A. Whatever we ask him to do, he does. And
14 it's a long those lines.
15 Q. And all this is related to official town
16 business?
17 A. Yes.
18 Q. So would all these emails, photos and
19 reports he provides to you, would that be
20 considered public records?
21 MR. GILL: Object to the form of the
22 question.
23 BY MR. ROEDER:
24 Q. You can answer that.
25 A. I don't know if all of them would be.
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1 There could be things he provides that I don't see,
2 so --
3 Q. Are they, maybe not public records, but
4 they are Town records?
5 MR. GILL: Object to the form of the
6 question.
7 You can answer, if you can, Rita.
8 THE WITNESS: Well, I guess, as far as I
9 know, they would be, but there might be some
10 that I don't know about.
11 BY MR. ROEDER:
12 Q. And just to clarify. We've heard about
13 the coordination Urban Design Kilday did for the
14 Town website. Can you confirm that?
15 A. Yes.
16 Q. Do you know of any Town records that were
17 produced in Kilday's setting up of the Town
18 website?
19 MR. GILL: Object to the form of the
20 question.
21 THE WITNESS: Say it again.
22 BY MR. ROEDER:
23 Q. Do you know of any Town records that
24 Kilday may have produced in the coordination of the
25 Town website?
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1 MR. GILL: Object to the form of the
2 question.
3 THE WITNESS: I just guessed it would be
4 invoices would be the only thing I would know
5 of for the work he did.
6 BY MR. ROEDER:
7 Q. Okay. But there may have been work, a
8 communication he had with the Town that may have
9 been the basis for the billing of those invoices,
10 too, correct?
11 MR. GILL: Object to form.
12 THE WITNESS: Yes.
13 BY MR. ROEDER:
14 Q. If you could just briefly outline for me
15 what steps you take when you receive a request to
16 inspect public records. What is the first thing
17 you do?
18 A. I read them. I think, do I have any of
19 this, then I give it to the -- whoever is handling
20 it for us at the time and they start the procedure.
21 They log it in. Get it in line. And then I may
22 not see it again until they start looking for
23 things and then I will help them if they need my
24 help.
25 Q. So you look to see if you have any of
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1 that, the record that may be requested, if not --
2 A. And what's in the -- that gives me a
3 chance to see what's in the mill. What's out there
4 that they are working on.
5 Q. And if you have it, you take care of it.
6 If not, then you turn it over to somebody else?
7 A. Well, if I have it, it goes along with the
8 request because there might be other things to be
9 found that I don't have at my fingerprints, so we
10 get it altogether, try to get it altogether at one
11 time.
12 Q. But then you look at it to see if you know
13 and then you either basically address that or you
14 turn it over to somebody who can, because then
15 after -- I hate to make this so complicated,
16 because then from that point, you said that it gets
17 signed in. So it either gets signed in by you or
18 one of the girls?
19 A. No, it gets logged in by one of the girls
20 that takes care of that sort of thing. I look at
21 all of them and if I immediately have input into
22 whatever is being asked for, when I give it to her
23 to log in, I tell her what I know about it.
24 Q. So you basically give it to one of the
25 girls to be basically the principal person involved
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1 with getting the record?
2 A. Well, and answering and filing.
3 Q. And then once a principle person is
4 involved, they are the ones who log it in?
5 A. Yes. Everything gets logged in.
6 Q. When it gets logged in, is that the time
7 when you actually put a record number to the
8 request?
9 A. Uh-huh.
10 Q. When do you create the online file; when
11 you first get the request or you wait until you
12 actually get a response to create the online file?
13 A. No, it's created right away, as far as I
14 know.
15 Q. And when that person gets it and they
16 basically log it in, that's when you are talking
17 about logging it into the log file, the one that
18 has all the public records request logged in and
19 all the different line categories?
20 A. Uh-huh.
21 Q. Do you ever, when you get a request, based
22 on your experience, when you are trying to decide
23 which girl or how maybe this request may be
24 addressed, do you make the decisions of which
25 vendor if a vendor may actually have the records?
19
Fort Lauderdale, Florida 954-755-6401
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1 A. No. When the person that logs it in, it
2 all starts there, unless I just happen to know
3 without a physical search. She handles it from
4 there on and then when she's found everything that
5 she can find, then she'll ask me.
6 Q. Now, what do you do before you actually
7 search for the records? Do you do anything like --
8 do you do anything like make an estimate or you
9 make an initial effort to search for the records
10 before you do an estimate?
11 A. Oh, yeah. Couldn't estimate it if you
12 didn't have some idea of what you were estimating.
13 Q. Is every request part of the log? Is
14 there any request that you ever get that's not put
15 into the log?
16 A. Not that I'm aware of.
17 Q. Is there a -- so you aren't aware that
18 there's any of that, but there could be one that
19 was actually --
20 A. Well, they are given a number, so the
21 numbers are consecutive. So unless there's
22 something that's gotten lost or accidentally thrown
23 away before it got into the mill, but I don't think
24 that's likely.
25 Q. Is there ever a request that's ever made
20
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1 anonymously?
2 A. Oh, yeah.
3 Q. But you never mark anything down
4 anonymously if you actually know who's made the
5 public records request? If you do, you actually
6 put a name and associate it with it?
7 MR. GILL: Object to the form of the
8 question.
9 THE WITNESS: Say that again.
10 BY MR. ROEDER:
11 Q. If you know who made the request, you mark
12 it down. You don't ever mark down anonymous if you
13 actually know who made the request?
14 MR. GILL: Object to the form.
15 THE WITNESS: Well, sometimes. I don't put
16 information in unless I know what it is. If
17 they sent it anonymous, you know --
18 BY MR. ROEDER:
19 Q. That's not what I'm not saying. So you
20 wouldn't, if you know who makes a request, you
21 never mark it anonymous?
22 MR. GILL: Object to the form of the
23 question.
24 THE WITNESS: I don't understand that
25 question.
21
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1 BY MR. ROEDER:
2 Q. I guess what I heard you say is that if
3 you know who makes the request, you mark it down,
4 correct?
5 A. Well, like, if somebody came in and made a
6 request and I know them, yeah, I would put their
7 name in.
8 Q. You would never have somebody come in like
9 that and you'd mark down anonymous?
10 A. Not if I knew them.
11 Q. Is it possible there may be requests that
12 have been made but have not been put into the log?
13 A. Not that I know of. Some things that
14 people think are public records requests are maybe
15 not.
16 Q. You don't know for sure if you are saying
17 to your knowledge, so you don't know for sure if
18 there's ever been a request made that has not been
19 put into the log?
20 A. No, I wouldn't say that. I would have to
21 know that.
22 Q. How do you search for a record? If you
23 get a request from record A, what decision process
24 do you make of where to go and how to look for it
25 or whether or not you have it in inventory,
22
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1 etcetera, etcetera?
2 A. Well, they always check everybody's
3 emails. I think that's where they start with it.
4 And I would check my hard copy files.
5 Q. So you have hard copy files. Do you have
6 some type of inventory control to keep track of all
7 the records you have?
8 A. No. They are filed alphabetically.
9 Q. So you have alphabetical files, you look
10 at alphabetical files but you don't -- there's not
11 like a -- similar to a library, a Dewey Decimal
12 System is not like some kind of system that you
13 have for certain records?
14 A. No.
15 Q. At what point do you ask a consultant if
16 he's got a record, a vendor or a consultant?
17 A. When the girl does that after she logs it
18 in and it comes up for time to search for it, there
19 might be several ahead, you know, before the actual
20 search starts. They are taking an order in the
21 order that we receive them.
22 Q. So the public records request are answered
23 in the order they come in?
24 A. Uh-huh. The order they are logged in.
25 Q. The order they are logged in. So
23
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1 something is logged in as item one, it's going to
2 get looked at long before item ten gets looked at?
3 A. That's right.
4 Q. Just one second.
5 You say you search for or address or look
6 for a record in the order in which it was received.
7 How about production? If you find it, how do you
8 produce a record? Is there any order of producing
9 a record?
10 A. Well, once they start looking for it and
11 they find it, they continue to look to see if they
12 can complete it. And there are times when -- if
13 they can only find -- if they think there might be
14 others or if somebody is claiming that there's
15 more, we might go ahead and process what we've got
16 and leave the rest of it until we either get it or
17 can find it.
18 Q. When is the record ever reviewed for
19 redaction or reviewed by the attorney?
20 A. Whenever we think or are uncertain as to
21 whether it should be redacted, then we make sure
22 the attorney gets it.
23 Q. And you basically do just about all of
24 what you are talking about before you ever get an
25 estimate to somebody what it would cost to produce
24
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1 the record?
2 A. Well, not always, because sometimes the
3 estimates are probably going to be low and we
4 always explain on there that it is an estimate and
5 that as we produce it, when we've used up, after
6 we've collected the money, if we have used it all
7 up, then we quit at that point of producing, until
8 another estimate is given for what it's going to
9 take to finish it.
10 Q. If somebody was to submit a request for
11 legal invoices, that almost always goes to the
12 attorneys for redaction?
13 A. Yes.
14 Q. Are you the records management liaison
15 officer for Gulf Stream?
16 MR. GILL: Object to the form of the
17 question.
18 THE WITNESS: I don't know really. We all
19 sort of have a hand in it. I am the records
20 custodian. That's -- when you say liaison,
21 with whom?
22 BY MR. ROEDER:
23 Q. Between the public and the Town, you are
24 basically --
25 A. Not always. I don't always --
25
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1 Q. And between your vendors and the Town.
2 You are basically the one that searches between the
3 Town and the vendors to see who might have public
4 records?
5 A. No, the girls do that, too.
6 Q. Well, they are considered to be an
7 extension of yourself; correct?
8 A. That's right.
9 Q. How about between the Town and the state?
10 I think that's where that term really pops up,
11 public records liaison. Are you basically the one
12 who deals with the state or any requirements the
13 state may have regarding public records?
14 A. Basically, yes.
15 Q. In your opinion, are all public records in
16 connection with the transaction of official town
17 business, is that considered to be public records?
18 MR. GILL: Object to the form of the
19 question.
20 THE WITNESS: I don't understand the
21 question. Say it again.
22 BY MR. ROEDER:
23 Q. Well, what's your definition of what is a
24 public record? You are the custodian of public
25 records. What is a public record?
26
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1 MR. GILL: Object to the form of the
2 question.
3 THE WITNESS: I can't name them all.
4 BY MR. ROEDER:
5 Q. Basically, the overriding definition
6 without offering or proffering a legal definition
7 but one that's in the 119 is that anything created
8 in connection with the transaction of official town
9 business, would that be austensibly your definition
10 of what a public record is?
11 A. Sure.
12 MR. GILL: Object to the form of the
13 question.
14 BY MR. ROEDER:
15 Q. And if something -- what would you
16 consider something that is -- well, you just said
17 you consider things in the transaction, official
18 town business of public records. Any records
19 created in the transaction official town business
20 that are not public records?
21 MR. GILL: Object to the form of the
22 question.
23 THE WITNESS: I suppose there could be. I
24 don't --
25 BY MR. ROEDER:
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1 Q. I don't want you --
2 A. I don't know.
3 Q. Okay. That's good.
4 A. I don't know.
5 Q. Are records created, i.e., communications
6 back and forth between the Town and consultants,
7 are those considered to be public records or Town
8 records?
9 MR. GILL: Object to the form of the
10 question.
11 THE WITNESS: The records that are what
12 now?
13 BY MR. ROEDER:
14 Q. Communications between the Town and their
15 vendors or their consultants, are those considered
16 to be Town records?
17 MR. GILL: Object to the form of the
18 question.
19 THE WITNESS: Most times, I would guess.
20 BY MR. ROEDER:
21 Q. As far as archiving, you know, we talked
22 about, you know, if there's any kind of inventory,
23 but if you get records that are produced,
24 communications, not emails, but letters, reports,
25 how are those archived?
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1 A. Well, they could be archived under the
2 subject matter, but as I said alphabetically.
3 Could be by the name of who we're dealing with or
4 it could be the subject matter.
5 Q. I don't know your filing system, but you
6 say subject matter, but then do you have, say,
7 permits are filed one place and zoning requests
8 filed in another --
9 A. Sure.
10 Q. -- things of that sort? So they each have
11 their own filing system within?
12 A. Yes.
13 Q. Do you handle public records request for
14 the police department as well?
15 A. Well, no, we -- it all depends. We don't
16 keep their records, but if it's something that
17 comes in a public record request that is in their
18 records, they do the search and they do the pulling
19 and if it's intermingled with ours, then we do it
20 all at the same time, but if it's a public record
21 request, it gets logged in, if it comes in as a
22 public record request. But they do get things, you
23 know, that accident report request and that sort of
24 thing, which we don't see.
25 Q. But you rely on them basically?
29
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1 A. Yes.
2 Q. Who keeps track of exactly where these
3 public records are stored, is it basically your
4 responsibility?
5 MR. GILL: Object to the form of the
6 question.
7 THE WITNESS: And the girls that work with
8 me.
9 BY MR. ROEDER:
10 Q. So besides the general filing system you
11 are talking about, you don't have any other type of
12 records management system that you use or any
13 formal type of records management system?
14 A. You mean -- I handle the destruction.
15 That's part of the system.
16 Q. But there's no formal records management
17 system other than destruction, formal system like a
18 Dewey Decimal system for a library?
19 A. No.
20 Q. There's no formal management system?
21 A. No.
22 Q. So, as a public records custodian, have
23 you ever asked a Florida Department of State to
24 help with your records management at all?
25 A. Well, what do you mean help?
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1 Q. Are you aware that they have several
2 services and resources that they can provide for
3 public records management?
4 A. Years ago we attended all of their
5 seminars and classes and everything.
6 Q. So you do --
7 A. I do use their --
8 Q. I think I know where you are heading.
9 A. I forget what they call it. Their
10 destruction schedule for all stuff that follow
11 that. We didn't establish our own, we decided to
12 go with theirs.
13 Q. But as far as obligations under Chapter
14 119 Florida Statutes, that's basically your
15 responsibility?
16 A. Yes.
17 Q. And are you related at all with the rules
18 of the Florida Administrative Code as it relates to
19 the standards of records management?
20 A. What do you mean standards?
21 Q. Let me go ahead and give you this.
22 (Plaintiff's Exhibit No. 4, Booklet, was
23 marked for Identification.)
24 BY MR. Four.
25 Q. If you could familiarize yourself with
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1 this.
2 Can you tell me what this is?
3 A. Yes. It's the booklet that's put out by
4 the State.
5 Q. Have you seen it before?
6 A. Oh, yes.
7 Q. So you are pretty much familiar with it?
8 A. Well, I don't know if this is like the
9 ones that we have, but it has the same title and I
10 probably do not have this revised one because I
11 haven't attended one of these for a while, but the
12 girls have, so they may have this, but I'm quite
13 sure I don't have this dated one, but I have the
14 ones as they progressed over the years.
15 Q. What's the date on this one?
16 A. This one says 2009.
17 Q. So you are familiar with the general
18 document, maybe an earlier version, but you are
19 familiar generally with this general document?
20 A. Yes.
21 Q. Could you turn to Page 26. And it lists
22 there other sources of information for records
23 management.
24 Are you familiar with the basic records
25 management, the basics of records management?
32
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1 A. Yes.
2 Q. Are you familiar with the records of
3 management self-evaluation guide?
4 A. Not really.
5 Q. Are you familiar with electronic records
6 and records management practices?
7 A. Basically I am, yes.
8 Q. Are you familiar with the files management
9 handbook?
10 A. I think that's the one I have.
11 Q. Are you familiar with the public records
12 storage guidelines for record centers and archives?
13 A. Yes.
14 MR. ROEDER: I want to ask, so we don't
15 have to go through this all over again with
16 this, are you willing to admit this into
17 evidence for 18093 and 007516 or do we just do
18 it --
19 MR. GILL: No, I'm not willing to admit it
20 into evidence.
21 MR. ROEDER: Okay.
22 BY MR. ROEDER:
23 Q. Back when Mr. O'Hare made his first
24 request to the City, do you recall what year that
25 was?
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1 A. No.
2 Q. Back in 2011 or December or January 2012,
3 do you recall what the status was of the public
4 records department here at the Town of Gulf Stream
5 was?
6 A. What do you mean status?
7 Q. What was the condition of the records
8 department? Excuse me, let me back up.
9 The mayor's made many inferences and I
10 think Bill's made many inferences, Bill Thrasher,
11 about the progress that the public records
12 department has made. What was the basic condition
13 of the public records department back in early
14 2012?
15 A. We didn't have hardly anything on
16 electronically at that time and we've been trying
17 to get everything on there.
18 Q. So you've come up with a formal set of
19 procedures?
20 A. Well, we're putting the stuff on the --
21 online so that people can get it, can see it.
22 Q. Maybe I referred to it wrong. You got a
23 public records policy for the Town of Gulf Stream?
24 A. Yes, we do.
25 Q. And it's actually been updated?
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1 A. Yes.
2 Q. Do you know what was the last year that
3 was updated?
4 A. Well, we review it once a year and we
5 reviewed it a few meetings ago.
6 Q. Do you know how much the public records
7 department or how much the Town has spent for
8 public records and equipment and software and
9 personnel to create the public records department
10 that now exists?
11 A. A fortune.
12 Q. Any idea how much?
13 A. Not offhand, no.
14 Q. You wouldn't be able to tell how much in
15 software?
16 A. No.
17 Q. Or equipment?
18 A. But it's a lot.
19 Q. Say personnel?
20 A. We have hired a temp over and above our
21 normal staff that we've been using for, I suspect,
22 three years probably, at least three years.
23 Q. So how many people do you have working on
24 public records total now?
25 A. Well, we have other duties. Our
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1 department is myself, two ladies and a temp and
2 Mr. Thrasher helps, too.
3 Q. But none of you spend a hundred percent of
4 your time doing public records request?
5 A. That's right. Some of us spend more than
6 others.
7 MR. ROEDER: This includes 18093. The
8 reason I was asking is because we really have
9 asked questions about 18093 and then we've
10 asked about generic public records questions
11 related to 18093. I'd just like to go on the
12 record that those same generic questions about
13 the policies were also -- so we don't have to
14 go through the questioning on 7516 all over
15 again.
16 MR. GILL: You just took a deposition, you
17 are still taking a deposition that it has been
18 noticed in both cases, so --
19 MR. ROEDER: That's why I just want to
20 make sure we're understood.
21 MR. GILL: Yes.
22 MR. ROEDER: That's perfect.
23 BY MR. ROEDER:
24 Q. Okay. We're getting close to the end
25 here, Rita.
36
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1 This is in Case 7516.
2 (Plaintiff's Exhibit No. 5, 6-17-2014
3 Letter, was marked for Identification.)
4 BY MR. ROEDER:
5 Q. If you could familiarize yourself with
6 that one, Rita.
7 MR. ROEDER: Can we take a quick break?
8 MR. GILL: Sure.
9 MR. ROEDER: Just five minutes.
10 MR. GILL: Yes. We're taking a break,
11 Rita.
12 (A brief recess was taken, after which the
13 following proceedings were had:)
14 BY MR. ROEDER:
15 Q. I think you have what's referred to as
16 Exhibit P-5?
17 A. Yes.
18 Q. Can you tell me what this is?
19 A. Well, this is a public records request
20 that was answered.
21 Q. So this is a response to a particular
22 public records request?
23 A. Yes, but the request itself is repeated in
24 here.
25 Q. And basically can you read to me what the
37
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1 response was regarding the specifics? There's a
2 first group of A, B, C and D which have the records
3 that were requested. You have a second group, the
4 A, B, C, D which is the response to those records.
5 A. Right.
6 Q. Can you tell me what the bold response was
7 to all those records?
8 A. The bold?
9 "No such record exists for A. No such
10 record exists for B. No such record exists for C.
11 D has, see attachment."
12 Q. And then basically the very last line,
13 what does that state with the provision of this
14 letter, what's the last line, the position of the
15 town?
16 A. "Unless we here back from you, we consider
17 this matter closed."
18 (Plaintiff's Exhibit No. 6, Photo, was
19 marked for Identification.)
20 BY MR. ROEDER:
21 Q. Can you please explain to me what this is?
22 A. Well, this is a page out of our style
23 book, that's what they refer to it as, a style
24 book, and this is a picture of a mailbox. It says
25 it's 2546.
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1 Q. So basically P-6 is the attachment that's
2 referred to in P-5?
3 A. I believe so.
4 Q. So anywhere on these two photos, do you
5 see the -- let me just back up for a second.
6 On the letter of June 17th, that was in
7 response to public record request made by
8 Mr. O'Hare, it states item D, "any photos in the
9 public record of the property known as and records
10 as PCN," and it gives a number. Is there anywhere
11 on these two photos where you see that PCN number?
12 A. No.
13 Q. So how did you find these photos in
14 response to Mr. O'Hare's public record request that
15 asks for a PCN number?
16 It's not a trick question. I'm just
17 trying to find out how you came to these two
18 records as being responsive when Mr. O'Hare asked
19 for a PCN number.
20 A. Well, I didn't handle this, so I don't
21 know.
22 Q. Could it have been filed under something
23 for the address of 2546 Avenue Au Soleil?
24 A. I don't know.
25 Q. So you don't have any idea how these two
39
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1 photos were produced?
2 A. No.
3 Q. But I think you did say that this second
4 photo came from the actual architectural style?
5 A. Yes.
6 Q. What do they call it, the architectural
7 style manual or architectural--
8 A. It's just a book, an architectural style
9 analysis. Everything in there says the same thing
10 at the top. It's a book of analysis of properties.
11 It's not complete, however.
12 Q. When you say you don't have any idea how
13 these were produced, but did you have any idea of
14 how maybe these things were arrived at or whoever
15 may have in staff conducted this production how
16 they may have found them?
17 A. I don't know. I can't comment about that.
18 Q. As the custodian of records -- now, this
19 photo, the second photo which existed in the
20 architectural style sheets, but if you have this
21 photo here, the first page which shows -- just tell
22 me, what does the first page show?
23 A. A mailbox basically.
24 Q. With an address number?
25 A. Address of 2546.
40
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1 Q. Okay.
2 A. And that's the address that's on the
3 analysis page.
4 Q. That's 2546 Avenue Au Soleil?
5 A. Right.
6 Q. So this second page, we know it comes from
7 the style sheet, so that's where it was filed. Do
8 you know where this -- any idea where this first
9 photo may have been filed then?
10 A. No, I don't.
11 Q. If you have any new records produced like
12 this, do you know how they would be handled, how
13 they would be filed away? You don't know where
14 this came from, but I'm asking you if you received
15 some additional records like this, do you know how
16 they would be filed away?
17 A. Well, I'm assuming that this had something
18 to do with an action, so it would be filed on
19 whatever this, wherever this -- wherever kind of an
20 action produced this, unless it was presented with
21 an application for a hearing, or it wouldn't have
22 been with the building permit, but it could have
23 been with an ARPB hearing of some kind. Those are
24 online now.
25 Q. Well, similar as you testified earlier
41
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1 that you made file items having to do with permit
2 requests in one file, alphabetically, numerically,
3 however that may be, the filing system you have and
4 then you may have code enforcement actions filed in
5 another file and then zoning requests in another
6 file. So what other places, besides the
7 architectural style sheets, what other places would
8 you look for something having to do with --
9 A. I would like in the ARPB file, which is
10 applications for reviews of various things would be
11 one place to look. I wouldn't look in building
12 permits for something like this, but --
13 Q. You don't get a building permit for a
14 mailbox?
15 A. No, not unless they put up the wrong kind.
16 Q. And where else might you look? ARPB?
17 Architectural style sheets? Where else might you
18 look?
19 A. In the land file.
20 Q. What do you mean by land file?
21 A. That's after a permit has been -- a job
22 has been completed, then all the work that went
23 through with the changes in the drawings and
24 everything, they are all filed then under the
25 address in the land file. Anything connected with
42
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1 that particular address by that, each job.
2 Q. Anyplace else you can think of that you
3 might look for?
4 A. No, but there probably is some. Offhand I
5 can't say what it might be.
6 Q. Destruction of record reports are probably
7 someplace, right?
8 A. Yes.
9 Q. Is that your normal course, to look there,
10 too?
11 A. Yes, but that's only a listing.
12 Q. Is it possible, this land file, which you
13 call the land file, if somebody was getting a
14 permit regarding address A, would there also, quite
15 possibly, be photographs of address B in that file
16 for the house next door?
17 A. No, but that could happen in the ARPB
18 file.
19 Q. Okay. Did you ever present an estimate to
20 Mr. O'Hare regarding this public record request in
21 the case 07516, the one that was submitted in the
22 original request April 24, 2014? Did you ever give
23 them an estimate for looking further or for the
24 cost of trying to produce additional records?
25 A. I don't know if that particular one had
43
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1 one or not. We do that on occasion, but I don't
2 know if that particular one has it.
3 Q. But as you sit here today, you don't know
4 of any other responsive records to this public
5 records request regarding PCN 204, so on and so on,
6 you don't know of any other request, any other
7 records that may exist?
8 A. No, I don't know.
9 Q. Okay. Have you asked any vendors if they
10 might have any records regarding that particular
11 property, PCN number or that address, corresponding
12 address?
13 A. The girls always do that, if there's any
14 involved.
15 Q. Is Marty Minor contacted as a general rule
16 whenever there's a public records request regarding
17 a particular property because of his experience
18 with, regarding all the different approval?
19 A. Not as a general rule.
20 Q. When would you -- when might you contact
21 him regarding maybe if he had any idea of there
22 being any responsive records?
23 A. If there is any -- if the request was
24 anything that we thought he would be involved with,
25 we would contact him.
44
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1 Q. Are you familiar with the Town's Design
2 Manual?
3 A. Yes.
4 Q. That's pretty much used in evaluating
5 zoning applications; is that correct?
6 A. Yes.
7 Q. Let me show you --
8 (Plaintiff's Exhibit No. 7, Page from Code
9 Book, was marked for Identification.)
10 BY MR. ROEDER:
11 Q. Are you familiar with this?
12 A. Well, it's a page out of our code book,
13 Section 70-32.
14 Q. Which would be a page out of the Design
15 Manual, right?
16 A. The Design Manual was the original
17 document. It later became Section 70 in the code.
18 Q. But it's what is affectionately called the
19 Design Manual?
20 A. Uh-huh.
21 Q. And that Design Manual was predominantly
22 created by Urban Design Kilday?
23 A. Yes.
24 Q. So they were involved, as far as creating
25 the Design Manual, with all the graphics and the
45
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1 tables and the photos and everything related to it?
2 A. Yes.
3 Q. So do you ask anyone at Urban Design
4 Kilday if they may have responsive photos, if you
5 are looking for photos regarding a particular
6 address, do you go to them because of their
7 familiarity with the Design Manual and ask them if
8 they know of any photos?
9 A. Yes, sometimes.
10 Q. But as far as you know, there are no
11 responsive records in a Design Manual?
12 A. I don't understand that.
13 Q. As far as to Mr. O'Hare's request
14 regarding 2546 Avenue Au Soleil or the PCN number
15 associated with it in our conversations, as far as
16 you know, there are no records in a Design Manual
17 that would be responsive to that request?
18 MR. GILL: Object to the form of the
19 question.
20 THE WITNESS: I don't understand.
21 BY MR. ROEDER:
22 Q. Maybe I can clarify.
23 Do you see the center photo? This is
24 actually not an overlay of the photos by anyone,
25 this is an actual picture of that particular page
46
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1 out of the Design Manual, as I think as you --
2 A. It looks like it, because it has all of
3 these descriptions here.
4 Q. Does the middle photograph look familiar
5 to you?
6 A. No.
7 Q. If you can bring back Exhibit P-6. Does
8 it look like what's in the architectural style
9 sheet in P-6?
10 A. Very similar. Could be the same one.
11 Q. So that would be -- could be the same one
12 as was responsive in your June 17th response.
13 If this is what you said is familiar to
14 the style sheet photo here, would that then be a
15 photo that this page, would this photo on this page
16 be also a record in response to item D in the
17 public records request that Mr. O'Hare made?
18 MR. GILL: Object to the form of the
19 question.
20 THE WITNESS: This picture, there's no
21 correlation. This is in here to demonstrate
22 an open front lawn. I have no way of knowing
23 what these addresses of all of these are.
24 There's no identification for it.
25 BY MR. ROEDER:
47
Fort Lauderdale, Florida 954-755-6401
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1 Q. You refer to the top. It says
2 Section 7032. What's the definition of
3 Section 7032?
4 A. Place Au Soleil District.
5 Q. So at least you know that these photos
6 come from the Place Au Solei District?
7 MR. GILL: Object to the form.
8 THE WITNESS: I guess one could assume
9 that.
10 BY MR. ROEDER:
11 Q. Well, there's no reason to put photos from
12 other parts of town if you are talking in a Design
13 Manual about Place Au Soleil?
14 A. No.
15 Q. Do you know how many homes are in Place Au
16 Soleil?
17 A. Probably 90 to 94 maybe.
18 Q. Let me just ask the reverse question here.
19 You can't say for sure that this is 2546 Avenue Au
20 Soleil, but you cannot say for sure that it is not
21 2546 Avenue Au Soleil as well?
22 A. No, I don't know what it is.
23 Q. Okay. So other than the responsive letter
24 that you sent, which is under P-5 dated June 17,
25 2014, there have been no other efforts since that
48
Fort Lauderdale, Florida 954-755-6401
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1 time to finding responsive records to Mr. O'Hare's
2 public records request?
3 MR. GILL: Object to the form.
4 THE WITNESS: It was closed. At that
5 point, we hadn't found any, so it's closed.
6 MR. ROEDER: Okay. I think that
7 concludes. Sorry we had to keep you.
8 MR. GILL: We will read and take a copy if
9 it's ordered.
10 (The deposition concluded at 4:30 p.m.)
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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 RITA TAYLOR 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
50
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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 RITA TAYLOR; that a review of the
transcript was requested; and that the foregoing
7 transcript, pages 4 through 48, 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
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1 PLEASE ATTACH TO THE DEPOSITION OF: RITA TAYLOR
2 IN THE CASE OF: O'HARE vs. TOWN OF GULF STREAM,
3 2017
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
52
Fort Lauderdale, Florida 954-755-6401
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1 February 7, 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: RITA TAYLOR, taken February 1, 2017
7 Dear Mr. Gill:
8 Please take notice that on the 1st day of
February, 2017, your client gave her deposition in
9 the above referred matter. At that time, she did
not waive her signature. It is now necessary that
10 she 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 _______________________
RITA TAYLOR
25
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
A
a.m 52:12
able 34:14
accident 10:2
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accidentally
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action 40:18,20
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actions 13:8
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address 17:13
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admit 32:16,19
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agreed 3:23
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AMENDMENT
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anonymous
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architectural
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architectural--
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archived 27:25
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associate 20:6
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assume 47:8
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attorney 23:19
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certification 7:2
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certifications 8:8
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certify 49:8 50:5
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CHANGE 51:8
changes 41:23
Chapter 13:15
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CIRCUIT 1:1,1
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Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
City 32:24
claiming 23:14
clarify 5:11
15:12 45:22
classes 30:5
clear 5:10
clerk 4:16 52:15
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created 6:12
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custodian 24:20
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day 49:9,13
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dealing 28:3
deals 25:12
Dear 52:7
December 5:21
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decide 18:22
decided 30:11
Decimal 22:11
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decision 21:23
decisions 18:24
declare 51:21
Defendant 1:10
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deponent 3:24
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District 47:4,6
document 5:7
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doing 35:4
door 42:16
drawings 41:23
Drive 7:10
duly 4:9 49:10
duties 4:17
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estimate 19:8,10
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everybody's
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Examination 3:3
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3
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
examine 5:7
exchange 14:10
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exhibit 5:4 6:14
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36:2,16 37:18
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Exhibits 3:19
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Fantastic 5:22
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February 1:14
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Felecia 1:21 49:6
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FIFTEENTH
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file 9:25 10:4
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filed 22:8 28:7,8
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files 22:4,5,9,10
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Fort 2:12 52:4
forth 27:6
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information
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input 17:21
inspect 6:8
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INSTRUCTI...
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instrumental
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interested 50:11
intermingled
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4
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
intersection 7:12
inventory 21:25
22:6 27:22
Invoice 6:1,6
invoices 6:6
11:23 16:4,9
24:11
involved 10:1
11:21 14:8
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item 23:1,2 38:8
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Johnson 2:10
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June 38:6 46:12
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middle 46:4
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Minor 12:6 13:3
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Monday 52:13
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Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
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Ocean 6:20,21
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October 6:2
offering 26:6
offhand 34:13
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official 14:15
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penalties 51:21
people 4:20 9:2
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10:12,15 11:15
24:3 31:10
34:22 42:4,6
47:17
procedure 16:20
procedures
33:19
proceedings
36:13
process 21:23
23:15
produce 6:11
14:10 23:8,25
24:5 42:24
produced 8:2
9:16 15:17,24
27:23 39:1,13
40:11,20
producing 23:8
24:7
production 23:7
39:15
Professional
49:7 50:5,20
proffering 26:6
progress 33:11
progressed
31:14
project 13:25
prompted 12:8
12:11
properties 39:10
property 38:9
43:11,17
provide 13:11,20
13:23 30:2
provides 14:19
15:1
provision 37:13
Pubic 5:4 8:13
public 1:22 3:10
3:12 5:17,18
6:8 8:25 9:3,10
12:11 14:20
15:3 16:16
18:18 20:5
21:14 22:22
24:23 25:3,11
25:13,15,17,24
25:24,25 26:10
26:18,20 27:7
28:13,17,20,22
29:3,22 30:3
32:11 33:3,11
33:13,23 34:6
34:8,9,24 35:4
35:10 36:19,22
38:7,9,14
42:20 43:4,16
46:17 48:2
49:7,17
pulling 28:18
put 8:9 10:8
18:7 19:14
20:6,15 21:6
21:12,19 31:3
41:15 47:11
6
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
putting 33:20
Q
question 14:3,22
15:6,20 16:2
20:8,23,25
24:17 25:19,21
26:2,13,22
27:10,18 29:6
38:16 45:19
46:19 47:18
questioning
35:14
questions 5:9,13
12:17 35:9,10
35:12
quick 36:7
quickly 12:17
quit 24:7
quite 31:12
42:14
R
read 5:23 16:18
36:25 48:8
51:5,22 52:14
reading 3:24
really 24:18
25:10 32:4
35:8
reason 10:23
35:8 47:11
51:8
reasonable
52:14
recall 32:24 33:3
receive 16:15
22:21
received 23:6
40:14
recess 36:12
recognize 7:11
7:14
record 3:10,12
4:12 5:4 8:13
8:25 9:3 17:1
18:1,7 21:22
21:23 22:16
23:6,8,9,18
24:1 25:24,25
26:10 28:17,20
28:22 32:12
35:12 37:9,10
37:10 38:7,9
38:14 42:6,20
46:16 50:7
records 4:18
5:17,18 6:9,11
9:5,10 12:11
14:20 15:3,4
15:16,23 16:16
18:18,25 19:7
19:9 20:5
21:14 22:7,13
22:22 24:14,19
25:4,11,13,15
25:17,25 26:18
26:18,20 27:5
27:7,8,11,16
27:23 28:13,16
28:18 29:3,12
29:13,16,22,24
30:3,19 31:22
31:24,25 32:2
32:5,6,11 33:4
33:7,11,13,23
34:6,8,9,24
35:4,10 36:19
36:22 37:2,4,7
38:9,18 39:18
40:11,15 42:24
43:4,5,7,10,16
43:22 45:11,16
46:17 48:1,2
redacted 23:21
redaction 23:19
24:12
refer 37:23 47:1
reference 6:7
referenced 6:10
referred 33:22
36:15 38:2
52:9
regarding 9:9
12:20 13:11,21
13:24 25:13
37:1 42:14,20
43:5,10,16,18
43:21 45:5,14
Registered 49:6
50:4,20
related 14:15
30:17 35:11
45:1
relates 30:18
relative 50:9,10
rely 28:25
remember 9:25
10:16 11:16
14:5,7
Renee 11:14
repeat 5:10
repeated 36:23
report 13:12
28:23 50:5
Reported 1:21
reporter 4:1
49:7 50:1,5,15
50:20
Reporting 52:21
reports 14:10,19
27:24 42:6
reproduction
50:13
request 3:10,12
5:5,17,19,20
5:25 6:8 8:3,14
9:1,11,17,19
9:23 12:12
16:15 17:8
18:8,11,18,21
18:23 19:13,14
19:25 20:5,11
20:13,20 21:3
21:6,18,23
22:22 24:10
28:13,17,21,22
28:23 32:24
35:4 36:19,22
36:23 38:7,14
42:20,22 43:5
43:6,16,23
45:13,17 46:17
48:2
requested 5:24
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37:3 50:6
requests 21:11
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41:2,5
requirements
25:12
reserved 3:24
resources 30:2
respective 3:23
response 8:3,24
9:9,14,16
12:11 18:12
36:21 37:1,4,6
38:7,14 46:12
46:16
responsibility
29:4 30:15
responsive 38:18
43:4,22 45:4
45:11,17 46:12
47:23 48:1
rest 23:16
return 52:17
reverse 47:18
review 34:4 50:6
reviewed 23:18
23:19 34:5
reviews 13:4
41:10
revised 31:10
revision 12:24
rider 8:19
riders 6:19 9:14
10:25
riding 9:2,15
right 8:10 18:13
23:3 25:8 35:5
37:5 40:5 42:7
44:15
Rita 1:13 3:2 4:7
4:13 6:17
12:18 15:7
35:25 36:6,11
49:8 50:6 51:1
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Road 1:16 2:2
2:16
Roeder 2:2,3 3:3
4:11,23,25 5:6
6:16 8:15 11:6
14:23 15:11,22
16:6,13 20:10
20:18 21:1
24:22 25:22
26:4,14,25
27:13,20 29:9
32:14,21,22
35:7,19,22,23
36:4,7,9,14
37:20 44:10
45:21 46:25
47:10 48:6
RPR 1:21 49:16
50:19 52:20
rule 43:15,19
rules 30:17
S
S 3:7,22,22
saw 11:23
saying 9:4 20:19
21:16
says 7:10 9:20
31:16 37:24
39:9 47:1
schedule 30:10
52:12
Sea 1:16 2:16
search 19:3,7,9
21:22 22:18,20
23:5 28:18
searches 25:2
second 7:4 23:4
37:3 38:5 39:3
39:19 40:6
Section 44:13,17
47:2,3
see 4:19 8:9,21
9:1 15:1 16:22
7
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
16:25 17:3,12
23:11 25:3
28:24 33:21
37:11 38:5,11
45:23
seen 31:5
self-evaluation
32:3
seminars 30:5
send 13:6
sent 20:17 47:24
September 9:10
services 13:11
13:20,23 30:2
set 33:18
setting 15:17
she'll 19:5
sheet 40:7 46:9
46:14 51:4,7
sheets 39:20
41:7,17
show 5:1 39:22
44:7
shown 10:11
shows 39:21
sign 51:6 52:10
52:14,16
signature 6:25
51:23 52:9,16
52:22
signed 17:17,17
49:13
signing 3:24
similar 22:11
40:25 46:10
sit 43:3
site 10:24
small 9:7
software 34:8,15
Solei 47:6
Soleil 38:23 40:4
45:14 47:4,13
47:16,20,21
somebody 10:12
10:14 17:6,14
21:5,8 23:14
23:25 24:10
42:13
someplace 42:7
sorry 4:23 48:7
sort 17:20 24:19
28:10,23
sources 31:22
Sparkling 2:2
specific 4:17
specifically 5:24
specifics 37:1
spend 35:3,5
spent 34:7
staff 13:7 14:11
34:21 39:15
standards 30:19
30:20
start 16:20,22
22:3 23:10
starts 19:2 22:20
state 1:22 4:12
13:13 25:9,12
25:13 29:23
31:4 37:13
49:3,7,17 50:2
stated 51:22
states 38:8
status 33:3,6
Statutes 30:14
stay 12:15
stenographic
50:7
stenographica...
50:5
steps 16:15
stipulated 3:23
storage 32:12
stored 29:3
straw 13:24
Stream 1:9,15
1:16 2:15,16
4:15 6:9,21
7:18,21 8:21
24:15 33:4,23
51:2 52:5
street 7:8,24
8:21
streets 7:8
Studio 6:5
stuff 30:10 33:20
style 37:22,23
39:4,7,8,20
40:7 41:7,17
46:8,14
subject 28:2,4,6
submit 24:10
submitted 42:21
Suite 2:11 52:3
summarize 9:8
Sunrise 2:11
52:3
supplying 9:7
suppose 26:23
sure 8:6 12:4
14:1 21:16,17
23:21 26:11
28:9 31:13
35:20 36:8
47:19,20
suspect 34:21
swear 4:1
Swearing 4:20
sworn 4:9 49:10
system 22:12,12
28:5,11 29:10
29:12,13,15,17
29:17,18,20
41:3
T
T 3:7,22,22
tables 45:1
take 4:22 5:8
8:17 16:15
17:5 24:9 36:7
48:8 52:8
taken 1:13 36:12
52:6
takes 17:20
talk 11:17
talked 27:21
talking 10:3
18:16 23:24
29:11 47:12
Taylor 1:13 3:2
4:7,13 49:8
50:6 51:1 52:6
52:24
Tel 2:4,13,17
tell 17:23 31:2
34:14 36:18
37:6 39:21
temp 34:20 35:1
ten 23:2
term 25:10
testified 4:9
40:25
testimony 3:2
4:2
Thank 5:14 6:13
8:1
theirs 30:12
Thereupon--4:6
thing 13:10 16:4
16:16 17:20
28:24 39:9
things 9:23 14:8
15:1 16:23
17:8 21:13
26:17 28:10,22
39:14 41:10
think 7:6 8:8
12:3,14 16:18
19:23 21:14
22:3 23:13,20
25:10 30:8
32:10 33:10
36:15 39:3
42:2 46:1 48:6
third-party
11:17,19
thought 4:23
8:12 9:24 10:3
43:24
Thrasher 4:22
33:10 35:2
three 12:9,10
34:22,22
thrown 19:22
time 5:8 8:17
13:17,19 16:20
17:11 18:6
22:18 28:20
33:16 35:4
48:1 52:9,14
times 23:12
27:19
title 31:9
tnazzaro@gul...
2:17
today 10:24 43:3
top 39:10 47:1
total 6:4 34:24
town 1:9,15 2:15
4:14,16 6:3,4,9
7:7 9:9,16 10:2
13:5,16,20,23
14:9,11,15
15:4,14,16,17
15:23,25 16:8
24:23 25:1,3,9
25:16 26:8,18
26:19 27:6,7
27:14,16 33:4
33:23 34:7
37:15 47:12
51:2 52:5
Town's 9:3
13:12 44:1
towns 7:22
track 22:6 29:2
transaction
25:16 26:8,17
26:19
transcript 5:2
50:6,7,13 51:5
51:6,6
trees 7:14
trick 14:3 38:16
true 50:7 51:22
truly 52:18
truth 4:3,3,4
try 17:10
trying 18:22
33:16 38:17
42:24
turn 5:23 17:6
17:14 31:21
two 35:1 38:4,11
8
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
38:17,25
type 7:14 22:6
29:11,13
U
U 3:22
Uh-huh 18:9,20
22:24 44:20
uncertain 23:20
underground
13:25
understand
20:24 25:20
45:12,20
understood
35:20
updated 33:25
34:3
Urban 6:5 11:24
12:2,5,19,21
13:1 15:13
44:22 45:3
use 11:10 12:23
12:24 13:12
29:12 30:7
V
v 1:8
various 41:10
vendor 11:18,19
11:19 18:25,25
22:16
vendors 25:1,3
27:15 43:9
version 31:18
vs 51:2 52:5
W
W 6:2
wait 18:11
waive 52:9,16,22
want 4:19 12:14
14:6 27:1
32:14 35:19
way 46:22
we'll 12:15
we're 5:2 28:3
33:20 35:20,24
36:10
we've 15:12
23:15 24:5,6
33:16 34:21
35:9
website 10:7,11
10:13,14,17
11:8,22 12:20
14:11,12 15:14
15:18,25
Wednesday 1:14
5:21
went 10:4,17
41:22
weren't 4:24
willing 32:16,19
wish 52:16
witness 4:5,8
11:3 15:8,21
16:3,12 20:9
20:15,24 24:18
25:20 26:3,23
27:11,19 29:7
45:20 46:20
47:8 48:4
work 9:23 16:5,7
29:7 41:22
working 10:21
17:4 34:23
wouldn't 20:20
21:20 34:14
40:21 41:11
wrong 33:22
41:15
X
x 1:11 3:1,7
Y
yeah 19:11 20:2
21:6
year 9:25 32:24
34:2,4
years 10:9 12:9
12:10 30:4
31:14 34:22,22
Z
zoning 13:4 28:7
41:5 44:5
0
007516 32:17
07516 42:21
1
1 1:14 3:10 5:3,4
52:6
1,600 6:3
100 1:16 2:16
1000 2:11 52:3
102612 6:1
119 26:7 30:14
17 47:24
17th 38:6 46:12
18093 12:15
32:17 35:7,9
35:11
19 6:5
1st 49:9 52:8
2
2 3:11 5:23 6:14
2009 31:16
2011 33:2
2012 6:2,5 33:2
33:14
2013 9:10 10:15
10:23
2014 11:13 12:9
42:22 47:25
2016 5:21
2017 1:14 7:3
49:9,13 50:16
51:3 52:1,6,8
204 43:5
24 42:22
2455 2:11 52:3
2546 37:25
38:23 39:25
40:4 45:14
47:19,21
26 6:2 31:21
28th 5:21
29 6:3,10 9:10
3
3 3:12 8:13
3:10 1:17
30 3:13
32819 2:3
33304 2:12 52:4
33483 2:16
37 3:14
38 3:15
4
4 3:3,13 30:22
50:7
4:25 5:21
4:30 1:17 48:10
52:12
407-758-4194
2:4
45 3:16
48 50:7
49199 6:6
5
5 3:10,14 36:2
502014CA007...
1:4
561-221-9008
2:17
5th 7:3
6
6 3:11,15 37:18
6-17-2014 3:14
36:2
6,312.30 6:4
7
7 3:16 44:8 52:1
70 13:15 44:17
70-32 44:13
7032 47:2,3
7414 2:2
7516 35:14 36:1
8
8 3:12 11:12
8th 49:13 50:16
9
9:00 52:12
90 47:17
94 47:17
954-463-0100
2:13
954-755-6401
52:21