HomeMy Public PortalAbout22-035 - Approving Legal Invoices Burnadette Norris Weeks PASponsored by: City Attorney
RESOLUTION NO. 22-035
A RESOLUTION OF THE CITY COMMISSION OF THE
CITY OF OPA-LOCKA, FLORIDA, APPROVING
SUBMITTED LEGAL INVOICES FROM BURNADETTE
NORRIS-WEEKS, P.A.; PROVIDING FOR
INCORPORATION OF RECITALS; PROVIDING FOR AN
EFFECTIVE DATE.
WHEREAS, the City Commission of the City of Opa-Locka, Florida ("City
Commission") finds that certain litigation bills have been submitted by Burnadette
Norris -Weeks, P.A. ("Law Firm") to the City Commission for payment; and
WHEREAS, the City of Opa-Locka ("City") has benefited from legal services
rendered by the law firm Burnadette Norris -Weeks, P.A.; and
WHEREAS, the City Commission finds it fitting and appropriate that the
Law Firm be paid for past work performed and desires to approve legal invoices
submitted.
NOW THEREFORE, BE IT RESOLVED THAT THE CITY COMMISSION
OF THE CITY OF OPA LOCKA, FLORIDA:
Section 1.
by reference.
Recitals. The recitals to the preamble herein are incorporated
Section 2. Approving Legal Invoices Submitted and Authorizing Payment.
The City Commission hereby approves legal invoices submitted and authorizes and
directs that appropriate payment to law firm Burnadette Norris -Weeks, P.A. for
legal services previously provided.
Section 3. Effective Date. This Resolution shall be effective immediately and
shall be forwarded to the Governor's Designee.
Resolution No. 22-035
PASSED AND ADOPTED this 5th day of October, 2022.
Veronica Williams, Mayor
ATTEST:
a Flores, City Clerk
APPROVED AS TO FORM AND
LEGAL SUFFICIENCY
Burnadette Norri-Weeks, P.A.
City Attorney
Moved by: Commissioner Dominguez
Seconded by: Commissioner Bass
VOTE: 4-1
Commissioner Bass: YES
Commissioner Davis: NO
Commissioner Dominguez: YES
Vice -Mayor Taylor: YES
Mayor Williams: YES
LEGAL INVOICES
SUBMITTED
Law Office of
Burnadette Norris -Weeks, P.A.
401 N. Avenue of the Arts 'Fort Lauderdale, Florida 33311
Phone (954) 768-9770 •Fax (954) 768-9790
INVOICE
CLIENT: CITY OF OPA-LOCKA - Litigation Cases September 1, 2021 through
September 30, 2021 g
Date ACTIVITY AND HOURS
9/30/21 Review and Filing of two (2) Summons Re: City of Opa-Locka v Jerome
Wolfson et al, Case No. 2021 -021307 -CA -01 (.4)
9/30/21 Preparation of two (2) Summons Re: City of Opa-Locka v Jerome Wolfson
et al, Case No. 2021 -021307 -CA -01
9/30/21 Review of various files in preparation for response to amended char e
RE: Sharron Gallimore EEOC Charge 510-2021-03618 (2.5) g
9/30/21 Review of Motion to Transfer and communication with C. Sterns RE:
Randolph Aikens vs City of Opa-Locka (.4)
9/30/21 Preparation of email to Human Resources Director concerning internal
management matters RE: AFSCME Bargaining (N/C)
9/29/21 Review of Notice of Sale Re: US Bank National Association v Ameena Ali,
Case No. 2018 -040548 -CA -01 (.2)
9/28/21 Review of Motion for Default RE: Fay Plasnie Corp v Four Property
Holdings, LLC, Case No. 2021 -010833 -CA -01 (.2)
9/28/21 Review of Memorandum RE: Deutsche Bank v Rocio Gonzalez, Case No.
2018 -018368 -CA -01 (.1)
9/28/21 Review of email from Federal Investigator Mathelier of the U.S. Equal
Employment Opportunity Commission Miami District Office concerning
amending charge RE: Sharon D. Gallimore v. City of Opa-Locka; EEOC
No.: 510-2021-03618 (.2)
9/28/21 Preparation of response to Federal Investigator Mathelier of the U.S.
Equal Employment Opportunity Commission Miami District Office RE:
Sharon D. Gallimore v. City of Opa-Locka; EEOC No.: 510-2021-03618
(.4)
9/27/21 Review of information from AAA on service matters RE: City of Opa-Locka
v. Wolfson RE: City of Opa-Locka v Jerome Wolfson et al, Case No. 2021-
021307 -CA -01 (.3)
9/27/21 Review of Notice of Filing RE: Trial Transcripts Re: Deutsche Bank v
Rocio Gonzalez, Case No. 2018 -018368 -CA -01 (.3)
9/27/21 Review of Memorandum of Law Re: Deutsche Bank v Rocio Gonzalez,
Case No. 2018 -018368 -CA -01 (.2)
9/27/21 Review of notice from the U.S. Equal Employment Opportunity
Commission Miami District Office concerning amending of charge RE:
Sharon D. Gallimore v. City of Opa-Locka; EEOC No.: 510-2021-03618
(.3)
9/27/21 Preparation of draft Motion to Strike Opt -Outs RE: George Suarez, et al v.
City of Opa-Locka, Case No. 17 -008285 -CA -01 (43) (.9)
9/27/21 Review of Service of Court Document Notice on Motion to Close Case RE:
Harvey Ruvin as Miami -Dade Clerk of the Courts vs City of Opa-Locka et
al, Case No. 2020 -020629 -CA -01 (.3)
9/27/21 Reviewed Service of Court Document Notice re: Harvey Ruvin as Miami -
Dade Clerk of the Courts vs City of Opa-Locka et al, Case No. 2020-
020629 -CA -01 Order Granting Motion to Close Case (.2)
9/27/21 Final review and revisions to Motion to Strike Opt -Outs RE: George
Suarez, et al v. City of Opa-Locka, Case No. 17 -008285 -CA -01 (.8)
9/27/21 Preparation of Draft Motion to Strike Opt -Outs RE. George Suarez, et al v.
City of Opa-Locka, Case No. 17 -008285 -CA -01 (2.9)
9/27/21 Review law applicable to Motion to Strike Opt -Outs and opt -outs submitted
by counsel to provide analysis for Motion to Strike Opt -Outs RE: George
Suarez, et al v. City of Opa-Locka, Case No. 17 -008285 -CA -01 (3.5)
9/27/21 Review and analysis of amended charge RE: Sharron Gallimore EEOC
Charge 510-2021-03618 (1.6)
9/24/21 Review of Exhibit List Re: Deutsche Bank v Rocio Gonzalez, Case No.
2018 -018368 -CA -01 (.3)
9/24/21 Review of Response to Plaintiff's Trial Brief RE: Deutsche Bank v Rocio
Gonzalez, Case No. 2018 -018368 -CA -01 (.2)
9/23/21 Review of Motion to Withdraw filed by Alex Dehghani, Esq. and review of
contact information for Plaintiff to set hearing Re: United States
Association of CDC v City of Opa-Locka, Case No. 2016 -024089 -CA -01
(.4)
9/23/21 Review and discussion of Draft Affidavit from Aria Austin In support of
Motion for Summary Judgment RE: United States Association of CDC Inc
v. City of Opa-Locka, Case No. 2016 -024089 -CA -01 (1.6)
9/23/21 Review of documents for inclusion in Motion for Summary Judgment RE:
United States Association of CDC Inc v. City of Opa-Locka, Case No.
2016 -024089 -CA -01 (.8)
9/23/21 Conference with A. Austin RE: Affidavit for inclusion in Motion for
Summary Judgment RE: United States Association of CDC Inc. v. City of
Opa-Locka, Case No. 2016 -024089 -CA -01 (.6)
9/23/21 Reviewed Budget Administrator's email concerning City compensation
proposal re: AFSCME Bargaining (N/C)
9/22/21 Review of final draft Motion for Summary Judgment RE: United States
Association of CDC Inc. v. City of Opa, Locka, Case No. 2016 -024089 -
CA -01 (.4)
9/22/21 Two Communications with opposing counsel to secure responses to
interrogatories RE: United States Association of CDC Inc v. City of Opa-
Locka, Case No. 2016 -024089 -CA -01 (.4)
9/21/21 Conference call with class counsel to discuss opt -out matter and impact of
Plaintiff's Motion to Substitute a class representative — RE: George
Suarez, et al v. City of Opa-Locka, Case No. 17 -008285 -CA -01 (.8)
9/21/21 Review of Notice to Invoke Discretionary Jurisdiction RE: George Suarez,
et. al. v. City of Opa-Locka, Case No. 17 -008285 -CA -01. (.4)
9/21/21 Reviewed City Clerk email response concerning execution of Declaration
RE: Case No. 17 -001268 -CA -01 (05), Universal Waste Services vs City
of Opa-Locka, Florida (N/C)
9/21/21 Review of court file for 3d DCA Order on deposit issue for preparation for
City's 10/20/2021 Motion to Strike Opt -Outs Hearing RE: George Suarez,
et al v. City of Opa-Locka, Case No. 17 -008285 -CA -01 (43) (.4)
9/20/21 Review of information and analysis from assigned Arbitrator on possible
bifurcation of Arbitration hearing RE: Bosque v. City of Opa-Locka Case:
01-21-0004-2772 (.6)
9/20/21 Review of email from outside counsel concerning execution of Declaration
RE: Case No. 17 -001268 -CA -01 (05), Universal Waste Services vs City
of Opa-Locka, Florida (N/C)
9/20/21 Preparation of email to City Clerk concerning execution of Declaration re:
Case No. 17 -001268 -CA -01 (05), Universal Waste Services vs City of
Opa-Locka, Florida (.2)
9/20/21 Review and analysis of Plaintiffs Motion to change class representative to
include Raul Fernandez, a plaintiff in another water dispute where City
Attorney is providing a defense, and the court order related thereto — RE:
George Suarez, et al v. City of Opa-Locka, Case No. 17 -008285 -CA -01
(1.2)
9/19/21 Review of Witness and Exhibit List Re: Deutsche Bank v Rocio Gonzalez,
Case No. 2018 -018368 -CA -01 (.2)
9/18/21 Review of Receipt for $401.00 filing fee Re: City of Opa-Locka v Jerome
Wolfson et al, Case No. 2021 -021307 -CA -01 (.1)
9/17/21 Review of outside counsel's email concerning revised Mediated
Settlement Term Sheet RE: George Suarez, et al v. City of Opa-Locka,
Case No. 17 -008285 -CA -01 (.3)
9/17/21 Review of outside counsel's email concerning Plaintiffs Notice of Service
of Class Notice and Opt Outs RE: George Suarez, et al v. City of Opa-
Locka, Case No. 17 -008285 -CA -01 (.3)
9/17/21 Preparation of email to Human Resources Director concerning internal
management meetings re: AFSCME Bargaining (N/C)
9/17/21 Review of proposed class settlement terms and provided input to outside
counsel RE: George Suarez, et al v. City of Opa-Locka, Case No. 17-
008285 -CA -01 (1.1)
9/16/21 Review of email of Risk Manager concerning execution of Notice of
Serving Interrogatories RE: Robbi Nelson v. City of Opa-Locka, et al,
Case No. 2020 -025819 -CA -01 (.3)
9/16/21 Review of email concerning Court's Order Setting Trial RE: Case 1:20-cv-
21927-RKA Harrell v. Opa-Locka (.2)
9/16/21 Review of EEOC's Dismissal and Notice of Right to Sue Letter RE: Ann
Barnett File: 640/41130 (.4)
9/16/21 Review of email concerning City's Reply to Plaintiff's Response in
Opposition to City's Motion for Summary Judgment re: Case 1:20-cv-
21927-RKA Harrell v. Opa-Locka (.3)
9/16/21 Follow-up email of Risk Manager concerning execution of Notice of
Serving Interrogatories RE: Robbi Nelson v. City of Opa-Locka, et al,
Case No. 2020 -025819 -CA -01 (N/C)
9/16/21 Review of Budget Administrator's email concerning City proposal re:
AFSCME Bargaining (N/C)
9/16/21 Preparation of email response to Budget Administrator concerning City
proposal re: AFSCME Bargaining (N/C)
9/16/21 Reviewed outside counsel's email concerning Mediated Settlement Term
Sheet RE: George Suarez, et al v. City of Opa-Locka, Case No. 17-
008285 -CA -01 (43) (.3)
9/16/21 Review of Court Order on Defendant's Motion to Dismiss Amended
Complaint RE: Randolph Aikens vs City of Opa-Locka, 2021 -CA -003184
(.3)
9/16/21 Preparation of initial draft of Motion for Summary Judgment RE: United
States Association of CDC v City of Opa-Locka, Case No. 2016 -024089 -
CA -01 (2.3)
9/16/21 Filing of Complaint and Civil Cover Sheet Re: City of Opa-Locka v.
Jerome Wolfson et al, Case No. 2021 -021307 -CA -01 (.7)
9/16/21 Final Preparation of Complaint and Civil Cover Sheet RE: City of Opa-
Locka v. Jerome Wolfson et al, Case No. 2021 -021307 -CA -01 (.8)
9/16/21 Review of Notice of Filing Re: Plaintiff's Trial Brief Re: Deutsche Bank v
Rocio Gonzalez, Case No. 2018 -018368 -CA -01 (.3)
9/16/21 Preparation and filing of Notice of Serving Answers to Interrogatories Re:
City of Opa-Locka v Opa-Locka CDC, Case No. 2021 -010170 -CA -01 (.7)
9/16/21 Review of new Florida summary judgment rule and applicable federal
cases in preparation of Motion for Final Summary Judgment — RE: United
States Association of CDC v City of Opa-Locka, Case No. 2016 -024089 -
CA -01 (1.7)
9/15/21 Revised City's Proposal RE: AFSCME 9/17/2021 Bargaining Session
(N/C)
9/15/21 Preparation of email to City Negotiation Team concerning City's Proposal
re: AFSCME 9/17/2021 Bargaining Session (N/C)
9/15/21 Reviewed City's Proposal re: AFSCME 9/17/2021 Bargaining Session
(N/C)
9/15/21 Preparation of revisions to City's Proposal RE: AFSCME 9/17/2021
Bargaining Session (N/C)
9/15/21 Reviewed email and telephone conference with opposing counsel
concerning final deed RE: Joseph Barton et al vs City of Opa-Locka,
2016 -011180 -CA -01 settlement (.5)
9/15/21 Preparation of response to email from opposing counsel concerning deed
RE: Joseph Barton et al vs City of Opa-Locka, 2016 -011180 -CA -01
settlement (N/C)
9/15/21 Attended Executive Session and meeting with Mayor and City
Commissioners RE: George Suarez, et al v. City of Opa-Locka, Case No.
17 -008285 -CA -01 (43) (N/C)
9/15/21 Reviewed outside counsel email concerning execution of Notice of
Serving Interrogatories RE: Robbi Nelson v. City of Opa-Locka, et al,
Case No. 2020 -025819 -CA -01 (.3)
9/15/21 Telephone conference with outside counsel concerning execution of
Notice of Serving Interrogatories RE: Robbi Nelson v. City of Opa-Locka,
et al, Case No. 2020 -025819 -CA -01 (.3)
9/15/21 Review of 3rd DCA Order Recognizing Appellant's Voluntary Dismissal of
Appeal RE: United States Association of CDC v City of Opa-Locka, Case
No. 2016 -024089 -CA -01 (.3)
9/15/21 Cursory review of thirty (30) Trial Exhibits and Exhibit Index Re: Deutsche
Bank v Rocio Gonzalez, Case No. 2018 -018368 -CA -01 (.4)
9/15/21 Review of Trial Briefs Re: Deutsche Bank v Rocio Gonzalez, Case No.
2018 -018368 -CA -01 (.2)
9/15/21 Review of Notice of Filing Re: Affidavit as to Time, Effort and Costs RE:
Deutsche Bank v Rocio Gonzalez, Case No. 2018 -018368 -CA -01 (.2)
9/14/21 Review of Response in Opposition to the City's Motion to Dismiss
Amended Complaint RE: Randolph Aikens vs City of Opa-Locka
Case#2021-CA-003184 (.3)
9/14/21 Review of Budget Administrator's email concerning City proposal RE: PBA
Bargaining (N/C)
9/14/21 Review of Activity Notice RE: Harrell v. Opa-Locka Scheduling Order
concerning Trial set for 1/11/2022; Case 1:20-cv-21927-RKA (.3)
9/14/21 Review of opposing counsel's email concerning City response to
Interrogatories RE: City of Opa-Locka vs Opa-Locka Community
Development Corporation; Case No. 2021 -010170 -CA -01 (.3)
9/14/21 Preparation of email to outside counsel concerning Executive Session RE:
George Suarez, et al v. City of Opa-Locka, Case No. 17 -008285 -CA -01
(43) (.1)
9/14/21 Verified with clerk on Voluntary Dismissal of Appeal RE: Case No.
3D2021-1005 United States Association of CDC, Inc., etc., vs City of Opa-
Locka (.3)
9/14/21 Review of Court Order Cancelling Foreclosure Sale Re: US Bank National
Association v Ameena Ali, Case No. 2018 -040548 -CA -01 (.2)
9/13/21 Preparation of email in response to outside counsel concerning execution
of Declaration RE: Case No. 17 -001268 -CA -01 (05), Universal Waste
Services vs City of Opa-Locka, Florida (.3)
9/10/21 Filing of Response to Request for Production RE: City of Opa-Locka v
Opa-Locka CDC, Case No. 2021 -010170 -CA -01 (.4)
9/10/21 Preparation of Response to Request for Production RE: City of Opa-Locka
v Opa-Locka CDC, Case No. 2021 -010170 -CA -01 (.8)
9/9/21 Review of Notice Re: Zoom instructions for Trial Re: Deutsche Bank v
Rocio Gonzalez, Case No. 2018 -018368 -CA -01 (.1)
9/9/21 Review of outside counsel's email concerning settlement offer from
continued Mediation RE: George Suarez, et al v. City of Opa-Locka, Case
No. 17 -008285 -CA -01 (.3)
9/9/21 Review of draft Answers to Florida Department of Transportation's Second
Set of Interrogatories RE: Robbi Nelson v. City of Opa-Locka, et al, Case
No. 2020 -025819 -CA -01 (.5)
9/9/21 Preparation of email to City Manager's Office concerning City's Service of
Answers to Florida Department of Transportation's Second Set of
Interrogatories approval RE: Robbi Nelson v. City of Opa-Locka, et al,
Case No. 2020 -025819 -CA -01 (.3)
9/9/21 Reciept and review of email response of outside counsel concerning
review of City's Service of Answers to Florida Department of
Transportation's Second Set of Interrogatories approval RE: Robbi Nelson
v. City of Opa-Locka, et al, Case No. 2020 -025819 -CA -01 (.2)
9/9/21 Review of outside counsel's email concerning Plaintiffs Second
Supplemental Expert Witness Disclosure RE: George Suarez, et al v. City
of Opa-Locka, Case No. 17 -008285 -CA -01 (N/C)
9/8/21 Preparation of email to City Manager's Office concerning responding to
Notice of Service of Interrogatories RE: Randolph Aikens vs City of Opa-
Locka, Case#2021-CA-003184, (.3)
9/8/21 Follow up email to Office of City Manager concerning response to Request
for Production RE: Case No. 2021 -010170 -CA -01, City of Opa-Locka v
Opa-Locka Community Development Corporation (.3)
9/8/21 Review and email response of City staff RE: Response to Request for
Production RE: City of Opa-Locka v Opa-Locka Community Development
Corporation, Case No. 2021 -010170 -CA -01 (.3)
9/7/21 Review of Service of Court Document RE: Randolph Aikens vs City of
Opa-Locka on Notice of Service of Interrogatories Case#2021-CA-003184
(.3)
9/6/21 Attended Second Scheduled Mediation on behalf of City as City
Representative RE: George Suarez, et al v. City of Opa-Locka, Case No.
17 -008285 -CA -01 (43) (7.0)
9/5/21 Review of email concerning 9/6/2021 Mediation RE: George Suarez, et al
v. City of Opa-Locka, Case No. 17 -008285 -CA -01 (.3)
9/3/21 Review of Motion to Reschedule Foreclosure Sale RE: Bank of New York
Mellon et. al. v. Vickie Garland; Case #2019 -005064 -CA -01 (.3)
9/1/21 Reviewed Activity Notice concerning City's Reply to Response to Motion
Motion for Summary Judgment RE: Case 1:20-cv-21927-RKA (N/C)
Total Hours 50 $225.00
Total Professional Services: $11,250.00
Costs
Facsimile Expenses: $25.00
Copying Services: $592.25
Courthouse Parking Costs: $54.00
Postage, FedEx and Courier Charges: $82.67
Court Call Line: $N/C
Research Services: $125.70
COSTS=$879.62
TOTAL: $12,129.62
Law Office of
Burnadette Norris -Weeks, P.A.
401 N. Avenue of the Arts •iiFort Lauderdale, Florida 33311
Phone (954) 768-9770 •D Fax (954) 768-9790
INVOICE
CLIENT: CITY OF OPA-LOCKA - Litigation Cases July 1, 2021 through July 31,
2021
Date ACTIVITY AND HOURS
8/31/21 Review of Amended Witness List Re: Deutsche Bank v Celia Gutierrez, et.
al., Case No. 2018 -018368 -CA -01 (.3)
8/30/21 Review of Notice of Hearing Re: US Bank National Association v Ameena
Ali, Case No. 2018 -040548 -CA -01 (.2)
8/27/21 Attended Management Meeting re: PBA Negotiation for 1 HR (N/C)
8/27/21 Review of Motion to Cancel Sale Re: US Bank National Association v
Ameena Ali, Case No. 2018 -040548 -CA -01 (.2)
8/27/21 Attended Management Meeting re: PBA Negotiation (N/C)
8/26/21 Preparation email to City Manager's Office concerning Wage Proposal
(N/C)
8/26/21 Telephone conference with Chief of Police regarding Disciplinary Action
taken in Dade County Police Benevolent Association v. City of Opa-Locka
and process RE: Case 01-21-0004-5180 (.8)
8/26/21 Attended Mediation as City Rep on behalf of City and reached settlement
RE: George Suarez, et al v. City of Opa-Locka, Case No. 17 -008285 -CA -
01 (8.0)
8/25/21 Review in Opposition to Defendant's Motion for Summary Judgment RE:
Harrell v. City of Opa-Locka, Case #1:20-cv-21927-RKA (.5)
8/25/21 Review of Order Setting Non -Jury Trial with Referral to Mediation Re:
Harvey Ruvin as Clerk of Courts for Miami -Dade County v Anthoneel Allen
et al, Case No. 2020 -16931 -CA -01 (.2)
8/23/21 Review of Notice of Sale Re: US Bank National Association v Ameena Ali,
Case No. 2018 -040548 -CA -01 (.2)
8/23/21 Preparation of email to City Manager's Office concerning City's response
to Defendant's First Set of Interrogatories to Plaintiff RE: City of Opa-
Locka v OLCDC; Case No. 2021 -010170 -CA -01 (.3)
8/20/21 Review of Motion Defendant's Motion for Summary Judgment Show
Cause response RE: Case 1:20-cv-21927-RKA Harrell v. Opa-Locka
Response to (.3)
8/20/21 Review of legal research concerning appeal of arbitration decision in
preparation of initiation of litigation RE: City of Opa-Locka v. Jerome
Wolfson, et al, Case No. 2021 -021307 -CA -01 (.7)
8/20/21 Review of Service of Court Document RE: Randolph Aikens v. City of
Opa-Locka, Notice of Filing Jurat Page; Case #2021 -CA -003184 (.1)
8/20/21 Revised draft Petition to Vacate Arbitration RE: City of Opa-Locka v.
Jerome Wolfson, et al, Case No. 2021 -021307 -CA -01 (.4)
8/19/21 Initial Preparation of Draft Petition to Vacate Arbitration RE: City of Opa-
Locka v. Jerome Wolfson, et al, Case No. 2021 -021307 -CA -01 (1.3)
8/19/21 Review of FWOP Notice and communications with staff Re: Ingram Park
Apts, LLC v Miami -Dade County, Case No. 2020 -008684 -CA -01 (.8)
8/19/21 Review of Receipt Re: Harvey Ruvin as Clerk of Courts for Miami -Dade
County v Anthoneel Allen et. al., Case No. 2020 -16931 -CA -01 (.1)
8/19/21 Review of Activity Notice RE: Harrell v. Opa-Locka Order to Show Cause,
Case 1:20-cv-21927-RKA 8/19/2021 (.1)
8/19/21 Review of Outside Counsel email concerning City's Motion for Summary
Judgment RE: Delia Kennedy v. City of Opa-Locka, Case No. 3D21-1218
(.3)
8/18/21 Attended PBA Negotiation Session on Behalf of City Two Attorneys (N/C)
8/16/21 Review of Appellant's Second Motion for Extension of Time to Serve Initial
Brief RE: United States Association of CDC, Inc. v. City of Opa-Locka,
Case No. 3D2021-1005 (.3)
8/16/21 Telephone conferece Alex Dehghani, Esq. Re: Second Extension of Time
to File Initial Brief Re: United States Association of CDC v City of Opa-
Locka, Appellate Case No. 3D2021-1005 (.3)
8/16/21 Review and response to various email from Alex Dehghani on Pleading
correction RE: United States Association of CDC v. City of Opa-Locka
Case #3D2021-1005 3rd DCA (.5)
8/16/21 Communication with Clerk on court schedule Re: United States
Association of CDC v City of Opa-Locka, Appellate Case No. 3D2021-
1005 (.3)
8/15/21 Review of Order Granting Motion to Release Clerk and Continue
Interpleader Re: Harvey Ruvin as Clerk of Courts for Miami -Dade County
v. Anthoneel Allen et. al., Case No. 2020 -16931 -CA -01 (.3)
8/15/21 Review of Service of Court Document RE: Harvey Ruvin as Miami -Dade
Clerk of the Courts v. City of Opa-Locka et. al, Case No. 2020 -016931 -
CA -01 Order Granting Motion to Release Clerk and Continue Interpleader
(.2)
8/13/21 Preparation of email and response to Budget Director's on City's Wage
Proposal RE: PBA Negotiation (N/C)
8/13/21 Telephone conference with Plaintiff's counsel RE: Harvey Ruvin as Clerk
of Courts for Miami -Dade County v Anthoneel Allen et al, Case No. 2020-
16931 -CA -01 (.4)
8/13/21 Review of Service of Court Document RE: Harvey Ruvin as Miami -Dade
Clerk of the Courts v. City of Opa-Locka et al, Notice of Lack of
Prosecution and Order to Appear for Hearing, Case No. 2020 -CA -
0169310 (.2)
8/12/21 Reviewed email response of AFSCME Regional Coordinator concerning
scheduling of next negotiation session re: AFSCME Negotiation (N/C)
8/12/21 Attended PBA Negotiation Session for 3.3 HRS (N/C)
8/12/21 Telephone conference with City Manager regarding union negotiation
(N/C)
8/12/21 Review of email to AFSCME Regional Coordinator concerning scheduling
of next negotiation session RE: AFSCME Negotiation (N/C)
8/12/21 Preparation of email to AFSCME Regional Coordinator concerning release
of employees for negotiation session RE: AFSCME Negotiation (N/C)
8/12/21 Attended PBA Union Contract Negotiation on behalf of City (N/C)
8/11/21 Review of Plaintiff's Discovery Answers for Response to Request for
Production and Answers to Interrogatories / Motion for Extension RE:
Randolph Aikens v. City of Opa-Locka; Case # 2021 -003184 -CA -01 (1.6)
8/11/21 Telephone conference with Alex Dehghani RE: Settlement Discussions
RE: United States Association of CDC v. City of Opa-Locka, Case
#3D2021-1005 3rd DCA (.3)
8/11/21 Telephone conference with PBA General Counsel to discuss contract (.3)
8/11/21 Review of Budget Director's comments RE: Union contract (N/C)
8/11/21 Review of revised Proposed AFSCME Contract in preparation for the next
Negotiation Session (N/C)
8/10/21 Telephone conference with Chief of Police regarding PBA
Negotiation and other police matters (.6)
8/10/21 Communication with Opposing Counsel concerning Defendant's Notice of
Serving First Set of Interrogatories to Plaintiff RE: City of Opa-Locka vs
Opa-Locka Community Development Corporation, Inc., Case No. 2021-
010170 -CA -01 (.3)
8/10/21 Communication with City Manager's Office concerning City's draft First Set
of Interrogatories to Plaintiff RE: City of Opa-Locka v. Opa-Locka
Community Development Corporation, Inc., Case No. 2021 -010170 -CA -01
(.7)
8/10/21 Review and response to email to Budget Director concerning City's Wage
Proposal re: PBA Negotiation (N/C)
8/10/21 Review of Notice of Interrogatories and follow-up RE: City of Opa-Locka v
Opa-Locka CDC, Case No. 2021 -010170 -CA -01 (.2)
8/9/21 Attended Negotiation Staff Meeting in preparation for AFSCME
Negotiation (N/C)
8/9/21 Reviewed and response to AFSCME Regional Coordinator concerning
next AFSCME Negotiation (N/C)
8/9/21 Review of FWOP Notice Re: Harvey Ruvin as Clerk of Courts for Miami -
Dade County v Anthoneel Allen et al, Case No. 2020 -16931 -CA -01 (.3)
8/9/2021 Review of public record concerning relevant resolutions and agreements
RE: Case No. 2017 -CA -001268, Universal Waste Services of Florida v.
City of Opa-Locka (N/C)
8/9/21 Review of email from Chief of Police concerning City's proposal RE: PBA
Negotiation (N/C)
8/9/21 Review of Notice to Appear at Hearing and calendar for 11/3/21 RE:
Harvey Ruvin as Miami -Dade Clerk of the Courts v. City of Opa-Locka et.
al.(.4)
8/8/21 Reviewed Zoom invite from AFSCME Regional Coordinator; Response to
AFSCME Regional Coordinator concerning next AFSCME Negotiation
(N/C)
8/7/21 Review of Budget Director's email concerning City's Wage Options
RE: PBA Compensation (N/C)
8/6/21 Reviewed Budget Director's email concerning City's Wage Proposal re:
AFSCME Negotiation (.2)
8/5/21 Preparation of email to Clerk and follow-up inquiry concerning relevant
resolution and agreements RE: Case No. 2017 -CA -001268, Universal
Waste Services of Florida v. City of Opa-Locka (.2)
8/4/21 Review of email from AFSCME Regional Coordinator concerning the
City's submission of changes (N/C)
8/3/21 Preparation of revisions to draft EEOC Position Statement RE: EEOC
charge #510-2021-03618 Sharon Gallimore v. City of Opa-Locka (1.7)
8/3/21 Emailed City Manager regarding AFSCME's concerns about wages (.20)
8/2/21 Preparation and research of EEOC Position Statement RE: EEOC charge
#510-2021-03618 Sharon Gallimore v. City of Opa-Locka (.6)
8/2/21 Reviewed email from AFSCME Regional Coordinator inquiring about
status of wage analysis (.20)
8/2/21 Review of email concerning City's Motion for Summary Judgment and
Supporting Memorandum of Law RE: Harrell v. City of Opa-Locka, Case
#1:20-cv-21927-RKA (.4)
Total Hours 25.5 $225.00
Total Professional Services: $5,737.50
Costs
Facsimile Expenses: $16.00
Copying Services: $338.75
Courthouse Parking Costs: $26.00
Postage, FedEx and Courier Charges: $154.24
Court Call Line: $N/C
Research Services: $N/C
COSTS -41,417.05
TOTAL: $7,154.55
Law Office of
Burnadette Norris -Weeks, P.A.
401 N. Avenue of the Arts • Fort Lauderdale, Florida 33311
Phone (954) 768-9770 • Fax (954) 768-9790
INVOICE
CLIENT: CITY OF OPA-LOCKA - Litigation Cases July 1, 2021 through July 31,
2021
Date ACTIVITY AND HOURS
7/30/21 Review and response to correspondence concerning Arbitrator's conflict
Re: Officer Jamesha McKinney (.2)
7/30/21 Telephone conference with PBA Attorney Daniel Vazquez on case list of
arbitrators RE: Sharon Gallimore v. City of Opa-Locka; EEOC No.: 510-
2021-03618 (.6)
7/28/21 Review of Extension for Initial Brief and call from Plaintiff's counsel Re:
United States Association of CDC v City of Opa-Locka, Appellate Case
No. 3D2021-1005 (.6)
7/28/21 Review and revisions to Answer for EEOC charge RE: Sharon D.
Gallimore v. City of Opa-Locka; EEOC No.: 510-2021-03618 (3.2)
7/28/21 Review of Notice of Special Set Hearing RE: Randolph Aikens v. City of
Opa-Locka Case #2021 -003184 -CA -01 (.2)
7/27/21 Review of Notice of Cancellation of Deposition RE: Randolph Aikens v.
City of Opa-Locka Case #2021 -003184 -CA -01 (.2)
7/26/21 Review of Order on Motion for Misc Relief RE: Harrell v. Opa-Locka Case
#1:20-cv-21927-RKA (.3)
7/24/21 Review of Order Referring case to mediation RE: Harrell v. Opa-Locka
Case #1:20-cv-21927-RKA (.2)
7/23/21 Review of Order on Motion for Summary Judgment RE: Harrell v. Opa-
Locka Case #1:20-cv-21927-RKA (.3)
7/23/21 Review and response to email from K. Ward regarding upcoming meeting
Re: AFSCME Negotiations (N/C)
7/23/21 Review of Motion to Dismiss Counts 1 and 3 of amended complaint Re:
City of Opa-Locka v Opa-Locka Community Development Corp, Case No.
2021 -010170 -CA -01 (.8)
7/23/21 Review of Answer and Affirmative Defense filed by Opa-Locka Community
Development Corporation Re: City of Opa-Locka v. Opa-Locka
Community Development Corporation, Case No. 2021 -010170 -CA -01 (.7)
7/23/21 Reviewed email of AFSCME Regional Coordinator concerning City's
Proposal re: AFSCME Negotiation (N/C)
7/22/21 Preparation and review of email follow-up RE: Harrell v. City of Opa-
Locka discovery coordination, Case 1:20-cv-21927-RKA (.2)
7/22/22 Telephone conference with Mayor Pigatt and discussion of declaration
format and facts for declaration RE: Harrell v. Opa-Locka Case #1:20-cv-
21927-RKA (1.3)
7/22/21 Review of email and follow up response to outside counsel RE: Harrell v.
City of Opa-Locka, Case 1:20-cv-21927-RKA (.2)
7/22/21 Review of email from Plaintiffs Counsel on water bill arrears concerning
settlement of property RE: Joseph Barton et al vs City of Opa-Locka,
2016 -011180 -CA -01 (.3)
7/22/21 Review of Internal Investigation of G. Bosque for preparation of response
to PBA Grievance, AAA Case Number: 01-21-0004-2772 (1.0)
7/22/21 Preparation of email to Outside Counsel concerning Declaration of Mayor
Matthew Pigatt RE: Case 1:20-cv-21927-RKA Harrell v. City of Opa-
Locka, Florida (.2)
7/22/21 Telephone conversation with PBA counsel RE: Sharon D. Gallimore v.
City of Opa-Locka; EEOC No.: 510-2021-03618 (.5)
7/21/21 Review of Motion for Enlargement RE: Randolph Aikens v. City of Opa-
Locka, 2021 -CA -003184 (.2)
7/20/21 Review of Activity log RE: Harrell v. Opa-Locka Motion for Miscellaneous
Relief, 1:20-cv-21927-RKA (.2)
7/20/21 Reviewed Outside Counsel email on scheduling Mediation and attorney
coverage for calendar invite RE: George Suarez, et al v. City of Opa-
Locka, Case No. 17 -008285 -CA -01 (.2)
7/20/21 Review of email from American Arbitration Association RE: Dade County
Police Benevolent Association v. City of Opa-Locka, Case 01-21-0004-
5180 for Selection of Arbitrator (.2)
7/20/21 Review of Plaintiff's Certificate of Service RE: Deutsche Bank v Rocio
Gonzalez, Case No. 2018 -018368 -CA -01 (.1)
7/20/21 Review of Notice of Zoom Instruction Re: Deutsche Bank v Rocio
Gonzalez, Case No. 2018 -018368 -CA -01 (.1)
7/20/21 Review of email from K. Ward regarding Re: AFCSME Negotiations (N/C)
7/20/21 Telephone conference with John Pate regarding the facts of case Re:
Sharon Gallimore v. City of Opa-Locka; EEOC No.: 510-2021-03618 (.6)
7/20/21 Reviewed Outside Counsel email concerning Plaintiffs Expert Report RE:
George Suarez, et al v. City of Opa-Locka, Case No. 17 -008285 -CA -01
(N/C)
7/20/21 Follow up response to outside counsel and coordination of calls RE:
Harrell v. City of Opa-Locka, Florida, coordination of telephone
conferences, Case 1:20-cv-21927-RKA (.3)
7/20/21 Review of Outside Counsel email RE: Delia Kennedy v. City of Opa-
Locka, Case No. 3D21-1218; Reply in Support of Petition for Writ of
Certiorari from the Circuit Court of the Eleventh Judicial Circuit in and for
Miami -Dade County; Case No. 17-16938-01 (3D21-1218) (.3)
7/16/21 Review and response to email from regarding compensation negotiations
Re: AFCSME Negotiations .10 (N/C)
7/16/21 Review of Order Resetting Calendar Call Re: Deutsche Bank v Rocio
Gonzalez, Case No. 2018 -018368 -CA -01 (.1)
7/16/21 Reviewed email and telephone conference with American Arbitration
Association RE: South Florida Police Benevolent Association v. City of
Opa-Locka - Case 01-21-0004-6580 Arbitrator Selection (.4)
7/16/21 Preparation of response to outside counsel RE: Harrell v. City of Opa-
Locka, coordination of telephone conferences Case 1:20-cv-21927-RKA
(.4)
7/15/21 Review of Order Setting Non -Jury Trial with Mediation Referral Re:
Deutsche Bank v Rocio Gonzalez, Case No. 2018 -018368 -CA -01 (.2)
7/15/21 Review of Plaintiff's Certificate of Settlement Authority Re: Deutsche Bank
v Rocio Gonzalez, Case No. 2018 -018368 -CA -01 (.1)
7/15/21 Preparation and attendance at AFSCME and City's 3.5 negotiation
session (N/C)
7/15/21 Review of AAA and resumes of potential arbitrators and discussion with
opposing counsel RE: Raminkie Arbitration (1.6)
7/15/21 Preparation of email to American Arbitration Association RE: Dade County
Police Benevolent Association v. City of Opa-Locka; Case 01-21-0004-
5180 Selection of Arbitrator matters (.2)
7/14/21 Telephone conference with John Pate regarding arbitration Re: Raminkie
Arbitration (.8)
7/14/21 Activity in Case 1:21-cv-21075-BB Barnett v. City of Opa-Locka Order on
Motion to Dismiss for Failure to State a Claim (.2)
7/14/21 Reviewed email response from Plaintiffs Counsel concerning deed for
settlement property re: Joseph Barton et al vs City of Opa-Locka, 2016-
011180 -CA -01 (.3)
7/13/21 Telephone call with Madelyn Gonzalez RE: supervisors not being notified
to release members for bargaining meetings; Preparation of email
memorializing her concern Re: AFCSME Negotiations (N/C)
7/13/21 Filing of actual Amended Complaint following order Re: City of Opa-Locka
v Opa-Locka Community Development Corp, Case No. 2021 -010170 -CA -
01 (.7)
7/13/21 Reviewed email response from Plaintiffs Counsel concerning deed for
settlement property re: Joseph Barton et al vs City of Opa-Locka, 2016-
011180 -CA -01 (.2)
7/13/21 Review of Activity Notice in Case 1:21-cv-21075-BB Barnett v. City of
Opa-Locka Reply to Response to Motion RE: Defendant's Motion to Stay
filed by City of Opa-Locka (.2)
7/13/21 Reviewed Outside Counsel email re: Robbie Nelson v. City of Opa-Locka,
Case # 2020 -025819 -CA -01 Plaintiffs Responses to Defendant, City of
Opa-Locka's First Set of Interrogatories (N/C)
7/13/21 Reviewed Outside Counsel email RE: Delia Kennedy v. City of Opa-
Locka, Case No. 3D21-1218, Response to Petition For Writ of Certiorari
from the Circuit Court of the Eleventh Judicial Circuit in and for Miami-
Dade County, Florida, the Honorable Samantha Ruiz Cohen Presiding
(.2)
7/13/21 Review of Outside Counsel email RE: Randolph Aikens vs City of Opa-
Locka on Defendant, City of Opa-Locka's Motion to Dismiss Amended
Complaint 2021 -CA -003184 (.3)
7/13/21 Review of AFSCME Representative email concerning employee release
time RE: July 15, 2021 AFSCME Bargaining Session (N/C)
7/12/21 Agreement with Counsel for Defendant on Order Granting Motion for
Leave RE: City of Opa-Locka v Opa-Locka Community Development
Corp, Case No. 2021 -010170 -CA -01 (.3)
7/12/21 Preparation of Motion for Leave to File Amended Complaint and
Complaint Re: City of Opa-Locka v Opa-Locka Community Development
Corp, Case No. 2021 -010170 -CA -01 (1.6)
7/12/21 Review of Order of Dismissal without Prejudice RE: JP Morgan Chase
Bank NA v Reliable Financial Enterprises Inc. et al, Case No. 2019-
003080 -CA -01 (.2)
7/12/21 Reviewed Outside Counsel email concerning Plaintiff's Notice of Serving
Answers to Defendant's Personal Injury Interrogatories RE: Stephanie
Fair v. City of Opa-Locka, Case No. 2021 -008822 -CA -01 (N/C)
7/12/21 Review of Activity Notice on Response in Opposition to Motion RE:
Bennet v. City of Opa-Locka, Case 1:21-cv-21075-BB (.2)
7/12/21 Preparation of email to Plaintiff's Counsel concerning deed for settlement
of property RE: Joseph Barton et al vs City of Opa-Locka, 2016 -011180 -
CA -01 (.1)
7/12/21 Review of Service of Court Document Notice RE: Unopposed Order on
Plaintiffs Motion for Leave to Amend Complaint on City of Opa-Locka vs
Opa-Locka Community Development Corporation; Case No. 2021-
010170 -CA -01 (.2)
7/9/21 Attendance at PBA Union Contract Negotiation meeting (N/C)
7/7/21 Response email to Chief of Police concerning inquiry concerning PBA
Contract for Union Negotiation proposal (.2)
7/7/21 Preparation and review of email from Department of Community and
Planning Director concerning legal description of property for preparation
of deed re: Joseph Barton et al vs City of Opa-Locka, 2016 -011180 -CA -01
(.2)
7/7/21 Reviewed of Amended Complaint RE: City of Opa-Locka vs Opa-Locka
Community Development Corporation, Case No. 2021 -010170 -CA -01 (.3)
7/7/21 Review and compiled exhibits for inclusion in Amended Complaint RE:
City of Opa-Locka vs Opa-Locka Community Development Corporation,
Case No. 2021 -010170 -CA -01 (.5)
7/7/21 Reviewed of City Manager response to PBA counsel RE: Gallimore
Grievance matter - Step 2 (.2)
7/7/21 Review of PBA Grievance of Sharon Gallimore (.2)
7/7/21 Reviewed PBA Counsel email response RE: PBA Grievance of Sharon
Gallimore (.2)
7/7/21 Communication with opposing counsel RE: PBA Grievance of Sharon
Gallimore (.3)
7/7/21 Communication with City staff RE: Water bill arrears on property RE:
Joseph Barton et al vs City of Opa-Locka, 2016 -011180 -CA -01 (.3)
7/7/21 Review of email from Plaintiffs Counsel on existing water bill arrears
concerning settlement property RE: Joseph Barton et al vs City of Opa-
Locka, 2016 -011180 -CA -01 (.3)
7/7/21 Telephone conference with Lida Rodriguez-Taseff RE: City of Opa-Locka
v. Opa-Locka Commmunity Development Corporation, Case No. 2021-
010170 -CA -01 (.8)
7/7/21 Statagy meeting and preparation for conference with Lida Rodriguez-
Taseff RE: City of Opa-Locka v. Opa-Locka Commmunity Development
Corporation, Case No. 2021 -010170 -CA -01 (.7)
7/7/21 Final review and revisions to Amended Complaint for eviction — City of
Opa-Locka v. Opa-Locka CDC - Case No. 2021 -010170 -CA -01 (1.5)
7/6/21 Review of Notice of Mediation Re: Deutsche Bank v Rocio Gonzalez,
Case No. 2018 -018368 -CA -01 (.1)
7/6/21 Review and response to email from M. Gonzalez; Telephone call with
attorneys Re: the City's response/proposal for AFSCME (N/C)
7/6/21 Review of Chief of Police inquiry concerning PBA Contract for Union
Negotiation proposal (N/C)
7/6/21 Review of Outside Counsel email concerning Amended Complaint RE:
2021 -CA -003184, Randolph Aikens vs City of Opa-Locka, Florida (.2)
7/6/21 Attended Internal Management Meeting for preparation for AFSCME
Negotiation (N/C)
7/5/21 Review of budget department staffs inquiry matters RE: PBA Contract for
Union Negotiation proposal (N/C)
7/5/21 Review of information RE: budget department inquiry concerning PBA
Contract (.2)
7/2/21 Telephone conference with Lida Rodriguez-Taseff RE: City of Opa-Locka
vs Opa-Locka Community Development Corporation, Case No. 2021-
010170 -CA -01 (.3)
7/2/21 Reviewed Human Resources department response concerning past police
department demographics for inclusion RE: Sharon D. Gallimore v. City of
Opa-Locka; EEOC No.: 510-2021-03618 (.2)
7/1/21 Review of PBA information from staff Re: Article 21: Off Duty Police
Compensation (N/C)
7/1/21 Review of Third Request for Production RE: Barnett v. City of Opa-Locka
Case #1:21cv21075 (N/C)
7/1/21 Review of email from Lida Rodriguez-Taseff on call RE: City of Opa-Locka
vs Opa-Locka Community Development Corporation, Case No. 2021-
010170 -CA -01 (.2)
7/1/21 Review of draft Amended Complaint RE: City of Opa-Locka vs Opa-Locka
Community Development Corporation, Case No. 2021 -010170 -CA -01 (.4)
7/1/21 AnaRevised draft Amended Complaint re: City of Opa-Locka vs Opa-
Locka Community Development Corporation, Case No. 2021 -010170 -CA -
01 (.2)
7/1/21 Review of Defendant's Request for Production RE: Randolph Aikens vs
City of Opa-Locka RE: 2021 -CA -003184 (N/C)
7/1/21 Review of Human Resources information for Bosque matter and follow-up
with Director RE: Dade County Police Benevolent Association v. City of
Opa-Locka - Case No. 01-21-0004-2772 (.3)
7/1/21 Communication with Human Resources department concerning
demographics matters RE: Sharon D. Gailimore v. City of Opa-Locka;
EEOC No.: 510-2021-03618 (.4)
Total Hours 29.9 $225.00
Total Professional Services: $6,727.50
Costs
Service of Process on Jerome Wolfson $110.00
Facsimile Expenses: $N/C
Copying Services: $375.55
Courthouse Parking Costs: $0.00
Postage, FedEx and Courier Charges: $136.86
Court Call Line: $0.00
Research Services: $57.14
COSTS=$679.55
TOTAL: $7,407.05
Law Office of
Burnadette Norris -Weeks, P.A.
401 N. Avenue of the Arts • Fort Lauderdale, Florida 33311
Phone (954) 768-9770 • Fax (954) 768-9790
INVOICE
CLIENT: CITY OF OPA-LOCKA - Litigation Cases June 1, 2021 through
June 30, 2021
Date ACTIVITY AND HOURS
6/30/21 Review of Memorandum of Disposition Re: Opa-Locka Community
Development Corp, Case No. 2021 -009822 -CA -01 (.3)
6/30/21 Attorneys meeting Telephone conference in preparation for
negotiations; Reviewed and provided feedback on proposal;
Reviewed email from J. Pate regarding the impact of possible PBA
internal wage increase plans; Management meeting with Finance
team (N/C)
6/30/21 AFSCME Prep meeting with City staff (N/C)
6/30/21 Telephone conference with Human Resources RE: Officer
Jamesha McKinney, Case 01-20-0014-5623 (.4)
6/30/21 Review Code of Professional Responsibility and the Arbitration
Rules; Review and response to email from S. Singer Re: Officer
Jamesha McKinney, Case 01-20-0014-5623 (.8)
6/30/21 Review of confidential and priv. memorandum from outside counsel
RE: Bennett v. City of Opa-Locka EEOC Charge No.
Gc2021101194 (.4)
6/30/21 Review of email from AAA on Status of Review RE: Jamesha
MMcKinney Case 01-20-0014-5623 (.2)
6/30/21 Attended internal Management Meeting discussion on City of Opa-
Locka v. Mckinney arbitration matter (.7)
6/30/21 Review of email from American Arbitration Association concerning
City Letter RE: Dade County Police Benevolent Association v. City
of Opa-Locka - Case No. 01-20-0014-5623 (McKinney) (.2)
6/30/21 Review of email from City Manager in response concerning PBA
Contract inquiry for Union Negotiation (N/C)
6/29/21 Review law to amend complaint RE: City of Opa-Locka v. Opa-
locka CDC (combined case) Case No. 2021 -010170 -CA -01 (1.3)
6/29/21 Reviewed of communications from American Arbitration
Association on Arbitrator on selection matters RE: McKinley
Arbitration (.5)
6/29/21 Review of case law concerning use RE: City of Opa-Locka vs Opa-
Locka Community Development Corporation, Case No. 2021-
010170 -CA -01 (.8)
6/29/21 Discussion of budget inquiry with John Pate Re: City of Opa-Locka
v. Opa-locka CDC - Case No. 2021 -010170 -CA -01 (.4)
6/29/21 Response to email on PBA Contract matters for Union Negotiation
proposal (N/C)
6/29/21 Review and response to Amended Complaint RE: City of Opa-
Locka v. Opa-Locka CDC, Case No. 2021 -010170 -CA -01 (1.8)
6/29/21 Review of case law on occupancy matters RE: City of Opa-Locka v.
Opa-Locka CDC - Case No. 2021 -010170 -CA -01 (1.3)
6/28/21 Review and response to AFSCME Contract Proposals Package to
City of Opa-Locka; Preparation of revisions to AFSCME Contract
Proposals Package; Meeting with Human Resources and City
Commission (N/C)
6/28/21 Review of Plaintiffs Certificate of Service Re: Deutsche Bank v
Rocio Gonzalez, Case No. 2018 -018368 -CA -01 (.2)
6/28/21 Reviewed staffs inquiry on PBA Contract for Union Negotiation
proposal (N/C)
6/28/21 Response email to budget department staff's inquiry concerning
PBA Contract for Union Negotiation proposal; Reviewed Chief of
Police email response concerning PBA Contract inquiry for Union
Negotiation proposal (N/C)
6/28/21 Review of City Manager's response concerning Chief of Police's
PBA Contract inquiry for Union Negotiation proposal (N/C)
6/28/21 Review of Activity Notice in Case 1:21-cv-21075-BB Barnett v. City
of Opa-Locka Motion to Stay (.2)
6/28/21 Barnett v. City of Opa-Locka Motion to Stay RE: Case # 1:21-cv-
21075-BB (.2)
6/25/21 Reviewed PBA contract to revise proposal draft for PBA Union
Negotiation (N/C)
6/25/21 Review of Service of Court Agreed Order on Plaintiffs Motion
for
Enlargement of Time RE: 2021 -CA -003184, Randolph Aikens vs
City of Opa-Locka, Florida (.2)
6/28/21 Reviewed Service of Court Document Notice re: 2021 -CA -00
Randolph Aikens vs City of Opa-Locka, Florida Amended 3184
Complaint (.2)
6/25/21 Review of Order Setting Non -Jury Trial with Mediation Referral,
Deutsche Bank v Rocio Gonzalez, Case No. 2018-018368-CAI01
(.2)
6/25/21 Review of City proposals, sick leave payout, PBA Articles 28
and
33 and discussed with City Manager; Drafted email to staff outliniin outstanding items needed for next meeting (N/C) g
6/25/21 Review of Service Document Notice RE: Randolph Aikens v.
Opa-Locka Notice of Taking Deposition of Randolph Aikens on CIJul ofty
28, 2021 (.2) Y
6/25/21 Review of Agreed Order granting Plaintiff's Motion for Enlar
geme
of Time RE:, Randolph Aikens vs City of Opa-Locka, Florida (.1) nt
6/25/21 Review of Plaintiffs Response to Defendant's Second Request Production RE: Randolph Aikens vs City of Opa-Locka RE: 2021 -
CA -003184 (N/C)
6/25/21 Reviewed Plaintiffs' Motion to Substitute Raul Fernandez as
Cl
Representative RE: Suarez, et al v. City of Opa-Locka, Case Noss
17 -008285 -CA -01 (43) (.2)
6/25/21 Reviewed Opposing Counsel's email concerning Plaintiff's intent to
substitute class representatives George Suarez, et al v. City of
Opa-Locka, Case No. 17 -008285 -CA -01 (43) (N/C)
6/25/21 Review of arguments from Class Counsel RE: Fernandez
involvement RE: George Suarez, et al v. City of Opa-Locka, Case
No. 17 -008285 -CA -01 (.3)
6/25/21 Review and response to email from Chief of Police RE: PBA
Contract for Union Negotiation proposal (N/C)
6/25/21 Telephone conference with class counsel to understand arguments
being made by Fernandez in class action to strengthen City's
position (Fernandez as class member) RE: Fernandez v. Opa-
Locka, Case No. 2019 -035518 -CA -01 (.4)
6/24/21 Research of potential counts of Promissory Estoppel and Unjust
Enrichment for inclusion in City's Motion to Amend Complaint RE:
City of Opa-Locka vs Opa-Locka Community Development
Corporation, Case No. 2021 -010170 -CA -01 (1.0)
6/23/21 Receipt and review of PBA suggested changes; reviewed
Compensation and Longevity proposal and drafted responses (N/C)
6/23/21 Attended PBA Union Negotiation on behalf of the City (N/C)
6/23/21 Reviewed staff's revised proposal for PBA Union Negotiation (N/C)
6/23/21 Review and analysis of CDC's Motion to Dismiss Complaint RE:
City of Opa-Locka v. Opa-locka CDC Case No. 2021 -010170 -CA -
01 (1.3)
6/22/21 Attendance at AFSCME preparation meeting N/C
6/22/21 Telephone conference with City Manager Re: Opa-Locka
Community Development Corporation v. City of Opa-Locka, Case
No. 2021 -009822 -CA -01 (.4)
6/22/21 Reviewed Outside Counsel's email concerning response to
Plaintiffs Request for Production RE: George Suarez, et al v. City
of Opa-Locka, Case No. 17 -008285 -CA -01 (.3)
6/22/21 Preparation of email to Class Counsel on Plaintiff's Request for
Production RE: George Suarez, et al v. City of Opa-Locka, Case
No. 17 -008285 -CA -01 (.2)
6/22/21 Reviewed Outside Counsel's email response concerning response
to Plaintiff's Request for Request for Production re: George Suarez,
et al v. City of Opa-Locka, Case No. 17 -008285 -CA -01 (1.3)
6/21/21 Review and analysis of CDC's Motion to Dismiss RE: City of Opa-
Locka vs Opa-Locka Community Development Corporation, Case
No. 2021 -010170 -CA -01 (.9)
6/21/21 Preparation of email to Suzanne Singer at AAA RE: Arbitrator
Conflict J. McKinnley (.4)
6/21/21 Preparation of City's Motion to Dismiss Re: Opa-Locka Community
Development Corp, v. City of Opa-Locka (First Case) Case No.
2021 -009822 -CA -01 (2.5)
6/21/21 Filing of Answer and Affirmative Defenses Re: Fay Plasnie Corp v
Four Property Holdings, LLC, Case No. 2021 -010833 -CA -01 (.4)
6/21/21 Preparation of Answer and Affirmative Defenses Re: Fay Plasnie
Corp v Four Property Holdings, LLC, Case No. 2021 -010833 -CA -01
(1.4)
6/21/21 Received and reviewed emails from John Pate's attorney RE:
FMLA matters (N/C)
6/21/21 Reviewed Service of Court Document Notice re: Fay Plasnie Corp.
v. Four Property Holdings, LLC et al, Case No: 2021 -010833 -CA -01
Answer (.2)
6/21/21 Reviewed Service of Court Document Notice RE: 2021 -CA -003184,
Randolph Aikens vs City of Opa-Locka, Florida Motion for
Extension of Time (.1)
6/21/21 Review of Motion for Extension of Time RE: Randolph Aikens v.
City of Opa-Locka Case # 123021 CA003184000001 (.4)
6/21/21 Review and analysis of Defendant CDC's Motion to Dismiss RE:
City of Opa-Locka vs Opa-Locka Community Development
Corporation, Case No. 2021 -010170 -CA -01 (.9)
6/20/21 Review of arbitration conflict matters and law RE: Officer Jamesha
McKinney, Case 01-20-0014-5623 (2.8)
6/18/21 Second Notification of Submission of Record on Appeal Re: United
States Association of CDC v City of Opa-Locka, Appellate Case
No. 3D2021-1005 (N/C)
6/18/21 Telephone conference with John Pate and review of email RE: PBA
documentation matters (N/C)
6/18/21 Review of Notification of Submission of Record on Appeal Re:
Case No. 3D2021-1005, United States Association of CDC, Inc.,
etc., vs City of Opa-Locka (.2)
6/18/21 Communication with Clerk of Court on record on appeal and status
for United States Association of CDC, Inc., etc., vs City of Opa-
Locka (.4)
6/17/21 Review of Order on Transfer from Judicial Section 23 Re: City of
Opa-Locka v Opa-Locka Community Development Corporation,
Inc., Case No. 2021 -010170 -CA -01 (.3)
6/17/21 Uploading Notice of Hearing and communication with Clerk Re:
Opa-Locka Community Development Corp, v. City of Opa-Locka
Case No. 2021 -009822 -CA -01 (.4)
6/17/21 Preparation of Notice of Hearing Re: Opa-Locka Community
Development Corporation, Case No. 2021 -009822 -CA -01 (.5)
6/17/21 Review of communications from Judicial Assistant on Agreed Order
Granting Motion to Transfer RE: City of Opa-Locka v. Opa-Locka
Community Development Corporation; Case No. 2021 -010170 -CA -
01 (.3)
6/17/21 Review of Status Update on scheduling of 6/24/21 Motion to
Consolidate RE: City of Opa-Locka vs Opa-Locka Community
Development Corporation, Case No. 2021 -010170 -CA -01 (.1)
6/17/21 Review of Confirmation Document Notice RE: City of Opa-Locka vs
Opa-Locka Community Development Corporation; Case No. 2021-
010170 -CA -01 Notice of Hearing for 6/24/21 Motion to
Consolidation (.2)
6/17/21 Review of Defendant's Response to Request for Production RE:
Randolph Aikens v. City of Opa-Locka's Response to Request for
Production 2021 -CA -003184 (.7)
6/16/21 Preparation and review of law on Motion to Consolidate;
Scheduling of Hearing with Plaintiff's Counsel and Court Re: Motion
to Consolidate Re: Opa-Locka Community Development Corp,
Case No. 2021 -009822 -CA -01 (1.3)
6/16/21 Review of Certificate of Service Re: US Bank National Association
v Ameena Ali, Case No. 2018 -040548 -CA -01 (.1)
6/16/21 Preparation of email to Plaintiffs Counsel concerning City's
Response to Plaintiff's Complaint RE: Fay Plasnie Corp. v. Four
Property Holdings, LLC et al, Case No: 2021 -010833 -CA -01 (.3)
6/16/21 Receipt and review of Plaintiff Counsel's response on City's
Response to Plaintiff's Complaint RE: Fay Plasnie Corp. v. Four
Property Holdings, LLC et al, Case No: 2021 -010833 -CA -01 (.4)
6/16/21 Review and revised Miami Dade County's Answer to Quiet Title
action and analysis of approach to secure surplus for the City (Fay
Plasnie Corp vs. Four Property Holdings, LLC, Case No. 2021-
003184 -CA -01) (2.0)
6/15/21 Attended four hour AFSCME Contract Negotiation meeting (N/C)
6/14/21 R/R email Re: Prep meeting; Reviewed and drafted responses to
AFSCME proposal in preparation for meeting; AFSCME prep
meeting to discuss City's responses (N/C)
6/14/21 Review of Receipt and Non Jury Trial Minutes Re: US Bank
National Association v Ameena Ali, Case No. 2018 -040548 -CA -01
(.2)
6/11/21 Receipt and review of numerous email and telephone calls from J.
Pate and K. Ward and Re: Scheduling and other matters RE:
AFCSME Negotiations (N/C)
6/9/21 Review of Plaintiff Counsel's email concerning status of Plaintiff RE:
Case No.: 2021 -007298 -CA -01; Harvey Ruvin v. Four Property
Holdings, LLC, et al (.2)
6/7/21 Review of Final Disposition Document Re: US Bank National
Association v Ameena Ali, Case No. 2018 -040548 -CA -01 (.1)
6/7/21 Review of Notice of Filing Re: Original Note and Mortgage Re: US
Bank National Association v Ameena Ali, Case No. 2018 -040548 -
CA -01 (.3)
6/7/21 Review of Final Judgment issued by Judge Re: US Bank National
Association v Ameena Ali, Case No. 2018 -040548 -CA -01 (.1)
6/7/21 Review of Order on Setting Hearing on Motion to Dismiss Amended
Complaint for Failure to State a Claim for 7/14/2021 RE: 1:21-cv-
21075-BB Barnett v. City of Opa-Locka Order (.2)
6/3/21 Preparation and Filing of Motion to Transfer and review of
procedures Re: City of Opa-Locka v Opa-Locka Community
Development Corporation, Inc., Case No. 2021 -010170 -CA -01 (1.5)
6/3/21 Reviewed Order Granting Motion to Disqualify RE: Raul Fernandez
and DJ Opportunities v. Opa-Locka, Case No. 2019 -035518 -CA -01
(.2)
6/3/21 Preparation and Attendance at Special Set Hearing RE: Fernandez
et al v City of Opa-Locka, Case No. 2019 -035518 -CA -01 (1.2)
6/2/21 Reviewed Plaintiffs Motion to Disqualify Circuit Judge from
Presiding Over Action RE: Raul Fernandez and DJ Opportunities v.
Opa-Locka, Case No. 2019 -035518 -CA -01 (.5)
6/2/21 Preparation for 6/3/2021 Hearing on City's Objection to Plaintiff's
Opt -Out RE: Raul Fernandez and DJ Opportunities v. Opa-Locka,
Case No. 2019 -035518 -CA -01 (1.7)
6/2/21 Review of filings and law to prepare for the City's Objection to
Plaintiffs Opt -Out and for Sanctions — Fernandez v. Opa-locka —
(2.7)
6/2/21 Review and analysis of Motion to Disqualify Judge Hanzman filed
by M. Pizzy RE: Fernandez v. Opa-Locka (.8)
6/1/21 Review of Order Granting Joint Motion on Rescheduling Mediation
Re: Harrell v. Opa-Locka, Case 1:20-cv-21927-RKA, (.2)
Total Hours 43.1 $225.00
Total Professional Services: $9,697.50
Costs
Facsimile Expenses: $12.00
Copying Services: $234.50
Courthouse Parking Costs: $22.00
Postage and FedEx Charges: $133.57
Court Call Line: $N/C
Research Services:$42.54
COSTS=$444.61
TOTAL: $10,142.11
Law Office of
Burnadette Norris -Weeks, P.A.
401 N. Avenue of the Arts • Fort Lauderdale, Florida 33311
Phone (954) 768-9770 • Fax (954) 768-9790
INVOICE
CLIENT: CITY OF OPA-LOCKA - Litigation Cases May 1, 2021 through May
31, 2021
Date ACTIVITY AND HOURS
5/28/21 Review and response to various email to schedule negotiations
with staff on PBA matters; Telephone contact with A. Axelrad (N/C)
5/28/21 Review of EEOC Charge matter Re: RE: Michele Elizabeth Henney
v. City of Opa-Locka; EEOC No.: 510-2021-02858 (.6)
5/28/21 Review of Agreed Order on Unopposed Motion To Consolidate RE:
City of Opa-Locka v. Opa-Locka Community Development
Corporations, Inc., Case No. 2021 -CA -010170 (.8)
5/28/21 Communication with Human Resources RE: Michele Elizabeth
Henney v. City of Opa-Locka; EEOC No.: 510-2021-02858 (.8)
5/27/21 Review of Activity Notice containing various orders including: Order
on Joint Motion to reschedule mediation concerning Scheduling
Order; Order Referring Case to Mediation; Order Referring Case to
Magistrate Judge; Order on Motion to Continue; Order on Motion to
Dismiss for Failure to State a Claim; Order on Motion for Judgment
on the Pleadings and docketing RE Harrell v. Opa-Locka Case 1:20-
cv-21927-RKA (.9)
5/27/21 Review of Activity Notice on Reply to Response on Motion to Dismiss
Amended Complaint/Amended Notice of Removal for Failure to
State a Claim RE: Case 1:21-cv-21075-BB Barnett v. City of Opa-
Locka (.4)
5/24/21 Review of Exhibit List Re: US Bank National Association v Ameena
Ali, Case No. 2018 -040548 -CA -01 (.5)
5/24/21 Review of Voluntary Dismissal RE: JP Morgan Chase Bank NA v
Reliable Financial Enterprises Inc. et al, Case No. 2019 -003080 -
CA -01 (.4)
5/24/21 Review of Final Disposition Document Re: JP Morgan Chase Bank
NA v Reliable Financial Enterprises Inc. et al, Case No. 2019-
003080 -CA -01 (.4)
5/24/21 Preparation of meetings Re: AFCSME Negotiations (N/C)
5/21/21 Review of Service of Court Document Notice RE: 2021 -CA -01017,
City of Opa-Locka vs Opa-Locka Community Development
Corporation, Inc. Return of Service and docket check (.3)
5/21/21 Telephone conference with attorney RE: Barnett v. City of Opa-
Locka Case 1:21-cv-21075-BB (.4)
5/20/21 Communication and review of email update from IT Department
Request for Production response Re: 2021 -CA -003184, Randolph
Aikens vs City of Opa-Locka, Florida (.3)
5/20/21 Review of current documents concerning Request for Production
response RE: 2021 -CA -003184, Randolph Aikens vs City of Opa-
Locka, Florida (.4)
5/20/21 Preparation of email concerning EEOC Complaint received and
follow-up and coordination RE: Barnett v. City of Opa-Locka, Case
No. 510-2021-03403 (.4)
5/20/21 Review and revisions for draft Opposition to Emergency Motion for
Temporary Restraining Order RE: Lakeview Ingram Park
Apartments, LLC v. Miami -Dade County et al.; Case Number 2020-
008684 -CA -01 (2.0)
5/20/21 Communications with Miami -Dade County water department
representatives and attorneys RE: Lakeview Ingram Park
Apartments, LLC v. Miami -Dade County et al.; Case Number 2020-
008684 -CA -01 (.7)
5/20/21 Reviewed Plaintiff's filing of Notice of Extra Record Communication
with the Judge, Suarez v City of Opa-Locka, Case No. 2017 -008284 -
CA -01 (N/C)
5/19/21 Review of Evidence Admitted (Modification Agreement) Re: US
Bank National Association v Ameena Ali, Case No. 2018 -040548 -
CA -01 (.4)
5/19/21 Review of Evidence Admitted (Financial Breakdown Summary) Re:
US Bank National Association v Ameena Ali, Case No. 2018-
040548 -CA -01 (.4)
5/19/21 Review of Evidence Admitted (Default Letter) Re: US Bank National
Association v Ameena Ali, Case No. 2018 -040548 -CA -01 (.2)
5/19/21 Review of Evidence Admitted (Copy of Mortgage) Re: US Bank
National Association v Ameena Ali, Case No. 2018 -040548 -CA -01
(.3)
5/19/21 Review of Evidence Admitted (Copy of Original Note) Re: US Bank
National Association v Ameena Ali, Case No. 2018 -040548 -CA -01
(.3)
5/19/21 Review of Motion for Continuance Re: US Bank National
Association v Ameena Ali, Case No. 2018 -040548 -CA -01 (.2)
5/19/21 Review of Answer and Affirmative Defenses filed by Hanan Ali Re:
US Bank National Association v Ameena Ali, Case No. 2018-
040548 -CA -01 (.3)
5/19/21 Various communications with Opposing Counsel on cases: Opa-
Locka Community Development Corporation, Inc. vs City of Opa-
Locka; Case No. 2021 -009822 -CA -01 and City of Opa-Locka vs
Opa-Locka Community Development Corporation; Case No. 2021-
010170 -CA -01 (.8)
5/19/21 Preparation of email to IT Department on Request for Production
response RE: Randolph Aikens vs City of Opa-Locka 2021 -CA -
003184 (.4)
5/18/21 Reviewed email update from IT Department concerning Request for
Production response RE: Randolph Aikens vs City of Opa-Locka
2021 -CA -003184 (.3)
5/18/21 Review and analysis of documents responsive to Request for
Production RE: Randolph Aikens vs City of Opa-Locka (1.4)
5/18/21 Review of Notice of Non -Jury Trial Re: US Bank National
Association v Ameena Ali, Case No. 2018 -040548 -CA -01 (.2)
5/18/21 Review of FIU and Miami Dade PBA Contracts and drafted
proposed language for leave time; PBA Negotiation Response with
staff (N/C)
5/17/21 Attendance at FWOP Hearing Re: JP Morgan Chase Bank NA v
Reliable Financial Enterprises Inc et al, Case No. 2019 -003080 -CA -
01 (.5)
5/14/21 Review of Notice of Confidential Information within Court Filing Re:
US Bank National Association v. Ameena Ali, Case No. 2018-
040548 -CA -01 (.2)
5/14/21 Preparation and attendance at meeting with Police staff and
discussion of process of arbitration matters (N/C)
5/14/21 Review of email from City Manager's Office on Request for
Production RE: Randolph Aikens vs City of Opa-Locka, Florida (.4)
5/14/21 Review of document response concerning Request for Production
response re: 2021 -CA -003184, Randolph Aikens vs City of Opa-
Locka, Florida (N/C)
5/14/21 Preparation and review of email to IT Department on Request for
Production response RE: Randolph Aikens vs City of Opa-Locka
2021 -CA -003184 (.2)
5/14/21 Telephone conference with Plaintiff counsel RE: 2021 -CA -003184,
Randolph Aikens vs City of Opa-Locka, Florida (.6)
5/13/21 Review of Human Resources Director information regarding EEOC
charge #510-2021-03403 Barnett v. City of Opa-Locka (.8)
5/13/21 Review and response to email and analysis of HR information RE:
EEOC charge #510-2021-03403 Barnett v. City of Opa-Locka (.4)
5/12/21 Review of Evidence Submission (Modification Agreement) Re: US
Bank National Association v Ameena Ali, Case No. 2018 -040548 -
CA -01 (.1)
5/12/21 Review and response to information Re: AFCSME Negotiations
(N/C)
5/11/21 Preparation of Notice of Hearing and scheduling communications
(Special Set) RE: Fernandez et al v City of Opa-Locka, Case No.
2019 -035518 -CA -01 (.9)
5/11/21 Review of evidence submission (Financial Breakdown Summary)
Re: US Bank National Association v Ameena Ali, Case No. 2018-
040548 -CA -01 (.5)
5/11/21 Review of various Evidence Submissions on Default, Mortgage,
Note Re: US Bank National Association v Ameena Ali, Case No.
2018 -040548 -CA -01 (.5)
5/11/21 Preparation and review of various email on Special Set Hearing
RE: Fernandez et. al. v. City of Opa-Locka, Case No. 2019-
035518 -CA -01 (.4)
5/11/21 Strategy Preparation Re: PBA follow-up discussion (N/C)
5/11/21 Review of Court document on Plaintiff's Reply to Defendant's
Response/Objection to the Court Ordered Notice of Filing Opt -Out
RE: Raul Fernandez and DJ Opportunities v. City Opa-Locka, Case
No. 2019 -035518 -CA -01 (2.5)
5/11/21 Review of Court Event Status Update Notice concerning June 3,
2021 Special Set Hearing on City's Objection to Plaintiff's Notice of
Opt -Out and for Sanctions RE: Raul Fernandez and DJ
Opportunities v. Opa-Locka, Case No. 2019 -035518 -CA -01 (.3)
5/11/21 Telephone conference with class counsel RE: Opt Out matters RE:
Raul Fernandez and DJ Opportunities v. Opa-Locka, Case No. 2019-
035518 -CA -01 (.8)
5/11/21 Telephone conference with Sarah Davis RE: Scheduling and
strategy on Fernandez, et al vs. Miami -Dade County and City of Opa-
Locka, Florida; Case No.: 2019 -035518 -CA -01 (.3)
5/11/21 Preparation and review of email the Sarah Davis on hearing
scheduling RE: Fernandez, et al vs. Miami -Dade County and City of
Opa-Locka, Florida; Case No.: 2019 -035518 -CA -01 (.2)
5/10/21 Preparation of email to City Manager concerning Request for
Production response RE: Randolph Aikens vs City of Opa-Locka
2021 -CA -003184 (.3)
5/10/21 Review and response to email from M. Gonzalez regarding Re:
AFCSME Negotiations (N/C)
5/7/21 Review and response to PBA's proposal (N/C)
5/7/21 Filing of Objection to the Plaintiff's Notice for Opt -Out and for
Sanctions RE: Fernandez et al v City of Opa-Locka, Case No.
2019 -035518 -CA -01 (.4)
5/7/21 Research and Preparation of Objections to the Plaintiff's Notice for
Opt -Out and for Sanctions RE: Fernandez et al v City of Opa-
Locka, Case No. 2019 -035518 -CA -01 (4.7)
5/7/21 Review, analysis and meetings with City Manager on Arbitrator's
decision Re: Officer Jamesha McKinney (1.7)
5/7/21 Review of Outside Counsel email concerning Plaintiffs request to
extend discovery deadlines RE: George Suarez, et al v. City of Opa-
Locka, Case No. 17-8285 CA -01 (N/C)
5/7/21 Review of Plaintiffs Motion to Amend Case Management Order RE:
George Suarez, et al v. City of Opa-Locka, Case No. 17-8285 CA -01
(N/C)
5/7/21 Review of Arbitrator's Director of Operations email concerning Award
submission RE: Dade County Police Benevolent Association v. City
of Opa-Locka - Case 01-20-0014-5623 (.3)
5/7/21 Review of Planning and Community Development Director's email
and follow-up concerning property status and necessary procedures
RE: Joseph Barton et al vs City of Opa-Locka, 2016 -011180 -CA -01
(.6)
5/7/21 Review of Activity Notice RE: Barnett v. City of Opa-Locka's Motion
to Dismiss for Failure to State a Claim RE: Case 1:21-cv-21075-BB
(.3)
5/7/21 Review of Court Document Notice RE: Rau! Fernandez and DJ
Opportunities v. Opa-Locka, Case No. 2019 -035518 -CA -01 City's
Objection to Plaintiff's Notice of Opt -Out and for Sanctions (.2)
5/6/21 Reviewed Outside Counsel email concerning Plaintiffs Motion to
Disqualify RE: George Suarez, et al v. City of Opa-Locka, Case No.
17 -008285 -CA -01 (43) (N/C)
5/6/21 Review and analysis Plaintiffs Motion to Disqualify RE: George
Suarez, et al v. City of Opa-Locka, Case No. 17-8285 CA -01 (43)
(N/C)
5/6/21 Review of Outside Counsel email on Plaintiff's Opt -out Notice and
analysis of Opt -Out issues RE: Raul Fernandez and DJ
Opportunities v. Opa-Locka, Case No. 2019 -035518 -CA -01 (.6)
5/6/21 Preparation of revisions and drafted Opposition to Notice of Opt -out
RE: Raul Fernandez and DJ Opportunities v. Opa-Locka, Case No.
2019 -035518 -CA -01 (1.5)
5/6/21 Reviewed and filed Motion to Compel and Motion for Protective
Order RE: Suarez v City of Opa-Locka, Case No. 2017 -008284 -CA -
01 (1.0)
5/5/21 Preparation of Draft Notice in Opposition to Opt Out RE: Raul
Fernandez and DJ Opportunities v. Opa-Locka, Case No. 2019-
035518 -CA -01 (1.8)
5/5/21 Review and response to email from J. Pate and M. Gonzalez
regarding scheduling Re: AFCSME Negotiations (N/C)
5/5/21 Review of Plaintiffs Motion for Extension of Time Re: JP Morgan
Chase Bank NA v Reliable Financial Enterprises Inc. et al, Case
No. 2019 -003080 -CA -01 (.4)
5/3/21 Review of Notice of Mediator Selection and Hearing for 8/6/2021
RE: Barnett v. City of Opa-Locka, Case 1:21-cv-21075-BB (.3)
5/3/21 Review of Order Scheduling Mediation RE: Opa-Locka Order
Scheduling Mediation Activity Notice RE: Barnett v. City of Opa-
Locka, Case 1:21-cv-21075-BB (.3)
5/3/21 Communication with outside counsel on mediation and scheduling
for attendance RE: Barnett v. City of Opa-Locka, 1:21-cv-21075-BB
(.3)
5/3/21 Review of Service of Court Document Notice RE: Harvey Ruvin as
Miami -Dade Clerk of the Courts vs Four Property Holdings, LLC et
al Answer, 2021 -CA -007298 (.3)
5/3/21 Review of notice of Removal from Service List RE: Harvey Ruvin as
Miami -Dade Clerk of the Courts vs Four Property Holdings, LLC et
al., Case Number 2021 -CA -007298, (.3)
5/3/21 Preparation of City's Answer to Complaint for Interpleader Re: Fay
Plasnie Corp. v. Four Property Holdings et al., Case No. 2021-
010833 -CA -01 (1.6)
5/3/21 Review of Order Scheduling Mediation RE: Barnett v. City of Opa-
Locka Case No. 21-cv-21075 (.2)
5/2/21 Review of Notice of Intent Re: US Bank National Association v.
Ameena Ali, Case No. 2018 -040548 -CA -01 (.4)
5/1/21 Review of receipt for $10.00 for issuance of 20 Day Summons Re:
City of Opa-Locka v Opa-Locka Community Development
Corporation, Inc., Case No. 2021 -010170 -CA -01 (.1)
5/1/21 Review of receipt for $401.00 for filing of Complaint Re: City of
Opa-Locka v Opa-Locka Community Development Corporation,
Inc., Case No. 2021 -010170 -CA -01 (.1)
Total Hours 41.8 $225.00
Total Professional Services: $9,405.00
Costs
Service of Process on American Arbitration Association RE: City of Opa-Locka v.
Jerome Wolfson $60.00
$10.00 for issuance of 20 Day Summons Re: City of Opa-Locka v Opa-Locka
Community Development Corp.
Service of Process on Jerome Wolfson $110.00
Facsimile Expenses: $13.00
Copying Services: $164.25
Courthouse Parking Costs: $N/C
Postage, Courier and FedEx Charges: $26.97
Court Call Line: $N/C
Research Services: $53.12
COSTS=$437.34
TOTAL: $9,842.34
Law Office of
Burnadette Norris -Weeks, P.A.
401 N. Avenue of the Arts • Fort Lauderdale, Florida 33311
Phone (954) 768-9770 • Fax (954) 768-9790
INVOICE
CLIENT: CITY OF OPA-LOCKA - Litigation Cases April 1, 2021 through
April 30, 2021
Date ACTIVITY AND HOURS
4/30/21 Preparation of email to David Rainer on scheduling of records
review RE: Reiner v City of Opa-Locka, Case No. 2021 -003184 -
CA -01 (.1)
4/30/21 Filing of 20 Day Summons for Issuance Re: City of Opa-Locka v
Opa-Locka Community Development Corporation, Inc., Case No.
2021 -010170 -CA -01 (.3)
4/30/21 Preparation of 20 Day Summons for Issuance Re: City of Opa-
Locka v Opa-Locka Community Development Corporation, Inc.,
Case No. 2021 -010170 -CA -01 (.4)
4/30/21 Review of outside counsel e-mail concerning transcript of
4/29/2021 status conference RE: George Suarez, et al v. City of
Opa-locka, Case No. 2017 -008285 -CA -01 (N/C)
4/29/21 Attendance at hearing on request of outside counsel RE: George
Suarez, et al v. City of Opa-locka, Case No. 2017 -008285 -CA -01
(.7)
4/29/21 Filing of Complaint and communication with clerk on assignment
RE: City of Opa-Locka v Opa-Locka Community Development
Corporation, Inc., Case No. 2021 -010170 -CA -01 (.4)
4/29/21 Research and Preparation of Complaint Re: City of Opa-Locka v
Opa-Locka Community Development Corporation, Inc., Case No.
2021 -010170 -CA -01 (3.6)
4/29/21 Various Staff communications for Complaint preparation RE: City of
Opa-Locka v Opa-Locka Community Development Corporation,
Inc., Case No. 2021 -010170 -CA -01 (.1.3)
1
4/28/21 Review of Notice RE: Barnett v. City of Opa-Iocka Motion for
Extension of Time to File Response/Reply/Answer Case# 1:21-cv-
21075-BB (.3)
4/28/21 Communication to City Manager concerning draft Complaint RE:
City of Opa-Iocka v. Opa-locka Community Development
Corporation, Inc., Case No. Case No. 2021 -CA -010170 and
documents needed (.4)
4/28/21 Review of email from Planning and Community Development
concerning status of property subject to settlement RE: Joseph
Barton et. al. v. City of Opa-Iocka, 2016 -011180 -CA -0 (.3)
4/28/21 Review of Service of Court Document, Notice of Appearance RE:
United States Association of CDC v. City of Opa-Iocka, Case No.
3D2021-1005 (.2)
4/27/21 Preparation of email to City Manager concerning requested
documentation and analysis for Arbitration proceedings RE: Dade
County Police Benevolent Association v. City of Opa-Iocka - Case
01-20-0014-5623 (.3)
4/27/21 Review of Arbitrator information on deadlines RE: Dade County
Police Benevolent Association v. City of Opa-Iocka, Case 01-20-
0014-5623 (.3)
4/27/21 Review of opposing counsel response to email to Arbitrator on
Award Deadline RE: Dade County Police Benevolent Association v.
City of Opa-Iocka, Case No. 01-20-0014-5623 (.3)
4/27/21 Preparation and analysis of response to Arbitrator concerning
Award RE: Dade County Police Benevolent Association v. City of
Opa-Iocka, Case No. 01-20-0014-5623 (.4)
4/27/21 Review of draft Complaint and Summons RE: City of Opa-Locka v.
Opa-Iocka Community Development Corporations, Inc., Case No.
2021 -CA -010170 (.8)
4/27/21 Review of Notice of Stipulation of Mediator Re: JP Morgan Chase
Bank NA v Reliable Financial Enterprises Inc et al, Case No. 2019-
003080 -CA -01 (.3)
4/26/21 Review of Arbitrator inquiry concerning on requested document of
Arbitration proceeding RE: Dade County Police Benevolent
Association v. City of Opa-Iocka - Case 01-20-0014-5623 (.3)
2
4/26/21 Review of email from outside counsel on case status RE: George
Suarez, et al v. City of Opa-Locka, Case No. 2017 -008285 -CA -01
(N/C)
4/24/21 Review of information issued to Plaintiff's counsel for Circuit Appeal
RE: United States Association of CDC v City of Opa-Locka, Case
No. 2016 -024089 -CA -01 (.3)
4/24/21 Analysis of Plaintiff arguments for potential appeal RE: United
States Association of CDC v City of Opa-Locka, Case No. 2016-
024089 -CA -01 (1.2)
4/23/21 Preparation and response to email to Plaintiff's counsel RE:
proposed order on Raul Fernandez and DJ Opportunities v. Opa-
locka and follow-up, Case No. 2019 -035518 -CA -01 (.4)
4/23/21 Review and analysis of opposing counsel email on Arbitrator
instructions for additional questions regarding facts of case RE:
Dade County Police Benevolent Association v. City of Opa-locka,
Case 01-20-0014-5623 (.3)
4/23/21 Review of Service of Court Document of Plaintiffs Motion for
Enlargement of Time to Respond to Plaintiff's Request For
Discovery RE: United States Association of CDC v. City of Opa-
locka (Case No.: 2016 -029089 -CA -01) (.3)
4/23/21 Review of Service of Court Document on Notice of Appeal and
review of docket RE: United States Association of CDC v. City of
Opa-locka (Case No: 2016 -029089 -CA -01) (.4)
4/23/21 Review and analysis of Court Order on Plaintiffs' Emergency
Motion for Temporary Restraining Order RE: Raul Fernandez and
DJ Opportunities v. Opa-locka, Casze No. 2019 -035518 -CA -01 (.4)
4/23/21 Preparation and attendance at Special Set Hearing on Plaintiff's
Motion for Temporary Restraining Order RE: Fernandez et al v City
of Opa-Locka, Case No. 2019 -035518 -CA -01 (1.8)
4/22/21 Review of opposing counsel email on Arbitrator's instructions for
additional questions on facts of case RE: Dade County Police
Benevolent Association v. City of Opa-locka - Case 01-20-0014-
5623 (.3)
4/22/21 Preparation of email response to opposing counsel on Arbitrator
instructions for additional questions regarding facts of case RE:
3
Dade County Police Benevolent Association v. City of Opa-locka -
Case 01-20-0014-5623 (.2)
4/23/21 Review Court Order denying Plaintiff's Motion for Temporary
Restraining Order - Raul Fernandez and DJ Opportunities v. Opa-
locka, Case No. 2019 -035518 -CA -01 (.3)
4/23/21 Preparation of draft letter to Judge regarding need for Plaintiff to
provide Memorandum to the court explaining how Plaintiff's opted
out of Suarez class action RE: Raul Fernandez and DJ
Opportunities v. Opa-Locks Case No. 2019 -035518 -CA -01 (.8)
4/23/21 Preparation of draft proposed order for Court and call to JA RE:
Raul Fernandez and DJ Opportunities v. Opa-locka, Case No.
2019 -035518 -CA -01 (.8)
4/22/21 Review of Witness and Exhibit List Re: JP Morgan Chase Bank NA
v Reliable Financial Enterprises Inc. et al, Case No. 2019 -003080 -
CA -01 (.6)
4/21/21 Review of Service of Court Document on Notice of Service of
Interrogatories and Request for Production RE: Randolph Aikens v.
City of Opa-locka, Florida, Case No. 2021 -CA -003184 (.4)
4/21/21 Review of Request for Production RE: Randolph Aikens v. City of
Opa-locka, Florida, Case No. 2021 -CA -003184 (.3)
4/21/21 Preparation of email concerning Request for Production RE:
Randolph Aikens vs City of Opa-locka, Florida, Case No. 2021 -CA -
003184 (.3)
4/21/21 Reviewed of status of state approval of settlement RE: B & G Opa
Holdings, Inc. and B&G Opa Land Holdings, L.L.C. v. City of Opa-
locka, Florida, and Newall J. Daughtrey Case No.: 1:18-cv-23269-
DPG (.3)
4/21/21 Response to outside counsel on status of state approval of
settlement RE: B & G Opa Holdings, Inc. and B&G Opa Land
Holdings, L.L.C. v. City of Opa-locka, Florida, and Newall J.
Daughtrey, Case No.: 1:18-cv-23269-DPG (.2)
4/20/21 Review of Service of Court Document on Notice of Service of
Interrogatories and Request for Production RE: Randolph Aikens vs
City of Opa-locka, Florida, Case No. 2021 -CA -003184 (.2)
4
4/20/21 Review of Defendant's Request for Production Re: Reiner v City of
Opa-Locka, Case No. 2021 -003184 -CA -01 (.5)
4/20/21 Preparation of draft and revisions on position statement RE: Marilyn
M. Chang v. City of Opa-locka; EEOC No.: 510-2021-02561 (5.3)
4/19/21 Review of Arbitrator assistant's email concerning Arbitrator
additional questions RE: Dade County Police Benevolent
Association v. City of Opa-locka, Case No. 01-20-0014-5623 (.2)
4/19/21 Review of court email concerning Notice of Electronic Filing of
Amended Complaint/Amended Notice of Removal RE: Case No.
1:21-cv-21075-BB Barnett v. City of Opa-locka (.2)
4/19/21 Receipt and review of email from PBA and AAA requesting a
meeting to discuss arbitration exhibits, gather of exhibits and
nalysis of documents RE: Jamesha McKinney arbitration (1.8)
4/19/21 Preparation of email to Jerome Wolfson RE: timing and response of
additional requests for information, analysis of documents RE:
Jamesha McKinney arbitration (.7)
4/19/21 Preparation Meeting with Staff and police RE: Jamesha McKinney
arbitration (.8)
4/19/21 Telephone call with PBA attorney RE: Jamesha McKinney
arbitration (.7)
4/18/21 Preparation and attendance at meeting with K. Ward RE: Aikens
arbitration FMCS Case #211216-02390 (1.3)
4/17/21 Telephone conference with City Manager RE: Management
decision RE: Aikens arbitration FMCS Case #211216-02390 (.6)
4/16/21 Reviewed Human Resources staff email and documents
concerning employment status of complainant for response in
EEOC Complaint RE: Michele Elizabeth Henney v. City of Opa-
locka; EEOC No.: 510-2021-02858 (1.2)
4/16/21 Review of employment file of complainant for response in EEOC
Complaint RE: Michele Elizabeth Henney v. City of Opa-locka;
EEOC No.: 510-2021-02858 (1.0)
4/16/21 Review of Scheduled Hearing Notice and docketing for Plaintiff's
Emergency Motion for Temporary Restraining Order RE: Raul
5
Fernandez and DJ Opportunities v. Opa-locka, Case No. 2019-
035518 -CA -01 for 04/23/21 (.3)
4/16/21 Review of Arbitrator's email RE: Dade County Police Benevolent
Association v. City of Opa-locka, Case No. 01-20-0014-5623 (.3)
4/16/21 Communication with City Manager and staff on Arbitrator notice
RE: Dade County Police Benevolent Association v. City of Opa-
locka, Case No. 01-20-0014-5623 (.2)
4/16/21 Review of email response to Arbitrator concerning Award Deadline
RE: Dade County Police Benevolent Association v. City of Opa-
locka, Case No. 01-20-0014-5623 (.2)
4/16/21 Reviewed court information on Notice of Electronic Filing of
Amended Complaint/Amended Notice of Removal re: Case No.
1:21-cv-21075-BB Barnett v. City of Opa-locka (.4)
4/16/21 Review of Scheduled Zoom Meeting Notification RE: Fernandez
et.al. v. City of Opa-Locka, Case No. 2019 -035518 -CA -01 (.3)
4/15/21 Reviewed Public Works email concerning relevant transfer station
RE: United Waste Services of Florida, Inc, Case No. 17-001268 CA
01 (N/C)
4/15/21 Negotiation Session with AFSCME (N/C)
4/14/21 Preparation of draft motion and research on Fifth Motion for
Summary Judgment and analysis on ways to finally dispose of case
RE: United States Association of CDC v. City of Opa-locka (Case
No.: 2016 -029089 -CA -01 (4.7)
4/14/21 Review of court information concerning Notice of Electronic Filing of
Reset Deadlines/Hearings/Discovery RE: Case 1:21-cv-21075-BB
Barnett v. City of Opa-locka (.3)
4/14/21 Reviewed court email concerning Notice of Electronic Filing of
Notice of cancellation of Hearing RE: Case 1:21-cv-21075-BB
Barnett v. City of Opa-locka (.2)
4/14/21 Review of Notice and Court Order Re: Yvette Harrell v City of Opa-
Locka, Case No. 1:20-cv-21927-RKA (.3)
4/14/21 Coordination with co -counsel on discovery matter RE: Yvette
Harrell v City of Opa-Locka, Case No. 1:20-cv-21927-RKA (.5)
6
4/14/21 Communication with City Manager on discovery from Human
Resources RE: Yvette Harrell v City of Opa-Locka, Case No. 1:20-
cv-21927-RKA (.4)
4/14/21 Review of Omnibus Order Re: Yvette Harrell v City of Opa-Locka,
Case No. 1:20-cv-21927-RKA (.2)
4/14/21 Review of Court Order Re: JP Morgan Chase Bank NA v Reliable
Financial Enterprises Inc et al, Case No. 2019 -003080 -CA -01 (.3)
4/14/21 Review of Order of Dismissal Re: JP Morgan Chase Bank NA v
Reliable Financial Enterprises Inc et al, Case No. 2019 -003080 -CA -
01 (.2)
4/14/21 Review of Order Setting Jury Trial with Mediation Referral Re: JP
Morgan Chase Bank NA v Reliable Financial Enterprises Inc et al,
Case No. 2019 -003080 -CA -01 (.2)
4/14/21 Review of various Service of Court Document email Re: JP Morgan
Chase Bank NA v Reliable Financial Enterprises Inc et al, Case No.
2019 -003080 -CA -01 (.3)
4/14/21 Review of Court Order Re: Reiner v City of Opa-Locka, Case No.
2021 -003184 -CA -01 (.5)
4/13/21 Uploading and communication with JA on Proposed Order Re: In -
Camera Inspection Re: Reiner v City of Opa-Locka, Case No.
2021 -003184 -CA -01 (.7)
4/13/21 Review of court email on Notice of Electronic Filing; Notice of
Hearing for Unopposed Motion to Continue Scheduling Order,
Second Motion to Dismiss Amended Complaint/Amended Notice of
Removal for Failure to State a Claim, and Defendant's Motion for
Judgment on the Pleadings (Counts III -V) Hearing set for 4/26/2021
re: Case 1:21-cv-21075-BB Barnett v. City of Opa-locka, (.4)
4/13/21 Reviewed Service of Court Document on Notice of Service of Order
on In Camera Inspection RE: David Reiner I I , v. City of Opa-locka
Case No: 21-3264 CA (01) (.3)
4/13/21 Review of Paperless Notice Re: Yvette Harrell v City of Opa-Locka,
Case No. 1:20-cv-21927-RKA (.1)
4/13/21 Preparation of Proposed Order Re: In -Camera Inspection Re:
Reiner v. City of Opa-Locka, Case No. 2021 -003184 -CA -01 (.8)
7
4/12/21 Review of court email concerning Notice of Electronic Filing of
Motion for Extension of Time RE: Case 1:21-cv-21075-BB Barnett
v. City of Opa-locka (.1)
4/12/21 Review of court notice on Notice of Electronic Filing of Scheduling
Report RE: Case 1:21-cv-21075-BB Barnett v. City of Opa-locka
(.3)
4/12/21 Review of court notice concerning Notice of Electronic Filing of
Order on Motion for Extension of Time RE: Case 1:21-cv-21075-BB
Barnett v. City of Opa-locka (.2)
4/12/21 Review of court email concerning Notice of Electronic Filing of
Scheduling Order re: Case 1:21-cv-21075-BB Barnett v. City of
Opa-locka (.2)
4/12/21 Preparation of follow up with Public Works Director concerning the
relevant transfer station and communication with defense counsel
RE: Universal Waste Services v. City of Opa-locka (2017 -001268 -
CA -01) (.3)
4/12/21 Review of Court Event Hearing Reminder Re: JP Morgan Chase
Bank NA v Reliable Financial Enterprises Inc et al, Case No. 2019-
003080 -CA -01 (.2)
4/11/21 Review of Court Event Hearing Reminder Re: Motion to Stay
Proceedings Re: JP Morgan Chase Bank NA v Reliable Financial
Enterprises Inc et al, Case No. 2019 -003080 -CA -01 (.2)
4/8/21 Preparation of Draft Second Set of Interrogatories and Request for
Production to Plaintiff RE: United States Association of CDC v. City
of Opa-locka (Case No.: 2016 -029089 -CA -01) (1.5)
4/8/21 Reviewed Service of Court Document of Notice of Service of
Second Set of Interrogatories to Plaintiff and request for production
RE: United States Association of CDC v. City of Opa-locka (Case
No.: 2016 -029089 -CA -01) (.4)
4/8/21 Preparation of Service of Court Document to Alex Dehghani, Esq.
Re: Notice of Service —Second Set of Interrogatories; Second Set
of Interrogatories; Second Request for Production Re: United
States Association of CDC v City of Opa-Locka, Case No. 2016-
024089 -CA -01 (.4)
8
4/8/21 Review of Court Reminder Re: Motion to Stay Proceedings Re: JP
Morgan Chase Bank NA v Reliable Financial Enterprises Inc et al,
Case No. 2019 -003080 -CA -01 (.2)
4/7/21 Review of Amended Witness List RE: US Bank National
Association v Ameena Ali, Case No. 2018 -040548 -CA -01 (.4)
4/7/21 Communication with Plaintiff's counsel on Opposition of Plaintiffs'
Emergency Motion to Dismiss RE: Raul Fernandez and DJ
Opportunities v. Opa-locka, Case No. 2019 -035518 -CA -01 (.6)
4/6/21 Preparation of email to Code Enforcement Director concerning lien
status of relevant property RE: Raul Fernandez and DJ
Opportunities v. Opa-locka, Case No. 2019 -035518 -CA -01 (.3)
4/6/21 Call to Clerk's Office on Motion to Set Aside Clerk's Default re:
David Reiner II, v. City of Opa-locka Case No: 21-3264 CA (.4)
4/6/21 Review of Human Resources staff information concerning
employment file on complainant RE: Marrilyn M. Chang v. City of
Opa-locka; EEOC No.: 510-2021-02561 (.7)
4/6/21 Telephone conference with Plaintiffs counsel on Court Order Re:
Reiner v. City of Opa-Locka, Case No. 2021 -003184 -CA -01 (.5)
4/6/21 Uploading of Court Order Re: Reiner v City of Opa-Locka, Case
No. 2021 -003184 -CA -01 (.4)
4/6/21 Preparation of Court Order Re: Reiner v City of Opa-Locka, Case
No. 2021 -003184 -CA -01 (.6)
4/6/21 Preparation and Attendance at Court Hearing Re: Reiner v City of
Opa-Locka, Case No. 2021 -003184 -CA -01 (2.3)
4/5/21 Preparation of Draft Court Document email on Motion to
Consolidate RE: Raul Fernandez and DJ Opportunities v. Opa-
locka, Case No. 2019 -035518 -CA -01 (.3)
4/5/21 Reviewed Service of Court Document on Plaintiff's Unopposed
Motion to Amend Amended Final Judgment of Foreclosure and to
Direct The Clerk to Amend Certificate of Title RE: Gloria Betancourt
vs New Beginning of South Florida Inc et al., Case No. 2015 -CA -
017927 (.3)
9
4/5/21 Review of Order on Plaintiffs Emergency Motion for Immediate
Hearing RE: Case No. David Reiner II v. City of Opa-locka Case
No: 21-3264 CA (.2)
4/5/21 Communication with City Manager Re: Reiner v City of Opa-Locka,
Case No. 2021 -003184 -CA -01 (.3)
4/5/21 Review of Court Order RE: Fernandez et al v City of Opa-Locka,
Case No. 2019 -035518 -CA -01 (.5)
4/5/21 Uploading of Proposed Order RE: Fernandez et al v City of Opa-
Locka, Case No. 2019 -035518 -CA -01 (.4)
4/5/21 Preparation of Proposed Order RE: Fernandez et al v City of Opa-
Locka, Case No. 2019 -035518 -CA -01 (.3)
4/5/21 Review of Witness and Exhibit List and Certificate of Service Re:
US Bank National Association v Ameena Ali, Case No. 2018-
040548 -CA -01 (.4)
4/6/21 Organization of notes and addition research in preparation of final
Motion for Summary Judgment — United States Association of CDC
v. City of Opa-locka, Case No. 3D2021-1005 (2.6)
4/5/21 Review and response to email and correspondence from the Office
of City Manager to AFSCME (N/C)
4/2/21 Drafted proposed order for Motion to Consolidate RE: Raul
Fernandez and DJ Opportunities v. Opa-Locka, Case No. 2019-
035518 -CA -01 (.6)
4/2/21 Preparation of email to Public Works Director concerning the
transfer station RE: Universal Waste Services v. City of Opa-locka
(N/C)
4/2/21 Reviewed email response of Public Works Director concerning the
relevant transfer station re: Universal Waste Services v. City of
Opa-locka (2017 -001268 -CA -01) (.3)
4/2/21 Emailed response to Public Works Director concerning the transfer
station re: Universal Waste Services v. City of Opa-locka (2017-
001268 -CA -01 (.3)
4/2/21 Reviewed email response of Public Works Director concerning the
transfer station re: Universal Waste Services v. City of Opa-locka
(2017 -001268 -CA -01) (.2)
10
4/2/21 Reviewed email of Human Resources staff concerning EEOC
complaint response re: Marilyn M. Chang v. City of Opa-locka;
EEOC No.: 510-2021-02561 (.4)
4/2/21 Communication with EEOC investigator concerning EEOC
complaint response RE: Marrilyn M. Chang v. City of Opa-locka;
EEOC No.: 510-2021-02561 (.5)
4/2/21 Review and analysis of denial of Order denying Motion to
Consolidate RE: Raul Fernandez and DJ Opportunities v. Opa-
locka, Case No. 2019 -035518 -CA -01 (.6)
4/1/21 Review of similar cases filed by Plaintiff's counsel and review of
dockets for responses RE: David Reiner I I , v. City of Opa-locka
Case No: 21-3264 CA (.8)
4/1/21 Preparation of Motion to Set Aside Clerk's Default RE: David Reiner
I I , v. City of Opa-locka Case No: 21-3264 CA (01) (.8)
4/1/21 Reviewed revised draft Motion to Set Aside Clerk's Default re:
David Reiner I I, v. City of Opa-locka Case No: 21-3264 CA (.6)
4/1/21 Reviewed Service of Court Document / Opposition to Plaintiffs'
Emergency Motion to Dismiss RE: Raul Fernandez and DJ
Opportunities v. Opa-Locka, Case No. 2019 -035518 -CA -01 (.6)
4/1/21 Reviewed and revised draft Motion to Set Aside Clerk's Default RE:
David Reiner II, v. City of Opa-Locka Case No: 21-3264 CA (.4)
4/1/21 Reviewed finalized draft Answer RE: David Reiner I I , v. City of
Opa-Locka Case No: 21-3264 CA (01) (.8)
4/1/21 Review of Service of Court Document of Answer and Affirmative
Defenses RE: Raul Fernandez and DJ Opportunities v. Opa-Locka,
Case No. 2019 -035518 -CA -01 (.3)
4/1/21 Preparation of draft Order concerning Plaintiff's Emergency Motion
for Immediate Hearing held on February 23, 2021 RE: David Reiner
II , v. City of Opa-Locka Case No: 21-3264 CA (.6)
4/1/21 Draft letter to Court concerning Order on Plaintiff's Emergency
Motion for Immediate Hearing held on February 23, 2021 RE: David
Reiner I I , v. City of Opa-Locka Case No: 21-3264 CA (01) (.6)
4/1/21 Filing of Motion to Set Aside Default unnoticed Re: Reiner v City of
Opa-Locka, Case No. 2021 -003184 -CA -01 (.8)
11
4/1/21 Review of Emergency Motion Re: Reiner v City of Opa-Locka,
Case No. 2021 -003184 -CA -01 (.5)
4/1/21 Uploading of Proposed Order Re: Reiner v City of Opa-Locka,
Case No. 2021 -003184 -CA -01 (.4)
4/1/21 Preparation of Proposed Order Re: Reiner v City of Opa-Locka,
Case No. 2021 -003184 -CA -01 (.8)
4/1/21 Filing of Answer and Affirmative Defenses Re: Reiner v City of
Opa-Locka, Case No. 2021 -003184 -CA -01 (.5)
4/1/21 Preparation of Answer and Affirmative Defenses Re: Reiner v City
of Opa-Locka, Case No. 2021 -003184 -CA -01 (3.1)
4/1/21 Filing of Defendant's Motion in Opposition to Plaintiff's Motion for
Reconsideration Re: Reiner v City of Opa-Locka, Case No. 2021-
003184 -CA -01 (.4)
4/1/21 Preparation and analysis in Opposition to Emergency Motion for
Temporary Restraining Order RE: Fernandez et al v City of Opa-
Locka, Case No. 2019 -035518 -CA -01 (2.9)
Total Hours 80.2 $225.00
Total Professional Services: $18,045.00
Costs
Court Complaint filing fee for Opa-Locka v Opa-Locka CDC $415.00
Summons Issuance Fee for Opa-Locka v Opa-Locka CDC $10.35
Facsimile Expenses: $26.00
Copying Services: $366.50
Courthouse Parking Costs: $22.00
Postage, FedEx and Courier Charges: $77.40
Court Call Line: $N/C
Research Services:$114.90
COSTS=$1,032.15
TOTAL: $19,077.15
12
Law Office of
Burnadette Norris -Weeks, P.A.
401 N. Avenue of the Arts • Fort Lauderdale, Florida 33311
Phone (954) 768-9770 • Fax (954) 768-9790
INVOICE
CLIENT: CITY OF OPA-LOCKA - Litigation Cases March 1, 2021 through
March 31, 2021
Date ACTIVITY AND HOURS
3/31/21 Filing of Motion to Consolidate RE: Fernandez et. al. v. City of Opa-
Locka, Case No. 2019 -035518 -CA -01 (.5)
3/31/21 Telephone conferences with Court judicial assistant on rule interpretation
and process for filing RE: Fernandez et. al. v. City of Opa-Locka, Case
No. 2019 -035518 -CA -01 (.4)
3/31/21 Final preparation and filing of Motion to Consolidate RE: Fernandez et. al.
v City of Opa-Locka, Case No. 2019 -035518 -CA -01 (.6)
3/31/21 Review of Notice of Hearing RE: JP Morgan Chase Bank NA v. Reliable
Financial Enterprises Inc. et. al., Case No. 2019 -003080 -CA -01 (.2)
3/31/21 Preparation of email and follow-up to opposing counsel concerning lien
status of relevant property RE: Raul Fernandez and DJ Opportunities v.
Opa-Locka, Case No. 2019 -035518 -CA -01 (.5)
3/31/21 Communication with City Manager on Motion to Consolidate intent and
need for affidavit, discovered information RE: Fernandez et. al. v. City of
Opa-Locka, Case No. 2019 -035518 -CA -01 (.6)
3/31/21 Preparation of Motion in Opposition to Set Aside Clerk's Default
RE: David P. Reiner v. City of Opa-Locka RE: CASE NO: 21-3264 CA
(01) (1.5)
3/31/21 Preparation of email to M. Pizzi RE: Mental impression matters in attorney
billing for water matters RE: David P. Reiner v. City of Opa-Locka
RE: CASE NO: 21-3264 CA (01) (.5)
3/31/21 Review and research of privilege log and related matters to exclude
mental impressions of attorney RE: David P. Reiner v. City of Opa-Locka
RE: CASE NO: 21-3264 CA (01) (1.5)
3/31/21 Preparation and Response to email to Bob Anathan on legal question for
settlement matter RE: The Brown Law Group, LLC vs. City of Opa-
Locka, 2019 -027913 -CA -01 (.5)
3/31/21 Telephone conference with Attorney Hearn RE: North Park Water Billing
Matter (N/C)
3/31/21 Preparation of email to A. Austin and information on background for
Affidavit RE: Fernandez et al v City of Opa-Locka, Case No. 2019-
035518 -CA -01 (.5)
3/31/21 Reviewed and filed Activity Notice to Continue RE: Harrell v. Opa-
Locka; Federal Case Number: 1:20-cv-21927-RKA (.3)
3/31/21 Review of Notice by Plaintiff on Proof of Service of 1st Set
Interrogatories RE: Harrell v. Opa-Locka, Federal Case Number: 1:20-cv-
21927-RKA (.4)
3/30/21 Review of court activity notice concerning Plaintiff serving First Request
for Production, review of request matters (Nolan, Debra) in Case No.
1:20-cv-21927-RKA Harrell v. Opa-Locka (.6)
3/30/21 Analysis, Preparation of email and telephone response to Code
Enforcement Director concerning lien status of relevant property RE: Raul
Fernandez and DJ Opportunities v. Opa-Locka, Case No. 2019 -035518 -
CA -01 (.6)
3/30/21 Review Code Enforcement Director's response on lien status of relevant
property RE: Raul Fernandez and DJ Opportunities v. Opa-Locka, Case
No. 2019 -035518 -CA -01 (.3)
3/30/21 Follow-up with Public Works Director concerning status of Affidavit
execution status for Opposition to Motion for Restraining Order RE: Raul
Fernandez and DJ Opportunities v. Opa-Locka, Case No. 2019 -035518 -
CA -01 (.7)
3/30/21 Review of information from Police Department on Jeffery Faulkner
employment status for administrative hearing and rank matters for
arbitration (.8)
3/30/21 Reviewed Activity Notice on Motion to Continue RE: Harrell v. Opa-
Locka, Case No. 1:20-cv-21927-RKA (.7)
3/30/21 Review and analysis of Court file for communication with insurance
counsel RE: Harrell v. Opa-Locka, Case No. 1:20-cv-21927-RKA (.8)
3/29/21 Meeting with K. Ward to discuss case status RE: Randolph Aikens for
Arbitration matter (1.2)
3/29/21 Communication with John Pate to discuss arbitration matter RE: Randolph
Aikens for Arbitration matter (.7)
3/29/21 Review of Plaintiffs' Notice of Appeal to the Florida Supreme Court
seeking discretionary review of the Third DCA ruling decertifying the
Deposit Class and comments and communication with outside counsel of
City's position RE: George Suarez, et al v. City of Opa-Locka, Case No.
2017 -008285 -CA -01 (1.3)
3/29/21 Preparation of email to Human Resource Director on access to account
RE: Michele Elizabeth Henney v. City of Opa-Locka; EEOC No.: 510-
2021-02858 (.4)
3/29/21 Review of court activity notice on Motion to Dismiss for Failure to State a
Claim RE: Barnett v. City of Opa-Locka Case 1:21-cv-21075-BB (.2)
3/29/21 Review of outside counsel email on Requests for Admissions RE:
Universal Waste Services of Florida v. City of Opa-Locka, Case No. 17-
001268 CA 01 (05) (.3)
3/29/21 Analysis and Preparation of email to Human Resource Director on
employment file of Marrilyn Chang for use in response to EEOC
Complaint RE: Marrilyn M. Chang v. City of Opa-Locka; EEOC No.:
510-2021-02561 (.6)
3/27/21 Preparation and analysis of email to James Greason RE: Executed
Settlement Agreement RE: Joseph Barton et. al. v. City of Opa-locka,
2016 -011180 -CA -01 (.4)
3/26/21 Preparation and review of email with Chris Stearns concerning draft
Motion to Dismiss and left message RE: Barnett v. City of Opa-Locka,
Case No. 1:21-cv-21075-BB (.4)
3/26/21 Review of Court Event Status Update email concerning Emergency
Motion for Temporary Restraining Order, checked docket for other status
RE: Raul Fernandez and DJ Opportunities v. Opa-Locka, Case No. 2019-
035518 -CA -01 (.4)
3/26/21 Review of Service of Court Document on 1/29/21 hearing transcript and
follow-up with Court RE: United States Association of CDC v. City of
Opa-locka (Case No.: 2016 -029089 -CA -01) (.4)
3/26/21 Research on legal operation of Emergency Motion for Temporary
Restraining Order timing matters RE: Raul Fernandez and DJ
Opportunities v. Opa-locka, Case No. 2019 -035518 -CA -01 (.8)
3/26/21 Communication with Plaintiff's attorney office on hearing matters and
notice RE: Raul Fernandez and DJ Opportunities v. Opa-Locka, Case No.
2019 -035518 -CA -01 (.4)
3/26/21 Preparation of email to James Greason on Settlement matters RE: Joseph
Barton et. al. v. City of Opa-Locka, 2016 -011180 -CA -01 (.4)
3/25/21 Review of various email from opposing counsel on agreed final judgment
for Defendant RE: United States Association of CDC v. City of Opa-locka
(Case No.: 2016 -029089 -CA -01) (.4)
3/25/21 Communication with opposing counsel on agreed final judgment for
Defendant RE: United States Association of CDC v. City of Opa-locka
(Case No.: 2016 -029089 -CA -01) (.5)
3/25/21 Preparation of email to opposing counsel RE: final judgment for
Defendant RE: United States Association of CDC v. City of Opa-locka
(Case No.: 2016 -029089 -CA -01) (.2)
3/25/21 Analysis of final judgment from opposing counsel RE: United States
Association of CDC v. City of Opa-Locka (Case No.: 2016 -029089 -CA -
01) (.4)
3/25/21 Review of Service of Court Document on Court Order RE: United States
Association of CDC v. City of Opa-Locka (Case No.: 2016 -029089 -CA -
01) (.3)
3/25/21 Review of email regarding agreed final judgment from Defendant RE:
United States Asociation of CDC v. City of Opa-Locka (Case No.: 2016-
029089 -CA -01) (.1)
3/25/21 Review of email on hearing dates for Plaintiffs Emergency Motion for
Temporary Restraining Order RE: Case No. Raul Fernandez and DJ
Opportunities v. Opa-Locka, Case No. 2019 -035518 -CA -01 (.3)
3/25/21 Communications with co-defendants on hearing and hearing dates on
Plaintiff's Emergency Motion for Temporary Restraining Order RE: Raul
Fernandez and DJ Opportunities v. Opa-Locka, Case No. 2019 -035518 -
CA -01 (.6)
3/25/21 Review of opposing counsel email concerning Plaintiffs Emergency
Motion for Temporary Restraining hearing RE: Raul Fernandez and DJ
Opportunities v. Opa-Locka, Case No. 2019 -035518 -CA -01 (.4)
3/25/21 Analysis and preparation of Motion for More Definite Statement RE: Raul
Fernandez and DJ Opportunities v. Opa-locka, Case No. 2019 -035518 -
CA -01 (1.8)
3/25/21 Reviewed follow up email concerning Plaintiffs Emergency Motion for
Temporary Restraining Hearing RE: Raul Fernandez and DJ Opportunities
v. Opa-Locka, Case No. 2019 -035518 -CA -01 (.4)
3/25/21 Review of co-defendant response concerning Plaintiffs Emergency
Motion for Temporary Restraining Order RE: Raul Fernandez and DJ
Opportunities v. Opa-Locka, Case No. 2019 -035518 -CA -01 (.2)
3/25/21 Review of Service of Court Document on Notice of Appearance in the
case of Randolph Aikens RE: Case No. 2021 -CA -003184 (.2)
3/25/21 Follow up with Staff concerning lien allegation of opposing counsel in
preparation for hearing RE: Raul Fernandez and DJ Opportunities v. Opa-
locka, Case No. 2019 -035518 -CA -01 (.4)
3/25/21 Telephone conferences with management in preparation for negotiations
Re: AFSCME (N/C)
3/25/21 PBA Negotiations and Management Preparation Meeting (N/C)
3/25/21 Preparation of email to Greg Gay on status of property with no parcel
number and follow-up RE: Joseph Barton et al vs City of Opa-locka,
2016 -011180 -CA -01 (.4)
3/24/21 Review of opposing counsel email regarding agreed final judgment for
Defendant RE: United States Association of CDC v. City of Opa-Locka
(Case No.: 2016 -029089 -CA -01) (.3)
3/24/21 Review and revision to agreed final order for Defendant RE: United States
Association of CDC v. City of Opa-locka (Case No.: 2016 -029089 -CA -
01) (.8)
3/24/21 Review and analysis of email of Planning and Community Development
staff concerning draft legislation on settlement in RE: B & G Opa
Holdings, Inc., v. City of Opa-locka and Newall J. Daughtrey, Case No.
1:18-cv-23269-DPG (.4)
3/24/21 Reviewed Service of Court Document on Notice of Hearing RE: Raul
Fernandez and DJ Opportunities v. Opa-Locka, Case No. 2019 -035518 -
CA -01 (.2)
3/24/21 Preparation and response to email with opposing counsel on agreed final
judgment and research of fees matter RE: United States Association of
CDC v. City of Opa-locka (Case No.: 2016 -029089 -CA -01) (.7)
3/24/21 Reviewed email on pending special set request RE: Raul Fernandez and
DJ Opportunities v. Opa-Locka, Case No. 2019 -035518 -CA -01 (.3)
3/23/21 Reviewed email concerning Notice of Electronic Filing of Order on Post -
Removal Procedures, and Requiring Scheduling Report and Certificates of
Interested Parties from court RE: Barnett v. City of Opa-Locka, Case No.
1:21-cv-21075-BB (.3)
3/23/21 Reviewed email from Planning and Community Development staff
concerning draft legislation RE: B & G Opa Holdings, Inc., v. City of
Opa-Locka and Newall J. Daughtrey, Case No. 1:18-cv-23269-DPG (.3)
3/23/21 Review of email from Chris Stearns concerning settlement agreement RE:
B & G Opa Holdings, Inc., v. City of Opa-Locka and Newall J.
Daughtrey, Case No. 1:18-cv-23269-DPG (.2)
3/23/21 Reviewed email from City Clerk and follow-up RE: settlement agreement
on B & G Opa Holdings, Inc., v. City of Opa-locka and Newall J.
Daughtrey, Case No. 1:18-cv-23269-DPG (.4)
3/23/21 Review of email from Chris Stearns RE: settlement agreement for B & G
Opa Holdings, Inc. v. City of Opa-Locka and Newall J. Daughtrey, Case
No. 1:18-cv-23269-DPG (.3)
3/23/21 Telephone conference with Planning and Community Development staff
on draft legislation and settlement RE: B & G Opa Holdings, Inc., v. City
of Opa-locka and Newall J. Daughtrey, Case No. 1:18-cv-23269-DPG (.5)
3/23/21 Preparation for 3/24/21 Hearing for Plaintiff's Motion for Entry of Final
Judgment RE: United States Association of CDC v. City of Opa-locka
(Case No.: 2016 -029089 -CA -01) (1.5)
3/22/21 Telephone conference with Jon Railey (outside co -counsel) concerning
Motion to Dismiss content RE: Barnett v. City of Opa-locka CASE# 1:21-
cv-21075-BB (.4)
3/22/21 Reviewed email from Arbitrator concerning Arbitration Award Due Date
RE: Dade County Police Benevolent Association v. City of Opa-locka -
Case 01-20-0014-5623 (.3)
3/22/21 Communication and meeting with Mayor RE: B & G Opa Holdings, Inc.,
v. City of Opa-locka and Newall J. Daughtrey, Case No. 1:18-cv-23269-
DPG (1.4)
3/22/21 Communication with Planning and Community Development staff on
presentation for meeting with Mayor RE: B & G Opa Holdings, Inc., v.
City of Opa-locka and Newall J. Daughtrey, Case No. 1:18-cv-23269-
DPG (.4)
3/22/21 Review of scheduling for additional Motion to Dismiss RE: Harrel
Deposition RE: Harrell v. Opa-locka, Case No. 1:20-cv-21927-RKA (.3)
3/22/21 Review of email of Jon Railey (outside co -counsel) RE: RE: Harrell v.
Opa-locka, Case No. 1:20-cv-21927-RKA (.2)
3/22/21 Review of court email concerning Notice of Electronic Filing of Clerk's
Notice of Judge Assignment to Judge Beth Bloom RE: Barnett v. City of
Opa-Locka, Case 1:21-cv-21075-BB (.2)
3/22/21 Review of court email concerning Notice of Electronic Filing of Notice of
Attorney Appearance RE: Barnett v. City of Opa-Locka, Case 1:21-cv-
21075-BB (.2)
3/22/21 Review of email from outside counsel concerning Court Order on City's
Motion to Compel RE: George Suarez et. al. vs. City of Opa-Locka, Case
No. 132017CA008285000001 (.2)
3/22/21 Gathered and produced information to Chris Stearns at League of Cities
RE: Harrell v. City of Opa-Locka (.7)
3/22/21 Preparation of email to Planning and Community Development staff
concerning draft legislation for settlement RE: B & G Opa Holdings, Inc.,
v. City of Opa-locka and Newall J. Daughtrey, Case No. 1:18-cv-23269-
DPG (.9)
3/21/21 Review of email and analysis of outside counsel concerning invoices at
subject of upcoming 4/6/21 Motion to Reconsider Request to Award Fees
and Costs and Motion for Rule to Show Cause and Motion For In Camera
Inspection hearing RE: Case No. 2021 -003264 -CA -01, David Reiner, II vs
City of Opa-locka (1.8)
3/19/21 Analysis and preparation of email to Arbitrator on Arbitration Brief RE:
Dade County Police Benevolent Association v. City of Opa-Locka Case
No. 01-20-0014-5623 (.8)
3/19/21 Review of email of from Planning and Community staff concerning
settlement agreement and follow-up RE: B & G Opa Holdings, Inc., v.
City of Opa-Locka and Newall J. Daughtrey, Case No. 1:18-cv-23269-
DPG (.7)
3/18/21 Meeting with City Staff RE: Setback matters and B&G Opa Holdings, Inc.
and B&G Opa Land Holdings, L.L.C. v. City of Opa-Locka, Florida, and
Newall J. Daughtrey; Case No.: 1:18-cv-23269-DPG (2.5)
3/18/21 Preparation and revisions to draft Arbitration Brief RE: Dade County
Police Benevolent Association v. City of Opa-locka, Case 01-20-0014-
5623 (.8)
3/18/21 Reviewed email of opposing counsel RE: Raul Fernandez and DJ
Opportunities v. Opa-Locka, Case No. 2019 -035518 -CA -01 (.4)
3/18/21 Reviewed email of opposing counsel concerning hearing date RE: Case
No. 2021 -003264 -CA -01, DAVID P REINER, II vs City of Opa-Locka
(.2)
3/18/21 Research of case law on dismissal standards RE: Dade County Police
Benevolent Association v. City of Opa-Locka - Case 01-20-0014-5623
(1.5)
3/17/21 Review of Arbitration Brief RE: Dade County Police Benevolent
Association v. City of Opa-Locka - Case 01-20-0014-5623 (.5)
3/17/21 Preparation and revisions to Arbitration Brief RE: Dade County Police
Benevolent Association v. City of Opa-Locka - Case 01-20-0014-5623
(.4)
3/17/21 Attendance at Motion Calendar Hearing Re: Emergency Temporary
Restraining Order RE: Fernandez et. al. v City of Opa-Locka, Case No.
2019 -035518 -CA -01 (1.7)
3/17/21 Review of Plaintiff's Initial Disclosures Re: Yvette Harrell v. City of Opa-
Locka, Case No. 1:20-cv-21927-RKA (.8)
3/17/21 Review of Plaintiff's Certificate of Other Affiliates/Corporate Disclosure
Statement Re: Yvette Harrell v City of Opa-Locka, Case No. 1:20-cv-
21927-RKA (.4)
3/17/21 Review of Plaintiff's Notice of Appearance and Email Designation (Debra
Nolan) Re: Yvette Harrell v City of Opa-Locka, Case No. 1:20-cv-21927-
RKA (.2)
3/17/21 Review of Defendant's Motion for Judgment on the Pleadings Re: Yvette
Harrell v City of Opa-Locka, Case No. 1:20-cv-21927-RKA (.9)
3/17/21 Preparation of Settlement Report to City Commission RE: B&G Opa
Holdings, Inc. and B&G Opa Land Holdings, L.L.C. v. City of Opa-locka,
Florida, and Newall J. Daughtrey Case No.: 1:18-cv-23269-DPG (.8)
3/17/21 Review of Defendant's Answer and Affirmative Defenses to Amended
Complaint with Jury Demand filed by Jonathan Railey, Esq. Re: Yvette
Harrell v City of Opa-Locka, Case No. 1:20-cv-21927-RKA (1.5)
3/16/21 Meeting with A. Austin RE: Water Utilities Deposit matters RE: Raul
Fernandez and DJ Opportunities v. Opa-locka, Case No. 2019 -035518 -
CA -01 (.7)
3/16/21 Meeting with Human Resources on Ann Barnett (Complaint) RE: PBA
Negotiation, Case No, 2021 -003663 -CA -01 (1.4)
3/16/21 Preparation of draft Motion to Dismiss RE: Ann Barnett v. City of Opa-
locka, Case No, 2021 -003663 -CA -01 (2.5)
3/15/21 Reviewed relevant employment documents for preparation of draft Motion
to Dismiss RE: Ann Barnett v. City of Opa-Locka, Case No. 2021-
003663 -CA -01 (3.2)
3/12/21 Preparation of suggested edits for City's Opposition to Emergency Motion
for Temporary Restraining Order RE: Raul Fernandez and DJ
Opportunities v. Opa-locka, Case No. 2019 -035518 -CA -01 (.5)
3/12/21 Review and discussion of draft affidavit for inclusion in City's Opposition
to Emergency Motion for Temporary Restraining Order RE: Raul
Fernandez and DJ Opportunities v. Opa-locka, Case No. 2019 -035518 -
CA -01 (.7)
3/10/21 Review of Notice of Attorney Appearance by Jonathan Railey, Esq. on
behalf of the City of Opa-Locka RE: Yvette Harrell v City of Opa-Locka,
Case No. 1:20-cv-21927-RKA (.1)
3/10/21 Review of Notice of Attorney Appearance by Christopher J. Stearns, Jr.,
Esq. on behalf of the City of Opa-Locka RE: Yvette Harrell v City of Opa-
Locka, Case No. 1:20-cv-21927-RKA (.1)
3/9/21 Preparation and analysis of Amended Motion to Consolidate and
Opposition to Emergency Motion for Restraining Order RE: Fernandez et
al v City of Opa-Locka, Case No. 2019 -035518 -CA -01 (3.8)
3/9/21 Preparation and review of email from City Staff on status RE: North Park
(.2)
3/8/21 Meeting with Matthew Pigatt RE: Whistleblower cases in litigation,
Ambrose Obasi v. City of Opa-Locka; Case Number: 2019 -025994 -CA -
01; Thomas Marko v. City of Opa-locka, Case Number: 201-012846 -
CA -01; and Roy Stephen Shiver v. City of Opa-locka, et al, Case
Number: 2016 -013003 -CA -01 (.8)
3/8/21 Preparation of email to Mayor Pigatt RE: Existing Whistleblower
litigation cases and research of status RE: Ambrose Obasi v. City of Opa-
locka, Case Number: 2019 -025994 -CA -01; Thomas Marko v. City of
Opa-locka, Case Number: 201-012846 CA -01; and Roy Stephen Shiver v.
City of Opa-locka, et al, Case Number: 2016 -013003 -CA -01 (3.6)
3/8/21 Preparation of email to Opposing Counsel for re -scheduling of hearing
RE: David Reiner, II vs City of Opa-Locka, Case # Case No. 2021 -003264 -
CA -01 (.4)
3/8/21 Review of Notice of Hearing RE: Fernandez et. al. v City of Opa-Locka,
Case No. 2019 -035518 -CA -01 (.6)
3/7/21 Review and analysis of personnel file RE: Randolph Aikens (763 pages)
and preparation of HR questions RE: Arbitration matter (5.8)
3/5/21 Telephone conference with Esin Abia and James Greason RE:
Requirements of Settlement Agreement RE: Joseph Barton et al vs City of
Opa-locka, 2016 -011180 -CA -01 (.5)
3/6/21 Review and response to email from James Greason RE: Joseph Barton et
al vs City of Opa-Locka, 2016 -011180 -CA -01 (.4)
3/5/21 Preparation of email to American Arbitration Association Representative
on matters related to City's Response Brief RE: Dade County Police
Benevolent Association v. City of Opa-locka, Case 01-20-0014-5623 (.3)
3/5/21 Conferences with John Pate and officer for final draft of the City's closing
argument for arbitration RE: Jamesha McKinney (1.8)
3/5/21 Review of Settlement Agreement in administrative Arbitration case Bryant
Colebrooke v. City of Opa-Locka (.5)
3/4/21 Preparation of revisions to Arbitration Brief RE: Dade County Police
Benevolent Association v. City of Opa-Locka, Case No. 01-20-0014-5623
(.5)
3/3/21 Preparation of revisions to Arbitration Brief RE: Dade County Police
Benevolent Association v. City of Opa-Locka, Case No. 01-20-0014-5623
(3.4)
3/2/21 Telephone conference and review of email communication from League
attorneys on comments for Settlement Agreement RE: B & G Opa
Holdings, Inc., v. City of Opa-locka and Newall J. Daughtrey, Case No.
1:18-cv-23269-DPG (.8)
3/2/21 Preparation of email to Greg Gay and analysis RE: Legal description
matters needed for settlement RE: Joseph Barton et al vs City of Opa-
locka, 2016 -011180 -CA -01 (.8)
3/2/21 Review of Final Judgment of Foreclosure Order and communication with
code enforcement staff on release of lien matters RE: US Bank National
Association v. Kemp (foreclosure matter) Case No: 2-17-003383CA-01
(.4)
3/2/21 Coordination of information on Second Set of Interrogatories and 2°d Set
of Request for Production RE: United States Association of CDC v City of
Opa-Locka, Case No. 2016 -024089 -CA (3.9)
3/2/21 Review of letter from Attorney Hearn and searched file matters RE: North
Park School Settlement Agreement and allegations (.5)
3/1/21 Review of Notice of Hearing RE: Plaintiff's Motion for Entry of Final
Judgment on United States Association of CDC v City of Opa-Locka,
Case No. 2016 -024089 -CA -01 (.3)
Total Hours 92.8 @ $225.00
Total Professional Services: $20,880
Costs
Facsimile Expenses: $27.00
Copying Services: $639.75
Sylvia Evans Court Reporting $556.50
Courthouse Parking Costs: $N/C
Postage, FedEx and Courier Charges: $119.84
Court CaII Line: $N/C
Research Services: $73.96
COSTS=$1,417.05
TOTAL: $22,297.05
Law Office of
Burnadette Norris -Weeks, P.A.
401 N. Avenue of the Arts • Fort Lauderdale, Florida 33311
Phone (954) 768-9770 • Fax (954) 768-9790
INVOICE
CLIENT: CITY OF OPA-LOCKA - Litigation Cases February 1, 2021 through
February 28, 2021
Date ACTIVITY AND HOURS
2/26/21 Meeting with city staff on pump station project design and review of related
matters in preparation for trial and for additional deposition RE: United States
Association of CDC v City of Opa-Locka, Case No. 2016 -024089 -CA -01 (2.5)
2/26/21 Review and analysis of Proposed Order from Plaintiff and impact on remaining
count RE: United States Association of CDC v City of Opa-Locka, Case No.
2016 -024089 -CA -01 (.7)
2/26/21 Communication with Plaintiff's counsel RE: scheduling matters and disagreement
as to controlling law RE: United States Association of CDC v City of Opa-Locka,
Case No. 2016 -024089 -CA -01 (.5)
2/26/21 Review and analysis of Court Order on Motion to Release, Clerk and Disburse
Remaining Surplus Funds RE: Harvey Ruvin v City of Opa-Locka et al, Case No.
2020 -020629 -CA -01 (.3)
2/26/21 Review of Return and mail on Christopher Andrew Angell RE: JP Morgan Chase
Bank NA v Reliable Financial Enterprises Inc. et. al. search for legal address;
Case No. 2019 -003080 -CA -01 (.2)
2/25/21 Review of court file on issues of consolidation with Suarez Class Action for
strategy RE: Raul Fernandez and DJ Opportunities v. Opa-Locka; Case No. 2019-
035518 -CA -01 (.9)
2/25/21 Review of court file on issues of consolidation with Suarez Class Action for
strategy RE: Lakeview Ingram Park Apartments, LLC vs. Miami -Dade County et
al.; Case No. 2020 -008684 -CA -01 (.7)
2/24/21 Preparation of draft on request communication, including call, for extension of time
to respond to EEOC Complaint RE: Marilyn M. Chang v. City of Opa-Locka;
EEOC Case No.: 510-2021-02561 (.7)
2/24/21 Preparation and email / questions to Human Resources Director on EEOC portal
matters RE: Marrilyn M. Chang v. City of Opa-Locka; EEOC No.: 510-2021-02561
and questions (.4)
2/24/21 Participation in negotiation with opposing counsel on release of surplus funds
matter and follow-up RE: Harvey Ruvin v City of Opa-Locka et al, Case No.
2020 -020629 -CA -01 (.8)
2/24/21 Research and analysis on Plaintiff's Motion for Judgment to appeal to include
implied covenant of good faith and fair dealing count and allegation that express
term of the contract had been breached RE: United States Association of CDC v.
City of Opa-Locka (Case No.: 2016 -029089 -CA -01 (1.6)
2/24/21 Review and analysis of transcript on 4th Motion for Summary Judgment Hearing
RE: United States Association of CDC v. City of Opa-Locka, Case No. 2016-
024089 -CA -01 (1.3)
2/24/21 Review of Certificate of Mailing Re: JP Morgan Chase Bank NA v Reliable
Financial Enterprises Inc. et al, Case No. 2019 -003080 -CA -01 (N/C)
2/24/21 Review of Plaintiffs Motion to Stay Re: JP Morgan Chase Bank NA v Reliable
Financial Enterprises Inc. et al, Case No. 2019 -003080 -CA -01 (.2)
2/24/21 Review of Plaintiff's Motion to Disburse Court Regulated Monies RE: Harvey
Ruvin v City of Opa-Locka et al, Case No. 2020 -020629 -CA -01 (.2)
2/23/21 Research and Preparation of requested follow-up information for production to
Arbitrator Wolfson RE: Dade County PBA & Jamesha McKinney vs. City of Opa
Locka (1.5)
2/23/21 Review of Complaint and communications with City Manager for history RE:
Ann Barnett v. City of Opa-Locka Case No. 2021 -003663 -CA -01 (1.4)
2/23/21 Preparation and communication with Plaintiff's counsel RE: Whistleblower
process for City and complaint matters RE: Ann Barnett v. City of Opa-Locka
Case No. 2021 -003663 -CA -01 (.8)
2/23/21 Preparation and Attendance at Emergency Motion for Immediate Hearing filed by
Plaintiff on public records matter RE: David P Reiner, II vs City of Opa-Locka
Case No. 2021 -003264 -CA -01 (1.6)
2/22/21 Communication and Preparation of email to Judicial Assistant providing copy of
court requested transcript of (1/29/21) hearing on City's Fourth Motion for
Summary Judgment regarding United States Association of CDC v. City of Opa-
Locka (Case No. 2016 -029089 -CA -01) (.7)
2/22/21 Communication with Court Reporter on transcript matters in preparation of
Arbitration Brief RE: Dade County Police Benevolent Association v. City of Opa-
Locka - Case No. 01-20-0014-5623 (.4)
2/22/21 Review, analysis of proposed Final Judgment on six (6) counts of Complaint
granted for dismissal in favor of City of Opa-Locka RE: United States
Association of CDC v. City of Opa-Locka (Case No.: 2016 -029089 -CA -01) (.8)
2/22/21 Review of summons matters on whistleblower claim Re: Aikens v. City of Opa-
Locka Case No: 2021 -003184 -CA -01 (.2)
2/19/21 Initial discovery communications with Plaintiff's Counsel on records issues for
administrative arbitration RE: Dade County PBA / McKinney v. City of Opa-
Locka (.7)
2/19/21 Review of Complaint RE: Aikens v. City of Opa-Locka; Case No: 2021 -003184 -
CA -01 (.8)
2/19/21 Review and analysis of information from Greg Gay on parking / club plans for
settlement issues RE: B & G OPA HOLDINGS, INC. et. al. v. CITY OF OPA-
LOCKA, Case #18-23269-CIV (.8)
2/18/21 Review and docketing of Order resetting Hearing to 2/23/21 RE: David P. Reiner,
II, v. City of Opa-Locka Public Records matter CASE NO: 21-3264 CA -01 (.2)
2/18/21 Research, analysis and preparation of Arbitration Brief RE: Dade County Police
Benevolent Association v. City of Opa-Locka, Case No. 01-20-0014-5623 (3.8)
2/18/21 Preparation of email to City Manager RE: documents needed for Arbitrator RE:
Dade County Police Benevolent Association v. City of Opa-Locka, Case No. 01-
20-0014-5623 (.2)
2/18/21 Review of redacted information from D. Shaw Wilder in preparation for hearing
RE: David P. Reiner, II, v. City of Opa-Locka Public Records matter CASE NO:
21-3264 CA (01) (.8)
2/18/21 Research and review of 119 research on protection log matters RE: David P.
Reiner, II, v. City of Opa-Locka on log matters (1.2)
2/17/21 Review of Plaintiff's Motion for Entry of Judgment for legal analysis RE: United
States Association of CDC v City of Opa-Locka, Case No. 2016 -024089 -CA -01
(1.3)
2/17/21 Telephone conference on Parking Agreement matters with Plaintiff's attorney and
John Pate RE: RE: B & G OPA HOLDINGS, INC. et. al. v. CITY OF OPA-
LOCKA, Case #18-23269-CIV (.4)
2/17/21 Communication on Shared Parking Agreement matters with City Manager to
preparation for call RE: Parking matters for settlement RE: B & G OPA
HOLDINGS, INC. et. al. v. CITY OF OPA-LOCKA, Case #18-23269-CIV (.7)
2/17/21 Preparation and Review of Shared Parking Agreement matters with League counsel
RE: Parking matters for settlement RE: B & G OPA HOLDINGS, INC. et. al. v.
CITY OF OPA-LOCKA, Case #18-23269-CIV (1.0)
2/17/21 Telephone conference with City Manager on requested documents for Arbitrator
RE: Dade County Police Benevolent Association v. City of Opa-Locka, Case No.
01-20-0014-5623 (.5)
2/17/21 Review of Notice of Readiness for Trial RE: Deutsche Bank National Trust
Company v Gonzalez, Case No. 2018 -018368 -CA -01 (.2)
2/16/21 Review of notes from PBA meeting and attended negotiations with PBA attorney
and John Pate; Summarized notes and drafted email in furtherance of negotiations
with team members for impact of future arbitration hearing and arbitration
selection procedures (N/C)
2/16/21 File review of water case and communications with City Staff on litigation
strategy RE: Ingram Park Apartments, LLC v Miami -Dade County and the City
of Opa-Locka, Case No. 2020 -008684 -CA -01 (.7)
2/16/21 File review of water case and communications with City Staff on litigation
strategy Raul Fernandez, DJ Opportunities v Miami Dade County and the City of
Opa-Locka, Case No. 2019 -035518 -CA -01 (.8)
2/16/21 File review of water case and communications with City Staff on litigation
strategy Lakeview Apts, LLC and L.L.C. Lakeview Apts vs Miami -Dade County
and the City of Opa-Locka, Case No. 20 -001124 -CA -01 (.6)
2/16/21 File review of water case and communications with City Staff on litigation
strategy Opa-Locka Warehouse Condominium Association, Inc. v. City of Opa-
Locka, Case No. 2018 -002828 -CA -01 (.6)
2/16/21 File review of water case and communications with City Staff on litigation strategy
GFM Operations, Inc. v. City of Opa-Locka, Case No. 2016 -026601 -CA -01 (.6)
2/14/21 Review of union public record requests for discussion with union on supervisory
status RE: Randolph Aikens administrative hearing (.4)
2/12/21 Telephone conference with opposing counsel regarding discovery timelines and
administrative hearing Re: Officer Jamesha McKinney (.6)
2/12/21 Reviewed of arbitration notes and research in preparation for City's closing
written argument and analysis of same RE: Officer Jamesha McKinney (4.3)
2/11/21 Review of FWOP Notice dated 5/17/2021 RE: JP Morgan Chase Bank NA v
Reliable Financial Enterprises Inc. et al. Case No. 2019 -003080 -CA -01 (.2)
2/11/21 Review of court documents and docket in preparation for response to Plaintiff's
Motion for Temporary Restraining Order RE: Raul Fernandez and DJ
Opportunities v. City of Opa-Locka, Case No. 2019 -035518 -CA -01 (1.5)
2/11/21 Preparation of email on Director of Public Works matters concerning affidavit for
City's Motion for Summary Judgment and follow-up RE: United States Association
of CDC v. City of Opa-Locka (Case No. 2016 -029089 -CA -01) (.7)
2/9/21 Review of B & G Agreement with City and file and preparation of strikethrough
comments RE: B & G OPA HOLDINGS, INC. et. al. v. CITY OF OPA-LOCKA,
Case #18-23269-CIV (3.4)
2/9/21 Review of Notice of Filing Affidavit as to fees RE: Deutsche Bank National Trust
Company v Gonzalez, Case No. 2018 -018368 -CA -01 (.3)
2/8/21 Meeting with Mayor Pigatt for case review of settlement matters RE: B & G OPA
HOLDINGS, INC. et. al. v. CITY OF OPA-LOCKA, Case #18-23269-CIV (2.6)
2/8/21 Preparation for Meeting with Mayor Pigatt for case review of settlement matters
RE: B & G OPA HOLDINGS, INC. et. al. v. CITY OF OPA-LOCKA, Case #18-
23269-CIV (.5)
2/8/21 Review of Court Order on City of Opa-Locka's Fourth Motion for Summary
Judgment RE: United States Association of CDC v City of Opa-Locka, Case No.
2016 -024089 -CA -01 (.4)
2/8/21 Review of Service Returned for Virginia Pellot, Motion for Default by Clerk,
Non-military Service Affidavit RE: Harvey Ruvin v City of Opa-Locka et al,
Case No. 2020 -020629 -CA -01 (.3)
2/5/21 Review of documents in response to Request for Production for coordination of
documents RE: James Dobson v. City of Opa-Locka (Case No. 2020 -018694 -CA -
01) (1.0)
2/5/21 Preparation of email to outside counsel in response to documents for Request for
Production RE: James Dobson v. City of Opa-Locka (Case No. 2020 -018694 -CA -
01 (.4)
2/5/21 Review of Service Returned RE: Harvey Ruvin v City of Opa-Locka et al, Case
No. 2020 -020629 -CA -01 (.2)
2/4/21 Review and analysis of Settlement Agreement on EEOC Administrative Action
RE: City of Opa-Locka and Michael Steel, EEOC Case No. 510- 2020-01823C
(1.4)
2/4/21 Review of Notice of Filing of Affidavit as to Time, Effort and Costs (N/C)
2/3/21 Review and analysis of information needed for affidavit and discovery (Request
for Production) RE: United States Association of CDC Inc. v City of Opa-Locka
RE: Case No. 2016 -024089 -CA -01 (.6)
2/3/21 Review of discovery information from Plaintiff's counsel and coordination of
responses regarding Request for Production RE: United States Association of CDC
Inc. v City of Opa-Locka; Case No. 2016 -024089 -CA -01 (2.5)
2/2/21
2/2/21
2/1/21
2/1/21
Preparation / Attendance at Special Set Hearing RE: United States Association of
CDC v City of Opa-Locka, Case No. 2016 -024089 -CA -01 (1.5)
Review of Amended Notice of Hearing RE: Deutsche Bank National Trust
Company v Gonzalez, Case No. 2018 -018368 -CA -01 (.4)
Review of Amended Witness List RE: Deutsche Bank National Trust Company v
Gonzalez, Case No. 2018 -018368 -CA -01 (.3)
Review of 3rd public records request with administrative review RE: Kuehne
Davis Law PRR on Jafet Castro (N/C)
Total Hours 57.8 (a, $225.00
Total Professional Services: $ 13,005.00
Costs
Facsimile Expenses: $8.00
Copying Services: $654.50
Sylvia Evans Court Reporting $556.50
Courthouse Parking Costs: $27.00
Postage, Courier and FedEx Charges: $176.39
Court Ca11 Line: $0.00
Research Services: $54.19
COSTS=$920.08
TOTAL: $13,925.08