HomeMy Public PortalAbout2016-12-16 AttorneyClient Bal Harbour Shops v BHV and Patricia Cohen CASE 16-18499CA091
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BAL HARBO UR VILLAGE
AT TORNEY/CLIENT SESSION
IN THE MATTER OF BAL HARBOUR SHOPS, LLC v.
15 BAL HARBOUR VILLAGE and PATRICIA COHEN
16 CASE NUMB ER: 16-18499 CA 09
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BAL HARBO UR VILLAGE HALL
655 96th STREET
BAL HARBOUR, FLORIDA 33154
FRIDAY, DECEMBER 16, 2016
8:49 a.rn. -9:25 a.m.
Taken before Mary G. Stephenson, FPR, Notary
Public for the State of Florida
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1 APPEARANCES:
2 CO UNCILMEM BERS:
3 GABRIEL GROISMAN, MAYOR
SETH E. SALVER, ASSISTANT MAYOR
4 DAVID ALBAUM, COUNCILMAN
PATRICIA COHEN, COUNCILWOMAN
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JE fFREY FREIMARK, COUNCILMAN
VILLAGE MANAGER:
JORGE M. GONZAL EZ
VILLAGE AT TORNEY:
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WEISS SEROTA HE LFM AN
PASTORIZA COLE & BONISKE, P.A.
BY: RICHARD JAY WEISS, ESQ.
JOSEPH SEROTA, ESQ.
SUSAN TREVARTHEN, ESQ.
JUSTIN LUGER, ESQ.
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Thereupon, the following proceedings were had:
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MAYOR GROISMAN: The door is open. There
is nobody outside.
order.
I am going to now call the next meeting to
The time is now 8:49 a.m.
Let's do another roll call.
MR. GONZALEZ: I'll do it.
MAYOR GROISMAN: Go ahead.
MR. GONZALEZ: Mayor Groisman.
MAYOR GROI SMAN : Here.
MR. GONZALEZ: Assistant Mayor Salver.
ASSISTANT MAYOR SALVER: Here.
MR. GONZALEZ: Councilwoman Cohen.
COUNCILWOMAN COHEN: Here.
MR. GONZALEZ: Councilman David Albaum.
COUNCILMAN ALBAUM: Here.
MR. GONZALEZ: Councilman Jeff Freimark.
COUNCILMAN FREIMARK: Here.
MR. GONZALEZ: Council is present.
MAYOR GROISMAN: Thank you. The time, as I
said, is 8:49 a.m. We are about to have --
MR. WEISS: Did you mention our names?
MR. GONZALEZ: Not in roll call.
MAYOR GROISMAN: We are about to have an
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attorney/client session in accordance with Florida
Statute 286.011 regarding the litigation styled
Bal Harbour Shops, LLC versus Bal Harbour Village
and Patricia Cohen, Case Number 16-18499 CA 09.
The session is estimated to last 30 minutes
and the following people will be in attendance at
this meeting: Myself, Mayor Groisman, Assistant
Mayor Salver, Councilmember Freimark,
Councilmember Albaum, Councilmember Cohen, Village
Manager Jorge Gonzalez, Village Attorneys Richard
Weiss, Joe Serota, Susan Trevarthen and Justin
Luger.
These proceedings be recorded by a
certified court reporter and, at the conclusion of
all litigation discussed, the transcript will be
made part of the public record.
All those individuals who I have not named
should leave this room at this time. Since there
is no one else in this room, we will close the
door and start the meeting.
So what I ask, let's not rehash things.
Let's focus, please, on this specific case.
MS. TREVARTH EN: Understood. Let me give a
brief overview of what this second case is about.
It's an action for declaratory injunctive relief
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as well as mandamus relief, and it's asserted
against Councilwoman Cohen as well as against the
village.
It asserts that Councilwoman Cohen should
be precluded from voting on matters relating to
the expansion of the shops because of an alleged
conflict of interest that violates the Miami-Dade
County Code of ethics.
The complaint also asserts that then Mayor
Packer and Councilmember Cohen violated the
Sunshine law by engaging in alleged secret
conversations while on the dais during the shops'
hearing on its request to have the village hall
sold to the shops as per their expansion claim.
That was the vote back in April of 2016.
The last thing that the complaint seeks is
to compel the village to participate in the
FLUEDRA proceedings. That is the Florida Land Use
and Environmental Dispute Resolution Act. That is
also part of the other case we talked about last
week.
They seek to compel our participation in
the proceedings in connection with that decision
not to sell village hall .
They also seek to invalidate the votes of
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Councilmember Cohen and Mayor Packer at that
meeting where we had the two two vote not to sell
village hall.
That is the shortest summary of what this
case involves.
In terms of where we are procedurally,
there has been a little bit of depositions and
discovery going on. There is a pending motion to
dismiss that is set for hearing, I believe it is
January 17th.
MAYOR GROISMAN: Is that to dismiss
everything?
MS. TREVARTHEN: Yes. We filed a motion to
dismiss. We have arguments that everything should
be dismissed on various grounds.
Also, Councilwoman Cohen's attorney filed
something as it relates to the claims that were
asserted against her personally.
MAYOR GROISMAN: What depositions were
taken?
MS. TREVAR THEN: I am trying to remember.
I didn't take a list with me. I just looked
through the pleadings to see what we have done so
far.
COUNCILWOMAN COHEN: I didn't have a
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deposition on that.
MS. TREVARTHEN: No? Maybe not.
MAYOR GROISMAN: Can we just get an update
from Jorge because at the last meeting we asked
MS. TREVARTHEN: Basically, it's holding.
MAYOR GROISMAN: We asked Jorge to go speak
to shops and see how, at least, the FLUEDRA
portion of this --
MS. TREVARTHEN: It's the landscaper. I
think that is what I saw.
MAYOR GROISMAN: The FLUEDRA portion of
this, which is the administrative action, which is
garbage, really, to see if they would drop, to see
if we can get them to drop.
COUNCI LWOMAN COHEN: Excuse me. Can I just
mention they harassed my landscape installer, who,
unfortunately, had done work for Brooks over here
in the gated community, my ex-home. Literally,
this guy doesn't even want to work for me anymore.
So at the end we are going to have to be dealing
with the damage that this has done to my
profession.
He had nothing. He was a Cuban installer.
For hours he was there trying to see what they can
whip up against him.
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MAYOR GROISMAN: Okay. Jorge.
MR. GONZALEZ: So as you mentioned at the
last meeting, you instructed me to go and reach
out and see if there was an interest or
willingness before we go forward in the process.
Generally, the response was that at this
time, they were not prepared to unilaterally
settle something like that. They did not want to
attach it to any actions that we would take. They
are also apparently reviewing or reconsidering or
revising the plan that they are working on for our
consideration if they want to submit something,
but they were not inclined to drop the cases just
as a gesture of good faith or goodwill.
COUNCILWOMAN COHEN: Correct, and they are
so delusional that they sent us an e-mail
yesterday, that I got to hear about last night, I
was doing something else, where they want meetings
with us.
We have 50 people come to this council
meeting and scream at our faces, not you two, but
before. You should not be negotiating with this
entity who are suing us, who are harassing us.
COUNCILMAN ALBAUM: You are represented by
the same firm on this case; is that correct?
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COUNCILWOMAN COHEN: Yes. Now he has filed
a motion.
COUNC ILMAN ALBAUM: So we are not dealing
with different attorneys?
COUNCILWOMAN COHEN: No, no.
MR. GONZALEZ: The same one.
MAYOR GROISMAN: And the fees to date on
this one?
COUNCILMAN ALBAUM: It's 50,000?
MR. GONZALEZ: No. On that one is 132.
MAYOR GROISMAN: For how long?
MR. GONZALEZ: Basically, I got bills in
August. Maybe started in July sometim~ frame.
July, August, September, October.
COUNCILMAN ALBAUM: Five months?
MAYOR GROISMAN: Four months.
MR. GONZALEZ: Four months or so. That is
how
COUNCILMAN ALBAUM: There is a lot of
production that is going to be involved in this
case too?
COU NC ILWOM AN COHEN: It's five months.
COUNCILMAN ALBAUM: I mean going forward.
MAYOR GRO I SMAN: There's no document
production.
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COUNCILMAN ALBAUM: It's depositions?
MR. GONZALEZ: Councilwoman Cohen was
saying her concern about what else is corning down
the line.
That e-mail thing may be whittling down,
only to have this part of it ramp up.
MR. WEISS: I think they were only
interested --in the public records case what we
discussed, they are only allowed to get public
records. So they are not allowed to get her
private business records of her business. I think
one of the reasons they filed the second case
alleging a conflict of interest, because that
allows them to go into her private business to see
whether she has had s ome private business dealings
with whoever they think is the --
COUNCILMAN ALBAUM: So you think the fees
are going to escalate on this case too? Is that
your feeling, Richard, or not?
MR. WEISS: My feeling, I do talk to them
from time to time, but, listen, I will go talk to
them on both accounts. I don't feel that they are
inclined just to --I think they are in this for
the long haul.
MR. GONZALEZ: Yes.
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MR. WEISS: The shops.
COUNCILMAN ALBAUM: So you think this could
be another?
MR. WEISS: Yes.
MAYOR GRO I SMAN: Let rne just interject on
this case just to give my comments on it.
First of all, the lawsuit, what they are
asking for I think is a huge overreach both on the
personal stuff and on the FL UED RA stuff, which is
really, really, I think, overreach and I think it
will be dismissed on that issue of conflict. With
Sunshine Law, they have other ave nu es if they
really were genuinely concerned about it to go
after instead of filing a lawsuit.
COUNCILWOMAN COHEN: They should have gone
to the ethics committee.
MAYOR GROISMAN: The ethics committee, that
is sort of the normal course of action. Whether
it's right of wrong, they decide. It's quick.
It's inexpensive.
MS. T REVARTHE N : And our argument is it's
the only one available and we think the law
supports that.
MAYOR GROISMAN: Okay. So that is great.
So there is a chance this thing is going to get
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dismissed early on with that.
Lawyers, including me, hate giving
percentages, but how do you view our chances on
the motion to dismiss?
MS. TREVARTHEN: I am not good on
percentages, but I think we feel like we have
strong arguments here.
I mean, just as an example, FLUEDRA on its
face says once you file litigation, you waive your
rights under FLUEDRA. And it only deals with land
development decisions. This is a legislative
decision to sell property. These are large
differences.
So I think as compared to the wide range of
litigation, our chances are better than --
MR. GONZALEZ: The city's chances, but they
are not going to stop with --
MR. SEROTA: I believe Ms. Cohen's attorney
has also filed a motion to dismiss.
MS. TREVARTHEN: Yes, and it tracks our
arguments. Part of what they were arguing is that
we didn't have a role in that, that we didn't have
standing. Yet, the target of that case is her
official action in voting. So we were found to
have the standing to defend that claim as well.
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MR. GONZALEZ: I was trying to highlight
it's the action, but it's also the alleged
violation of Sunshine and the alleged bias and all
that other stuff that will remain and they are
going to keep --I would expect, as Richard, I
agree with Richard. They are going to keep trying
to do whatever they want.
MS. TREVARTHEN: I agree with the
motivation. It's January 17th, I believe.
ASSISTANT MAYOR SALVER: How quick does the
judge rule on those?
MS. TREVARTHEN: On the motion to dismiss,
we hope so, but he could hold it in advisement and
he could wait.
It's Judge Gerald Bagley I believe.
COUNCILMAN ALBAUM: I would like to just go
on the record.
MR. WEISS: I really think just to go out
on a limb here, all of this needs to be resolved
holistically, all of it.
MS. TREVARTHEN: I agree.
COUNCILMAN FREIMARK: That was going to be
my question, and I want to be sure I ask that
question at the right point in time in the
discussion.
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MR. WEISS: You did.
COUNCILMAN FREIMARK: In that given the
various matters that are in action at this point
in time, how do we approach this from a holistic
perspective without compromising any of the
individual discussions.
MAYOR GROISMAN : Just to interject,
Ms. Cohen, you said you don't want to sit down
with them, negotiating with terrorists or
whatever. I understand the feeling of it, but
there is no need to make deals with people you
agree with, or people you disagree with because
those are people you have conflicts with.
I think it does do all of us and you
personally probably more than anybody to sit down
and reach a resolution. Not one in which you
recuse yourself. I think that is ridiculous.
COUNCILWOMAN COHEN: But reach a resolution
by going to the meeting? Is that what you are
saying?
MAYOR GROISMAN: Going to what meeting? To
have a private meeting, settlement meeting?
COUNCILWOMAN COHEN: Yes.
MAYOR GRO ISMAN: Yes. Why not?
COUNCILWOMAN COHEN: That is not what they
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wrote. I thought it was about to talk about their
project. It doesn't say resolution at all on the
e-mail, not at all.
It says, we would like to meet with each of
you individually. I did not read into i t that it
was anything litigation related. Not at all. I
thought it was to talk about the future.
MR. GONZALEZ: I think you are probably
right. It's the shops.
COUNCILWOMAN COHEN: Of course, of course.
I don't think they would do that. They would say,
bring an attorney, whatever. They didn't mention
any of that.
MR. WEISS: Ultimately, they are not into
random sparring here. They are trying to get
their project approved. That is what this is
about.
COUNCILMAN ALBAUM: And I would like to
say, as long as Patricia or anybody here is on the
council, you have a right to vote on everything.
COUNCILWOMAN COHEN: Obviously, but --
COUNCILMAN ALBAUM: No, no, but I mean that
is just where I stand. You are a member. You are
here, and you are going to vote.
COUNCILWOMAN COHEN: Let's go back to what
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they are trying --
COUNCILMAN ALBAUM: I just want to say
that.
COUNC I LWOMAN COHEN: The platform here is
we are the legislators. We have a right to vote
the way we want to. They are disputing my vote.
This is what is at hand here.
In the meantime, they still want to meet
with us before next council meeting. That is what
I read last night. None of you got it?
COUNCILMAN ALBAUM: On the 20th? We are
talking about Tuesday?
COUNCILWOMAN COHEN: Yes.
MAYOR GROISMAN: Maybe they sent you an
e-mail.
COUNCILWOMAN COHEN: So you think it's old
that e-mail?
COUNCILMAN FREIMARK: I didn't get an
e-mail but they did reach out.
MAYOR GROISMAN: Let's focus the
discussion. The Ball Harbour Village was sued
here not just by name specifically as was
Ms. Cohen.
My question to Susan is: Are the
interests, legally speaking, with Bal Harbour
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Village and Patricia Cohen aligned here or is
there a conflict?
MS. TR EVART HE N: I don't think there is a
conflict per se. I think the issues that we have
raised go to the jurisdiction to even bring this
claim, which is not something where there is going
to be a conflict of interest.
There is the factual matter of whether
there was, in fact, a violation of the Sunshine
Law, but we have also addressed that in our motion
to dismiss, that the available evidence that they
cite in their complaint falls far short of even
trying to establish. It's one way communication.
MR. WEISS: The answer to your question
really is what your perspective is on this
project, I hate to say.
If the council, its members are in favor of
approving some form of a big shop expansion, then
the truth is that then you want their lawsuits to
succeed. You want the Sunshine --I mean, there
is an issue here because the council has not made
any kind of formal declaration as to how it feels
on any plan, but that is what this is all about.
MAYOR GRO I SMAN: I disagree with you. The
reason I disagree with you, Richard, if there is
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someone on the council that is generally not
against a type of shop expansion, that doesn't
have to be at the expense of an improper lawsuit
or the crucifixion, to use a terrible word --
COUNCILWOMAN COHEN: It is crucifixion.
MAYOR GROISMAN: of a specific person.
Maybe that is how the shops or the people
from the outside should look at it, but I urge all
of us not to look at it like that no matter what
our position. They should be separate things.
COUNCILMAN ALBAUM: Exactly.
MAYOR GROISMAN: If you are for the type of
expansion, whatever, they don't have an
application now. So we don't even know what they
would be offering. Even if you are for what they
are offering, it shouldn't be at the expense of
another member of the council.
COUNCILWOMAN COHEN: I think most people
would tend to agree with you. It's been a year or
more and we haven't had one person come up here to
this dais and I agree with the shops, I think that
Mrs. Cohen has erred. There is not one single
person. How come?
MAYOR GROISMAN: So what I was trying to
focus in discussion --
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COUNCILWOMAN COHEN: I think that is pretty
much understood.
MAYO R GROISMAN: What I am trying to focus
the discussion on is have we been working with
Kent, the attorney's name
MS. TREVARTHEN: Yes.
MAYOR GROISMAN: --on this matter?
MR. WEISS: Yes.
MAYOR GROISMAN: Have we been coordinating
our efforts?
MR. WEISS: Yes.
MAYOR GROISMAN: Because what I don't want
to happen is --
MR. WEISS: We have been doing the work.
COUNCILWOMAN COHEN: It's litigation,
redundancy.
MS. TREVAR THEN: On this one, we went first
and then they filed one that was along the lines
of what we filed.
MAYOR GROISMAN: If all he has done is file
a motion to dismiss, how have we been billed
100,000?
ASSISTANT MAYOR SALVER: That is what I'm
trying to figure out.
MAYOR GROISMAN: Because a motion to
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dismiss in state court shouldn't cost more than --
COUNCILWOMAN COHEN: He has been doing most
of the work.
MAYOR GROISMAN: They just said the
opposite. That is what I'm trying to understand.
MS. TREVARTHEN: Well, we filed the motion
to dismiss first, but there was this, and I
personally wasn't involved, so I don't have all
the details, but the deposition of your landscape
person and some fighting over that, that I think
your attorney has taken the lead on.
MAYOR GROISMAN: So without going
backwards, I would like to hear from staff. I
don 1 t want to direct Richard on this at all, but
to the extent that Richard is going to speak with
Kent on the fee issue, which I think should also
be a whole discussion about this, but as far as
direction goes, like we said on the other one, the
direction was let's focus on settlement. This
one, the focus, I think, should be on allowing for
him to piggyback on the work of Weiss Serota.
Anything he needs to interject for you,
Patricia, he should do it and he knows how to do
it. He can file a motion if he disagrees with the
other motions that were filed and then you just
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add your arguments. There is ways to do that, so
that way we are not paying twice for the same
thing.
Can I hear thoughts on that?
COUNCILWOMAN COHEN: Well, nobody is
advocating for redundancy in fees . I think you
should take the time to read the time sheets and
see what they did and what he did. I doubt that
there is redundancy.
MAYOR GROISMAN: I'm not looking backwards,
but what I am saying is we are agreeing on the
same thing, but lawyers work at the direction of
their clients. So if the client doesn't say
anything and they want to bill the time, they are
doing all the work, and they are getting paid
anyway. If the client tells you, I want you to
just try as much as possible to piggyback on this
defendant's work, he will do it.
Of course, he still has a legal obligation
to defend you a hundred percent. So it's not that
you are going to lose anywhere on that subject.
I don't think you are disagreeing. I don't
want to focus on what he did before because it
doesn't do anything for us. Let's just focus on
moving forward.
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Does anyone else want to say anything?
COUNCILMAN FREIMARK: So we had the fees
before and this is for Patricia's attorney,
correct?
MAYOR GROISMAN: Yes.
COUNCILMAN FREIMARK: What are our
arrangements with Weiss Serota?
MR. WEISS: We get paid hourly. I think
235 an hour.
COUNCILWOMAN COHEN: For all of them. For
all the specialists that you use.
MS. TREVART HEN: It's a blended rate for
all the work we do for the village.
MR. WEISS: It's a blended rate. We don't
charge for phone calls. We don't charge for
attendance for any of the council meetings.
COUNCILMAN FREIMARK: So the costs that we
heard are increased by a factor X, whatever that X
is.
MAYOR GROISMAN: Correct.
COUNCILMAN FREIMARK: How do we bring this
to an overall solution?
MR. WEI SS: That is really where I was sort
of going. I mean, the shops want some application
heard. They want the item on the ballot so the
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voters can vote on selling. I don't even know if
the village hall is involved any more. Whatever
it is they want to do, and I think that as part of
the development agreement, you settle all this
stuff and say, go away, we are going to put your,
you know, and that was sort of where we were going
last time, and you thought that you didn't really
want to make a deal like that. So Jorge asked
would they do it unilaterally, but that didn't
work.
COUNCILMAN FREIMARK: Okay. Also then in
the context of all this, how does the petition
potentially impact on this?
MR. WEISS: Well, that is a good question.
COUNCILMAN FR E IM ARK: And is this the
appropriate time to ask that question?
MR. WEISS: There is two separate
petitions.
COUNCILMAN FREIMARK: Right. I'm
questioning the 60 percent. Go ahead. Sorry.
MR. WEISS: The 60 percent, and then there
is one that deals with retail and commercial.
The petitions that were filed, we sent it
to the Dade County supervisor of elections and he
noticed that in one of the petitions, the
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commercial and retail, that their different --
same petition had different wording. Some used
retail, some used retail and commercial. So that
sort of ran around.
In the meantime, I had to wait. I think he
forwarded it. In the meantime, Shubin has --I
wrote a letter saying he has legal concerns about
the substance of the petitions, one, and also the
procedure that was used, number two. We sent the
letter to J.C. Planas, who represents the
petitioners, for his comment, and I was hoping he
would send us back a letter saying, I disagree
with John for this reason, but he didn't.
So our recommendation is going to be on
those petitions, so either way
MR. GONZALEZ: He has this item on the
agenda as a discussion.
MR. WEISS: Either way, this item is
getting settled in court. If we put it on the
ballot, the shops are going to sue us. If it
doesn't go on the ballot, J.C. Planas will sue us.
So our strategy we are going to recommend
to you is that we have these two parties fighting
over language in the petition, whether it's even
legal, the petition, the format they have used.
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We think the least expensive way for the village
to sort of get out of this is to file a
declaratory judgment and then just back off of it.
Basically saying to the court, we have lawyers
here that say it's good, and we have lawyers there
that say it's not properly done.
One of the things that has happened here in
the past is that the residents expect the village
to end up being a judge like the ownership of the
residential area.
It's not a great scenario for us. So that
is the least expensive way, and then let John
Shubin and J .C. Planas go fight this thing out in
circuit court. At some point, some judge will
say, J.C. Planas, you are correct and the issue go
into ballot or some mixture of that. That is our
thoughts.
MR. SEROTA: This is all tied into this
other lawsuit. That is really what we are talking
about.
COUNCILWOMAN COHEN: Correct.
MR. SEROTA: It is all related.
ASSISTANT MAY OR SALVER: One at a time.
MAYOR GROISMAN: Let's let Jeff finish his
comments.
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COUNCILMAN FREIMARK: So bringing us back
to this, looking at it from the perspective of
trying to get to a holistic settlement, the shops
have got to be thinking that this is a risk
element to the extent that village hall may be
involved in a potential expansion and transaction.
This is a risk element and potentially raising the
risk from 50 percent to 60 percent.
MR. WEISS: Yes.
COUNCILMAN FREIMARK: So does that help in
your view relative to getting, and plus time has
just flown by on this.
MR. WEISS: We have gotten different
indications that they may be redoing their plan.
I don't know what the plan is. I don't know
whether it includes village hall or doesn't
include village hall.
MR. GONZALEZ: But to your question, in
their minds and, of course, it creates a
difficult, a higher threshold by which any plan
that they want to do might be applied.
MAYOR GRO I SMAN: Seth wanted to say
something.
ASSISTANT MAYOR SALVER: Richard, your
comments, I only understood you were referring to
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the case about the commercial
MR. WEISS: There's two petitions.
ASSISTANT MAYOR SALVER: So are we going to
do declaratory judgment for both?
MR. WEISS: Both, because they have both
been challenged.
ASSISTANT MAYOR SALVER: Oh, they have.
COUNCILWOMAN COHEN: But in the meantime,
where does that put us? We can go ahead and
ignore this and go ahead and proceed towards
MR. WEISS: Until the court decides. We
are going to end up in court on this anyway.
COUNCILWOMAN COHEN: Talking about
holistic --
ASSISTANT MAYOR SALVER: Are we able to
just throw a hot potato to circuit court?
MR. GONZALEZ: Hold on. One at a time.
COUNCILWOMAN COHEN: A reassessment of the
market conditions and realized perhaps what they
have in mind, the wishful thinking that they have,
it's not that valuable given today's commercial.
I'm praying and hoping that they will
reassess, they will regroup. You know, we all
need to evolve with the times.
MAYOR GROISMAN: Seth, were you --
- -_________________ ___,
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COUNCILWOMAN COHEN: The market has
changed.
MAYOR GROISMAN: Seth, go ahead.
ASSISTANT MAYOR SALVER: So we can just lob
the hot potato to the court and then not have any
more fees or anything like that?
MR. WEISS: We are going to draft language,
which, according Joe, the speech or effort is not
going to be a lot. Nothing to distract the
complaint. We are going to attach these two
letters.
I drafted an e-mail for Dwight to send to
J .C. Planas saying, we got your letter, but we are
very interested in your substantive thoughts about
the issue you raised. I want to attach that to
our lawsuit, so we have both letters and then we
will have to do a little bit
ASSISTANT MAYOR SALVER: What is the style
of the case? Bal Harbour Shops versus?
MR. WEISS: Bal Harbour Shops versus both
of them.
MR. GON ZALEZ: Bal Harbour Village.
MR. WEISS: Bal Harbour Village versus both
of them.
MAYOR GROISMAN: So on this case, it
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doesn't sound like there is anything to talk about
as far as holistic approaches other than if their
position is Patricia needs to recuse herself, and
that is not changing. There is not much to
discuss.
If their position is anything other than
that, that is not on the table. If they take that
off the table, then we should always be open to
have another discussion as to what it is they are
looking for to resolve it, but it shouldn't
include a recusal of any member of the council.
COUNCILMAN FREIMARK: But that is a relief
they seek.
MAYOR GROISMAN: We are talking about just
focusing for a moment on the resolution.
So the only other topic is fees, right?
COUNCILMAN ALBAUM: Exactly.
MAYOR GROISMAN: If it's fees, I would like
to just have a discussion on fees, not on other
issues.
My proposal is just when Richard speaks to
the attorney to just try to direct him to try to
piggyback his time on Weiss Serota's.
COUNCILWOMAN COHEN: Haven't you been doing
that? Haven't you guys been controlling all
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along.
MAYOR GROISMAN: It se ems like it has
shifted to that. So let's do that, and make the
discussion. When we are talking about, the
overall fee structure, it should involve
everything.
MR. GONZALEZ: Just to give you good
clearance, their guidance is, is this notion of a
cap to be for both cases or just the cap
discussion about the first one?
ASSISTANT MAYOR SALVER: Specially if this
case is a public records case, we don't want to
resolve that one and then all of a sudden --
COUNCILMAN ALBAUM: That is why I was
treating them separate.
MR. GONZALEZ: You need clearance.
MS. TREVARTHEN: We get it.
MR. SEROTA: So you are seeking a cap on
both cases.
This case, by the way, to answer the
mayor's question early on, we are not in conflict.
We have different interests, but we are not in
conflict. In other words, I mean --
MAYOR GROISMAN: So we can work together
and Kent should focus on Patricia's specific
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issues to make sure she is one hundred percent
covered, and the issues that are for both, he can
make sure that he is content with what Weiss
Serota is doing and supplement where he feels
necessary, but I would rather have --
MR. WEISS: I think that is what we need to
do.
COUNCILWOMAN COHEN: Yes.
MAYOR GRO I SMAN: That is good. So maybe
the only direction is when you talk about fees, it
should be about both cases. It's pretty simple.
ASSISTANT MAYOR SALVER: Before we adjourn
this, back to what Councilman Freimark was saying
with approaching this holistically and seeing kind
of like looking at trying to see what is going to
happen in the future and see what the shops'
interest might be changing in light of this
petition, if we can kind of make them an offer
where we would hear this new application within a
certain timeline, maybe they would be more
inclined to drop something.
COUNCI LMAN ALBAUM: They can just apply
anytime, right, Jorge?
MR. GONZALEZ: Yes, they can apply anytime.
My expectation is they are reaching out to
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you guys, I don't know how many of you maybe have
scheduled meetings or not meetings.
MAYOR GROISMAN: Next week, I have a
meeting with them.
MR. GONZALEZ: All of these things, I
think, is in advance of them coming and saying
something on Tuesday.
COUNCILWOMAN COHEN: About what? Not about
the lawsuit?
MR. GONZAL EZ: No, no, no, no, no.
COUNCILWOMAN COHEN: This is a slap in the
face. You guys continue to give them, oh, yes,
yes, you are a valid applicant.
It should be, no, we don't talk to you
until we resolve our legal issues.
In the private sector, you do that.
MAYOR GROISMAN: I know, but we are not in
the private sector.
I think if that is our position as a
village, and we have to be careful now, because
this is another thing, but just to say
specifically or carefully if that is our position,
it needs to be our official position as a
resolution or ordinance across the board.
We can't deal with specific applicants in
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one way. If we have a blanket ban on considering
applications because they are in lawsuits, that is
one thing, but to say specific applicants have
different issues, we can't do it.
MR. WEISS: I will defer to Susan on this,
but I don't think you can do ·that.
People have a right to file zoning
applications.
MS. TREVARTHEN: Specifically, we said no
to a particular applicant. They are currently
banned from coming back for a year for exactly the
same thing. That was the application that
excluded village hall what was heard in October
and denied.
That is factually where we are, but I do
agree with what Richard is saying that there is
background law here that people have a right to
petition their government.
MAYOR GROISMAN: No one here is advocating
a special favor anyway is what you are saying.
COUNCILWOMAN COHEN: Correct.
MR. GONZALEZ: You don't have to give them
what they are asking for.
COUNCILWOMAN COHEN: Exactly.
MR. GONZALEZ: But they have a right to
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come and ask.
MS. TREVARTHEN: Councilman Salver is just
talking about timing.
MAYOR GROISMAN: Let's go one at a time.
That is what I am saying. For what they
said to Jorge in the last meeting, which is as
long as Patricia doesn't recuse herself, there is
no resolution. If that is the case, there is not
really a discussion to have from my perspective
because nobody should be recusing on the basis of
the allegations they have made. That is not a
position.
MR. GONZALEZ: Let me make sure I relay it
clearly.
With respect to the settlement, I asked
them, will you drop the cases that are pending.
They said, absent that recusal, we are not
dropping.
With respect to any future application,
they felt they are entitled to submit an
application.
MR. WEISS: I think aside from that issue
if we made a proposal to them, aside from that
issue, which is a nonstarter, I understand, I am
just putting this effort, if we made a proposal to
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them that said, you dismiss your lawsuits, we will
schedule whatever application you want for
MAYOR GROISMAN: For the summer.
MR. WEISS: --for a certain amount of time
or something like that. I would throw in there
the fact that we are not going to pay their
attorneys fees for these public records lawsuits.
MR. GONZALEZ: And you sent us to go and
negotiate.
MR. WEISS: But for the issue with the
conflict, I think that is something that they
would look at.
COUNCILMAN FREIMARK: Coming back to what
Assistant Mayor Salver was saying, and I
completely agree, absent the discussion of the
conflict that I am not minimizing that at all, I
happen to agree with what is being said around the
table, I think the potential ripening and the
threat of a petition from a business perspective
has got to stir them to want a timeline to be
accelerated to the extent that it can. So I
completely agree with that.
COUNCILMAN ALBAUM: But then in the back of
their minds, Richard, they know they can apply
anytime anyway.
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ASSISTANT MAYOR SALVER: The last time they
applied, how long did it take for us to hear their
application?
MAYOR GROISMAN: Last council, last time
this came around to have a hearing, it was pushed
out probably an additional, just going by memory,
six months.
COUNCILWOMAN COHEN: Six months.
MS. TREVARTHEN: July, they requested.
COUNCILMAN ALBAUM: Wait a minute. So,
Richard, you are saying if we propose that to them
and they agree, we would schedule it within 30,
60 days. That would give them something.
MAYOR GROISMAN: Thirty, 60 days wouldn't
give us --
MS. TREVARTHEN: There is advertising.
COUNCILMAN ALBAUM: I am trying to think
what their incentive is to do that.
MR. GONZALEZ: Let me kind of lay this out
for you.
Our work and the time that it would take
for us depends on what they submit to us. We
don't know that the plan is. We don•t know
anything. If it is similar to what was the April
plan, then it won't take as much. If it's varying I
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that, then, you know. We don't know that.
They do, though, I think recognize that
there is an urgency which is that pending petition
requirement. They are not going to want something
that is going to take eight, 10, 12 months to
evaluate and review and be heard. So whatever
willingness there is to hear an application, it
behooves them to keep the application as close to
what we have already seen and as quickly as they
can make i t happen and then you all scheduling it
for a hearing as diligently as possible.
I suspect that on Tuesday, they are going
to, or if not on Tuesday, when they meet with you
all, they are going to tell you what their
thinking is as relates to their plans.
COUNCILMAN ALBAUM: What do you mean when
they meet with us?
MR. GONZALEZ: They are trying to meet with
all of you. They are reaching out.
COUNCILMAN ALBAUM: In a session like this,
you mean?
MR. GONZALEZ: No, no, no.
MS. TREVARTHEN: Individually.
COUNCILMAN FR EI MARK: For the record, I met
with them already.
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COUNCILMAN ALBAUM: Oh.
MAYOR GROISMAN: Did they give you a new
plan.
COUNCILMAN FREIMARK: They are talking
about a new plan, yes.
COUNCILMAN ALBAUM: Oh, okay. Well, I got
a call to meet with them. Oh, okay. I didn't
know why.
MR. GONZALEZ: They want a private
explanation.
COUNCILMAN ALBAUM: There is no ethic,
there is nothing
MR. SEROTA: You can meet with them
privately. We should be careful about how --I
think this is still settlement discussions. This
is still settlement discussion.
COUNCILWOMAN COHEN: It is.
MS. TREVARTHEN: We will talk to you
offline about that.
COUNCILMAN ALBAUM: Okay.
MAYOR GROISMAN: Just focusing on this
lawsuit because of the privilege issues. So there
is nothing on the table from them right now for us
to know how long it would take or not take.
So to the extent that it is conveyed to
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them that Patricia being recused isn't on the
table by way of settlement.
MR. GONZALEZ: I told them that.
MAYOR GROISMAN: Okay. That is one.
Two, as far as scheduling goes, first of
all, we can't and we can't do it, in fact, where
we seem to be pushing one way or the other because
of a petition. Things need to happen in their
ordinary course, but that being said, we can agree
not unreasonably delay things.
Anyway, we are in a vacuum is the point
today because we don't have their plan, if their
plan is totally different. We also want to hear
once they have a plan, I think it's fair to hear
from the new members. They are going to want to
have their time, if it's the same as they are
planning on, to get their hands dirty or into the
plans. There's a lot of details in the plans,
which you guys will go through and you will
understand and you have comments on. You will
want to negotiate yourselves. You want that
opportunity.
But the point is I think we are still in a
vacuum today. I don't know why we are here to
talk about what settlement terms we have with them
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because we don't even know what the plan will be.
MR. WEISS: Just to set expectations, I
will reach out to Kent today. I will reach out to
the shops advising the chances of having something
by Tuesday.
MS. TREVARTHEN: That is not happening.
COUNCILMAN FREIMARK: It's Friday.
COUNCILMAN ALBAUM: Then maybe we shouldn't
even have the discussion on the agenda.
MAYOR GROISMAN: It's up to you separately.
It's your right if you want. Don't bring it up
now because that is something we vote on or
whatever. That comes before the council, but that
is you prerogative .
COUNCILMAN ALBAUM: I would just say at
this point if something happens before Tuesday, if
there is some kind of an arrangement with fees, if
that would happen, then I would say we could
discuss it and vote. If it doesn't, then I would
drop it.
MS. TREVARTHEN: At the beginning of the
meeting, you can move to amend the agenda.
MAYOR GROISMAN: You will have an
opportunity to move to withdraw it.
COUNCILMAN ALBAUM: But there is something
---------------------'
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on the table.
MAYOR GROISMAN: You can speak to Richard
before the meeting starts since it 1 s your item.
COUNCILMAN ALBA UM: Yes, exactly.
MAYOR GROISMAN: When we ask for
withdrawals, that is up to you.
COUNCILMAN ALBAUM: Would it be proper that
you, when you discuss it with them, that it could
be on the agenda for a vote or is that something
you wouldn't necessarily do?
MS. TR EVARTH EN: It's already on the
agenda.
MAYOR GROISMAN: It's on the agenda.
COUNCILMAN ALBAUM: I assume they will
attend the meeting.
MS. TREVARTHEN: That is their choice.
MAYOR GROISMAN: They always do.
Specifically on this lawsuit, does anyone
else on the council who are --
ASSISTANT MAYOR SALVER: I don't know if
this is an offline question for the attorneys or
it's appropriate here, but when we do meet with
them individually, should we be trying to advocate
or even talk about settling anything or no?
Actually advocate like how you would like to see
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these cases, you know.
MR. SEROTA: You mean when you talk
individually to them?
ASSISTANT MAYOR SALVER: Yes.
MR. SEROTA: We should talk outside of
this.
MAYOR GROISMAN: Let's talk outside of
this. We don't want to waive the privilege.
ASSISTANT MAYOR SALVER: Okay.
COUNCILWOMAN COH EN : We can't really talk
outside of this meeting.
MAYOR GROISMAN: You can separately.
COUNCILWOMAN COHEN: But I want to say as a
blanket that if I were in your shoes and I was
being called, I would say, you know something, I
have no love lost for you. Your behavior is
simply antagonistic and it's really not in the
spirit of cooperation.
MAYOR GROISMAN: I just want to cut you off
because I don't disagree with what you are saying,
but we have to talk about just this lawsuit.
COUNCILWOMAN COHEN: It is.
MAYOR GROISMAN: No, it's not. I think we
are crossing the line. I don•t want to waive this
important discussion's privilege.
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COUNCILWOMAN COHEN: We are talking about
negotiations with Bal Harbour Shops. That is
exactly what we are talking about.
MAYOR GROISMAN: But we can't talk about
negotiations with Bal Harbour Shops for
their application exclusively.
COUNCILWOMAN COHEN: Let's not talk about
the application. Let's talk about the spirit, the
optics thing that Jeff was saying.
MAYOR GROIS~AN: The lawsuit.
COUNCILWOMAN COHEN: Yes. If we as a
council in unison collectively, the spirit was we
stand up for each other, we respect each other,
and you won't harass us, believe me, you start
getting a different reaction on their part.
MAYOR GROISMAN: I don't disagree with your
thought.
Okay. Anyone else?
The attorney/client session has now been
terminated and the meeting is now open. The
public is now invited to return for any further
proceedings, although there are none.
We are off the record.
(Thereupon, the proceedings were concluded
at 9:25 a.m.)
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Page 44
C E R T I F I C A T E
I, Mary G. Stephenson, FPR, State of Florida at
Large, certify that I was authorized to and did
stenographically report the foregoing proceedings and
that the transcript is a true and complete record of my
stenographic notes.
Dated this 3rd day of January, 2017.
Mary G. Stephenson, FPR
Veritext Legal Solutions
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Veritext Legal Solutions
305-376-8800
[pay -reporte.r]
pay 35:6
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Veritext Legal Solutions
305·376·8800
[represented -strong]
represented 8 :24
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Veritext Legal Solutions
305-3 76-8800
lviUage -zoning]
26: 17 28:22,23
32:20 33:13
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305-376-8800