HomeMy Public PortalAbout2017-07-18 AttorneyClient In The Matter Of Bal Harbour Yacht Club CASE156568CA30, .,
1
2
3
4
5
6
7
8
9
10
11
12
1 3
14
15
16
17
1 8
19
20
21
22
23
24
25
Page 1
BAL HARBOUR VI LLAGE
ATTOR NEY/CLIENT SESS I ON
IN THE MATTER OF: BA L HARBOUR YACHT CLUB , INC., et al v .
BA L HARBOUR V I LLAG E
CASE NUM BER : 15-6568 CA 30
ORIGINAL
BA L HARBOUR VILLAGE HALL
655 96th S TREET
BAL HARBOUR, F LORIDA 3315 4
TUESDAY , JULY 1 8, 2017
6 :1 0 p .m. -6 :30 p .m.
Taken before Ma r y G. Stephenson, FP R , No t ary
Public for t he State of Florida
Veritext Legal Solutions
800-726-7007 3 05-376-8800
1 APPEARANCES:
2 COUNCILMEMBERS :
3 GABRIEL GROISMAN, MAYOR
SETH E . SALVER , ASSISTANT MAYOR
4 DAVID ALBAUM , COUNCILMAN
PATRICIA COHEN , COUNCILWOMAN
5 JEFFREY FREIMARK , COUNC ILM AN
6
7
8
9
10
11
12
13
14
1 5
VILLAGE MANAGER:
JORGE M. GONZALEZ
VI LLAGE ATTORNEY:
WEISS SEROTA HELFMAN
COLE & B I ERMAN, P.L .
BY : JOSEP H SEROTA, ESQ .
SUSAN TREVARTHEN , ESQ .
VI LLAGE CLERK :
DWIGHT S . DANIE
Page 2
(Present during public session only)
16
17
18
19
20
21
22
23
24
25
800-726-7007
Veritext Legal Solutions
305-376-8800
1
2
3
4
5
6
7
8
9
10
11
12
1 3
14
1 5
16
1 7
18
1 9
20
2 1
22
23
24
25
Page 3
Th ere u pon , the fo llowing proceedin gs were had :
800 -726 -7007
order.
here.
MA YOR GROISMA N: I ca ll this meeting to
Dwight is going to call the rol l.
MR . DAN I E : Roll cal l .
Mayor Groisman.
MAYOR GROISMAN: Here .
MR . DANIE : Assistant Mayor Salve r i s no t
Councilman Albau m.
COUNC ILMA N ALBAU M: He re .
MR. DANIE: Counci l woman Cohen .
COU NCI LWOMA N COHE N : Here .
MR . DANIE : Councilman Freimark .
COUNCILMA N FRE I MARK : Here .
MR~ DANIE : We have a quorum .
(Thereupon, Mr . Dani e l eft the room .)
MA YO R GRO I S MAN: The t i me i s now 6 :1 0 p .m .
We are about to h ave an a t torney/client
session in accordance wi th Florida Statute 286 .0 1 1
regardi ng the litigation styled Ba l Harbou r Yacht
Club, Inc . and Flami n go Way E nterprises versus Bal
Harbour Villa g e , Case Number 1 5 -6568 CA 30 .
The session is est i mated t o l ast half an
hour and the f o l lowing people wi l l be in
Veritext Legal Solu tions
305-376-88 00
1
2
3
4
5
6
7
8
9
10
11
1 2
13
14
15
16
17
18
19
20
2 1
22
23
24
25
800-726 -7007
Page 4
attendance at this meeting: Myself, Mayor
Groisman, Councilmember Freimark, Councilmember
Albaum, Councilmember Cohen, Village Manager Jorge
Gonza l ez, Vi llage Attorney Joe Serota, Village
Attorney Susan Trevart hen.
These proceedings will be recorded by a
certified court reporter and, at the conclusion of
all litigation discussed, t he transcript wil l be
made part of t he public record .
All those individuals who I have not named
should leave. There is no one else in the room
other than the court reporter .
Let's get started.
MR . SEROTA : So , we a re here under Florida
Sta tute 286.011 to update all of you on
litigation, and with that is litigation
expenditures, which have not been tha t significant
at a l l s in ce I have been here last, but they could
change in the future depending on how you want to
handle it.
Let me just spend about five minutes or
less just talking about where we are because it's
relevant or where we have come from, why we are
here.
This case was filed in March of 2015 . The
Veritext Legal Solutions
305-376-8800
1
2
3
4
5
6
7
8
9
1 0
11
12
1 3
14
1 5
16
17
18
19
20
2 1
22
23
24
25
800-726-7007
Page 5
Yacht Club asked for a declaratory judgment that
they are operating in compl i ance with the village
code . That is what they asked for .
Your village attorneys had issued an
opinion just before this lawsuit was f i led, which
said based upon the fac ts that we knew at that
time , t hat we had no information that the marina
they were operating was noncommercia l . It has to
be noncommercial but that --no , I am sorry . That
we had informa tion that it was noncommercia l . But
we specifically stated that the only way to know
was if you would have a declaratory judgment , if
you request discovery and you can find out how
they operate .
What happened is right after we said that ,
literally within days they f i led a declaratory
judgment .
There 's two issues in th e l itigat ion.
Number one, is this a noncommercial marina
operating properly . T hat is the first issue, that
i t has to be noncommercial, not commercial . That
is one question.
The second question is if i t was operating
properly at some point in the past , has t hat use
been abandoned because the way that the Yach t Club
V eritext Legal Solutions
305 -37 6-8800
1
2
3
4
5
6
7
8
9
1 0
1 1
12
13
14
15
16
1 7
18
19
20
21
22
23
24
25
800 -726 -7007
Page 6
is operating has changed over the years . So even
if they were operating properl y years ago , have
the changes in their operation been such that they
are no longer operating properly.
Those are really --that is what the case
is about. We fi l ed a counterclaim seeking a very
similar declaration. The reason we filed the
counterclaim was in case they dismissed the i r
case, we wanted to be able to continu e ou r
discovery and come to a conclusion .
Patricia, I didn't mean to give you my
back.
COUNCILWOMAN COHEN: Don 't worry. I chose
this cha i r because it is so comfortable . Thank
you .
MR . SEROTA: Extensive litigation followed .
We discovered some facts that really do question
their amount of commercial use. They fought us on
everyth ing . A lot of depositions were taken. The
prior councilmembers were taken, the mayor and
others. Patricia 's deposition was taken . We also
hired an accounting expert, corporate expert to
help us determine what we should be l ook i ng for.
This was Kaufman and Rossin. They were very good ,
gave us some very good direct i o n and we found some
Veritext Lega l So lutions
305 -376-8800
1
2
3
4
5
6
7
8
9
1 0
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
800-726-7007
Page 7
good information that he lped us.
We filed a motion to compel because even
though we had good information, they were
resisting others . We filed our motion to compel,
set it for hearing , and then negotiations broke
out . So our hearing on our motion to compel was
not heard. It has been postponed a couple of
times . Right now, it 's scheduled for the end of
August . So that wou l d be the next step i n the
litigation . If you were to direct us to go back
to , in a sense, to l i tigation , that would be it.
Now, there is another l awsuit going on that
i s relevant . Normally, in one executive session ,
we don't talk about another lawsuit , but here I
feel it 's appropriate to do that .
In another lawsuit going on, Stanley Tate
and I think it 's Kelly Stoppa .
MS . TREVARTHEN: Ree Kelly Stoppa.
MR. SEROTA : Ree Kelly Stoppa challenged
the ownership and the process used by Flamingo Way
to get these park lots . So they were cha l lenging
that. That kind of stopped.
We had --Susan knows better, but very
close to a settlement agreement , a really
substantial one , I mean , great detail, ready to
Veritext Legal So lutions
305-376 -880 0
1
2
3
4
5
6
7
8
9
1 0
1 1
12
1 3
14
15
16
17
18
19
20
2 1
22
23
24
25
800-726-7007
Page 8
go, but then once they were challenging t he
ownership of the lots , that was part of the
sett l ement and the r efore we kind of just sat on
the sidelines waiting for th i s to happen .
About a week ago, Judge Cueto, who is very
decisive , strong judge , ruled t h at Tate and S t oppa
did no t have s ta nding and h e den i ed all their
mot i ons and he said, basically , over , no h earings,
no nothing , you are done .
So that was a v e ry s tr ong somewhat
surprising and decisive decision that the y knocked
them out . That is to some degree why we are here
today because I think you a ll --Susan made you
aware of that, but that sort of changes things
back.
So the question is now where do we go from
here . That is really it .
Let me just bring you up to date on a
couple of othe r related stuff. First of all ,
Stoppa and Tate have an appellate remedy .
Probably a petition 'for cert , I th ink something
l ike that , not a very strong appellate remedy , but
you can always appeal something. So t hey might be
able to do that . They might file an i ndependent
lawsuit . We rea ll y don't know that, but r i ght now
Veritext Legal So lut ions
3 05-376-8800
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
800-726-7007
Page 9
they are out. They can make some effort to come
back.
COUNCILWOMAN COHEN: I'm sorry. I didn't
understand. What is an independent lawsuit?
MAYOR GROISMAN: A new lawsuit. They can
file something else .
MR . SEROTA: They tri ed to get into the
Flamingo lawsuit where they got these lots, but
they could file an independent lawsuit.
COUNCILWOMAN COHEN: Against the village?
MAYOR GROISMAN: Against anybody .
(Thereupon, Assistant Mayor Salver entered
the room .)
MAYOR GROISMAN: Mr. Seth Salver is in the
room.
MR . SEROTA: I have been talking. Nobody
else has spoken yet .
All right. So Stoppa and Tate have some
remedy if they choose to take it .
Other things that are relevant in general
in this area, Flamingo is challenging the denial
of the plat waiver. That was from some time ago.
That matter has been briefed. That is in the
appellate division of the circuit court sitting
t here right now.
Veritext Legal Solutions
305-376-8800
1
2
3
4
5
6
7
8
9
1 0
11
12
13
14
1 5
16
1 7
18
19
20
21
22
23
24
25
800-726-7007
Page 10
Settlement agreement relating to the plat
waiver says that the vi l lage wi l l get a new
appl i cation and i f that works ou t , then they
dismiss the appeal, they dismiss all the
li tigation. That is part of the settlement.
Then there is an issue as t o a second
application , waiver application that they filed.
Jorge, wh a t is th e status of that?
MR. GONZALEZ : It 's just sitting on a desk.
MR. SEROTA: Sitting on a desk. Okay.
I only br i ng tha t up because these are just
so a l l of you understand everything that is out
there that is relevant to t ha t . T h at i s rea l ly
whe r e we are.
MAYOR GROISMAN : Just to bri ng everyone up
to date because I was sort of , along with Jorge ,
leading a lot of the settlement discussions . A
lot of this has to do with the quality of life in
the gated community because the marina has no
regu l ations. The city imposes no regu l ations on
the ma r ina , and doi n g so has been very difficult
in the past. So a l ot of this was really used,
when they sued u s, as an opportunity to .try to put
our arms around this operation that is happening
with peop l e sleepi ng there and all these other
Veritext Legal Solutions
305-376-8800
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
800 -72 6-7007
Page 11
issues .
So we came up with this sort of whole
structure , which we have spoken about in the past
on different things. They brought in , they
meaning the marina , brought in the civic
association and said , I want to wrap everything
up , I want everything done with this. That is
sort of where things were, on pause.
I think we are like 98 percent agreed , all
the parties are , the three parties are into that
settlement . I say 98 pe rc ent b ecau se t h ere is
still a small dispute on some language , nothing to
do with t he v i llage, but the marina won 't settle
unless God settles too . I 'm sort of playing
mediator on that third part.
CO UNC I LMAN FR E IMARK: And that being the
association?
MAYOR GROISMAN : Yes, the assoc i ation,
exactly.
COUNCILWOMAN COHEN: That is with the
understanding that it 's a commercial marina and it
can operate? I mean , it 's a concession basically
because you know it 's a commercia l mar i na .
MAYOR GROISMAN : Exactly .
MS . TREVARTHEN : For the record , no, it 's
Ver itext Lega l Solu tions
305-376-8800
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
1 8
1 9
20
21
22
23
24
25
800-726 -7007
Page 12
not . It 's supposed to be a noncommercial marina.
Tha t is what we are litigating on in the Yacht
Club case.
COUNCI LWOMAN COHEN: Tha t means that the
premise is that you accept that it is .
MAYOR GROISMAN: The premise is an initial
ordinance where we change the la nguage of that
zoning to allow commercial , a commercial ma rina
because , I 'l l say from my perspective , it's
clearly a commercial marina. It has to be proven
i n court, et cetera, but it's clearl y a commercial
marina . So let 's make it real, and let 's put
restrictions on it that they aren't going to
oppose and then move forward .
COUNCILWOMAN COHEN : Exactly .
MAYOR GROISMAN : I thin k we are very close .
The very important pa r t was when these challengers
came to challenge the ownersh ip of the parks. It
sort of put a --what 's the expression?
MR . GONZALEZ : Kibosh?
MS. TREVARTHEN : A damper .
COUNCILMAN ALBAUM : A wrench in the works.
MAYOR GROISMAN : A wrench , whate ver ,
because if he can 't give the civic association the
parks , then nothing else is triggered .
Veritext Legal Solutions
305-376-8800
1
2
3
4
5
6
7
8
9
10
1 1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
800-726-7007
Page 13
Just like if we don 't approve, we will have
a hearing on it and ge t the chance to , but if we
don 't approve the plat waiver , it also stops
things. So those things stop moving. It looks
like we are almost done .
They filed a notice or a ppeal, right?
Isn 't it ten days to file a notice of
appeal and then 30 days to file the appeal , right?
MR . SEROTA : Well , depends. I f it 's a
direct appeal , it 's 30 days. If it 's a petition
for cert --
MS . TREVARTHEN : It's 30 days .
MR . SEROTA: It's also 30 days, yes .
MS . TREVARTHEN : Reconsideration is ten
days , I think, right?
MR. SEROTA: They can f ile whatever they
want . This judge is not reconsidering . It will
just be an appeal.
MAYOR GROISMAN : An appeal is going to be
thrown out in the first instance . They weren 't a
party to the case.
So t he point is t h e reason we sort of
stopped pushing the case was we don 't want to
spend money if we are so close to resolving it.
So le t 's wait a second . Let 's see if this Stoppa
Veri text Legal Solutions
305-376 -8800
1
2
3
4
5
6
7
8
9
10
11
12
1 3
14
1 5
16
1 7
18
19
20
21
22
23
24
25
800 -726-7007
Page 14
thing ends . If it does , we can settle everything .
There was a hearing, t he hearing for the
motion to compel was set for l ike last month and
we used it to tell the marina to move on some of
their language. If you show you are st ill moving
in good faith, to try to bridge that gap even more
for the settlement, and they did . It doesn 't mean
we are a hundred percent there yet , bu t we are
very , very close.
MS . TREVARTHEN: The new da t e is August
24th , I th in k .
MAYOR GROISMAN: All the dates are good for
us because t hey don 't want to give us those
documents that they will be ordered to give us for
sure in that hearing.
MR. SEROTA: Right. The other th ing too is
what they discovered is that you have to be
careful what you ask for in life. They filed this
declaratory judgment, tell us we are
noncommercial, and we discovered some pretty good
information that says , we are commercial . I know
I represented the mayor when his deposition was
taken . One of the questions was
MAYOR GROISMAN : I was a bad witness .
MR. SEROTA: No , you were f i ne .
Veritext Legal So lutions
305 -376-8800
1
2
3
4
5
6
7
8
9
10
11
12
13
14
1 5
1 6
17
18
19
20
21
22
23
24
25
800-726-7007
Page 15
Tell us why we are commercial , you know.
Gabe was prepared and laid out all these facts and
i t was, okay , you know .
MS. TREVARTHEN: That is artful.
MR. SEROTA: I think really they recognize
this is no slam dunk. They re a l ly thought i t was
a slam dunk. They realized we found some stuff.
The other thing is this. We are public.
Everything we have is out there . They are not.
So when we start asking , what did you pay each
one, what did you pay your wife, what did you pay
your kids, what were your profits or not profits.
Th is is a nonprofit organization . How did you pay
t hi ngs? Let 's see your income tax returns.
So they reached a point that they weren't
so excited abo u t it anymore . So t ha t helps.
As Gabe says , a mot i on to compel, they h ave
not been t ha t anxious. I think we are going to
win parts of that at l east on the motion to
compel.
So we do have them in a good place to
resolve it, but we still need to deliver the
pa r ks.
MS. TREVARTHEN: So my goal for today is
just let you know the settlement agreement is the
Veritext Legal Solutions
305-376-8800
1
2
3
4
5
6
7
8
9
10
11
12
1 3
14
15
1 6
17
1 8
1 9
20
21
22
23
24
25
800-726-7007
Page 16
same one we o u tlined back in February with the
executive sessions in F l am i ngo Way and in Yacht
Club assuming there is no appeal in t he Stopp a
Tate matter .
We wanted to be clea r tha t we a r e go i ng to
continu e moving down that pa t h of tryi n g to se t tle
u nless we hear different guidance today.
MAYOR GROISMAN : T h a t h a s to approve d b y
t h e counc il anyway .
MS . TREVARTHEN: So what happens i s we
would b ring i t to fruition . We wo u l d ge t them on
record as supporting i t . We would bring it t o you
i n public . You would have a chance to have a
publ i c hea r ing and vote on the settlement . T h en
you would also have a separate o b l ig ation to look
at the waiver o f p l at , have a quasi-judicial
hearing , make that finding , e i ther approve it or
not . I f you rejec t the wa i ver of plat , t he
sett l ement agreement u nwinds . Th a t i s what i t
looks like .
MA YOR GROISMAN : I just have a t echnical
ques t ion . Because the o t her cases we had ended up
being d i smi ssed without a settl eme n t agreemen t .
So for a settlemen t agreeme nt , we ac t ua ll y have a
public h ea ri ng on wh ether we sett l e or no t ?
Veritext Legal Solutions
3 05-3 76-8800
1
2
3
4
5
6
7
8
9
1 0
11
12
13
1 4
15
16
17
18
19
20
21
22
23
24
25
800-726-7007
Page 17
MS. TREVARTHEN: Yes.
MAYOR GROISMAN:
and the who l e thing?
Like with p ub lic comment
MS. TREVA RTHEN : There are numerous
Sunshine l aw cases that invalidat e settl ements
unless yo u have not just a pub l ic hearing , but i t
can't be a rubber stamp. It has to be a genuine
discussion and deliberat i on in the pub l ic .
Then separate l y, because we are trying to
get a land use approval , t hese waivers of plat,
they wou l d be going through that quasi -j udicial
process.
MAYOR GROISMAN: Okay .
COUNCILMAN ALBAUM: So we can't real l y do
anything until September. There is no August
cou ncil meeting .
MAYOR GROIS MAN: Right . So that sort of
works t o our advantage in a sense sort of from the
negotiating standpoint.
First of all, t ime is on our side in
general on this .
Seco n d of a l l, this gives t i me for the
other case to hopefu ll y drop off the map, which
looks like it 's on its way at l east f or now. The
case can change in a moment .
Veritext Legal Solutions
305-376-8800
1
2
3
4
5
6
7
8
9
10
11
1 2
1 3
14
1 5
16
1 7
18
1 9
20
21
22
23
24
25
800-726-7007
Page 18
MS . TREVARTHEN: I t can.
MAYOR GROISMAN: Right? So far , i t 's
fal li ng into the right place. They are not
pushing because i f t hey are going to push, we
can't have a hearing next month.
COUNCI LMAN FRE I MARK: So basically the
point for discussion r i ght now is whether or not
we want to consider a change of strategy and
approach?
MS . TREVARTHEN: Yes, and to keep you up to
date.
COUNCILMAN FREIMARK: I, for one, wou l d be
supportive of continuing exactly the way we are
right now.
COUNCILMAN ALBAUM: Sit tight.
MR. SEROTA: As long as we are here , it
sounds like we have a consensus. If they file
some appellate remedy tha t will slow us down --
MR. GONZALEZ: The Kelly Stoppa?
MR. SEROTA: Yes.
MS. TREVARTHEN : And Tate .
MR. SERO TA: And Tate . Le t 's just talk
about that because we have been talking strategy
wi t h the mayor on different parts. Just like the
last time t hat we continued, the mayor's
Veritext Legal Solutions
305-376-8800
1
2
3
4
5
6
7
8
9
10
1 1
12
13
14
1 5
1 6
1 7
18
19
20
21
22
23
24
25
8 00-726-7007
Page 19
suggestion was l et 's get a specific response on
these topics from them and then we will consider
doing , and it worked very well . Within an hour ,
we got a response on that.
So if , though , there is an appellate remedy
or the y try some t hing , are you guys okay with u s
pos t poning the August 24 th hearing i f otherwise
th in gs we r e to go?
That was something that we t alked t o the
mayor about , not just being the mayor , but also
because this i s what h e does for a living in terms
of talking about strategy . So I'l l be around.
I'm happy to have this conversation , but I was
just wondering .
COUNCILMAN FREIMARK : What are t he pros and
cons?
MR . SEROTA : First of a l l , you know , we
have a vo l atile party on t he other side.
COUNCILMAN FREIMARK : Just one?
MR . SEROTA : Right . You have a lot of them
a r ound here . You know , if we say no and we sti l l
really want to settle if we can , but if we say no ,
there's usual l y significant repercussions , you
know . It's taken very pe rsonal ly . Specially this
one because here t h e motion to compe l is n ot just
Veritext Legal Solution s
305-3 76-880 0
1
2
3
4
5
6
7
8
9
1 0
11
12
13
14
15
1 6
17
18
1 9
20
21
22
23
24
25
I
800-726 -7007
Page 20
any motion . It 's a motion seeking personal
financial informa t ion from them . So it's just not
like a perfunctory motion . It 's one that means
something to them . So they are not going to be
t hat happy .
If the idea is that we feel like we have ,
and we do, a settlement agreement that most
again , as the mayor says and Susan, it will come
before we are not ask i ng you to approve
anything sitting here today . It will come before
you and you will look at i t carefully, but if you
f eel we have something, ins i sting on that hearing
could invalidate that .
COUNCILMAN FREIMARK : This is a l so in the
context of what I hear is a high degree o f
confidence and success regarding being able to
rebut an appeal.
MR . SEROTA : I t hink so . I think so. You
know, we are not a party to it. So we are not the
one who is doing it, but, I mean, I t hink that
they put on a weak case to show that they have
standing .
This is a good j udge. He 's decisive . We
all thought he was going to have a hearing , maybe
even a n evidentia ry hearing where you have
Veritext Legal Solutio ns
305-376-8800
1
2
3
4
5
6
7
8
9
10
1 1
12
13
14
15
16
1 7
18
19
20
21
22
23
2 4
25
800 -726 -7007
Page 21
witnesses and stuff. He dec i ded, he read
everything and he didn't need to hear anything
further.
COUNC I LWOMAN COHEN : They don 't have
standing because they don 't live in the gated
community . Is that why?
MR. SEROTA: They are not affected to a
degree, Pa t ricia , different than the general
public. That is general l y the standard.
MAYOR GROISMAN: Jus t a side note on the
negotiations, there is an alternat i ve that I am
trying to explore with t h em if the Stoppa Tate
t h ing contin u es. I don't know i f I 'll get there
or not , but they are t he ones who brought in let's
try to resolve everything together with the civic
assoc i ation. So now I'm starting to explore with
them if this doesn 't work out, what can a
settlement look like sort of to cut that out.
The pros and cons is that I am always
the one that says keep pushing the case and let's
talk sett l emen t on the side . In litigation, you
fight with this hand and try to settle with this
hand all the time.
Now, depending on how those discussions go,
if tha t o t her l awsuit continues , t he parks lawsui t
Veritext Legal So lu tio ns
305-376-8800
1
2
3
4
5
6
7
8
9
10
11
1 2
13
1 4
15
16
17
18
1 9
20
21
22
23
24
25
800-726-70 07
Page 22
continues or a new one is filed , I 'll initiate
some alternative sett l ement discussions , let 's
say , bas i cal l y t o peel off all those other issues
and see if there i s some t hing to resolve .
The way I have been approaching it , if they
are ta l king good faith and coming back with things
t hat are at least pretty close to what I think
would be good for us to agree to , then I say, all
right , let 's ho l d off on the hearing because, with
them, if we move forward with the hearing as a
matter of cou r se , t hey won 't talk to us for
settlement fo r two months .
MR . GONZALEZ : I think the case is at a
point where i f we start asking for the next things
that you wou l d ask for , it 's kind of like a bridge
too far at that point .
MS . TREVARTHEN : It can blow it up .
MR . GONZALEZ : I t may not come back to
settlement .
COUNC ILMAN FREIMARK : That stuff in that
type of an environment is deeply personal .
MAYOR GROISMAN: It rea l ly is .
MR . GONZALEZ : If we go there , we probably
are going to go a l l the way at that point because
the settlement is off the table . To ask fo r it
Verite xt Legal Solutions
305-376-88 00
1
2
3
4
5
6
7
8
9
10
11
1 2
13
1 4
15
16
17
18
19
20
21
22
23
24
25
800-726-7007
Page 23
now is probably not necessary.
MS . TREVARTHEN : I think we have all been
sensitive to this notion of we don 't want to
litigate the village just to li tigate . There has
been a lot of litigation. If there is an abi l ity
to resolve it that is in the interest of the
village, we are going to give th em every
opportunity.
So that is why Joe is raising it . I 'm glad
he is raising this issue about do we have the
flexibility on that August 24th date, because I do
think there is merit to this notion that if we go
forward, we could blow the whole thing up .
COUNCILMAN FREIMARK : T hat wou l d certainly
seem to make sense.
Is there anyth in g that would stop or could
stop Tate and Stoppa from bringing somebody in,
adding a party or filing a li tigation with a party
that does have standing inside t he gated
community?
MS. TREVARTHEN: A filing fee and some
effort and time.
ASSISTANT MAYOR SALVER : I s i t just the
gated community or anyone can?
MAYOR GROISMAN: Also th e wes t side.
Ver itext Legal So lutions
305-376-880 0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
1 5
16 I
17
18
19
20
21
22
23
24
25
800-726-7007
Page 24
COUNCILMAN FREIMARK: The west side of
Collins?
MAYOR GROISMAN: They could bring anybody
in.
ASSISTANT MAYOR SALVER: I'm surprised they
haven 't .
MAYOR GROISMAN : It 's a money question.
How much does Tate want to fund it . He would be
the one funding it. He just spent a bunch of
money.
COUNCILMAN ALBAUM: Do t hey still have the
same atto r ney?
MS. TREVARTHEN : The motion to remove
Gunster from the case was refused by the court .
So they are still representing Imbesi.
I think that is everything we had if you
don 't have any more ques t ions.
MR . SEROTA: So t hat is where we are. We
understand.
MS. TREVARTHEN: Staying the course
basically.
MR . SEROTA : And also to the extent that we
need to postpone August 24th, I 'll touch with the
mayor before we do anything, but t he consensus
would be that we should do that if we still feel
Veritext Leg al Solutions
305-376-8800
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
1 7
18
19
20
21
22
23
24
25
800-726-7007
Page 25
t hat settlement is an option. Okay.
MAYOR GROISMAN : Good .
I will now reopen the meeting .
The attorney/client session has now been
terminated . The mee t ing is now open to a l l of t he
publ i c and everyone is now invited to return fo r
f u rther p r oceedings.
MS . TREVARTH EN: Motion to a djourn.
MAYOR GROISMAN: Mo tion to adjourn .
(Thereupon , the proceedings were conc l uded
at 6:30 p.m.)
Veritext Legal Solutions
305-376-8800
1
2
3
4
Page 26
C E R T I F I C A T E
5 I, Mary G. Stephenson , FPR , State of Florida at
6 Large, certify that I was authorized to and did
7 stenographica ll y report the foregoing proceedings and
8 that the transcript is a true and complete record of my
9 stenographic notes .
10
11 Dated this 3 1 st day of July , 2017.
12
13
14
15
1 6
1 7
1 8
19
20
21
22
23
24
25
Mary G . Stephenson , FPR
Veritext Legal Solutions
800-726-7007 305-376-8800
[& -comfortable]
& al 1: 13
albaum 2:4 3:10,11
l 4:3 12:2217:14
18:15 24:1 1
& 2:12
15-6568 1:15 3:23 allow 12:8
1--1_8_1_: 1_9 ____ ----i alternative 21: 11
2 22:2
2015 4:2 5 amount 6 :18
2017 1:19 26:11 anxious 15 :18
24th 14 :1119:7 anybody 9:11 24:3
23:11 24:23 anymore 15 :16
286.011 3 :20 4:15 anyway 16:9
3 appeal 8:23 10:4
13 :6,8 ,8 , 10, 18, 19
30 1:1 5 3:23 13:8 16:3 20:17
13: 10, 12, 13 appearances 2: 1
31st 26:11 appellate 8:20,22
I 33154 1:19 9:24 18:18 19:5
' ____ 6 ___ ----i application 10 :3,7
655 1:18
6:10 1:20 3:18
6:30 1:20 25:11 ,._
9
1 96th 1:18
98 11:9,11
10:7
approach 18:9
approaching 22:5
appropriate 7: 15
approval 17:10
approve 13:1,3
16:17 20:9
,--___ a ___ ....., approved 16:8
abandoned 5:25
ability 23:5
able 6:9 8 :24 20: 16
accept 12 :5
accounting 6:22
adding 23: 18
adjourn 25:8,9
advantage 17:18 I ago 6:2 8:5 9:22
agree 22:8
agreed 11:9
agreement 7 :24
10:1 15 :25 16:19
16:23,24 20:7
area 9:21
arms 10:24
artful 15:4
asked 5:1,3
asking 15:10 20:9
22:14
assistant 2:3 3:8
I 9: 12 23:23 24:5
association 11 :6, 17
11 :18 12:24 21:16
assuming 16 :3
attendance 4:1
attorney 1:8 2:10
3:19 4:4,5 24:12
Page 27
25:4 cases 16:22 17:5
attorneys 5:4 cert 8:21 13:11
august 7 :9 14 :10 certainly 23:14
17:15 19:7 23:11 certified 4:7
24:23 certify 26:6
authorized 26:6 cetera 12: 11
aware 8:14 chair 6 :14 ,_ ______ ____.
b challenge 12 :18
,_b_a_c_k_6_: 1_2_7_: 1_0_8_:_15_, challenged 7: 19
challengers 12:17 9:2 16:1 22:6,18
bad 14 :24 challenging 7:21
8:1 9:21
bal 1:6,13,14,18,19 chance l3:2 16:13 3:21 ,22
based 5 :6 change 4:19 12 :7
basically 8:811:22 17 :2518:8
18:6 22:3 24:21 changed 6 :l
better 7 :23 changes 6:3 8:14
choose 9:19
chose 6:13
bierman 2: 12
blow 22:17 23:13 circuit 9:24 bridge 14:6 22:15
b . ~d 9 .23 1 city 10:20
neie · · · 1 5 2 24 bring 8:18 10:11,15 CIVIC l: 1 :
16:11 ,12 24:3 21 :15
clear 16 :5 bringing 23: 17
broke 7 :5 clearly 12:10,1 1
clerk 2:14 brought 11 :4,5
21:14 client 1:8 3:19 25:4
close 7:24 12 :16 bunch 24:9 13:24 14:9 22:7
1-----c --------1 club 1:13 3:22 5:1
C 26: 1,1
ca 1:15 3:23
call 3:2,4,5
careful 14:18
carefully 20: 11
case 1:15 3:23 4:25
6:5 ,8,9 12:3 13:21
13:23 17 :23,25
20:2121:2022:13
24:14
5:25 12:3 16:3
code 5:3
coben 2:4 3:12,13
4:3 6:13 9:3 ,10
11:20 12:4,15 21:4
cole 2: 12
collins 24:2
come 4:236:109:1
20:8,10 22 :18
comfortable 6:14
Veritext Legal Solutions
800-726-7007 305-376-8800
[coming -foregoing]
coming 22:6
comment 17:2
commercial 5 :21
6 :18 11 :21,23 12:8
12:8,10,11 14:21
15:1
community 10:19
21:6 23:20,24
compel 7:2,4,6 14:3
11:20 12:4,15 21:4 desk 10:9,10
counterclaim 6:6,8 detail 7:25
couple 7:7 8: 19 determine 6:23
course 22:11 24:20 different 11 :4 16:7
court 4:7,12 9:24 18:24 21 :8
12:11 24:14 difficult 10:21
cueto 8:5 direct 7:10 13:10
cut 21: 18 direction 6 :25 >---------~
d discovered 6:17
Page 28
excited 15:16
executive 7:13 16:2 j
expenditures 4:17
expert 6:22,22
explore 21:12,16
expression 12: 19
extensive 6:16
extent 24:22
f
15: 1 7 ,20 19: 25 1--d-a_m_p_e_r-12-:-2-1 --------i
complete 26:8
14:17,20 f 26:1
discovery 5:13 6:10 facts 5 :6 6 :17 15 :2 danie 2:15 3:5,8,12 compliance 5:2 3:14,16,17
concession 11 :22 date 8 : 18 lO: 16
concluded 25:10 14 :l0 lS:ll 23 :l l
conclusion 4:7 6:10 dated 26:l l
confidence 20: 16
cons 19:16 21 :19
consensus 18: 17
24:24
consider 18:8 19:2
context 20: 15
continue 6:9 16:6
continued 18:25
continues 21 : 13 ,25
22:1
continuing 18:13
conversation 19: 13
corporate 6:22
council 16:917:16
councilman 2:4,5
3:10,11,14,15
11:16 12:2217:14
18:6,12,15 19:15
19:19 20:14 22:20
23:14 24:1,11
councilmember 4 :2
4:2,3
councilmembers
2 :2 6:20
dates 14:12
david 2:4
day 26:11
days 5: 16 13:7,8,10
13:12,13,15
decided 21: 1
decision 8: 11
decisive 8:6, 11
20:23
declaration 6:7
declaratory 5: I, 12
5:16 14:19
deeply 22:21
degree 8:12 20:15
21:8
deliberation 17:8
deliver 15 :22
I denial 9:21
denied 8:7
depending 4:19
21:24
depends 13 :9
deposition 6:2 1
14:22 councilwoman 2:4 depositions 6: 19
3:12,13 6:13 9:3,10
discussed 4:8 faith 14 :6 22 :6 discussion 17: 8 falling 18:3
18 :7 far 18:2 22:16
discussions 10: 1 7
21 :24 22 :2 february 16:1
fee 23:21
dismiss 10:4,4
dismissed 6:8 16:23 feel 7 :l 5 20 :6 '12
24 :25
dispute 11: 12
division 9:24 fight 21 =
22
file 8:24 9:6,9 13:7
documents 14:14 13:8,16 18:17
doing 10:21 19 :3 filed 4:25 5:5 ,16
20:20 6 :6 ,7 7:2,4 10:7
drop l 7:23 13:6 14:18 22:1
dunk 15 :6 , 7 filing 23: 18,21
,_d_w_i~ht_l_:_t 5_3_:_4 _ ____. financial 20:2
e ___ ----l find 5: 13
e 2:3 26:1,1
effort 9:1 23:22
either 16:17
ended 16:22
ends 14:1
entered 9:12
enterprises 3:22
environment 22:21
esq 2:12,13
estimated 3 :24
1 et 1:1312:11
evidentiary 20:25
exactly 11: 19,24
12:15 18:13
finding 16:17
fine 14:25
first 5:20 8:19
13:20 17:20 19:17
five 4 :21
flamingo 3:22 7:20
9 :8,21 16:2
flexibility 23: 11
florida 1: 19,24
3:20 4:14 26:5
followed 6 : 16
following 3: 1,25
foregoing 26:7
Veritext Legal Solutions
800-726-7007 305-376-8800
(forward -litigation] Page 29
forward 12:14 22:13,18,23 helps 15:16 judgment 5:1,12,17
22:10 23:13 good 6:24,25 7:1,3 high 20:15 14:19
fought 6:18 14:6,12,20 15:21 hired 6:22 judicial 16:16
j found 6:25 15:7 20:23 22 :6,8 25:2 hold 22:9 17:11
fpr 1:23 26:5,15 great 7:25 hopefully 17:23 july 1:19 26:11
~ -
freimark 2:5 3:14 groisman 2:3 3:2,6 hour 3:25 19:3 k
3:15 4:2 11:16 18:6 3:7,18 4:2 9:5,11 f-h_u_n_d_re_d_1_4:_8 __ kaufman 6:24
18:12 19:15,19 9:14 10:15 11:18 >------•-· __ ___, keep 18:10 21:20
20:14 22:20 23:14 11:24 12:6,16,23 idea 20:6 kelly 7 :17,18,19
24:1 l3:I 9 l 4 :l 2,24 imbesi 24:15 18:19
fruition 16:11 16 =8,21 17 =2,13 ,17 important 12:17 kibosh 12:20
fund 24:8 18:2 21:1022:22 . 10 20 kids 15·.12 imposes :
funding 24:9 23:25 24:3,7 25:2,9 income 15:14 kind 7:22 8:3 22:15
further 21 :3 25:7 guidance 16:7 knew 5 ·.6 independent 8:24
1--fu_tu_r_e_4_:1_9 __ ---1 gunster 24:14 9 :4,9 knocked 8:11
~--~g~-------1g~u~y_s _l 9_:_6------i individuals 4: 10 know 5: 11 8:25
g 1:23 26:5,15 ~ ___ h ___ -----1 information 5:7,10 11:23 14:21 15:1 ,3
gabe 15:2,17 half 3:24 7:1,3 14:21 20:2 15:25 19:17,21 ,24
gabriel 2:3 hall 1 :18 initial 12:6 20:19 21 :13
gap 14:6 hand 21:22,23 initiate 22:1 knows 7:23
gated 10:19 21:5 handle 4:20 inside 23:19 1
23: 19,24 happen 8:4 insisting 20:12 laid 15 :2
general 9:20 17:21 happened 5:15 instance 13:20 land 17 :lO
21:8 happening 10:24 interest 23:6 language 11: 12
generally 21 :9 happens 16:10 invalidate 17:5 12 :7 14:5
genuine 17:7 happy 19:13 20:5 20:13 large 26 :6
give 6:11 12:24 harbour 1:6,13,14 invited 25:6 law 17 :5 14:13 ,14 23:7 1:1 8,19 3:21,23 issue 5:20 10:6 1 •t 5 5 7 12 14 awsm : : ,
gives 17:22 hear 16:720:15 23:10 7:16 8:25 9:4,5,8 ,9
glad 23 :9 21 :2 issued 5 :4 21:25,25
go 7:10 8:1,16 19:8 heard 7:7 issues 5:18 11 :1 leading l 0:17
21:24 22:23,24 hearing 7:5,6 13:2 ,____22_:_3 ____ ----1 leave 4 :11
23:12 14:2,2,15 16:14,17 -------'J"--. ___ left 3:17
goal 15 :2 4 16:25 17:6 18:5 jeffrey 2 :5 life 10:18 14:18
god 11:14 19:7 20:12,24,25 joe 4 :4 23 :9 literally 5:16
going 3:4 7:1 2,16 22 :9 ,10 jorge 2:8 4:3 10:8 litigate 23:4,4
12:13 13:19 15:18 hearings 8:8 IO:l6 litigating 12:2
16:5 17:11 18:4 helfman 2:11 joseph 2:12 litigation 3:21 4:8
20:4,24 22:24 23:7 help 6:23
1
judge S:5,6 13:17 4:16,16 5:18 6:16
gonzalez 2:8 4:4 helped 7: 1
10:9 12:20 18:19 20:23 7:10,1110:5 21:21
Veritext Legal Solutions
800-726-7007 305-376-8800
[litigation -pros]
23:5,18
live 21:5
living 19: 11
long 18:16
longer 6:4
look 16:15 20:11
21 :18
looking 6:23
looks 13:4 16 :20
17 :24
lot 6:19 10:17,18
10:22 19:20 23:5
lots 7:21 8:2 9:8
m
Page 30
means 12:4 20:3 number 1:15 3:23 path 16:6
mediator 11 :15 5:19 patricia 2:4 6: 11
meeting 3:2 4:1 numerous 17:4 21:8
17:16 25:3,5 0 patricia's 6:21
· 23 12 ----------i pause 11 :8
merit : obligation 16:15 Ollll13 minutes 4:21 pay 15:1 , , ,
okay 10:10 15:3 peel 22:3 moment 17:25 7 13 19 6 25 1 1 : : : people 3:25 10:25 money 13:24 24:7 8 1
once : percent 11:9,11 24:10 ones 21:14
14:8 month 14 :3 18:5 25 5
open : perfunctory 20:3 months 22:12 5 14 11 22 operate : : personal 20: 1 motion 7:2,4,6 14:3 rati·ng 5·2 8 20
ope · ' ' 22:21 15:17,19 19:25 5 23 6·1 2 4
: · ' ' personally 19:24 20:1,1,3 24:13 25:8 t· 6 3
opera ion : perspective 12 :9 25:9 10 24
m 2:8 : petition 8 :2 1 13:10 motions 8:8 · 5 5
manager 2:7 4:3 opimon : place 15:21 18:3 move 12:14 14:4 ·t 10 23 map 17:23 opportum Y : plat 9:22 10:1 13:3 22:10 23:8 o march 4:25 moving l3:4 14 :5 16:16,18 17:1
marina 5:7,19 oppose 12 =14 playing 11 :1 4 16:6 · 25 1 10:19,21 11:5,13 1----..::....._ ______ option : point 5:24 13:22
11:21 ,23 12 :1,8,10 1----___ n ____ ord er 3 :3 15:15 18:7 22:14
d 4 10 ordered 14 :14 12:12 14:4 I name : 22:16,24
mary 1:23 26:5,15 necessary 23:1 o rdinance 12 =7 postpone 24:23
matter 1:13 9:23 need 15:22 21 :2 organization 15:13 postponed 7:7
16:4 22:11 24:23 outlined 16 =1 postponing 19:7
· 17 19 ownership 7:20 8:2 mayor 2:3,3 3:2,6,7
1
negotiatmg : premise 12:5 ,6
3:8,18 4:16:209:5 I negotiations 7:5 12:18 prepared 15 :2
9:11,12,14 10:15 21:11 P present 2 :15
11:18,24 12 :6,16 new 9:5 10 :2 14 :lO p.1. 2:12 pretty 14:20 22:7
12:23 13:19 14:12 22:1 p.m. 1:20,20 3:18 prior 6:20
14:22,24 16:8,21 noncommercial 5:8 25:11 probably 8:21
17 :2,13,17 18:2 ,24 5:9,10,19,21 12 :l I park 7:21 22:23 23:1
19 :10,10 20:8 14:20 parks 12:18,25 proceedings 3:1
21:10 22:22 23:23 nonprofit 15:13 15:23 21:25 4:6 25:7,10 26:7
23:25 24:3,5,7,24 normally 7:13 part 4 :9 8:2 10:5 process 7:20 17:12
25:2,9 notary 1:2 3 11:15 12:17 profits 15:12,12
mayor's 18:25 note 21:10 parties 11:10,10 properly 5:20,24
mean 6:11 7:25 notes 26:9 parts 15:19 18:24 6:2,4
11:22 14:7 20:20 notice 13:6,7 party 13:21 19:18 pros 19 :15 21:19
meaning 11:5 notion 23:3,12 20:1923:18,18
Veritext Legal Solutions
800-726-7007 305-376-8800
[proven -started)
proven 12:10
public 1 :24 2: 15
4:915:8 16:13 ,14
16:25 17:2,6,8 21 :9
25:6
push 18:4
pushing 13 :23 18 :4
21:20
recorded 4:6
ree 7:18,19
refused 24: 14
regarding 3:21
20 :16
regulations I 0 :20
10:20
reject 16:18
put 10:23 12:12,19 related 8:19
20:21
1
----=--=~..:..._ _______ _J_J relating 10: 1
1
-----_:i...:iqL ______ relevant 4:23 7:13
quality 10:18 9.20 10:13
quasi 16:16 17:11 remedy 8:20,22
question 5 :22,23 9:19 18:18 19:5
1
6:17 8:16 16:22 remove 24:13
24:7 reopen 25:3
questions 14 :23 repercussions
24:17 19:23
1
qu::.:...:o:...:r-=u~m'...........:3'...:.:: 1~6!._ _ _J report 26: 7
1
reporter 4:7,12
r __ ____. represented 14:22
r 26:1
raising 23:9,l0
reached 15:15
read 21:1
ready 7:25
real 12:12
realized 15:7
really 6:5,17 7:24
8: 17,25 IO: 13,22
15:5,6 17:14 19:22
22:22
reason 6:7 13:22
rebut 20:17
recognize 15 :5
reconsideration
13:14
reconsidering
13:17
record 4:9 11 :2 5
16:12 26:8
representing 24: 15
request 5:13
resisting 7:4
resolve 15:22 21: 15
22:4 23:6
resolving 13:24
response 19: 1,4
restrictions 12: 13
return 25:6
returns 15:14
1 right 5:15 7:8 8:25
9:18,25 13:6,8,15
l4:16 17:17 18:2,3
18:7,14 19:20 22 :9
roll 3:4,5
room 3:174:11
9:13,15
rossin 6:24
rubber 17:7
Page 31
l settlements 17:5
1
----:-_ __::s:..__ __ _JI settles 11 : 14
s 2:15 , show 14:520:21
ruled 8:6
salver 2:3 3:8 9:l 2 side 17:20 19:18
9 :14 23:23 24 :5 21 :10,21 23:25
sat 8:3 24 :1
says 10:2 14:21 sidelines 8:4
15:1720:821:20 signature 26:14
scheduled 7:8 significant 4: 17
second 5:23 10:6 19:23
13.25 17:22 1 similar 6:7
see 13:25 15: 14 sit 18:15
22:4 sitting 9:24 10:9,10
seeking 6 :6 20: 1 20: 10
sense 7:1117:18 slam 15:6,7
23:15 sleeping 10:25
sensitive 23:3 slow 18:18
separate 16:15 small 11: 12
separately 17:9 somebody 23:17
septem her 17: 15 somewhat 8: 1 o
serota 2:11 ,12 4 :4 sorry 5:9 9:3
4:14 6:16 7:19 9:7 sort 8:14 10:16
9:16 10 :10 13:9,13 11:2,8,14 12:19
13:16 14:16,25 13:22 17:17,18
15:5 18:16,20,22 21:18
19:17,20 20:18
21:7 24:18,22
session 1:8 2:1 5
3:20,24 7:13 25:4
sessions 16:2
set 7:5 14:3
seth 2:3 9:14
settle 11:1314:l
16:6,25 19:22
21:22
settlement 7:24 8:3
10:1 ,5,17 11 :11
14:7 15:25 16:14
16:19,23,2 4 20:7
2 1:18,21 22:2,12
sounds 18:17
specially 19:24
specific 19: 1
specifically 5: 11
spend 4 :2 1 13:24
spent 24:9
spoken 9:17 11 :3
stamp 17:7
standard 21 :9
standing 8:7 20:22
21:5 23 :19
standpoint 17: 19
stanley 7: 16
start 15: 10 22: 14
started 4:13
22:19,25 25:1
Ven;•te~x;-t LLie:g:a~IS~o~lut~1:• 0:ns~~-_J_ _____ ___,
800-726-7007 305-376-8800
[starting -zoning)
starting 21 : 16
state 1 :24 26:5
stated 5:11
status 10:8
I statute 3:20 4:1 5
staying 24:20
stenographic 26:9
stenographically
26:7
step 7:9
stephenson 1 :23
26:5,15
stop 13:4 23:16,17
stoppa 7:17,18,19
8:6,20 9:18 13:25
16:3 18:19 21:12
23:17
stopped 7:22 13:23
stops 13:3
strategy 18:8 ,2 3
19:12
street 1:18
strong 8:6,10,22
structure 11 :3
stuff 8:19 15:7 21:1
22:20
styled 3:21
substantial 7 :25
success 20:16
sued 10·23
suggestion 19: 1
sunshine 17:5
supporting 16:12
supportive 18 : 13
supposed 12:1
sure 14:15
surprised 24:5
surprising 8: 11
susan 2: 13 4:5 7:23
8:13 20:8
800-726-7007
t times 7:8
t 26:1,1 today 8:13 15:24
table 22:25 16:7 20:10
Page 32
volatile 19: 18
vote 16: 14
w
take 9: 19 topics 19:2
taken 1:23 6:19,20 touch 24:23 wait 13:25
6:21 14:23 19:24 transcript 4:8 26:8 waiting 8:4
talk 7:14 18:22 trevarthen 2:13 4 :5 waiver 9:22 10:2,7
21:2122:11 7:1811:25 12:21 13:316:16,18
talked 19:9 13:12,1414:l0 waivers 17:10
talking 4 :22 9:16 15:4,24 16:10 17:l want 4:19 11:6,7
18:23 19:12 22:6 17:4 18:1,10,21 13:17,23 14:13
tate 7:16 8:6,20 22:17 23:2,21 18:8 19:22 23:3
9:18 16 :41 8:21,22 24:13,20 25:8 24:8
21:1223:1724:8 tried 9:7 wanted 6:916:5
tax 15:14 triggered 12 :25 way 3:22 5:11,25
technical 16 :21 true 26:8 7:20 16:2 17:24
tell 14:4,19 15:1 try 10:23 14:6 19:6 18:13 22:5,24
ten 13:7,14 21:15 ,22 weak 20:21
terminated 25:5 trying 16:6 17 :9 week 8:5
terms 19:11 21:12 weiss 2:11
thank 6:14 tuesday 1:19 west 23:25 24:1
thing 14:1,16 15:8 two 5:18 22:12 wife 15:11
17:3 21:13 23:13 e 22:21 win 15:19
things 8:14 9:20 1 .o.....:....-----=~u=--------witness 14:24
11:4,8 13:4,415:14 witnesses 21:1
1
understand 9:4 9:8 22:6,14 l0:l 2 24:19 wondering 19:14
think 7:17 8 :13,2l work 21:17
11:9 12:16 13:15 understanding worked 19:3
11:21
14:11 15 :5,1 8 unwinds 16:19 works 10·3 12·22
20:18,18,20 22:7 update 4:15 17:18
22:13 23:2,12 worry 6:13
24:16 use 5:24 6:18 17:10 wrap 11:6
third 11.· 15 ,_JJ.sually 19:23 wrench 12:22,23
thought 15:6 20:24 v y
three 11:10 v 1:13 thrown 13:20 versus 3:22 yacht l:13 3:215:1
tight 18:15 village 1:6,14,18 5:25 12:2 16 :2
time 3:18 5:7 9:22 2:7,10,14 3:23 4:3 years 6:1,2
17:20,22 18:25 4:4,4 5:2,4 9:10
21:23 23:22 10:2 11:13 23:4,7
z
zoning 12 :8
Veritext Legal Solutions
305-376-8800