HomeMy Public PortalAboutRita Taylor Deposition1
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO.: 50-2013-CA-018101-XXXX-MB-AO
CHRISTOPHER F. O'HARE,
Plaintiff,
vs.
TOWN OF GULF STREAM,
Defendant.
_________________________________/
100 Sea Road
Gulf Stream, Florida
Friday, 9:00 a.m.
April 7, 2017
VIDEOTAPED DEPOSITION of RITA TAYLOR, a
witness herein, taken pursuant to the Rules and Notice
hereinbefore filed, before SHAWN R. REMENAR, Court
Reporter and Notary Public in and for the State of
Florida at Large, at the Gulf Stream Town Hall, 100 Sea
Road, Gulf Stream, Florida, on Friday, April 7, 2017,
commencing at or about 9:00 a.m.
2
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 APPEARANCES:
2 LOUIS ROEDER, ESQUIRE
7414 Sparkling Lake Road
3 Orlando, Florida 32819
(407) 758-4194
4 Of Counsel
On behalf of the Plaintiff
5
EDWARD (TREY) C. NAZZARO, ESQUIRE
6 100 Sea Road
Gulf Stream, Florida 33483
7 (561) 276-5116
Of Counsel
8 On behalf of the Defendant
9
PRESENT:
10
RITA TAYLOR
11 Deponent
12 CHRISTOPHER F. O'HARE
13 WILLIAM H. THRASHER
ICMA-CM, CGFO, CGFM
14 Town Manager
15
REPORTED BY:
16
SHAWN R. REMENAR
17 Court Reporter and
Notary Public
18 101 Northeast 3rd Avenue
Suite 1500
19 Fort Lauderdale, Florida 33301
20
* * * * * *
21
22
23
24
25
3
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 I N D E X
2 WITNESS EXAMINATION PAGE
3
RITA TAYLOR Direct 4
4 (By Mr. Roeder)
5
6
7
8
9
10
11 E X H I B I T S
12 Exhibit No. 1
For Identification 13
13
Exhibit No. 2
14 For Identification 18
15 Exhibit No. 3
For Identification 19
16
Exhibit No. 4
17 For Identification 27
18 Exhibit No. 5
For Identification 28
19
Exhibit No. 6
20 For Identification 50
21 Exhibit No. 7
For Identification 53
22
Exhibit No. 8
23 For Identification 54
24 Exhibit No. 9
For Identification 55
25
4
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 MR. O'HARE: This is a video recording of
2 deposition of Rita Taylor in Christopher F.
3 O'Hare vs. Town of Gulf Stream, Case No.: CA
4 018101. This is being videotaped. The tape is
5 available to anyone who wants it after the
6 deposition.
7 THEREUPON:
8 RITA TAYLOR
9 having been first duly sworn, was examined and testified
10 as follows:
11 MR. ROEDER: I do.
12 DIRECT EXAMINATION
13 BY MR. ROEDER:
14 Q Good morning, Rita.
15 A Good morning.
16 Q Can you state your name for the record?
17 A Rita L. Taylor.
18 Q And your job position with the city of
19 Gulf Stream or town of Gulf Stream?
20 A Town clerk.
21 Q And address for the town?
22 A 100 Sea Road, S-e-a, Gulf Stream, two
23 words, Florida 33483.
24 Q Thank you. And you know if you have any
25 questions at all, we've been through this before. So
5
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 it's probably covering all ground. But if you have any
2 questions at all about the question that I've asked you,
3 please just, you know, interrupt me and ask for clari-
4 fication.
5 A (Witness nods head).
6 Q Try to answer to the best of your know-
7 ledge if you know. Attorney will tell you if you know,
8 say you know. But if you don't, say you don't know.
9 A (Witness nods head).
10 Q How long have you been employed with the
11 town of Gulf Stream?
12 A A little over twenty-seven years.
13 Q And you are the town clerk.
14 A I am.
15 Q Also the town supervisor of elections?
16 A Yes.
17 Q And when the town manager's away, do you
18 also assume some of his duties?
19 A Yes.
20 Q As part of your duties, do you participate
21 in the preparation of the agenda for the public meetings?
22 A Yes.
23 Q Do you participate in recording of minutes
24 of the public meetings?
25 A I do.
6
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q That--that's audio. Right? Is that audio
2 and video, or just audio?
3 A You mean my participation?
4 Q Or the meetings in general, they're done
5 in audio and video.
6 A Yes.
7 Q And your--your part is the audio portion.
8 A Yeah.
9 Q Okay. And do you supervise the processing
10 of permits?
11 A I supervise it.
12 Q Okay. Somebody else does it underneath
13 your supervision.
14 A Yes.
15 Q And do you participate in the straw
16 balloting for recent project to bury utility lines, that
17 type of stuff, too?
18 A Yes, um-hum.
19 Q And do you participate in the notice of
20 assessments to property owners for funding different
21 projects, or is that handled by somebody else?
22 A Well, if it's--if it's a city thing, not
23 the tax assessments or that sort of thing, not the ad
24 valorem. But any special assessments--
25 Q Special assessments?
7
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A --or anything like that, yes.
2 Q I already did that one.
3 MR. O'HARE: Okay.
4 BY MR. ROEDER:
5 Q But when you're saying "special assess-
6 ments", an example of that would be the special assess-
7 ments for the recent undergrounding project. That's it.
8 That would be an example.
9 A Yes.
10 MR. NAZZARO: No, Lou. I appreciate your
11 line of questioning here. I know you have a
12 motion to dismiss on a sort of different case.
13 So as far as your trying to take discovery in a
14 related case that you have a hearing for next
15 week, I would just like you to sort of stay on
16 track with what this case is that we're here
17 for today.
18 MR. ROEDER: We're just trying to, at the
19 beginning here, just get a general feeling for
20 the whole compass of all of her duties as town
21 clerk and then how that relates to the public
22 records. But duly noted.
23 BY MR. ROEDER:
24 Q Did you--as town clerk, did you partici-
25 pate in the recent annexation?
8
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A Sure.
2 Q Okay. And do you participate in the
3 preparation of any code enforcement actions?
4 A Yes.
5 Q Okay. Again, I'm just trying to get a
6 general idea of everything that you do, which seems to be
7 a lot. And you're also then the custodian of public
8 records for the town of Gulf Stream.
9 A Yes.
10 Q Okay. Can you describe for me in--in your
11 own words what a public record is?
12 MR. NAZZARO: Object to form.
13 THE WITNESS: It's a--documents that are
14 used in the various things that towns do with
15 the public.
16 BY MR. ROEDER:
17 Q And as custodian of the public records,
18 what are your specific responsibilities as you understand
19 them?
20 A Well, to--to maintain them, produce them
21 when asked, destroy them when it's time. That's, basi-
22 cally, it.
23 Q And as far as those responsibilities, do
24 you supervise other people who help you on those--
25 A I do.
9
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q --fulfilling those responsibilities? And
2 who are those people who assist you today?
3 A Renee, and Rebecca, and--
4 Q That's Renee--
5 A Basal.
6 Q --Basal and Rebecca?
7 A Tew, T-e-w.
8 Q Okay.
9 A And then we have a temp--
10 Q And a temp?
11 A --who helps with them.
12 Q And that temp is--could be different from
13 week-to-week.
14 A Well, we're pretty lucky. Most of the
15 time, they stay several months. But we've had several in
16 the past three years.
17 Q Do you have a name for the existing temp
18 today?
19 A Dee--I think it's Dina. I don't know what
20 her last name is.
21 Q Has anybody ever told you that they don't
22 want to assist with public records?
23 A Oh, yeah.
24 Q Who, specifically?
25 A Well, we had two ladies that--that quit
10
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 because they were too stressed with the public records.
2 And that was Kelly Avery and--and Freda. I forget her
3 last name.
4 Q Defosse?
5 A Yes.
6 Q Did they, either one or both of them,
7 submit anything in writing as to why they quit?
8 A I don't remember if they did or not.
9 Q And has Ms. Basal or Ms. Tew--I assume
10 it's Rebecca Tew. Ms.--it's okay. I'll refer to them as
11 Ms. Ms. Tew or Ms. Basal, has either one of them ex-
12 pressed any dissatisfaction with the--satisfaction with
13 assisting in public records?
14 A Not so far.
15 Q Why is that?
16 MR. NAZZARO: Object to form.
17 THE WITNESS: I don't know why. I'm
18 tickled to death they haven't.
19 BY MR. ROEDER:
20 Q Well, I'm just trying to understand that
21 Ms. Avery and Ms. Defosse quit because of it. I'm just
22 wondering why.
23 A Well, they were at it for a longer time
24 than what these two are.
25 Q So--but nobody--neither one of those,
11
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 neither Ms. Basal nor Ms. Tew has ever expressed any
2 dissatisfaction regarding assisting with the production
3 of public records.
4 A Not to me, they haven't.
5 Q And you're--you're the supervisor. So
6 there's nothing you've heard from them regarding that.
7 A No.
8 Q Okay. Do you have a temporary worker
9 named Jones? Is that Dina? Is that her name, Dina
10 Jones?
11 A It could be, but I can't say for sure
12 because I don't remember.
13 Q We're specifically trying to find out who
14 was a temporary worker in that last November.
15 A I don't remember the date she started
16 here.
17 Q So you have any idea who the temp may have
18 been last November of 2016?
19 A It may have been her, but I'm not sure.
20 MR. NAZZARO: Lou, again this is a public
21 records request from 2013. So I'd just like to
22 keep you on track a little bit. I have no
23 objection to you asking questions generally of
24 Ms. Taylor.
25 But as far as what the town was doing in
12
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 2016, the time period that's relevant to this
2 request, I believe, is 2013 where the request
3 was received and responded to during that time
4 frame. So we're talking about a number of
5 years later, you know, just for expediency
6 purpose.
7 MR. ROEDER: Well, duly noted, but at the
8 hearings, we keep hearing a narrative about
9 what's happened since 2013. So we're just
10 trying to get down, plug--plug down the
11 narrative as to--we didn't bring it up. It's
12 been brought up in all the hearings what's
13 happened since 2013.
14 BY MR. ROEDER:
15 Q So you all know who were--who was actually
16 your temp in November of 2016. Was Ms. Defosse assisting
17 you with record requests in September of 2013?
18 A I don't remember if that--she could have
19 been.
20 Q We're just trying to get a handle on--we
21 had seen a response back from the clerk in 2013. Is that
22 something that was handled by you, or would that be
23 handled by Ms. Defosse or who else?
24 A It could have been me, or it could have
25 been either of the other ladies that were here at the
13
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 time.
2 Q Do you understand the--the public records
3 request that's the subject of this complaint right now
4 that we're talking about?
5 A Say it again.
6 Q Do you understand the subject matter of
7 the existing public records request?
8 A It's something to do with pictures, I
9 thought.
10 MR. ROEDER: Okay. I want to go ahead and
11 introduce this here as Exhibit--Exhibit 1.
12 (Whereupon, the above-referenced documents
13 were marked as Exhibit No. 1 for identification)
14 BY MR. ROEDER:
15 Q Just have you take a look at that. Just
16 take your time. So you finished?
17 A Sure.
18 Q So what exactly is the--the subject matter
19 of that public records request?
20 A You want any pictures of George Elmore's
21 property that we have.
22 Q Okay. And that is the subject of the
23 complaint here today as far as you know.
24 A That's all it says in here.
25 Q Okay. Well, I'll get to that in a minute.
14
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 So you--do you know whether or not Ms. Defosse worked for
2 the town at the time this public records request was
3 made?
4 MR. NAZZARO: Object to form.
5 THE WITNESS: I don't--I don't remember
6 the dates that she started or left. She could
7 have been.
8 BY MR. ROEDER:
9 Q So how would we or how would you determine
10 who was actually handling the public records at that
11 point in time, November of 2016, or here at the date of
12 this request in September of 2013? How would you find
13 out who was actually handling the request?
14 MR. NAZZARO: Object to form.
15 THE WITNESS: Well, it could have been any
16 of us ladies that were here. And I would have
17 to look at the employment records to see who
18 was working at the--that particular time. But
19 I wouldn't know exactly if--even if I knew what
20 dates everybody was here, I still wouldn't
21 particularly know that one person was looking
22 for a particular record because we sort of all
23 work together.
24 BY MR. ROEDER:
25 Q So we wouldn't be able to--so what you're
15
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 telling me, there's no way of really finding out who
2 particularly handled this public records request in
3 September of 2013.
4 MR. NAZZARO: Object to form.
5 THE WITNESS: Probably--probably not.
6 BY MR. ROEDER:
7 Q Getting back to Ms. Defosse, you said that
8 she--don't mean to put words in your mouth. But para-
9 phrasing, you said she left because of the pressure from
10 the public records request.
11 A Yeah.
12 Q What exactly did she tell you why she was
13 leaving?
14 A Because of the stress from--that was
15 placed on her having to deal with public records, and
16 also she had other duties to perform as well.
17 Q But she specifically said that the--or one
18 of the reasons that she was leaving was because of public
19 records, the stress.
20 A The main reason, yeah.
21 Q Main reason? Do you have anything in
22 writing to that effect?
23 MR. NAZZARO: Object, form.
24 THE WITNESS: I don't know if we do or
25 not. I don't remember.
16
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 BY MR. ROEDER:
2 Q Are you aware that she said that she gave
3 the city a letter of resignation?
4 A If she did, then we've got it, but I don't
5 remember.
6 Q And who did you replace Ms. Defosse with?
7 A I--I guess it was Rebecca, I reckon.
8 Q Rebecca, not Kelly Avery?
9 A No. Kelly was here longer than--Kelly was
10 here the same time that Freda was here.
11 Q And you said "for other reasons". Let me
12 rephrase that here. You said, "Ms. Defosse left for a
13 number of reasons, the main one of which was the stress
14 from the public records." What were some of the other
15 reasons she gave for leaving?
16 MR. NAZZARO: Object to form.
17 THE WITNESS: Well, the--the stress of the
18 work. She did other things besides public
19 records.
20 BY MR. ROEDER:
21 Q Now Ms. Tew, she's a temporary who handled
22 the--she a temporary? No. She's not one of the
23 temporaries.
24 A No.
25 Q Ms. Tew, she's one of the regular--
17
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A Right.
2 Q And what's her first name again?
3 A Rebecca.
4 Q Rebecca, you say Rebecca Tew replaced
5 Defosse.
6 A Um-hum.
7 Q Did she have the same duties as Defosse?
8 A No. They changed. They changed some.
9 Q She had more or less.
10 A Well, just redistributed some of it. We
11 gave the public records--Freda's public records work to
12 Kelly. And some of Kelly's work then went to Freda or
13 Rebecca.
14 Q As far as capability, are Ms. Defosse and
15 Ms. Tew, basically, just as capable as far as public
16 records, responsive?
17 A As far as I can see, they're all capable.
18 Q So if somebody submits a public records
19 request, and they needed or wanted to know who was
20 actually handling it, you can't tell them who's actually
21 handling it.
22 MR. NAZZARO: Object to form.
23 THE WITNESS: Not really because we've all
24 got a finger in it.
25 BY MR. ROEDER:
18
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q Then help me understand. If everybody has
2 a finger in it, everybody works for you. And there's
3 either two people plus a temp working for you handling
4 public records. How would one person get stressed out?
5 A Because there was so much of it, and they
6 tried to turn it out as quickly as possible. And that--
7 that adds a lot of stress.
8 Q Then explain to me why one person would
9 quit because of the stress and another person wouldn't.
10 MR. NAZZARO: Object to form.
11 THE WITNESS: Well, different people have
12 different hangups, I guess. Or some people can
13 stand more stress than others. Why I don't
14 know.
15 BY MR. ROEDER:
16 Q You never seem to be stressed. At least,
17 you don't show it. That's not a question.
18 A No.
19 Q That's just--it's a comment. Let me see
20 here.
21 MR. ROEDER: I have Exhibit 2. You might
22 want to go off the record to label this one.
23 (Whereupon, the above-referenced documents
24 were marked as Exhibit No. 2 for identification)
25 (Whereupon, a brief, informal discussion
19
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 was held off the record.)
2 BY MR. ROEDER:
3 Q Let's see, one, two, here it is. Can you
4 look at this Rita and tell me what it is?
5 A It's a reply to a public records request,
6 an acknowledgement of receiving it, basically.
7 Q Is it actually a response to the public
8 records request in Exhibit 1?
9 A Yes, it is.
10 Q I'll come back to this one.
11 MR. O'HARE: What's that?
12 MR. ROEDER: I'll come back to this one.
13 MR. O'HARE: Okay.
14 MR. ROEDER: And here you want to go off
15 record. This is Exhibit No. 3.
16 (Whereupon, the above-referenced documents
17 were marked as Exhibit No. 3 for identification)
18 BY MR. ROEDER:
19 Q I'll give you this. Oh, one second, give
20 you that, Rita. That's what's been labeled as Exhibit
21 No. 3. Can you tell me what that is please?
22 A Yeah. This is a reply that would have
23 been sent as a result of this public records request
24 advising that no such records exist.
25 Q Okay. Does it specifically say who the
20
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 author is of it or what--excuse me. Let me rephrase
2 that. What does it list as the author of the letter?
3 A Well, they all say "Sincerely, Town Clerk,
4 Custodian of the Records". That's me.
5 Q So if it's anybody other than you, which I
6 think in previous answers you've given that other people
7 could be handling it. If it's seen by other than you,
8 there's no way of knowing who that might be.
9 A That's right. It's one of the other two.
10 Q And are you--are you aware as part of your
11 knowledge of public records, the public records law, that
12 there's a requirement that the custodian notify, request,
13 or if someone else were responsive to public records
14 request besides the custodian?
15 MR. NAZZARO: Object to form.
16 THE WITNESS: Well, we are putting that on
17 there now. But back then, we didn't.
18 BY MR. ROEDER:
19 Q So now you have--whoever the specific
20 responder is, you're saying now you actually do that, but
21 back--back then you didn't. So no one ever informed Mr.
22 O'Hare that anybody different other than you was actually
23 handling this public records request.
24 A No.
25 Q And all you know right now as you--based
21
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 on what you have in front of you and your knowledge,
2 basically, you can't say who specifically handled this
3 public records request.
4 A We may have all looked. It's a small
5 office.
6 Q So as you sit here today, you did not. Or
7 do you recall whether or not you actually searched for
8 this record? Or do you know for sure that somebody else
9 searched for it?
10 MR. NAZZARO: Object to form.
11 THE WITNESS: I vaguely recall this, and
12 I'm sure that we discussed it amongst ourselves
13 as we did most of them. If somebody couldn't
14 find it we'd say, "Does anybody know where else
15 to look?" But to say one person, no, I can't
16 say that.
17 BY MR. ROEDER:
18 Q So what you're saying is you all came to
19 the conclusion that no record existed, but only after
20 making a good faith effort to try and find it.
21 A We make a good faith effort on all of
22 them.
23 Q And again, what was the record that you
24 understand was being looked for here?
25 MR. NAZZARO: Object to form.
22
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 THE WITNESS: Photographs of Mr. Elmore's
2 property.
3 BY MR. ROEDER:
4 Q And how was that searched for?
5 MR. NAZZARO: Object to form.
6 THE WITNESS: Well, we would look in the
7 architectural review files. We would have
8 looked in the property files.
9 BY MR. ROEDER:
10 Q Now you say "architectural review files".
11 I don't mean to cut you off. Have you gotten any more?
12 A No. That's all right.
13 Q When you say "architectural review files",
14 what files specifically are those?
15 A When anybody's going to build a house or
16 do major renovations to the exterior, they go for a
17 review in front of the Architectural Review Board. And
18 then it's followed with an appearance in front of the
19 town commission, who gives the final decision on whether
20 or not what they want to do meets the code.
21 Q What about property files? How are those
22 different--
23 A Those--because those are the files where
24 building permits are requested. They're mostly con-
25 struction related.
23
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q And so A.R.B. is, basically, zoning or
2 planning related. And property files are building
3 related.
4 A Yeah.
5 Q I don't--I don't mean to put words in your
6 mouth.
7 A Yeah, no.
8 Q I'm just trying to understand.
9 A That's, basically, the difference, al-
10 though they can overlap somewhat. But detail wise, one
11 is more detailed towards the code. And the other is more
12 detailed towards construction.
13 Q Got it. That helps. Is there anywhere
14 else where photos of the residence may be located?
15 A Possibly in the code book as examples,
16 maybe.
17 Q What about the architectural style book?
18 A That's not complete either, but yes.
19 That's--there are some in there.
20 Q And after you got the complaint, did
21 anybody go back and look again? Or what--let me just
22 rephrase that. After you get a complaint file, do you go
23 back, and try and double-check again, and then make sure
24 there's nothing that's been overlooked?
25 A What do you mean a complaint file?
24
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q Well, when Mr. O'Hare, after the response
2 that no such records exist--
3 A Right.
4 Q --filed a complaint, so after the com-
5 plaint was filed, did you go back and check again? Or
6 did somebody check again?
7 A If we get--if somebody comes back and asks
8 again, yes, and we check every one that comes in.
9 Q So--but that--that's the request that
10 comes in.
11 A Yeah.
12 Q See, that's the request. But then a
13 complaint gets filed saying, "We didn't get what we
14 wanted." Do you go back and check again?
15 A Sure, um-hum.
16 Q Do you ever go back and contact the re-
17 quester after the complaint is filed, contact them again
18 about what you may or may not have confirmed after the
19 complaint was filed?
20 MR. NAZZARO: Object to form.
21 THE WITNESS: Well, if we think there's
22 something that they can add to help us locate
23 it, yes.
24 BY MR. ROEDER:
25 Q Well, speaking of locating the record,
25
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 what happens when you receive a document? How do you
2 create or receive a public record?
3 A It's logged.
4 Q How do you know how to label it so it
5 could be easily found in the future?
6 A They're numbered.
7 Q So something is numbered. But how does
8 someone know to look for photos in a certain file, versus
9 permits in another file, versus correspondence in another
10 file? How would you know where to look for the record?
11 A Well, when you work with it, they file by
12 subject matter, titles, some of them.
13 Q So do you have a formal system of--of
14 labels, or titles, or tags that you put on public
15 records?
16 A Well, if you've looked in our laser fiche
17 file, you'll see that each one of them goes under--there
18 are a number of headings. And it's determined when it's
19 received which heading it goes under.
20 Q When you say into your microfiche, you're
21 talking about your digital on-line records.
22 A Um-hum.
23 Q Those actually can do word searches. But
24 I'm just wondering for hard copy, do you have anything to
25 help you find a document? Like are they tagged a certain
26
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 way or labeled a certain way? Do you have a formal
2 system?
3 A I've got--if it's a contract, it goes in
4 the drawer where the contracts are. If it's a--
5 something else, off the top of my head, I can't think of
6 what--
7 Q Picture?
8 A Well, all pictures wouldn't go in one file
9 called "Pictures".
10 Q For the different types of pictures, one's
11 related--
12 A That's right.
13 Q --to code. Another's related to--
14 A Right.
15 Q --building permits. But there's nothing
16 similar to like a library has with a Dewey Decimal
17 System.
18 A No.
19 Q There's no type of system like that.
20 A No.
21 Q But if you get something like a--something
22 for architectural approval, which you say will go into
23 the code file or the A.R.B. file, it has--different parts
24 may be involved in going to architectural approval. So
25 do you file each and every part where it may be easily
27
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 accessible? Or you just leave everything in that file.
2 MR. NAZZARO: Object to form.
3 THE WITNESS: Everything stays.
4 BY MR. ROEDER:
5 Q So just hypothetically speaking, unless
6 you know personally that the picture is in a certain
7 file, since they're not labeled, "Pictures", unless it's
8 tagged uniquely, there's no other method besides just
9 your memory or knowledge to try and search out that
10 picture.
11 MR. NAZZARO: Object to form.
12 THE WITNESS: Well, if it's an A.R.P.B.,
13 all the A.R.P.B.'s are under one heading. And
14 there are subheadings after that, addresses,
15 basically.
16 BY MR. ROEDER:
17 Q So what I'm seeing, there's actually a
18 learning curve, that the learning curve is what really--
19 your experience or the experience of any of the people
20 working underneath you, that learning curve is what's
21 critical to being able to identify or find the records.
22 A Oh, sure. It's with anything.
23 MR. ROEDER: Okay. Mark this, you want to
24 go off, as Exhibit No. 4.
25 (Whereupon, the above-referenced documents
28
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 were marked as Exhibit No. 4 for identification)
2 BY MR. ROEDER:
3 Q Okay, Rita. I'll give you what's been
4 marked as Exhibit No. 4. You can look at that and get
5 familiar with it. Can you tell me in your own words
6 what's being requested there?
7 A He wants certified copies of a file, of an
8 A.R.--out of an A.R.P.B. file. He wants certain copies
9 certified.
10 Q And when was that request made?
11 A October 26, 2016.
12 MR. ROEDER: I actually have an original
13 here we can submit as Exhibit No. 5.
14 (Whereupon, the above-referenced documents
15 were marked as Exhibit No. 5 for identification)
16 BY MR. ROEDER:
17 Q Rita, let me give you this. And if you
18 could, describe to me what that is.
19 A It's a receipt for certified copies,
20 fifteen dollars received from Chris O'Hare. And the
21 receipt is signed by Renee.
22 Q Does that match up? You take a look at
23 Exhibit No. 4 again. Does that match up to the request
24 at the bottom of Exhibit No. 4, fifteen pages at a dollar
25 a page?
29
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A Yes. It seems to, although the num--the--
2 the file that they were taken from is not shown on this
3 receipt. But the dates are matching. And the amount
4 matches. And it is received from Mr. O'Hare. And that's
5 who the request was from. So I think it's safe to say
6 that, that matches with that.
7 MR. ROEDER: Okay. If you want to go off
8 record, I got--yeah. We can go off record. I
9 got--
10 COURT REPORTER: Do you concur?
11 MR. NAZZARO: For what purpose? Just--
12 MR. ROEDER: For lining up another
13 exhibit.
14 MR. NAZZARO: Yeah. That's fine.
15 (Whereupon, a brief, informal discussion
16 was held off the record.)
17 MR. ROEDER: I'll go back on record
18 with--you try on this one yet? Just back
19 on--back on record. It's Exhibit No. 5. I may
20 swap out the actual receipt because we may need
21 that for trial instead of the copy. And I'll
22 leave you the copy of this for the record.
23 COURT REPORTER: Do you want me to mark
24 No. 6 now?
25 MR. ROEDER: Just one second. If we could
30
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 take care of the--
2 MR. NAZZARO: What number?
3 MR. ROEDER: Remark No. 5 as the copy of
4 the receipt, and I'll keep the original. The
5 reason I'm doing that, I'm going to do the same
6 thing when I introduce No. 6.
7 (Whereupon, the above-referenced documents
8 were marked as Exhibit No. 6 for identification)
9 BY MR. ROEDER:
10 Q And Rita, I'll give you this here as
11 Composite No. 6. And so what are those? In your own
12 words, what are--what are those pages?
13 A It's a portion of the application that
14 went before the Architectural Review Board and the town
15 commission when Mr. Binnie was wanting to make improve-
16 ments to his house.
17 Q So let me ask you. Are those the same
18 fifteen pages that made up the request in Exhibit No. 4?
19 MR. NAZZARO: Object to form.
20 THE WITNESS: I don't know. I can't say
21 exactly, but everything appears that way.
22 BY MR. ROEDER:
23 Q Well, I think the page numbers are
24 actually labeled on Request No. 4. If you could, just
25 double-check and make sure that those are the page
31
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 numbers.
2 MR. NAZZARO: Object to form. There's no
3 pending question.
4 THE WITNESS: Well, these page--these page
5 numbers are not--the documents that you gave me
6 do not have page numbers on them. So--
7 BY MR. ROEDER:
8 Q So if you can't say what they are--
9 A --I assume so. They are in a packet, a
10 part of a packet as far as the material that would be in
11 a packet. But those are numbered when they put them on
12 the laser fiche. That--that's when the numbers get
13 assigned. These number--page numbers are not assigned
14 prior to having these hearings.
15 Q Then if this were--
16 A The software puts them on there.
17 Q But if this is what was given by your
18 office as a response to Request No. 4, how would we be
19 able to tell that it is responsive to Request No. 4 if
20 you can't tell it's responsive to Request No. 4?
21 MR. NAZZARO: Objection.
22 BY MR. ROEDER:
23 Q Or maybe just put it how would we be able
24 to tell that this is responsive to Request No. 4.
25 MR. NAZZARO: Object to the form of the
32
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 question.
2 THE WITNESS: Well, I guess you could go
3 back, and look at the laser fiche, and look to
4 see if it matched what these copies are that I
5 gave you. But I put my--my certificate on
6 there. I certified that it's what you asked
7 for. So I guess you're taking my word for it.
8 BY MR. ROEDER:
9 Q Oops. So you examined the first page, the
10 one that's--you mentioned as to William Binnie, a letter
11 to William Binnie.
12 A Um-hum.
13 Q So that's your certification at the
14 bottom. Correct?
15 A That's right.
16 Q And you did write this letter to Mr.
17 Binnie.
18 A Yes, I did.
19 Q And what's the date the letter was
20 written?
21 A May the 15th, 2011.
22 Q So it would be--would it be safe to say
23 that this is--these are excerpts as you just previously
24 mentioned? These are excerpt pages from an application
25 for architectural approval on this residence.
33
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A That's right.
2 Q And since the date of the record is May
3 15, 2011, this is a record that you had in your pos-
4 session in May, 2011.
5 A Yes.
6 Q And all these pages that are listed here,
7 each page is certified by you.
8 A Yes.
9 Q And just to verify, each one of the
10 fifteen pages has a certification on it by you.
11 A Yes.
12 Q And this certifies that--just to make
13 sure, this certified that it's from your town records.
14 A Yes.
15 Q Can you please look at the eighth page? I
16 guess you count in. This will be easier for you to do
17 than it will be for me. Let me see if that matches up
18 here. I think that does. Let me just make sure. Nope,
19 that doesn't match up.
20 A No. Maybe I miscounted.
21 MR. O'HARE: Is it right there?
22 MR. ROEDER: I think he's got the same one
23 I do.
24 THE WITNESS: I count this as eight.
25 MR. ROEDER: Okay. I think, Trey, you
34
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 count--yep, you count that as eight, too. I
2 think yours matches up. Just want to make
3 sure, Chris. Let me show you the pages--
4 THE WITNESS: This one had--
5 BY MR. ROEDER:
6 Q Yeah. That's it.
7 A --a label on it.
8 Q Yep. That's it. Okay. I think I got it
9 here. Can you describe to me what's on that Page 8 of
10 that record?
11 A Appears to be an aerial of a lot, was
12 taken from the property appraiser's book or record, says
13 "George Elmore" on the property record.
14 Q And can you tell me? There's a portion of
15 this photo that's highlighted. Correct?
16 A Yes.
17 Q What is that highlighted, that's high-
18 lighted?
19 MR. NAZZARO: Object to form.
20 THE WITNESS: I assume--and this is an
21 assumption--that, that is supposed to be
22 described in this property detail, which says
23 that it's George Elmore's. It's a view of
24 George Elmore's, and his tax value, and so on.
25 BY MR. ROEDER:
35
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q Okay. Now if you could go to Page 13, I'm
2 going to let you bring me up your Page 13 because mine
3 aren't in order. It should be the one also marked photo.
4 If you could hand me that for a second, I'll give it
5 right back to you.
6 MR. ROEDER: Trey, does this match up to
7 your thirteen? I don't think it does, or does
8 it?
9 MR. NAZZARO: Yeah.
10 MR. ROEDER: It does? Good.
11 BY MR. ROEDER:
12 Q Okay. I'll give this back to you, Rita.
13 Can you describe to me what that--what that is?
14 A It's an aerial view of an area in the town
15 with a highlighted lot on it. And it's saying that it is
16 George Elmore's, 1320 North Ocean. It's a property
17 appraiser's record.
18 Q So these two photos were photos that were
19 in the public records for Gulf Stream.
20 MR. NAZZARO: Object to form, mis-
21 characterizes the evidence.
22 THE WITNESS: Yes.
23 BY MR. ROEDER:
24 Q Okay. And so given the date of the
25 letter, May, 2011, would it be safe to say that these
36
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 existed in the record as of September 29, 2013?
2 MR. NAZZARO: Object to form.
3 THE WITNESS: Yes.
4 BY MR. ROEDER:
5 Q And knowing what you know now, would you
6 say that these now--these photos would be responsive to
7 Exhibit No. 1, public records request?
8 MR. NAZZARO: Object to form, mis-
9 characterizes the evidence.
10 THE WITNESS: No. I would not say that.
11 BY MR. ROEDER:
12 Q You described these as photos of Elmore's
13 property.
14 A This is a--
15 MR. NAZZARO: Objection, mischaracterizes
16 previous testimony.
17 THE WITNESS: --an aerial photograph of an
18 area. This is--you'd never know that, that was
19 George Elmore's property.
20 BY MR. ROEDER:
21 Q But it's labeled in the owner information
22 to the upper right, correct, in each one of the photos?
23 A Yes.
24 Q So--
25 A But these were not submitted as photos.
37
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 This was his list of property owners to notify.
2 Q So these are not photos as--these aren't
3 photos in your opinion.
4 A They were submit--they were submitted to
5 satisfy list--giving us a list of property owners within
6 so many feet to notify that there was to be a hearing.
7 Wasn't for the purpose of a photograph as we know a
8 photograph. It was--this is his list that he submitted.
9 Q So you're saying because it had a dif-
10 ferent purpose that it's not a photo.
11 MR. NAZZARO: Object to form.
12 THE WITNESS: As far as we're concerned,
13 yes.
14 BY MR. ROEDER:
15 Q But I don't think I'm mischaracterizing
16 it. You had referred to this in your descriptions as an
17 aerial photo of--
18 A Of an area.
19 Q --for a gentleman's property.
20 MR. NAZZARO: Object to form, mis-
21 characterizes previous evidence. She did not
22 call the photograph, Mr. Roeder.
23 MR. ROEDER: Well, we can go back and play
24 back what she first described the two photos.
25 MR. NAZZARO: Objection, again. It's
38
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 not--she did not refer to it as a photo. You
2 can refer to it as a photo all day. Ms. Taylor
3 did not say the word, photo. If you would like
4 the Court Reporter to read back her testimony--
5 MR. ROEDER: Yes, I would--
6 MR. NAZZARO: --absolutely.
7 MR. ROEDER: --because I'd like to see how
8 she described it. If you could, when she
9 described the two photos two different
10 instances, and I asked her to describe what it
11 was, can you tell me what she described it as?
12 (Whereupon, a recess was held)
13 MR. O'HARE: This is the resumption of the
14 deposition of Ms. Rita Taylor.
15 MR. ROEDER: Let's let Trey get seated.
16 MR. NAZZARO: I'd just like to note for
17 the record this was improperly noticed as a
18 video deposition because it didn't include the
19 information that was required. I have no
20 objection to Mr. O'Hare videotaping the
21 deposition.
22 But as far as using it as some sort of
23 official record, I would just note that again,
24 it's not properly noticed. The notice didn't
25 include the name of the person who would be
39
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 taking the video and all that's required. So
2 you could please go ahead and finish. I
3 believe we were at the issue of whether or not
4 Ms. Taylor referred to something in Exhibit 6.
5 MR. ROEDER: Just for convenience, we had
6 the Court Reporter look up the two instances
7 where she referred to the photographs. And
8 we'll have her just read back those two
9 instances where I describe--I asked you to
10 describe what you were looking at.
11 MR. NAZZARO: And again, you're referring
12 to them as photographs. They're pictures from
13 the property appraiser's office.
14 MR. ROEDER: Whatever they are.
15 MR. NAZZARO: What--what is in Exhibit 6?
16 MR. ROEDER: You can go back.
17 (Whereupon, the above-referenced question
18 and answer were read by the Court Reporter)
19 MR. ROEDER: Back on the record. So I'll
20 hand it to you. I'll split it with you, Trey.
21 One of them referred to an aerial view. The
22 other one referred to it as a photograph.
23 BY MR. ROEDER:
24 Q So you referred to them both ways. So
25 are--is one a view and the other one a photograph, or are
40
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 they both views? They both photographs?
2 A I don't consider them photographs. No,
3 not of--not of George Elmore's house. You'd never know
4 that was--if it didn't say so on there, you'd never know
5 it. And this was submitted to us as a list of properties
6 within a distance. It was not submitted in the appli-
7 cation as--as a photograph. It was a list. That's what
8 we used it for.
9 Q But in going back, you described it as a
10 photograph. That aside for the moment, was this actually
11 part of the public records back in 2013?
12 A Oh, yes.
13 MR. NAZZARO: Object to the form.
14 BY MR. ROEDER:
15 Q And if you had knowledge of these records,
16 would you have produced them back for Mr. O'Hare in 2013?
17 MR. NAZZARO: Object to the form.
18 THE WITNESS: Say it again.
19 BY MR. ROEDER:
20 Q If you had knowledge of these records in
21 2013, would you have produced them for Mr. O'Hare?
22 MR. NAZZARO: Object to the form.
23 THE WITNESS: Well, if I had thought that
24 they were photographs of Mr. Elmore's house,
25 yes, I would have. But I wouldn't--I wouldn't
41
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 have known to--to--I wouldn't have thought to
2 look at these as a photograph of Mr. Elmore's
3 house.
4 BY MR. ROEDER:
5 Q Well, let me refer you back to Exhibit 1
6 if you could look at that again. Is it asking for a
7 photograph of--photos of Mr. Elmore's house or Mr.
8 Elmore's property?
9 A No. You're quite right. It is asking for
10 his property, but I would never--when I would have looked
11 at this, I would have thought of what he wanted was to
12 actually see his house. I wouldn't have considered this
13 because this to me was a list.
14 Q All right. And it--you said you never
15 would have thought. So were you confused at the time, do
16 you think? Or you knew he was--you say he was looking
17 for photos. But you never would have thought that an
18 aerial view--
19 A I wouldn't have considered this a photo.
20 Q So there was no thought of asking for any
21 clarification at all.
22 A Not at that time, no. We ask for clarifi-
23 cations a lot of times.
24 Q But you didn't ask for a clarification on
25 this one.
42
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A No.
2 Q Okay. Just to recap here, you've--you've
3 talked about as town clerk, you have served as supervisor
4 of elections. You sometimes act in the absence of town
5 manager with some of--help him with some of his duties.
6 You participate in preparing agendas for the meetings.
7 You supervise the process for building permits.
8 You participated in the straw ballots or
9 the undergrounding process. You participate in the
10 town's annexations of neighboring properties. And you
11 participate in the preparation of code enforcement
12 actions. And then top of all that, you're also the
13 custodian of public records.
14 Other than the people you referred to
15 earlier today, or maybe just to go back and just clarify,
16 how many people help you with all these duties?
17 MR. NAZZARO: Object to form.
18 THE WITNESS: The--the ladies that--that I
19 mentioned and--
20 BY MR. ROEDER:
21 Q Ms. Tew?
22 A And--
23 Q Ms. Basal?
24 A Yeah.
25 Q The temp?
43
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A And the temp and sometimes the town
2 manager.
3 MR. ROEDER: Off the record.
4 (Whereupon, a brief, informal discussion
5 was held off the record.)
6 BY MR. ROEDER:
7 Q All these duties we talked about, at any
8 one time, do you consider yourself to be overwhelmed?
9 MR. NAZZARO: Object to form.
10 THE WITNESS: No. Overworked maybe, but
11 not overwhelmed.
12 BY MR. ROEDER:
13 Q Have you--so I guess to paraphrase, you've
14 never been overwhelmed in your job. Even though it has
15 all these characteristics, you've never felt overwhelmed.
16 A Oh, before I had any help, yes.
17 Q Oh, okay.
18 A I was back then.
19 Q Okay. Have you ever had to shut down the
20 office because you've been overwhelmed, or you all had
21 too much work to do?
22 A No. We've never shut down the office. It
23 just--everything just has to wait till we get to it.
24 Q Now we mentioned what help you had--you
25 have here today, but what help specifically? Can you
44
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 recall what help you had in--personnel wise back in 2013,
2 specifically, the date of this request, September, 2013?
3 A I can't say exactly, but because I don't
4 have all those dates at the tip of my fingers. I don't
5 need them, but we had--Gail was here.
6 Q Gail who?
7 A Begin with an A., Abeloe.
8 Q Thank you. I never knew how that was
9 pronounced.
10 A That's the way she pronounced it.
11 Q I thought it was Gail Abeloe.
12 A No. It's Abeloe.
13 Q I'm sorry. Who else?
14 A We had Linda Harvel, but I'm not sure if
15 she was here at the period that you're talking about.
16 Q Was Ms. Defosse here at that time?
17 A I know she took Gail's place.
18 Q And then there's--
19 A And Kelly.
20 Q --Kelly Avery. But you'd--
21 A She took Linda's place, I think. And at
22 that particular time, I don't know if we had a temp or
23 not. And I would know who it was if we did.
24 Q But you've never had to refuse to provide
25 service to city, you know, town customers due to all
45
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 these--the status of all these different jobs?
2 A No. Everything just has to wait. We have
3 somebody walk in. We take care of them. That's why we
4 have so many different people involved in all of the
5 duties actually.
6 Q So you've never had to shut down your
7 office because of all the requests that Mr. O'Hare's
8 made.
9 MR. NAZZARO: Objection, asked and
10 answered.
11 THE WITNESS: No. They--we've had to
12 withhold what maybe is considered promptness,
13 but we never have shut down the office. Door's
14 always open.
15 BY MR. ROEDER:
16 Q Have you ever been scared because of
17 public records requests from Mr. O'Hare?
18 A What do you mean scared?
19 Q That's a phrase that's been used by one of
20 the past employees. I just wondered. Have you ever been
21 scared from the public records requests that have been
22 made?
23 A Well, I don't get scared too much, but I
24 don't know. I don't really know what--how it was used--
25 Q So--
46
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A --whoever said that. But--
2 Q So you've never had an employee tell you
3 they were scared because of the public records requests.
4 MR. NAZZARO: Object to form.
5 THE WITNESS: No, not--not scared of
6 public records requests. I've had them say
7 they were scared of some people.
8 BY MR. ROEDER:
9 Q Anybody tell you they were scared of Mr.
10 O'Hare?
11 A I don't recall his name being attached to
12 that.
13 Q Has Mr.--to your knowledge, has Mr. O'Hare
14 been rude to you?
15 A No.
16 Q Do you know if he's ever been rude to any
17 of your employees?
18 A Not that I know of.
19 Q Has he ever threatened you or threatened
20 one of the employees?
21 A Not to my knowledge. He better not.
22 Q He better not either. Has he ever de-
23 manded that the town respond to his request immediately?
24 A Oh, probably. Most all of them, if
25 they're--if we don't get to them when they think we
47
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 should, I'm sure that all of them have demanded for one
2 reason or another. But I don't recall a specific inci-
3 dent. No.
4 Q Has Mr. O'Hare ever said he would pay for
5 a public record, and then you produced it? And then he
6 not pay for it?
7 A We have--back in the early days, we have
8 prepared them. And then they didn't get picked up if
9 that's what you mean by not paying for them. Anything
10 that--as far as I know, anything that he actually took
11 hold of or--or took he's paid for. But he did leave some
12 that we had prepared that he didn't pick up.
13 Q Has he ever told you--has he ever said,
14 "Please prepare this, and I'll pay for them," and then he
15 doesn't show up and pick them up?
16 MR. NAZZARO: Asked and answered.
17 THE WITNESS: Not re--
18 MR. NAZZARO: We have some cases pending
19 that this specifically touches on that are set
20 for hearing, I believe, this month. So as far
21 as your trying to take discovery in other cases
22 that are pending in a few weeks, I'd rather you
23 stick to what the issues are here.
24 There was a response, but there was no
25 record. I don't understand how the issue of
48
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 payment, and picking up, not picking up comes
2 in other than you taking discovery in other
3 cases that are not noticed for deposition right
4 now.
5 BY MR. ROEDER:
6 Q You--you can go ahead and answer that if
7 you want to.
8 A What--what is--I forgot the question.
9 Q Has he ever--have you ever given him a
10 price for a record? He said he will pay it and not--and
11 he not pick it up?
12 A Back in the early days, I think so.
13 Q But you can't tell what records that he's
14 said he would pay for it, and he failed to pick up.
15 A I can't off the top of my head. No.
16 Q So you can't say with any certainty that
17 he actually did commit to pick up records, and pay for
18 them, and failed to pick them up.
19 MR. NAZZARO: Asked and answered.
20 THE WITNESS: What I said.
21 BY MR. ROEDER:
22 Q Has a town manager ever expressed a dis-
23 satisfaction with anybody working underneath you for pub-
24 lic records?
25 A Not that I can recall.
49
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q Has the mayor ever expressed any dissatis-
2 faction with anybody working underneath you, public
3 records?
4 A Not that I can recall, no.
5 Q Have any of the people working underneath
6 you on public records ever made any mistakes regarding
7 the response to public records?
8 A Oh, probably. We all make mistakes when
9 you handle twenty-five hundred public records. There's
10 bound to be some mistakes.
11 Q Do you know what kind of mistakes?
12 MR. NAZZARO: Object to form.
13 THE WITNESS: I don't--I don't recall in
14 particular, no. Maybe pulled the wrong ones or
15 something, but I don't know that.
16 BY MR. ROEDER:
17 Q I guess the previous question I asked if
18 you--if Mr. O'Hare had ever committed to pay for public
19 records, asked you to produce them, and failed to pick
20 them up, and you couldn't recall for sure, has he ever
21 asked you to make a list of any records that he may have
22 committed to pick up and failed to pick up?
23 MR. NAZZARO: Object to form.
24 THE WITNESS: Not that I recall.
25 BY MR. ROEDER:
50
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q As far as your knowledge, has anybody who
2 works underneath you on public records ever--to your
3 knowledge, ever violated sections of one nineteen, public
4 records law?
5 MR. NAZZARO: Object to form.
6 THE WITNESS: Not that--not that I--
7 MR. NAZZARO: Calls for a legal con-
8 clusion.
9 BY MR. ROEDER:
10 Q Let me rephrase that.
11 A At least not knowingly.
12 Q Well, instead of--let me reword that. Has
13 anybody underneath you failed to provide public records
14 as required under Florida 119?
15 MR. NAZZARO: Same objection.
16 THE WITNESS: I suppose if they couldn't
17 find them, but not--not failing to reply to
18 them just because they didn't want to. No.
19 BY MR. ROEDER:
20 Q Has Mr. O'Hare ever asked for public
21 records that you considered to be frivolous?
22 MR. NAZZARO: Objection, calls for legal
23 conclusion.
24 THE WITNESS: Oh, I'm sure, yes.
25 BY MR. ROEDER:
51
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q You sure?
2 A I don't know which ones they were now,
3 but--
4 Q An example?
5 A I--I can't give you an example. But
6 when--when there are so many, there has to be some that
7 you would think, "What in the world would he need these
8 for?"
9 Q Has Mr. O'Hare ever asked you for records
10 about Officer Ginsburg?
11 A Well, he had public--several public
12 records requests regarding those.
13 Q About--has he asked you for public records
14 regarding code enforcement violations?
15 A Yes, um-hum.
16 Q Has he asked you for public records re-
17 garding different town policies?
18 A Yes.
19 Q Has he requested public records about
20 different town decisions?
21 A I don't understand what you mean by
22 decisions.
23 Q Decisions by the commission.
24 A Public records regarding--
25 Q Commission decisions.
52
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 MR. NAZZARO: Object to form.
2 THE WITNESS: I--I can't answer that.
3 I--I--I'm not privy of that.
4 BY MR. ROEDER:
5 Q Has he ever asked you for public records
6 about public meetings?
7 A Oh, I'm sure he has. I mean minutes and
8 everything, I don't remember specifically. But--
9 Q Why do you think Mr. O'Hare asked to in-
10 spect these public records?
11 A We don't ask that. We just try to supply
12 them.
13 Q Do you ever consider your obligations
14 underneath one nineteen to provide public records as
15 defined under open government to be burdensome?
16 A Oh, absolutely, when there's so many, but
17 that's the job. It's what it says. So that's what you
18 do.
19 Q So you think that your obligations to
20 comply are unreasonable.
21 MR. NAZZARO: Objection, mischaracterizes
22 previous testimony.
23 THE WITNESS: In some--in some regard,
24 yes, but it's the law. So you do it.
25 MR. ROEDER: Okay. Go off the record here
53
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 on Exhibit 7.
2 (Whereupon, the above-referenced documents
3 were marked as Exhibit No. 7 for identification)
4 (Whereupon, a brief, informal discussion
5 was held off the record.)
6 MR. ROEDER: Back on the record.
7 BY MR. ROEDER:
8 Q Rita, let me hand you that. Could you
9 look at that and tell me what it is?
10 A Well, it says it's a notice of commence-
11 ment.
12 Q All right. Is this one of the documents
13 you may have processed as one of your jobs for the town?
14 A That would be affiliated with the--the
15 Building Department. I personally would probably not
16 handle this particular document, but it would be some-
17 thing that's submitted.
18 Q What is it exactly?
19 A Well, when they file for an actual
20 building permit, this document is required to give notice
21 of commencement so that everybody is going to know that
22 these people--there's going to be stuff purchased to go
23 along with this job. And it has to do with liens.
24 Q What's the date on that?
25 A In this, is it--2005. It's the 26th day
54
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 of July, 2005.
2 Q And what's the name on the commencement?
3 A Percy Orthwein.
4 Q And the address?
5 A 543 Palm Lake, Gulf Stream.
6 MR. ROEDER: Okay. You can go off the
7 record for a new exhibit, eight.
8 (Whereupon, the above-referenced documents
9 were marked as Exhibit No. 8 for identification)
10 BY MR. ROEDER:
11 Q Rita, I'll give you this and ask if you
12 could tell me what it is.
13 A It's a--our receipt for our fees for a
14 building permit.
15 Q Have you ever seen this document before?
16 A This particular one, no. It's a standard
17 form.
18 Q So what is--it's a--says "a billing review
19 receipt". What's the date on it?
20 A 2010.
21 Q And the name?
22 A April 15th, Percy Orthwein.
23 Q And the address?
24 A 543 Palm way.
25 MR. ROEDER: And I think our final
55
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 exhibit, we can go off line again, No. 9.
2 (Whereupon, the above-referenced documents
3 were marked as Exhibit No. 9 for identification)
4 MR. ROEDER: We'll let Trey look at that.
5 THE WITNESS: Um-hum.
6 MR. NAZZARO: What's that? Oh, yeah. Let
7 the record show I'm hungry. It's--my stomach
8 just growled.
9 MR. ROEDER: Did it really?
10 MR. NAZZARO: Sorry. Apparently, it was--
11 MR. ROEDER: Don't put that on the record.
12 MR. NAZZARO: --for the deponent to notice
13 and say something. I'm very embarrassed.
14 MR. ROEDER: Is there a formal objection
15 to stomach growling? Probably should be.
16 BY MR. ROEDER:
17 Q Can you describe what that is?
18 A Well, it's the eight-page -- probably the
19 first page of a set of minutes dated June the 1st, 2007.
20 And they are commission meeting minutes.
21 Q Does it list you participating as the
22 clerk?
23 A Yes.
24 Q And who is the last person on the list of
25 participants?
56
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A Well, it says "Percy Orthwein", but that--
2 that just meant that he had appeared at some point in
3 the--in the meeting.
4 Q So you--you knew a Percy Orthwein.
5 A Yes. He's town resident.
6 Q And you also know that he's married to
7 the--to the mayor at the time, Joan Orthwein.
8 A She was vice-mayor at the time.
9 Q Vice-mayor at the time?
10 MR. NAZZARO: Again, Lou, you know this
11 relates to an appeal from a case that is
12 decided in the town's favor. This relates in
13 any way to that case, I would just ask that you
14 please try to keep on track. We're dealing
15 with one case that was noticed. We're not
16 dealing with cases that are on appeal.
17 We're not dealing with the undergrounding
18 that's set for motion to dismiss next week.
19 We're not dealing with other cases that are set
20 for summary judgment hearings later this month.
21 Let's try to keep it to this case, and I would
22 ask you do the same for Mr. Thrasher's depo-
23 sition.
24 MR. ROEDER: Let's go off the record for
25 one minute here.
57
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 (Whereupon, a brief, informal discussion
2 was held off the record.)
3 MR. ROEDER: Okay, want to go back on.
4 MR. NAZZARO: You can take Ms. Taylor and
5 Mr. Thrasher's deposition in any case. But
6 with this case and with those cases, I just
7 would want you to keep on track. We--we waited
8 half an hour for Mr. O'Hare to get here out of
9 a courtesy.
10 It's now ten past 11:00. We thought this
11 would be a little bit quicker. I'm sure Ms.
12 Rita has a lot of work to do. So if we could
13 just keep that in mind, I'd appreciate it.
14 MR. ROEDER: Duly noted.
15 BY MR. ROEDER:
16 Q You stated that one of your jobs is parti-
17 cipating in the preparation of agendas for the public
18 meetings.
19 A Um-hum.
20 Q So when I ask you about records that you
21 assemble, the meeting packets for those meetings, what is
22 a meeting packet?
23 A It's material, an accumulation of material
24 that is listed on the agenda itself, any backup.
25 Q So the packet contains records prepared in
58
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 regard to the matters before the commission.
2 A Sure.
3 Q Now--and the packet contains records pre-
4 pared regard to matters that may be considered by members
5 of the A.R.B.
6 A That's not on the commission agenda, but
7 on their own agenda, yes.
8 Q And how do the members, or the--or the
9 commissioners, or the A.R.P.B. receive these records
10 prior to the meeting?
11 A They're hand delivered by the Police
12 Department.
13 Q Wow, they're delivered to their homes or
14 to their offices.
15 A Yes, to their homes.
16 Q Fantastic.
17 A It's kind of standard in a town this size.
18 Q Who was the mayor at the time of the
19 request in Exhibit 1 was made? That's the September,
20 2003, '13, excuse me.
21 A What--what was the date?
22 Q September, 2013, do you know?
23 A Well, no, not for sure. The dates all run
24 together for me. I've worked for three mayors in Gulf
25 Stream. First, it was Mayer Koch. Then it was Mayor
59
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Orthwein, and then it was Mayor Morgan in that order. So
2 I don't--I don't know if Mayor Orthwein was still mayor
3 then because along about that time, Mayor Morgan was
4 appointed.
5 Q So do you know where Percy and Mayor
6 Orthwein's home, or vice-mayor at the time, where their
7 home was located?
8 A I know where it's located. Yeah.
9 Q Do you know the address?
10 A No.
11 Q Hold on just one second. All right. But
12 when you have these documents delivered, delivered to
13 their home, you know the addresses that are being de-
14 livered to. Right?
15 A No. The policeman does.
16 Q The policeman?
17 A I put their names on them.
18 Q So you put the names, and the police
19 deliver them to the address. Have you ever sent Mr.
20 O'Hare a notice of violation for anchoring a boat behind
21 the Orthweins' home?
22 A Yes.
23 MR. NAZZARO: I would just make the same
24 comment, Mr. Roeder. This has absolutely
25 nothing to do with the case that is noticed
60
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 here. That is a completely separate issue that
2 is also in the process of--I mean still in
3 litigation with our outside counsel.
4 I would like you to take discovery in this
5 case and this case only. You've taken dis-
6 covery in about four other cases that come to
7 mind.
8 MR. ROEDER: Well, but it does go--just
9 for the record, it does go to all of her duties
10 and duties that have been claimed to be over-
11 whelmed. So we're just trying to get an under-
12 standing of what those duties are, and whether
13 you're overwhelmed, and specifically, what--
14 what's involved in those duties.
15 MR. NAZZARO: I think she testified as far
16 as generally what her duties are. If you want
17 her to go into specifics, that is quite all
18 right. But I would ask that you maybe go into
19 specifics that don't implicate current cases
20 between your client and the town that are not
21 noticed for this particular deposition.
22 BY MR. ROEDER:
23 Q Is your understanding of the custodian of
24 records that you charge the requester of public records a
25 cost of producing the record?
61
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A Yes.
2 Q Are you entitled to charge a--for the
3 actual cost of duplication of the record?
4 MR. NAZZARO: Objection, calls for legal
5 conclusion.
6 THE WITNESS: By the law, as long as it's
7 by the law.
8 MR. ROEDER: I won't get into answering
9 the objection.
10 BY MR. ROEDER:
11 Q Are you entitled to charge for extensive
12 clerical supervisory assistance required to produce the
13 record?
14 A Yeah.
15 MR. NAZZARO: Objection, calls for legal
16 conclusion.
17 MR. ROEDER: I--again, I won't challenge
18 that. I'll just let the objection sit.
19 MR. NAZZARO: I mean if you're going to
20 read the statute and ask her if she knows what
21 the statute is, I mean--you know.
22 MR. ROEDER: I'm just asking her, her
23 understanding. She is the custodian of public
24 records.
25 BY MR. ROEDER:
62
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q Are you entitled to be paid providing an
2 estimate only for the actual--for the cost of producing a
3 public record?
4 MR. NAZZARO: Same objection.
5 THE WITNESS: Say it again.
6 BY MR. ROEDER:
7 Q In your opinion, are you entitled to be
8 paid for providing an estimate for the cost of producing
9 a public record?
10 MR. NAZZARO: Same objection.
11 THE WITNESS: I don't know what you mean
12 providing. Do you mean the time that we spend
13 to provide an estimate?
14 BY MR. ROEDER:
15 Q Let me just back up. When Mr. O'Hare
16 submits his public records request, he usually does so in
17 writing. Correct?
18 A Yes.
19 Q And at the bottom, he asks to be notified
20 if the cost of production is over a dollar to be given an
21 estimate of what that is. Correct? On those public
22 records requests, he notes in there that if the cost of
23 production, an estimate of the cost of production is over
24 one dollar, he'd like to be--to know that before the
25 actual record is produced.
63
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 A Yes.
2 Q So that is it your opinion that to provide
3 the estimate, you're allowed to charge him for at least
4 even providing the estimate?
5 A Well, we give them fifteen minutes free.
6 So usually we can estimate during that time.
7 Q Have you ever charged him or--
8 A I don't know.
9 Q --tried to charge him for an estimate?
10 A I don't--I don't know if we have. It's
11 possible. If it was--took a long, long time to even get
12 an estimate figured or estimated, it might have been
13 included in the end result. I--I can't say to that.
14 MR. NAZZARO: Again, Lou, there's no
15 estimate at issue here. This is taking
16 discovery in a completely separate case.
17 MR. ROEDER: Just talking about the
18 whole--
19 MR. NAZZARO: I mean I don't know how many
20 times I need to make the same objection.
21 MR. ROEDER: As many times as you want
22 because I'm talking about the whole process
23 here because that's what it relates to.
24 MR. NAZZARO: I don't think it relates to
25 the whole process. What is at issue here is
64
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 there was no record produced, whether or not
2 the record was produced. There's no estimate.
3 There's no cost to provide an estimate.
4 There's cases that are set for summary
5 judgment hearings on this exact issue that
6 you're taking discovery on. I'm sure that
7 videotape's going to end up with any number of
8 Mr. O'Hare or anyone's, you know, any of his
9 other lawyers in order to prepare for that
10 hearing.
11 So I don't appreciate you taking discovery
12 in a separate case when this case is about a
13 photo. The response was no such record, and
14 that's at issue. There--there's no estimate at
15 issue. There's no charging for estimates at
16 issue. That's at issue in a separate case.
17 That's going to a hearing for summary judgment
18 within the next two weeks.
19 MR. ROEDER: Objection is duly noted. If
20 you want to instruct her not to answer, you can
21 instruct her not to answer. But the faster we
22 get through this, I can go through these
23 questions, the faster we'll be out of here.
24 BY MR. ROEDER:
25 Q Are you--in your opinion as the custodian
65
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 of records, are you entitled to be paid a deposit if the
2 requester chooses not to agree to a deposit?
3 MR. NAZZARO: Object to form.
4 THE WITNESS: Say it again.
5 BY MR. ROEDER:
6 Q Are you entitled--the requester, Mr.
7 O'Hare, asks for an estimate. You give him an estimate
8 of X dollars, and you want a deposit. If he refuses to
9 give the deposit, are you entitled to give the--get the
10 deposit before you produce the public record?
11 A Yeah.
12 Q Okay. Under what circumstances would you
13 choose not to charge for producing a public record?
14 MR. NAZZARO: Object to form.
15 THE WITNESS: I don't know that there's
16 ever a time that we don't charge unless there's
17 some extenuating circumstance. But as a rule,
18 we--we do charge. However, we always give--
19 like I said, we give the fifteen minutes for
20 free.
21 BY MR. ROEDER:
22 Q So just to be clear, I just want to step
23 back here. Mr. O'Hare asked for an estimate beforehand.
24 You give him an estimate and say, "He needs to put a
25 deposit down." Then he refuses to put down the deposit.
66
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Are you still entitled to the deposit even though you're
2 not producing the record?
3 A No.
4 Q Okay. Have you charged--you mentioned
5 here the first fifteen minutes free. Have you ever
6 charged for labor on anything that took less than fifteen
7 minutes?
8 A I wouldn't know for sure. I would not
9 have intended to, but--
10 Q Have you ever required a deposit for less
11 than fifteen minutes in order to produce a public record?
12 A No.
13 MR. NAZZARO: Object to form.
14 THE WITNESS: Not that I'm aware of. I'll
15 put it that way.
16 MR. NAZZARO: If you're going to insist on
17 continuing to take the deposition testimony
18 from this individual on separate cases, I'll go
19 ahead and move for a Court order before
20 agreeing to any future deposition on these
21 individuals to make sure that you will take the
22 deposition relative to the case that you notice
23 the deposition for, not and for other cases,
24 Mr. Roeder.
25 I would appreciate as a professional
67
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 courtesy that you take deposition testimony in
2 this case only. And as far as--it is my
3 understanding being a law clerk and dealing
4 with a number of discovery disputes for two
5 years, literally nothing but discovery dis-
6 putes, your conduct is improper.
7 And I would have no problem going before a
8 Court before agreeing to any subsequent depo-
9 sition of these individuals to make sure that
10 you take deposition on whatever case is
11 noticed. Please continue to ask questions in
12 other cases that are--have not been properly
13 noticed. But I would just like to note my
14 objection in your statement that your conduct's
15 unprofessional.
16 MR. ROEDER: Now you've gone too far.
17 Your speaking objection, No. 1, is unprofes-
18 sional. No. 2, I've told you that we're--we're
19 sitting here. We've been presented with af-
20 firmative defenses.
21 And one of your co-counsel has made it
22 abundantly clear that he's going to challenge
23 everything to do with Mr. O'Hare, how the
24 records are done, bringing into question the
25 ability of the town to perform because of Mr.
68
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 O'Hare's public records request. So I have
2 every right to be able to explore and look for
3 possible evidence regarding the way the town
4 responds, if they have been held up, if they
5 have run up against a brick wall.
6 And the longer you object, the longer it's
7 going to take. But I'm--if you want to stop
8 the deposition because I'm asking questions
9 about how she performs what she considers to be
10 her duties or not her duties, what she
11 considers to be fees that she's--legitimate
12 fees to charge, those are all fair game.
13 MR. NAZZARO: I got it.
14 THE WITNESS: Oh, it went way over there.
15 Thank you.
16 MR. NAZZARO: I don't believe any of those
17 affirmative defenses are at issue in this case.
18 To the extent that they are, that's--that's--
19 you know that's your call. We'll let the Judge
20 figure it out before we agree to any subsequent
21 deposition. Please, continue.
22 BY MR. ROEDER:
23 Q Do you consider Gulf Stream to be a small
24 town?
25 A Yes.
69
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q Do you have the same governing powers in
2 your--to your knowledge, do you have the same governing
3 powers granted by the legislatures as other municipali-
4 ties--
5 A Yes.
6 Q --regardless of size?
7 A As far as I know, yeah.
8 Q And because of its size, is Gulf Stream
9 exempt from any of the requirements of one nineteen, the
10 public records law?
11 MR. NAZZARO: Object to form, calls for
12 legal conclusion.
13 THE WITNESS: Not that I know of.
14 BY MR. ROEDER:
15 Q And in your opinion as the custodian of
16 public records, is Gulf Stream to be excused from re-
17 sponding to public records requests due to its size?
18 A No.
19 Q So on--in your opinion, you provide the
20 same services to residents as they would get from any
21 clerk of any town size in Florida.
22 A (Witness nods head). Yes.
23 Q Are there any functions in all the duties
24 that we talked about that you participate, all the duties
25 that--the popery of duties that you have, are any of
70
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 those functions that you can't provide because of the
2 size of the town?
3 A We provide all of the services, although
4 because of our size, we may not get to them as fast. But
5 we do provide them. And we do whatever, if we have to
6 reach outside sometimes for help.
7 Q What is a public records log?
8 A It's a--it's a chart that shows when the
9 record was received, what number it was issued, what it
10 said, what was done to dispose of it.
11 Q And that's sometimes referred to as a
12 public records numbers log. Correct?
13 A Maybe some people refer to it that way.
14 To me, it's just the--the public records log.
15 Q Is every request for public records put in
16 that log?
17 A In our--I can't speak for other towns, but
18 in--in this town, it is.
19 Q Are there any entries in that log that are
20 not public records requests?
21 A Not to my knowledge.
22 Q And are there any entries in that log that
23 are changed after they're entered?
24 A Well, they're changed as the action con-
25 tinues on.
71
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q So if I was to get the current log, that
2 would be--every entry in that log would be accurate to
3 your--to your knowledge.
4 A To the best of my knowledge, yes.
5 Q Let me just confer. I think we're just--
6 we're over it unless we have some more questions here.
7 Do you commit--do you attend most commission meetings?
8 A Yes.
9 Q And at those commission's meetings, have
10 you ever heard Mr. O'Hare ask the commission any ques-
11 tions?
12 A Yes.
13 Q Does the mayor usually refer those
14 questions to Mr. Thrasher for a--to answer?
15 A Yes, but not--not on the podium.
16 Q Hold on here one second.
17 MR. O'HARE: Yeah. Forget about it.
18 MR. ROEDER: Okay. I think we're done.
19 Thank you, Rita.
20 MR. NAZZARO: I have nothing.
21 THE WITNESS: Okay. What about these?
22 (Whereupon, the videotaped deposition was
23 concluded at 11:30 a.m.)
24
25
72
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 CERTIFICATE OF OATH
2
3
4 STATE OF FLORIDA )
5 ) SS
6 COUNTY OF BROWARD )
7
8
9 I, the undersigned authority, certify that
10 RITA TAYLOR personally appeared before me and was duly
11 sworn.
12
13 WITNESS my hand and official seal this 21st
14 day of April, 2017.
15
16
17
18
19
20 ______________________________
SHAWN R. REMENAR, COURT REPORTER
21 Commission No.: FF925834
Expires: December 7, 2019
22
23
24
25
73
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 REPORTER'S DEPOSITION CERTIFICATE
2
3
4
5 I, SHAWN R. REMENAR, Registered Professional
6 Reporter, certify that I was authorized to and did
7 stenographically report the videotaped deposition of RITA
8 TAYLOR; that a review of the transcript was requested;
9 and that the transcript is a true and complete record of
10 my stenographic notes.
11
12 I further certify that I am not a relative,
13 employee, attorney or counsel of any of the parties, nor
14 am I a relative or employee of any of the parties'
15 attorney or counsel connected with the action, nor am I
16 financially interested in the action.
17
18 Dated this 21st day of April, 2017.
19
20
21
22 ___________________________________
23 SHAWN R. REMENAR, COURT REPORTER
24
25
74
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 DEPOSITION ERRATA SHEET
2 Page No. __________Line No.__________Change to:__________
3 _________________________________________________________
4 Reason for change:_______________________________________
5 Page No.___________Line No. _________Change to:__________
6 _________________________________________________________
7 Reason for change:_______________________________________
8 Page No.___________Line No.__________Change to:__________
9 Reason for change:_______________________________________
10 Page No.__________Line No.___________Change to:__________
11 _________________________________________________________
12 Reason for change:_______________________________________
13 Page No.__________Line No.___________Change to:__________
14 _________________________________________________________
15 Reason for change:_______________________________________
16 Page No.__________Line No.___________Change to:__________
17 _________________________________________________________
18 Reason for change:_______________________________________
19 Page No.__________Line No.___________Change to:__________
20 _________________________________________________________
21 Reason for change:_______________________________________
22 SIGNATURE:______________________DATE:____________
RITA TAYLOR
23
Please forward the original signed errata sheet to this
24 office so that copies may be distributed to all parties.
25
75
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 DAUGHTERS REPORTING, INC.
101 Northeast 3rd Avenue
2 Suite 1500
Fort Lauderdale, Florida 33301
3
(954) 755-6401
4
April 21, 2017
5
Ms. Rita Taylor
6 c/o Edward (Trey) C. Nazzaro, Esquire
100 Sea Road
7 Gulf Stream, Florida 33483
8 RE: CHRISTOPHER F. O'HARE VS. TOWN
OF GULF STREAM
9 Case No.: 50-2013-CA-018101-XXXX-MB-AO
10 Dear Ms. Taylor:
11 Relative to the above, please be advised that your
deposition taken on April 7, 2017, is available at our
12 office for reading, the making of any corrections,
additions or alterations, and signing your deposition
13 here at this office.
14 The deposition will be forwarded to LOUIS ROEDER,
ESQUIRE, as required, with or without your signature by
15 noon on May 5, 2017.
16 Please call this office to make an appointment to read
your deposition to assure that we will have someone here
17 to assist you.
18 Sincerely,
19
20 Shawn R. Remenar
Court Reporter
21
cc: Louis Roeder, Esquire
22 Edward (Trey) C. Nazzaro, Esquire
23
24
25
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
A
a--26:4 36:14
a--documents
8:13
a--for 61:2
a--it's 70:8
a--our 54:13
a--says 54:18
a--something
26:21
a--to 71:14
a.m 1:12,21
71:23
A.R.--out 28:8
A.R.B 23:1
26:23 58:5
A.R.P.B 27:12
28:8 58:9
A.R.P.B.'s 27:13
Abeloe 44:7,11
44:12
ability 67:25
able 14:25 27:21
31:19,23 68:2
About--has
51:13
above-referen...
13:12 18:23
19:16 27:25
28:14 30:7
39:17 53:2
54:8 55:2
absence 42:4
absolutely 38:6
52:16 59:24
abundantly
67:22
accessible 27:1
accumulation
57:23
accurate 71:2
acknowledge...
19:6
act 42:4
action 70:24
73:15,16
actions 8:3
42:12
actual 29:20
53:19 61:3
62:25
actual--for 62:2
ad 6:23
add 24:22
additions 75:12
address 4:21
54:4,23 59:9
59:19
addresses 27:14
59:13
adds 18:7
advised 75:11
advising 19:24
aerial 34:11
35:14 36:17
37:17 39:21
41:18
af-67:19
affiliated 53:14
affirmative
68:17
agenda 5:21
57:24 58:6,7
agendas 42:6
57:17
agree 65:2 68:20
agreeing 66:20
67:8
ahead 13:10
39:2 48:6
66:19
al-23:9
allowed 63:3
alterations 75:12
amount 29:3
anchoring 59:20
and--9:3 42:19
42:22
and--and 10:2
annexation 7:25
annexations
42:10
Another's 26:13
answer 5:6
39:18 48:6
52:2 64:20,21
71:14
answered 45:10
47:16 48:19
answering 61:8
answers 20:6
anybody 9:21
20:5,22 21:14
23:21 46:9
48:23 49:2
50:1,13
anybody's 22:15
anyone's 64:8
Apparently
55:10
appeal 56:11,16
appearance
22:18
APPEARANC...
2:1
appeared 56:2
72:10
appears 30:21
34:11
appli-40:6
application
30:13 32:24
appointed 59:4
appointment
75:16
appraiser's
34:12 35:17
39:13
appreciate 7:10
57:13 64:11
66:25
approval 26:22
26:24 32:25
April 1:12,20
54:22 72:14
73:18 75:4,11
architectural
22:7,10,13,17
23:17 26:22,24
30:14 32:25
are--31:8
are--have 67:12
are--is 39:25
are--what 30:12
area 35:14 36:18
37:18
as--as 40:7
as--it 67:2
as--these 37:2
aside 40:10
asked 5:2 8:21
32:6 38:10
39:9 45:9
47:16 48:19
49:17,19,21
50:20 51:9,13
51:16 52:5,9
65:23
asking 11:23
41:6,9,20
61:22 68:8
asks 24:7 62:19
65:7
assemble 57:21
assess-7:5,6
assessments 6:20
6:23,25
assessments--
6:24
assigned 31:13
31:13
assist 9:2,22
75:17
assistance 61:12
assisting 10:13
11:2 12:16
assume 5:18
10:9 31:9
assume--and
34:20
assumption--t...
34:21
assure 75:16
attached 46:11
attend 71:7
attorney 5:7
73:13,15
audio 6:1,1,2,5,7
author 20:1,2
authority 72:9
authorized 73:6
available 4:5
75:11
Avenue 2:18
75:1
Avery 10:2,21
16:8 44:20
aware 16:2
20:10 66:14
B
B 3:11
back 12:21 15:7
19:10,12 20:17
23:21,23 24:5
24:7,14,16
29:17,18 32:3
35:5,12 37:23
37:24 38:4
39:8,16,19
40:9,11,16
41:5 42:15
43:18 44:1
48:12 53:6
57:3 62:15
65:23
back--back
20:21
backup 57:24
balloting 6:16
ballots 42:8
Basal 9:5,6 10:9
10:11 11:1
42:23
basi-8:21
basically 17:15
19:6 21:2 23:1
23:9 27:15
be--every 71:2
be--to 62:24
be--would 32:22
BEACH 1:2
beginning 7:19
behalf 2:4,8
believe 12:2 39:3
2
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
47:20 68:16
best 5:6 71:4
better 46:21,22
billing 54:18
Binnie 30:15
32:10,11,17
bit 11:22 57:11
Board 22:17
30:14
boat 59:20
book 23:15,17
34:12
bottom 28:24
32:14 62:19
bound 49:10
brick 68:5
brief 18:25
29:15 43:4
53:4 57:1
bring 12:11 35:2
bringing 67:24
brought 12:12
BROWARD
72:6
build 22:15
building 22:24
23:2 26:15
42:7 53:15,20
54:14
burdensome
52:15
bury 6:16
but--46:1 51:3
52:8 66:9
C
C 2:5 75:6,22
c/o 75:6
CA 4:3
call 37:22 68:19
75:16
called 26:9
calls 50:7,22
61:4,15 69:11
cally 8:22
capability 17:14
capable 17:15,17
care 30:1 45:3
case 1:3 4:3 7:12
7:14,16 56:11
56:13,15,21
57:5,6 59:25
60:5,5 63:16
64:12,12,16
66:22 67:2,10
68:17 75:9
cases 47:18,21
48:3 56:16,19
57:6 60:6,19
64:4 66:18,23
67:12
cation 40:7
cations 41:23
cc 75:21
certain 25:8,25
26:1 27:6 28:8
certainty 48:16
certificate 32:5
72:1 73:1
certification
32:13 33:10
certified 28:7,9
28:19 32:6
33:7,13
certifies 33:12
certify 72:9 73:6
73:12
CGFM 2:13
CGFO 2:13
challenge 61:17
67:22
change 74:2,4,5
74:7,8,9,10,12
74:13,15,16,18
74:19,21
changed 17:8,8
70:23,24
characteristics
43:15
characterizes
35:21 36:9
37:21
charge 60:24
61:2,11 63:3,9
65:13,16,18
68:12
charged 63:7
66:6
charged--you
66:4
charging 64:15
chart 70:8
check 24:5,6,8
24:14
choose 65:13
chooses 65:2
Chris 28:20 34:3
Christopher 1:4
2:12 4:2 75:8
cipating 57:17
CIRCUIT 1:1,1
circumstance
65:17
circumstances
65:12
city 4:18 6:22
16:3 44:25
claimed 60:10
clari-5:3
clarifi-41:22
clarification
41:21,24
clarify 42:15
clear 65:22
67:22
clerical 61:12
clerk 4:20 5:13
7:21,24 12:21
20:3 42:3
55:22 67:3
69:21
client 60:20
clusion 50:8
co-counsel 67:21
code 8:3 22:20
23:11,15 26:13
26:23 42:11
51:14
com-24:4
come 19:10,12
60:6
comes 24:7,8,10
48:1
commence-
53:10
commencement
53:21 54:2
commencing
1:21
comment 18:19
59:24
commission
22:19 30:15
51:23,25 55:20
58:1,6 71:7,10
72:21
commission's
71:9
commissioners
58:9
commit 48:17
commit--do 71:7
committed
49:18,22
compass 7:20
complaint 13:3
13:23 23:20,22
23:25 24:4,13
24:17,19
complete 23:18
73:9
completely 60:1
63:16
comply 52:20
Composite
30:11
con-22:24 50:7
70:24
concerned 37:12
concluded 71:23
conclusion 21:19
50:23 61:5,16
69:12
concur 29:10
conduct 67:6
conduct's 67:14
confer 71:5
confirmed 24:18
confused 41:15
connected 73:15
consider 40:2
43:8 52:13
68:23
considered
41:12,19 45:12
50:21 58:4
considers 68:9
68:11
construction
23:12
contact 24:16,17
contains 57:25
58:3
continue 67:11
68:21
continuing
66:17
contract 26:3
contracts 26:4
convenience
39:5
copies 28:7,8,19
32:4 74:24
copy 25:24
29:21,22 30:3
correct 32:14
34:15 36:22
62:17,21 70:12
corrections
75:12
correspondence
25:9
cost 60:25 61:3
62:2,8,20,22
62:23 64:3
counsel 2:4,7
60:3 73:13,15
count 33:16,24
34:1
count--yep 34:1
COUNTY 1:2
72:6
Court 1:1,17
2:17 29:10,23
38:4 39:6,18
3
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
66:19 67:8
72:20 73:23
75:20
courtesy 57:9
67:1
covering 5:1
covery 60:6
create 25:2
critical 27:21
current 60:19
71:1
curve 27:18,18
27:20
custodian 8:7,17
20:4,12,14
42:13 60:23
61:23 64:25
69:15
customers 44:25
cut 22:11
D
D 3:1
date 11:15 14:11
32:19 33:2
35:24 44:2
53:24 54:19
58:21 74:22
dated 55:19
73:18
dates 14:6,20
29:3 44:4
58:23
DAUGHTERS
75:1
day 38:2 53:25
72:14 73:18
days 47:7 48:12
de-46:22 59:13
deal 15:15
dealing 56:14,16
56:17,19 67:3
Dear 75:10
death 10:18
December 72:21
decided 56:12
Decimal 26:16
decision 22:19
decisions 51:20
51:22,23,25
Dee--I 9:19
Defendant 1:8
2:8
defenses 67:20
68:17
defined 52:15
Defosse 10:4,21
12:16,23 14:1
15:7 16:6,12
17:5,7,14
44:16
deliver 59:19
delivered 58:11
58:13 59:12,12
demanded 47:1
dent 47:3
Department
53:15 58:12
depo-56:22 67:8
deponent 2:11
55:12
deposit 65:1,2,8
65:9,10,25,25
66:1,10
deposition 1:15
4:2,6 38:14,18
38:21 48:3
57:5 60:21
66:17,20,22,23
67:1,10 68:8
68:21 71:22
73:1,7 74:1
75:11,12,14,16
describe 8:10
28:18 34:9
35:13 38:10
39:10 55:17
describe--I 39:9
described 34:22
36:12 37:24
38:8,9,11 40:9
descriptions
37:16
destroy 8:21
detail 23:10
34:22
detailed 23:11
23:12
determine 14:9
determined
25:18
Dewey 26:16
dif-37:9
difference 23:9
different 6:20
7:12 9:12
18:11,12 20:22
26:10 38:9
45:1,4 51:17
51:20
different--22:22
digital 25:21
Dina 9:19 11:9,9
Direct 3:3 4:12
dis-48:22 60:5
67:5
discovery 7:13
47:21 48:2
60:4 63:16
64:6,11 67:4,5
discussed 21:12
discussion 18:25
29:15 43:4
53:4 57:1
dismiss 7:12
56:18
dispose 70:10
disputes 67:4
dissatis-49:1
dissatisfaction
10:12 11:2
distance 40:6
distributed
74:24
document 25:1
25:25 53:16,20
54:15
documents
13:12 18:23
19:16 27:25
28:14 30:7
31:5 53:2,12
54:8 55:2
59:12
doing 11:25 30:5
dollar 28:24
62:20,24
dollars 28:20
65:8
don't--I 14:5
23:5 49:13
59:2 63:10
Door's 45:13
double-check
23:23 30:25
drawer 26:4
due 44:25 69:17
duly 4:9 7:22
12:7 57:14
64:19 72:10
duplication 61:3
duties 5:18,20
7:20 15:16
17:7 42:5,16
43:7 45:5 60:9
60:10,12,14,16
68:10,10 69:23
69:24,25
E
E 3:1,11
earlier 42:15
early 47:7 48:12
easier 33:16
easily 25:5 26:25
Edward 2:5 75:6
75:22
effect 15:22
effort 21:20,21
eight 33:24 34:1
54:7
eight-page 55:18
eighth 33:15
either 10:6,11
12:25 18:3
23:18 46:22
elections 5:15
42:4
Elmore 34:13
Elmore's 13:20
22:1 34:23,24
35:16 36:12,19
40:3,24 41:2,7
41:8
embarrassed
55:13
employed 5:10
employee 46:2
73:13,14
employees 45:20
46:17,20
employment
14:17
enforcement 8:3
42:11 51:14
entered 70:23
entitled 61:2,11
62:1,7 65:1,9
66:1
entitled--the
65:6
entries 70:19,22
entry 71:2
errata 74:1,23
Esquire 2:2,5
75:6,14,21,22
estimate 62:2,8
62:13,21,23
63:3,4,6,9,12
63:15 64:2,3
64:14 65:7,7
65:23,24
estimated 63:12
estimates 64:15
ever--have 48:9
ever--to 50:2
everybody 14:20
18:1,2 53:21
evidence 35:21
36:9 37:21
68:3
ex-10:11
exact 64:5
exactly 13:18
14:19 15:12
4
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
30:21 44:3
53:18
EXAMINATI...
3:2 4:12
examined 4:9
32:9
example 7:6,8
51:4,5
examples 23:15
excerpt 32:24
excerpts 32:23
excuse 58:20
excused 69:16
exempt 69:9
exhibit 3:12,13
3:15,16,18,19
3:21,22,24
13:13 18:21,24
19:8,15,17,20
27:24 28:1,4
28:13,15,23,24
29:13,19 30:8
30:18 36:7
39:4,15 41:5
53:1,3 54:7,9
55:1,3 58:19
Exhibit--Exhi...
13:11
exist 19:24
exist--24:2
existed 21:19
36:1
existing 9:17
13:7
expediency 12:5
experience 27:19
27:19
Expires 72:21
explain 18:8
explore 68:2
expressed 11:1
48:22 49:1
extensive 61:11
extent 68:18
extenuating
65:17
exterior 22:16
F
F 1:4 2:12 4:2
75:8
faction 49:2
failed 48:14,18
49:19,22 50:13
failing 50:17
fair 68:12
faith 21:20,21
familiar 28:5
Fantastic 58:16
far 7:13 8:23
10:14 11:25
13:23 17:14,15
17:17 31:10
37:12 38:22
47:10,20 50:1
60:15 67:2,16
69:7
fast 70:4
faster 64:21,23
favor 56:12
feeling 7:19
fees 54:13 68:11
68:12
feet 37:6
felt 43:15
ferent 37:10
FF925834 72:21
fication 5:4
fiche 25:16
31:12 32:3
fifteen 28:20,24
30:18 33:10
63:5 65:19
66:5,6,11
figure 68:20
figured 63:12
file 23:22,25
25:8,9,10,11
25:17 26:8,23
26:23,25 27:1
27:7 28:7,8
29:2 53:19
filed 1:17 24:4,5
24:13,17,19
files 22:7,8,10,13
22:14,21,23
23:2
final 22:19 54:25
financially 73:16
find 11:13 14:12
21:14,20 25:25
27:21 50:17
finding 15:1
fine 29:14
finger 17:24
18:2
fingers 44:4
finish 39:2
finished 13:16
firmative 67:20
first 4:9 17:2
32:9 37:24
55:19 58:25
66:5
Florida 1:2,11
1:19,20 2:3,6
2:19 4:23
50:14 69:21
72:4 75:2,7
followed 22:18
follows 4:10
forget 10:2
71:17
forgot 48:8
form 8:12 10:16
14:4,14 15:4
15:23 16:16
17:22 18:10
20:15 21:10,25
22:5 24:20
27:2,11 30:19
31:2,25 34:19
35:20 36:2,8
37:11,20 40:13
40:17,22 42:17
43:9 46:4
49:12,23 50:5
52:1 54:17
65:3,14 66:13
69:11
formal 25:13
26:1 55:14
Fort 2:19 75:2
forward 74:23
forwarded 75:14
found 25:5
four 60:6
frame 12:4
Freda 10:2
16:10 17:12
free 63:5 65:20
66:5
Friday 1:12,20
frivolous 50:21
from--that 15:14
front 21:1 22:17
22:18
fulfilling 9:1
functions 69:23
70:1
funding 6:20
further 73:12
future 25:5
66:20
G
Gail 44:6,11
Gail's 44:17
game 68:12
garding 51:17
general 6:4 7:19
8:6
generally 11:23
60:16
gentleman's
37:19
George 13:20
34:13,23,24
35:16 36:19
40:3
get--if 24:7
Getting 15:7
Ginsburg 51:10
give 19:19,19
28:3,17 30:10
35:4,12 51:5
53:20 54:11
63:5 65:7,9,9
65:19,24
give--65:18
given 20:6 31:17
35:24 48:9
62:20
gives 22:19
go 13:10 18:22
19:14 22:16
23:21,22 24:5
24:14,16 26:8
26:22 27:24
29:7,8,17 32:2
35:1 37:23
39:2,16 42:15
48:6 52:25
53:22 54:6
55:1 56:24
57:3 60:9,17
60:18 64:22
66:18
go--just 60:8
goes 25:17,19
26:3
going 22:15
26:24 30:5
35:2 40:9
53:21,22 61:19
64:7,17 66:16
67:7,22 68:7
good 4:14,15
21:20,21 35:10
got--29:9
got--if 26:3
got--yeah 29:8
gotten 22:11
governing 69:1,2
government
52:15
granted 69:3
ground 5:1
growled 55:8
growling 55:15
guess 16:7 18:12
32:2,7 33:16
43:13 49:17
Gulf 1:7,11,19
1:20 2:6 4:3,19
4:19,22 5:11
5
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
8:8 35:19 54:5
58:24 68:23
69:8,16 75:7,8
H
H 2:13 3:11
had--34:4
had--Gail 44:5
had--you 43:24
half 57:8
Hall 1:19
hand 35:4 39:20
53:8 58:11
72:13
handle 12:20
49:9 53:16
handled 6:21
12:22,23 15:2
16:21 21:2
handling 14:10
14:13 17:20,21
18:3 20:7,23
hangups 18:12
happened 12:9
12:13
happens 25:1
hard 25:24
Harvel 44:14
has--different
26:23
have--back 47:7
have--whoever
20:19
head 5:5,9 26:5
48:15 69:22
heading 25:19
27:13
headings 25:18
heard 11:6 71:10
hearing 7:14
12:8 37:6
47:20 64:10,17
hearings 12:8,12
31:14 56:20
64:5
held 19:1 29:16
38:12 43:5
53:5 57:2 68:4
help 8:24 18:1
24:22 25:25
42:16 43:16,24
43:25 44:1
70:6
helps 9:11 23:13
hereinbefore
1:17
high-34:17
highlighted
34:15,17 35:15
hold 47:11 59:11
71:16
home 59:6,7,13
59:21
homes 58:13,15
hour 57:8
house 22:15
30:16 40:3,24
41:3,7,12
hundred 49:9
hungry 55:7
hypothetically
27:5
I
I'm--if 68:7
I--50:6
I--again 61:17
I--I 16:7 51:5
52:2 63:13
I--I--I'm 52:3
ICMA-CM 2:13
idea 8:6 11:17
identification
3:12,14,15,17
3:18,20,21,23
3:24 13:13
18:24 19:17
28:1,15 30:8
53:3 54:9 55:3
identify 27:21
if--even 14:19
immediately
46:23
implicate 60:19
improper 67:6
improperly
38:17
improve-30:15
in-52:9
in--in 8:10 70:18
in--personnel
44:1
inci-47:2
include 38:18,25
included 63:13
individual 66:18
individuals
66:21 67:9
informal 18:25
29:15 43:4
53:4 57:1
information
36:21 38:19
informed 20:21
insist 66:16
instances 38:10
39:6,9
instruct 64:20
64:21
intended 66:9
interested 73:16
interrupt 5:3
introduce 13:11
30:6
involved 26:24
45:4 60:14
is--could 9:12
is--I 48:8
is--it's 54:18
is--these 32:23
is--you'd 36:18
issue 39:3 47:25
60:1 63:15,25
64:5,14,15,16
64:16 68:17
issued 70:9
issues 47:23
it's--if 6:22
It's--my 55:7
it--2005 53:25
it--you 41:14
J
Joan 56:7
job 4:18 43:14
52:17 53:23
jobs 45:1 53:13
57:16
Jones 11:9,10
Judge 68:19
judgment 56:20
64:5,17
JUDICIAL 1:1
July 54:1
June 55:19
just--29:11 71:5
just--everything
43:23
just--it's 18:19
K
keep 11:22 12:8
30:4 56:14,21
57:7,13
Kelly 10:2 16:8
16:9 17:12
44:19,20
Kelly's 17:12
kind 49:11 58:17
knew 14:19
41:16 44:8
56:4
know 4:24 5:3,7
5:7,8,8 7:11
9:19 10:17
12:5,15 13:23
14:1,19,21
15:24 17:19
18:14 20:25
21:8,14 25:4,8
25:10 27:6
30:20 36:5,18
37:7 40:3,4
44:17,22,23,25
45:24,24 46:16
46:18 47:10
49:11,15 51:2
53:21 56:6,10
58:22 59:2,5,8
59:9,13 61:21
62:11,24 63:8
63:10,19 64:8
65:15 66:8
68:19 69:7,13
know-5:6
knowing 20:8
36:5
knowingly 50:11
knowledge 20:11
21:1 27:9
40:15,20 46:13
46:21 50:1,3
69:2 70:21
71:3,4
known 41:1
knows 61:20
Koch 58:25
L
L 4:17
label 18:22 25:4
34:7
labeled 19:20
26:1 27:7
30:24 36:21
labels 25:14
labor 66:6
ladies 9:25 12:25
14:16 42:18
Lake 2:2 54:5
Large 1:19
laser 25:16
31:12 32:3
Lauderdale 2:19
75:2
law 20:11 50:4
52:24 61:6,7
67:3 69:10
lawyers 64:9
learning 27:18
27:18,20
leave 27:1 29:22
47:11
leaving 15:13,18
16:15
ledge 5:7
6
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
left 14:6 15:9
16:12
legal 50:7,22
61:4,15 69:12
legislatures 69:3
Let's 19:3 38:15
56:21,24
letter 16:3 20:2
32:10,16,19
35:25
library 26:16
lic 48:24
liens 53:23
lighted 34:18
Linda 44:14
Linda's 44:21
line 7:11 55:1
74:2,5,8,10,13
74:16,19
lines 6:16
lining 29:12
list 20:2 37:1,5,8
40:5,7 41:13
49:21 55:21,24
list--giving 37:5
listed 33:6 57:24
literally 67:5
litigation 60:3
little 5:12 11:22
57:11
livered 59:14
locate 24:22
located 23:14
59:7,8
locating 24:25
log 70:7,12,14
70:16,19,22
71:1,2
logged 25:3
long 5:10 61:6
63:11,11
longer 10:23
16:9 68:6,6
look 13:15 14:17
19:4 21:15
22:6 23:21
25:8,10 28:4
28:22 32:3,3
33:15 39:6
41:2,6 53:9
55:4 68:2
looked 21:4,24
22:8 25:16
41:10
looking 14:21
39:10 41:16
lot 8:7 18:7
34:11 35:15
41:23 57:12
Lou 7:10 11:20
56:10 63:14
Louis 2:2 75:14
75:21
lucky 9:14
M
main 15:20,21
16:13
maintain 8:20
major 22:16
making 21:20
75:12
manager 2:14
42:5 43:2
48:22
manager's 5:17
manded 46:23
mark 27:23
29:23
marked 13:13
18:24 19:17
28:1,4,15 30:8
35:3 53:3 54:9
55:3
married 56:6
match 28:22,23
33:19 35:6
matched 32:4
matches 29:4,6
33:17 34:2
matching 29:3
material 31:10
57:23,23
matter 13:6,18
25:12
matters 58:1,4
Mayer 58:25
mayor 49:1 56:7
58:18,25 59:1
59:2,2,3,5
71:13
mayors 58:24
mean 6:3 15:8
22:11 23:5,25
45:18 47:9
51:21 52:7
60:2 61:19
62:11,12 63:19
mean--you
61:21
meant 56:2
meeting 55:20
56:3 57:21,22
58:10
meetings 5:21,24
6:4 42:6 52:6
57:18,21 71:7
71:9
meets 22:20
members 58:4,8
memory 27:9
ment 53:11
mentioned 32:10
32:24 42:19
43:24 66:4
ments 7:6,7
30:16
method 27:8
microfiche 25:20
mind 57:13 60:7
mine 35:2
minute 13:25
56:25
minutes 5:23
52:7 55:19,20
63:5 65:19
66:5,7,11
mis-35:20 36:8
37:20
mischaracteri...
36:15 52:21
mischaracteri...
37:15
miscounted
33:20
mistakes 49:6,8
49:10,11
moment 40:10
month 47:20
56:20
months 9:15
Morgan 59:1,3
morning 4:14,15
motion 7:12
56:18
mouth 15:8 23:6
move 66:19
Mr.--to 46:13
Ms.--it's 10:10
municipali-69:3
my--my 32:5
N
N 3:1
name 4:16 9:17
9:20 10:3 11:9
17:2 38:25
46:11 54:2,21
named 11:9
names 59:17,18
narrative 12:8
12:11
Nazzaro 2:5 7:10
8:12 10:16
11:20 14:4,14
15:4,23 16:16
17:22 18:10
20:15 21:10,25
22:5 24:20
27:2,11 29:11
29:14 30:2,19
31:2,21,25
34:19 35:9,20
36:2,8,15
37:11,20,25
38:6,16 39:11
39:15 40:13,17
40:22 42:17
43:9 45:9 46:4
47:16,18 48:19
49:12,23 50:5
50:7,15,22
52:1,21 55:6
55:10,12 56:10
57:4 59:23
60:15 61:4,15
61:19 62:4,10
63:14,19,24
65:3,14 66:13
66:16 68:13,16
69:11 71:20
75:6,22
need 29:20 44:5
51:7 63:20
needed 17:19
needs 65:24
neighboring
42:10
neither 11:1
never 18:16
36:18 40:3,4
41:14,17 43:14
43:15,22 44:8
44:24 45:6,13
46:2
never--when
41:10
new 54:7
nineteen 50:3
52:14 69:9
nobody--neither
10:25
nods 5:5,9 69:22
noon 75:15
Nope 33:18
North 35:16
Northeast 2:18
75:1
not--and 48:10
not--not 46:5
50:17 71:15
not--she 38:1
not--the 31:5
Notary 1:18 2:17
note 38:16,23
7
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
67:13
noted 7:22 12:7
57:14 64:19
notes 62:22
73:10
notice 1:16 6:19
38:24 53:10,20
55:12 59:20
66:22
noticed 38:17,24
48:3 56:15
59:25 60:21
67:11,13
notified 62:19
notify 20:12
37:1,6
November 11:14
11:18 12:16
14:11
Now--and 58:3
now--these 36:6
num--the--29:1
number 12:4
16:13 25:18
30:2 64:7 67:4
70:9
number--page
31:13
numbered 25:6
25:7 31:11
numbers 30:23
31:1,5,6,12,13
70:12
O
O'Hare 1:4 2:12
4:1,3 7:3 19:11
19:13 20:22
24:1 28:20
29:4 33:21
38:13,20 40:16
40:21 45:17
46:10,13 47:4
49:18 50:20
51:9 52:9 57:8
59:20 62:15
64:8 65:7,23
67:23 71:10,17
75:8
O'Hare's 45:7
68:1
OATH 72:1
object 8:12
10:16 14:4,14
15:4,23 16:16
17:22 18:10
20:15 21:10,25
22:5 24:20
27:2,11 30:19
31:2,25 34:19
35:20 36:2,8
37:11,20 40:13
40:17,22 42:17
43:9 46:4
49:12,23 50:5
52:1 65:3,14
66:13 68:6
69:11
objection 11:23
31:21 36:15
37:25 38:20
45:9 50:15,22
52:21 55:14
61:4,9,15,18
62:4,10 63:20
64:19 67:14,17
obligations
52:13,19
Ocean 35:16
October 28:11
of--37:17
of--help 42:5
of--I 60:2
of--let 50:12
of--not 40:3
of--of 25:13
of--photos 41:7
office 21:5 31:18
39:13 43:20,22
45:7,13 74:24
75:12,13,16
Officer 51:10
offices 58:14
official 38:23
72:13
Oh 9:23 19:19
27:22 40:12
43:16,17 46:24
49:8 50:24
52:7,16 55:6
68:14
okay 6:9,12 7:3
8:2,5,10 9:8
10:10 11:8
13:10,22,25
19:13,25 27:23
28:3 29:7
33:25 34:8
35:1,12,24
42:2 43:17,19
52:25 54:6
57:3 65:12
66:4 71:18,21
on--back 29:19
on--in 69:19
on--we 12:20
on-line 25:21
one's 26:10
ones 49:14 51:2
Oops 32:9
open 45:14
52:15
opinion 37:3
62:7 63:2
64:25 69:15,19
or--63:7
or--or 47:11
order 35:3 59:1
64:9 66:11,19
original 28:12
30:4 74:23
Orlando 2:3
Orthwein 54:3
54:22 56:1,4,7
59:1,2
Orthwein's 59:6
Orthweins'
59:21
our--I 70:17
outside 60:3
70:6
over-60:10
overlap 23:10
overlooked
23:24
overwhelmed
43:8,11,14,15
43:20 60:13
Overworked
43:10
owner 36:21
owners 6:20
37:1,5
P
packet 31:9,10
31:11 57:22,25
58:3
packets 57:21
page 3:2 28:25
30:23,25 31:4
31:6 32:9 33:7
33:15 34:9
35:1,2 55:19
74:2,5,8,10,13
74:16,19
page--these 31:4
pages 28:24
30:12,18 32:24
33:6,10
pages--34:3
paid 47:11 62:1
62:8 65:1
Palm 1:1 54:5,24
para-15:8
paraphrase
43:13
pared 58:4
part 5:20 6:7
20:10 26:25
31:10 40:11
parti-57:16
partici-7:24
participants
55:25
participate 5:20
5:23 6:15,19
8:2 42:6,9,11
69:24
participated
42:8
participating
55:21
participation
6:3
particular 14:18
14:22 44:22
49:14 53:16
54:16 60:21
particularly
14:21 15:2
parties 73:13
74:24
parties'73:14
parts 26:23
pate 7:25
pay 47:4,6,14
48:10,14,17
49:18
paying 47:9
payment 48:1
pending 31:3
47:18,22
people 8:24 9:2
18:3,11,12
20:6 27:19
42:14,16 45:4
46:7 49:5
70:13
people--there's
53:22
Percy 54:3,22
56:1,4 59:5
perform 15:16
67:25
performs 68:9
period 12:1
44:15
permit 53:20
54:14
permits 6:10
22:24 25:9
26:15 42:7
person 14:21
18:4,8,9 21:15
8
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
38:25 55:24
personally 27:6
53:15 72:10
photo 34:15 35:3
37:10,17 38:1
38:2,3 41:19
64:13
photograph
36:17 37:7,8
37:22 39:22,25
40:7,10 41:2,7
photographs
22:1 39:7,12
40:1,2,24
photos 23:14
25:8 35:18,18
36:6,12,22,25
37:2,3,24 38:9
41:17
phrase 45:19
phrasing 15:9
pick 47:12,15
48:11,14,17,18
49:19,22,22
picked 47:8
picking 48:1,1
picture 26:7
27:6,10
pictures 13:8,20
26:8,9,10 27:7
39:12
place 44:17,21
placed 15:15
plaint 24:5
Plaintiff 1:5 2:4
planning 23:2
play 37:23
please 5:3 19:21
33:15 39:2
47:14 56:14
67:11 68:21
74:23 75:11,16
plug--plug 12:10
plus 18:3
podium 71:15
point 14:11 56:2
police 58:11
59:18
policeman 59:15
59:16
policies 51:17
popery 69:25
portion 6:7
30:13 34:14
pos-33:3
position 4:18
possible 18:6
63:11 68:3
Possibly 23:15
powers 69:1,3
pre-58:3
preparation
5:21 8:3 42:11
57:17
prepare 47:14
64:9
prepared 47:8
47:12 57:25
preparing 42:6
PRESENT 2:9
presented 67:19
pressed 10:12
pressure 15:9
pretty 9:14
previous 20:6
36:16 37:21
49:17 52:22
previously 32:23
price 48:10
prior 31:14
58:10
privy 52:3
probably 5:1
46:24 49:8
53:15 55:15,18
Probably--pro...
15:5
problem 67:7
process 42:7,9
60:2 63:22,25
processed 53:13
processing 6:9
produce 8:20
49:19 61:12
65:10 66:11
produced 40:16
40:21 47:5
62:25 64:1,2
producing 60:25
62:2,8 65:13
66:2
production 11:2
62:20,23,23
professional
66:25 73:5
project 6:16 7:7
projects 6:21
promptness
45:12
pronounced
44:9,10
properly 38:24
67:12
properties 40:5
42:10
property 6:20
13:21 22:2,8
22:21 23:2
34:12,13,22
35:16 36:13,19
37:1,5,19
39:13 41:8,10
provide 44:24
50:13 52:14
62:13 63:2
64:3 69:19
70:1,3,5
providing 62:1,8
62:12 63:4
pub-48:23
public 1:18 2:17
5:21,24 7:21
8:7,11,15,17
9:22 10:1,13
11:3,20 13:2,7
13:19 14:2,10
15:2,10,15,18
16:14,18 17:11
17:11,15,18
18:4 19:5,7,23
20:11,11,13,23
21:3 25:2,14
35:19 36:7
40:11 42:13
45:17,21 46:3
46:6 47:5 49:2
49:6,7,9,18
50:2,3,13,20
51:11,13,16,19
51:24 52:5,6
52:10,14 57:17
60:24 61:23
62:3,9,16,21
65:10,13 66:11
68:1 69:10,16
69:17 70:7,12
70:14,15,20
public--several
51:11
pulled 49:14
purchased 53:22
purpose 12:6
29:11 37:7,10
pursuant 1:16
put 15:8 23:5
25:14 31:11,23
32:5 55:11
59:17,18 65:24
65:25 66:15
70:15
putes 67:6
puts 31:16
putting 20:16
Q
ques-71:10
quester 24:17
question 5:2
18:17 31:3
32:1 39:17
48:8 49:17
67:24
questioning 7:11
questions 4:25
5:2 11:23
64:23 67:11
68:8 71:6,14
quicker 57:11
quickly 18:6
quit 9:25 10:7
10:21 18:9
quite 41:9 60:17
R
R 1:17 2:16
72:20 73:5,23
75:20
re-24:16 51:16
69:16
re--47:17
reach 70:6
read 38:4 39:8
39:18 61:20
75:16
reading 75:12
really 15:1 17:23
45:24 55:9
really--27:18
reason 15:20,21
30:5 47:2 74:4
74:7,9,12,15
74:18,21
reasons 15:18
16:11,13,15
Rebecca 9:3,6
10:10 16:7,8
17:3,4,4,13
recall 21:7,11
44:1 46:11
47:2 48:25
49:4,13,20,24
recap 42:2
receipt 28:19,21
29:3,20 30:4
54:13,19
receive 25:1,2
58:9
received 12:3
25:19 28:20
29:4 70:9
receiving 19:6
recess 38:12
reckon 16:7
record 4:16 8:11
12:17 14:22
9
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
18:22 19:1,15
21:8,19,23
24:25 25:2,10
29:8,8,16,17
29:19,22 33:2
33:3 34:10,12
34:13 35:17
36:1 38:17,23
39:19 43:3,5
47:5,25 48:10
52:25 53:5,6
54:7 55:7,11
56:24 57:2
60:9,25 61:3
61:13 62:3,9
62:25 64:1,2
64:13 65:10,13
66:2,11 70:9
73:9
recording 4:1
5:23
records 7:22 8:8
8:17 9:22 10:1
10:13 11:3,21
13:2,7,19 14:2
14:10,17 15:2
15:10,15,19
16:14,19 17:11
17:16,18 18:4
19:5,8,23,24
20:4,11,11,13
20:23 21:3
24:2 25:15,21
27:21 33:13
35:19 36:7
40:11,15,20
42:13 45:17,21
46:3,6 48:13
48:17,24 49:3
49:6,7,9,19,21
50:2,4,13,21
51:9,12,13,16
51:19,24 52:5
52:10,14 57:20
57:25 58:3,9
60:24,24 61:24
62:16,22 65:1
67:24 68:1
69:10,16,17
70:7,12,14,15
70:20
records--Fred...
17:11
redistributed
17:10
refer 10:10 38:1
38:2 41:5
70:13 71:13
referred 37:16
39:4,7,21,22
39:24 42:14
70:11
referring 39:11
refuse 44:24
refuses 65:8,25
regard 52:23
58:1,4
regarding 11:2,6
49:6 51:12,14
68:3
regarding--
51:24
regardless 69:6
Registered 73:5
regular--16:25
related 7:14
22:25 23:2,3
26:13
related--26:11
relates 7:21
56:11,12 63:23
63:24
relative 66:22
73:12,14 75:11
relevant 12:1
Remark 30:3
remember 10:8
11:12,15 12:18
14:5 15:25
16:5 52:8
Remenar 1:17
2:16 72:20
73:5,23 75:20
Renee 9:3 28:21
Renee--9:4
renovations
22:16
rephrase 16:12
20:1 23:22
50:10
replace 16:6
replaced 17:4
reply 19:5,22
50:17
report 73:7
REPORTED
2:15
Reporter 1:18
2:17 29:10,23
38:4 39:6,18
72:20 73:6,23
75:20
REPORTER'S
73:1
REPORTING
75:1
request 11:21
12:2,2 13:3,7
13:19 14:2,12
14:13 15:2,10
17:19 19:5,8
19:23 20:12,14
20:23 21:3
24:9,12 28:10
28:23 29:5
30:18,24 31:18
31:19,20,24
36:7 44:2
46:23 58:19
62:16 68:1
70:15
requested 22:24
28:6 51:19
73:8
requester 60:24
65:2,6
requests 12:17
45:7,17,21
46:3,6 51:12
62:22 69:17
70:20
required 38:19
39:1 50:14
53:20 61:12
66:10 75:14
requirement
20:12
requirements
69:9
residence 23:14
32:25
resident 56:5
residents 69:20
resignation 16:3
respond 46:23
responded 12:3
responder 20:20
responds 68:4
response 12:21
19:7 24:1
31:18 47:24
49:7 64:13
responsibilities
8:18,23 9:1
responsive 17:16
20:13 31:19,20
31:24 36:6
result 19:23
63:13
resumption
38:13
review 22:7,10
22:13,17,17
30:14 54:18
73:8
reword 50:12
right 6:1 13:3
17:1 20:9,25
22:12 24:3
26:12,14 32:15
33:1,21 35:5
36:22 41:9,14
48:3 53:12
59:11,14 60:18
68:2
Rita 1:15 2:10
3:3 4:2,8,14,17
19:4,20 28:3
28:17 30:10
35:12 38:14
53:8 54:11
57:12 71:19
72:10 73:7
74:22 75:5
Road 1:11,20
2:2,6 4:22 75:6
Roeder 2:2 3:4
4:11,13 7:4,18
7:23 8:16
10:19 12:7,14
13:10,14 14:8
14:24 15:6
16:1,20 17:25
18:15,21 19:2
19:12,14,18
20:18 21:17
22:3,9 24:24
27:4,16,23
28:2,12,16
29:7,12,17,25
30:3,9,22 31:7
31:22 32:8
33:22,25 34:5
34:25 35:6,10
35:11,23 36:4
36:11,20 37:14
37:22,23 38:5
38:7,15 39:5
39:14,16,19,23
40:14,19 41:4
42:20 43:3,6
43:12 45:15
46:8 48:5,21
49:16,25 50:9
50:19,25 52:4
52:25 53:6,7
54:6,10,25
55:4,9,11,14
55:16 56:24
57:3,14,15
59:24 60:8,22
61:8,10,17,22
61:25 62:6,14
63:17,21 64:19
64:24 65:5,21
10
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
66:24 67:16
68:22 69:14
71:18 75:14,21
rude 46:14,16
rule 65:17
Rules 1:16
run 58:23 68:5
S
S 3:11
S-e-a 4:22
safe 29:5 32:22
35:25
satisfaction
48:23
satisfy 37:5
saying 7:5 20:20
21:18 24:13
35:15 37:9
says 13:24 34:12
34:22 52:17
53:10 56:1
scared 45:16,18
45:21,23 46:3
46:5,7,9
Sea 1:11,19 2:6
4:22 75:6
seal 72:13
search 27:9
searched 21:7,9
22:4
searches 25:23
seated 38:15
second 19:19
29:25 35:4
59:11 71:16
sections 50:3
see 14:17 17:17
18:19 19:3
24:12 25:17
32:4 33:17
38:7 41:12
seeing 27:17
seen 12:21 20:7
54:15
sent 19:23 59:19
separate 60:1
63:16 64:12,16
66:18
September
12:17 14:12
15:3 36:1 44:2
58:19,22
served 42:3
service 44:25
services 69:20
70:3
session 33:4
set 47:19 55:19
56:18,19 64:4
Shawn 1:17 2:16
72:20 73:5,23
75:20
she's--legitimate
68:11
she--don't 15:8
sheet 74:1,23
show 18:17 34:3
47:15 55:7
shown 29:2
shows 70:8
shut 43:19,22
45:6,13
signature 74:22
75:14
signed 28:21
74:23
signing 75:12
similar 26:16
Sincerely 20:3
75:18
sional 67:18
sit 21:6 61:18
sition 56:23 67:9
sitting 67:19
size 58:17 69:6,8
69:17,21 70:2
70:4
small 21:4 68:23
So--31:6 36:24
45:25
So--but 10:25
24:9
software 31:16
some-53:16
some--in 52:23
somebody 6:12
6:21 17:18
21:8,13 24:6,7
45:3
somewhat 23:10
sorry 44:13
55:10
sort 6:23 7:12,15
14:22 38:22
Sparkling 2:2
speak 70:17
speaking 24:25
27:5 67:17
special 6:24,25
7:5,6
specific 8:18
20:19 47:2
specifically 9:24
11:13 15:17
19:25 21:2
22:14 43:25
44:2 47:19
52:8 60:13
specifics 60:17
60:19
spect 52:10
spend 62:12
split 39:20
sponding 69:17
SS 72:5
stand 18:13
standard 54:16
58:17
standing 60:12
started 11:15
14:6
state 1:18 4:16
72:4
stated 57:16
statement 67:14
status 45:1
statute 61:20,21
stay 7:15 9:15
stays 27:3
stenographic
73:10
stenographica...
73:7
step 65:22
stick 47:23
stomach 55:7,15
stop 68:7
straw 6:15 42:8
Stream 1:7,11
1:19,20 2:6 4:3
4:19,19,22
5:11 8:8 35:19
54:5 58:25
68:23 69:8,16
75:7,8
stress 15:14,19
16:13,17 18:7
18:9,13
stressed 10:1
18:4,16
struction 22:25
stuff 6:17 53:22
style 23:17
subheadings
27:14
subject 13:3,6
13:18,22 25:12
submit 10:7
28:13
submit--they
37:4
submits 17:18
62:16
submitted 36:25
37:4,8 40:5,6
53:17
subsequent 67:8
68:20
Suite 2:18 75:2
summary 56:20
64:4,17
supervise 6:9,11
8:24 42:7
supervision 6:13
supervisor 5:15
11:5 42:3
supervisory
61:12
supply 52:11
suppose 50:16
supposed 34:21
sure 8:1 11:11
11:19 13:17
21:8,12 23:23
24:15 27:22
30:25 33:13,18
34:3 44:14
47:1 49:20
50:24 51:1
52:7 57:11
58:2,23 64:6
66:8,21 67:9
swap 29:20
sworn 4:9 72:11
system 25:13
26:2,17,19
T
T 3:11
T-e-w 9:7
tagged 25:25
27:8
tags 25:14
take 7:13 13:15
13:16 28:22
30:1 45:3
47:21 57:4
60:4 66:17,21
67:1,10 68:7
taken 1:16 29:2
34:12 60:5
75:11
talked 42:3 43:7
69:24
talking 12:4 13:4
25:21 44:15
63:17,22
tape 4:4
tax 6:23 34:24
Taylor 1:15 2:10
3:3 4:2,8,17
11:24 38:2,14
39:4 57:4
72:10 73:8
11
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
74:22 75:5,10
tell 5:7 15:12
17:20 19:4,21
28:5 31:19,20
31:24 34:14
38:11 46:2,9
48:13 53:9
54:12
telling 15:1
temp 9:10,12,17
11:17 12:16
18:3 42:25
43:1 44:22
temp--9:9
temporaries
16:23
temporary 11:8
11:14 16:21,22
ten 57:10
testified 4:9
60:15
testimony 36:16
52:22 66:17
67:1
testimony--38:4
Tew 9:7 10:10
10:11 11:1
16:21,25 17:4
17:15 42:21
Tew--I 10:9
than--Kelly 16:9
Thank 4:24 44:8
68:15 71:19
that's--that's--
68:18
That's--there
23:19
that's--you
32:10
that--18:6 56:1
that--as 47:10
that--just 33:12
that--not 50:6
that--she 12:18
that--that 9:25
42:18
that--that's 6:1
24:9 31:12
that--the 69:25
that--what
35:13
the--30:1
the--get 65:9
the--in 56:3
the--or 15:17
58:8
the--satisfaction
10:12
the--she 16:22
the--that 14:18
the--the 13:2,18
16:17 42:18
53:14 70:14
the--to 56:7
there's--44:18
There--there's
64:14
these--the 45:1
they're--if 46:25
They--we've
45:11
thing 6:22,23
30:6 53:17
things 8:14
16:18
think 9:19 20:6
24:21 26:5
29:5 30:23
33:18,22,25
34:2,8 35:7
37:15 41:16
44:21 46:25
48:12 51:7
52:9,19 54:25
60:15 63:24
71:5,18
thirteen 35:7
those--8:24
Those--because
22:23
thought 13:9
40:23 41:1,11
41:15,17,20
44:11 57:10
Thrasher 2:13
71:14
Thrasher's
56:22 57:5
threatened
46:19,19
three 9:16 58:24
tickled 10:18
ties--69:4
till 43:23
time 8:21 9:15
10:23 12:1,3
13:1,16 14:2
14:11,18 16:10
41:15,22 43:8
44:16,22 56:7
56:8,9 58:18
59:3,6 62:12
63:6,11 65:16
times 41:23
63:20,21
tinues 70:25
tions 71:11
tip 44:4
titles 25:12,14
to--26:13
to--so 14:25
to--to 8:20
to--to--I 41:1
to--we 12:11
today 7:17 9:2
9:18 13:23
21:6 42:15
43:25
told 9:21 47:13
67:18
top 26:5 42:12
48:15
touches 47:19
town 1:7,19 2:14
4:3,19,20,21
5:11,13,15,17
7:20,24 8:8
11:25 14:2
20:3 22:19
30:14 33:13
35:14 42:3,4
43:1 44:25
46:23 48:22
51:17,20 53:13
56:5 58:17
60:20 67:25
68:3,24 69:21
70:2,18 75:8
town's 42:10
56:12
towns 8:14
70:17
track 7:16 11:22
56:14 57:7
transcript 73:8,9
Trey 2:5 33:25
35:6 38:15
39:20 55:4
75:6,22
trial 29:21
tried 18:6 63:9
true 73:9
try 5:6 21:20
23:23 27:9
29:18 52:11
56:14,21
trying 7:13,18
8:5 10:20
11:13 12:10,20
23:8 47:21
60:11
turn 18:6
twenty-five 49:9
twenty-seven
5:12
two 4:22 9:25
10:24 18:3
19:3 20:9
35:18 37:24
38:9,9 39:6,8
64:18 67:4
type 6:17 26:19
types 26:10
U
um-hum 6:18
17:6 24:15
25:22 32:12
51:15 55:5
57:19
under-60:11
under--there
25:17
undergrounding
7:7 42:9 56:17
underneath 6:12
27:20 48:23
49:2,5 50:2,13
52:14
undersigned
72:9
understand 8:18
10:20 13:2,6
18:1 21:24
23:8 47:25
51:21
understanding
60:23 61:23
67:3
uniquely 27:8
unprofes-67:17
unprofessional
67:15
unreasonable
52:20
upper 36:22
used--45:24
usually 62:16
63:6 71:13
utility 6:16
V
vaguely 21:11
valorem 6:24
value 34:24
various 8:14
verify 33:9
versus 25:8,9
vice-mayor 56:8
56:9 59:6
video 4:1 6:2,5
38:18 39:1
videotape's 64:7
videotaped 1:15
4:4 71:22 73:7
12
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
videotaping
38:20
view 34:23 35:14
39:21,25
view--41:18
views 40:1
violated 50:3
violation 59:20
violations 51:14
vs 1:6 4:3 75:8
W
wait 43:23 45:2
waited 57:7
walk 45:3
wall 68:5
want 9:22 13:10
13:20 18:22
19:14 22:20
27:23 29:7,23
34:2 48:7
50:18 57:3,7
60:16 63:21
64:20 65:8,22
68:7
wanted 17:19
24:14 41:11
wanting 30:15
wants 4:5 28:7,8
was--55:10
was--if 40:4
was--this 37:8
was--took 63:11
was--you 41:16
Wasn't 37:7
way 15:1 20:8
26:1,1 30:21
44:10 54:24
56:13 66:15
68:3,14 70:13
ways 39:24
we'll 39:8 55:4
64:23 68:19
we're 7:16,18
9:14 11:13
12:4,9,20 13:4
37:12 56:14,15
56:17,19 60:11
71:5,6,18
we're--we're
67:18
we've 4:25 9:15
16:4 17:23
43:22 67:19
we--we 57:7
65:18
week 7:15 56:18
week-to-week
9:13
weeks 47:22
64:18
went 17:12
30:14 68:14
were--31:15
were--who 12:15
what--26:6
60:13
what--excuse
20:1
what--how
45:24
what--let 23:21
What--what
39:15 48:8
58:21
whelmed 60:11
when--when
51:6
whole--63:18
William 2:13
32:10,11
wise 23:10 44:1
with--you 29:18
withhold 45:12
witness 1:16 3:2
5:5,9 8:13
10:17 14:5,15
15:5,24 16:17
17:23 18:11
20:16 21:11
22:1,6 24:21
27:3,12 30:20
31:4 32:2
33:24 34:4,20
35:22 36:3,10
36:17 37:12
40:18,23 42:18
43:10 45:11
46:5 47:17
48:20 49:13,24
50:6,16,24
52:2,23 55:5
61:6 62:5,11
65:4,15 66:14
68:14 69:13,22
71:21 72:13
wondered 45:20
wondering
10:22 25:24
word 25:23 32:7
38:3
words 4:23 8:11
15:8 23:5 28:5
30:12
work 14:23
16:18 17:11,12
25:11 43:21
57:12
worked 14:1
58:24
worker 11:8,14
working 14:18
18:3 27:20
48:23 49:2,5
works 18:2 50:2
world 51:7
would--38:5
wouldn't 14:19
14:20,25 18:9
26:8 40:25
41:1,12,19
66:8
wouldn't--I
40:25
Wow 58:13
write 32:16
writing 10:7
15:22 62:17
written 32:20
wrong 49:14
X
X 3:1,11 65:8
Y
yeah 6:8 9:23
15:11,20 19:22
23:4,7 24:11
29:14 34:6
35:9 42:24
55:6 59:8
61:14 65:11
69:7 71:17
years 5:12 9:16
12:5 67:5
Yep 34:8
you'd--44:20
you're--you're
11:5
you've--you've
42:2
you--are 20:10
you--as 7:24
you--based
20:25
you--do 14:1
you--has 47:13
you--if 49:18
you--in 64:25
you--so 43:13
you--you 48:6
56:4
your--to 69:2
71:3
your--your 6:7
Z
zoning 23:1
0
018101 4:4
1
1 3:12 13:11,13
19:8 36:7 41:5
58:19 67:17
100 1:11,19 2:6
4:22 75:6
101 2:18 75:1
11:00 57:10
11:30 71:23
119 50:14
13 3:12 35:1,2
58:20
1320 35:16
15 33:3
1500 2:18 75:2
15th 1:1 32:21
54:22
18 3:14
19 3:15
1st 55:19
2
2 3:13 18:21,24
67:18
2003 58:20
2005 54:1
2007 55:19
2010 54:20
2011 32:21 33:3
33:4 35:25
2013 11:21 12:2
12:9,13,17,21
14:12 15:3
36:1 40:11,16
40:21 44:1,2
58:22
2016 11:18 12:1
12:16 14:11
28:11
2017 1:12,20
72:14 73:18
75:4,11,15
2019 72:21
21 75:4
21st 72:13 73:18
26 28:11
26th 53:25
27 3:17
276-5116 2:7
28 3:18
29 36:1
3
13
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
3 3:15 19:15,17
19:21
32819 2:3
33301 2:19 75:2
33483 2:6 4:23
75:7
3rd 2:18 75:1
4
4 3:3,16 27:24
28:1,4,23,24
30:18,24 31:18
31:19,20,24
407 2:3
5
5 3:18 28:13,15
29:19 30:3
75:15
50 3:20
50-2013-CA-0...
1:3 75:9
53 3:21
54 3:23
543 54:5,24
55 3:24
561 2:7
6
6 3:19 29:24
30:6,8,11 39:4
39:15
7
7 1:12,20 3:21
53:1,3 72:21
75:11
7414 2:2
755-6401 75:3
758-4194 2:3
8
8 3:22 34:9 54:9
9
9 3:24 55:1,3
9:00 1:12,21
954 75:3