HomeMy Public PortalAboutWilliam Thrasher Transcript 6/10/15UNITED STA' --3S DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
CASE. NO. 9:13-CV-81053-MIDDLEBROOKS/BRANTNON
Condensed
CHRISTOPHER E. O'HARE,
Plaintiff,
v.
TOWN OF GULF STREAM, et al.,
Defendants.
DEPOSITION OF WILLIAM F. THRASHER, JR.
(videotaped)
Wednesday, June 10, 2015
10:52 - 3:33 P.m.
Town of Gulf Stream - Town Hall
100 Sea Road
Gulf Stream, Florida 33483
Reported By:
Rachel W. Bridge, RMR, CRR, FPR
Florida Court Reporting
2161 Palm Beach Lakes Boulevard, Suite 302
West Palm Beach, Florida 33400
(561)689-0999
Job #110394
Florida Court Reporting
561-689-0999
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APPEARANCES-
On behalf of the Plaintiff
INDEX
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JONATHAN O'BOYLE ESQUIRE
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- - -
O'BOYLE LAW FlRtt
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WITNESS: DIRECT CROSS REDIRECT RECROSS
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IDOI Broad$met
Johnsiow Ptennsylvama 15906
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William Thrasher
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Telephone: 814-535-5175
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By Mr. O'Boyle 4
E-mail lonathanroboyleegmail cum
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LOUIS L ROEDER Bl, ESQUIRE
R
.i-
7414 Sparkling Lake Road
E X II ( B I T S
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Orlando, Florida 32919
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- . -
telephone :407-7594194
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EXHIBIT DESCRIPTION PAGE
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E-mail Lou@Louroedereom
MARK 1 HANNA, ESQUIRE
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Dcfendams19 12-14-11 letterto Chris 136
GMM/MADISON PA
011are from Te=a Lunn
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401 South County Road #3272
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Palm Beads Florida 334869991
Defendant's 20 Photograph 73
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I 13
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On behalfofthe Defendam.
DeRndanCs21 Buildingpemd[ 100
'.4
CHRISTOPHERI. STEARNS, ESQUIRE
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JOHNSON, ANSELMO, MURDOCH. BURKE.
Derodarifs22 10.28-13NoticeofViolation 122
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PIPER 8 HOCI:MAN, P.A.
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2455 East Sunrise Boulevard, Suite 1000
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Fon LaudeNule-Florida 33304
Telephone: 954-463-OIOD
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E-mail- Sreams_Fjambgtomm
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is
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Also Present ChrislopherOrHare
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Chief Went
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2122
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PROCEEDINGS
f 1
Q And how long have you had that position?
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_ _ - I
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A. Fifteen J ears.
3
Deposition taken before Rachel W. Bridge,
3
Q. And that would be 2000'1 2001?
4
Cerdled Realtime Reporter and Notary Public in and for
4
A. Whatever. 1 don't )mow.
5
die State of Florida at large, in the above cause.
5
Q. Okay. And you were torn manager before?
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_ _ _
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A. No.
7
Thereupon I
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Q. What was your occupation before being town
8
(WILLIAM F. THFASIIL-R) I
B
manager?
9
having been first duly sworn or affirmed. was wmnined
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A. I was assistant teem manager and finance
10
and testified as follows: i
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director.
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THE WITNESS: I do.
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Q. That was for the Town of Gulf Stream?
12
DIRECT EXAMINATION
12
A. Yes.
13
BY MR O'BOYLE:
13
Q. How tong were you assistant town manager and
14
Q. Will you-- Jonathan O'Boyle forthe
14
finance director?
15
plaintiff, pro hoc vice.
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A. Two years.
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MR. HANNA: Mark Hanna for plaintiff.
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Q. Did you work for the Town of Gulf Stream prior
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MR. STEARNS: Christopher Steams for William
17
t0 that?
16
Thrasher.
I
18
A. Yes
19
BY MR O'BOYLE:
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Q. What did you -
20
Q. Okay. Will you please state your name for the
20
A. I was finance director and assistant to the
21
record.
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town manager.
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A. William Ilarrison Thrasher, Jr.
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Q. Okay. Sorry, I'm a little bit confused here.
23
Q. .And you are a — your position with the Town
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Is there a difference between being assistant to the
24
of Gulf Sveam?
24
town manager and being town managers assistant?
25
A. Torn manager.
25
Why don't 1 back up. Can you please describe
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?age 7
1
}our employment history with the Town of Gulf Strcam?
1
managemrnL finance.
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A. 1 just did. I was hired April'96 as listener:
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Q. Did you get your MBA before you started
3
director and assistant to the town manager.
3
working in die financial, as a finance person for
4
Upon the retirement of Scott Herrington, 1,
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governments?
5
through the transition to Chris Garrison. I obtained the
5
A. Ycs.
6
title of assistant tour manager and finance director.
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Q. Olay. Pretty handy with the budget?
7
And then when she retired or she terminated, I was town
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A. I have a workable knowledge of the budget.
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manager.
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Q. Okay. Now let me ask in 1996 when you were
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Q. Okay. Before that, did you work for any
` 9
finance director and assistant to the town manager, what
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government agencies?
10
was — well. let me back up.
11
A. Yes.
1;
Who hired you for that role?
12
Q. Which government agencies and what was 3 nor
I 12
A. Scott Herrington.
13
role?
I 13
Q. And he was the town manager for the town?
14
A. City of Pahokee, finance director.
I 14
A. Correct.
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Q. Is that the only government position?
15
Q. Did he need commissioner approval to hire?
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A. Prior to that. district director, Loxahatehee
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A. No.
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Groves Water Conml District.
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Q. Okay. Was he, was the relationship I guess
18
Q. Anything prior to that in terms of govemment?
18
1
contractual? Was it az-will employment?
19
A. No.
19
A. At will.
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Q. Okay. And so your career with Florida
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Q. At will. So it was Mr. Herrington who had the
21
governments dates back to when?
21
ability to fee or institute discipline?
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A. '92.
22
A. Yes.
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Q. Okay. And it's fair to say that you — well,
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Q. Was he the only person?
24
what training do you have with financing?
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A. Yes.
25
A. On thejob. 1 have a degree, a BBA. MBA
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Q. Okay. And when you became assistant town
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manager, what were your dudes as an assistant town
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A. i was present. I wasn't listening to
2
manager?
2
everything.
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A. N•'hatever I was assigned.
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Q. Okay. Did you hear anything about telephones,
4
Q. Okay. Were you assigned to your hiring,
4
about the lighudng strike with the telephone?
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firing?
5
A. Yes.
6
A. No — sorry, I interrupted you.
6
Q. So w•bcn you said day -today operations, I said
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Q. No, I'm just trying to understand what 1
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something like telephones, referencing back to that
6
guess—
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A. Okay.
9
MR. STEARNS: Keep going.
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Q. So they would be minor, yoi re called onto
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BY MR.O'BOYLE:
10
make decisions — sorry•,youdistractedmealittlebit
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Q. —what the town managers have historically
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there.
12
done in this town.
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You are required to make minor decisions for
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So they have — well, tell me a little bit
13
the town on a day -today basis?
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about thaL What is thejob of town manager? What is
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A. I don't know what minor means.
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that? What do you understand that to be?
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Q. Okay. Whattypesofdecisions-
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A. Generally speaking, the day -today operations
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A. I make decisions.
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of the town.
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Q. All of them?
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Q. And that would include phones?
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A. No.
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A. I don't understand your question.
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Q. Are you responsible for all of the decisions?
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Q. You — let me back up here.
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A. I'm responsible for my decisions.
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You have sat through the depositions of every
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Q. Okay. Can you delegate certain functions?
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person in this matter so far?
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A. Yes.
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A. 1 believe the answer is yes.
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Q. Okay. What functions have you delegated in
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Q. Okay. And you were present and listening to
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the past?
25
Commissioner Orthwein?
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A. To the town clerk my entire responsibilities.
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Q. But if the town clerk were to let's say.
1
A. lam.
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quota unquote. get something wrong or make a mistake.
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Q. Okay. Let me make this a little bit easier.
3
you would ultimately be responsible for that?
3
You wear many hats in this town; is that correct?
4
A. Yes.
4
A. I don't know what you mean by hats.
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Q. Okay. Do you do any other delegating besides
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Q. Okay. You have many different roles in this
6
all your duties — let me back up. You delegate your
6
town encompassed within town manager?
7
duties to the town clerk under what circumstances?
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A. I have the responsibility for being the town
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A. In my absence.
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manager.
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Q. So vacation?
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Q. Okay. You just said that you are also the
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A. In my absence.
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finance director.
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Q. Okay. So that would be sick days, vacation.
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A. Correct.
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or are there any times where you delegate your
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Q. What other titles do you hold with the town?
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authority? Let me back up.
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A. I don't know that I hold any other tides. I
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What do you mean when you sa3 absence? You
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have some functions.
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mean physical absence?
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Q. Okay. What other functions?
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A. Yes.
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A. I am the building official.
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Q. Okay. Do you do any other delegations besides
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Q. Okay.
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the town clerk?
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A. I'm the code inspector. That's all I can
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A. I don't recall.
I is
remember right now.
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Q. Okay. When you first — I'm Sony. let me
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Q. Okay. When you say building official, what
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back up.
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does that mean?
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Is them a finance director for the Town of
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A. It can mean a lot of things. What I can cite
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Gulf Stream to dale?
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for you this morning is that if a permit were to come
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A. Yes.
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in. I would review it and decide whether it's a,
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Q. Who is die finance director?
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something I can approve.
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A permit would have to be a level one permit.
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Gulf Stream?
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what we define as a level one, which by code the town
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A Generally, it's related to the Florida
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building official can approve or not approve.
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Building Code, assuring that the safety and health and
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Q. Okoy. Sticking with building official, the
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welfare of the residents is accounted for as it relates
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Town of Gulf Stream• it does not have its own building
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to construction activities.
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department?
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Q. Construction being distinct from zoning?
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A. No.
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A. Yes.
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Q. What — okay. i know 1 know and I know you
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Q. Do ) au know who Steve Tobias is?
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know the answer, but for the record where is the tow n's i
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A. Yes.
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building department or how is that, how does that work?
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Q. Tell me who he is.
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A. Well, we have building permit information
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A. He is an employee with the City of Delray
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here. We file them, save them
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Beach.
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Q. Is there a relationship with Delray Beach in
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Q. What is his relationship — I'm sorry, how do
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terms of building permits, inspections?
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you know him?
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A The City of Delray Beach Is our permit and h
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A. He works for the City of Delray Beach in their
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inspection arm.
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building department.
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Q. And what do they do? I
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Q. And that is a building department that works
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By the way, these are not trick questions.
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with the Town of Gulf Stream?
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These arejust getting it out them what the City of
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A. I don't understand the question.
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Delta) Beach does and what you do not do.
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Q. Okay. Is there an inter -local agreement
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A. Understood.
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between the Town of Gulf Stream and Delray Beach?
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Q. Right.
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A. Yes.
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A. Could you repeat the question?
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Q. Okay. And that— well, tell me what you
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Q. Sum. What does the City of Delray Beach.
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generally understand that agreement to be.
25
what does their building department do for the Town of
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A. It is an agreement between the Town of Gulf
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Stream and the City of Delray Beach to provide building
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Q. Okay. Is Mr. Tobias the chief inspector?
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permit applications and review and approval and
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A. tic may be. I dont know.
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inspections.
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Q. Okay. But --okay. So when would the Town of
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Q. And that would be subject to only the Florida
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Gulf Stream find it appropriate to call the City of
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Building Code?
5
Delray Beach?
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A. Yes.
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A. I don't understand your question.
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Q. So that is, just to help me and the record
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Q. Okay. Pursuant to the imer-local agreement
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understand, that is like where your wall sockets are,
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which you have identified earlier, when does the Town of
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whetheryou have this type ofanelectrical circuit,
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Gulf Strewn. under what circumstances have they called
i 0
canslruction-related items?
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the City of Delray Beech?
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A. 1 don't know.
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A. 1 still don't understand }rout question.
32
Q. Okay. 157rat— then what is your understanding
12
Q. Okay. The City of Delray Beach under the
13
of Mr. Tobias'— I'm sorry, Mr. Tobias is the building
23
inter local agreement. I've asked you what they do for
14
inspector for die City of Delray Brach?
( 14
the town. And correct me if I'm wrong, you said they
15
A. He is at least one of them 1 don% know his
15
administer the Florida Building Code and they perform
16
title.
16
building inspections for the Florida Building Code, is
17
Q. Okay. Is he the -- well, is he the person
17
that coned?
18
that would come and do inspections far the Town of Gulf
is
A. Generally comet
19
Strewn?
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Q. Is there anything else that they do?
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A. Could be.
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A. 1 think that its purpose is to provide for the
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Q. Is his department or the department that he
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health, safety and welfare of residents.
22
works for!
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Q. Right. But they're not out feeding the
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A. Somebody in the City of Delray Beach building
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homeless or building shelters?
24
department would be responsible for that function. 'Mio
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A. 1 didn't say that
25
exactly. I dont know.
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Q. No, but you said the purpose is to provide --
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A. Generally speaking is what I said.
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Q. Okay. Let me ask you this. no City of
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Q. Right. And what activities would they do to
2
Delmy Beach under the imer-local agreement, they, that
3
further that goal?
3
department which you refmtd to as Mr. Tobias'
A. I don't know.
4
department. they come out and they do actual
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Q. Okay. Does the City of Delray Beach perform
5
measurements, they inspect buildings, they make sure
6
their tasks pursuant to the inter -local agreement inside
6
sockets are above a certain line and that structural
7
the City of Delray Beach?
7
integrity is --
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A. As it [elates to our inter -local agreement?
8
A. As it relates to the Florida Building Code.1
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Q. Yes.
9
do not know.
10
A. I believe they perform a function of their
10
Q. Okay. Are you the person that communicates
11
responsibilities inside the City of Delray Beach.
it
with the City of Delray Beach pursuant to their duties
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Q. Okay. What I'm getting at here is --
22
under the inter -local agreement?
13
A. I'm not sure —
13
A. I'm one of them.
14
MR. STEARNS: Where they physically do the
14
Q. Okay. Who else communicates with them?
15
job?
15
A. Our town clerk. Our occupational and building
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MR. O'BOYLE: Yes, where they physically do
16
clerk.
17
the job.
17
Q. Who is the occupational building clerk?
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MR. STEARNS: Let's say that Ile does
le
A. Its a description of her job, but that's
19
inspections of the property in the town and he may
19
Rebecca Tew. She functions as the building clerk She
20
do some paperwork or something back in Delray.
20
does the financial work. She handles occupational
21
BY MIL 0130YLE:
21
registrations.
22
Q. Is that correct?
22
Q. This is Ms. Taylor?
23
A. Yes.
23
A. No, Rebecca Tew, T -e -w.
24
Q. So he would do the inspections first?
24
Q. Rebecca as well?
25
A. I don't it now the order.
25
A. Rebecca Tew.
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Q, So she operates as a clerk for you separate
1
proceed, they need to apply for a permit
2
and distinct from the town clerk?
2
Q. Okay. rat sorry, is there more? I just
3
A. Yes.
3
wanted to let you know that I understood what you said.
4
Q. So it is you and Ms. Teawho communicate with
4
A. Okay. There may be more, I don't recall.
5
the City of Delay Beach?
5
Q. I was sort of waiting for the pan where
6
A. And the town clerk.
6
Delydy Beach gets involved.
7
Q. That would be Ivls. Taylor, correct?
7
A. They didn't get involved with this.
0
A. Ms. Rita Toylor. yes. Thafswhatican
8
Q. Okay. This was as building—okay. Wasthis
9
recall.
9
a zoning issue, this issue that you're referring m?
10
Q. Okay, Baro — I guess can you tell me a time
10
A. No. I'm sorry, I'll correct myself. It was
11
based on yaw personal knowledge that you recall calling
11
both.
12
the City of Delray Beach to perform an inspection of the
12
Q. Okay. And the incident reportwas fur the
13
Florida Building Code?
13
purposes ofzoning only or for zoning both and building?
1. 4
A. Within the last 90 days, I would say.
1-4
A. The incident report was for the purpose of
15
Q. And con you tell me a little bit about that
15
recording the activity.
2.6
process and what sort of happens.
16
Q. Okay. Just making a record?
17
A. It was observed by me that building activities
17
A. Cor'aCL
16
uam taking place an a property, and I later discovered
I 2 E
Q. All rfghL So when you observed building or
19
that a permit had not been applied for.
19
what you think to be I guess building that requires a
20
Q. And so then what happens next?
20
permit, you did not in this instance talk to Delray
21
A. Once it's determined a permit has not been
21
Beach and ask for one of their building inspectors?
22
applied for, I ask for an incident report and there is
22
A. I asked that —I think in this. it might have
23
communication by some person— could be the police
23
been Rebecca. I asked somebody to call Delray Beach to
24
officer or me. I don't recall in this Instance — drum
24
veri*, our records that a building permit had not been
25
there is work going on without a permit and that to
25
applied for.
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Q. Because Delray Beach is in charge of issuing
1
A. ComccL
2
die permits?
2
Q. So are they not responsible for enforcement?
3
A. Building permits. yes.
3
A -It didn't go that far. No, they are —
4
Q. I'm sorry, building permits, In the Town of
4
Q. I'm not talking about this particular
5
Gulf Stream, though, they have to accept the building
5
incident.
6
permits as well?
6
A. Oh.
7
A. 1 don't understand your question.
7
Q. rm talking about more generally.
e
Q. Okay. Does the Town of Gulf Stream issue the
a
A. 'Chen I'd ask you to repeat the question.
9
building permits?
9
Q. Sure. The—when you see a building and you
10
A. No.
10
look to see whether there's a permit or not and you find
11
Q. That is done through the City of Delray Beach?
11
out that there isn't one, you then call the City of
12
A. Yes.
12
Delray Beach?
13
Q. And the Cityof Delray Beach has the
13
A. I may ask somebody to du so.
14
jurisdiction to enforce the building code regulations?
14
Q. Okay, or you will ask somebody. But you'll
15
A. Florida Building Cotte, yes.
15
get in touch with the City of Delroy Beach?
16
Q. So if you sate somebody building without a
16
A. Correct
17
pern8, that's outside of3aurjob description as town
17
Q. And they have thcirown inspectors?
16
manager, outside of your duties?
18
A. Yes.
i9
MR. STEARNS: Object to the form.
19
Q. And those inspectors will come out and I guess
20
THE WCNESS: I don't believe so.
20
inspect?
21
BY MR. O'BOYLE: !
21
A. If I ask them to.
22
Q. Okay. But the City of Delray Beach, though,
22
Q. Okay. And they, if somebody violates the
23
has been contracted to deal with those issues?
23
building code, does Delray Beach handle that or is that
24
A. CormcL
24
Gulf Stream?
25
Q. Building issues?
25
A. Ifsomebody violates the Florida Building
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Code, Delray Beach would handle that
1
MR. O'BOYLE: I'm asking you, Mr. Thrasher,
2
Q. Okay. And just to be clear, the zoning code
i 2
arc you, you have no ability to set any policy
3
is, still remains with you?
3
whatsoever?
4
A. Correct.
4
MR. STEARNS. Just wanted that clear for the
5
Q. Okay. And just to help my understanding,
5
record. Object to the form.
6
zoning is outside of the house and building is inside of
6
THE WITNESS: I'd say generally that's
7
the house?
7
correct There may be some instances in which I
8
A. Repeat the question.
8
may set apolicy. I just cannot recall of ever
9
Q. Okay. Does zoning deal with matters inside
9
doing that at this point in time.
10
the house or outside the house as opposed to building?
10
BY MR. O'BOYLE:
11
A. Generally speaking, outside the house.
11
Q. Okay. So when — let me ask you this. You
12
Q. Okay. As town manager, where do you —1'm
12
have — have you reviewed the complaint?
13
sorry, what decisions are reserved for the town
13
A. Which one?
14
cammission?
14
Q. The one brought by Mr. O'Hare.
15
A. Policy decisions.
15
MR STEARNS: Which version? First. second,
16
Q. Okay. Could you explain a little bit about
16
third?
17
what you mean? i
17
BY MR.O'BOYLE:
18
A. This is a commission manager farm of
19
Q. Okay. La's — which versions have you
19
government The commission sets policy. The town
19
reviewed, of Mr.O'Hares complaint?
20
manager enforces policy.
20
A. 1 will begin by saying reviewed without
21
Q. And is completely unable to make policy?
21
comprehension. Reviewed the filings, I think by Robert
22
A. Correct. I
22
Gershman. the withdrawal finm representation by Robert
23
Q. Okay.
23
Gershman, the first amended complaint and the second
24
MR. STEARNS: I'm sorry? He is or the I
24
amended complaint
25
commission is?
25
Q. Did you review any other documents filed in
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the, in this case?
1
or Mr. Piper or the town attorney about the case.
2
A. Idon'trecall.
2
THE WITNESS:Thankyou.
3
Q. Okay. Did you ever review any motions to
3
Yes.
4
dismiss?
4
BY MR. O'BOYLE:
5
A. I — if there were such a thing, i would have.
5
Q. Okay. Do you have a common interest or Joint
6
t don't recall.
6
Defense Agreement with the Town of Oulf Stream?
7
MR. STEARNS: A brilliant work ofprose.
7
MR. STEARNS: Object to the form. No such
8
(Discussion held off the record.)
8
dung Is required. Federal law provides a
9
BY MR. O'BOYLE:
9
privilege, and that's not a question that he would
10
Q. Sot think where we were was did you review
10
know the answer to, so I'll answer for him.
11
any of the motions to dismiss?
11
MR. O'BOYLE: Okay, I didn't know ifyou have
12
A. And I believe i answered brat question. (
12
to sign one or —
13
MR. STEARNS: He doesn't remember,
13
MR. STEARNS: No. there is a privilege under
14
BY MR. OBOYLE: �
14
federal law.
5
Q. Can you say you don't remember?
15
BY MR. O'BOYLE:
16
A. I don'tremember.
16
Q. Olay. So let me go back. Do you know, did
17
Q. Okay. That's fine.
17
you know that the town was being sued as well?
18
Do you know that the town is being sued in
16
A. Yes.
19
this matter:+
19
Q. Okay. Did you see in the complaint the wards
20
A. In the matter in which you are representing
20
policy and custom?
21
Mr. O'Hare?
21
A. Don'trecall.
22
Q. Pro hac vice, yes.
22
Q. Okay. Have you heard me use those words
23
MR. STEARNS: [ just want to make sure to
23
before?
24
caution you, as you know, not to talk about
24
A. Haw c 1 heard you? 1 don't recall.
25
communications that you've had with either myself
25
Q. Okay. Let me just ask, lou did sit through
7 (Pages 22 to 25)
Florida Court Reporting
561-689-0999
B (Pages 26 to 29)
Florida Court Reporting
561-689-0999
Page 26
rt:.ge 27
1
the depositions?
1
you're not quite sure what that means?
2
A. Yes.
A. Definitely not.
3
Q. Okay. But you don't remember me using those
3
Q. Okay.
4
words specifically?
4
A. I'm sorry, no.
5
A. No.
5
Q. No and definitely not?
6
Q. Do you remember any discussions about that?
6
A. No.
7
A. No.
7
Q. They are the same thing, right?
8
Q. Policies or customs?
8
A. No.
9
A. No.
9
Q. What's the difference between —
10
Q. Okay. Do you know that those arc legal words?
10
A. Other than a singular word versus —
11
A. They sound like it.
11
Q. It's the same response, though, definitely not
12
Q. Okay. I mean that those are words that have
12
just being emphasis?
13
legal effect with regard to the town?
13
A. No, I don't believe it is.
14
MR STEARNS: Does he know that indcpcndently l
14
Q. Okay.
15
Docs he know that via something that he has been
15
MR. O'BOYLE: Can we read back the question?
16
told by his attorneys? Because you are floating
MR. STEARNS: What does it matter? Move on.
17
very closely to communications that he would have
i16
17
(A portion of the record was read by the
18
had, and dtafs improper questioning.
18
reporter.)
19
BY MR. O'BOYLE:
19
(
THE WITNESS: Can I strike that?
20
Q. Excluding communications with your attorneys.
20
MR. STEARNS: Change it to no.
21
unless you've talked to anybody else about that outside
I 21
THE WITNESS: I'm going to change it to no.
22
ofYom attorneys —
22
BY MR.O'BOYLF.:
23
A. I don't know. I don't recall. And I'm not
I 23
Q. Okay. Outside of the Icgal context, do you
24
being evasive. Ijust don't recall.
24
generally understand what policy or custom, what a
25
Q. Okay. So when you say policy or custom,
I 25
policy is?
Pago 28
Page 29
1
A. Did you instruct me that I didn't have to
1
A. I don't know.
2
generate or answer from opinion?
2
Q. Okay. You have, you never used the word
3
Q. No, I didn't instruct you.
3
policybefore?
4
A. So I don't have an answer to that. I dont
4-
MR. STIE DINS: Object to the form. This is
5
know.
5
improper questioning and harasssive and
6
Q. You don't know what the definition ofpolicy
6
argumentative.
7
means? Okay.
7
THE WITNESS: Yes.
8
MR STEARNS: You arc asking for legal arms,
8
MR. STEARNS: I'm going to instruct) ou to
9
and outside orwhat the legal term is, it makes no
9
move on.
30
damn difference if he knows what it means.
10
BY MR. O'BOYLE:
11
MR O'BOYLE: If a legal term and a toy term
11
Q. Okay. Thank you.
12
have die same word, then rve got to distinguish
12
So going back to a couple of minutes ago, you
13
between the two.
13
said that the town commission sets policies. You
14
MR. STEARNS: A municipal custom and policy is
14
enforce them.
15
a legal temp. Ite's not an attorney. He's not
15
A. Yes.
16
going to explain to you what he thinks it means.
16
Q. Is that correct?
17
MR. O'BOYLE: Right, but I need to know —
17
A. Yes.
18
MR. STEARNS: You have a dictionary in front
18
Q. Okay. i asked you then what policies do you
19
ofyou, so look it up when you want to.
19
set? And you — or did you set policies? And you said
20
BY MR O'BOYLE:
20
generally, no, but what policies do you create for the
21
Q. hfr. Thrasher, do you know what the word policy
21
town?
22
means outside of tie ]aw'?
22
A. As I answered earlier, I do not recall.
23
MR. STEARNS: Object to the form.
23
Q. Have you ever told town staff, as town
24
BY MR O'BOYLE:
24
manager, that things need to be done a certain way?
25
Q. And used in a general context?
25
A. 1 don't recall.
B (Pages 26 to 29)
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9 (Pages 30 to 33)
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Page 30
Page 31
1
Q. May. Let me ask this. Which employees are
1
municipal policy or custom. not wits[ kind of shoes
2
you responsible far?
2
you ww, what time you get to work. None of that
3
A. I believe myjob description code. all of
3
makes any difference, and it's just a waste of all
4
them.
4
of our time.
5
Q. What happens when an employee comes in late?
5
BY MR O'BOYLE:
6
A. Don't recall that happening. but I'm sura it's
6
Q. Mr. Thrasher —
7
happened. I haven't penalized anybody, if that's what
7
A. Yes.
8
you mean.
8
Q. What policies do you implement Cur your
5
Q. No, not in particular, but have you everssid
9
employees?
10
to anybody "You need to show up at nine in the morning
i o
MR. STEARNS: Move on. Pm going to fnswm
11
or eight in the morning"?
11
you not to answ er. Move on.
12
A. I personally. no.
12
BY MR O'BOYLE:
13
Q. But you are responsible for the town employees
13
Q. What policies do the commissioners sal? Pm
14
over there for showing up on time?
14
sorry. No, why don'tyou answer that one first.
5
MR STEARNS: Counsel, how is this possibly,
15
You told me prior that the commission sets
6relevant
to the issues in this case?
i 6
policies, } ou cofor� them.
:7
MR. OTiOYLE: This is about esta6lishtng
17
What types of policies? Are there any general
18
policies, Chris.
ig
areas orpoucies?
19
M.R. STEARNS: What a policy is. Pm going to
19
A. Personnel.
20
help you with. a policy is a policy of unlawful
20
Q. Can you maybe delve into that a little bit
21
discrimination. Not what time you get to work.
21
mom?
22
It's got to be a policy of retaliation.
1. 22
A. l don't understand your question.
23
That's what you need to ask questions about,
23
Q. Okay. is ft the commissioners job or is it
24
other people that have been retaliated against.
24
yourjob to let's just say implement a sexual harassment
25
[hugs lika that. TMI's what's relevant to a
25
policy?
Page 32
Page 33
1
A. I believe sexual harassment is addressed in ff
1
Q. What was hisjob?
2
the personnel manual. I
2
A. lie was a swum police officer that towards the
3
Q. Okay. You're responsible for the personnel I3
end of his career with Gulf Stream assisted me as a
4
manual?
4
part-time employee, assisted me with code en:brcemcnt
5
A. I dont create it.
5
Q. Okay. So did you have to deputize him?
6
Q. Okay. Do you adopt il?
6
A. No.
7
A. No.
7
Q. Did you have to appoint him?
8
Q. Okay. Who adopts it?
8
A. I asked him to help me on certain matters.
9
A. The town commission.
9
Q, Okay. So there was nolhing official?
10
Q. Okay. When did they adopt the personnel
10
A. I didn4 say than.
11
manual?
11
Q. Okay. Well, what was the official act that
12
A. Throughout the years. I don't have, I don't
12
empowered W. Ginsberg to help you?
13
recall.
-.3
A. I don't know the answer to that question.
14
Q. Okay. Are you —1'm sorry, you said that 1
14
Q. Okay. So thenjust explain to me then how
15
yourjoborpart ofyourjobwas chief —or I'm sorry, 1
15
Mr. Ginsberg became an assistant or a code enforcement
16
building and planning administrator?
16
person that worked with you.
17
A. Something of that nature. It's defined by
17
A. He assisted me in code enfarcanent. Was
. 18
code, I believe.
18
presorted to tic town commission as an idea for
19
Q. And you have the ability to appoint a code
i9
implementing and financing, and it was approved.
20
enforcement officer?
20
Q. Okay. Financing him as trade enforcement?
21
A. No.
21
A. Yes, part-time code enforcement activities.
22
Q. Are you the code enforcement officer?
22
Q. And what financing would that require?
23
A. Yes,
23
A. Appropriations from the town commission.
24
Q. Do you know who Mr. Ginsberg is?
24
Q. For what? Because he was already a police
25
A. Yes.
25
ofieeratthe time, correct?
9 (Pages 30 to 33)
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111 (Pages 39 to 3'I)
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Page 34
I
Pace 35
1
A. Uh-huh.
1
MR. STEARNS: He is a code enforcement
2
Q. So what further appropriations were necessary?
2
officer.
3
A. He wasn't functioning 1 don't believe as a
3
BY MR. O'BOYLE:
4
full-time police officer at the time, and the concept
4
Q. Wait. Is he a code enforcement officer or
5
was implemented in 2008. I'm guessing. I'm not sure.
5
not'?
6
Q. Okay. Did you pick Mr. Ginsberg out or did he
6
A. I do not believe that he is. I believe I'm
7
have to send in an application?
7
the code enforcement officer who, he would assist me
6
A. That's something you need to ask Chief Ward.
8
with gathering information, for me to make a
9
He is a police officer. I don't get invoh ed with that
9
determination whether a code violation exists.
20
aspect of it
20
Q. Okay. So —well, tell me a little bit more
11
Q. Right, but I'm not asking how he became a
11
about that relationship.
12
police officer. I'm asking about how he became code
12
Did you tell him to go out and do things or
13
enforcement, a code enforcement officer or code
13
did he. as his duty as a police officer, drive around
14
enforcement offeer with yourself.
14
and also see code enforcement issues and bring them to
15
A. I generally believe that Chief Ward cad I
15
you, or how did that —
16
discussed the concept.
16
A. Could 3 ou simpli6, your question, please?
17
Q. Okay. Was anybody else madecodcenforcement i
17
Q. Sure.
18
officer with Mr. Ginsberg?
16
A. You lost meabout30seconds ago.
19
A. In.
19
Q. All right. R'cold you direct Mr. Ginsberg to
20
Q. So he wasjust there to be an assistant for
20
perform code enforcement activities?
21
you or was he there to stand in your place?
21
A. Not initially.
22
A. He was thereto assist me.
22
Q, Okay. Initially what was the relationship?
23
Q. What were his duties as assistant?
23
A. I would request Chief Ward for assistance.
4
MR. STEARKS: Not assistant
24
Q. And itvvould be Mr. Ginsberg exclusively?
25
THEWITNFSS: Assistant what?
25
A. No.
111 (Pages 39 to 3'I)
Florida Court Reporting
561-689-0999
Page 36
Page 37
1
Q. So any police officer of —by the way, well
1
A. I didn't say that
2
establish Chief Ward is the chief -cif -police for tha Town
2
Q. Okay. But he expressed interest in being a
3
of GulfSomarn, correct?
3
code enforcement officer?
4
A. That is correct
4
A. I d rA ta!k m him about it.
5
Q. Okay. So chief, you would contact Chief Ward
5
Q. Okay. And he didn t send In an application?
6
and he would send one of his officers over to assist you
6
A. I don't know.
7
in a code enforcement action?
7
Q. Okay. So I just want to get this straight.
a
A. 1 would contact Chief Ward and request his
8
All you remember is that you had asked Chief Ward for
9
assistance. How he helped me with that, it was his
9
assistance and then you would discuss a concept
30
decision.
10
regarding David Ginsberg being a code enforcement
11
Q. So sometimes an officer would be sent,
'_i
officer and then his position was approved?
12
sometimes an officer would not be sent to assist you?
12
A. Mr. O'Boyle, I do not understand that Bow or
13
A. Yes.
13
questioning.
14
Q. And it was not exclusively Mr. Ginsberg?
14
Q. Okay. N no talked to Mr. Ginsberg about
15
A. Correct.
15
bacoming a code enforcement officer under the concept
16
Q. So how did Mr. Ginsberg than become
16
that you and Mr. Wind discussed?
17
exclusively a code enforcement officer?
17
A. I believe Chief Ward did.
18
A. There was a budgetary concept that we would
18
Q. Okay. So it would be Chief Ward who had the
19
augment that portion of the budget for that purpose ad
19
conversations with Mr. Ginsberg, and you were just told
20
maintain a budgeted level for police officers.
20
David Ginsberg is your guy?
21.
Q. Did Mr. Ginsberg .-and Ion asking really why
21
A. I didnI say that.
22
Mr. Ginsberg did he stand out?
22
Q. Okay. See, I'm hating a hard time here
23
A. No, be, I believe he didn't want to work full
23
getting between you asking Mr. Ward, Pm sorry, Chicf
24
time.
24
Ward for assistance or discussing a concept in terms
25
Q. Sothis was just a financial decision?
25
of -
111 (Pages 39 to 3'I)
Florida Court Reporting
561-689-0999
11 (Pages 38 to ;1)
Florida Court Reporting
561-689-0999
Page 38
Page 39
1
A. ICI said that, l misled you.
t
1
represent and am responsible exclusively for that
2
1 dont know really where that came from. If
2
function.
3
1 mid it, I must have misunderstood the question.
3
How I accomplish the task can be through
4
Q. Okay. Hos, did David Ginsberg become code
4
assistance of various people.
5
enforcement officer, tither code enforcement officer or
5
Q. Okay. That's your understanding under the
C
an assistant to you?
6
code?
7
A. He was neither orthose. I fe was not assistant
7
A. Yes.
9
to me nor a code enforcement officer. He functioned to
6
Q. Okay.Andyou'vebeen —and nobody has told
9
assist ma
9
you different?
10
During budget considerations on an annual
10
A. No, not that I recall.
11
basis, chierand I discussed manpower.
12
Q. So when you said before that you delegated
12
And in those discussions this concept of a
12
you powers to the town clerk, Ms. Taylor, in your
13
person in the police department to assist me was
13
absence, she would then become the code enforcement
14
discussed. And chief would sometimes, because he was a
14
officer?
15
swam ofEw, would use him primarily for his police
15
A. That is correct.
16
officer requirements.
16
Q. Okay. And she would be able to deputize
17
But to implement such a thing required
17
certain employees to assist in that?
:8
appropriations from the commission.
19
MR. SIEARNS: Object to the form.
19
Q. Okay. So David Ginsberg did not volunteer for
19
THE WITNESS: No, no deputies. It's a request
20
this?
20
for help.
21
A. I don't know. I don't know how that happened.
21
BY Iv1R. O'BOYI.E:
22
Q. Okay. And when you say he's not a code
22
0. Okay. And the request for help —well, let
23
enforcement officer and he's not —
23
me ask you. you've made requests for help in regard with
24
A. Technically by code, if I can correct, I am
24
code enforcement. right?
15
the milt code enforcement officer. I initiate and
_— _
25
A. Correct.
Page 90
.—_—
. Page 41
1
Q. And what do those requests for help look like?
1
of only pass a little hit through Gulf Stream. or do you
2
Do you remember any?
1
2
come from the south and pass through the bulk of Gulf
3
A. Primarily verbal. asking for verification of a
3
Stream?
possible violation.
4
A. Generally from the north.
5
Q. And hove would you become aware of a passible
5
Q. Okay. And Gulf Stream. I mean just so we m
6
violation?
6
clear, the north of town hall, haw much. Imam Is then e
'7
A. Various manners I could be notified by a
7
only about a quarter mile of road that is Gulf Stream?
8
resident I could observe them myself. A police
8
A. I don't know tie answer to that
9
officer could observe it. Our maintenance people could
9
Q. Okay. is the majority of the town south of
10
observe it, as an alleged violation.
10
the town hall?
11
Q. When you said you could observe ityou=14
11
A. Yes.
12
do you patrol?
12
Q. Okay. Did you ever come in through the south?
13
A. I used to do that more than I do now, but it's
13
A. Yes.
14
not outside of my scope of work.
14
Q. Okay. And that would be AIA?
15
Q. Okay. In 2011 were you patrolling more
15
A. Could be AIA or Federal Highway.
16
frequently?
16
Q. All right Now, Mr. Ginsberg, was he asked to
17
A. Generally, I would answer yes. 1 don't really
17
patrol to assist you in patrolling for code violations
18
recall. I don't keep those kind of logs.
is
or -
19
Q. Okay. About how frequent would you patrol?
19
A. I think initially he was, but I'm not sue.
20
A. In the core district and Place Au Soleil, I
20
Q. Did he do anything else?
21
strive to. at least once a week. Obviously as I drove
21
A. You'd have to check with Chief Ward 1 don't
22
to work I might spot something In this area
22
know.
23
Q. And when you drive to work, which way do you
23
Q. I mean in terns orcode enforcement
24
come into Gulf Stream?
24
A. Did he do anything more?
25
Do you come in from Woolbright and then sort
25
Q. Right, than patrol.
11 (Pages 38 to ;1)
Florida Court Reporting
561-689-0999
12 (Pages 42 to 45)
Florida Court Reporting
561-689-0999
Faye 42
I
F3ge 43
1
A. He would investigate alleged violations.
?
MR. STEARNS: You have to accept that one.
^.
specific.
2
'RHE 1X7TNESS: I'm an employee for the Town of
3
Q. Okay. Would he serve people with notices
3
Gulfstream.
4
or—
4
BY MR. O'BOYLE•:
5
A. Could you clarify that?
5
Q. I know, 1 understand you are trying to be
6
Q. Yes. Would he give people pieces of paper
6
humble.
7
sating that you are not. or that you arc violating the
7
A. No, I'm not. That's how I believe.
a
town code?
6
Q. I'm sora?
9
A. He might be a delivery person. We do deliver
9
A. That's what I belier e. I'm an employee of the
10
notices of that sometimes. Sometimes we mail them. But
10
Town of Gulf Stream, like any other employee we have.
11
1 would suspect that from time to time he has delivered I
11
Q. But you have mote responsibilities?
12
paperwork of some different types.
12
A. Yes.
13
Q. But he is, he would be delivering paperwork I
13
Q. Okay. When you — okay. When you assist.
14
issued by you?
14
when you ask for assistance or help for code
15
A. Could be me or by Rita Taylor
15
enforcement, do you have to directly supervise them?
16
Q. Right. I guess the lop officials of the town i
16
A. No.
17
Would you consider yourself and Rim the top officials
i7
Q. Okay. How does that help or assist, I mean
18
outside of the elected officials?I
'- E
hm% does that work?
19
A. ] don't lite the reference. III
19
A. Could you clarify your question?
20
Q. Okay. 1 he highest officials? I
20
Q. Sure. You, Pm assuming, reach out m
21
A. Still don't like the reference. I
21
somebody and say I need assistance?
22
Q. Okay.
22
A. Could you identify that person or position?
:. 3
MR. STEARNS: Chief executive officer. I
23
Q. A police officer for code enforcement. You\ L
t
BY MR O'BOYLE:
-
also asked Rim to help you?
S
Q. Okay. Chief executive officer?
'-
A. What isyour question?
12 (Pages 42 to 45)
Florida Court Reporting
561-689-0999
Page 44
!
Page 45
1
Q. Okay. My question is do you supervise the
( 1
get to the facts of the case and what has actually
2
town employees or agents when they arc perforating code
2
occurred here?
3
enforcement tasks?
3
MR- O'BOYLE: Sure.
4
A. Would you spccificully identlt)• a r pe or
4
BY MR. O'BOYLE:
5
position of employing?
5
Q. When you ask for assistance for code
6
Q. Okay, let's start with a police officer. You
6
enforcement, do you provide any tmining?
7
have asked the police for help.
7
A. No.
e
A. ( Willi= nods head up and down)
B
Q. Do you provide direction?
9
Q. Than you would supervise them?
9
A. Yes, to some employees.
10
A. No.
(
30
Q. To others, you did not provide direction?
11
Q. Okay. Who would supervise them?
11
A. The police department, I do not provide
12
A. ItwouldbeCltiefP'ard'sresponsibilfty.
12direction
to the officers.
13
Q. For performing code enforcement activities?
13
If I were to ask for assistance from my
14
A. For obtaining information to verify an alleged
14
maintenance personnel, I would give direction.
15
complaint.
15
Q. Okay. In 2011, Mr. Ginsberg, did you provide
16
Q. Okay. So when you asked for essismnce — let
16
him with any training?
17
me back up here. When you asked for assistance. you're
17
By the way, I'm not asking about in 2011,
18
asking for assistance in Investigation?
28
Mr. Ginsberg, 2011, so Mr. Steams knows I'm talking
19
A. I dont know the answer. I would ask for
19
about something in the complaint.
20
reification of an alleged complaint.
20
Mr. Ginsberg, when he became an assistant or a
21
Q. okay. So that would be if— let me back up.
21
part-time assistant —1'm sorry.
22
You wouldn't call that an investigation?
22
At,. Ginsberg, when he was working with you,
23
A. I wouldn't, no.
23
what do you want to call him? Because I know you
24
Q. Okay.
24
said -
25
MR. STEAMS: This is semantics. How about we
25
A. Call him Mr. Ginsberg.
12 (Pages 42 to 45)
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Page 46
Page 47
1
Q. Right. but when I say call him, you said he's
1
participate in code enforcement?
2
not a code enforcement officer. You said he was an
2
A. That's a question to be answered by Chief
3
assistant code enforcement officer.
3
Ward,
4
What should we call him? How do I identify
4
Q. Okay. You receive code enforcement complaints
5
Mr. Ginsberg Harking with you on a part-time basis for
5
from police officers?
6
code enforcement?
6
A. 1 usually, if I hear of anything, it is a
7
A. He vvos and 1 think still is a svom Florida
Iquestion
mare than anything else, is this a violation of
8
police officerM1toseassignments were toassist me
8
acode?
9
gathering information on alleged code violations.
9
And than at that point. an incident report and
10
Q. Okay. The position that was appropriated from
10
information is gathered.
11
the town commission?
'-1
Q. Okay. When the say the code, the town rade. we
12
A. Correct.
I 12
were talking about the entire town code, the record that
13
Q. Okay. So did you provide Mr. Ginsberg with
13
you woWd receive from police officers?
14
any training when you had that relationship with
14
A. Could you cluif-v your question?
15
Mr. Ginsberg?
15
Q. Sure. The town code has many chapters in it.
16
A. No.
16
A. Yes.
17
Q. Okay. Did you have any training for code
17
Q. Let me ask this. Do die police officers
18
enforcement?
16
report suspected incidents of Chapter 66 and Chapter 70,
19
A. No.
19
the town code?
20
Q. Do you Mow if other towns within this area
20
A. I don't recall.
21
have trained their code enforcement officers?
2 i
Q. Do you Mow 11 hat Chapter 66 is in the town
22
A. I don't know.
22
code?
23
Q. You said--I'msorry.letmejustaskthe
23
A. Generally.
24
question instead ofrefieuhingyour memory.
24
Q. The zoningprovision7
25
Arc all police officers expected to
25
I
A. Yes.
Page 48
Page 49
1
Q. Okay. And Chapter 70, the design manual?
1
A. Yea.
2
A. Chapter 70I think is identified as the design
2
Q. Okay. What discretion or wbat guidelines have
3
manual. It's part of the code.
3
you implemented for enforcing the town code?
4
Q. Right. So because I do Mow that there is
4
is there any prosecutorial discretion?
5
other parts of the code that talk about parking and
5
A. I don't understand the question.
6
such, but the reports that you would get from police
6
Q. Do you have discretion to what to enforce as a
7
officers, have they ever been with regard to zoning or
7
violation or not?
8
design, Chapter 66 or Chapter 70?
8
A. Toa certain extent 1 believe I do.
9
A. I don'trecall such.
9
Q. Okay. And whatguidelines do you follow, or
1 c
Q. Okay. And these arc —
10
tell me little hit about that discretion.
11
A. May I strike that and ask you to repeat the
11
MR. STEARNS: Object to the form. Go ahead.
12
question?
12
TI If: WITNESS: I don't recall. i just,
13
Q. Yes.
13
typically generally I do have that discretion.
14
MR. STEARNS: You certainly may.
14
BYMR.O'BOYLE:
15
BY MR. O'BOYI.E:
15
Q. And are there any factors that you consider
16
Q. Yes, of course.
16
whim exercising that discretion?
17
A'hen the police would give you ups, incident
17
A. More recently, if there is open litigation.
18
report, let you know that somedting was going on with
18
live active litigation.
19
the code, have you personally witnessed the police
i9
Q. And that is a factor for determining whether
20
gn ing 1 ou those tips or hints or incident reports with
20
to prosecute somebody under, for a core violation?
11
regard to Chapter 66, Chapter 70?
21
A. Can be.
22
A. Yes. 1
22
Q. Okay. Are there any other factors?
23
Q. And I don't rally rare if somebody's dog is
23
A. Don't recall.
24
running loose cr something likethat. I'm talking about
24
Q. Okay. How about resources?
25
mile enforcement issues.
25
A. No.
13 (Pages 46 tn 49)
Florida Court
Reporting
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14 (Pages 50 to 53)
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Page 50
page 51
_
Q. Okay.
1
dummies. Tm talking about if code violeGan comes to
2
A. Can I strike thal?
2
your attention and you say I done[ want to prosecute
3
Q. Sure.
3
that because it's either not in the benefit of the town,
4
A. And ask you to clarify the question, please?
4
that we just don't have the manpower to go out there and
5
Q. When determining whether- Ict'sjust say you
5
enforce it.
6
have identified a suspected alleged code violation. you
6
A. 1 think that the restraints maybe time at
7
identified it, but you decide not to enfame the code.
7
this les all ofresponsibility. So there arc some
e
i was asking what factors you use to determine
a
msoumcs that we such that would delay the
9
whether to enforce the code or whether to not enforce
9
investigation of an alleged incident.
10
the code.
3 0
Now if that's w hal you mean by process —
11
A. And I said—
11
whatever you said. times what I would like to make
12
MR STEARNS: He was talking about the
12
clear.
13
msourres.
13
Q. Sure. And I'm going to has c some follow-ups
14
THE WITNESS: Resources, the word resources is
14
here, but let me be more dear.
15
what I'm talking about.
15
When 1 worked at the FAA, then: were certain
16
MIL STEARNS: Do you mean does he have a book
16
violations we just didn't pursue because a
'r
on code enforcement for dummies or does he have the
17
strongly -warded letter would get the same job done and
code?
is
we (rankly couldn't go atter everybody all the time.
9
771E WITNESS: Clarify msoutecs.
19
A. I don't think I have that discretion. 1 think
20
BYMR. O'BOYLE•
20
as they come in, 1 have a responsibility. How I
21
Q. Okay. Resources, I'm going to use that word
21
prioritize my time and activifies and demands on me is a
22
broadly. Obviously I'll tell you v. hat I'm not talking
22
discretion ft, I'm ref:rringto,
23
about
23
Q. Okay. So that discretion, 1 just wren[ to be
24
I'm not talking about whether you have code
24
clear. That discretion was the discretion whether to
25
hooks, sufficient code banks or code ehhferremenl Por
I 25
initiate a code enforcement hearing to send out a letter
Page 52
Page 53
1.
or to investigate — talk a little bit more about that.
i
notice. The objective is to seek and obtain compliance.
2
A. That was referring to investigation or review
2
Q. Okay. And if somebody were to comply, then
3
of the alleged complaint.
3
nothing happens?
4
Q. But once you have an investigation completed.
4
A. Correct.
5
1 mean is there any discretion as to whether to send out I
5
Q. Okay. Is there ever a time where you saw that
6
a notice letter?
6
they were not in compliance and you said well, I'm not
7
A. 1 may determine that there's not a violation
7
going to prosecute this right now, it's not a big enough
8
and then —
8
deal for me?
9
Q. That's a good reason not to send one out, but
9
A. What do you mean by prosecute? Could you
i 0
let's say you have determined that there is a violation.
10
define and clarify that for me?
ii
is there any reason not to send out a code
11
Q. Sure. As building administrator, building and
12
enforcement letter?
12
planning administrator, You determine whether to
13
A. Yes.
13
initiate code enforcement proceedings, right?
14
Q. What reasons have you used in the past?
14
A. First step is to have information provided to
15
A. We primarily try to communicate individually
15
me of the alleged complaint or violation. Not
16
with the offender or the person involved with the
16
necessmily immediately set out for special magistrate
17
alleged violation to discuss the matter with them.
i7
proceedings.
18
That's primarily and generally the first thing that w c
18
Q. But you arc the person that determines whether
19
do.
19
to call up the special magistrate or not?
20
Q, And when you say discuss, do you call them at
20
A. I am one of them.
21
their hoose or do you —
21
Q. W'ho else makes that determination?
22
A. Well, it could vary. It varies.
22
A. Our town attorney assists mein sending those
23
1 believe I have spoken with them in my —
23
letters ovL
24
with some in my office with our clerk.
24
Q. Assists you Ina clerical or ministerial %my
25
I believe thhat I have sent out a courtesy
25
or assists you in —
14 (Pages 50 to 53)
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Page 59
pane 55
1
A. Assists me with the points of law that we are
1
Olay, perform i guess an inquiry into.
2
potentially citing.
2
A. Yes,
3
Q. Right. But it is you who say I want to bring
3
Q. Okay. Are all the town employees given a code
4
this to a code enforcement hearing, I —
4
book when you ask them to assist you in code
5
A. Well, I know this is a tedious point, but 1
5
enforcement?
6
never want to bring anything to a special magistrate.
6
A. No.
7
Q. Why is that7
Q. So how do they know what they're looking for?
9
A. It's, it's time consuming. It's costly. It
8
A. I ask them to gather information about the
9
Is difficult, and it's not something that I enjoy.
9
alleged complaint.
10
Q. You would mtherjust have the resident just
30
Q. And the complaint would be —
11
comply with the code or at least your understanding of
11
A. Strikc that. I dont ask them. I direcimy
12
the code?
12
questions as it relates to a police officer to Chief
13
A. Correct.
13
Ward. If I am using. as I said earlier, a maintenance
14
Q. Okay. Do all suspected violations require an
14
personnel. I would give them instructions and tell them
15
investigation?
15
what I need.
16
A. They require evidence.
16
Q. Okay.
17
Q. Righ4 but ifa police officer, a resident, or
17
A. What I think I need.
19
ifyou observed something yourself, do you require at
18
Q. Okay. By the way, as (mm manager, do you
19
least some level ofinvestigafion?
15
have supervisory capacity over Chief Ward?
20
A. Yes.
20
A. Iwouldsayno.
21
Q. Okay.
2i
Q. You would say no, or that's a definite no?
22
A. Actually, may I strike that and ask you to
22
A. Personally, no.
23
define investigation?
23
Q. You mean as a maner of fact or as a matterof
24
Q. Sure. Let's see if] can get a little help
24
your duties?
25
here.
25
A. 1 dont recall ever trying to supervise Chief
Page 56
Page 57
1
Ward.
1
at one. I'm not sum about the word demand. It's
2
Q. I was going to say I assume you guys are
2
obviously from the town. It has significance, l would
3
colleagues and you work w•e?l together.
3
hope, to the person that receives the letter.
4
A. I believe so.
4
Q. But you don'tsend a courtesy letter and
5
Q. But 1 didn't know if them was a hierarchy.
5
expect the resident to do nothing?
6
A. No.
6
A. No, l — no.
7
Q. Okay. What can you tell me about remediation
7
Q. So it is a demand?
9
pe Ms in terms of code enforcement?
8
A. I again do not undersand the word demand.
9
A. Idont. understand yourqucstion.
9
Q. Okay.
10
Q. Sum. When you send out a code enforcement
10
A. What is so funny'? You asked me a question. I
ll
letter. courtesy letter, Notice of Violation — by the
11
answered it.
12
way, is them a differance between the two?
12
Q. Sae.
13
A. Yes.
13
A. i don't know w•hy everybody stared laughing
14
Q. Can you tell me what that difference is?
1;
It's an insult.
15
A. Official. One is not official. One is
15
Q. A demand —
16
official.
16
MIM. STEARNS: We all understand what the word
17
Q. The courtesy is —
17
demand means. The problem is in your question.
18
A. Courtesy.
SB
BY MIL O'BOYLE:
19
Q. Saying that we will do XY and Z unless you do
19
Q. Okay.
20
A,B C?
20
A. Its purpose is to seek and obtain compliance.
21
A. Sometimes that may be part ofthe language.
21
Q. Right. And you, the resident, will do this or
22
It is trying to communicate to the resident.
22
else we're going to take you to a code enforcement
23
Q. It's a demand without carrying particular
23
hearing?
24
weight to it; is that fair?
24
A. Its purpose is to communicate an alleged
25
A. You know, it's been awhile since I've looked
25
violation, seeking compliance.
15 (Pages 54 to 57)
Florida Court Reporting
561-689-0999
16 (Pages 58 to 61)
Florida Court Reporting
561-689-0999
Page 58
Page 59
1
Q. Voluntarily?
i
what amount of time is required for remediation?
2
A. Yes,
2
A. I don% know the answer to that question. f
3
Q. Okay. And in what, who decides whether to
3
think it could vary, but there may be a minimum amount
4
send out it courtesy letter?
I 4
oftimm
5
A. 1 do.
5
Usually at that Iced, l seek legal advice,
6
Q. Okay. And is there a general category of code
( 6
and that advice may include such timelines.
7
enforcement violations where you would send out a
7
Q. Okay. So I mma if something is not an
6
courtesy letter before a citation?
f 6
emergency. is then: a standard or a customary —
9
A. 1 don't know the answer to that question.
9
A. i dont recall. Again, as it gets to that
10
Q. Can you recall any courtesy letters thatI
10
level, I'm seeking legal advice.
11
you've sent out?
11
Q. Sure. Then general]). not specifically, is it
12
A. 1 recall sending out courtesy notices, but I
12
I
usually more than ten days you giw somebody?
13
can't recall a specific one.
• 3
A. 1 dolt recall. Jonathan, Mr. O'Boyle.
14
Q. So that means, just to be clear, that you
I 14
Q. You can call me Jonathan. That's fine. Chris
15
can't recall why you decided to send out a courtesy I
15
does.
16
letter?
16
A. i understand,
17
A. No.
17
Q. Okay. So — well, lel me ask )on this. You
28
Q. Okay. When y on send out a courtesy letter, do
1 a
don't usually give people one day or two days to fix a
19
you give the resident a particular number of days to —
I
15
problem?
20
A. That would bean official notice, a certain
20
A. 1 have.
21
number of days. (
21
Q. Are there any particular instances that stand
22
Q. Okay.22
I
22
out?
23
A. That's not a courtesy notice.
23
A. Not that [ recoil.
24
Q. Okay. So than what is, what's required when I
24
Q. Like a, something like a nuisance, like they
25
you said somebody a, we'll call it an official notice,
25
have a raulmnake bush or something, got to get diat
16 (Pages 58 to 61)
Florida Court Reporting
561-689-0999
Page 60
Page 61
1
out of there?
1
1
Q. Tben what —
2
A. Definitely not that
2
A. I think notice to them.
3
Q. Oksy. Do you ever speak with the commission
3
Q. Okay -
about instituting code enforcemcm proceedings?
4
A. I think.
5
A. I think I baso
j 5
Q. Allright Havc you ever sought clarification
6
Q. Over the course of your history with the town?
6
from the commission on any code enforcement action?
7
A. I believe 1 have once.
7
A. No.
8
Q. Okay. What incident or. I'm sorry, what was
6
Q. And I just want to be clear. You haven't
9
that conversation like for that particdar event that
9
communicated nidi ]lie commissioners or mayor for any
30
Ino described?
10
code enforcement actions?
11
A. I don't recall, but it was in a public
11
A. Would) on simplify the question?
12
hearing, in a commission meeting. I don't recall what
12
Q. Okay. have you ever communicated with the
13
ecoctly it was about, but I do believe that at one point
13
commissioners or mayor asking for guidance in a code
14
in time I may have communicated that we need to proceed.
14enforcement
matter?
15
but I just don't recall what I said and I'm not even
15
A. No.
16
sure that tie event took place. Just that's my memory.
16
Q. Okay. But commissioners and mayors have
17
Q. Okay. But so —
17
reported cote violations to you?
16
A. It was many) ears ago.
18
A. No.
19
Q. Okay. It did not involve —14
Q, Okay,
20
A. Over a decade ago.
20
A. They have asked me questions, whether
21
Q. Okoy. where you sought clarification —
21
something is allowed in town, but they haven't directed
22
A. 1 didn't seek clarification, no, from the
22
me or stated such a violation exists. They asked me if
23
commission.
23
one does exist.
24
Q. On that issue? I
24
Q. All right Do you know who Commissioner
25
A. No.
25
Orlhwein is. for the record?
16 (Pages 58 to 61)
Florida Court Reporting
561-689-0999
17 (Pages 62 to 65)
Florida Court Reporting
561-689-0999
Page 62
'
Page 63
1
A. Yes,
I
1
the center of Polo Cove?
2
Q. Okay. Did she communicate something about a
['
MR. STEARNS: Talking about Mr. O'Hare's boat,
3
boat in Polo Cove to you?
3
yes?
4
A. She asked me if that was a violation. That's
s
MR. O'EOYLE: Yes, Mr. O'Elare's bast Sorry,
5
all I can recall. She didn't direct me and she didn't
5
Commissioner Orthw ein didnt play games with that.
6
state it was a violation.
6
MR. STEARNS: Do you know about Mr. O'Hare's
7
Q. Did she—well, how did that communication
7
boat?
8
go" Was that an e-mail?
0
THE WITNESS: I know of it being there at one
9
A. A verbal. And 1 dont recall what exactly was
9
point in time.
10
said or where it was said.
10
BY MR. O'EOYLE:
11
Q. Okay. So you can't remember if it was verbal
11
Q. Okay. And that's from Commissioner Orrin, tin?
12
or if it was --
12
A No. 1 don't think at that time we knew who
13
A. No, it was; verbal. That I remember.
13
the boat belonged to. It was a boat that had been
5.4
Q. Okay. And this was a telephone call?
—4
placed there by a person or persons unknown,
15
A. No, it was face to face.
15
Q. Okay. Were there any distinctive features
16
Q. Okay. Do you remember about what time that
16
about the boat?
27
was?
17
A. It obt iously had objects of art. I would say,
18
A. Don't recall.
is
located on the boat It seemed to he small in nature.
19
Q. Was it the first time that you had heard about
19
That's about all I remember.
20
a boat in Polo Cove?
20
Q. When you say objects eart — Pm sorry, did
21
A. I don't recall.
21
you say objects of an or objects d'art?
22
Q. Well, tell me about the boat in Polo Care.
22
A. Let me just say they wrote in my opinion art
23
A. It was a boat in Polo Cove.
23
Q. Is there a difference between an object of art
24
Q. And just to be clear, there Is many boats in
24
and an object d'art?
25
Polo Cove, but this 6 one that was anchored 1 guess in
25
A I don't know.
17 (Pages 62 to 65)
Florida Court Reporting
561-689-0999
Page 64
(
Page 65
1
Q. Okay. Is objects d'art in the code?
I
1
think it's a creation by perhaps a person or tiring whose
2
A. i think there is some reference to that in the
purpose is to pmvid: art appreciation to the creator,
3
code, in the later part of the code.
3
the us~r or the obsen cror all three. 1 rally don't
4
Q. Okay. The latterpact. Is that Chapter70?
4
know how else to define t§at for you.
5
A. Latter put of 70, yes.
5
Q. Okay. Is it primarily thr c -dimensional or
6
Q. What about objects Can or objects of an?
G
two-dimensional? Is there any dimensional distinction?
7
A. They fall within a section of our code that is
7
A. I believe that it could be both.
8
identified as prohibited from view from the mad, or
E
Q. So a sign could be an object d'art^
9
something of that nature.
9
A. I don't know the answer to that question.
10
Q. Okay. Do you need to see that section of the
10
Q. Well, haveyou ever seen any signs by
11
code?
11
Mr. O'Hare? Have you seen any signs that he's ever
12
A. No.
12
displayed?
13
Q. Okay. Obviously you know it by memory?
13
A. I dont recall.
14
A. No, but T don't need to sea it Can't you ask
14
Q. Okay. How• about this? Have you evaseen
15
me the questions without me looking at it? Probably you
15
signs displayed at 2520 Avenue Au Solcil or 2516 Avenue
16
Oun,
16
Au Soleil?
17
Q. Probably I could.
17
NIR. STEARNS: Objection, characterization of
i6
A. Ifyou ask a question that] think I need to
is
signs.
19
see it, I'll ask you for it
19
THE WITNESS: With respect to Mr. O'Hare, he
20
Q. Fair enough Okay, so what is an objects
20
has identified that as an. And at a commission
21
d'art under the code?
21
mating he offered to sell copies of it to mu
22
A. Well 1, asyou know, l don't drink it really
22
commissioners ifthey wanted a copy.
23
has a definition in our code, but in my — sorry, phones
23
So he, W. O'Hare, I bcl leve, defines it as
24
and laughs and all kinds of things going on here.
24
art, and 1 respect that
25
It doesn't have a definition. Mimi, I
25
17 (Pages 62 to 65)
Florida Court Reporting
561-689-0999
18 (Pages 66 to 69)
Florida Court Reporting
561-669-0999
Page 66
Page 67
1
BY MR. O'BOYLE:
r-
located? You said something on a hedge. but I just want
2
Q. Okay. So you do know, you have read the
2
to be clew.
3
complaint?
3
A. I dont know how to clarify it even more.
4
A. Some time ago, yeah.
4
Q. Sure.
5
Q. Sure. So you do know about objects d'art?
5
A. l bay were four-bv-eight anwork, attached in
6
A. I'm sorry. which complaint are you talking
6
some manner to what 1 believe to be his hedges.
7
about?
7
Q. Could you recognize that artwork as — I'm
8
Q. The most recent, the second amended —
e
sorry, did that artwork have any three-dimensional
9
A. Second amended eamplain4 okay.
9
aspect to it?
10
Q. Right. So you haw a seen Mr. O'Horc s — cull
( 10
A. In my opinion. it did not
11
it artwork? I call it signs, but you call it artwork,
11
Q. Okay. It was Me. if you put a frame on it,
12
outside of his house?
12
would it look like apainting?
13
A. I drove by once, maybe trice, and observed
13
A. Yes.
14
them. I believe they were hanging onto his hedge.
14
Q. Did you recognize that artwork as being
15
Q. Okay.
15
political in nature?
3.6
A. Facing the road.
16
A. No.
17
Q. Did you take pictures of those?
17
Q. Okay. What did you recognize about that
18
A. I don't recall. I may have, but I don't
18
artwork?
19
recall.
19
A. 1 don't recall.
20
Q. Did you ask anybody to take pictures?
20
Q. Okay. I have wine copies of it here, Before
21
A. I don't believe 1 did, but I don't recall.
21
w c go through any ofthese things, do) on remember that
22
Q. Okay. When you drove by you were able to see
22
ertw•ork being critical of town officials?
23
their location on Mr. O'HaWs property?
23
A. I would not use the word critical. Ithink
24
A. Generally, yes.
24
they arc elected officials and they are. should be
25
Q. Okay. And could you describe where they were
25
capable of handling that font of communication.
Page68
f
Page 69
1
Q. What do you mean by capable of handling that
1
you m a king, maybe King George, IfI car something with
2
form of communication?
2
your trod on it, would that sound about right?
3
A. WeIL they, they are elected officials and, by
3
A. I would not accept that --
4
law, I believe there are certain elonkatcd references
4
(
Q. Okay.
5
made about them that they have to accept in that
5
A. — slutement by you. no.
6
position.
6
Q. Okay. So whatwere the depictions ofwhat you
7
Q. So did you recognize this artwork as being
7
can remember of) ourself?
8
politically charged, as a political satire?
a
MR. STEARNS: We would say that the pictures
9
A. i did not.
9
speak Por themseh•es, and ifyou want to show him a
i 0
Q. What did you recognize it as being? Was it
10
specific picture, that's fine. Otherwise. let's
11
mean spirited?
11
move an to what he did and things like that.
12
A. I did not recognize it as such.
12
h1R O'BOYLE: Okay.
13
Q. So you didn't have any — I mean making this
13
MR. STEARNS: Mr. O'Hare can "plain his
14
somewhat difficult, because it either was political
14
pictures when he weans to.
15
speech or It wasn't
15
BY MR. O'BOYLE:
16
A. I don't know the answer.
16
Q. Were you offended by any of these pictures
17
Q. Was it offensive?
17
about yourseli?
18
A. I did not take offenseta it.
18
A. No.
19
Q. Okay. Were there not pictures or artwork or
19
Q. Okay. Do those pictures fit within the
20
pictures or paintingsofyou?
20
character of the town?
21
A. I believe there were.
21
MR. STEARNS: Object to the fort.
22
Q. Okay. And do you recall any of the paintings
22
THE WITNESS: You objected to form?
23
or the depictions of yourself?
23
M& STEARNS: Idid object. You can still
24
A. I don't recall them, no.
24
answer, though.
25
Q. If I told you that Mr. O'Hare hada picture of
25
THE WITNESS: Could you dcscribc character?
18 (Pages 66 to 69)
Florida Court Reporting
561-669-0999
19 (Pages 70 to 73)
Florida Court Reporting
561-669-0999
Page 70
'Pane 71
1
BY MR O'BOYLE.
1
good taste and good design?
2
Q. The, I guess the reputation of the town. the
2
A. That's act a decision I would mals.
3
tray things, the way this town is known to operate.
3
Q. Righl, but I'm asking you haw you felt about
4
MR. STEARNS: Object to the form.
4
them in relationship to the town.
5
THE WITNESS: I don't know the answer to your
5
A. 1 don't know.
6
question.
6
Q. You don't know how you felt about the
7
MR STEARNS: How about has anybody else
7
paintings?
8
placed similar pictures about the town?
8
A. I don't know the answer to your question.
9
That he can probably answer.
9
Q. Okay. When you saw the paintings or tite
10
MR. O'BOYLE: Okay.
10
artwork• did they make you upset?
11
BY MR. O'BOYLF.:
Il
A. No.
12
Q. Well go with Chris' question. Has anybody
12
MR STFARNS: Asked and ansvvtired.
13
else put on) similar pictures up around the town?
13
BY MR. O'BOYL.E:
14
A. I don't think similar would be the right word.
14
Q. Did they make you happy?
15
Q. Oka%. Here's character. "a trait of good
15
A. No.
16
quality, reputation, or individual traits."
16
Q. What emotion did they elicit from you?
17
A. I don't know.
17
A. More work.
18
Q. Okay. You don't know whetter those signs fit
18
Q. Why more work?
19
within the character of the town?
29
A. Well, it appeared to me to be a violation of
20
_ MR. STEARNS: Object to the form. You can
20
our code.
21
answer if you Can.
21
Q. And that would be the objects d'art?
22
TUE WITNESS: I don't know as defined just now
22
A. Yes.
23
by you.
23
Q. Was it also a violation of the sign ordinance?
24
BY It1011. O'BOYLE:
24
MR. STEARNS: Object to the form.
25
Q. Okay. Did they fit within the elements of
25
THE WITNESS: I don't know the answer to that
19 (Pages 70 to 73)
Florida Court Reporting
561-669-0999
Page 72
Page 73
1
question.
1
THE WITNESS: No. 1 don%I don't know that
2
BY MR. O'BOYLE:
2
I can.
3
Q. Have you n cr cited anybody for a sign
3
BY MR.O'BOYLL
4
ordinance violation?
4
Q. Okay. So the first thing that popped into
5
A. Yes.
5
Your head was objects d'art.
6
Q. I lave you ever taken anybody to a code f
t
A. Actually, it mel have been. 1 thought they
7
enforcement hearing on a sign ordinance issue?
7
were, and I was recognizing that it was additional work
e
A. Don't recall.
a
that would be brought an to stag
9
Q. Okay. But you were notable to ddentify
9
Q. Okay. Did you ever see the boat— let me
10
whether Chris O'Hare's signs, artwork violated the sign
10
ask, did you etcr see the boat in Polo Cove with) our
11
ordinance?
11
own eyes?
12
MR. STEARNS: He didn't cite him for it, so
12
A. Yes.
13
why does that matter?
13
Q. Did you, you saw the signs on the boat?
14
BY MR. OBOYLE:
14
A. I saw what looked to be the same tlpe of
15
Q. I want to know why you didn'tcite him for it
15
artwork. but I don't know if they were signs. 1 don't
16
MR STEARNS: Doesn't matter either.
16
recall. And I don't know what that special magistrate
17
THE WITNESS: So have wo got an objection to
17
approach was. I just w•hatewnr it was, die records
is
roma or what?
10
speak for themselves. They arepublic records
19
MR. S17ARNS: That's an objection.
19
Q. Okay.
20
THE WM*ESS: 1 don't know what the hell to do
20
MR. O'BOYLE: I'm going to mark this as
21
here.
21
Exhibit20.
22
MR. OBOYLE: Right
I
22
(The document was marked Plaintiff's Exhibit 20
23
MILSTEARNS: Can you possibly answer the
23
for identification.)
24
question. why you didn't do something drat luu I
24
MR. STEARNS: You are showing one afthe many
25
didn'tdo7 I
25
that were posted?
19 (Pages 70 to 73)
Florida Court Reporting
561-669-0999
20 (Pages l,; to 77)
Florida Court Reporting
561-689-0999
Page 74
Page 75
1
MR. O'BOYLE: Yes.
1
Q. Okay. But I'm not asking you what ,you said to
2
BY MR. O'BOYLE:
2
your attorney. I'm saying what —
3
Q. is that the boat that you saw at Polo Cove?
1 3
MR STCARNS: Or what his amomcy said to
4
A. Ibelieve so.
( 4
him.
5
Q. Are those the signs that you saw on the boat?
i 5
BY MR O'BOYLE:
6
MR. STEARNS: Object to the form.
6
Q. Right. Unless you have told other people acd
7
THE WITNESS: 1 believe so.
7
waived it, then by all means, tell me.
8
BY MR O'BOYLE:
a
MR STEARNS: The simple aacwcr mould be that
9
Q. Okay. And is that a, somebody that you know
9
he thought it was a violadon of code. and you v. ant
10
being depicted on that sign?
10
to argue with him. The place to do that is with
11
MR. STEARNS: Object to the form.
11
the federal judge. He has told you what he
12
THE WITNESS: This appears to be. but I'm not
12
thought Were done with that
13
sure. Mayor Orthwein to — she might have been
, 13
MR. O'BOYLE: I don'tthink you did tell me
14
mayor at that time, Mayor Orthwein, Commissioner
1;
what you thought, but why did you — actually, l
15
Orthwein.
I 15
think you just said something about counsel.
16
BY MR. O'BOYLE:
16
BY MR. O'BOYLE:
a7
Q. I think so. Now didn't you cite Chris O'Hare (
17
Q. So wiry did you cite Cluis O'Hare under the
is
for having signs in the riglit-of-way?
!a
sign ordinance for having a sign in the right-of-way
19
A. I don't recall. Those are public records.
19
with that boat?
20
Whatever they are is v% l did.
20
A. Idrift recall. Idon't know.
21
Q. Okay. I'm going to tell you that you did cite
21
Q. Okay.
22
him for having signs in the right-of-way.
22
A. Have to review the records.
713
Why did you cite him for having signs in the
23
Q. All right. Was that about the same time that
19
rightof-way?
24
you cited Mr. O'Haic for having objects d'art?
5
A. Imill rely on a:tomeylclient privilege.
25
A. Idon't recall.
20 (Pages l,; to 77)
Florida Court Reporting
561-689-0999
Page 7
Tlou
Page 7"
1
Q.
Okay. If I told you that it was within a
thdraw the charges?
2
month or two-month period, dons that sound about right?
2
MR SITAR\S: That's fine. He can say
3
A.
Could be.
3
whateverhe"ants.
4
Q.
If I told you it was within a six-month
4
BY MR O'BOYLE:
5
period, does that sound about right?
f 5
Q. Did you withdraw the charges?
6
A.
No.
I 6
A. It's my recollection that the special
7
Q.
Okay. I'll leave that for a second. j
7
magistrate proceeding was m i0tdrawn. I don't know by
8
With regard to that bout, did you seek any
8
whom or wits.
9
advice from any of the town staff on what to do? Ij
9
Q. The sign ordinance par or where you cited him
10
A.
No. I
10
with die sign ordinance or you cited him with the
31
Q.
Did you reach out to Marg• \linar at all?
ii
mooring? Which one %us withdrawn?
12
A.
I don't recall.
12
MR STEARNS: Object to the form.
13
Q.
Do you consider Marry Minor pari of the town
13
THE WITNESS: I don'trecall. The records
14
staff?
'-4
speak for themselves.
15
A.
No.
15
BY MR. O'BOYLE:
16
Q.
just a consultant?
16
Q. Okay. So whatever the records say, that s
17
A.
Yes. I
i7
what happened?
18
Q.
Okay. With regard to the objects d'art, did
18
A. Whatever the special magistrate —if this was
19
you tali! to Marty Minor about the objects d'art?
19
the special magistrate proceeding. I think we went,
20
A.
I don't recall.
20
provided our citings. So 1 can't recall what they are.
21
Q.
Okay. With regard to that boat, did you not
21
1 will accept them as %chat's on those
22
du Mr. 01 lare for mooring improperly in die tm%n cuve?
22
documents.
'd3
A.
I don't recall. The document is a public
23
Q. Sure. What's not in the public record is why
4
record.
It should speak for itself
24
were these, why were these charges withdrawn?
5
Q.
Those have been a little hard to come by. Did
25
A. I don't recall.
20 (Pages l,; to 77)
Florida Court Reporting
561-689-0999
21 (Pages 78 to 81)
Florida Court Reporting
561-689-0999
Page 73
Pagr. 79
1
Q. The objects d'art charges, why were they
1
A. It's a legal matter.
2
withdrawn?
2
Q. But so —so then what does Marty Minor assist
3
A. 1 don't recall. I'm sure under advice of
3
you with?
4
counsel. but I don't recall the conversation.
4
A. He could assist me with such things as giving
5
Q. Okay. Advice of Skip Randolph?
5
me input. but when it becomes a manor of special
6
A. General counsc4 the firm, yes.
6
magistrate, I try to get direction from general counsel,
7
Q. Okay. Is it possible that it was at the
7
but input could be used from Marty Minor in regards to
a
advice of Marty Minor?
8
the documentation and the ease itself.
9
A. No, no.
9
Q. Because, conect me if I'm wrong— and I
10
Q. You say that with certainly.
10
believe you sat there in Mr. Minor's deposition.
11
A. At that level, I wouldn'tbe talkingto Marty
] ]
A. I sat through it.
12
Minor
12
Q. Yes. He assists you with interpreting the
13
Q. Okay. Is Many Minor. has Man' Minor ever
13
code?
14
toldyou to be careful with the code enforcement action
14
A. Sometimes.
15
because of the First Amendment?
( 15
Q. What else does he assist you with? I mean I'm
is
MR. STEARNS: Object to the form.
16
assuming he's got a pretty broad spectrum.
17
11.12 WITNESS: I believe there is some
17
A. Yeah, he's opened the door for me on occasion.
18
correspondence that has the word First Amendment in
16
He's done the DCA comp plan. Annexation I think his
19
it. I do not recall exactly what h was• but I
19
fine w•a; invulvcd with, but his involvement I don't
20
believe those documents arc public record also.
20
recall. Things of that nature.
21
BY MR. O'BOYLE:
21
Q. Okay. Do you recall any time, since were
22
Q. Right.
22
speaking about the town anomey, that the town attorney
23
A. On that matter, Mart), would not be the
23
ever told you to go out and find vlolanom?
24
determining factor.
24
A. I do not recall ever that.
25
Q. Because this is above his pay grade?
25
Q. Fm talking about code enforcement violations.
Page 80
I
Fage Fi
1
A. No. +
1
A. No.
2
Q. Okay. Do you recall at any time anybody I
2.
Q. Okay.
3
telling you to go out and find violations? I
3
A. I'm sore, he has generally heaped us, yeah,
4
A. No.
4
initially.
5
Q. Okay. Is there a possibility that that
5
Q. And who's responsible for the content of that
6
happened but you just don't remember?
6
website?
7
MR. STEARNS: Object to the form.
7
A. Well, there's no policy involved in relation
'e
THE WITNESS: No.
6
to the website. I believe that answer is me.
9
BY MR. O'BOYLE:
9
Q. Okay. I mean I'll tell you it's absolutely
1 D
Q. Okay. So I just want to be sure.
10
beautiful.
1'_
A. I don't—
11
A. I don't like it
12
Q. That was a double negative. So nobody just
12
Q. Wow. 1 fed a little bit like &smacked —
13
told you to go out and to pick on somebody, to find
13
well --
14
something?
14
A. We have uur cvvn opinions, right?
15
A. No.
15
Q. That's true. Okay_
16
Q. Okay. Are you responsible for the town's
16
So if you mind me asking, what don't you like
17
website?
17
about it?
18
A. I review it and approve iL
18
A. It seems m be old and tired and it's not as
19
Q. Okay. Who maintains it?
19
user friendly as 1 would like.
20
A. Combination of people. We do quite a bit
20
Q. And when you say user friendly, what does that
21
ourselves. We call upon a consultant to help us from
21
mean? I mean I have my definition.
22
time to time. We have IT problems from time to time.
22
A. Generally being able to easily maneuver
23
We connect with them.
23
through sections of the website, correlating in some
24
Q. And the consultant, we're not talking about
24
simple, but logical pattern.
25
Marty Minor, are we?
25
Q. And do you have copywriters? I mean who
21 (Pages 78 to 81)
Florida Court Reporting
561-689-0999
22 (Pages 82 to 85)
Florida Court Reporting
561-689-0999
Page 62
Page B3
1
writes the information. on there? And I'm not talkins
1
Q. Or the Gulf Stream School?
2
about the public retards repositoy or the contact list.
2
A. No, not that 1 recall.
3
I'm talking about the more interactive features.{
3
Q. Okay. So let me ask, why arc the Gulf Stream
4
A. Could you just ask me one question at a time,
4
School and the Gulf Stream Civic Association referenced
5
please?
5
I
in the town's website?
6
Sum
Q. SuSure.
6
A. They area pan of the community. It was our
7
Who's responsible for typing out all those
1 7
thought that that would be information available to our
8
things and putting them —
E
residents.
9
A. Various people.
5
1
Q. Do they meet a certain criteria?
10
I cited some of the people that we've used on
10
A. No.
11
that That would be the same answer.
11
Q. Like bring in the public good?
12
Q. Okay. And that is subject to your approval?
12
A. Thcy are located within our town. I know that.
13
A. Ultimately, yes.
13
Q. So this was just put up — by the way, who
14
P,'thether there is something that 1 have missed
14
drafted the content for the school and for the civic
is
it's possible. But it is certainly. I dant see it to
:5
association?
16
be a policy issue.
in
A. I believe that was, I'm going to say primarily
17
Q. Okay. Has anybody ever eked to pm something
-
Marty Minor. Thats. I'm not sure about that.
is
on the website and asked for your approval?
I o
Q. Did they seek, did he seek input from the
19
A. Yes.
19
!
school or from the —
20
Q. Who has asked?
20
A. I believe so.
21
A. ICI recall correctly, Mr. O'Hare. That's all
21
Q. And input I'm assuming from the civic
22
1 can recall.
22
I
association?
23
Q. Okay. Did the GulrStruam Civic Association
1 23
A. I don't know shout that.
24
nerask?(
2,
Q. Okay. And r, hat svasMr. O'liare'sregaestwith
25
A. No, not that I recall.
25
regard to the w ebsitc?
Page 84
I
Page 85
1
A. I don't recall.
i 1
verbal communication and agreement that took place and
2
Q. He asked to put something on the website.
II 2
transpired between myself and I believe Allen Bona
3
though. right^.
3
Q. Andwho isMr. Boma?
4
A. Yes.
4
A. I believe that be is the miner of Green Group.
5
Q. Do you remcmbcr if it w asa lirdt to his
5
That's my thinking anyway.
S
website or if it was a blurb or something else?
6
Q. And the Town of Gulf Stream, did tbeyt didn't
7
A. Could have been. I don't recall.
7
they receive a discount for displaying Green Group
8
Q. And whatever that request was, it was turned
8
Studios?
9
down by the town?
9
A. Yes, we did.
10
A. Yes.
10
Q. And did that discount go away when they
ii
Q. And why was it turned down?
11
rcmmxd-
12
A. I don't recall.
12
A. Yes. Actually, we had to enure to an
13
Q. Okay. The town contracted with Green Group
13
agreement, financial agreement between Green Group and
14
Studios?
14
the town.
15
A. Yes.
15
Q. And you Acreresponsible for —
16
Q. Okay.
16
A I was responsible.
17
A. Via the initial connection through Urban
17
Q. For the negotiations?
18
Design Studios.
12
A. I was.
19
Q. Okay. And Green Group Studios was able to
19
Q. Okay. Was Green Group removed because
20
advertise on the website?
20
Mr. O'Hare made a request to put his link to his w ehsitu
21
A. ror a time.
21
on the town's website?
22
Q. For a time. And why were they, or what
22
A. I dont think so, but I don't recall.
23
happened?
23
Q, Du you know if there uta any documents or
24
A. We asked them to remove our time or their name
24
memoranda that might rennet this decision to remove
25
Immour website,and there was discussion about the
25
Gran Group?
22 (Pages 82 to 85)
Florida Court Reporting
561-689-0999
23 (Pages 86 to 89)
Florida Court Reporting
561-669-0999
Page 85
Page 87
1
A. If there are, they are associated with some
1
to —
2
requests as it relates to the website, 1 believe that
2
A. To include anybody that would like to seek
3
would be either. A4r. O'Hare or Mr. O'Bugle, Martin
3
such privilege or have such a requesL
4
tyBoyle.
4
Q. And since ,you told me a little bit about your
5
Q. Martin, okay.
5
conversation with general counsel, the First Amendment
6
A. But I don't know. I don't mail exactly what
6
came up.
7
it was.
7
A. No, I don't recall that
8
Q. Okay. You mean whether it was Mr. O'Hare or
8
Q. Okay. The words public forum»
9
Mr. Matin O'Boyle?
9
A. I don'trecall that
10
A. T haes correct 1 don't recall.
10
Q. Okay.
11
Q. But Green Group was removed because one of
11
A. I think It was actually just a verbal
12
the, either. hR. O'Hare m Mr. Martin O'Boyle made a
12
communication, very general in nature. And I believe
13
request to put a link onto the town's w ebsitc, and
13
I
Mr. Randolph said I should contact Greco Group and s x
14
rather than allowing Mr. O'1[me or Mr. Martin O'Boy It to
14
what we needed to do to take ihem off our website.
15
have a link, they decided to just remove Green Group?
15
Q. Did the— I'm sorry, did the commissioners
16
MR. STEARNS: Object to the fumt
16
weigh in on any of this?
17
THE %%'MESS: That was a long one.
=7
A. No.
is
BY MR O'HOYLE:
16
Q. Okay. This was just between you and
19
Q. 1 apologize.
19
Mr. Randolph?
20
A. We decided, I believe we were directed or had
20
A. May 1 strike and make another comment?
1
communication with general counsel that we should
21
Q. Yes.
::2
e:imin icthc possibility ofanybody advertising an our
22
A. Therc was several commissionermmments prior
23
site. It wasn't just exclusively Mr. O'Hare or
23
to a website by both commissioners end residents that
24
Mr. O'Boyle. But its intent was be general.
24
there was a real need to develop a town website.
5
Q. What do you mean by general? You can refer
i 25
So fn�m that perspective, a consensus, you
Page 88
Page 85
1
might say, of opinion that I took and took direction
1
not?
2
from.
2
A. No.
3
Q. Okay.
3
Q. By the way.just for the record, when I say
4
A. But as fm as the individual dccisions,
4
civic association, you understand that to be the Gulf
5
specific decisions, that's all my responsibility, or at
S
Stream Civic Association?
6
least I assumed that it was.
6
A. I'm assuming that.
7
Q. Okay. So after Green Group was remov ed, the
7
Q. Okay. If I told y ou that's what 1 intended It
E
school and the civic association remained on the
9
to be, none of our answers would change?
9
website?
9
A. No.
10
A. Yes.
to
Q. Are they the only civic association or
11
MR. ST'EARNS: Object to the form.
it
nonprofit chic association within the town?
12
BY MR. O'BOY1.E:
12
A. I believe so,
13
Q. Is there any reason why Green Group was
13
Q. Okay. When the website was being developed.
14
removed, yet the school and the civic association got to
14
did the commissioners review and make comments?
15
remain?
15
A. I believe they may have reviewed it. I asked
16
A. I dent recall.
16
them to review it, I think, make comments and
17
Q. Okay.
17
suggestions. yes.
18
A. I think that was something that we initiated
18
Q. But that's pretty much all the input?
19
rather than an outside influence initiating action, but
19
A. other than what I previously stated about
20
Icon'trecall.
20
consensus, about the need ofawebsite,yes.
21
Q. Okay. Does the school pay for any
21
Q. Right, okay.
22
advertising —
22
A. To my recollection.
23
A. No,
23
Q. Sure, sure, sure.
24
Q. — on the town's website? Okay.
24
What was the civic association's input?
25
And the civic assm6ation I'm assuming does
25
A. I don't recall.
23 (Pages 86 to 89)
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1
Q. But you recall that they did give input?
' i
Q. Okoy. Possibly because you've made your
2
A. i really don't recall.
2
determination as there's no code violation, no need to
3
Q. Okay.
3
follow up?
4
A. 1 don't know whether that's something Marty
4
A. Could be that or it could be that i wasn't
5
Minor did. I justdon'tknow.
5
going to send anybody out, just myself.
6
Q. Okay. Is that something that they would
6
Q. Okay. So if you weren't going to send anybody
7
apically get Involved in?
7
out, you would go yourself? Go ahead.
9
A. No.
8
A. I think generally that's correct.
9
Q. Okay. What would the civic association
9
Q. Okay. Are you aware that Mr. O'Hare has made
10
typically get involved in?
10
complaints, code enforcement complaints to the town?
11
A. I don't know.
11
A. I believe that he has, as well as general
12
Q. You don't know what they would typically get
12
communication that may be interpreted as complaints.
13
involved in — or let me ask you this.
13
I'm not sure.
14
Do you recall issues that they have gotten
14
Q. Okay. But he has pointed out particular
15
involved in?
is
things that he finds to violate the law?
16
A. No.
16
A. I consider that to be communication that
17
Q. Okay. Actually, I w ant to ask you this. Back
17
Mr. O'Hare is initiating to me.
13
to code enforcemen4 when does something come across
18
Q. Okay.
19
your desk regarding code enforcement — or Pot sorry,
19
A. Could be a violation, bra I believe it to be
20
has there been an instance w here something comes across
20
communication. -
21
your desk regarding code enforcement and you decide not
21
Q. But he's, but you've understood that
22
to send anybody out to go investigate?
22
Mr. O'Hare — well, let me ask you this. In the
23
A. Yes.
23
communications does he send you pictures?
24
Q. Can you maybe give me an example?
24
A. Yes. he hue.
25
A. 1 can't recall right now.
25
Q. He has. in certain communications?
Page 92
(
Page 93
1
A. Yes.
I 1
BY MIL O'80YLE:
.
Q. And in the communications vhue he sends you
2
Q. Okay. Have you ever found Mt O'Hare's
3
pictures, isn't he usually complaining about a violation
3
complaints regarding — these complaints by the way,
4
of the law?
4
they arc regarding code enforcement, right?
5
A. 1 rind that sometimes he ends his
5
A. I would have to sec what you're talking about.
6
communication with "I'm not really complaining about or
6
but I am again stating that I am not clear whether they
7
making a complaint against."
7
arc communication or complaints. Those that arc
B
So I am perhaps unclear as to what his purpose
a
complaints, that I believe to be complaints. I evaluate
9
in perhaps communicating to me was or is.
9
to some level.
10
Q. Does he cite code violations?
10
Q. Okay. And the communications, when we'rc
11
A. Hesametimescilessactionsofthecode.
it
talking about communications, when Mr. O'Hare sends you
12
Q. Okay. And sometimes he does tell you that he
12
pictures and then sends yrou a particular section of the
13
wants the loom to do something?
13
code, you don't understand that to be a complaint?
14
A. I think it's possible ler says that in some of
14
MR STEARNS: Object to the font.
15
his, like "do your job" at something like that
15
THE WITNESS: I'd have to sat it. I'm not
16
Q. Right. And how do you treat Mr. O'Hartes I
16
sure, but its posshble.
17
complaints?
17
BY MA O'BOYLE:
18
NIR. SILARNS: Object to the form.
16
Q. Okay. Generally speaking, has Mr. O'Hare made
19
THE WITNESS: I treat them as communication
19
a substantial amount of complaints in the last two,
20
and do not respond to him. And those that are
20
three months?
21
complaints that I can identify as elcar complaints.
21
MR. STEARNS: Object to the farm
22
1 respond or at least evaluate and investigate
22
THE AMNESS: t have received I believe a
23
whether or not indeed the allegation is a true
23
number ofe•mailsfrom Mr. O'Hare.
24
violation or a conect violation ofour code.
24
BYNIROBOYLE:
25
25
Q. Do some of those e-mails ask you to do
24 (Pages 90 to 93)
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25 (Pages 94 to 97)
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1
Page 95
1
something?
1 1
BY MR.O'BOYLE:
2
A. I don'trecall.
2
Q. Okay. Vlhat if theyw•cre in violation under
3
Q. Okay. Did you understand those e-mails as
3
the o!d sign ordinance?
4
being complaints?
4
A. I-
5
A. Some I did. Some I did not
5
MR. STEARNS: Form. Go ahead.
6
Q. The recent complaints about a sign ordinance,
6
THE WITNESS: 1 don't see the relevance of an
7
is that your general understanding?
7
old sign ordinance as it relates to --
8
A. Yes.
B
BY MIR. O'BOYLE:
9
Q. Have you found anyone or have you
9
Q. Then they would be grandfathered in?
10
investigated any one of.Mr. O'fWs complaints?
10
A. I said as it relates to the new ordinance.
11
A. I have observed all, and because of time
11
Q. Right. but if something didn't comply with the
12
restraints, because ofactive open litigation, all that
12
old ordinance, is it to be grandfathered in under the
13
I've been able to do is to observe the complaint.
13
new ordinance?
14
I would also think that as itrelates to the
14
A. Could you repeat it agut[0
15
recent or only sign ordinance, that as advised by
I5
Q. Sure. II'Mr. O'Hare was to point out to you a
16
counsel in a public hearing or a public meeting, they
16
sign that was not in compliance with the old ordinance.
i7
were potentially or possibly grandfathered in.
17
would it be grendlathemd in under the new ordinance?
18
Q. All of them?
18
A. I'd have to look at it on an individual basis.
19
A. I dont, I don't recall. That would be part
19
I know as it relates to 15-1 ordinance. mference w as
20
of the consideration when I got to them.
20
1
made by counsel, general counsel that existing, whatever
21
Q. So the new sign ordinance grandfathers in
21
they are, would be grandfathered in. I haven't done any
22
everything?
22
detailed evaluation, interpretation as of this date.
23
M4R. STEARNS: Object to the form.
23
Q. Okay. Wish regard to these sign complaints
24
THE WITNESS: I dont know.
24
that — I'm sorry, let me back up.
25
25
Did you ever sec a letter from Mayor Morgan
Page 96
Page 97
1
dated March 26 drat went out to all the residents?
1
Q. Okay. I'm sure that it was.
2
A. I don't recall it. It's very possible.
2
MIL STEARNS: I'm quite certain we'v: covered
3
Q. Okay. Let me help you refresh your memory.
3
everything as it relates to his obligations of rode
4
Do you remember seeing a letter wfierc Mayor
4
enforcement.
5
Morgan listed all the properties that Mr. O'Hare made
5
Can we gel to whatever your next arca is?
6
complaints about?
5
BY MR.O'BOYLG:
7
A. I remember to some extent that general letter,
7
Q. Code enforcement. But Wit start back with
B
yes.
B
Mr. Ginsberg.
9
Q. Okay. Did you and Mayor Morgan. did you guys
9
A. Okay.
10
divvy up who would take care of the code enforcement AM
10
Q. What do you know about the history or
11
who wouldn't take care of the code anforcemem?
11
Mr. Ginsberg and Mr. O'Hare?
12
A. Mr. 019oy Ic, to a certain extent that's very
12
MIL STEARNS: To an extent, that would bring
13
Insulting. but the answer is no. I said to a certain
13
in attomey/client privilege and meetings I have
14
extent. its very insulting, but the answer is no.
14
recently had. lfyou want to tally to him about
15
Q. w'hy is that insulting'
15
spcci fic dates in the past and what occurred in
16
A. Because 1 have answered repeatedly that I am
16
communications he had, that would be the way of
17
the code enforcement officer and the commission is not.
17
handling It, not what does he know now.
15
That should be suff cium.
18
MR. O'BOYLE. Actually, lei's take a break.
19
And 1 just consider it to be an insult that
19
(A recess was taken.)
20
you would come around and ask tat type of question. Is
20
BY MR. O'BOYLE:
22
that a privilege that I have to smtc that to you or
21
Q. Okay. Mr. Thrasher, you understand that you
22
not? If it's not, I'll apologize to you right now.
22
are still under oath?
23
Q. You ate allowed to be an<^ry with me.
23
A. Yes.
24
A. I'm not angry. I said ft was insulting, and 1
24
Q. So Mr.— v. ell, let's start back before then.
25
believe tlahhwas.
25
Do you remember your first interaction with
25 (Pages 94 to 97)
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26 (Pages 98 to 101)
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1
Page ^9
1
Mr. O'Hare. or the first time you ever met him?
1
Au Soleil?
2
A. I'm wondering whether we actually ever
I 2
A. I'm not sure when that date was. I'm going In
3
officially met, but I don't recall.
3
guess — I don't know.
4
Q. Okay. So if I told you that you guys met in
4
Q. Generally with Place All Solcil, that's the
5
2002 over a retaining wall. does that refresh your
5
only neighborhood that lics Art of guess the rest of
6
memory at all?
6
Gulf Stream?
A. I don't know if tee mel, but I remember a
7
A. West of the lnuacoastal, yes.
9
retaining wall issue or circumstance on Middle Road,1
• 8
Q. So its not connected by any direct mads?
9
think.
9
A. No.
10
Q. Okay. Do you remember anything about that?
10
Q. Is there any — well, let me ask this. Has
11
A. No.
1;
Place All Soleil, has the town ever considered getting
12
Q. Okay. Would it surprise you to learn that you
12
rid or Place An Soleil?
13
gave Mr. O'Hara a permit to build a retaining wall and
13
A. I don't think the town has.
14
then you told him that he had to rip it out?
14
Q. Okay. De you knots, you say that as if maybe
15
A. Yes, that would surprise me.
15
staff has considered proposing that.
16
Q. We'll move on a little bit here.
16
A. I did.
17
A. All right
_"
Q. ,1nd when did you propose that?
18
Q. Sure. Middle Road, by the way, where is that
18
A. I believe that was in a, a Plan Au Soleil
19
located in the Town of Gulf Stream?
19
l lomeowners Association board meeting or annual meeting,
20
A. it's a cure district, towards the central
20
annual meeting.
21
part
21
Q. And you mended?
22
Q. The core district meaning from town hail to
22
A. Yes. l believe f was the one thatset it.
23
let's say the Gulf Stream golf course
23
Q. Okay. Do you a::cud all the homeowners
24
A. Generally speaking, that's correct. j
24
associations —
5
Q. Do you recall when Mr. O'Hare mot ad to Place I`
25
A. I don't think m. I'm seny, wnuldyou
Page 100 I
Page 101
1
complete your question?
1
BY MR O'BOYLE:
Q. Sure. Do you attend all of the homeowners
2
Q. Does that permitmfresh-
3
association meetings? (
3
.NOLSTEARNS: Let him —
S
A. No.
4
MR. O'BOYLE- I'm sorry.
...
Q. Do you have a particular affinity for Place An
5THE
WITNESS: Doesn't refresh my memory, no.
C
Soleil?
6
I'll lake it forwhaahe, uimt this permit says.
7
A. It's myjob responsibility, just as it, is as
7
rat not sure what that is. I don't recall It,
6
much as it is over here.
8
BY MR. O'BOYLE;
9
Q. Okay. I mean the homeowners association,
9
Q. Okay. So just w be clear, you might not
1 0
pardon me, in Place An Soleil, do you attend their
10
recall issuing that permit or dealing with that permit,
11
meetings more frequently than —
11
but do y on recall telling Mr. O'Hara that he needed to
12
A. I'm invited to more than I am over hem. 1
12
tcmove the well for which Haat permit grants him the
13
don't get invited to the civic association meetings.
13
ability to build?
14
Q. Okay. But that's not a homeowners
14
A. No, i don't.
15
Association?
15
Q. Okay. Then toric done with that one.
16
A. No, that's a civic association.
16
MR STEARNS: I'm just looking at it while you
17
Q. Are there homeowners associations on —
17
go om
is
A. There could be. I don't know how active they
i6
MR O'BOYLE: Okay. go ahead.
19
are.
19
BY MR O'BOYLE;
2 O
Q. Okay. Let's see here. Going back to that--
20
Q. Now I think I referred to a low w ail in 2002,
21
can I mark this as Exhibit 21.
21
and 1 apologize. It's actually 2006 with the permit.
22
(Ile document was marked Plaintiffs Exhibit 21
22
Do you recall meeting your fust meeting with
23
for identification.)
1
23
Mr. O'Hare being in December 2002?
24
MR O'BOYLE: Chris, well try to staple those
24
A. No.
25
back together.
25
Q. Okay. Do you ever remember saying to anybody
26 (Pages 98 to 101)
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561-689-0999
27 (Pages 102 to 105)
Florida Court Reporting
561-689-0999
Page 102
Page 103
1
coo know how to keep the rich and powerful people in
_
outside of talks with counsel, unless of courseyou
2
line?
_
waive that privilege, feel Gee to tell me, what do you
3
A. Me saying something like that?
3
know about Mr. Ginsberg and Mr. O'Hare, their
4
Q. Uh-huh.
4
relationship?
5
A. No.
5
A. I dont know anything about their
6
Q. Okay. You had an clement of surprise there.
6
relationship.
7
A. Yes. Doesn't sound like me at all.
7
Q. Okay. Did Mr. O'Hare ever complain to you
B
Q. Okay. Is there any particular reason —
6
about VG. Ginsberg?
9
A. I don't talk like that.
9
A. 1 believe he did.
10
Q. Using the royal we or. I mean —
10
Q. Outside of a complaint in the court, he come
11
A. Now you lost mo.
11
to you?
12
Q. When yuusayyou don't lal:l@e that, meaning
12
A. Ibelieve he did.
13
that them is something offersive about that?
13
Q. Can you tell nice little bit about that
14
A. It's not offensive, but it's not howl would
14
occurrence?
15
talk to somebody or even make such a proclamation.
15
A. I can tell you generally about the occurrence.
:6
Q. Okay. So David Ginsberg, I think we talked
16
Q. Sure.
:7
about howyou kne v him, how he became code erforameal
17
A. How it came abuet, I'm not sure• But there
18
officer, right?
18
was a meeting at town hall on some date or time, and I
19
A. I think we did.
19
was present. Mr. O'Hare was present. Me, Roedcr was
20
MR. STEARNS; I know w•e did.
20
present, and Mr. Randolph was present. 1 think dial's
21
MR. O'BOYI.E: I Just wanted to make sure that
21
It.
22
there is nothing new.
22
Q. Do you think Chicf Ward was there as well?
23
THE WITNESS: Not that 1 can recall.
23
A. i dial think so.
14
BY hill. OSOYLE:
21
Q. Okay. Was Mr. t;;rsberg authorized by y ou to
15
Q. All right. Now. outside ofthe complaint and
I 25
issue stop work ordca'
Page 105
Page 104
1
A. 1 know definitely any stop work was at my
1
Q. I'm sorry. could you say that a little bit
2
direction. 1 don't recall David Ginsberg. I do believe
2
diffcrendy7 When you said transcended -
3
1 had such a direction that 1 Ile%c to, I think Steve
3
MR STEARNS: Exceeded
4
Tobias.
4
THE WITNESS: Exceeded.
5
Q. Okay. So if you w cru loissue a stop work
5
BY MIL O'BOYLF.:
6
order. could communicate that order that came from you,
6
Q. Okay. And that would be a determination made
7
bw. y ou never gave anybody the power to iswre a stop
7
by you based on esidence?
e
work order without your consent?
B
A. That's right.
9
A. I dont recall such an action.
9
Q. Would that be based on evidence or would
10
Q. Because you am, as the planning and building
10
somebody call you up?
1i
administrator?
11
A. No, 1'd be observing the documents involved
12
A_ Pretty serious matter.
12
and the situation on site-
ite13
i3
Q. Right. And what does a stop work order
13
Q. Okay. So do you know anything about this
14
email?
14
interaction between Mr. Ginsberg and Mr. O'Hara: where
15
A. The specific answer I dont knew, but in
15
the word beaners was thrown around?
16
essence, its purpose is to stop work on a particular
16
A. No.
17
construction site.
17
Q. You never heard Mr. Ginsberg or
10
Q. Right, Olay. Am there any proadums or
Ill
Officer Ginsberg, I'm sorry, use the w Ord beaner?
i9
anything that surrounds it? I think the W'illic Sutton
19
A. No.
20
ordar is the stop work order is to stop w orking. but is
20
Q. When was the Wal-Mart being built across from
21
there airy procedures dint have to be followed before?
21
Place Au Solcil?
22
A. I don't know if they have to. Typically it is
22
A. Approximately three years ago.
23
a determination that work has mintp'ured without a
23
Q. That's when it was finished?
24
permit or work has transcended the initial or the permit
24
A. 1 don't recall the specifics.
25
approval process. I
25
Q. Sure. But around thmoyears ago it was under
27 (Pages 102 to 105)
Florida Court Reporting
561-689-0999
28 (Pages 106 to 109)
Florida Court Reporting
561-689-0999
Page 106
Page 107
1
construction?
1
A. But it's a lot of the, the reports are
2
A. Constructibn or finished.
2
directed to I think FDLE or FLDF_ whatever the state
3
Q. Okay. By the way, was there an immigration
3
reporting requirement, their public records.
4
issue within the town?
4
Q. But do crimes get reported to you?
5
A. No.
5
A. Not always.
6
Q. Was there a crime issue within thc town about
6
Q. You just hear about it through osmosis,
7
three years ago?1R.
7
scutuebutt?
8
A. We always have had some level of crime, so the
8
MS EARNS: Object to the form
9
answer would be yes.
9
THE WMESS: Yeah, l don't know what you mean
10
Q. Okay. What level of, i cancan !whet kind of
.0
by that, but typicalh I will receive mmmunication
11
crime does this town experience?
'.'-
in one form or another from Chief Ward.
12
A. It's very low, but any occurrence is more than
12
I
Sometimes he does not. I'm mrtain that he
13
the want.
13
does not relay everything to me.
14
Q. Without saying.
14
BY MIL O'BOYLE:
15
A. Yeah
15
(
Q. Sure. But the major stuff, to your knowledge?
16
Q. Butw•hatare the types oferimes, assuming
16
A. Major stuff. There is probably some things he
17
triple homicides are not —
17
doesn't want to disclose. It maid be an investigation
18
A. I don't recall such a thing.
1e
ongoing Things -- I dant know protocol, but I have
19
Wo have had dhiev ery. I'm not sure what the
19
gotten communication of one form or another or one form
20
correct classification is.
20 '
or fashion from Chief Wart
21
Q. Sure, people stealing things.
21
Q. Ali right So it's fab to say you get the
22
A. Thievery, breaking and entering and stealing.
22
general lay of the land, you are not privy to ongoing —
2 3
We've had a damage to one of our police cam.
23
A. As it relates to police motters, I have a high
24
I cant recall.
24
deal of respect for not only the police thief, but the
25
Q. Okay.
25
entire police form.
Page. 108
Page 109
1
Q. Right. But the information that you get is
1
that fair?
2
,omewhtat restricted?
2
A. No, I don't accept that ststemmL I said any
3
A. Can be.
3
occurrence vviudgiewer is Significant for the Toim of
4
Q. Can be. Okay.
4
Gulf Stream. That is my answer.
5
You mentioned before banking and entering.
5
Q. Okay. All right. That's fins
6
Has that what level has that been a problem in the
6
Did Mr. Ginsberg communicate to you in
7
town?
7
September of 2811 any incident with Mr, O'Hare?
8
A. I dont understand the question.
0
A. I don't recall.
9
Q. Okay. To 1 our understanding from the
9
Q. Okay. If I cold you something about workers
10
information that's been conveyed to you, Ict's just say
10
and permits and the lack of a decal, does that help at
11
2011, was breaking and entering a big problem back then? I
11
all refresh your memory?
12
A. As I have stated earlier, one occurrence would
12
A. I think I heard testimony from
13
be a significant occurrence in our town.
13
Oftiar Ginsberg in referring to it The specifics I am
14
Q. Right But this town is not a high crime
14
net aware of or 1 cannot recall.
15
axe.
15
Q. Okay. As in you, outside of Officer Ginsberg,
16
A Does that matter?
16
you don't recall maybe being on the phone with him. him
17
Q. It mold.
17
saying "Hey. I got Mr. O'Hara here and he's got workers
18
A. Why?
18
and they need a decal and -"
29
Q. Well, I Wee your answer to your question,
19
A. No, I dont recall that.
20
Its a legal matter.
20
Q. Okay. Is that something that you would
21
A. Okay. that's my answer.
21
typically get involved in?
22
Q. Iswhy?
22
A. Decals, no.
23
A. I :s{.rd why it would matter? And you said it
23
Q. Workers without a registered permit?
24
was a legal an %%rr. So I accept that.
24
A. Weil, we have occupational registration. Is
25
Q. Okay. Sothis is not o high crime area. Is
25
that what you arc referring in?
28 (Pages 106 to 109)
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561-689-0999
29 (Pages 110 to 113)
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Page 110
I
Page 111
1
Q. Yes.-
1
them that It is a requirement to be registered to do
2
A. No.
2
work in the town, and a, generally a document that's
3
Q. Okay. Is that something that code enforcement
3
1
provided which gives them instructions in registering
4
would get involved int
4
the Town of Gulf Stream.
5
A. I don't recall ever taking such action.
5
Usually on the first instance. I'm not
6
Q. Okay.
6
certain, but I think many times it's just simply a
7
A. It's usually handled by the police department. I
7
warning to the individual, instructions to get
e
Q. All right When you say usually, that's
6
registered, and sometimes I guess the work is halted
9
Chapter 10, right? +
9
until they have completed the process of occupational
10
A. I would say generally, speaking. that's handled
10
registration.
11
by the police department as it relates to occupational
11
Q. And when you say the work is halted, is that a
12
registrations. 1 do get those repons.
f
12
stop work order?
13
Q. But you don't consider that part of the code
13
A. No, no.
14
enforcement?
24
Q. What is that?
15
A. Oh. no, I do. But I have asked for their
15
A. lust simply a communication between the
16
assistance in such maucrs. So they are doing their
26
officer and the party.
17
job.
17
Q. Okay. And—
SB
Q. Is— okay. So if particular person or
is
A. Usually they are very responsive.
19
titre's an investigation and you've determined that
19
Q. So if somebody were to say I'm going to go get
20
there is no decal. wha! is that? Is that a fine? Is
20
the permit right now, can you let these guys keep
21
that a code enforcement hearing? Mutt is the remedy for
(
21
working, that's usually how things are handled?
22
that?
22
A. 1 think it would depend on the circumstances.
23
A. Usually this is handled in the field by a
23
For example, if somebody was pouring concrete, that
24
police officer. It is a communication that takes place
24
probably would be allowed to continue to the stop of
25
Muten the otlicu and the parry or parties. informing
15
that activity, to avoid I guess it cold joint I'm not
29 (Pages 110 to 113)
Florida Court Reporting
561-689-0999
Page 112
Pace 113
1
sure what that is, but I have heard that terminology.
1
TIIE WITNFSS: Okay. I don't know the date and
2
Q. Like irreparable herr?
2
I dont I'm not sure of the allegation.
?
A. No.
( 3
BY MR O'BOYLE:
Q. Ito sorry, what was that?
4
Q. Okay. The allegation in the second amcndd
i�
A. Thank•3oufort'sat—
5
complaint is that David Ginsberg. I'm sorry.
G
MR. 014ARE: Cold joint Building ta^n
+
I 6
Officer Ginsberg went Into Chris ('Hen's house and shut
•7
THE WITNESS: I'm glad it's a building term.
+ 7
down or issued a stop work order from inside the house.
8
Thank you for the laugh. 1 needed It
a
A. I have no facts on that matter. It doesn't
9
BY MR OSOYLE:
9
sound to me a being accurate, but rm not sure.
10
Q. Fair enough. Okay. So the factors of
10
Q. Okay. Did you — %roll, did you talk to
11
allowing somebody some leniency to go and get the deed,
ii
hit. Ginsberg on that day about Mr. O'Hwe's house?
12
can you tell me what those factors are, whether to do it
12
A. I don't recall.
13
or not to do it?
13
Q. Okay. Anything out there that might help your
14
A. I relyon the police officers judgment
14
memory?
15
Q. Okay. And if somebody refuses. is that
15
A. There may be. I don't know
16
something that would come to you or is that something
16
Q. Okay. Do you remember seeing any pictures
17
that would mine to Chief Ward?
17
from inside Mr. O'HaWs house?
18
A. I would caped that to go directly to the
16
A. I remember seeing pictures of the outside of
19
chief. The chief may confer withme,Idontknow.
19
the mar ofhis house, lbelieve.
20
Thcy are under his empinyment.
20
Q. The rear.
21
Q. Wereyou in communication with Mr. Ginsberg.
2I
A. It would be the west elevation.
22
rm going to say October 28, 2011. 1 think we all son
22
Q. Okay. The west elevation would be —
23
of know this as the day that Mr. Ginsherg went
23
A. I believe shaft; most
24
allegedly went into W. O'Hare's house.
24
Q. Just for the record, Mr. O Hare% house is on
25
MR. STEARNS: Object to the farm. !
25
the comer, correct?
29 (Pages 110 to 113)
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561-689-0999
30 (Pages 114 to 117)
Florida Court Reporting
561-6B9-0999
Page 114
Page 115
I
A. Yes. It faces east.
1
I'm not trying to be facetious here.
Q. And north?
2
A. No, I understand.
3
A. Faces east His entrance is on the east.
3
Q. I think there was a pool outside.
4
Q. So the west would be his back yard?
4
A. Ido believe I saw• a pool and the west
5
A. That's what I think.
5
elevation of his house, perhaps partial elevatioa 1
6
Q. So you saw pictures inside his back yard?
6
dont know. but it was either the westerly portion of
7
A. I saw pictures of the west elevation of his
7
his house or the rear portion. I'm not sure hose you
8
house. I dont recall anything else.
8
would like to have it defined.
9
Q. I have a map here. I apologize, because this
9
Q. And when you say elevation. ljust, that's
10
is —
10
son of it feels like an architectural term.
1S
MR. O'BOYLE: Exhibit 22.
11
A. The west plain maybe of his house.
:. 2
Now there are some markings on here.
12
Q. The facade, comer section?
13
MR. 04IARE: This is from somebody else.
13
A. Yeah.
14
NIR. O'BOYLE: Do we have a blank one?
14
Q. Those arc fair words, side.
15
MR. O'HARE: You mean an aerial?
15
A. Okay.
16
MR. O'BOYLE: Yes.
16
Q. All right. And why did you see those
17
BY MR O'BOYLE:
17
pictures?
18
Q. The west elevation of Chris' house, what did
18
A. I think Officer Ginsberg provided them to the
19
you see?
19
town subsequent to taking them
20
A. i personally saw nothing.
20
Q. Okay. Providing them to the town, just for
21
Q. You saw the picture?
21
specific, to yourself?
22
A. I saw the picture, yes.
22
A. No, I don't think so. I believe flint on
23
Q. Could you see his house?
23
employee, l want to say that it zeas Kelly Avery, but I'm
24
A. Describe house.
24
not tenant, but an employee of the town downloaded and
2 5
Q. A dwelling or building with walls, a mof.
' 25
printed the pictures.
Page 116
1
Page 117
1
Q. And they were just this employee was acting
1
can go as high as a level three application, which is an
2
as like a conduit?
2
application that bus recommendations up and down from
3
A. Yeah.
3
the ARPB and is reviewed by the commission for their
4
Q. it was directed, the communication was
4
review, opprovak mje::60n.
5
directed towards you?
5
Q. But those site plans are for zoning or are
6
A I'll say yes.
6
they for building as well?
7
Q. Okay. And what did Mr. Ginsberg want you to
7
A. They arc for both. It's important to know
8
do about that, those pictures or any infomrallon that he
8
.chert the work is going on as It relates to the lot
9
sent you?
9
itself.
10
A. I believe that he called town hall and 1
10
Q. Sure. Let me just ask a couple of the things
11
believe that he spoke with a different employee asking
11
here.
12
whether there was a permit for the work that was
12
(Discussion held off the record.)
13
described for this location.
13
BY MR O'B011.E:
14
Q. Isthcre—well.letmeask. What work needs
14
Q. For the inside of the, interior of the house,
15
a permit in the town, or maybe its easier to ask what
15
ifyou needed to repaint, do you need a permit?
16
work docs not need a permit? I'll let you pick mid
16
A. That's correct.
17
choose. r
17
Q. Tiling inside?
is
A. Thanks. I
18
A. You are going to get into areas of my
19
Just about everytldng I can think of requires
19
inability to give a professional, accurate answer, but
20
a Gulf Stream site plan or permit. I don't know of
20
to that one, the answer 1 believe is no, tile.
21
amthing — I'm sure there's something. but I don't know
21
Q. Okay. And I'm assuming if you're cleaning and
22
what it is.
22
hedge trimming, it c can say — do you need a permit for
23
The level one application goes as far down as
23
hedge trimming?
24
changing the rough exterior surface ofa home to smuotli
24
A. No. I ihinkyoure right.
25
or painting the home with pastel colors of choice, and
25
Q, So if it's on the interior and it's aesthetic,
30 (Pages 114 to 117)
Florida Court Reporting
561-6B9-0999
Page 118
1 generally thats more of a Florida Building Code Issue
2 or not even an issue at all?
3 A. I do not beliesc you need a permit from
4 any body for that kind of work
5 Q. Okay. So what did Mr. Ginsberg say u as
6 happening in Mr. O'Hare's house that he needed a p=it?
7 MR STEARNS: Object to the form.
8 THE WITNESS: I do not recall speaking to him
9 directly at that point.
10 BY MR O'BOYLE:
it Q. Yaujust received pictures?
12 A. That was after the fact as fares eller the
13 incident being discovered.
14 Q. Okay.
15 A. When he lumcd them in, I couldn't tell you.
16 Q. So he didn't send the pictures right from
17 the—
I6 A No.
19 Q. Ile didn'tscnd them from the job site?
20 • A. No.
21 Q. Okay. All righL And Officer Ginsberg called
22 somebody at the town hall, but that wasn't you?
23 A No.
24 Q. Did he give a message to somebody to relate to
25 you?
Page 120
1 A. Yeah. I believe It was the backyard.
2 Q. Do you know that —so we're talking about
3 2520 Avenue Au Soleil. right?
4 A. Yes.
5 Q. Do you know that Mr. O'Hare also owns the
6 adjacent property, 2516?
7 A Yes.
8 Q. Do) ou know that there is a fence dividing the
9 tmo?
10 A. I believe there maybe. I dont recall, but 1
11 think that its possible.
12 Q. Okay. Now in order for you — I mean you sate
13 the pictures that Mr. Ginsberg took In order fer you
14 to see through his own fens, did you have to, did
15 Mr. Ginsberg have to go over a fence?
16 A. 1 don't know. I don't know.
17 Q. Do you remember seeing a fence in the picture?
18 A. No.
19 Q. Okay. But you, there is a fence dividing the
20 two properties?
21 A. There could be.
22 Q. Okay.
23 A. 1 dont recall.
24 Q. On the eastern elevation for 2516 and on the
25 western elevation for 2520?
Page 119
1 A. No. Ibelieve --I don'trecall—that slier
2 their inquiring at the City of Delay Beach, it was
3 communicated to me that there was no permit for this
4 type of work
5 Q. Can you expand upon this type of work? What
6 type of work?
7 A. h was apparent that a certain, apparent at a
e certain level that the entire rear of the house was
9 missing. You could see maybe two -by -Pours. I don't
10 know if they were structural in nature or not, but I
11 think, I think he— I'm sorry. Mr. O'Hare may have had
12 a mof Permit that was active.
13 Q. But — okay. So you're saying that —
14 A. So when they called, they may have answered—
is I don't know what they. I don't lmow how they arswered,
16 but it was concluded that the type of w ark going on was
17 not permitted.
16 And I have to say that I communicated to
19 either Mr. Ginsberg or Mr. Tobias about a stop work
.20 order. I think it was Tobias, rm not sure.
21 Q. Whicb pan, was it the wcmem elevation that
22 had two-by-fours exposed?
23 A. I'rn thinking it was, yes. It w is the portion
24 of the house opposlte his front door.
25 Q. The back yard?
31 (Pages 118 to 121)
Florida Court Reporting
561-689-0999
1
A.
Could be.
2
Q.
You justdon't matembet?
3
A.
Not as I tit here.
4
Q.
Okay. Did you see any pictures from inside
5
Mr. O'Hare's home?
6
A.
I don't recall my.
7
Q.
Okay. Did you issue a stop work order that
6
day?
9
A.
I did.
30
Q.
Okay. How many times?
11
A.
I thought only once.
12
Q.
Okay. You didn't issue a verbal one?
13
A
I don't think so.
14
Q.
Okay.
15
A.
1 might have directed to have one. but 1 don't
16
retell.
17
Q.
You mean it's possible that you ailed up
18
Officer Ginsberg and you said this is such a seven
19
situation, we need to shut down everything?
20
A.
if its work without a permit, we would, could
21
ask an
ot'ficer m ask them to stop, which may have taken
22
plate Orere. I dant reap.
23
MR. O'BOYLE: Now I'm going to mark this as
24
Evhtbi: 22.
25
31 (Pages 118 to 121)
Florida Court Reporting
561-689-0999
32 (Pages 122 to 125)
Florida Court Reporting
561-689-0999
Page 122
Pane 123
1
(The document was marked Plaintiffs Exhibit 22
1
construction. This was hand -delivered on October 28.
2
for identification.)
2
1 don't see any service document, but it's
3
BY AIR O'BOYLE:
3
very possible that this was delivered on October 28th.
4
Q. And I ask you to authenticate that.
4
Q. And then just to be clear, when the town
5
Mr. Steams 1 think is going to read it, and
5
issues letters like that, they usually do incorporate
(3
you can take a glance at it. Take my word for it or not
6
the portion ofthe code which they referred to in their
7
that that is the October 28, 2011 stop work permit. I'd
7
letter!
8
ask you to authenticate that.
8
A. Usually.
9
MR. STEARNS: That's not a stop work order.
9
Q. Okay.
10
That's a letter.
in
A. It can happen.
11
BY MR. O'BOYLE:
11
Q. Sure.
12
Q. Well — can you identify that document,
12
A. Courtesy notice may reference the code.
13
Mr. Thrasher?
13
Q. So is that a courtesy notice or is that
14
A. It appears to be documentation of or
14
something more?
2 5
presentation ofsections of the town code. Whether or
15
A. No, this is not a courtesy notice. This is a
16
not these were actually attached at the time, I have no
26
Notice of Violation.
17
recollection.
17
Q. And that means that Mr. O'Hare, ifhe doesn't
18
This is a, this is a Notice of Violation to
1B
do some remedial action, he will be taken to a code
19
Christopher F. O'Hare at 2516 Avenue Au Soleil.
19
enforcement hearing?
20
Q. So that's not a stop work order?
20
A. I guess the answer would be yes.
21
A. No.
21
Q. Or I mean or worse'? Is there any other —
22
Q. Okay. That's a code enforcement hearing
22
A. I don't know how it gets any worse than that,
23
violation?
23
but I guess it could be appealed to the circuit court,
24
A, It's a notice of a violation. And oh, it is
24
and on and on and on.
25
underway at 520, considerable amoura of interior
I 25
Q. Right. But there is a criminal provision in
Page 124
Page 125
1
the town code?
1
A. Subsequent to this notice, yes.
2
A, I don't know the answer to that question.
2
Q. Okay. And was he required to haven permit?
3
Q. Okay. That would be sort of outside the code
3
A. Yrs.
4
aaforccment?
4
Q. Dolourecallwhatt)peofactividmhetias
5
A. I think it s outside my expertise.
5
engaged in that required a permit?
6
Q. Okay. That deer say interior of the home, did
6
A. Not specifhcal ly. no.
7
it not?
7
Q. Okay. And by the way, if Mr. O'Hare would
e
A. I think it did, yes.
a
have said "No, I do nat believe that I need a permit,"
9
Q. And lou authored that let:cr'
9
he would have gone to a code enforcement hearing?
10
A. I can't be certain. I signed it. but 1 don't
10
MR STEARNS: Object to die torn.
11
know if 1 authored it.
11
TI IE WIIT'ESS: I would probably have sought
12
Q. Okay. When I say authored it. i meant don't
12
legal advice on such aconhment.
13
know if it was you. Town Manager Thrasher putting keys
13
BY MR O'BOYLE:
14
into a kniward and then typing that out, but did you
14
Q. Okay.
15
direct somebody to write that, I guess?
15
A. That's pretty hypothetical there
16
A. Yes. If I didn't do it, I would have directed
16
Q. Well, if he did get a notice. so I didn't
17
somebody to do this.
17
know —
18
Q. Okay. So what is being referred to there with
18
A. ThaCs not what you said or asked me most
19
die interior ofthe home?
19
recently. You asked me a hypothetical question. and
20
A. 1 don'tknow the answer to that.
20
1-
21
Q. You dont remember ifyou had any information
21
Q. Was that notice —1 apologize. Was that
22
that came from inside of Mr. allare's home?
22
notice putting Mr. O'Hare bound for a code enforcement
23
A. No, I dolt think so.
23
hearing?
24
Q. Okay. Now, did Mr. O'Hare rc:eih e it permit to
24
A. Not necessarily.
25
do whatever it was he wvu doing inside of his house?
25
Q. Is there something that has to occur further
32 (Pages 122 to 125)
Florida Court Reporting
561-689-0999
33 (Pages 126 to 129)
Florida Court Reporting
561-689-0999
Pa7c 126
Page 227
1
before a code enforcement hearing could —
1
stop work order?
2
A. Yes.
2
A. No.
3
Q. What is that?
3
Q. Why did he not?
4
A. Compliance.
4
A. I did.
5
Q. Right. And because compliance is the ultimate
5
Q. So you did issue— so it's not within the
6
goal — sorry if laughed there a little bit.
6
Town of Delray Beach's prerogative to issue?
7
I mean is there any other sort of subsequent
7
A. No.
8
notice flint says "Hey, Mr. O'Hare, we're really serious
a
Q. Okay. Did Mr. Tobias report to you back why
9
now, you are going to a code enforcement hearing"?
9
or did he help you in making that determination?
10
A. It's my recollection, and I could be
10
A. I think he substantiated that work was going
11
incorrect, that very shortly after receiving this
11
on without a permit, and it did need a permit. How he
12
notice, Mr. O'Hare applied for and received a permit
12
did that, I don't know, and I don't recall him saying
13
from the City of Delray Beach, the date of which 1 am
13
exactly that.
14
not certain.
14
Q. All right. And that's fair. You are just
i5
Q. Okay. And was Mr. Tobias accompanying
15
paraphrasing.
16
Mr. Ginsberg on that day?
16
A. I wasn't there.
11
A. Yes.
17
Q. Right. But Mr. Tobias did report back to you?
is
Q. How did Mr. Tobias get involved?
is
A. What 1 do Mow is that I directed Mr. Tobias
i9
A. I called him.
is
to place a stop work order at that location. I did
-'0
Q. So you had some information that—
25
that.
21
A. 1 had indication and I wanted Mr. Tobias to
21
Q. Right. And because Mr. Tobias was the
22
issue a stop work order if indeed there was a permit
22
building inspector for the City of Delray Beach?
23
required for the type of work that was allegedly going
f 23
A. He was an inspector. I don't know what level
24
on.
24
he was involved as inspections.
25
Q. Okay. So was — did Mr. Tobias issue that
25
(
Q. Amyou oryour assignees —when I say
Page 128
rage 129
1
assignees, people you ask —
1
Q. You Avoid not ask than to do code enforcement"
2
A. That's fine.
2
A. To do that n pe of enforcement, no. Their
3
Q. Okay. In furtherance of code enforcement and
3
pumsc is to gather information. I may ask for a
4
building. were you allowed to go into any house in the
4
picture or something of that nature. but dot's about
5
Town of Gulf Stream?
5
it.
6
A. No.
6
Q. Okay. Under what circumstances can your code
7
MRSTEARNS: Objccttotheform.
7
enfhrcemen4 in your code enforcement duties or your
8 '
THE WITNESS: Could you clarify that?
8
assigns, under what circumstances can they enter the
9
BY MR O'BOYLE:
9
back yard or go over fences or look over fences?
10
Q. Sure. Ifyou suspect, Icrs just say you (
_0
A. I don't know the answer to the question.
11
suspect that there is a code violation can the interior.
11
MR STEARNS: Object to the form.
12
Have you or have any of your assigusjust I
12
BY MR.OSOYLE:
13
walked into the house to investigate?
13
Q. Okay. Has there ever been any discussions
1 :
A. Not to my knowledge. I
14
about the privacy orthe residents and entering their
15
Q. Is there a, any sort of policy that you have
15
private areas of their homes?
16
promulgated with going into people's houses?
:6
A. Not that I recall. There may have been. I
17
A. I have not.
17
just don't recall.
18
Q. Okay. Have you instructed anybody that they
16
Q. Okay. So 1 on would recognim it as wrong for
19
need to get a warrant or some court order?
19
one ofyour code enforcement assigns to just walk into
20
A. I leave that instruction, that type of
20
somebody's house and startwriting than up?
21
instruction to the police department.
21
?-M STEARNS: Object to the form.
22
Q. Okay. So if you asked Brian Dietriek —
22
THE WITNESS: I would say that I would leave
23
A. I would not do that.
23
that in the hands of the police derrartment.
24
Q. A public works employee?
24
BY MR O'BOYLE:
25
A. No. I
25
Q. As to whether— but I'm asking. do you think
33 (Pages 126 to 129)
Florida Court Reporting
561-689-0999
34 (Pages 130 to 133)
Florida Court Reporting
561-689-0999
Page 130
Page 131
1
that that's %rung? Do you recognize that?
1
reasons?
MR. STEARNS: Object to the form.
2
MR. STEARNS: Object to the form.
3
THE WITNESS: 1,1 think its a legal
3
THE WITNESS: There probably are instances as
4
question. I don't have an answer for you.
4
related to almm codes going off, evidence of
5
BY MR O'BOYLE:
5
breaking and entering, broken windows, doors. I,
6
Q. Okay. Have you had any sort of training in
6
I'm sure there Is others. I just daft know.
7
having government employees going into people's private
7
BY MR O'BOYLE:
6
arm?
6
Q. Okay. So — all right. That's line.
9
A. No.
9
Well, that's fine, because anything else --
10
Q. Okay.
10
are you talking about circumstances that have occurred
11
MR STEARNS: These are pure legal questions.
11
or --
3 2
MR. O'BOYLE: Whether there has been training?
12
A. I believe so, yes.
13
MR STEARNS: No. your questions of is it
i3
Q. Okay. But anything beyond that would really
14
wrong? Is it right? All of that.
14
just be you guessing?
15
MR, O'BOYLE: Might feel moral compunction.
15
A. Yes.
16
BY MR. O'BOYLE:
16
Q. Okay. That's fine.
17
Q. Does the town code allow far code enforcement
17
Are you aware that Chris O'Hare applied for a
18
officers to go inside a house for any reason?
le
metal roof?
79
MR. STEARNS: Object to the form.
19
A. Yes.
20
THE WITNESS: I do not believe so.
20
Q. What was your Involvement with those
21
BY MR O'BOYLE:
21
decisions? I'm sorry, the decision -- it hat was your
22
Q. Are there certain reasons that they are
22
involvement with Mr. O'Hare and a metal roof in the
23
allowed to go inside a home?
23
town?
24
A. Ifinviicd.
24
A. Idon'tknowwheretostar,
25
Q. '??tai's a goad reason. Are There any other
I 2.5
Q. I mean if you could provide a nt rative, that
Page 132
Page 133
1
would be fine.
1
else who probably worked with Mr. Roeder, they asked
2
A. Can 1 what?
2
about a metal roof in the town initially, cntrect7
3
Q. Pmvidc o narrative.
3
Asked you about it?
4
A. I find it difficult to do that It's quite
4
A. 1 dont recall that.
5
extensive.
5
Q. What do you remember with Mr. Roeder and
6
Q. Okay. Well. how du we get that information
6
conversations about a metal roof?
7
that you have onto this court rcpurlces machine?
7
A. I know there were conversations in the public
9
MR. STEARNS: Did Chris O'Hare submit a roof
a
hearing. I have general mcollection ofthe -- I don't
9
permit application to you?
9
know if it's conversation, or statements by Mr. Raeder
l o
THE WITNESS: Okay, I'll try.
10
in a Board of Adjustment hearing.
11
MR STEARNS: IM saying he can ask you single
1 i
And there may have been it communication
12
questions and take you step by step, but you ve got
12
of some type.
13
to star there.
13
Q. Prior to Mr. O'Hare submitting a level one
14
171E WITNESS: I see. Go ahead.
14
permit for a metal roof, were there prc-permit
ib
MR STEARNS: Did Chris O'Hare submit—
15
communications?
16
MR O'BOYLE: No, wait
16
A. Mr. O'Hare did not submil'a level one
17
BY DTR. O'BOYLE:
17
application for a metal roof. He. in August of201i he
10
Q. Did any one of Chris O'Hue's a@ents reach out
is
applied for a white through-and-through cement concrete
19
to the town and inquire about a Tnetal roof?
19
the roof, which was approved in that some month.
0
A. I had conversstons with Mr. Lou Rocdey 1
20
In November I believe he came, his agent or
:i
believe, and maybe — I don't recall anybody else. We
21
representative, his contractor came in for a roof
2
had conversaduns, but I don't recall.
22
revision. The permit itself written by the contractor
3
Q. But not malhy with Mr. O'Hare initially?
23
indicated that RIn O'Hare wants a metal roof. 11:at's
2 4
A. I don't think so. I dont think so.
24
approximately the middle of the month. That revision
25
Q. And with Mr. Roeder, he was, or maybe somebody
25
was not approved. The original white cement the roof
34 (Pages 130 to 133)
Florida Court Reporting
561-689-0999
35 (Pages 134 to 137)
Florida Court Reporting
561-689-0999
Page 134
Page 135
1
was.
1
that effect.
2
And then we•get into -- I'll let you take it
2
Q. Did you ever tell Mr, O'Hare about this
3
from there.
3
exception?
4
Q. Sure. You responded to that request to change
4
A. No.
5
to a metal roof, did you not?
5
Q. Okay. And that so Mr. O'Hare then submitted
6
A. I'm sure i did in some form or fashion.
6
for a permit?
7
Q. Okay. Do you remember saying that no metal
7
A. tvty O'Hare. his agent in November, November of
6
roofs are allowed in Gulf Stream, period?
a
2011, rcquested a permit revision. He presented to us a
9
A. i believes did.
9
permit revision form.
10
Q. Okay. Were you correct in making that
10
And on that it said that W. O'Hare wants a
it
statement?
11
metal roof, Didn't say he needed a metal roof. Said
12
MR. STEARNS: Object to the form.
12
that he wants a metal roof.
13
THE WITNESS: Except where a metal roof is
13
Q. Is that a level one review? Is that something
14
allowed by code related to a decorative accent. but
14
you could do unilaterally?
15
not the entire roof structure itself.
15
A. The metal roof or denying a metal roof?
16
BY NIR. O'BOYLE:
16
Q. Well. approve it or deny h.
17
Q. Okay. So there's no exemption under the town
17
A. I would not be able to approve a metal roof,
is
code for structurally -infirm buildings to have a metal
] a
no.
19
roof?
19
Q. wily?
20
A. There was a code that allowed that. I don't
20
A. Its prohibited by code.
21
recall the language, but in essence,lhafs the content
21
Q. But there is an exemption?
22
of the code.22
!
A. Yes.
23
If a roof could not support the weight, l
23
Q. And that exemption required an engineer's
24
guess, of a concrete tile roof, that an engineering
I 24
certificate. right?
25
report, that provision may be waived, or something to
25
A. I believe that that report could be, that
Page 136
Page 137
1
single -page document from J4r. Lunn could he considered a
I
BY MR. O'BOYLE:
2
reriLcate.
2
Q. Why did you deny Mr. O'l lare?
3
Q. I'm sorry. it could?
3
A. This tars s decision I made, that the inquest
A. 1 believe so.
4
wins for a metal roof, and I did not approve the permit.
5
Q, Okay, But it is not a report^
5
Q. Was there anything defective about the
6
A. It seemed to be a letter of general name
6
engineering steel or was this just something --I don't
7
tram Mr. Lunn, but his seal, 1 guess he's a structural
7
know, maybe you can tell me,
a
engineer on that, on the face of that letter.
a
MRL STEARNS: Object to the form. Can you
9
9
answer that quation?
10
1The document was marked Defendam's
10
THE WITNESS: 1 have comments about it.
11
Exhibit 19 for identification.)
11
MR. STEARNS: Go ahead.
12
BY MR. O'BOYLE:
12
THE WITNESS: in mid October Mr. O'Hare
13
Q. Okay. And— well, I'm going to show you
13
applied through his agent or representative for a
14
Exhibit 19. Did you already lock at this?
14
roof m'ision, mid November 2011.
15
A. I'm familiar with it
15
In mid December Mr. Lunn said he had visited
16
Q. Okay. that's perfect.
16
the premises, one month lata and after the
17
A. I may ask you to give itto me, but generally
17
revision request which stated that Mr. O'Hare
is
I'm familia with it.
is
wanted a metal roof.
i9
Q. Okay. Aral this was not significant --or fm
19
What I am used to seeing in some documentation
20
sorry, this was not significant
20
ofthat gives a general report. and engineers
21
What was wrong with this certification in the
21
usually have some kind of backup calculations.
22
language of the code? Why did Mr. O'Hare not gel a
22
What was attached to Mr. Lunn's letter w as five
23
mew war
23
pieces of reference material about him and nothing
24
MR STEARNS: Youjust asked three quer ions.
24
else.
25
JB2. O'BOYLE: Sure, okay.
25
35 (Pages 134 to 137)
Florida Court Reporting
561-689-0999
36 (Pages 138 to 141)
Florida Court Reporting
561-689-0999
Page 138
Page 139
1
BY MR.O'BOYLE:
1
BY MR.O'BOYLE:
2
Q. You mean about him, resumes and —
2
Q. How about we leave Ods as just maybe you
3
A. Yeah. where he had worked and affiliations
3
being surprised at some later date.
4
that he had, but no documentation.
4
Olay.
5
Q. Did you consult x Rh Mart}• Minor on this or
5
A. I think Mr. Roeder was present at the Board of
6
b4. Minor?
6
Adjustment hearing as well, made comments on behalf of
7
A. 1 may have.
7
his client.
8
Q. When }nu say may have—
8
Q. Yes. And you prepared a staff report for the
9
A. I don't recall. I'm not saying I didn't. f
9
Board of Adjustment, right?
10
don't recall.
10
A. I'm sure1 did.
1.1
Q. Did you consult with town counsel on this?
1 i
Q. And that was to deny —
12
A. 1 think I did. but I don't recall that as
12
A. Probably recommendation to — I don't know.
13
well
13
should have been a recommendation to uphold town
14
Q. Do you remember what own counsel said?
14
administrator's decision.
15
A. No.
I 15
Q. Right Now, do you recall saying, telling
16
Q. Okay.
16
Mr. O'Hare that he needs to get a variance If he wants a
17
A. No.
17
metal root?
18
Q. Would it surprise you to learn that tourI
18
A. I typically have a standard conversation with
n
counsel said Mr. O'Hare did not need a variance and that
, 19
residents. so I believe that I did, and also I believe I
:•o
this certificate. Eehibit 19,was all that was required
I 20
had communication with Mr Roeder that options available
21
under the town code?
21
to Mr. O'Hare were, one. apply for a variance: or two,
22
MR. STEARNS: Object to the form.
22
challenge my administrative decision on the matter
23
THE WITNESS: It would surprise me, y cs.
23
before the Board of Adjustments.
24
MR O'BOYL& Do we have the transcript?
24
Obviously they chose to challenge my
25
(Discussion held off the record.)
25
administradsc decision. I do not believe that
Page 140
Page 141
1
Mr. O'Hare filed for a variance application.
1
concept.
2
Q. Okay.
2
Q. Ora great exempla Nonetheless, did you tell
3
A. But he did challenge m} administrative
3
Mr. O'Hare that if town engineer was alloned to
4
decision, which is an option prmtided to any resident
4
inspect his propem•, he might have second thoughts?
5
property owner to do. I
5
A. I don't know if I had conversations with
6
So as a standard procedure, I'm pretty
6
Mr. O'Hare. I know that there was conversation perhaps
7
confident that I had those communications with either I
7
at commission level about this very thing.
a
Mr. O'Hare. Mr. Roeder, or hath
8
I know that at that commission meeting, my
9
Q. And a variance. just so I understand it, is
9
recollection is that I asked Mr. Roeder for backup
10
like a catch-all, if something is prohibited under the
i o
material o Mr. Lurds report, perhaps engineering
11
code, you can always ask for a variance?
11
calculations.
12
A. Well, l could and should ask you what you mean
12
I believe Mr. Rocdces response was "I don't
13
by catch-all.
13
believe my client wants you to have those."
14
Q. If something is prohibited by the code —
14
So it was an attempt by me in asking
.5
A. Olay.
is
Mr. Roeder that qu=ion as he was tcstif}•ing to perhaps
16
Q. But for whatever reason, you think you need
16
impossblyjustifythe metal roof application. but they
17
iy you can apply for a variance and get things the you
17
did not want to provide any documentation, and I bcL'evc
is
would not otherwise gel?
18
Mr. Roeder said his client does not want us on or in his
19
A. It's an option provided to the plan owner, the
19
property,
20
resident property muter to have an additional review by
20
That's my recollectiom Could be wrong
21
the commission.
2i
Q. Okay. And by the way, the last question I
22
My decision may be no metal roof. but in a
22,
asked was did you tell Mr. O'Hare this, but —
23
quasi-judicial hearing it may be determined no, were
23
A. I thought 1 answered I don't recall, but it
4
going to give ynu a metal roof. Metal roof may be a
24
went—I know it was part of the commission or the
25
poor example since that's part of the case, but same
25
Board of Adjustment commtmication, and comment.
36 (Pages 138 to 141)
Florida Court Reporting
561-689-0999
37 (Pages 142 to 145)
Florida Court Reporting
561-689-0999
Page 142
"
Page 143
1
Q. Okay. This is a different question.
1
Officer Ginsberg.
2
Do you know iFTown Clerk Rita Taylor told
2
A. It was involving Officer Ginsberg. yes.
3
either yourself or Mr. O'Hare that the town's engineer
3
Q. Can you tell mea little bit about what was
4
should review Mr. O'Eiam's property, get inside there?
4
said at that meeting?
5
A. Say that again or ask that again, please.
5
A. Well, my recollection is poor. 1 believe
6
Q. Did Town Clerk Rita Taylor tell either you or
6
Mr. O'Hare or Mr. Roeder made claims or allegations that
7
Mr. O'Hare that the town's engineer should go Inside of
7
Mr. Ginsberg entered the house without permission or
6
Mr. O'Hare s home to review?
6
something to that nature.
9
A. i don't, l dont — the word "should"Ido nut
9
Q. Okay.
10
recall.
10
A. I don't recall any more than that. other than
11
Q. Okay. This is, by the way, prior to the
11
Mr. O'Etare getting upset and saying "1 think I'm going
12
appeal to the Board of Adjustment.
12
to thrmv this table. I might thrmv this table at you.
13
A. That could have happened. I wasn't present.
13
this glass table hese." I remember that pretty clear.
14
1 don't know.
14
Q. Mr. O'Hare said that?
15
Q. Okay. So you don't =member any convers=ions
15
A. Mr. O'Hare said that, absolutely. Absolutely.
16
about getting the town employee inside Mr. O'liare's
16
Q. You seem a little bit upset right now.
17
house?
17
A. Yes, it did trigger—he bothered me with
le
A. Town employee?
19
that statement and he actually caused me to fear for. -n,
19
Q. An engineer. an agent, a consultant
19
own life, absolutely.
20
A. Oh. I don't recall.
20
Q. And was Officer Ward them?
21
Q. Okay.
21
A. And Mr. Roeder and Mr. Randolph were present.
22
A. May have happened. I don't recall.
22
That is correct
23
Q. Now. you had a meeting with -- I think you
23
Q. Was Chief Ward there as well?
24
referenced it before-- with Mr. O'Hare. Mr. Roeder. l
24
A. No.
25
think yourself, and possibly Mr. Randolph regarding
( 25
Q. Okay.
37 (Pages 142 to 145)
Florida Court Reporting
561-689-0999
Pago 144
"
Page 145
1
A. You—IrememberiL
1
foliage.
2
Q, Okay. Do you remember anythingclse?
I
2
Do you remember that?
3
A. No.
3
A. I renuanber the incident. I don't r member the
4
Q. Okay. Other than Mr. O'Hare making you upset?
4
date. 1 do remember that it was reported to me that he
5
A. 1 said he made me upset and he caused me to
5
was p!aming in the right -of -"ay, duwn the right -of -v. a} .
6
fear for my life.
6
Q. Okay.
7
MR. STEARNS: And he also summarized what you
7
A. Sort of species, I don't remember which one
a
said about Ginsberg.
a
they were.
9
BY MR. O'BOYLE:
9
Q. Did you see it yourselfpersonally?
10
Q. Okay. Let me ask you this little pertubation.
10
A. No.
11
Just tell me ifyou remember this or if it refreshes
11
Q. Did you communicate with a police offices?
12
yourmemory.
12
A. Yes.
13
Did town attorney, Mr. Randolph, did be say
13
Q. Was that police officer Sergeant Gorel?
14
anything about Mr. Ginsberg enforcing immigration?
14
A. Yes.
15
A. I dont recall that at ail.
15
Q. And Sergeant Gorcl was talking to you or
16
Q. Okay. Hat c you heard anybody in the town or
3.6
reporting this to you via the telephone?
17
the town police WL about enforcing imunigration laws?
17
A. Yes.
18
A. Not that I recall.
16
Q. Okay. And what he said to you was that
19
Q. And you yourself have not —
19
Mr. O'Hare was planting the wrong type of species?
20
A. No.
20
A. No.
21
Q. — directed anybody to?
21
Q. Okay. What did he say?
22
A. No.
22
A. That Mr. O'Hare was planting irce; I believe,
23
Q. Okay. Now back in 2011, and I'll say it's
23
in the right-of-way, town's right-of-way.
24
November 2011. Mr, O'Mara was planting trccs, I thinks.
24
Q. Okay. And did he tell you how he knew it was
25
or there was un incident with him planting trees or
25
the right-of-way?
37 (Pages 142 to 145)
Florida Court Reporting
561-689-0999
38 (Pages 146 to 149)
Florida Court Reporting
561-689-0999
Page 146
!
Page 147
1
A. I third,, we had a conversation as to the
I 1
this order?
2
approximate distance from the edge of road they were
2
A. Sometime later I went onto other business.
3
planting.
3
Q. Did you send Mr. O'Hare a letter subsequent to
4
Q. Okay. So it was a rough estimation that this
4
that incident saying that he needs a permit before doing
5
was in the right-of-way?
5
any landscaping on his property?
6
A. I don't know exactly what the technique we
6
A. I may have.
7
for determining the distance, but that was generally the
7
Q. Okay. Is there a basis —
8
conversation. 011endmcs they will measure from the
I 6
A. I don't know, permit. site plan combination.
9
center of the mad or a distance from the edge of the
9
Is there a basis? It seemed that it was a
10
road. just ballpark, but I don't know what he did.
10
material change to his landscaping.
1 1
Q. Do you know If they normally overmeasure just
11
Q. Okay. And whatpartof the code says that for
12
to make sure that they are definitely —
12
any landscaping you need to ha%a a per idt?
13
MR. STEARNS: Object to the form.
13
A. I don't think the code does, but we mov have a
14
THE WfINESS; I don't know.
14
permit application level one that talks about it, but 1
15
BY MR. O'BOYLE:
15
have not seen it
16
Q. Okay. Do you recall that Mr. O'Hare
16
Q. Okay.
17
immediately removed those trees?
17
A. I think the code perhaps talks about let el
18
A. I believe that he did, yes. He removed the
18
two, level duce applications, quasi-judicial hearings.
19
treys.
19
There is language about such.
20
Q. Okay. Based upon, tvua it you asking him or
20
Q. Okay. And what part of the onde says that
21
was it Sergeant Gorel?
21
you're notallowed to plant trees in the right-of-way?
22
A. I directed Sergeant Gorel to inform him that
22
A. There is no such code.
23
the trees hod to be removed from the town's
23
Q. Okay. Is there any type of minor landscaping
24
right-cf-way.
i 24
that doesn't require a permit?
:5
Q. And how did you Icarn that he complied with
25
A. Yes. I don't know what it is, but typically
Page 148
Page 149
1
somebody about who is wanting to install a tree or two,
1
BY MR. O'BOYLE:
that would not require apermit ora site plan review.
2
Q. Okay. Did )To direct Officer Ginsberg to take
3
unless it's observed that it's potentially being located
3
pictures of Mr. O'Hare's house past October 28, 2011?
4
in die town's right-of-way or on wwn property.
•1
A. I don't rswll,
5
Q, Okay. So like a llower garden. flat's not
5
Q. Do you remember ever receiving any pictures of
6
really —
6
At. O'HaWs home after October 28, 2011?
7
A. No. no. As long as it's not in the
7
A. It's possible. 1 just don't recall.
B
right-of-way. live had such things occur. I believe
8
Q. Okay. NYhen I say home, I mean 2520 Avenue Au
9
Mr. Roeder or Mr. O'Harc has informed me ofsomcthing
9
Soleil.
20
similar. Had to do with a mailbox which was two doors
10
A. Understood.
11
west of Ned McDonald's old place. But I asked the poor
11
Q. Or 2516, as bath —
12
lady to remove all theastuiT. Shc had somebody do it.
12
MIR. STEARNS: Homes.
13
Q. You seem like you found that to bejust silly.
13
MR. O'BOYLE: Homes.
14
A. No, I recognized their concern and responded
14
BY MR O'BOYLE:
15
accordingly.
15
Q. Okay. Did Mr. 07iare make a window
16
Q. So he actually, Mr. O'Hare was correct in
16
application in about early 20127
17
pointing out a code enforcement?
i7
Do you remember that?
18
MR. STEARNS: Object to the form. I
i B
A. I do beletL Mr. O'l lare applied for a window
19
THE WITNESS: I —
19
porniL I don't know the date. It's probably in that
20
MR. STEARNS: What does correct mean?
20
range of time.
21
THE WMESS: I don't know other than these
21
Q. Do you recall what happened with that permit?
11:1
plantings. and I thirds there was some brick work
22
A. It's my recollection that I initially asked
:3
µLie observed to be recently installed and they
23
for additional input referencing die section ofthe code
34
were located in the right-of-way.
24
that related to windows being divided by mullions, but
25
^.5
I'm not certain. Thafs generally my recollection.
38 (Pages 146 to 149)
Florida Court Reporting
561-689-0999
39 (Pages 150 to 153)
Florida Court Aeporting
561-GB9-0999
Page 150
Page 151
1
Q. So when you say you rejected it, did you flat
1
three.
2
out reject it or did you make It a level two?
2
Q. Right Okay.
3
A. I think that normally my procedure is. and I
3
A As a general practice. I don't approve
4
think that's what I followed here, is to communicate
4
discouraged items. I catch them.
5
with the contractor. Tried to give him copies of the
5
MR. O'BOYLE: Let's take a quick break.
6
code for clarification of what would be expected or
6
THE WITNESS: Thank yam
7
something that I had the authority to approve.
7
(A recess was taken.)
a
Q. Okay. And mullions arc, I guess, do they make
8
BY MR. O'BOYLE:
9
you feel uncomfortable that that's sort of, should be
9
Q. All right, Mc Thraehcr, can werejust
10
dealt with by n higher potrer7
is
discussing windows and no permits.
11
A. What's that?
it
A. Okay.
12
Q. Ngen you get a permit application for window's
i 12
Q. And you were telling Mr. O'Hare that
13
that contain mullions —
13
1& O'Harc's window permits were denied or they were met
14
A. Okay.
14
with a condition?
15
Q. —is that something that you would typically
15
A. No, we I think asked for fiat er
16
approve or is that something that you would give to the
16
clarification. We provided further clarification to the
17
Architectural Review Board?
17
contractor. That's my remembrance. I don't recall.
3.8
A. No, I can approve something like that if it
is
Q. Okay. And I apologize. Nghar did you say to
19
meets the code. If it did not meet the code by
19
the contractor')
20
something that's determined to be discouraged, I would
20
A I didn't speak to the contractor. Somebody in
21
not approve it.
21
the office did.
22
Q. Because discouraged would require— is that
22
Q. Okay. Now, let's see, wficre was it? By the
23
Architectural Review Board?
23
way. when was the first time that you saw
24
A. I believe that by code, I have the option to
24
Officer Ginsberg's incident report?
25
increase any level review one level, excluding level
25
A. I dont recall.
39 (Pages 150 to 153)
Florida Court Aeporting
561-GB9-0999
Page 152
Page 153
1
Q. Okay. Have you seen it al all to date?
1
i
Q. When you say predominant, do you mean dominant
2
A. I don't think so, but I don't recoil.
2
or what do you mean by that?
3
Q. Okay. And when you receive reports from the
3
A It has a multitude ofarchftectural elements
4
police, they come in the form ora standard form
4
that generally are attributed to Gulf Slrea n Bermuda
5
incident report?
5
Georgian -style hums.
6
A. Sometimes it can be communication. Sometimes
6
Q. Is it categorized as a various or an other?
7
it's an incident repon, yes.
7
A It is in our history book of styles as of t999
9
Q. Communications like an a -mail?
9
as a Gulf Stream Bermuda
9
A. Lisually phone or some comcrsation with the
9
Q. Is them any other pan of the code which
10
chief
10
contradicts that?
11
Q. Right, but that's a verbal communication?
11
I'm cony, what is that style reference that
12
A. Yes.
12
you justrelamnced? What is that? Is that in the town
13
Q. Not Twittering each other?
13
code?
14
A. No.
14
A. Yes
15
Q. Faro enough.
15
Q. Chapte00?
16
Mr. O'Hares house — I'm sorry, under Chapter
16
A Yes.
17
70, the design manual, there we three ditTerent
17
Q. Where Mr. O'Hare's house is labeled as a
18
categorizations orstylings of houses; is that correct?
18
Bermuda?
19
A. Generally.
19
A. I sold that the pmdaminant architectural
20
Q. And what were those three stylings?
20
elements of his home are of the Gulf Stream Bermuda
21
A. Otter various, Mediterranean, Gulf Stream,
21
style.
22
Bermuda (
22
Q. So [hero is other elements that arc not?
2.3
Q. What style of house is Mr. O'Iiare's?
23
A Yes.
24
A. It has predominant Gulf Strcam Bermuda
24
Q. And do youbave that map?
25
features.
25
In the [ohm code, hough, isnt Mr. O'Hare's
39 (Pages 150 to 153)
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1
house at 2520 Avenue An Solcil, isn't that listed as a
'_
1
But the town manager at that time. Chris
2
various other?
2
Garrison, did a suave) of the elements, l assume —1
3
A. 1 believe that on the analysis sheet it is
3
don't know for sure — and determined that this home had
4
listed as other various. but the actual review of his
4predominant
Gulf Stream Bermuda features and idendficd
5
home is of Gulf Stream Bermuda style. It was
I 5
as such on our photo analysis sheet
6
determined to be such as early as 1999, and not by me.
6
Q. Is that photo analysis par of the code?
7
Q. And so which one is I guess predominant or
I 7
A. I believe that it is referenced in our code by
8
which one carries the higher force?
8
that, but I'm not certain.
9
Is it the diagram in Chapter 70, which I'm
9
Q. 0o you know where in O:e code it would be
10
sure well show you in a second —
10
referenced?
11
MR. STEARNS: We dont need it
11
A. No.
12
THE WITNESS: The more restrictive section of
I 12
Q. Okay. Would it be in Chapter 70?
13
the code, which would be the actual existing
13
A. If it exists, it would be in 70, yes.
14
elements, would be considered Gulf Stream Bermuda.
14
Q. So you're not particularly sure if it exists?
15
BY MR. O'BOYLE:
I 15
A. No.
16
Q. Okay.
is
Q. Okay.
17
A. And that analysis sheet actually needs to be
17
A. I'm noL What I am sure are the elements
is
changed at some point in time. But it is not the
18
listed in the Gulf Stream Bcrmuda section of die code
19
overriding laclur in dacrnrining the architectural style
19
for architectural styling.
20
ofa home. The elements are.
20
Q. And under the cado, depending on what
21
Q. Okay. And if — it ell, how does one change the
21
architectural style you have —
2 2
styling? How did W. O'Hare's home go from being a
22
A. Okay.
23
various other to Bermuda?
23
Q. — you're allowed to have dhTerent things
24
A. Well. I don't know that it was actually other
24
depending on different styles; is that correct?
25
Carious. It may very well be.
25
A. 1, I don't kmow what you mean by that
Page 156
Page 15;
1
question, frankly.
1
snwoth or not smooth enough?
2
Q. Okay. Certain elements of style, certain
2
A. It was rejected because it didn't have detail
3
building elements would be perhaps discouraged fur a
3
in the garage doors such as conurtonly seen in Gulf stream
4
Spanish Mediterranean, but would be preferred if the
4
Bemtuda style hone s. panels and rectangular features.
5
house was a Bermuda house!
5
Q. Okay. So in pan, Otis smooth garage door was
6
A. That's I'd say generally correct
6
denied because Mr. O'Hare find a Bermuda style house?
7
Q. And than if you're various other, do you have
7
A. Yes.
8
the most latitude?
8
Q. Okay. And was this the first time to your
9
A. I would say in my estimation, yes. Yes.
9
knowledge that something was rejected from 7520 Avenue
10
Q. Because you we not really fining into either
10
An Salcil because of a style clash?
11
category?
11
A. I don't recall.
12
A. Right.
12
Q. Okay. And how does one get recategodud from
13
Q. Okay. And do you remember denying — I'm
23
a Bermuda style to a Spanish Mediterranean or to an
14
sorry, do you et a recall W. O'Hare submitting a permit
14
uther?
15
for hurricane -rated garage door? I
15
A. I think there are various possibilities. One
16
A. Yes.
16
could be as simple as the owner of the house wanting to
17
Q. What happened with that permit?
17
change the rough surface, concrete exterior surfwe to
is
A. 1 believe it was denied.
18
smooth, or painting the home with soft pastel colors.
19
Q. Do you know why it was denied?
19
Could be changing a maL
20
A. It was not in keeping with the GulfSueani
20
It could be also accomplished through
21
style element—
21
quasi-judicial hearings of level lwro. possibly level
22
Q. Okay.
22
Once, wherea home lsdemalishedand start all o.cr,
23
A. —of rectangular features and door detail.
23
that sort of thing. I mean theremay be other options.
24
It was smooth, as I recall, totally smooth.
24
Q. Okay. Are you aware of any other routes that
25
Q. As in it was rejected because it was too I
25
people have taken under your tenure as town manage.
40 (Pages 154 to 157)
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A. I know of, I think] know of. as far as a
1
Q. Okay. Would it surprise you ifyou did?
2
nonlevel three application, I believe there was one, and
2
A. Yes.
3
there is possibly one yet to come down the pike.
3
Q. Okay. Did you ask Marty Minor to determine
4
Doesn't happen too much. It's a rather significant
4
that Mr. O'Hare's home is Gulf Stream Bermuda?
5
change or could be costly. I don't know, other than
5
A. I asked for a report of the inventory of the
6
that.
I 6
elements of Mr. O'Harces home, what was his view.
7
Q. Is it easier to go from a various other
7
Q. And why did you ask?
6
classification into Spanish Mediterranean orBernuda?
8
A. lust to supplement my own conclusion.
9
Is it easier to do that than to go from Bermuda to
9
I
Q. Did Mr. O'Hare have the ability to argue that
10
Spanish Mediterranean?
10
his house should not be recategorized?
11
A. I don't know.
I 11
A. This is determined by architectural elements
12
Q. But it does require a hearing, though?
1 12
that exist on the structure itself.
13
A. No.
I 13
Q. So is this an instance of beauty is in the eye
14
Q. May. Who can change the style or how does
i4
of the beholder or —
15
the style get changed without a hearing?
15
MR. STEARNS: He told you that it wits
16
A. The only approach that I know without a
16
recategorized in 1999. Mr. O'Hare bought the
17
hearing is if the owner determines to make changes to
17
property in 2011, right?
19
his home in which I have the ability to approve, or
ill
MR. OSOYLE: Yes, but there's also,
19
authority to approve —
19
Mr. Thrasher also asked Mr. Minor to justify a
20
Q. Okay.
20
recategorization.
21
A. -- outside a quasi-judicial hearing, which
21
THE WITNESS: I didn't ask him to justify. if
22
would be a natural event.
22
I did I shouldn't have used that word.
23
Q. Okay. Have you ever approved a smooth garage
23
I asked him to give me an independent report
24
door for any other Bermuda style hurne?
24
of what he determined to be the architecture
25
A. Not to my knowledge.
25
elements ofthe home, outside of it being a
41 (Pages 158 to 161)
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Page 161
1
particular style.
1
would take action?
2
BY MR. O'BOYLE:
2
MR STEARNS: Object to the form
3
Q. Are than any other instances where you asked
3
THE WITNESS: Yeah, because that to me was
4
Mr. 4larty.furor to take a second look at the
I
something that could affect the neighborhood, the
5
classification of the style of a home? (
5
neighbors, and if they didn't feel like it affected
6
A. Not that I recall. !!!
6
them, then I didn'Lthink that I should go any
7
Q. Okay.
7
further.
6
A. Could have happened. ljustdon't recall.
9
BYMR.O'BOYLE:
9
Q. Now Mr. O'Hare had some landscaping done in
9
Q. And do you recall what actions you did take
10
late 2012. Do you =call any incident with that?
10
with regard to Mr. O'Hare's landscaping as a result of
11
A. Vaguely,
it
that communication with the homeowners association?
12
Q. Do you need me to help refresh your memory?
12
A. I don't think that 1 took any action exclusive
13
A. Sure.
13
of that communication. I mean there had to be more
14
Q. Okay. Do you recall an e-mail that you wrote
14
reasoning behind it than just that communication.
15
to Place Au Soleil Homeowners Association asking the
15
Q. Okay. Well, did you send Mr. Marty M'mor out
16
members if they liked Mr. O'Hare's landscaping?
16
to go inspect Mr. O'Hare's home after —
17
A. I believe I do. I did do that.
17
A. To inspect the landscaping, I believe.
18
Q. Okay.
is
Q. Yes. Andthatwas as a result of the
19
A. I don't know if that's the term I used, like
19
communications with the homeowners association?
20
it or whatever, but maybe I did.
20
A. No, that was — no. That was just augmenting
21
Q. Okay.
21
my supposed position on the matter.
22
A. I was trying to get input from the homeowners
22
Q. And what cons your position on the matter with
23
association.
23
regard to Mr.O'Hare's landscaping?
24
Q. Did you ask them if they lilted it, you would I
24
A. This went to special magistrate. A finding
25
leave Mr. O'Hare alone, but if they didn't like it. you r
25
was provided by the special magistrate, and I would let
41 (Pages 158 to 161)
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1
Page 162
III
Page 163
1
those retards speak for themselves.
I 1
about the general characteristics of -
2
Q. Right. Now part of the contention with
2
MR. STEARNS: Arc we talking about open front
3
Mr. O'Hare was an open front lawn provision. Do you
3
lawns still?
4
remember that?
4
MR OBOYLE: Yes.
5
A. Again —yes, I remember that.
5
MR. STEARNS: What's the point? He already
6
Q. Okay. And the open front lawn provision of
6
told you that the magistrate ruled and that's what
7
the — it's in the design manual, correct?
7
we arc stuck with, and whatever happened in the
8
A. It's in a section of the design manual,
a
past is the past. You re just wasting cvery body's
9
Chapter 70.
9
time.
10
Q. Okay. Now, what is an open front lawn?
i o
MR O'BOYLE: Okay.
11
A. There was a ruling by the special magistrate,
11
BY MR. O'BOYLE:
12
a finding, and 1 would let the records speak for
12
Q. Is that the first time that you enforced that
13
themselves.
13
provision of the code?
14
Q. Okay. That section of the town code, that's
14
A. No.
15
called article two of the design manual?
I '-5
Q. Okay. When else have you enforced that
15
A. Could be.
I 1F,
provision of the code?
"
Q. Yes. Let me back up. Why does that, why is
17
A. I don't recall. I know of one instance w here
8
that not just a general overview of the town?
I 16
the front yard was obscured from view, and in the
19
A. I don't know.
19
const ucton phase it was encouraged that it be removed.
20
Q. So every part of that provision carries the
20
1 think they did it. And I'm sure there's other such —
21
force of law?
21
Q. Have you enforced that provisionsubsequent to
22
MR. STEARNS: Object to the form.
22
Mr. O'Hare?
23
THE WITLESS: 1 don't know that.
23
A. I believe this one was subsequent to
24
BY MR. O'BOYLE:
24
Ivlr. O'Hare, but 1 couldn't he for stye.
25
Q. Okay. So isn't it a hue that the 70 32 talks
5
Q. Okay. Are there un. houses in Place Au Soleil
Page 164 ( Page 165
1
which have closed front lawns?
1
Q. Okay. And I forget, so forgive me. It was
2
A. Yes.
2
siithhcld for?
3
Q. Have you taken action against them?
3
A. Ido not recall why.
4
A. No.
4
Q. Was that counsel that made that call'?
5
Q. Is there a particular reason?
5
A. I'm sure there was advice from counsel in the
6
A. I believe those are existing hedges and
6
whole matter in that stage.
7
grandfathered in.
7
Q. Okay. Now for objects d'art, have you ever
8
Q. And where is the, which part of the code is
8
seen any other objects d'art Indus town?
9
die grandfather clause?
9
A. Yes.
10
A. 1-7, 1-8. I'm not sure.
10
Q. Have you cited people for -
11
Q. Okay.
11
A. I have spoken t0 them about it, yes.
12
(Discussion held off the record.)
12
Q. Okay. And when holidays come around, how do
13
BY MR. O'BOYLE:
13
you deal with thud^
14
Q. So back to the objects d'art. I'm going to be
14
A. We dan't, I don't enforce those seasonal
15
very pointed here.
15
decorative elements.
16
A. Okay.
16
Q. Okay. Is there any particular reason why?
17
Q. Did you cite Mr. O'Hare for having objects
17
A. Advice ofcounsA.
18
d'art because you did not want to cite him under the
18
Q. So counsel told you not to enforce the
19
town sign ordinance?
19
seasonal?
20
A. No.
20
A. Can I call that privileged?
21
Q. But you, but his objects d'art, his artwork
2 i
MR STEARNS: Not really'.
22
mus not considered a sign?
22
THE WITNESS: Okay. lie didn't tell me, but
23
A. I cited him — I'm sorry, the special
23
stating that the town does not. Ile has a longer
24
magistrate proceeding that was withheld describes the
24
history than I do.
25
language of the citing and it speaks for itself.
25
42 (Pages 162 to 165)
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43 (Pages 166 to 169)
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I
Page 167
1
BYMR.O'BOYLE:
1
Q. But does he always speak?
2
Q. Itjust doesn4. it'sjust part of the—
2
A. Not always.
3
A. Yeah. I suppose thats — there's a reason.
3
Q. Okay. Does he speak die most, more than any
4
Q. Well. again, nobody wants to be the grinch: is
4
other resident?
5
that a fair enough reason?
5
A. I'm so sorry.
6
A. No. I wouldn't classify it as that. 1 just
6
Q. I really want to laugh with you right now.
7
don't know.
7
A. The answer is no.
e
Q. Do you have any personal animus toward
8
Q. At a— well, excluding the commissioners who
9
Mr. O'Hare?
9
themselves we residents, but in all tamest, does
10
A. No.
10
Mr. O'Hare not speak the most?
11
Q. You attend most commiss;on meetings, right, if
11
A. In my opinion, he hasn't, he's not, he doesn't
12
not ill?
12
hold that title to me, no.
13
A. I think] have missed one in my tenure
13
Q. Okay.
14
Q. Okay. Have you seen Mr. O'Hare at those
14
A. Of the other residents, I don't know hot%• to
15
commission meetings?
15
answer that, but no. I'II just leave it at that.
16
A. Yes.
16
MIL STEARNS: No volunteering.
17
Q. Does he usually speak?
17
THE WITNESS: That's right.
18
A. Most of the time he appears at a commission
18
BY MR. O'BOYLE:
19
meeting or with an ARPB, he does speak.
19
Q. So what did Chris tell you about volunteering?
20
Q. And do you know when Mr. O'Hare started
20
MR. STEARNS: No volunteering.
21
attending meetings?
21
THE WITNESS: par trying to shut my mouth.
22
A, No.
22
BYhIR.O'BOYLE:
23
Q. Okay. When he speaks, is Ire usually the only
23
Q. All right, okay. So are there any Diner times
24
one that speaks?
24
besides the table incident that Mr. O'Hare has made you
25
A. Sometimes.
25
upset?
43 (Pages 166 to 169)
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Page 169
1
A. No. I don't know that he made me upset. I
1
artwork?
2
told you, he made me fearful. Other than that, the
2
A. I don't have an opinion.
3
amwcr is no.
3
Q. You arejust agnostic to the whole —
4
Q. Okay. Never, when I say upset, I don't w tint
4
A. I don't have an opinion. ft's not my jab.
5
to play semantics here, so angry, viscerally distraught,
5
Q. His speech doesn't evoke any emotion?
6
disgusted.
6
A. I'm sure it evokes something. I just don't
7
A. What is the yuestion7
7
know what it is or—
o
MR. STEARNS: Did he make you feel any of
a
Q. Like a new feeling that you nc%er had before
9
those things?
9
A. Oh. no.
10
THE WITNESS: No.
10-
MR STEARNS: Object to the form. Asked and
11
BY MR O'BOYLE:
11
answered ten times.
12
Q. Okay. And you have never taken any action
12
THE WITNESS: No.
13
against Mr. O'Hare because of the things he has said?
I
13
BY MR. O'BOYLE:
14
A. Answer is no.
14
Q. Okay. Now Mr. O'Hare applied for an election
15
Q. And to 3 our knowledge, has anybody else in the
15
hearing committee, do you remember that?
16
torn taken such action?
16
A. I vaguely remember communication from
17
A. No.
17
Mr. O'Hare involving such a matter, yes.
is
Q. Have they ever talked about %vunting to take
18
Q. And this was about, this was prior to the 2014
19
such an action?
19
general election for municipalities?
20
A. No.
20
A. Yes.
21
Q. So they love what Mr. O'Hare says?
21
Q. Do you recall what Mr. O'Hare wanted out of
22
A_ I don't know.
22
that application?
23
Q. Do you like what Mr. O'Hare says?
23
A. No, I don't
24
A. i don't have an opinion.
24
Q. Are you, wcreyou the one to handle that
25
Q. At die commission meetings or about his I
25
application?
43 (Pages 166 to 169)
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44 (Pages 170 to 173)
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1
Page 171
1
A. No.
1
Q. Okay. Do you remember what the charter
2
Q. who was?
I 2
amendment was for?
3
A. I believe perhaps the Supervisor of Elcedon.
3
A. I don't.
4
Palm Beach County, or from a state level. I'm not sure.
4
Q. If I said —
5
Q. Okay. But now in order for it to get to. his
i 5
A. Oh, bad to do with something about the
6
application to get to the Supervisor of Elections. the
6
election.
7
town. Gulf Stream. had to certify that Mr. O'Hare met
7
Q. If I said staggering terms, is that —
8
all of the requirements?
°
A. Yes, staggering tants, that's what it was
9
A. I'm not familiar with that. I don't know. I
9
about
10
Q. So you never saw his application?
1 o
Q. And that required —well, let me ask you.
11
A. I don't recall.
11
Did you have any involvement with getting that, the
12
Q. Did you ever hent about a all from the
I
12
charter amendment either to the ballot, which I believe
13
Florida Elections Commission?
13
it didn't go to the ballot, but in any steps getting it
14
A. No.
14
on the ballot?
15
Q. Okay. No, and u -hen I say call. I man
15
A. I don'trecall.
6
communication, e-mail. somebody says "Hey, the Florida
15
Q. Do you know who in the town would be
17
Elections Commission is on the phone"?
17
responsible for that?
i8
A. I don't recall.
18
A. The town commission.
19
Q. Okay. I
19
Q. For certifying that certain requirements are
20
A. Probably not a call I would take. i
20
met, certain petitions are met to then give to the Board
21
Q. Do you, were you aware that the Gul fStream
21
of Elections?
22
Civic Association wattled to do a charter amendment in
22
A. Oh. no. Are we back on this? I was talking
23
late 2013?
23
about staggering.
24
A. Amember of the— a resident of the own
24
Q. Right
25
indicated such at a commission meeting.
25
A. That wauld be the commission. The other, l
44 (Pages 170 to 173)
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Pagp. 172
1
Page 173
1
don't know, who would be responsible. I think I onswered
1
Q. You follow it regularly?
that
2
A. No.
3
Q. Right. okay. So to your knowledge, there
I 3
Q. Okay. By the way, is that the paper that
wasn't apetition withjust town residents that was
4
circulates around the town?
5
submitted to the commission as prerequisite to a charter
5
A. I don't know.
6
amendment?
6
Q. Okay. Did you ever question -- I'm sorry,
7
A. I don't recall that.
7
were you here February 14, 2014, in this commission
8
Q. Okay. Have you ever said anything bad about
8
chamber?
9
Mr. O'llare?
9
A. I believe so, if there was a commission
10
A. Not tbat I recall.
10
meeting.
11
Q. Okay. Have you ever made any statements about
-- I
Q. Do you remember an elderly lady in a
12
his mental health?
12
wheelchair?
13
A. Nat that I recall.
13
A. Yes.
14
Q. Okay. If I said the word psychopath, would
14
Q. Okay. Do you remember what happened?
15
that ring a bell?
15
A. Details I'm not sure of.
16
A. No.
16
Q. Okay. Did you understand that that lady was
17
Q. Nc%cr referred to Mr. O'Hare as a psychopath?
17
W. O'Hare's mother?
18
A. No.
18
A. ],through hearsay, I believe so.
19
Q. Okay. Let me ask you this. The town changed
19
Q. Okay.
?0
its parking ordinance about a year ago, wcM say.
20
A. I don't know for sure.
21
Do you know why they changed the parking
21
Q. Did you ever make any statements saying "I
22
ordinance?
22
wonder whether that is Mr. O'Hare's mother or not"?
23
A. No.
23
A. No.Idon4recall.
24
Q. Okay. Do you read the Coastal Stat?
24
Q. Is that incident, when I say that incident, is
25
A. Yes,
25
that—was her presence here that day the reason why
44 (Pages 170 to 173)
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I
Page 175
1
the town has gotten ADA improvements?
1
capacity and not?
2
MR. STEARNS: Object to the form.
2
A. i don% know.
3
THE WITNESS: Primarily.
3
Q. Okay -
4
BY MR. O'BOYLE:
4
A. No, the answer is no. No.
5
Q. Okay. Would you consider that a good thing
5
Q. I ask because 1 have seen letters and they
6
for the town?
6
look different. and I suspect some are from Rita acting
7
MR. STEARNS: Jonathan, how is this possibly
7
in your capacity.
8
related to this case? Come on. you have gone
a
A. Very possible.
9
everywhere you can possibly with this deposition.
9
Q. I just didn% know ifyou color -coded them or
10
If there is nothing else relevant to the
10
not.
11
issues in the complaint, slop, because you are just
11
A. No.
12
harassing now. 1 understand that your father wants
12
Q. By the way, is there a league of town managers
13
to have an ADA claim and has been, has sought to
13
or something to that effect?
14
evaluate all the buildings. That is not this case,
14
A. There is organizations for city and county
15
okay? Are we done?
15
managers throughout the United States,
16
MR. O'BOYLE: Come on, Chis.
16
Q. And do they give you —I'm sorry, are you a
17
BY MIL O'BOYLE:
I 17
member of thou organizations?
18
Q. When you send letters on the town stationery,
10
A. I'm a member of that one that I just
19
your signature — I'm sorry, when your signature is
19
referenced.
20
affixed to it as town manager, do you, is there a color
20
Q. Okay. And do they give you recurrent training
21
system which shows that it has been copied by you or
21
or any training on being town manager?
22
whether IN an original from you?
22
A. Not them, no.
23
A_ No.
23
Q. Is there anybody out there that does
24
Q. Is there a distinguishing factor between when
24
administer?
2"
Rita or Town Clerk Rita Taylor is acting in your
25
A. They make available training, yes.
45 (Pages 174 to 177)
Florida Court Reporting
561-689-0999
Page 176
Page 177
1
Q. Okay. And do you participate, or what
1
people parking on the right -of --way?
2
training do you participate?
2
A. I let the police department handle that,
3
A. I try to participate in training.
3
Q. So not a code enforcement isstre? Really
4
Q. Okay. What types of training is out there,1
4
outside ofyour--
5
guess, or what type of training have you participated
5
A. Cnuld be a code enforcement but the police
6
in?
6
department handles that.
7
MR. STEARNS: This is not possibly re'.cvant to
7
Q. Okay. Is time a permit that can be sought
8
arything. There is no claim for his training. It
8
either officially or unofficially ujust permission to
9
doesail matter.
9
park on the town's right-of-way?
10
THE WITNESS: It's varied. les varied. I
20
A. I don't recall.
11
BY MR. O'BOYLE:
11
Q. Okay. I don't know if people have parties
12
Q. And that's on your own accord, or does the
12
around here and they sometimes line cars on the
13
town commission mandate that you take training?
13
rightof--way?
14
� A. To try knowledge, the town toes not mandate
14
A. I don't know.
35
that.
IS
MR OBOYLF.: Do you guys have anything else?
16
Q. Okay.
16
MR. O'AARE: Let's take a break for a second.
17
MR. OBOYLE: Well, Chris, I think the only
17
MR. OBOYLE: Yes, take a break.
18
questions I have lett —
18
MR. SITARNS: Go quickly, because this lies
19
MR. STEARNS: Aro related to the public
19
gone way beyond reasonable and it's harassing.
20
records issues, and 1 won't let you ask them.
20
(A recess %as taken.)
21
MR. O'BOYLE: Actually, I want to get that on
21
MR. O'BOYLE: I just wanted to put on the
22
the record
22
record that we wanted to further inquire into
23
MR. STEARN& I just put it there.
23
public records and RICO matters, and Mr Steams
24
BY MR. O'BOYLE;
24
objected, and we will respectfully take our maner
25
Q. What's the town's enforcement policies with
25
to the court.
45 (Pages 174 to 177)
Florida Court Reporting
561-689-0999
46 (Pages 178 to 181)
Florida Court Reporting
561-689-0999
Page 178
I
Fage 179
_
MR. S'IEARNS: That's it. He will read. Thank
1
CERTIFICATE OF OATH
2
you. If it's ordered. I want it.
2
STATE OF FLORIDA
3
THE REPORTER: Is it ordered at this point?
3
COUNTY OF PALM BEACH
4
MR. O'BOYLE: I'm going to consult.
5
5
6
I, the undersigned authority, certify that
6
(Witness excused.)
7
personally
William F. Thrasher, Jr. onall • Rn red before me
7
(Deposition tlas concluded.)
( eP
8
e T
and was duly sworn on the IOth day aCJune, SIS.
6
9
9
10
Witness my hand and official seal this 12th
10
11
day of July, 2015.
11
12
12
13
13
i4
15
1-0
15
16
16
Rachel W. Bridge, RMR, CRR
17
17
NotaryPublic- StateofFlorida
18
My Commission Expires: 1/] 5119
9
i8
My Commission No_ FF 159892
iL
19
21
20
21
22
22
23
23
29
29
5
25
Page 180
I
Page181
1
CERTIFICATE
1
DATE: Jdy 12,205
STATEOFFLORIDA
I 2
TO: W IVe .1"thruhs Job011004
'
tly:1MYPF PALM BEACH
3
a,s+]I.steplarslumc r,.
1:�.., Amcbrc. dal.
5
1, IIz11rl W Bride, Certifid ltrsuma
2e °.c Em Ssarn aaa:n,nq Sue, .10V
Fn:l.ndmLT.F.urlc313oc
Ripener enJ Notm pubhc in said for she swe cr
ReW
t,
May OFlr: t+Tnun rf Ou'f50-um
t
}7;tida at large, do hereto• «nifY thm the
6
n'u tv
The o-e"ttdTeelms reYmm
'/
zfirstdnd to
the wholeunits: will;
sesufyNe whole auW: that lwae suthanrnito and
sandy
7
sW Amt,
6•IFIS bu henewalldsluW emusruSlnp and
did suporr said deposition in unto pe, and tiros UteI
P
vilsdnp. Asprev,sWy aprsE, the vmiscnpt wia he
famrebedmymdewgh Jnmcems,l
taegvin[WBa numteactl l to 178. mell4irdaraa Bus
indwrrtw ar_t:ri,+tian oCmy'shnrhartd noses otsaid
r
Alae deftlreamedpr,.1,m9 udm
5
dep':sitim
fR]h dl:tl Ahay (md„Imrialcilicaldbemir3e,
ml
LJ
IPorihireand Ilamsirdinalm
_.
it. u ti.,4 nwid,
I. minhohimid
she,ri'v ihtt4sang PNcm3i.oe menbo-otrldd
esetfis
semen m n use and piece m1 torch and
nwirs
docs,. nncc ym Wre tud used my
11
c
on ins commenced an!
a smo
ukmg
11
dlmres he mrc 9 e...1.iud
and dor dm ems tbur sod
ercina ove set
rompided as hereinabove set out
isetpie
3.'
ingn
rcmm ifY c Peggie m mc.
Ify]u do ns sed and sip dedepmmm
12
t further cerntY tin s an, not, Homey or
13
winds '..ble time iLe miguul wmoh has
laud!' bree mrwnded to ate oldana momey,ml-be
13
eounsd of my _rs.nm etnlerelalilea
> Rc'
fi:N,ritb ails Dvm utdle amt Ifycu,rshm wore
em;loy'eeofany merncl or counsel of party mnnected
as
y^ss:gnmwc ugaymstume u Ili,W hii is
14
nih ther..._^, nor an i fscanciallymmisled:n the
W]= eJ this lnwrd rant mut
amort
15
;S
Ssttrth
'file foregoing caliGcatron of this Iranurip:
5E
1G
does not apply to my re mciction of the same k any
1•
— —- ---
rtrstsmins. under Use direct eamol andior dirmdnn f
R h,1%V.8ddggaMRCRR
1
rfduamfyincroponer
1a
""ma Cost Reponmg
3161 Pd. B..h Lamm slid Su?.c Me
!
Dared Chir I2th day nftuly.'2'015.
Is
Wen Pelm Bn:!r lade 3340
phase (!n!ldw�rlya
2a
clash lt'. Budge. MtR CItR
21
Ida hereby note m}•dpmmre
22
=3
wtfe'ut F—'Ln:he, L.
24
1
25
]5
46 (Pages 178 to 181)
Florida Court Reporting
561-689-0999
Page 182
Page 183
1
CERTIFICATE
1
ERRATA SHEET
2
_ _ _
2
INRE OHnrevs.TownofGultSreom
3
THE STATE OF FLORIDA
3
GR: Rachel Badge
DEPOSITIONOF WdEsm F. Thresher, Jr.
4
COLTN7Y OF PALM BEACH
5
TAKEN: 6•!0.15
5
1 hereby certify that I have read the
C
DO NOT WRITE ON TRANSCRIPT • ENTER CHANGES HERE
6
foregoing deposition by me given, and that the
7
PACER LINES CHANGE REASON
7
statements contained herein are true and correct to the
8
best of my knowledge and belief, frith the exception of
9
arty corrections or notations made on the errata sheet,
9-
10
if one was executed.
10
_..
11
12
Dated this _day of
11
12
— —"
11
13
2015.
11
14
15
_
-----
15
1617
_
16
17
1F
is
19
Please fonwrd the txrginel signed erne sheet to this
office in, that euaics w4y be distributed to all ponies.
19 WILLIAM F. THRASHER, ]R.
20
• e
esY
21
21
dcniiiand 'm u a true an maw s:tynias
22
any changes in farm or substance enteed here
23
22
24
23
DATE'
v
25
25
SIONATURF OF DEPO,\M1NT
47 (Pages 182 to 183)
Florida Court Reporting
561-689-0999
_ A
A,B 56:20
A1A41:14,15
ability 7:2123:2
32:19101:13
158:18 159:9
able 39:16 66:22
72:9 81:22 84:19
94:13 135:17
absence 10:8,10,14
10:1539:13
absolutely 81:9
143:15,15,19
accent 134:14
accept20:5 43:1
68:5 69:3 77:21
108:24 109:2
accompanying
126:15
accomplish 39:3
accomplished
157:20
accord 176:12
accounted 13:4
accurate 113:9
117:19
act 33:11
acting 116:1
174:25 175:6
action 36:7 61:6
78:14 88:19 104:9
110:5123:18
161:1,12 164:3
168:12,16,19
180:14.14
actions 61:10 161:9
active 49:18 94:12
100:18 119:12
activities 13:5 16:2
18:17 33:2135:20
44:13 51:21 125:4
activity 19:15
111:25
actual 17:4 154:4
154:13
ADA 174:1,13
additional 73:7
140:20 149:23
addressed 32:1
adjacent 120:6
Adjustment 133:10
139:6,9 141:25
142:12
Adjustments
139:23
administer 15:15
175:24
administrative
139:22,25 140:3
administrator
32:16 53:11,12
104:11
administrator's
139:14
adopt 32:6,10
adopts 32:8
advertise 84:20
advertising 86:22
88:22
advice 59:5,6,10
76:9 78:3,5,8
125:12 165:5,17
advised 94:15
aerial 114:15
aesthetic 117:25
affect 161:4
affiliations 138:3
affinity 100:5
affirmed 4:9
affixed 174:20
aforementioned
180:6
agencies 6:I0,12
agent 133:20 135:7
137:13 142:19
agents 44:2 132:18
agnostic 169:3
ago 29:12 35:18
60:18,20 66:4
105:22,25 106:7
172:20
agreed 181:7
agreement 13:20
13:24,25 15:7,13
16:6,8 17:2,12
25:6 85:1,13,13
ahead 49:11 91:7
95:5 101:18
132:14 137:11
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alarm 131:4
allegation 92:23
1132,4
allegations 143:6
alleged 40:10 42:1
44:14,20 46:9
50:6 51:9 52:3,17
53:15 55:9 5724
allegedly 11234
126:23
Allen 85:2
allow 130:17
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96:23 111:24
128:4 130:23
134:8,14,20 141:3
147:21 155:23
allowing 86:14
112:11
amended 23:23,24
66:8,9 113.4
amendment 78:15
78:18 87:5 170:22
171:2,12 172:6
amount 59:1,3
93:19 122:25
analysis 154:3,17
155:5,6
anchored 62:25
and/or 180:16
angry96:23,24
168:5
animus 166:8
Annexation 79:18
annual 39:10 99:19
99:20
Anselmo 2:14
181:3
answer 823 12:9
25:10,10 28:2,4
31:11.14 33:13
40:17 41:8 44:19
58:9 592 65:9
68:16 69:24 70:5
70:9,2171:8,25
72:23 75:8 81:8
82:1196:13,14
104:15106:9
108:19,21,24
109:4 117:19,20
123:20 124:2,20
129:10 130:4
137:9 167:7,15
168:3,14 175:4
answered 24:12
29.22 47:2 57:11
71:12 96:16
119:14,15 141:23
169:11 172:1
answers 89:8
anybody 26:21
30:7,10 34:17
66:20 70:7,12
72:3,6 80:2 82:17
86:22 87:2 90:22
91:5,6 101:25
104:7 118:4
128:18 132:21
144:16,21 168:15
anyway 85:5
apologize 86:19
96:22 101:21
114:9 125:21
151:18
apparent 119:7,7
appeal 142:12
appealed 123:23
APPEARANCES
2:1
appeared 71:19
179:7
appears 74:12
122:14 166:I8
application 34:7
37:5 116:23 117:1
117:2 132:9
133:17 140:1
141:16 147:14
Florida Court Reporting
561-689-0999
OM
149:16 150:12
158:2 169:22,25
170:6,10
applications 14:2
147:18
applied 18:19,22
19:25 126:12
131:17 133:18
137:13 149:18
169:14
apply 19:1 139:21
140:17 180:16
appoint 32:19 33:7
appreciation 65:2
approach 73:17
158:16
appropriate 15:4
appropriated
46:10
appropriations
33:23 34:2 38:18
approval 7:15 14:2
82:12,18 104:25
117:4
approve 11:25 12:3
12:3 80:18 135:16
135:17 137:4
150:7,16,18,21
151:3 158:18,19
approved 33:19
37:II 133:19,25
158:23
approximate 146:2
approximately
105:22 133:24
April 6-2
architectural
115:10 150:17,23
153:3,19 154:19
155;19,21159:11
architecture
159.24
area 40:22 46:20
97:5 108:15,25
areas31:18 117:18
129:15 130:8
argue 75:10 159:9
argumentative
29:6
arta 12:16
ARYB 117:3
166:19
art63:17,21,22,23
64:6 65:2,20,24
article 162:15
artwork 66:11,11
67:5,7,8,14,18,22
68:7,19 71:10
72:10 73:15
164.21 169:1
asked 15:13 19.22
19:23 29:18 33:8
37:941:164324
44:7,16,17 57:10
61.20,22 62:4
71:12 82:17,18,20
84:2,24 89:15
108:23 110:15
125:18,I9 128:22
133:1.3 136:24
141:9122 148:11
149:22 151:15
159:5,19,23 160:3
169:10
asking 23:128:8
34:11,12 36:21
37:23 40:3 44:18
45.1750:8 61:13
71:375:1 81:16
116:11 129:25
141:14 146:20
160:15
aspect34:10 67:9
assigned 8:3,4
assignees 127:25
128:1
assignments 46:8
assigns 128:12
129:8,19
assist 34:22 35:7
36:6,12 38:9,13
39:17 41:17 43:13
43:17 46:8 55:4
79:2,4,15
assistance 35:23
36:9 37:9,24 39:4
43:14,2144:16,17
44:18 45:5,13
110:16
assistant 5:9,13,20
5:23,24 6:3,6 7:9
7.25 8:133:15
34:20,23,24,25
38:6,7 45:20,21
46:3
assisted 33:3,4,17
assists 53:22,24,25
54:179:12
associated 86:1
association 82:23
83:4,15,22 88:8
88:14,25 89:4,5
89:10,1190:9
99:19 100:3,9,13
100:15,16 160:15
160:23 161:11,19
170:22
association's 89:24
associations 99:24
100:17
assume 56:2 155:2
assumed 88:6
assuming 43:20
79:16 83:2188:25
89:6 106:16
117:21
assuring 13:3
at-wi117:18
attached 67:5
122:16 137:22
attempt 141:14
attend 9923 100:2
100:10 166:11
attended 99:21
attending 166:21
attention 51:2
attorney 25:1
28:15 53:22 75:2
75:3 7922,22
144:13 180:12,13
181:13
attorney/client
74:25 97:13
attorneys 26:16,20
26.22
attributed 153:4
An 40:20 65:15,16
99:1,4,11,12,18
100:5,10 105:21
120:3 122:19
149:8 154:1
157:10 160:15
163:25
augment 36:19
augmenting 161:20
August 133:17
authenticate 122:4
122:8
authored 124:9,11
124:12
authority 10:13
150:7 158:19
179:6
authorized 103:24
180:7
available 83:7
139:20 175:25
Avenue 65:15,15
120:3 122:19
149:8 154:1 157:9
Avery 115:23
avoid 111:25
awaits 181:7
aware 40:5 91:9
109:14 131:17
157:24 170:21
B 3:8 �._.... _
back 5:25 6:217:10
8:20 9:7 10:6,13
10:21 16:2025:16
27:15 29:12 44:17
44:2190:17 95:24
97:7,24 100:20,25
108:11114:4,6
119:25 120:1
127:8,17 129:9
144:23 162:17
164:14 171:22
backup 137:21
141:9
bad 172:8
ballot 171:12,13,14
ballpark 146:10
based 18:11 105:7
105:9 146:20
basis 9:13 38:11
46:5 95:18 147:7
147:9
BBA 6:25
Beach 1:19,20 2:11
12:13,15,20,24
13:12,15,21 14:1
14:14,23 15:5,10
15:12 16:5,7,11
17:2,11 18:5,12
19:6,21,23 20:1
20:11,13,22 21:12
21:15,23 22:1
119:2126:13
127:22 170:4
179:3 180:3
181:18,19 182:4
Beach's 127:6
banner 105:18
besners 105:15
beautiful 81:10
beauty 159:13
becoming 37:15
behalf 2:2,13 139:6
beholder 159:14
belief 182:8
believe 8.23 16:10
20:20 24:12 27:13
30:3 32:1,18 34:3
34:15 35:6,6
36:23 37:17 43:7
43:9 49:8 52:23
52:25 56:4 60:7
60:13 65:7,23
66:14,2167:6
68:4,21 74:4,7
78:17,20 79:10
81:8 83:16,20
Florida Court Reporting
561-689-0999
165
85:2,4 86:2,20
87:12 89:12,15
91:11,19 93:8,22
96:2599:18,22
103:9,12 104:2
113:19,23 115:4
115:22 116:10,11
117:20 118:3
119:1 120:1,10
125:8 130.20
131:12 132:21
133:20 134:9
135:25 136:4
139:19,19,25
141:12,13,17
143:5 145:22
146:18 148:8
149:18 150:24
154:3 155:7
156:18 158:2
160:17 161:17
163:23 164:6
170:3 171:12
173:9,18
bell 172:15
belonged 63:13
benefit 51:3
Bermuda 152:22
152:24 153:4,8,18
153:20 154:5,14
154:23 155:4,18
156:5 157:4,6,13
158:8,9,24 159:4
best 182:8
beyond 131:13
177:19
big 53:7 108:11
bit 5:22 8:13 9:10
11:2 18:15 22:16
31:20 35:10 41:1
49:10 52:180:20
81:12 87:4 98:16
103:13 105:1
126:6143:3,16
blank 114:14
181:14
blurb 84:6
Blvd 181:18
board 99:19 133:1
139:5,9,23 141:2,
142:12 150:17X
17120
boat 62:3,20.22,23
63:2,4,7,13,13,16
63:18 73:9.10,13
74:3,5 75:19 76:8
76:21
boats 62:24
body 175:23
book 50:16 55:4
153:7
books 50:25,25
Borza 85:2,3
bothered 143:17
bottom 181:14
bought 159:16
Boulevard 1:19
2:15181:3
bound 125:22
break97:18 151:5
177.16,17
breaking 106:22
108:5,11 131:5
Brian 1280
brick 14822
Bridge 1:18 4:3
179:16 180:5,22
181:17183:3
brilliant 24:7
bring 35:14 54:3,6
97:12
broad 2:4 79:16
broadly 50:22
broken 131:5
brought23:14 73:8
budget 7:6,7 36:19
38:10
budgetary36:18
budgeted 3620
build 98:13 101:13
building 3:13 11:16
11:2012:3,4,5,10
12:I1,14,25 13:3
13:16,17 14:1,5
14:13,23 15:15,1(
15:16,23 17:8,15
17:17,19 18:13,1 i
19:8,13,18,19,21
19:24 20:3,4,5,9
20:14,15,16,25
21:9,23,25 22:6
22:10 32:16 53:11
53:11 104:10
112:6.7 114:25
117:6 118:1
127:22 128:4
156:3
buildings 17.5
134:18 174:14
built 105:20
bulk41:2
BURKE 2:14
bush 59:25
business 1472
C _
C 4:156:20 180:1,1
182:1,1
c/o 181:2
calculations 137:21
141:11
call 15:4 19:23
21:1144:22 45:23
45:25 46:1,4
52:20 53:19 58:25
59:14 62:14 66:10
66:11,1180:21
105:10165:4,20
170:12.15,20
:ailed 9:9 15:9
116:10 118:21
119:14 121:17
126:19 162:15
:ailing 18:11
tapable 67:25 68:1
rapacity 55:19
175:1,7
:are48:23 96:10,11
:areer 6:20 33:3
areful78:14
arries 154:8
162:20
carrying 56:23
cars 106:23 177:12
case 1:2 24:125:1
30:1645:1 79:8
140:25174:8,14
catch 151:4
catch-all 140:10,13
categorizations
152:18
categorized 153:6
category 58:6
156:11
cause 4:5
caused 143:18
144:5
caution 24:24
cement 133:18,25
center 63:1 146:9
central 98:20
certain 9:21 17:6
29:24 33:8 39:17
49:8 51:15 58:20
68:4 83:9 91:25
96:12,13 972
107:12 111:6
115:24 119:7,8
124:10 126:14
130:22 149:25
155:8 156:2,2
171:19,20
certainly 48:14
82:15
certainty 78:10
certificate 13524
136:2 138:20
179:1
certification
136:21 180:15
Certified 4:4 180:5
-ertffy 170:7179:6
180:6,10,12 182:5
.ertifying 171:19
180:17
:hallenge 139:22
139:24 140.3
:amber 173:8
change27:20,21
89:8 134:4 147:1(
154:21 157:17
158:5,14 181:10
183:7
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158:15 172:19,21
changes 158:17
181:9,11 183:6,21
changing 116:24
157:19
Chapter 47:18,18
47:2148-.1,2,8,8
48:21,2164:4
110:9 152:16
153:15 154:9
155:12 162:9
chapters 47:15
character 69:20,25
70:15,19
characteristics
163:1
characterization
65:17
charge20:l
charged 68:8
charges 77:1,5,24
78:1
charter 170:22
171:I,12 172:5
check 41:21
chief 2:20 15:1
32:15 34:8,15
35:23 36:2,5,5,8
37:8,17,18,23
38:11,14 41:21
42:23,25 44:12
47:2 55:12,19,25
103:22 107:11,20
107:24 112:17,19
112:19 143:23
152:10
:hief-of-police 362
:hoice 116:25
:hoose 116:17
:hose 139:24
�hris 3:116:5
Florida Court Reporting
561-689-0999
30:18 59:14 72:10
74:17 75:17
100:24 113.6
131:17 132:8,15
132:18 155:1
167:19 174:16
176:17
Chris' 70:12
114:18
Christopher 1:4
2:14,19 4:17
122:19 181:2
circuit 14:9 123.23
circulates 173:4
circumstance 98:8
circumstances 10:7
15:9 111:22 129:6
129:8 131:10
citation 58:8
cite 11:22 72:12,15
74:17,21,23 75:17
76:22 92:10
164:17,18
cited 72:3 75:24
77:9,10 82:10
164:23 165:10
cites 92:11
citing 54:2 164:25
181.10
citings 77:20
city 6:14 12:15,19
12:24 13:11,15
14:1,14,23 15:4
15:10,12 16:5,7
16:11 17:1,11
18:5,12 20:11,13
20:22 21:11,15
1192 126:13
127:22 175:14
:ivic 82:23 83:4,14
83:2188:8,14,25
89:4,5,10,11,24
90:9 100:13,16
170:22
:laim 174:13 176:8
:laims 143:6
:larification 60:21
61j2211: 150:6
151:16,16
clarify 42:5 43:19
47:14 50:4,19
53:1067:3 128:8
clas1L157:10
classification
106:20158:8
160:5
classify 166:6
clause 164:9
cleaning 1 17:21
clear 22:2 23:4
41:6 51:12,14,24
58:14 61:8 62:24
67:292-2193:6
101:9123:4
143:13
clerical 53:24
clerk 9;25 10:1,7
10:1817:15,16,17
17:19 18:1,2.6
39:12 52:24 142:2
142:6174:25
181:13
client 139:7 141:13
141:18
closed 164:1
closely 26:17
Coastal 172:24
code 11:IS 12:2
13:3 14:5 15:15
15:1617:8 18:13
20:14,15 21:23
22:1,2 30:3 32:18
32:19,22 33.4,15
33:17,20,2134:12
34:13,13,17 35:1
35:4,7,9,14,20
36:7,17 37:3,10
37:15 38:4,5,8,22
38:24,25 39:6,13
39:24 41:17,23
42:8 43:14,23
44:2,13 45:5 46:2
46:3,6,9,17,21
47:1,4,8,11,11,12
47:15,19,22 48:3
48:5,19,25 49:3
49:20 50:6,7,9,10
50:17,18,24,25,2
51:1,25 52:11
53:13 54:4,11,12
55:3,4 56:8,10
57:22 58:6 60:4
61:6,10,13,17
64:1,3,3,7,11,21
64:23 71:20 72:6
75:9 78:14 79:13
7925 90:18,19,2I
91:2,10 92:10,11
92:24 93:4,13
96:10,11,1797:3
97:7 102:17 110:3
110:13,21118:1
122:15,22 123:6
123:12,18 124:1,3
125:9,22 126:1,9
128:3,11 129:1.6
129:7,19130:17
130:17 134:14,18
134:20,22135:20
13622 138:21
140:11,14 147.11
147:13,17,20.22
148:17 149:23
150:6,19,19,24
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154:13 155:6,7.9
155:18,20 162:14
163:13,16 164:8
177:3,5
codes 131:4
cold 111:25 112:6
colleagues 56:3
color 174:20
color -coded 175:9
colors 116:25
157:18
combination 80:20
147:8
come 1123 14:18
17:4 21:19 40:24
40:25 41:2,12
51:20 7625 85:12
90;18 96:20
112:16,17152:4
5 158.3 165:12
174:8,16
comes 30:5 51:1
90.20
commenced 180:11
comment 87:20
125:12 14125
comments 87:22
89:14,16 137:10
139:6
commission 22:14
22:18,19,25 29:13
31:15 32:9 33:18
33:23 38:18 46:11
60:3,12,23 61:6
65:20 96:17 117:3
140:21 141:7,8,24
166:11,15,18
168:25 170:13,17
170:25 171:18,25
172:5 173:7,9
176:13 179:17,18
commissioner 7:15
8:25 61:24 63:5
63:1174:14 87:22
commissioner's
31:23
commissioners
31:13 61:9,13,16
65:22 87:15,23
89.14 167:8
committee 169:15
common 25:5
commonly 157:3
communicate 18:4
52:15 56:22 57:24
62:2104:6109:6
145:11 150:4
communicated
60:14 61:9,12
119:3,18
communicates
17:10,14
communicating
92:9
communication
18:23 62:7 67:25
68:285:1 86.21
87:12 91:12,16,20
92:6,19 93:7
107:10,19 110:24
111:15 112:21
116:4133:11
139:20 141:25
152:6,11 161:11
161:13,14 169:16
170:16
communications
24:25 26:17,20
91:23,25 92.2
93:10,1197:16
133:15 140:7
152:8 161:19
community 83:6
comp 79:18
complain 103:7
complaining 92:3,6
complaint 23:12,19
23:23,24 25:19
44:15,20 45:19
52:3 53:15 55:9
55:10 66:3,6,9
92:7 93:13 94:13
10225 103:10
113:5 174:11
complaints 47:4
91:10,10,12 92:17
92:21,2193-3,3,7
93:8,8,19 94:4,6
94:10 95:23 96:6
complete 100:1
completed 52:4
111:9 180:11
181:7
completely 22:21
compliance 53:1,6
57:20,25 95:16
126:4,5
complied 146:25
comply 53:2 54:11
95:11
Florida Court Reporting
561-689-0999
187
comprehension
23:21
compunction
130:15
eoncept34:4,16
36:18 37:9,15,24
38:12141:1
concern 148.14
concluded 119:16
178:7
conclusion 159:8
concrete 111.23
133:18 134:24
157:17
condition 151:14
conduit 116:2
confer 112:19
confident 140:7
confused 5:22
connect 80:23
connected 99:8
180:13
connection 84:17
consensus 87:25
89:20
consent 104:8
consider42:17
49:15 76:13 91:16
96:19 110:13
174:5
considerable
12225
consideration
94:20
considerations
38:10
considered 99:11
99:15 136:1
154:14 16422
construction 13:5,6
104:17 106:1,2
123:1163:19
construction -rein...
14:10
consult 138:5,11
178:4
consultant 76:16
80:21,24 142:19
consuming 54:8
contact36:5,8 82:2
87:13
contain 150:13
contained 182:7
content 81:5 83:14
134:21
contention 162:2
context27:23
28:25
continue 111:24
contracted 20:23
84:13
contractor 133:21
133:22 150:5
151:17,19,20
contractual 7:18
contradicts 153:10
control6:17 180:16
conversation 60:9
78:4 87:5 133:9
139:18 141:6
146:1,8 152:9
conversations
37:19132:20,22
133:6,7 141:5
142:15
conveyed 108:10
copied 174:21
copies 65:2167:20
150:5183:19
copy 65:22
copywriters 81:25
core 40:20 98:20,22
corner 113:25
115:12
correct 7:14 11:3
11:11 15:14,17,18
16:2218:7 19:10
19:17 20:24 21:1
21:16 22:4,22
23:7 29:16 33:25
36:3,4,15 38:24
39:15,25 46:12
53:4 54:13 79:9
86:10 91:8 92:24
98:24 106:20
113:23,25 117:16
133:2 134:10
143:22 148:16,20
152:18 155:24
156:6 162:7 180:E
182:7 183:21
corrections 181:9
182:9
correctly 82:21
correlating 81:23
correspondence
78:18
costly 54:8 158:5
counse130:15
75:15 78:4,6 79:6
86:21 87:5 94:16
95:20,20 103:1
138:11,14,19
165:4,5,17,18
180:13,13 181:8
county 2:11 170:4
175:14 179:3
180:3 182:4
couple 29:12
117:10
course 48:16 60:6
98:23 103:1
court 1:1.19 103:10
123:23 128:19
132:7 177:25
181:13,18
courtesy 52:25
56:11,17,18 57:4
58:4,8,10,12,15
58:18,23 123:12
123:13,15
:ove 62:3,20,22,23
62:25 63:173:10
74:3 76:22
:overed 97:2
,R 183:3
:reate 29:20 32:5
reation 65:1
reator65:2
rime 106:6,8,11
108:14,25
crimes 106:16
107:4
criminal 123:25
criteria 83:9
critical 67:22,23
CROSS 3:3
CRR 1:18 179:16
180:22 181:17
custom 25:20 26:25
27:24 28:14 31:1
customary 59:8
customs 26:8
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64:1,6,2165:8
66:5 71:2173:5
75:24 76:18,19
78:1 164:14,18,21
165:7,8
damage 106:23
damn 28:10
date 10:23 95:22
99:2 103:18 113:1
126:13 139:3
145:4 149:19
152:1 181:1,11
183:23
dated 96:1 180:19
182:12
dates 6:2197:15
David 37:10,20
38:4,19 102:16
104:2 113:5
day 59:18 11223
113:11 121:8
126:16 173:25
179:8,11 180:19
182:12
Jay -to -day 8:16
9:6,13
Jays 10:11 18:14
58:19,2159:12,18
DCA79:18
Ieal20:23 22:9
53:8 107:24
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dealing 101:10
dealt 150:10
decade60:20
decal 109:10,18
110:20 112:11
Decals 10922
December 101:23
137:15
decide 11:24 50:7
90:21
decided 58:15
86:15,20
decides 58:3
decision 36:10,25
71:2 85:24 131:21
137:3 139:14,22
139:25 140:4,22
decisions 9:10,12
9:15,16,19,20
22:13,15 88:4,5
131:21
declare 183:20
decorative 134:14
165:15
defective 137:5
Defendant 2:13
Defendant's 3:11
3:12,I3.14 136:10
Defendants 1:8
Defense 25:6
define 12:2 53:10
54:23 65:4
defined 32:17
70:22 115:8
defines 65:23
definite 55:21
definitely 27:2,5,11
60:2104:1 146:12
definition 28:6
64:23,25 81:21
degree 6:25
delay 51:8
delegate 9:21 10:6
10:12
We
9:23
39:11
Florida Court Reporting
561-689-0999
M
delegating 10:5
delegations 10:17
deliver 42:9
delivered 42:11
123:3
delivering 42:13
delivery 42:9
Delray 12:13,15,20
12:24 13:11,15,21
14:1,14,23 15:5
15:10,12 16:5,7
16:11,2017:2,11
18:5,12 19:6,20
1923 20:1,I1,13
20:22 21:12,15,23
22:1 119:2 126:13
127:6,22
delve 31:20
demand 56:23 57:1
57:7,8,15,17
demands 51:21
demolished 157:22
denied 151:13
156:18,19 157:6
deny 135:16 137:2
139:11
denying 135:15
156:13
department 12:6
12:10,25 13:16,17
14:21,21,24 17:3
17:4 38:13 45:11
110:7,11 128:21
12923 177:2,6
depend 111:22
depending 155:20
155:24
depicted 74:10
depictions 68:23
69:6
DEPONENT
183:25
Deposition 1:114:3
79:10 174:9 178:7
180:7,9,10,11
181:6,9,12 182:6
183:4,21
depositions 821
26:1
deputies 39:19
deput¢e33:5 39:1
describe 5:25 66:2
69:25 114:24
described 60:10
116:13
describes 164:24
description 3:10
17:18 20:17 30:3
design 48:1,2,8
71:184:18 152:1
162:7,8,15
desk 90:19,21
detail 156:23 157:2
detailed 95:22
Details 173:15
determination 35:9
53:2191:2104:23
105:6 127:9
determine 50:8
52:7 53:12 159:3
determined 18:21
52:10110:19
14023 150:20
154:6155:3
159:11,24
determines 53:18
158:17
determining 49:19
50:5 78:24146:7
154:19
develop 87:24
developed 89:13
diagram 154:9
dictionary 28:18
Dietrick 128:22
difference 5:23
27:9 28:1031:3
56:12,14 63:23
different 11:5 39:9
42:12 116:11
142:1 152:17
155:23,24175:6
differently 1052
difficult54:9 68:I4
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dimensional 65:6
direct 3:3 4:12
6 35:19 55:1162-5
5 99:8 124:15 149:2
180:I6
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86:20 107:2116:4
116:5 121:15
124:16 127:18
144:21 146:22
direction 45:8,10
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directly 43:15
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10:22,25 11:10
discipline 7:21
disclose 107:17
discount 85:7,10
discouraged
15020,22 151:4
156:3
discovered 18:18
118:13
discretion 49:2,4,6
49:10,13,16 51:19
51:22,23,24,24
52:5
discrimination
30:21
discuss 37:9 52:17
52:20
discussed 34:16
37:16 38:11,14
discussing 37:24
151:10
discussion 24:8
84:25 117:12
138:25 164:12
discussions 26:6
38:12 129:13
disgusted 168:6
dismiss 24:4,11
displayed 65:12,15
displaying 85:7
distance 146:2,7,9
distinct 13:6 18:2
distinction 65:6
distinctive 63:15
distinguish 28:12
distinguishing
174:24
distracted 9:10
distraught 168:5
distributed 183:19
district 1:1,1 6:16
6:17 40:20 98:20
98:22
divided 14924
dividing 120:8,19
divvy 96:10
document 73:22
76:23 100:22
111.2122:1,12
123:2136:1,10
documentation
79:8 122:14
137:19 138:4
141:17
documents 23:25
77:22 78:20 85:23
105:11
dog 48:23
doing 23:9 110:16
124:25147:4
dominant 153:1
door 79:1711924
156:15,23 157:5
158:24
doors 131:5 148:10
157:3
double 80:12
downloaded
115:24
drafted 83:14
drive 35:13 40:23
drove40:21 66:13
66:22
duly4:9179:8
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dummies 50:17
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duties 8:110:6,7
17:1120:18 34:23
55:24 129:7
duty35:13
dwelling 114:25
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earlier 15:8 29:22
55:13 108:12
early 149:16 154:6
earnest 167:9
easier 11:2 116:15
158:7,9
easily 81:22
east 2:15 114:1,3,3
181:3
eastern 120:24
edge 146:2,9
effect 26:13 135:1
175:13
eight30:11
either 24:25 38:5
51:3 68:14 72:16
86:3,12 115:6
119:19 140:7
142:3,6156:10
171:12 177:8
elderly 173:11
elected 42:18 67:24
68:3
election 169:14,19
170:3 171:6
Elections 170:6,13
170:17171:21
electrical 14:9
element 102:6
156:21
Flor_da Court Reporting
561-689-0999
189
elements 70:25
153:3,20,22
154:14,20 155:2
155:17 156:2,3
159:6,11,25
I65:15
elevation 113:21,22
114:7,18 115:5,5
115:9 119:21
120:24,25
elicit 71:16
eliminate 8622
elongated 68:4
emergency 59:8
emotion 71:16
169:5
emphasis 27:12
employee 13:11
30:5 33:4 43:2,9
43:10 115:23,24
116:1,11 128:24
142:16,18 180:13
employees 30:1,13
31:9 39:17 44:2
45:9 55:3 130:7
employing 44:5
employment 6:1
7:18 112:20
empowered 33:12
encompassed 11:6
encouraged 163:19
ends 92:5
enforce20:14
29:14 31:16 49:6
50:7,9,9 51:5
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enforced 163:12,15
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33:17,20,2134:13
34:13,14,17 35:1
35:4,7,14,20 36:7
36:17 37:3,10,15
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39:13,24 41:23
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124:4125:9,22
126:1,9 128:3
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176:25 177:3,5
enforces 22:20
enforcing 49:3
144:14,17
engaged 125:5
engineer 136:8
141:3 142:3,7,19
engineer's 135:23
engineering 134:24
137:6141:10
engineers 137:20
en joy 54:9
entail 104:14
enter 129:8 183:6
entered 143:7
183:21
entering 106:22
108:5,11 129:14
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entire 9:25 47:12
107:25 119:8
134:15
entrance 114:3
errata 181:9,10,11
182:9 183:19
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ESQUIRE, 2:3,7,10
2:14
essence 104:16
134:21
establish 36:2
establishing 30:17
estimation 146:4
156:9
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evaluate 92:22 93:8
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evaluation 95:22
evasive 26:24
event 60:9,16
158:22
everybody 5 1: 18
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everybody's 163:8
evidence 54:16
105:7,9 131:4
evoke 169:5
evokes 169:6
exactly 14:25 60:13
62:9 78:19 86:6
127:13 146:6
EXAMINATION
4:12
examined 4:9
example 90:24
111:23 140:25
141:2
Exceeded 105:3,4
exception 135:3
182:8
excluding 26:20
150:25 167:8
exclusive 161:12
exclusively 35:24
36:14,17 39:1
86:23
mcused 178:6
mecuted 182:10
mecu tive 42:23,25
:xemption 134:17
135:21,23
:xercising 49:16
:xhibit3,10 73,21
73:22 100:21,22
114:11 121:24
122:1 136:11,14
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exist 61:23 159:12
existing 95:20
154:13 164:6
exists 35:9 61:22
155:13,14
expand 119:5
expect 57:5 112:18
expected 46:25
150:6
experience 106:11
expertise 124:5
Expires 179:17
explain 22:16
28:16 33:14 69:13
exposed 119:22
expressed 37:2
extensive 132:5
extent49:8 96:7,12
96:14 97:12
exterior 116:24
157:17
eye 159:13
eyes 73:I1
F 1:11 4:8 122:19
179:7 180:1 181:2
181:23 182:1,19
183:4
FAA 51:15
facade 115:12
face 62:15,15 136:8
faces 114:1,3
facetious 115:1
Facing 66:16
fact 55:23 118:12
Factor49:19 78:24
154:19 174:24
Factors 49:15,22
50:8 112:10,12
Facts 45:1 113:8
Fair 6:23 56:24
64:20 107:21
109:1 112:10
115:14 127:14
152:15 166:5
all 64:7
familiar 136:15,18
170:9
far 8:22 21:3 88:4
116:23 118:12
158:1
fashion 107:20
134:6
father 174:12
FDLE 107:2
fear 143:18 144:6
fearful 168:2
features 63:15 82:3
152:25 155:4
156:23 157:4
February 173:7
federal 25:8,14
41:15 75:11
feeding 15:22
feel 81:12 103:2
130:15 150:9
161:5 168:8
feeling 169:8
feels 115:10
felt 71:3,6
fence 120:8,15,17
120:19
fences 129:9,9
FF 179:18
field 110:23
Fifteen 5:2
file 12:12
filed 23:25 140:1
181:13
filings 23:21
finance 5:9,14,20
6:2,6,14 7:1,3,9
10:22,21 11:10
Financial 7:3 17:20
36:25 85:13
Financially 180:14
Financing 6:24
33:19,20,22
rind 15:4 21:10
79:23 80:3,13
92:5 132:4181:8
finding 161:24
162:12
Florida Court Reporting
561-689-0999
finds 91:15
fine 24:17 59:14
69;10 77:2 109:5
110:20 128:2
131:8,9,16 132:1
finished 105:23
106:2
fire 7:21
firing 8:5
firm 2:3 78:6 79:19
first 4:9 10:20
16:24 23:15,23
31:14 52:18 53:14
62:19 73:4 78:15
78:18 87:5 97:25
98:1 101:22 111:5
151:23 157:8
163:12180:6
fit 69:19 70:18,25
fitting 156:10
rive 137:22
fix 59:18
flat 150:1
FLDE 107:2
floating 26:16
Florida 1:1,15,19
1:20 2:8,11,16 4:5
6:20 13:2 14:4
15:15,16 17:8
18:13 20:15 21:25
46:7 118:1 170:13
170:16 179:2,17
180:2,6181:4,18
181:19 182:3
How 37:12
Hower 148:5
Foliage 145:1
Follow 49:9 91:3
173:1
follow-ups 51:13
Followed 104:21
150:4
'ollows 4:10
bree 107:25 154:8
162:21
bregoing 180:8,15
182:6
forget 165:1
forgive 165:1
form 20:19 22:18
23:525:7 28:23
29:439:18 49:11
67:25 68:2 69:21
69:22 70:4,20
71:24 72:18 74:6
74:1177:12 78:16
80:7 86:16 88:11
92:18 93:14,21
94:23 95:5 107:8
107:11,19,19
112:25 118:7
125:10 128:7
129:11,21 130:2
130:19131:2
134:6,12 135:9
137:8 138:22
146:13 148:18
152:4,4 161:2
162:22 169:10
174:2183:21
Fort 2:16181:4
forth 180:10
forum 87:8
forward 183:19
forwarded 181:13
found 93:2 94:9
148:13
four -by -eight 67:5
FPR 1:18
frame 67:11
franidy51:18
156:1
free 103:2
frequent 40:19
frequently 40:16
100:11
friendly 81:19,20
front 28:18 11924
162:3,6,10 163:2
163:18 164:1
full 36:23
full-time MA
function 14:24
16:10 39:2
functioned 38:8
functioning 34:3
functions 9:21,23
11:14,15 17:19
funny 57:10
furnished 181:8
further 16:3 34:2
125:25 151:15,16
161:7 177:22
180:10,12
furtherance 128:3
G
G 4:1
games 63:5
garage 156:15
157:3,5 158:23
garden 148:5
Garrison 6:5 155:2
gather 55:8 129:3
gathered 47:10
gathering 35:8
46:9
general28:25
31:17 58:6 78:6
79:6 86:21,24,25
87:5,12 91:1I
94:7 95:20 96:7
107:22133:8
136:6 137:20
151:3 162:18
163:1 169:19
generally 8:16 13:2
13:24 15:18 16:1
21:7 22:1123:6
27:24 29:20 34:I5
40:17 41:447:23
49:13 52:18 59:11
66:24 81:3,22
91:8 93:18 98:24
99:4103:15
110:10 111:2
1I8:1 136:17
146:7149:25
152:19 153:4
156:6
generate 28:2
George 69:1
Georgian -style
153:5
Gershman 23:22
23:23
getting 12:19 16:12
37:23 99:11
142:16 143:11
171:11,13
Ginsberg 32:24
33:12,15 34:6,18
35:19,24 36:14,16
36:21,22 37:10,14
37:19,20 38:4,19
41:16 45:15,18,20
45:22,25 46:5,13
46:15 97:8,11
102:16 103:3,8,24
1042 105:14,17
105:18 109:6,13
109:15 112:21,23
113:5,6,11 115:18
116:7 118:5,21
119:19 120:13,15
121:18 126:16
143:1,2,7 144:8
144:14 149:2
Ginsberg's 151:24
give 42:6 45:14
48:17 55:14 58:19
59:12,18 90:1,24
117:19 118:24
136:17 140:24
150:5,16 159:23
171:20 175:16,20
given 55:3 182:6
gives 111:3 137:20
giving 48:20 79:4
glad 112:7
glance 122:6
glass 143:13
GMMWADISON
2:10
go 21:3 25:16 35:12
49:1151.4,18
62:8 67:2170:12
79:23 80:3,13
85:10 90:22 91:7
91:7 95:5 101:17
101:18 11I:19
112:11,18 117:1
120:15128:4
129:9 130:18,23
132:14 137:11
142:7 154:22
158:7,9 161:6,16
171:13 177:18
goal 16:3 126:6
goes 116:23
going 8:9 18:25
27:2128:1629:8
29:12 30:19 31:10
48:18 50:2151:13
53:7 56:2 57:22
64:24 73:20 74:21
83:16 91:5,6 99:2
100:20 111:19
112:22117:8,18
119:16 121:23
122:5 126:9,23
127:10 128:16
130:7 131:4
136:13 140:24
143:11 164:I4
178:4
golf 98:23
good 52:9 70:15
71-1,183:11
130:25 174:5
Gorel 145:13,15
146:21,22
gotten 90:14
107:19 174:1
government 6:10
6:12,15,18 22:19
130:7
governments 6:21
7:4
grade 78:25
grandfather 164:9
grandfathered
94:17 95:9,12,17
95:21 164:7
grandfathers 94:21
Florida Court Reporting
561-689-0999
191
grants 101:12
great 141:2
Green 84:13,19
85:4,7,13,19,25
86:11,15 87:13
88:7,13
grinch 166:4
Group 84:13,19
85:4,7,13,19,25
86:11,15 87:13
88:7,13
Groves 6:17
guess 7:17 8:8
18:10 19:19 21:19
42:16 55:162:25
70:2 99:3,5 111:8
111:25 123:20,23
124:15 134:24
136:7150:8 154:7
176:5
guessing 34:5
131:14
guidance61:13
guidelines 49:2,9
Gulf 1:7,14,15 4:24
5:11,16 6:110:23
12:5 13:1,18,21
13:25 14:18 15:4
15:9 20:5,8 21:24
25:6 33:3 36:3
40:24 41:1,2,5,7
43:3,10 82:23
83:1,3,4 85:6 89:4
98:19,23 99:6
109:4 111:4
116:20 128:5
134:8 152:21,24
153:4,8,20154:5
154:14155:4,18
156:20 157:3
159:4170:7,21
181:5 183:2
guy 37:20
guys 56:2 96:9 98:4
11120 177:15
H 3:8183:1
hac 4:15 24:22
hall 1:14 41:6,10
98:22 103:18
116:10 118:22
halted 111:8,11
hand 179:10
hand -delivered
123:1
handle2l:23 22:1
169:24 177:2
handled 110:7,10
110:23 111:21
handles 17:20
177:6
handling 67:25
68:197:17
hands 129:23
handy7:6
hanging 66:14
Hanna 2:10 4:16
4:16
happen 123:10
158:4
happened 30:7
38:2177:17 80:6
84:23 142:13,22
149:21 156:17
160:8 163:7
173:14
bappening 30:6
118:6
happens 18:16,20
30:5 53:3
happy 71:14
harassing 174:12
177:19
harassment 31:24
32:1
ha rasssive 29:5
hard 37:22 76:25
harm 112:2
Harrison 4:22
hats 11:3,4
head 44:8 69:2 73:5
health 13:3 15:21
172:12
hear 9:3 47:6 ION
170:12
heard 25:22,24
62:19 105:17
109:12 112:1
144:16
hearing 51:25 54:4
57:23 60:12 72:7
94:16 110:21
122:22 123:19
125:9,23 126:1,9
133:8,10 139:6
140:23 158:12,15
158:17121 169:15
hearings 147:18
157:21
hearsay 173:18
hedge 66:14 67:1
117:22,23
hedges 67:6 164:6
held 24:8 117:12
138:25 164:12
hell 72:20
help 14:7 22:5
30:20 33:8,12
39:20,22,23 40:1
43:14,17,24 44:7
54:24 80:21 96:3
109:10 113:13
127:9 160:12
helped 36:9 81:3
hereinabove
180:10,11
Herrington 6:4
7:12,20
Hey 109:17 126:8
170:16
hierarchy 56:5
high 107:23 108:14
108:25 117:1
iiigher 150:10
154:8
iighest 42:20
lighway 41:15
lints 48:20
lire 7:15
sired 6:2 7:11
hiring 8:4
historically 8:1 ]
history 6:160:6
97:10 153:7
165:24
HOCKMAN 2:15
hold 11:12,13
167:12
holidays 165:12
home 116:24,25
121:5 124:6,19,22
130:23 142:8
149:6,8153:5,20
154:5,20,22 155:3
157:18,22 158:18
158:24 159:4,6,25
160:5 161:16
homeless 15:23
homeowners 99:19
99:23 100:2,9,14
100:17 160:15,22
161:11,19
homes 129:15
149:12,13 157:4
homicides 106:17
hope 57:3
house 22:6,7,10,10
22:11 52:2166:12
112:24 113:6,7,11
113:17,19,24
114:8,18,23,24
115:5,7,11 117:14
118:6 119:8,24
124:25 128:4,13
129:20 130:18
142:17 143:7
149:3 152:16,23
153:17 154:I
156:5,5 157:6,16
159:10
houses 128:16
152:18 163:25
humble 43:6
hurricane -rated
156:15
hypothetical
125:15,19
idea 33:18
identification
73:23 100:23
122:2 136:11
identified 15:8 48:2
50:6,7 64:8 65:20
155:4
identify 43:22 44:4
46:4 72:9 92:21
122:12
11I2:7 69:1
immediately 53:16
146:17
immigration 106:3
144:14,17
implement 31:8,24
38:17
implemented 34:5
49:3
implementing
33:19
important 117:7
impossibly 141:16
improper 26:18
29:5
improperly 76:22
improvements
174:1
inability 117:19
incident 18:22
19:12,14 21:5
47:9 48:17,20
51:9 60:8 109:7
118:13 144:25
145:3 147:4
151:24 152:5,7
160:10 167:24
173:24,24
incidents 47:18
include 8:18 59:6
87:2
inclusive 180:8
incorporate 123:5
Incorrect 126:11
Increase 150:25
independent
Florida Court Reporting
561-689-0999
192
159:23
independently
26:14
indicated 133:23
170:25
indication 126:21
individual 70:16
88:4 95:18 111:7
individually 52:15
influence 88:19
inform 146:22
information 12:11
35:8 44:14 46:9
47:10 53:14 55:8
82:1 83:7 108:1
108:10 116:8
124:21 126:20
129:3 132:6
informed 148:9
informing 110:25
initial 84:17 104:24
initially 35:21,22
41:19 81:4 132:23
133:2 149:22
initiate38:25 51:25
53:13
initiated 88:18
initiating 88:19
91:17
input 79:5,7 83:18
83:21 89:18,24
90:1 149:23
160:22
inquire 132:19
177:22
inquiring 119:2
inquiry 55:1
Inside 16:6,1122:6
22:9 113:7,17
114:6 117:14,17
121:4 124:22,25
130:18,23 142:4,7
142:16
aspect 17:5 21:20
141:4 161:16,17
nspection 12:16
18:12
inspections 12:14
14:3,18 15:16
16:19,24127.24
inspector 11:18
14:14 15:1 127:22
127:23
inspectors 19:21
21:17,19
install 148:1
installed 148:23
instance 1824
19:20 90:20 111:5
159:13 163:17
instances 23:7
59:21 131:3 160:3
institute 7:21.
instituting 60:4
instruct 28:1,3 29:8
31:10
instructed 128:15
instruction 128:20
128:21
instructions 55:14
111:3,7
insult 57:14 96:19
insulting 96:13,14
96:15,24
integrity 17:7
intended 89:7
intent86:24
inter -local 13:20
15:7,13 16:6,8
17:2,12
interaction 97:25
105:14
interactive 82:3
interest25:5 37:2
interested 180:14
interior 117:14,25
122:25 124:6,19
128:11
interpretation
95:22
interpreted 91:12
interpreting 79:12
interrupted 8:6
Intracoastal 99:7
inventory 159:5
investigate 42:1
52:190.22 92:22
128:13
investigated 94:10
investigation 44:18
44:22 51:9 52:2,4
54:15,19,23
107:17 110:I9
invited 100:12,13
13024
involve 60:19
involved 19:6,7
34:9 52:16 79:19
81:7 90:7,10,13
90:15105:11
109:21 110.4
126:18 I27:24
involvement 79:19
131:20,22 171:11
involving 143:2
169:17
irreparable 112:2
issue 19:9,9 20:8
60:24 72:7 82:16
98:8 103:25 104:5
104:7 106:4,6
118:1,2 121:7,12
126:22,25 127:5,6
177:3
issued 42:14 113:7
issues 20:23,25
30:16 35:14 48:25
90:14 123:5
174:11 176:20
issuing 20:1 101:10
items 14:10 151:4
J 2:10.14
job 1:216:25 8:14
16:15,1717:18
20:17 30:3 31:23
31:24 32:15,15
33:151:17 92:15
100:7 110:17
118:19169:4
181:2
Johnson 2:I4 181:3
Johnstown 2:4
joint25:5 111:25
112:6
Jonathan 2:3 4:14
59:13,14 174:7
Jonathouroboyle...
2:5
Jr 1:114:22 179:7
181:23 182:19
183:4
judge 75:11
judgment 112:14
July 179:11 180:19
181.•1
June 1.12 179:8
jurisdiction 20:14
justify 141:16
159:19,21
_ K
keep 8:9 40:18
102:1 111:20
keeping 15620
Kelly 115:23
keyboard 124:14
keys 124:13
kind 31:140:18
106:10 118:4
137:21
kinds 64:24
king 69:1,1
knew 63:12 102:17
145:24
know 5:4 9:14 11:4
11:13 12:8,8,8,9
13:8,1414:11,15
14:25 15.2 16.4
16:25 17:9 19:3
24:18,24 25:10,11
25:16,1726:10,14
26:15,23 28:5,6
29:17,2129:1
32:24 33:13 37:6
38:2,21,2141:8
41:22 43:5 44:19
45:23 46:20,22
47:2148:4,18
54:5 55:7 56:5,25
57:13 58:9 59:2
61:24 63:6,8,25
64:13,22 65:4,9
66:2,5 67:3 68:16
70:5,17,18,22
71:5,6,8,25 72:15
72:20 73:1,15,16
74:9 75:20 77:7
83:12,23 85:23
86:6 90:4,5,11,12
94:24 95:19 97:10
97:17 98:7 99:3
99:14 100:18
102:1,20 103:3,5
104:1,I5,22
105:13 107:9,18
112:19,23 113:1
113:15 115:6
116:20,21117:7
119:10,15,15
120:2,5.8,16.16
123:22 124:2,11
124:13,20 125:17
127:12,18,23
129:10 131:6,24
133:7,9137:7
139:12141:5,6,8
141:24 142:2,14
146:6,10,11,14
147:8,25 148:21
149:19 154:24
155:3,9,25 156:19
158:1,1,5,11,16
160:19 162:19,23
163:17166:7,20
167:14 168:1,22
169:7 170:9
171:16172:1.21
173:5,20 175:2,9
177:11,14
knowledge 7:7
18:11 107:15
128:14 157:9
158:25 168:15
Florida Court Reporting
561-669-0999
193
172:3 176:14
182:8
known 70:3
knows 28:10 45:18
__ L
L 2:7
labeled 153:17
lack 109:10
lady 148:12 173:11
173:16
Lake 2:7
Lakes 1:19 181:18
land 107.22
landscaping 147:5
147:I0,12,23
160:9,16161:10
161:17,23
language 56:21
134:21 136:22
147:19 164:25
Large 4:5 180:6
late 30:5 160:10
170:23
latitude 156:8
Lauderdale 2:16
181:4
laugh 112:8 167:6
laughed 126:6
laughing 57:13
laughs 64:24
law2:3 25:8.14
2822 54:1 68:4
91:15 92:4 162:21
lawn 1623,6,10
lawns 163:3 164:1
laws 144:17
lay 28:11 107:22
league 175:12
learn 98:12 138:18
14625
leave 76:7128:20
129:22 139:2
160:25 167:15
left 176:18
legal 26:10,13
27:23 28:8,9,11
28:15 59:5,10
79:1108:20,24
125:12 130:3,11
leniency 112:11
lens 120:14
let's 10:1 16:18
23:18 31:24 44:6
50:5 52:10 54:24
69:1097:7,18,24
98:21 100:20
108:10 128:10
151:5,22 177:16
letter3:1 151:17,25
52:6,12 56:11,11
57:3,4 58:4,8,16
58:18 95:25 96:4
96:7122:10 123:7
124:9136:6,8
137:22 137:3
181:14
letters 53:23 58:10
123:5 174:18
175:5
level 12:1,2 36:20
51:7 54:19 59:5
59:10 78:1193:9
106:8,10 108:6
116:23 117:1
119:8127:23
133:13,16 135:13
141:7147:14,17
147:18150:2,25
150:25,25 157:21
157:21170:4
lies 99:5
life 143:19 144:6
lightning 9.4
liked 160:16,24
line 17:6102:2
177:12181:10
183:7
link 84:5 85:20
86:13,15
list 82:2
listed 96:5 154:1,4
155:18
listening 8:24 9:1
litigation 49:17,18
94:12
little 5:22 8:13 9:1 C
11:2 18:1522:16
31:20 35:10 41:1
49:10 52:154:24
76:25 81:12 87:4
98:16 103:13
105:1 126:6 143:3
143:16144:10
live49:18
located 63:18 67:1
83:12 98:19 148:3
148:24
location 66:23
116:13 127:19
logical 81:24
logs 40:18
long 5:1,13 86:17
148:7
longer 165:23
look 21:10 28:19
40:167:12 95:18
129:9 136:14
160:4 175:6
looked 56:25 73:14
looking 55:7 64:15
101:16
loose 48:24
lost35:18 102:11
lot 11:22 107:1
117:8
Lou 132:20
Lou®Louroeder...
2:9
LOUIS 2:7
ove168:21
ow 101:20 106:12
',oxahatchee 6:16
,unn 3:11 136:1,7
137:I5
Ann's 137:22
141:10
M
aachine 132:7
magistrate 53:16
53:19 54:6 73:16
77:7,18,19 79:6
161:24,25 162:11
163:6 164:24
mail42:10
mailbox 148:10
maintain 36:20
maintains 80:19
maintenance 40:9
45:14 55:13
major 107:15,16
majority 41:9
making 19:16
68:13 92:7 127:9
134:10 144:4
management 7:1
manager4:25 5:5,8
5:9,13,21,24 6:3,6
6:8 7:9,13 8:1,2
8:1411:6,8 20:18
22:12,18,20 29:24
55:18 124:I3
155:1 157:25
174:20 175:21
manager's 5:24
managers 8:11
175:12,15
mandate 176:13,14
maneuver 81.22
manner 67:6
manners 40:7
manpower 38:11
51:4
manual32:2,4,11
48:1,3 152:17
162:7.8,15
map 114:9 153:24
March 96:1
nark 2:10 4:16
73:20 100:21
121.23
narked 73:22
100:22 122:1
136:10
narkings 114:12
dartin 86:3,5,9,12
86:14
Marty 76:11,13,19
78:8,11,13,13,23
79:2,7 80:25
83.17 90:4 138:5
159:3 160:4
161:15
material 137:23
141:10 147:10
matter 8:22 24:19
24:20 27:16 52:1 i
55:23123 61:14
72:13,16 78:23
79:1,5 104:12
108:16,20,23
113:8 139:22
161:21,22) 165:6
169:17 176:9
177:24
matters 22:9 33:8
107:23 110:16
177:23
mayor 61:9,13
74:13,14,14 95:25
96:4,9
mayors 61:16
MBA 6.25 7:2
McDonald's
148:11
mean 10:14,15 11:4
11:21,22 22:17
26:12 30:8 41:5,6
41:23 43:17 50:16
51:10 52:5 53:9
55:23 59.7 68:1
68:11,13 79:15
81:9,21,21,25
86:8,25 100:9
102:10 106:10
107:9 114:15
120:12 121:17
123:21 124:12
126:7131:25
138:2 140:12
148:20149:8
153:1,2 155:25
157:23 161:13
170:15
Florida Court Reporting
561-689-0999
194
meaning 98:22
102:12
means 9:14 27:1
28:7,10,16,22
57:17 58:1475:7
123:17 180:16
measure 146:8
measurements
17:5
Mediterranean
152:21 156:4
157:13 158:8,10
meet 83:9 150:19
meeting 60:12
65:21 94:16.99:19
99:19,20 101:22
101:22 103:18
141:8 142:23
143:4 166:19
170:25 173:10
meetings 97:13
100:3,11,13
166:11,15,21
168.?5
meets 150:19
member 170:24
175:17,18
members 160:16
memoranda 85:24
memory 46.14
60:16 64:13 96:3
98:6 101:5 109:11
113:14 144:12
160:12
mental 172:12
mentioned 108:5
message 118:24
met 98:1,3,4,7
151:13 170:7
171:20,20
metal 131:18,22
132:19 133:2,6,14
133:17,23 I34:5,7
134:13,18 135:11
135:11,12,15,15
135:17 136:23
137:4,18 139:17
140:22,24,24
141:16
mid 137:12,14,15
middle98:8,18
133:24
mile 41:7
mind 81:16
minimum 59:3
ministerial 53:24
minor9:9,12,14
76:11,13,19 78:8
78:12,13,13 79:2
79:7 80:25 83:17
90:5138:5,6
147:23 159:3,19
160:4161:15
Minor's 79:10
minutes 29:12
misled38:1
missed 82:14
166:13
missing 119:9
mistake 10:2
misunderstood
38:3
month 76:2133:19
133.24 137:16
months 93:20
mooring 76:22
77:11
moral 130:15
Morgan 95:25 96:5
96:9
morning 11:23
30:10,11
mother 173:17,22
motions 24:3,11
mouth 167.21
move27:16 29:9
31:10,1169:11
98:16
moved 98:25
Mr.- 97:24
mullions 149:24
150:8,13
multitude 153:3
municipa] 28:14
31:1
municipalities
169:19
MURDOCH2:14
_ N
N 3:14:1
name4:20 84:24,24
181:14
narrative 131:25
132:3
natural 158:22
nature32:17 63:18
64:9 67:15 79:20
87:12119:10
129:4136:6 143:8
necessarily 53:16
125:24
necessary34:2
Ned 148:11
need 7:1519:1
28:17 29:24 30:10
30:23 34:8 43:21
55:15,17 60:14
64:10,14,18 87:24
89.20 91:2109:18
116:16 117:15,22
118:3 121:19
125:8 127:11
128:19 138:19
140:16 147:12
154:11 160:12
needed 87:14
101:11112:8
117:15118:6
135:11
needs 116:14
139:16 147:4
154:17
negative 80:12
negotiations 85:17
neighborhood 99:5
161:4
neighbors 161:5
neither 38:7
never 29:2 54:6
104:7 105:17
168:4,12 169:8
170:10 172:17
new 94:2195:10,13
95:17 102:22
169:8
nine 30:10
nods 44:8
nonlevel 158:2
nonprofit 89:11
normally 146:11
150:3
north 41:4,6 114:2
Notary 4:4179:17
180:5
notations 182:9
noted 181:9,10
notes 180:8
notice 3:14 52:6
53:156:1158:20
58:23,25 61:2
122:18,24123:12
123:13,15,16
125:1,16,21,22
126:8,12
notices 42:3,10
58:12
notified 40:7
November 133:20
135:7,7 137:14
144:24
nuisance 59:24
number 58:19,21
93:23 181:10
numbered 180:8
_ O _
04:1
O'Boyle 2:3,3 3:5
4:13,14,19 8:10
16:16,2120:21
23:1,10,17 24:9
24:14 25:4,11,15
26:19 27:15,22
28:11,17,20,24
29:10 30:17 31:5
31:12 35:3 37:12
39:2142:24 43.4
195
45:3,4 48:15
95:15 96:5 97:11
49:14 50:20 57:18
98:1,13,25 101:11
59:13 63:4,10
101:23 103:3,7,19
66:169:12,15
105:14 10 9:7,17
70:1,10,11,24
112:6114:13,15
71:13 72:2,14,22
119:11120:5
73:3,20 74:1,2,8
122:19 I23:17
74:16 75:5,13,16
124:24 125:7,22
77:4,15 78:21
126:8,12 131:17
80:9 86:3,4,9,12
131:22 132:8,15
86:14,18,24 88:12
132:23 133:13,16
93:1,17,24 95:1,8
133:23 135:2,5,7
96:12 97:6,18,20
135:10 136:22
100:24101:1,4,8
137:2,12,17
101:18,19102:21
138:19139:16,21
102:24105:5
140:1, 8 141:3,6
107:14112:9
141:22 142:3,7,24
113:3 114:11,14
143:6,11,14,15
114:16,17117:13
144:4,24 145:19
118:1012I:23
145:22146:16
122:3,11125:13
147:3 148:9,16
128:9 129.12,24
149:15,18 151:12
130:5,12,15,16,21
156:14 157:6
131:7 132:16,17
159:9,16 160:9,25
134:16 136:12,25
162:3 163:22,24
137:1 138:1,24
164:17166:9,14
139:1 144:9
166:20167:10,24
146:15149:1,13
168:13,21,23
149:14151:5,8
169:14,17,21
154:15 159:18
170:7 172:9,17
160:2161:8
177:16181:5
162:24163.4,10
183:2
163:11164:13
O'Hare's23:19
166:1 167:18,22
63:2,4,6 66:10,23
168:11169:13
72:10 83:24 92:16
174:4,16,17
93:294:10112:24
176:11,17,21,24
113:6,11,17,24
177:15,17,21
118:6 121:5
178:4
124:22 132:18
O'Hare 1:4 2:19
142:4.8,16 149:3
3:1123:1424:21
149:6 151:13
65:11,19,23 68:25
152:16,23 153:17
69:13 74:17 75:17
153:25 154:22
75:24 76:22 8221
159:4,6 160:16
85:20 86:3,8,12
161:10,16,23
86:14,23 91:9,17
173:17,22
91:22 93:11,18,23
oath 97:22 179:1
Florida Court Reporting
561-689-0999
object 20:19 23:5
25:728:23 29:4
39:1849:1163:2:
63:24 65:8 69:21
69:23 70:4,20
71:2474:6,11
77:12 78:16 80:7
86:1688:11 92:11
93:14,2194:23
107:8112:25
118:7125:10
128:7 129:11,21
130:2,19 131:2
134:12 137:8
138:22 146:13
148:18 161:2
162:22 169:10
174:2
objected 69:22
177:24
objection 65:17
72:17,19
objective 53:1
objects 63:17,20,21
63:2164:1,6,6,20
66:5 71:2173:5
75:24 76:18,19
78:1164:14,17,21
165:7,8
obligations 97:3
obscured 163:18
observe 40:8,9,10
40:1194:13
observed 18:17
19:18 54:18 66:13
94:11149:3,23
observer 65:3
observing 105:11
obtain 53:157:20
obtained 6:5
obtaining 44:14
obviously 40:21
50:22 572 63:17
64:13 139:24
occasion 79:17
occupation 5:7
occupational 17:15
17:17,20 109:24
110:11111:9
occur 12525 148:8
occurred 45:2
97:15 131:10
occurrence 103:14
103:15 106:12
108:12,13 109:3
October 112:22
122:7 123:1,3
137:12 149:3,6
offended 69:16
offender 52:16
offense 68:18
offensive 68:17
102:13,14
offered 65:21
office 52:24 151:21
183:19
officer 18:24 3220
32:22 33:2,25
34:4,9,12,13,14
34:18 35:2,4,7,13
36:1,11,12,17
37:3,11,15 38:5,5
38:8,15,16,23,25
39:14 40:9 42:23
42:25 43.23 44:6
46:2,3,8 54:17
55:12 96:17
102:18 105:18
109:13,15 110:24
110:25 111:16
113:6 115:18
118:21 121:18,21
143:1,2,20 145:11
145:13 149:2
151:24
officer's 112:14
sfricers 36:6,20
45:12 46:21,25
47:5113,17 48:7
130:18
)fficial 11:16,20
12:3,4 33:9,11
56:15,15,16 58:20
58:25 179:10
officially 98:3
177:8
officials 42:16,17
42:18,20 67:22,24
68:3
Oftentimes 146:8
oh 21:6 110:15
122:24 142:20
169:9 171:5,22
okay 4:20 5:5,22
6:9,20,23 7:6,8,[7
7:25 8:4,24 9:3,8
9:15,21,23 10:5
10:11,17.20 I1:2
11:5,9,15, 17,20
12:4,8 13:20,23
14:12,17 15:1,3,3
15:7,12 16:5,12
17:1,10,14 18:10
19:2,4,8,8,12,16
20:8,22) 21:14,22
22:2,5,9,12,16,23
23:11,18 24:3,17
25:5,11,16,19,22
25:25 26:3,10,12
26:25 27:3,14,23
28:729:2,11,18
30:131:23 32:3,6
32:8,10,14 33:5,9
33:11,14,20 34:6
34:17 35:10,22
36:5 37:2,5,7,14
37:18,22 38:4,19
38:22 39:5,8,16
39:22 40:15,19
41:5,9,12,14 42:3
42:20,22,25 43:13
43:13,17 44:1,6
44:11,16,21,24
45:15 46:10,13,17
47:4,1148:1,10
49:2,9,22,24 50:1
50:2151:23 53:2
53:5 54:14,21
55:1,3,16,18 56:7
57:9,19 58:3,6,18
58:22,24 59:7,17
60:3,8,17,19,21
61:3,12,16,19
62:2,11,14,16
63:11,15 64:1,4
64:10,13,20 65:5
65:14 66:2,9,15
66:22,25 67:11,1
67:20 68:19,22
69:4,6,12,19
70:10,15,18,25
71:9 72:9 73:4,9
73:19 74:9,21
75:1,2176:1,7,18
76:2177:16 78:5
78:7,13 79:21
80:2,5,10,16,19
81:2,9,15 82:12
82:17,23 83:3,24
84:13,16,19 85:19
86:5,8 87:8,10,18
88:3,7,17,21,24
89:7,13.2190:3,6
90:9.17 91:1,6,9
91:14,18 92:12
93:2,10,18 94:3
95:2,23 96:3,9
97:1,9,2198:4,10
98:12 99:14,23
100:9,14,20 101:9
101:15,18,25
102:6,8,16 103:7
103:24 104:5,18
105:6,13 106:3,10
10625 108:4,9,21
10825 109:5,9,15
109:20 110:3,6,18
111:17 112:10,15
113:1,4,10,13,16
113:22 115:15,20
116:7 117:21
118:5,14,21
119:13 120:12,19
120:22 121:4,7,10
121:12,14 122:22
123:9 124:3,6,12
124:I8,24125:2,7
125:14 126:15,25
Florida Court Reporting
561-689=0999
196
127:8 128:3,18,22
129:6,13,18 130:6
130:10 131:8,13
131:16 132:6,10
134:7,10,17 135:5
136:5,13,16,19,25
138:16 139:4
140:2,15 141:21
142:1,11,15,21
143:9,25 144:2,4
144:10,16,23
145:6,18.2(,24
146:4,16.20 147:7
147:11,16,20,23
148:5 149:2,8,15
150:8,14 151:2,11
151:18,22 152:1,3
154:16,21 155:12
155:16,22 156:2
156:13,22157:5,8
157:12,24 158:14
158:20,23 159:1,3
160:7,14,18,21
161:15 162:6,10
162:14,25 163:10
163:15,25 164:11
164:16165:1,7,12
165:16,22 166:14
166.23 167:3,13
167:23 168:4,12
169:14170:5,15
170:19 171:1
172:3,8,11,14,19
172:24 173:3,6,14
173:16,19 174:5
174:15 175:3,20
176:1,4,16 177:7
177:11
old 81:18 95:3,7,12
95:16 148:11
once 18:2140:21
52:4 60:7 66:13
121:11 181:10
)ngoing 107:15,22
)pen 49:17 94:12
162:3,6,10 163:2
)pened 79:17
o perate 70:3
operates 18:1
operations 8:16 9:6
opinion 28:2 63.22
67:1088:1 167:11
168:24169:2,4
opinions 81:14
opposed 22:10
opposite 119:24
option 140:4.19
15024
options 139.20
157:23
order 16:25 104.,6
104:6,8,13,20,20
111:12113:7
119:20 120:12.13
121.7122:9,20
126:22 127:1,19
128:19 147:1
170:5
ordered 178:2,3
ordering 181:13
orders 103:25
ordinance 71:23
72:4,7,1175:18
77:9,10 94:6,15
94.2195:3,7,10
95:12,13,16,17,19
164:19 172:20,22
organizations
175:14,17
original 133:25
174:22 181:12
183:19
Orlando 2:8
Orthwein 8:25
61:25 63:5,11
74:13,14,15
osmosis 107:6
outside20:17,18
22:6,10,1126:21
27:23 28:9,22
40:14 42:18 66:12
88:1910225
103:1,10 109:15
113:18 115:3
124:3,5 158:21
159:25 177:4
overmeasure
146:11
overriding 154:19
overview 162.18
owner 85:4140:5
140:19,20 157:16
158:17
owns 120:5
P
P4:1
P.A2:15
P.m 1:13
PA 2:10
page 3:10 181:10
183:7
pages 180:8 181:11
Pahokee6:14
painting 67:12
116:25 157:18
paintings 68.20,22
71:7,9
Palm 1:19,20 2:11
170:4 179:3 180:3
181:18,19182:4
panels 157:4
paper 42:6 173:3
paperwork 16:20
42:12,13
paraphrasing
127:15
pardon 100:10
park 177:9
parking 48:5
172:20,21 177:1
part 19:5 32:15
48:3 56:2164-3,4
64:5 76:13 77:9
83:6 94:19 98:21
110:13 119:21
140:25 141:24
147:11,20 153:9
155:6 157:5162:2
162:20 164:8
166:2
part-time 33:4,21
45:21 46:5
partial 115:5
participate47:1
176:1,2,3
participated 176:5
particular 21:4
30:9 56:23 58:19
59:2160:9 91:14
93:12 100:5 102:8
104:16 110:18
160:1164:5
165:16
particularly 155:14
parties 110:25
177:11 180:13
183:19
parts 48:5
party 110:25
111:16 180:13
pass 41:1?
pastel 116:25
157:18
patro140:12,19
41:17,25
patrolling 40:15
41:17
pattern 8124
pay 78:25 88:21
penalized 30:7
penalty 18320
Pennsylvania 2:4
people 3024 39:4
40:9 423,6 59:18
75:6 80:20 82:9
82:10 102:1
106:21128:1
157:25 165:10
177:1,11
people's 128:16
130:7
perfect 136:16
perform 15:15 16:5
16:10 18:12 35:20
55:1
performing44:2
44:13
period 765134:8
periods 56:8
perjury 183:20
permission 143:7
177:8
permit 3:13 11:23
12:1,1,11,15 14:2
18:19,21,25 19:1
19:20,24 20:17
21:10 98:13 101:2
101:6,10,10,12,21
104:24,24 109:23
111:20 116:12,15
116:16,20 117:15
117:22 118:3,6
119:3,12 121:20
122:7 124:24
1252,5,8 126:12
12622127:11,11
132:9 133:14,22
135:6,8,9137:4
147.4,8,12,I4,24
148.2 149:19,21
150:12 156:14,17
177:7
permits 12:14 20:2
20:3,4,6,9 109:10
151:10,13
permitted 119:17
person 7:3,23 8:22
14:1717:10 18:23
33:16 38:13 42:9
43:22 52:16 53:18
57:3 63:14 65:1
110:18
personal 18: 11
166:8
personally 30:12
48:19 55:22
114.20 145:9
179:7
personnel31:19
322,3,10 45:14
55:14
persons 63:14
perspective 87:25
pertubation 144:10
Florida Court Reporting
561-689-0999
197
petition 172:4
petitions 171:20
phase 163:19
phone 109:16
152:9 170:17
181:19
phones 9:18 64:23
photo 155:5,6
Photograph 3:12
physical 10:15
physically 16:14,16
pick 34:6 80:13
116:16
picture 6825 69:10
114.21,22 120:17
129.4
pictures 66:17,20
68:19,20 69:8,14
69:16,19 70:8,13
91:23 92:3 93:12
113:16,18114:6.7
115:17,25 116:8
118:11,16 120:13
121:4 149:3,5
pieces 42:6 137:23
pike 158:3
Piper 2:15 25:1
place 18:18 34:21
40:20 60:16 75:10
85:198:25 99.4
99:11,12,18 100:5
100:10 105:21
110:24 121:22
127:19 148:11
160:15 163:25
180:10
placed 63:14 70:8
plain 115:11
plaintiff 1:5 22
4:15,16
Plaintiff 73:22
100:22122:1
plan 79:18 116:20
140:19 147:8
148:2
planning 32:16
53:12 104:10
plans 117:5
plantl47:21
planting 144:24,25
145:5,19,22 146::
plantings 148:22
play 63:5 168:5
please4:20 5:25
35:16 50:4 82:5
142:5183:19
point 23:9 47:9
54:560:13 63:9
95:15118:9
154:18 163:5
178:3
pointed 91:14
164:15
pointing 148:17
points54:1
police 18:23 333
33:2434-.4,9,12
35:13 36:1,20
38:13,15 40:8
43:23 44:6,7
45:1146:8,25
47:5,13,17 48:6
48:17,19 54:17
55:12106:23
107:23,24,25
110:7,11,24
112:14128:21
129.23 144:17
145:11,13 152:4
177:2,5
policies 26:8 29:I3
29:18,19,20 30:18
31:8,13,16,17,18
17625
policy22:15,19,20
22.21 23:2,8
25:20 26:25 27:24
27:25 28:6,14,21
29:3 30:19,20,20
30:22 31:1,25
81:7 82:16 128:15
political 67:15 68:8
68:14
politically 68:8
Polo 62:3,20,22,23
62:25 63:173:10
74:3
pool 115:3,4
poor 140:25 143:5
I48:11
popped 73:4
portion 27:17
36:19 115:6,7
119:23 123:6
position 423 5:1
6:15 37:1143:22
44:5 46:10 68:6
161:21,22
possibilities 157:15
possibility 80:5
86:22
possible 40:4,5
78:7 82:15 92:14
93:16 96:2120:11
121:17 123:3
149:7 175:8
possibly 30:15
72:23 91:194:17
142:25 157:21
158:3 174:7,9
176:7
posted 73:25
potentially 54:2
94:17 148:3
pouring 111:23
power 104:7
150:10
powerful 102:1
powers 39:12
practice 151:3
pre -permit 133:14
vredominant
152:24 153:1,19
154:7 155:4
n•e£erred 156:4
premises 137:16
)repared 139:8
prerequisite 172:5
irerogative 127:6
iresence 173:25
iresent2:19 8:24
9:1103:19.19,20
103:20 139:5
142:13 143:21
presentation
122:15
presented 33:18
135:8
pretty 7:6 79:16
89:18 104:12
125:15 140:6
143:13
previously 89:19
18I:7
primarily 38:15
40:3 52:15,18
65:5 83:16 174:3
printed 115:25
prior 5:16 6:16,18
31:15 87:22
133:13 142:11
169:18
prioritize 51:21
privacy 129:14
private 129:15
130:7
privilege 25:9,13
74:25 87:3 96:21
97:13 103:2
privileged 165:20
privy 107:22
pro 4:15 24:22
probably 64:15,17
70:9107:16
111:24 125:11
131.3 133:1
139:12149:19
170:20
problem 57:17
59:19 108:6,11
problems 8022
)rocedure 140:6
150:3
)rocedures 104:18
104:21
)roceed 19:160:14
)roceeding 77:7,19
164:24
proceedings 53:13
53:17 60:4
process 18:16
51:10 104:25
111:9
proclamation
102:15
professional
117:19
prohibited 64:8
135:20 140:10,14
promulgated
128:16
properties 96:5
120:20
property 16:19
18:18 66:23 120:6
140:5,20 141:4,19
142:4 147:5 148:4
159:17
propose99:17
proposing 99:15
prose 24:7
prosecute 49:20
51:2 53:7,9
prosecutorial 49:4
protocol 107:18
provide 14:1 15:20
15:25 45:6,8,10
45:11,15 46:13
652 131:25 132:3
141:17
provided 53:14
77:20 111:3
115:18 140:4,19
151:16 161:25
provides 25:8
Providing 115:20
provision 47:24
123:25 134:25
162:3,6,20 163:13
163:16,21
psychopath 172:14
172:17
public 4:4 60:11
73:18 74:19 76:23
77:23 78:20 82:2
Florida Court Reporting
561-689-0999
!Zi
83:11 87:894:16
94:16 107:3
128:24 133:7
176:19 177:23
179:17 180:5
pure 130:11
purpose 15:20,25
19:14 36:19 57:20
57:24 65:2 92:8
104:16 129:3
purposes 19:13
pursuant 15:7 16:6
17:11
pursue 51:16
put 67:1170:13
82:17 83:13 84:2
85:20 86:13
176:23 177:21
putting 82:8
124:13 125:22
quality 70:16
quarter41:7
quasi-judicial
140:23 147:18
157:21 158:21
question 8:19
12:23 13:19 15:6
15:11 20:7 21:8
22:8 =4:12 25:9
27:15 3122 33:13
35:16 38:3 43:19
43:25 44:146:24
47:2,7,14 48:12
49:5 50:4 56:9
57:10,17 58:9
59:2 61:1164:19
65:9 70:6,12 71:8
72:1,24 82:4
96:20 100:1 108:8
108:19 124:2
125:19 129:10
130:4 137:9
141:15,21 142:1
156:1 168:7 173:6
luestioning 26:18
29:5 37:13
questions 12:18
3023 55:12 61:20
64:15 130:11,13
132:12 136:24
176:18
quick 151:5
quickly 177:18
quite 27:1 8020
972132:4
quote 102
R4:1 180:1182:1
183:1,1
Rachel 1:18 4:3
179:16180:5,22
181:17183:3
Randolph 78:5
87:13,19103:20
14225143:21
144:13
range 149:20
rattlesnake 59:25
reach 43:20 76:11
132:18
read 27:15,17 66:2
122:5172:24
178:1181:9,10,12
182:5183:20
reading 181:7
real 87:24
really 36:2138:2
40:1748:23 64:22
65:3 90:2 92:6
126:813I:13
132:23 148:6
156:10 165:21
167:6177:3
Realtime4.4 180:5
rear 113:19,20
115:7119;8
reason 52:9,11
88:13 102:8
130:18,25 140:16
164:5 165:16
166:3,5 173w5
183:7
reasonable 177:19
181:12
reasoning 161:14
reasons 52:14
130:22 131:1
Rebecca 17:19,23
17:24,25 19:23
recall 10:19 18:9
18:11,24 19:4
23:8 24.2,625:21
25:24 26:23,24
29:22,25 30:6
32:13 39:10 40:18
47:20 48:9 49:12
49:23 55:25 58:10
58:12,13,15 599.
59:13,23 60:11,12
60:15 62:5,9,18
62:2165:13 66:18
66:19,2167:19
68:22,24 72:8
73:16 74:19 75:20
75:25 76:12,20,23
77:13,20,25 78:3
78:4,19 79:20,21
79:24 80:2 82;21
82:22 ?5 83:2
84:1,7,12 85:22
86:6,10 87:7,9
88:16,20 89:25
90:1,2,14,25 94:2
94:19 96:2 98:3
98:25101:7,10,11
101:22 102:23
104:2,9 10524
106:18,24 109:8
109:14,16,19
110:5 113:12
114:9 118:8119:1
120:10,23 121:6
121:16,22 125:4
127:12 129:16,17
132:21 133:4
134:21 138:9,10
138:12 139:15
141:23 142:10,20
142:22 143:10
recording 19:15
144:15,18 146:16
records 19:24
149:4,7,21 151:17
73:17,18 74:19
151:251523
75:22 77:13,16
156:14,24 157:11
82:2 107:3 162:1
160:6,8,10,14
162:12176:20
161:9 163:17
177:23
165:3 169:21
RECROSS 3:3
170:11,18 171:15
rectangular 156:23
172:7,10,13
157:4
173:23 177:10
recurrent 17520
recategorization
REDIRECT3:3
159:20
refer 86:25
recategorized
reference 42:19,21
157:12 159:10,16
64:2 95:19 123:12
receive 47:4.13
137:23 153:11
85:7107:10
referenced 83:4
12424 152:3
142:24 153:12
received 93:22
155:7,10 175:19
118:11 126:12
references 68.4
receives 57:3
referencing 9:7
receiving 126:11
149:23
149:5
referred 17:3
recess 97:19 151:7
101:20 123:6
177:20
124:18172:17
recognize 67:7,14
referring 19:9
67:1768:7,10,12
51:2252:2109:13
129:18 130:1
109:25
recognized 148:14
reflect 85:24
recognizing 73:7
refresh 96:3 98:5
recollection 77:6
101:2,5 109:11
89.22122:17
160:12
126:10 133:8
refreshes 144:11
141:9,20143:5
refreshing46:24
14922,25
refuses 112:15
recommendation
regard 26:13 3923
139:12,13
48:7,2176:8,18
recommendations
76:2183:25 95:23
117:2
161:10,23
record 4:2112:9
regarding37:10
14:719:16 23:5
90:19,2193;3,4
24:8 27:17 47:12
142:25
61:25 7624 77.23
regards 79:7
78:20 89:3 113:24
registered 109:23
117:12138:25
111:1,8
164:1217622
registering 111:3
177:22
registration 109.24
Florida Court Reporting
561-689-0999
111:10
registrations 17.21
110:12
regularly 173:1
regulations 20:14
reject 150:2
rejected 150:1
156:25 157:2,9
rejection 117:4
relate 118:24
related 132 131:4
134:14 149:24
174:8 176:19
relates 13:4 16:8
17:8 55:12 86:2
94:14 95:7,10,19
97:3 10723
110:11 117:8
relation 81:7
relationship 7:17
12:13 13:13 35:11
35:22 46:14 7I:4
103:4,6
relative 180:13
relay 107:13
relevance 95:6
relevant 30:16,25
174:10 176:7
rely 74:25 112:14
remain 88:15
remained 88:8
remains 22:3
remedial 123:18
remediation 56:7
59:1
remedy 110:21
remember 11:19
24:13,15,16 26:3
26:6 37:8 40:2
62:11,13,16 63:19
67:21 69:7 80:6
84:5 96:4,7 97:25
98:7,10 101:25
113:16,18 120:17
121:2 124:21
133:5 134:7
138:14 142:15
143:13 144:I,2,11
145:2.3,3,4,7
149:5,17 156:13
162:4,5 169:15,16
171:1173:11,14
remembrance
151:17
remove 84:24
85:24 86:15
101:12 148:12
removed 85:11,19
86:1188:7,14
146:17,18,23
163:19
repaint 117:15
repeat 1223 21:8
22:8 48:11 95:14
repeatedly 96:16
report 18:2219:12
19:14 47:9,18
127:8,17 134:25
135:25 136:5
137:20 139:8
141:10 151:24
152:5,7 159:5,23
180:7
reported 1:18
61:17 107:4 145:4
reporter 4:4 27:18
178:3 180:5,17
reporter's 132:7
reporting 1:19
107:3 145:16
181:18
reports 48:6,18,20
107:1110:12
152:3
repository 82.2
represent 39:1
representation
2322
representative
133:21137:13
representing 24:20
reproduction
180:16
reputation 70:2,16
request 35:23 36:8
39:19,22 83:24
84:8 85:20 86:13
87:3 134:4 137:3
137:17
requested 135:8
requests 39:23 40:1
86:2
require 33:22
54:14,16,18
147:24 148:2
150:22 158:12
required 9:12 25:8
38:17 5824 59:1
125:2,5 126:23
135:23 138:20
171:10
requirement 107:3
111:1
requirements
38:16 170:8
171:19
requires 19:I9
116:19
reserved 22:13
resident 40:8 54:10
54:17 56:22 57:5
57:21 58:19 140:4
140:20 167:4
170:24
residents 13:4
15:21 83:8 87:23
96:1 129:14
139:19 167:9,14
172:4
resources 49:24
50:13,14,14,19,21
51:8
respect 65:19,24
107:24
respectfully 177:24
respond 92:20,22
responded 134:4
148:14
response 27:11
141:12
responsibilities
9:25 16:1143:11
responsibility 11:7
44:12 51:7,20
88:5 100:7
responsible 9:19,2(
10:3 14:24 21:2
30:2,13 32:3 39:1
80:16 81:5 82:7
85:15,16171:17
172:1
responsive 111: 18
rest 998
restraints 51:6
94:12
restricted 1082
restrictive 154:12
result 161:10,18
resumes 1382
retaining 98:5,8,13
retaliated 30:24
retaliation 3022
retired 6:7
retirement 6:4
return 181:11,14
review 11:2414:2
23:25 24:3,10
52:2 75.22 80:18
89:14,16 117A
135:13 140:20
142:4,8 1482
150:17,23,25
154:4
reviewed 23:12,19
23:20,2189:15
117.3
revision 133:22,24
135:8,9 137:14,17
:ich 102:1
UCO 177:23
-id 99:12
-fight 11:19 12:22
15:22 16:2 19:18
27:7 28:17 34:11
35:19 39:24 41:16
41:25 42:16 46:1
48:453:7,13 54:3
54:17 57:2161:5
61:24 66:10 69:2
70:14 71:3 72:22
75:6,23 76:2,5
78:22 81:14 84:3
89:2190:25 92:1 i
93:4 95:1196:22
98:17102:18,25
104:13,18 105:8
107:21 108:1,14
109:5 110:8,9
111:20 115:16
11724 118:16,21
120:3 123:25
126:5 127:14,17
127:21 130:14
131:8 135:24
139:9,15 143:16
151:2,9 152:11
156:12 159:17
162:2166:11
167:6,17,23
171:24 172:3
right -of -Kray 74:18
74:22,24 75:18
145:5,5,23,23,25
146:5,2414721
148:4,8,24 177:1
177:9,13
ring 172:15
rip 98:14
Rita 18:8 42:15,17
4324 142:2,6
174.25,25 175:6
RMR 1:18179:16
180:22 181:17
road 1:14 2:7,11
41:7 64:8 66:16
98:8,18 146:2,9
146:10
•oads 99:8
2obert2321 22
2oeder2:7 103:19
132:20,25133:1,5
133:9 139:5,20
140:8 141:9,15,18
142:24 143:6,21
148:9
Florida Court Reporting
561-689-0999
200
Roeder's 141:12
role 6:13 7:11
roles 11:5
roof 114:25 119:12
131:18,22 132:8
132:19 133:2,6,14
133:17,19,21,23
133:25 134:5,13
134:15,19,23,24
135:11,11,12,15
135:15,17 136:23
137:4,14,18
139:17 140:22,24
140:24 141:16
157:19
roofs 134:8
rough 116:24 146:4
157:17
routes 157:24
royal 102:10
ruled 163:6
ruling 162:11
running 48:24
S 3:8 4:1 183:1
safety 13:3 15:21
sat 8:21 79:10,11
satire 68:8
save 12:12
saw 20:16 53:5
71:9 73:13,14
74:3,5 114:6,7,20
114.21,22 115:4
120:12 151:23
170:10
raying 23:20 42:7
56:19 75:2 101:25
102:3 106:14
109:17 119:13
127:12 132:11
134:7 138:9
139:15 143:11
147:4 173:21
ays 92:14 101:6
126:8 147:11,20
168:21,23 170:16
school 83:1,4,14,1
88:8,14,21
scope40:14
Scott 6:4 7:12
scuttlebutt 107:7
Sea 1:14
seal 136:7 179:10
seasonal 165:14,19
second 23: 15,23
66:8,9 76:7 113:4
141:4154:10
160:4177:16
seconds 35:18
section 64:7,10
93:12115:I2
149:23 154:12
155:18 162:8,14
sections 81:23
92:11122:15
see 21:9,10 25:19
35:1437:22 54:24
64:10,14,19 66:22
73:9,10 82:15
87:13 93:5,15
95:6,25100:20
114:19,23 115:16
119:9120:14
121:4123:2
132:14 145:9
151:22
seeing 96:4113:16
113:18120:17
137:19
seek 53:1 57:20
59:5 60:22 76:8
83:18,18 87:2
seeking 57:25
59:10
seen 65:10,11,14
66:10147:15
152:1157:3 165:8
166:14 175:5
sell 65:21
semantics 44:25
168:5
send 34:7 36:6 37:5
51:25 52:5,9,11
9 56:10 57:4 58:4,7
58:15,18,25 90:22
9I:5,6,23 118:16
118:19 147:3
161:15 174:18
sending 53:22
58:12
sends 92:2 93:11,12
sent 36:11,12 52:25
58:11 116:9
separate 18:1
September I09:7
Sergeant 145:13,15
146:21,22
serious 104:12
126:8
serve 42:3
service 123:2
set23:2,8 29:19,19
31:13 53:16 99:22
180:10,11
sets 22:19 29:13
31:15
severe 121:18
sexual 31:24 32:1
sheet 154:3,17
155:5 181:9,10,11
182:9 183:19
shelters 15:23
shoes 31:1
shorthand 180:8
shortly 126:11
show 30:10 69:9
136:13 154:10
showing 30:14
73:24
shows 174:21
shut 113:6121:19
167:21
sick 10:11
side 115:14
sign 25:12 65:8
71:23 72:3,7,10
74:10 75:18,18
77:9,10 94:6,15
94:2195:3,7,16
95:23 164:19,22
181:11,12,14
signature 174:19
174:19 181:14,21
183:25
signed 124:10
183:19
significance 57:2
significant 108:13
109:3 136:19,20
158:4
signing 181:7
signs 65:10,11,15
65:18 66:11 70:18
72:10 73:13,15
74:5,18,22,23
silly 148:13
similar 70:8,13,14
148:10
simple 75:8 81:24
157:16
simplify 35:16
61:11
simply 111:6,15
Sincerely I81:15
single 132:11
single -page 136:1
singular 27:10
sit25:25 121:3
site 86:23 104:17
105:12 I16:20
117:5 118:19
147:8 148:2
situation 105:12
121:19
six-month 76:4
Skip 78:5
smacked 81:12
sma1163:19
smooth 116:24
156:24,24 157:1,1
157:5,18 158:23
sockets 14:8 17:6
soft 157:18
Solei140:20 65:15
65:16 99:1,4,11
99:12,18 100:6,10
105.21120:3
201
122:19149:9
76:2,5102:7
154:1 157:10
113:9
160:15 163:25
south 2:1141:2,9
somebody 14:23
41:12
19:23 20:1621:13
SOUTHERN 1:1
21:14,22,25 43:21
Spanish 156:4
49:20 53:2 58:25
157:13 158:8,10
59:12 74:9 80:13
Sparkling 2:7
102:15 105:10
speak 60:3 69:9
111:19,23 112:11
73:18 76:24 77:14
112:15114:13
151:20162:1,12
118:22,24 124:15
166:17,19 167:1,3
124:17132:25
167:10
148:1,12151:20
speaking 8:1616:1
170:16
22:1179.22 93:18
somebody's48:23
98:24110:10
129:20
118:8
somewhat 68:14
speaks 164:25
108:2
166:23,24
sorry 5:22 8:6 9:10
special53:16,19
10:20 13:13 14:13
54:6 73:16 77:6
19:2,1020:4
77:18,1979:5
22:13,24 27:4
161:24,25 162:11
31:14 32:14,15
164:23
37:23 43:8 45:21
species 145:7,19
46:23 60:8 63:4
specific 422 58:13
63,20 64:23 66:6
69:10 88:5 97:15
67:8 81:3 87:15
104:15 115:21
90:19 95:24 99:25
specifically 26:4
101:4105:1,18
44:4 59:11125:6
112:4 113:5
specifics 105:24
119:11 126:6
109:13
131:21136:3,20
spectrum 79:16
152:16 153:11
speech 68:15 169:5
156:14 164:23
spirited 68:11
167:5 173:6
spoke 116:11
174:19 175:16
spoken 52:23
sort 18:1619:5
165:11
40:25112:22
spot 40:22
115:10 124:3
staff29:23 73:8
126:7128:15
76:9,14 99:15
130:6 145:7150:9
139:8
157:23
stage 165:6
sought 60:2161:5
staggering 171:7,8
125:11174:13
171:23
177:7
stand 34:2136:22
sound 26:1169:2
59:21
Florida Court Reporting
561-669-0999
standard 59:8
139:18 140:6
152:4
staple 100:24
Star 172:24
start 44:6 97:7,24
129:20 131:24
132:13 157:22
started 7:2 57:13
166:20
state 4:5,20 62:6
96:21107:2 170:4
179:2,17 180:2,5
182:3
stated 61:22 89:19
108:12 137:17
statement 69:5
109:2134:11
143:18
statements 133:9
172:11173:21
182:7
States 1:1 175:15
stating 93:6 165:23
stationery 174:18
stealing 106:21,22
Stearns 2:14 4:17
4:17 8:9 16:14,18
20:19 22:24 23:4
23:15 24:7,13,23
25:7,13 26:14
27:16,20 28:8,14
28:18,23 29:4,8
30:15,19 31:10
34:24 35:139:18
42:23 43:144:25
45:18 48:14 49:11
50:12,16 57:16
63:2,6 65:17 69:8
69:13,21,23 70:4
70:7,20 71:12,24
72:12,16,19,23
73:24 74:6,11
75:3,8 77:2,12
78:16 80:7 86:16
88:1192:18 93:14
93:2194:23 95:5
97:2,12 101:3,16
102:20 105:3
107:8 112:25
118:7 122:5,9
125:10 128:7
129:11,21130:2
130:11,13,19
131:2 132:8,11,15
134:12136:24
137:8,11 138:22
144:7 146:13
148:18,20 149:12
154:11 159:15
161:2 162:22
163:2,5 165.21
167:16,20168:8
169:10 174:2,7
176:7,19,23
177:18,23 178:1
181:2
Stearns a jambg....
2:17
steel 137:6
stenotype 180:7
step 53:14 132:12
132:12
steps 171:13
Steve 13:8 104:3
Sticking 12.4
stop 103:25 104:1,5
104:7,13,16,20,20
111:12,24 113:7
119:19 121:7,21
122:7,9.20 126:22
127:1,19 I74:11
straight 37:7
Stream 1:7,14,15
4:24 5:11,16 6:1
10:23 12:5 13:1
13:18,21 14:1,19
15:4,9 20:5,8
21:24 25:6 33:3
36:3 40:24 41:1,3
41:5,7 43:3,10
82:23 83:1,3,4
85:6 89:5 98:19
98:23 99:6109:4
111:4 116:20
128:5 134:8
152:21,24 153:4,8
153:20 154:5,14
155:4,18 156:20
157:3 I59:4 170:7
170.21 181:5
183:2
Street2:4
strike 9:4 27:19
48:11 50:2 54:22
55:11 87:20
strive 40:21
strongly -worded
51:17
structural 17:6
119:10 136:7
structurally -in fi r...
134:18
structure 134:15
159:12
stuck 163:7
Studios 84:14,18
84:19 85:8
stuff 107:15,16
148:12
style 152:23 153:11
153:21 154:5,19
155:21 156:2,21
157:4,6,10,13
158:14,15,24
160:1,5
styles 153:7 155:24
styling 154:22
155:19
stylings 152:18,20
subject 14:4 82:12
183:2I
submit 132:8,15
133:16
submitted 135:5
172:5
submitting 133:13
15614
iubsequent]15:19
125:1 126:7 147:3
163:21,23
substance 183:21
substantial 93:19
substantiated
127:10
sued 24:18 25:17
suf icient50:25
96:18
suggestions 89:17
Suite 1:19 2:I5
181:3,18
summarized 144:7
Sunrise 2:15 181:3
supervise 43:15
44:1,9,1155:25
Supervisor 170:3,6
supervisory 55:19
supplement 159:8
support 134:23
suppose 166•:3
supposed 161:21
sure 12.24 16:13
17:5 21:9 24:23
27:130:6 34:5
35:17 41:19 43:20
45:3 47:15 50:3
51:13 53:1154:24
56:10 57:1,12
59:1160:16 66:5
67:4 74:13 77:23
78:3 80:10 82:6,6
83:17 89:23,23,23
91:13 93:16 95:15
97:198:18 99:2
100:2 101:7
102:21 103:16,17
105:25 106:I9,21
107:15 112:1
113:2,9 115:7
116:21 117:10
119:20 123:11
128:10 131:6
134:4,6 136:25
139:10 146:12
154:10 155:3,14
155:17 160:13
163:20,24 164:10
165:5 169:6 170:4
Florida Court Reporting
561-689-0999
202
173:15,20 181:11
surface 116:24
157:17,17
surprise 98:12,15
102:6 138:18,23
159:1
surprised 139:3
surrounds 104:19
survey 155:2
suspect42:11
128:10,11 175:6
suspected 47:18
50:6 54:14
Sutton 104:19
sworn 4:9 33:2
38:15 46:7179:8
180:6
system 174:21
_ T
T3:8 180:1,1 182:1
182:1 183:I,1
T -e ,vv 17:23
table 143:12,12,13
167:24
take 57:22 66:17,20
68:18 87:14 96:10
96:11 97:18 101:6
122:6,6 132:12
134:2 149:2 151:5
160.4161:1,9
168:18 170:20
176:13 177:16,17
177:24
taken 4:3 72:6
97:19 121:21
123:18 151:7
157:25 164:3
168:12,16 177:20
180:10 181:6
183:5
takes 110:24
!alk 19:20 24:24
37:4 48:5 52:1
76:19 97:14102:9
102:12,15 113:10
144:17
talked26,21 37:14
102:16 168:18
talking 21:4,7
45:18 47:12 48:24
50:12,15,22,24
51:163:2 66:6
78:1179:25 80:24
82:1,3 93.5,11
120:2131:10
145:15163:2
171:22
talks 103:1147:14
147.17162:25
task 39:3
tasks 16:6 44:3
taste 71:1
Taylor 17:2218:7
I9:8 39:12 42:15
142.',6 174:25
Technically 38:24
technique 146:6
tedious 54-.5
telephone 2:5,8,16
9:4 62:14 145:16
telephones 9:3,7
tell 8:13 13:10,23
18:10,15 35:10,12
49,1050:22 55:14
56:7,14 62:22
74:2175:7,13
81:9 92:12 103:2
103:13,15 112:12
118:15 135:2
137:7141:2,22
142:6143:3
144:11 145:24
165:22 167:19
telling 803 101:11
139:15 I51.12
ten 59:12 169:11
tenure 157:25
166:13
term 28:9,11,11,15
112:6,7 115:10
160:19
terminated 6:7
terminology 112:1
terms 6:18 12:14
28:8 37,24 41:23
56:8 171:728
Terrence3:11
testified 4:10
testify 180:7
testifying 141:15
testimony 109:12
Tew 17:19,23,25
18:4
Thank 25:2 29:11
112:5,8 151:6
178:1
Thanks 116:18
thievery 106:19,22
thing 24:5 25:8
27:7 38:17 52:18
65:173:4 106:18
141:7 157:23
174:5
things 11:22 29:24
30:25 35:12 64:24
67:21 69;11 70:3
79:4,20 82:8
91:15 106:21
107:16,18 111:21
117:10 140:17
148:8 155:23
168:9,13
think 15:20 19:19
19:2223:21 24:10
41:19 46:7 48:2
51:6,19,19 55:17
59:3 60:5 61:2,4
63:12 64:2,18,22
65:167:23 70:14
74:17 75:13,15
77:19 79:18 85:22
87:11 88:18 89:16
91:8 92:14 94:14
98:9 99:13,25
101:20 102:16,19
103:20,22,23
104:3,19 107:2
109:12 111:6,22
112:22 114:5
115:3,1822
116:19 1I7:24
119:11,11,20
120:11 121:13
122:5 124:5,8,23
127:10 129:25
130:3 132:24,24
138:12 139:5
140:16 142:23,25
143:11 144.24
146:1 147:13,17
148:22 150:3,4
151:15 152:2
157.15 158:1
161:6,12 163:20
166:13 172:1
176:17
thinking 85:5
119:23
thinks 28:16
third 23:16
thought 73:6 75:9
75:12,14 83:7
121:11 141:23
thoughts 141:4
Thrasher 1.-113:4
4:8,18,22 23:1
28:2131:6 97:21
122:13 124:13
151:9159:19
179:7181:2,23
182:I9 183:4
three 653 93:20
105:22,25 106:7
117:1 136:24
147:18 151:1
152:17,20 157:22
158:2
three-dimensional
65:5 67:8
through-and-thr...
133:18
throw 143:12,12
thrown 105:15
tile 117:20 133:19
133:25 134:24
Tiling 117:17
time 18:10 23:9
30:14,2131-2,4
33:25 34:4 36:24
37:22 42:11,11
51:6,18,2153:5
54:8 59:1,4 60:14
62:16,19 63:9,12
66:4 74:14 75:23
79:21 80:2,22,22
80:22,22 82:4
84:21,22 94:11
98:1103:18
122:16 149:20
151:23 154:18
155:1 157:8 163:9
163:12 166:18
180:10 181:12
timelines 59:6
times 10:12111:6
121:10 167:23
169:11
tips 48:17,20
tired 81:18
title 6:614:16
167:12
titles 11:12,13
Tobias 13:814:13
15:1 104:4119:19
119:20 126:15,18
126:21,25 127:8
127:17,18,21
Tobias' 14:13 17:3
told 26:16 29:23
31:15 37:19 39:8
68:25 75:6,11
76:1,4 78:14
79:23 80:13 87:4
89:7 99.4,14
109:9 142:2
159:15 163:6
165:18 168:2
top 42:16,17
totally 156:24
touch 21:15
town 1:7,14,14 4:23
4:25 5:5,7,9,11,13
5:16,21,24,24 6:1
6:3,6,7 7:9,13,13
Florida Court Reporting
561-689-0999
203
7:25 8:1,11,12,14
8:17 9:13,25 10:1
10:7,18,22 11:3,6
11:6,7,12 12:2,5
I2:25 13:18,21,25
14:18 15:3,8,14
16:19 17:15 18:2
18:6 20:4,8,17
22:12,13,19 24:18
25:1,6,1726:13
29:13,21,23,23
30:13 32.9 33:18
33:23 36:2 39:12
41:6,9,10 42:8,16
43:2,10 44:2
46:1147:11,12,15
47:19,2149:3
51:3 53:22 55:3
55:18 57:2 60:6
61.,2167:22 69:20
70:2,3,8,13,19
71:4 76:9,13,22
79:22,22 83:12
84:9,13 85:6,14
87.24 89:1191:10
92.13 98:19,22
99:11,13 103:18
106:4,6,11 108:7
108:13,14109:3
111:2,4 115:19,20
115:241I6.10,15
118:22 122:15
123:4 124:1,13
127:6 128:5
130:17 131:23
132:19 133:2
134:17138.11,14
138:18,21139:13
141:3 142:2,6,16
142:18 144:13,16
144:17 148:4
153:12,25 155:1
157:25 162:14,18
164:19 165:8,23
168:16 170:7,24
171:16,18 172:4
172:19 173:4
174:1,6,18,20,25
175:12,21 176:13
176:14 181:5
183:2
town's 12:9 80:16
83:585:21 86:13
88:24 142:3,7
145:23 146:23
148:4 176:25
177:9
towns46:20
trained 46:21
training 6:24 45:6
45:1646:14,17
130:6,12 175:20
I75:21,25 176:2,3
176:4,5,8,13
trait 70:15
traits 70:16
transcended
104:2: 105:2
transcript 138:24
180:15 181:6,7,8
181:10 183:6
transcription 180:8
transition 6:5
transpired 85:2
104:23
treat 92:16,19
tree 148:1
trees 144:24,25
145:22 146:17,19
146:23 147:21
trick 12:18
Tried 150:5
trigger143:17
trimming 117:22
117:23
triple 106:17
true 8 1: 15 92:23
162:25 180:8
182:7 183:21
truth 180:7
try 52:15 79:6
100:24 132:10
176:3
trying 8:7 43:5
55:25 56:22 115:
160:22 167:21
turned 84:8,I1
118:15
twice 66:13
Twittering 152:I3
two 5:15 28:13
56:12 59:18 93:1!
120:9,20 139:21
147:18 148:1,10
150:2 157:21
162:15
two-by-fours 119:9
119:22
two-dimensional
65:6
two-month 76:2
type 14:9 44:4
73:14 96:20 119:4
119:5,6,16 125:4
126:23 128:20
129:2 133:12
145:19 147:23
176:5
types 9:15 31:17
42:12 106:16
176:4
typically 49:13
90:7,10,12 104:22
107:10 109:21
139:18 147:25
150:15
typing 82:7 124:14
Uh-huh 34:1 102:4
iltimate 126:5
iltimately 10:3
82:13
enable 22:21
tnclear 92:8
mcomfortable
150:9
mdersigned 179:6
mderstand 8:7,15
8:19 13:19,24
14:8 15:6,1120:7
27:24 31:22 37:1:
43:5 49:5 56:9
57:8,1659:16
89:4 93:13 94:3
97:21 108:8 115:
140:9 173:16
174:12
understanding
14:12 22:5 39:5
54:1194:7 108:9
understood 12:21
19:3 91:21149:1(
underway 122:25
unilaterally 135:14
United 1:1 175:15
unknown 63:14
unlawfu130:20
unofficially 177:8
unquote 10:2
uphold 139:13
upset 71:10 143:11
143:16 144:4,5
167:25 168:1,4
Urban 84:17
use25:22 38:15
50:8,2L 67:23
105:18
user 65:3 81:19 20
usually 47:6 59:5
59:12,18 92:3
110:7,8,23 111:5
111:18,21 123:5,8
137:21 152:9
166:17,23
- v
v 1:6
vacation 10:9,11
vaguely 160:11
169:16
eariance 138:19
139:16,21 140:1,9
140:11,17
Paried 176:10,10
Paries 52:22
carious 39:4 40:7
82:9 152:21 153:6
154:2,4,23,25
156:7 157:15
158:7
vary 52:22 59:3
verba140:3 62:9,11
62:13 85:187:11
121:12 152:11
verification 40:3
44:20
verify 19:24 44:14
version 23:15
versions 23:18
versus 27:10
vice 4:15 24:22
videotaped 1:11
view 64:8 159:6
163:18
violate 91:15
violated 72:10
violates 21:22,25
violating 42:7
violation 3:14 35:9
40:4,6,10 47:7
49:7,20 50:6 51:1
52:7,10,17 53:15
56:1157:25 61:22
62:4,6 71:19,23
72:4 75:9 91:2,19
92:3,24,24 95?
122:18,23,24
123:16 128:11
violations 41:17
42:146:9 51:16
54:14 58:7 61:17
79:23,25 80:3
92:10
viscerally 168:5
visited 137:15
Voluntarily 58:1
volunteer 38:19
+olunteering
167:16,19,20
,s 181:5 183:2
N 1:18 4:3 179:16
180:5,22181:17
Florida Court Reporting
561-609-0999
204
wait 35;4 132:16
waiting 19:5
waive 103:2 181:13
181:21
waived 75:7 134 25
Wal-Mart 105:20
walk 129:19
walked 128:13
wall 14:8 98:5,8,13
101:12,20
walls 114:25
want 24:23 28:19
36:23 37:7 45:23
51:2,23 54:3,6
61:8 67:169:9
72:15 75:9 80:10
90:17 97:14
106:13 107:17
115:23 116:7
141:17,18 164:18
167:6 168:4
176:21 178:2
wanted 19:3 23:4
65:22 102:21
126:21 137:18
169:21 170:22
177:21,22
wanting 148:1
157:16 168:18
wants 69:14 77:3
92:13 133:23
135:10,12 139:16
141:13 166:4
174:12
Ward 2:20 34:8,15
35:23 36:2,5,8
37:8,16,17,18,23
37:24 41:2147:3
55:13,19 56:1
103:22 107:11,20
112:17 I43:20,23
Vard's 44:12
varning 111:7
varrant128:19
vasn't 9:134:3
68:15 86.23 91:4
118:22 127:16
142:13 172:4
waste31:3
wasting 163:8
Water 6:17
way 12:18 29:24
36:140:23 45:17
53:24 55:18 56:12
70:3,3 83:13 89:3
93:3 97:16 98:18
106:3 125:7
141:21142:11
151:23 173:3
175:12 177:19
we'll 36:159:25
70:12 98:16
100:24154:10
172:20
we're 41:5 57:22
75:1279:21 80:24
93:10101:15
120:2126:8
14013
we've 82:10 97.2
106:23
wear 11:3 31:2
website 80:17 81:6
81:8,23 82:18
83:5,25 84:2,6,20
84:25 85:20,21
86:2,13 87:14,23
87:24 88:9,24
89:13,20
Wednesday 1:12
week 4021
weigh 87:16
weight 56:24
134:23
welfare 13:415:21
went 77:19 96:1
11223,24 113.6
141:24147:2
161:24
weren't 91:6
west 110 99:5,7
113:21,22 114:4,7
114:18115:4,11
148:11181:19
westerly 115:6
western 119:21
12025
whatsoever 23:3
109:3
wheelchair 173:12
white 133:18,25
William 1:1] 3.4
4:8,17,22 179:7
181:2,23 182:19
183:4
Willie 104:19
window 149:15,18
151:13
windows 131:5
149:24 150:12
151:10
wish 181:9,13
withdraw 77:1,5
withdrawal 23:22
withdrawn 77:7,11
77:24 78:2
withheld 164:24
165:2
witness 3:3 4:11
20:20 23:6 25:2
27:19,2129:7
34:25 39:19 43:2
44:8 49:12 50:14
50:19 63:8 65:19
69:22,25 70:5,22
7125 72:17,20
73:174:7,12
77:13 78:17 80:8
86:17 92:19 93:15
93:22 94:24 95:6
101:5 102:23
105:4 107:9112:7
113:1 118:8
125:11 128:8
129:22130:3,20
131:3 132:10,14
134:13 137:10,I2
138:23 146:14
148:19,21 151:6
154:12 159:21
161:3 162:23
16522 167:17,21
168:10 169:12
174:3 176:10
178:6179:10
180:6
witnessed 48:19
wonder 173:22
wondering 98:2
Woolbright 40:25
word 27:10 28:12
28:2129:2 50:14
50:21 57:1,8,16
67:23 70:14 78:18
105:15,18 122:6
142:9 159:22
172:14
words 25:19,22
26:4,10,12 87:8
115:14
work 5:16 6:9
12:10 17:2018:25
24:7 30:2131:2
36:23 40:14,22,23
43:18 56:3 71:17
71:18 73:7103:25
104:1,5,8,13,16
104:20,23,24
111:2,8,11,12
113:7116:12,14
116:16 117:8
118:4 119:4,5,6
119:16,19121:7
121:20 122:7,9,20
126:22,23 127:1
127:10,19 148:22
workable 7:7
worked 33:16
51:15 133:1 138:3
workers 109:9,17
109:23
working 7:3 45:22
46:5104:20
111:21
works 13:15,17
14:22 128:24
worse 123:21,22
wouldn't 44:22,23
78:11 96:11 166:6
Wow 81:12
write 124;15 183:6
writes 82:1
writing 129:20
written 133:11,22
wrong 10:2 15:14
79:9 129:18 130:1
130:14 136:21
141:20 145:19
wrote 160:14
X3:1,8
X,Y 56:19
yard 114:4,6
119:25 120:1
129:9 163:18
yeah 66:4 79:17
81:3 106:15 107:9
115:13 116:3
120:1 138:3 161:3
166:3
year 172:20
years 5:2,15 32:12
60:18 105:22,25
106:7
Z56:19
zoning 13:619:9,13
19:13 222,6,9
47:24 48:7117:5
1180.8
1-7 164:10
1-8 164:10
1115119179:17
101:12 110:9
10-28-13 3:14
10:52 1:13
1001:14 3:13
10002:15 181:3
Florida Court Reporting
561-689-0999
205
10012:4
10th 179:8
1103941:21 181:2
12181:1
12-14-113:11
122 3:14
12th 179:10 180:19
136 3:11
14173:7
15-195:19
159062:4
159892 179:18
178180:8
193:11 136:11,14
138.20
19967:8
1999153:7 154:6
159:16
__ 2 _
203:12 73:21,22
2000 5:3
20015:3
2002 98:5 10120
101,23
2006101:21
2008 34:5
201140:15 45:15
45:17,18 108:11
109:7 112:22
122:7 133:17
135:8 137:14
144:23,24 149:3,6
159:17
2012149:16 160:10
2013170:23
2014 169:18 173:7
20151:12 179:8,11
I80:19 181:1
182:13
213:13 100:21,22
21611:19 181:I8
223:14 114:11
121:24 122:1
24552:15 181:3
251665:15 120:6
120.24 122:19
149:11
9
252065:15120:3
9:13 -CV -81053-...
120:25 I22:25
1:2
149:8 154:1 157:9
90 18:14
26 96:1
92 6:22
28 112:22 122:7
954-463-0100 2:16
123:1149:3,6
966:2
28th 123:3
3:33 1:13
30 35:18
302 1:19 181:18
32 162:25
3272 2:11
32819 2:8
33304 2:16 181:4
334001:20
33409181:19
33480-99912:11
334831:15
4 _
4 3:5
4012:11
407-758-4194 2:8
561 181:19
561)689-09991:20
6
6-10-15181:7
183:5
66 47:18,2148:8,21
689-0999181:19
70 47:18 48:1,2,8
48:2164:4,5
152:17 153:15
154:9 155:12,13
162:9,25
73 3:12
7414 2:7
814-535-5175 2:5
Florida Court Reporting
561-689-0999
PASIN