HomeMy Public PortalAboutCG Acquisition Hearing (7123) 06/16/15PROCEEDINGS June 16, 2015
CG ACQUISITION vs. TOWN OF GULFSTREAM 1
PROCEEDINGS June 16, 2015
CG ACQUISITION vs. TOWN OF GULFSTREAM 2
1 APPEARANCES OF COUNSEL
2
3 On behalf of the Plaintiff:
4 JONATHAN O'BOYLE, P.C.
BY: NICKALAUS TAYLOR, ESQ.
5 and GIOVANI MESA, ESQ.
1286 N. Newport Center Drive
6 Deerfield Beach, FL 33442
954-834-2209
7 ntaylor@oboylelawfirm.com
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On behalf of the Defendant:
9
JONES, FOSTER, JOHNSTON & STUBBS, P.A.
10 BY: JOANNE O'CONNOR, ATTORNEY-AT-LAW
505 S. Flagler Drive
11 Suite 1100
West Palm Beach, FL 33401
12 561-659-3000
joconnor@jonesfoster.com
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PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
3
1 Proceedings in the Matter of CG ACQUISITION COMPANY,
2 INC. vs. THE TOWN OF GULFSTREAM.
3 June 16, 2015
N
5 THE COURT: We are here on CG Acquisition
6 Company vs. The Town of Gulfstream, Plaintiff's
7 Motion for Protective Order. I received the
8 Plaintiff's motion and attached documents, I
9 received the Defendant's response with attached
10 case law.
11 I'll start with appearances of counsel,
12 please, first for the Plaintiff.
13 MR. TAYLOR: Yes, Your Honor. Nick Taylor
14 appearing for CG Acquisition.
15 THE COURT: Thank you.
16 MS. O'CONNOR: Joanne O'Connor for The
17 Town of Gulfstream.
18 THE COURT: Thank you.
19 Mr. Taylor, I have read your motion and
20 your attachments and your supporting authority
21 that I think came separately. What else do you
22 want to tell me about your motion?
23 MR. TAYLOR: Yes, Your Honor. What we
24 have here is essentially a simple public records
25 request case. We have filed a motion for
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PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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1 protective order because the Defendant seeks to
2 depose the corporate representative of CG
3 Acquisition. The reason we filed this motion
4 for protective order is really simple, it's a
5 simple public records case.
6 Prior, Your Honor, I was here on a motion
7 for protective order I believe back in
8 September; similar cases, similar circumstances
9 for the same protective order. You did actually
10 deny that protective order and opposing counsel
11 is likely going to try to draw comparison with
12 the protective order that my client filed today.
13 The situations could not be anymore
14 different, and they're different because of
15 this: The deposition that was taken as a result
16 of that order happened September 15, 2014, that
17 deposition lasted eight hours, eight whole hours
18 of the deposition of Martin O'Boyle. Out of
19 that eight hours there was no more than 15
20 minutes of that deposition that actually
21 pertained to the facts of the public records
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request, the rest of it was simply a fishing
expedition looking for anything possible to
prolong the deposition and, quite frankly,
harass my client.
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PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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1 In this case we have a different scenario.
2 In this case it is a corporate representative
3 and they're seeking to depose the actual
4 corporate representative of the client. Case
5 law is clear --
6 THE COURT: Who is the corporate
7 representative?
8 MR. TAYLOR: One has not been designated
9 as of yet and likely will be, and which I don't
10 want to make an absolute assertion, but likely
11 William Ring, who I believe is vice-president of
12 the company, if I'm not mistaken.
13 THE COURT: Even now I think in your
14 responses they would be entitled to inquire into
15 two of the main areas listed.
16 MR. TAYLOR: Absolutely.
17 THE COURT: Is there any reason you
18 haven't designated the corporate representative
19 for those areas?
20 MR. TAYLOR: Well, the reason, Your Honor,
21 quite frankly, is just we were actually looking
22 for a blanket protective order based on case law
23 that limits, extremely limits actually, the
24 scope of depositions or the depositions at all.
25 They're extremely --
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THE COURT: Even now that have entitlement
to deposition in those two areas?
MR. TAYLOR: Yes, Your Honor.
THE COURT: You haven't designated a
corporate representative.
MR. TAYLOR: Not as of yet.
THE COURT: Okay.
MR. TAYLOR: And I was going to say, Your
Honor, if failing a complete blanket protective
order banning all depositions and all discovery,
we would at the very least request discovery
limited to an hour -and -a -half and be limited
only to the facts that are pertaining to the
public records request in that any depositions
and any discovery not get into the actual motive
of the requestor.
As 20 years of case law, and specifically
the Gadd case, which I can provide you a copy of
if you so want to, it provides that any
depositions that pertains to the motivation of
the requestor is irrelevant. In that specific
case the actual subpoena or the notice of
deposition was quashed. Would you like a copy
of that case, Your Honor.
THE COURT: I don't need it right now.
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PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
7
1 Thank you.
2 If I understand the issues in this case,
3 however, one of the issues in this is whether or
4 not all documents were produced as to one
5 request, because my understanding is that the
6 Town said they didn't have certain documents and
7 you basically say you don't believe them; and,
8 as far as the other, it was was their response
9 timely; in other words, was the timing of the
10 response reasonable or was it delayed
11 unreasonably? Doesn't that open up the
12 discovery to a bit broader area so that the
13 Court could use to determine those issues?
14 MR. TAYLOR: Your Honor, looking at the
15 Complaint, I believe the issues of the Complaint
16 is -- You're correct, the second count of the
17 Complaint actually states that they replied that
18 there were no records available. My client
19 disagrees with that and believes he has proof
20 that that's not the case.
21 THE COURT: If they have proof, wouldn't
22 the Defendant be entitled to see what that proof
23 is before trial, before a hearing on that?
24 MR. TAYLOR: Yes, Your Honor, and --
25 THE COURT: That's one of the areas they
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PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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1 think should remain open.
2 MR. TAYLOR: Absolutely, Your Honor, and
3 the first --
4 THE COURT: What about they've suggested
5 in their response that there were hundreds of
6 public records requests made within a very short
7 period of time by what's in effect is the same
8 entity or similar entities or similar
9 identities, both individual and corporate, and
10 that affects what would be reasonable in terms
11 of the timing of their response?
12 MR. TAYLOR: Yes, and --
13 THE COURT: Wouldn't they be entitled to
14 some discovery on that as well?
15 MR. TAYLOR: Well, not in this case, Your
16 Honor, because if you look at the first count
17 that we amended, the first count the Defendant
18 essentially says they didn't produce the
19 documentation because the $1.54 copying fee was
20 not paid.
21 There's really no allegation that The Town
22 of Gulfstream didn't respond in time or that
23 they didn't do something correctly. The
24 allegation here is that they didn't produce the
25 records because the $1.54 was not paid.
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PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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1 THE COURT: So I think Ms. O'Connor in her
2 pleadings suggested if you're willing to
3 stipulate that you're waiving any argument that
4 the response was untimely, that maybe some of
5 this discovery wouldn't be necessary; are you
6 telling me you're agreeing to her stipulation?
7 MR. TAYLOR: As to the $1.54 or --
8 THE COURT: As to the claim that their
9 response was untimely.
10 MR. TAYLOR: Yes, absolutely, Your Honor,
11 there's been -- The timeliness is not the issue.
12 The issue here is -- Well, I guess timeliness is
13 the issue if it's true that they have not
14 produced the documents at all because, I mean,
15 if they haven't produced it to now obviously
16 it's not in a timely manner, but their response
17 in saying that there were no documents available
18 or no documents existed, there's been no
19 allegation that that response from Gulf Stream
20 to the Plaintiff was not timely, so --
21 THE COURT: Well, there are two issues, as
22 I understand it; one is they say they don't have
23 any so they can't produce any, you challenge
24 that and said you don't believe them; the other
25 is the timeliness of the response.
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PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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1 I asked you if you received discovery of
2 information relating to other pending claims at
3 the time or within a short time frame within the
4 time of this claim as well as a number of public
5 records requests made; wouldn't all that be
6 discoverable in terms of their raising their
7 defense and your ability to challenge that
8 defense.
9 MR. TAYLOR: But the defense that they
10 would be raising would not be valid in this case
11 because, again, my client is not questioning the
12 timeliness of the response. We're saying that,
13 "You have documentation and you haven't provided
14 it," so whether they received --
15 THE COURT: You're talking about No. 2 and
16 I'm talking about No. 1.
17 MR. TAYLOR: Okay.
18 MS. O'CONNOR: There's two counts.
19 MR. TAYLOR: Yes, I'm aware of that. No.
20 1, the first count is essentially saying that
21 they --
22 THE COURT: They didn't respond timely.
23 They say, "Oh, we responded. We told them we
24 got it and we sent them a bill, an estimate of
25 the cost, and they never responded," I don't
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CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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know whether you challenge that or not. If you
say, "We never received that," in effect it
seems to me you're saying, "They were untimely
in the response and on that basis that is just
like not giving us anything and so we should get
our fees."
MR. TAYLOR: Well, as it pertains to the
first count?
THE COURT: Yes.
MS. O'CONNOR: If I may, Judge.
THE COURT: Yes.
MS. O'CONNOR: I think the confusion Mr.
Taylor may have is that if you're looking at
your Amended Complaint, when they originally
filed the Complaint the Town's response had not
come out yet because they filed the Complaint we
submit prematurely, I mean, immediately.
Then they amended the Complaint after we
had actually responded and still pled it as an
unlawful refusal to provide any documents on
Count I when, in fact, we had responded, given
them an estimate, said, "We have 300 pages of
documents," this was back in June 2014.
THE COURT: Am I correct that your
response came about four weeks after the
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CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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1 request?
2 MS. O'CONNOR: Correct.
3 THE COURT: So I'm assuming that there's
4 an issue whether the response four weeks later
5 is or is not timely, reasonable under the
6 statute.
7 MS. O'CONNOR: We submit so.
8 THE COURT: I assume you believe it is and
9 I'm assuming it was just a factual dispute
10 whether they sent you this estimate or didn't
11 send you this estimate, and you're not saying,
12 "Well, the estimate was too late even if they
13 did send it," then maybe a lot of this stuff
14 isn't an issue because it's just a question of
15 fact did they send you the estimate or did they
16 not?
17 If you're saying, "Well, they waited four
18 weeks and there's no reasonable basis under the
19 statute to wait four weeks," then that seems to
20 me the Court needs to consider what else was
21 going on at the time.
22 MR. TAYLOR: Your Honor, I think the issue
23 now in the Amended Complaint is actually the
24 $1.54, because we're stipulating that, you know,
25 they did actually let - we're stipulating that
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PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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there was no issue regarding the timeliness with
this Amended Complaint.
What we're saying is with the $1.54 that I
guess Defendant is saying that they actually
produced the documentation and they produced the
letter stating that there was a $1.54 copying
charge, we do not have that, that was not in the
Amended Complaint. To be honest, I don't know
if it was sent. Again, I, as counsel, have not
seen it.
Now, if they did produce the documentation
and the amount has not been paid, that would be
something completely different. I think that we
would be able to take care of the first count as
it is.
If the actual $1.54 charge was not sent,
that will be an issue of fact, but at the same
time it would not have anything to do with
whether there was a timely response or not, it
would just be a question of fact as to whether
the notice of the $1.54 charge was sent or it
wasn't.
THE COURT: All right. I don't know where
it was that I saw it in your response, somewhere
you very cleverly stated the stipulations you
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PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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1 thought would eliminate some of the discovery
2 request that you're making; can you pull that up
3 and read it into the record?
4 MS. O'CONNOR: Yes, Your Honor. Your
5 Honor, I don't see it here, but as to Count I we
6 would expect in order to avoid any discovery on
7 Count I, we would need a stipulation that the
8 Town's June 25, 2014 response to the first
9 public records request was timely provided.
10 In that request we provided an estimate,
11 advised Plaintiff - I don't know how much it was
12 for, I don't have our answer in front of me, but
13 we advised that we possessed 330 pages of
14 responsive records, so we need them to stipulate
15 that the Town did, in fact, respond to the first
16 request and did so timely.
17 As to Count II, in order to avoid --
18 THE COURT: Well, before you go to Count
19 II --
20 MS. O'CONNOR: Sure.
21 THE COURT: -- can you tell me what page
22 you're reading from?
23 MS. O'CONNOR: Sure, page 4, paragraph 9,
24 and I do have the correspondence attached as
25 Exhibit B to my opposition.
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PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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1 THE COURT: Well, I can understand Mr.
2 Taylor doesn't want to stipulate that you sent
3 this and they received this notice of the cost,
4 but it seems to me the stipulation would really
5 have to say not that they are conceding they
6 received it, but they are conceding that aside
7 from that issue of whether it was sent or
6 received, they're waiving any other argument
9 that the response was unreasonable in its
10 timing; isn't that what you would have to have
11 to get you out of this discovery so you know
12 these other issues aren't really on the table
13 anymore?
14 MR. O'CONNOR: Correct.
15 THE COURT: So if we're clear on Count I,
16 if what you're telling me is that the only issue
17 as to the reasonableness of their response is
18 whether they did or did not send this cost
19 estimate to you on the date they allege they did
20 it, then all this other stuff about the number
21 of cases pending, the number of claims pending
22 and all that may not have any relevance for
23 purposes of discovery.
24 MR. TAYLOR: That is correct, Your Honor,
25 if they did send that estimate. The only thing
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CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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1 would be if they sent the estimate and the $1.54
2 was paid and then that was some months ago and
3 here it is June 16th --
4 THE COURT: Understood.
5 MR. TAYLOR: But to answer your question,
6 yes, Your Honor, if it was sent from The Town
7 and my client received it in a timely manner,
8 yeah, absolutely.
9 MS. O'CONNOR: Well, I think that
10 presupposes -- If he says his client received it
11 in a timely manner, that presupposes - I mean,
12 that creates a fact issue as to whether it was
13 timely.
14
MR.
TAYLOR: Well,
I'm --
15
THE
COURT: Well,
I'm not saying this
16
precludes
all discovery.
I'm still not clear on
17
what you're
telling me,
Mr. Taylor. Are you
18 agreeing the issue on the first request for the
19 public records that --
20 MS. O'CONNOR: And here's the response, by
21 the way. I don't know where the $1.54 comes
22 from or it's an estimate.
23 THE COURT: -- that you're willing to
24 agree that the only claim you're pursuing
25 against The Town for noncompliance is based upon
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CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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1 the factual dispute as to whether The Town did
2 or did not produce to you timely this -- Let me
3 see if I can --
4 MR. TAYLOR: Your Honor, I believe when I
5 said, 11$1.54," I believe that might be the page
6 amount because this I'm showing that the billing
7 is for two hours of administrative support for
8 $39.23. Again, I've never seen this until just
9 now.
10 THE COURT: I'm looking at paragraph 9 of
11 The Town's response, it says: On June 25, 2014
12 in response to the first request, The Town
13 advised Plaintiff that it was prepared to
14 produce responsive records to Plaintiff upon
15 payment by a deposit permitted under the Public
16 Records Act for the significant time and
17 expenses associated with gathering those
18 documents and the actual cost of duplication.
19 Now, am I correct that you've challenge
20 that, that allegation, that they gave you that
21 response on June 25th?
22 MR. TAYLOR: Your Honor, I do not know if
23 that --
24 THE COURT: You don't know whether you're
25 challenging that?
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June 16, 2015
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1 MR. TAYLOR: No, I don't know if the
2 response was received on the 25th as of right
3 now.
4 THE COURT: It says The Town advised you
5 on June 25th. Is that fact in dispute as to the
6 accuracy of that allegation, that they provided
7 you with a cost estimate on June 25th?
8 MR. TAYLOR: Yes, that is in dispute as of
9 right now.
10 THE COURT: Knowing that that is in
11 dispute, whether it was produced, whether it
12 gave you the cost estimate, whether you received
13 it on or about that time, do you have any other
14 claims for noncompliance with the statute as to
15 Count I other than that specific issue?
16 In other words, Ms. O'Connor has raised on
17 behalf of The Town that the Court has to
18 consider all of the circumstances in determining
19 whether their response was reasonable and
20 timely, and so for that reason they want me to
21 open discovery regarding the other claims that
22 were pending; how many had been made in the past
23 few months; how many had been made that week,
24 that day, that sort of thing.
25 Are you telling me that you are not going
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June 16, 2015
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1 to make an argument or that you're specifically
2 waiving any argument that based upon the
3 totality of the circumstances, their response
4 was deficient because of the timeliness or lack
5 1 of timeliness of it?
6 MR. TAYLOR: Yes, Your Honor, the argument
7 is not - we're not seeking to argue that their
8 response was not timely, that's why we believe
9 that any depositions that are taken or any
10 questions that are asked regarding how many
11 requests they received that week, whether it's
12 400 or 800 would be completely irrelevant.
13 THE COURT: So the basis then for your
14 claim that their response was not in compliance
15 with the statute is what specifically as to
16 Count I or Request I?
17 MR. TAYLOR: I guess, Your Honor, at this
18 point it would just be a simple matter of the
19 fees and whether the fees are actually adequate,
20 whether they're legally charged.
21 Again, I'm showing that there was a $1.54
22 amount and then I'm seeing this paper today
23 that's $39 and I believe 23 cents, so
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essentially we're
not challenging
the actual
25
timeliness of the
response of the
letter that
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CG ACQUISITION vs. TOWN OF GULFSTREAM
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was sent from Gulf Stream, that would be the
only challenge, but, again, there is no
challenge to timeliness in the first count.
THE COURT: So you're only challenging as
to amount of the cost estimate that they gave to
you is being unreasonable.
MR. TAYLOR: Yeah. Oh, yeah.
THE COURT: And that's the only issue.
MR. TAYLOR: That's the only issue.
THE COURT: Okay. With that stipulation,
Ms. O'Connor, do you agree that limits your need
for discovery?
MS. O'CONNOR: Yes, Your Honor, to some
extent. We also have Count III for injunctive
relief in this case, and there's an allegation
there that claims that The Town's actions with
respect to providing records to the public
demonstrates a pattern of noncompliance with the
Public Records Act and a likelihood of future
harm in the form of denial of access to public
records to this Plaintiff and the public at
large.
I can tell you my concern. My concern is
I'm trying to move these cases towards
dispositive motion practice. I don't want to
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CG ACQUISITION vs. TOWN OF GULFSTREAM 21
1 come in with an affidavit from The Town
2 outlining what was going on at The Town at the
3 time we received these public records requests;
4 i.e., we received 400 this month, we received
5 100 the week before, and have them try to refute
6 that evidence just prior to a summary judgment
7 hearing.
8 So, you know, I think I'm entitled to know
9 on what actions are they complaining about in
10 Count III. I don't want to go into -- And I can
11 represent to the Court that, and I think I've
12 told Mr. Taylor, I mean, the depositions -- And
13 I've tried to tee up depositions in a number of
14 cases and they've been met with motions for
15 protective order in every single one in which
16 we've tried to tee up a motion and trying to tee
17 up depositions.
18 I specifically picked the corporate
19 representative of the Plaintiff thinking that
20 would be the most fair. I'm not telling them I
21 need Mr. O'Boyle or Mr. Ring. I just want them
22 to come in with the corporate representative of
23 this Plaintiff with knowledge about the
24 allegations that have been made in this
25 Complaint.
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CG ACQUISITION vs. TOWN OF GULFSTREAM
June 16, 2015
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1 MR. TAYLOR: Well, Your Honor, that's
2 perfectly understandable, but based on past
3 practices not necessarily by Ms. O'Connor, but
4 The Town, other counsel with Gulf Stream, it's
5 clear that a lot of these depositions have
6 turned into fishing expeditions, marathons that
7 have either been meant to just drag out, have
8 nothing, nothing whatsoever to do with the facts
9 of the case, and just meant to drag out, they're
10 meant to harass.
11 Like I said earlier, the last deposition
12 that was on September 15th, seven to eight
13 hours, 15 minutes actually on the facts, and
14 it's not over, it never actually concluded.
15 That's what we're looking --
16 THE COURT: Let's right now try to limit
17 it to this particular case because you attached
18 transcripts from two other cases that I assume
19 are in front of me but aren't in front of me
20 today.
21 So your claim for injunctive relief, I'm a
22 little confused why it's paired in this cause of
23 action or grouped in this cause of action, is
24 probably more appropriate, in light of the fact
25 that you're telling me now the only defect
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CG ACQUISITION vs. TOWN OF GULFSTREAM
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you're claiming against The Town is that they
charged too much for copies.
Are you limiting your injunctive relief to
the same remedy, you want the Court to somehow
enter an injunction to say that, "Going
henceforward, The Town of Gulfstream can't
charge more or can't estimate more than X amount
of dollar per page," or something like that; is
that the limit of the injunctive relief you're
seeking as well?
MR. TAYLOR: Well, Your Honor, that isn't
the only thing. Again, we're alleging in Count
II that they have records that they just flatly
haven't produced. What my client is seeking is
an injunction based on these two actions that we
pled in this case.
THE COURT: The Count II, the
non -production, if I'm clear, you're not
claiming that has anything to do with an
unreasonable delay based upon the volume of
requests, you're saying they're not being
truthful with you, right?
MR. TAYLOR: Exactly, because they
produced some documentation or actually they
responded saying no documentation exists.
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THE COURT: So is your request for
injunctive relief today as part of this case
that's before the Court today really just based
upon two different grounds; one, that they have
to be truthful and tell you what documents they
actually have that are public records and
produce them and; two, that they can't
overestimate the cost of the production?
MR. TAYLOR: Correct, Your Honor, and the
injunctive relief is basically enjoining them
from violating Chapter 119 Florida Statutes.
THE COURT: Well, that's a different issue
because there's a lot of stuff in 119. If
you're telling me today you're limiting your
injunctive relief to those two things, then
again, I think that may put some limits on the
discovery which Ms. O'Connor's client is
entitled to.
MR. TAYLOR: Yes, Your Honor.
THE COURT: Now, Ms. O'Connor, we have an
additional stipulation, that the issues here
relate to the first two counts only to
inappropriate cost assessments, they relate to
lack of candor in the documents that actually
exist, and that the third count for injunctive
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relief will seek relief only based on those two
grounds, so with that stipulation, what
discovery do you need?
MS. O'CONNOR: With that stipulation, Your
Honor, I'm just looking and it might be helpful
for us to walk through the topics of inquiry,
but what we need are - we would need the
discovery related to Count II, we would --
THE COURT: Can we do this, and maybe I'm
looking at the wrong thing, maybe you need to
direct me to the actual duces tecum.
MS. O'CONNOR: I have a copy.
THE COURT: I was looking at Mr. Taylor's
Notice of Filing Case Law, and on page 2 he
tells me they agree you should get topics 3 and
4, and then on the next two pages they list 1
through 15; are those all of the topics that we
need to address?
MS. O'CONNOR: I think he maybe got 3 and
4 from the - there's a document request as well,
that's the 30(b)(6) notice.
THE COURT: So you're asking me to look at
Exhibit B --
MS. O'CONNOR: Correct.
THE COURT: -- which has 15 different
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1 numbered paragraphs, and this is attached to the
2 Subpoena Duces Tecum Notice to CG Acquisition
3 with the case number that is hopefully, yes,
4 before the court today.
5 All right. So do items --
6 MS. O'CONNOR: I mean, it might --
7 THE COURT: Do Mr. Taylor's indication
8 that topics 3 and 4 --
9 MS. O'CONNOR: -- it might help --
10 THE COURT: -- relate to 3 and 4 on
11 Exhibit B?
12
MS.
O'CONNOR: I think he meant the list
13
on Exhibit
A.
14
THE
COURT: All right. Let's take Exhibit
15
B.
16
MS.
O'CONNOR: Sure.
17
THE
COURT: Does everybody have Exhibit B?
18
MS.
O'CONNOR: Yes.
19
MR.
TAYLOR: Yes.
20
THE
COURT: All right. Let's go through
21
it, start
with No. 1. Tell me what think you
22
need and why, Ms. O'Connor, what you think
23
you're entitled
to and why.
24
MS.
O'CONNOR: Well, this goes to - I
25 1 mean, if we'll have the stipulation on Counts I
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1 and III, then as to Count II, the Complaint is
2 replete with allegations that Plaintiff believes
3 there are additional documents.
4 So I don't know who they're going to
5 produce as the corporate representative, so I
6 think as a background matter I need to know who
7 are the related individuals, who are the
8 officers, directors, and employees that might
9 have information that they're going to come into
10 court at a hearing or in response to a summary
11 judgment and say, "Well, that wasn't our
12 30(b)(6) representative," but maybe they put up
13 Mr. Ring who's the vice-president as their
14 corporate representative, but then Marty O'Boyle
15 submits an affidavit saying, "I think there were
16 response to records and here's why," so I think
17 item one is clear background information.
18 Item two --
19 THE COURT: Have you asked for the
20 corporate representative pursuant to Carriage
21 Hills and the 1.130(b)(6).
22 MS. O'CONNOR: Correct, Your Honor.
23 THE COURT: So they're locked in on that.
24 If they produce Mr. Ring and Mr. Ring becomes
25 the spokesman for the corporation for those
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1 particular issues, so it wouldn't do Mr. O'Boyle
2 any good to come in and say, "Wait a minute, I'm
3 supposed to be it," because they've already
4 designated Mr. Ring.
5 MS. O'CONNOR: Hopefully so.
6 THE COURT: All right. Let's for now
7 eliminate 1. No. 2?
8 MS. O'CONNOR: I don't need No. 2, at
9 least at this point, depending on our
10 stipulation of Counts I and II.
11 THE COURT: No. 3?
12 MS. O'CONNOR: No. 3 is the foundation for
13 most of the other topics.
14 THE COURT: Okay. No. 4?
15 MS. O'CONNOR: I don't need 4 and 5 if
16 they're not challenging the timeliness of our
17 response.
18 THE COURT: Okay. No. 6, the purpose.
19 MS. O'CONNOR: Sure.
20 THE COURT: Most cases say the purpose
21 isn't really relevant.
22 MS. O'CONNOR: Well, if you look at Count
23 II they assert - and Count II goes to public
24 records request 549.
25 All four of these requests were made on
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the same day, May 13, 2014, and they all sought
to, according to Plaintiff's allegation, to
trace the source of funds that The Town received
pursuant to this certain resolution. So when I
said the purpose for the public records request,
it's going to - I intended it to go to why did
they believe there were documents? What were
they looking for?
They put at issue in the allegations of
the Complaint why they were looking for it,
what --
THE COURT: So these are the ones, 548
through 551, that you've said you don't have any
and they said, "We don't believe you."
MS. O'CONNOR: 549 is the one that we said
we have nothing.
THE COURT: Okay, 549.
MR. TAYLOR: So, Your Honor --
THE COURT: So I don't know that entitles
you to get to the purpose, but I think you're
entitled to inquire why they believe you do have
documents related to 549 and you say you don't;
agreed, Mr. Taylor?
MR. TAYLOR: Absolutely, Your Honor.
THE COURT: So not the purpose, but basis
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1 for belief that Defendant has responsive
2 documents, and that's 549 only.
3 Okay. Go on to No. 7.
4 MS. O'CONNOR: No. 7, again, this is Count
5 II, would go to attempts they've made to gather
6 documents that were responsive to this public
7 records request, and I can limit it here again
8 to 549, which is the subject of Count II. The
9 idea being if they have documents in their
10 possession in some sort of "gotcha" fashion
11 that, you know, we should know that they think a
12 certain document was responsive but wasn't
13 turned over, that's what we're trying to get to.
14 THE COURT: So No. 7, 549 only; agree, Mr.
15 Taylor?
16 MR. TAYLOR: I don't, Your Honor.
17 THE COURT: Tell me.
18 MR. TAYLOR: It refers to a third party.
19 For case law, it doesn't matter if a third party
20 has documentation.
21 THE COURT: Well, it seems like it would
22 be discoverable there because you're saying,
23 "They told us they don't have it, we think they
24 have it," so if they get to inquire already
25 under No. 6, what's the basis for your belief?
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So I'm thinking for under No. 6 they're able to
say, for instance, "Did you try to gather these
documents somewhere else related to 549; did you
get them?" Because that's really part and
parcel of - it may be part and parcel of why you
think they should be producing documents
pursuant to that request.
So it's not opening it up for every
document request, but if you, through your
attempts to gather documents, you found
documents responsive to 549 that they haven't
produced, I think they should be entitled to
that through discovery, so I'm going to give
them No. 7 as relates to 549 only.
Okay. No. 8?
MS. O'CONNOR: No. 8 is related to No. 7.
There are certain exhibits in the Amended
Complaint, A, B, and C that they've attached
when they walked through their allegations that
they believe that other documents exist.
THE COURT: Well, how does -- I don't have
A, B, and C in front of me, do they relate to
the request of 549?
MS. O'CONNOR: Yes. They're various --
There are certain receipts.
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1 MR. TAYLOR: There's receipts, there's
2 blind items for budgets, things of that nature.
3 I can't possibly see how they would actually --
4 MS. O'CONNOR: I --
5 MR. TAYLOR: -- how that would have
6 anything to do with the public records request
7 that's the subject of this proceeding.
8 THE COURT: Why are they attached to the
9 Complaint?
10 MR. TAYLOR: They're attached to the
11 Complaint, Your Honor, basically as proof to
12 show that Gulf Stream makes a pattern of
13 whatever they spend on -- This is really about a
14 specific fund, it's for I believe a construction
15 permit, it costs a certain amount, Gulf Stream
16 charges a certain amount, but it's not meant to
17 raise revenue, it's meant to offset certain
18 costs. My client simply wants to figure out
19 where the money is going.
20 The attachment to the Complaint is
21 essentially attached to show, look, they do keep
22 this documentation, they do code it when it's
23 spent on certain things, so because they do that
24 it's very hard to believe that, especially as it
25 pertains to Count II, that they have no
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1 documentation showing where they spend the money
2 or transfer it to.
3 THE COURT: So does it support your belief
4 that in response to Count II or to Request II
5 they have documents that they haven't produced?
6 MR. TAYLOR: It certainly suggests that,
7 but at the same time from what I'm gathering
8 from the information request they want to know
9 where the information came from.
10 MS. O'CONNOR: Your Honor --
11 MR. TAYLOR: What difference does it --
12 MS. O'CONNOR: -- I'd be willing to revise
13 8 to the effect we seek information on why you
14 believe that Exhibits A, B, and C support the
15 existence of additional responsive documents,
16 something to that effect, if that's acceptable.
17 THE COURT: So A, B, and C. Eight will
18 relate why and how Exhibits A, B, and C support
19 your belief that they haven't produced documents
20 under 549.
21 No. 9?
22 MS. O'CONNOR: No. 9 goes to Count I, and
23 the reason for No. 9 is even after amending the
24 Complaint they continued to allege that this was
25 an unlawful withholding count, just trying to
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1 think whether our stipulations --
2 THE COURT: Is it your position you got
3 the request but didn't pay it because it was
4 unreasonable or is it your position that you
5 didn't get the request for payment or is it your
6 position that either/or?
7 MR. TAYLOR: Really either/or, Your Honor.
8 THE COURT: Okay. So if part of your
9 claim is that you didn't think you should have
10 to pay this, they may certainly maybe entitled
11 to ask why you didn't think you should pay it.
12 MR. TAYLOR: Understood.
13 THE COURT: So that will be allowed.
14 No. 10?
15 MS. O'CONNOR: No. 10 is just generally --
16 MR. TAYLOR: Ten I don't --
17 MS. O'CONNOR: Ten, you're okay?
18 MR. TAYLOR: I don't have a problem with
0MiUl
20 THE COURT: Ten is okay.
21 MR. TAYLOR: Yes.
22 THE COURT: Eleven?
23 MS. O'CONNOR: Eleven again goes to the
24 idea that there are additional documents, what
25 did they understand the terms of the process by
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which we collect these fees?
THE COURT: Sounds to me more like it goes
to -- Well, this 549, are those the zoning
review fees?
MS. O'CONNOR: Correct. The request was
for any documents that show how we used those
monies that came in. Our position, these are
commingled funds, they're not tracked as they go
out, they come in in a particular line item, but
they're not going out as any given line item,
so.
MR. TAYLOR: Your Honor, if I may, the
reason I object to that is because part of the
reason for asking for the records was to gain
knowledge. Whether the Plaintiff had knowledge
of the zoning review fees or not, it has nothing
to do with whether Gulf Stream should have to
produce the documentation under Chapter 119 or
not.
THE COURT: I think the relation of
paragraph 11 to the non -production of documents
claim would be covered by the other requests
that I've already allowed you to go into, so I
will disallow No. ii.
No. 12, again, that's the Plaintiff's
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knowledge question, as is No. 13, and I'm not
sure, Ms. O'Connor, how that would need to be
discoverable at this point based upon the
stipulation by Mr. Taylor.
MS. O'CONNOR: I think 10 is probably an
umbrella to cover that.
THE COURT: So we'll leave 12 and 13 out
as encompassed as relates to 549.
Fourteen, litigation history including
public record requests, that wouldn't seem to
have relevance based in this case anyway based
upon the stipulation.
MS. O'CONNOR: Agreed.
THE COURT: And 15.
MS. O'CONNOR: Fifteen --
THE COURT: You have a claim for
attorney's fees.
MS. O'CONNOR: Correct.
THE COURT: So I'm not sure what
relationship between Plaintiff and its counsel
including, but not limited to, retention of
counsel would have to do, but it seems to me you
would be entitled to a retainer fee agreement
that would specify the hourly rate and that sort
of thing.
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1 MR. TAYLOR: My only comment to that, Your
2 Honor, would be you would be absolutely right,
3 but our position, our client's position, is that
4 Chapter 119 allows for fees when there's a
5 determination that Chapter 119 has been
6 violated. As that has not happened as of yet,
7 it's our position the issue is moot. Now --
8 THE COURT: Premature?
9 MR. TAYLOR: Yes.
10 THE COURT: So what you're willing to do
11 is to stipulate if the Court finds in your favor
12 that you will then produce those documents prior
13 to an attorney's fees hearing.
14 MR. TAYLOR: Or Ms. O'Connor's willing to
15 stipulate to judgment today, but I don't think
16 that's going to happen.
17 THE COURT: I don't think you're going to
18 that.
19 All right. So as far as being premature,
20 Ms. O'Connor, if the Court makes the
21 determination of entitlement to fees, you'll get
22 it well in advance of the fee hearing?
23 MS. O'CONNOR: That's fine, Your Honor.
24 We were just trying to move it along.
25 THE COURT: All right. So does that cover
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all of the outstanding requests?
MS. O'CONNOR: I believe so.
THE COURT: Which of you would like to
prepare the order?
MS. O'CONNOR: I'll be happy to prepare
the order.
THE COURT: You'll be happy to prepare the
order, okay.
MS. O'CONNOR: Sure. Anything else on
this?
MR. TAYLOR: No.
MS. O'CONNOR: While we're here, and I
apologize, I didn't raise it with Mr. Taylor,
but we have a case coming to you from Judge
Brunson and it involves redactions of a public
records request, and pursuant to the Public
Records Act when there are work product
exemptions that are redacted the Court reviews
the unredacted.
What it is is invoices from Mr.
Sweetapple's law firm and some items were
redacted that reflect work product we submit in
an ongoing matter, and the Public Records Act
contemplates that you review it in -camera, about
five pages.
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I actually haven't ever had a dispute over
a privilege log where the privileged documents
were submitted in camera, so my question for you
is whether you have - in terms of how we submit
to you evidence
So, for example, you know, I may need to
submit an affidavit to you from Mr. Sweetapple
who says, "Okay. The witness whose name is
listed on August 15th entry was a - or the
person whose name is listed is a potential
witness in this case to support the exemption."
THE COURT: Let me interrupt you. I want
you to understand, although it sounds like most
of these cases are coming to this division,
you've been living with the intricacies, both of
you, more than I have. I have about
1,200 cases, I don't mean that disrespectful.
It's hard for me to take in exactly the totality
of the circumstances that you're talking about
that's going to lead to this potential in -camera
review by this court.
What I would suggest, if you all meet and
if you all have a process that works, send it to
me in a agreed order in that case and I'll look
at it. If I understand it and agree with it
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I'll sign off on it. If I don't understand it I
can bring you in for a brief hearing or if I
don't agree with it, assuming I understand the
proposal, I'll tell you why I don't agree and
send an order out to you that way.
You know that in a couple months you're
going to have a different judge on this.
MS. O'CONNOR: Yes.
THE COURT: So if I thought I was here for
the long-term it would make sense to try and
rush this through, or not rush this through, try
to get it to me to keep things moving, but I
think you're going to have to bring another
judge up to speed on all of this in a couple
months anyway, so you decide whether you want me
to keep addressing these issues until I'm gone
or whether you want to wait and educate the next
judge, I believe it's Judge Oftedal. I have no
preference on that, whatever works for all of
you is fine with me.
For today, I appreciate you guys getting
your materials ahead of time and you'll submit
the proposed order as long as Mr. Taylor agrees
to the form and content and I'll sign off on
that.
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My question for you since you're here, I
got something on a different case but related to
that, and I forget the name of the parties and
it's an attorney from Orlando that may be
representing one of the public records
requestors, and I can't tell you which one, but
they sent me a cover letter with a thumb drive
taped to it. I haven't put it on my computer
and will not, but I had my JA call and say, "set
this for hearing," and that call was made
June 8th and I haven't heard a thing, so I'm
getting ready to send that back unless you can
me something about it or something I should
know.
MS. O'CONNOR: Is it a Gulf Stream case,
do you know?
THE COURT: Good question. Do you want to
wait a minute and I'll grab it?
MS. O'CONNOR: Sure.
(Short break.)
THE COURT: Okay. This is Christopher
O'Hare vs. Town of Gulf Stream, it's 13CA17717,
the cover letter from Mr. Roeder.
MR. TAYLOR: Roeder.
THE COURT: Says, "Enclosed please find a
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computer flash drive containing digital copies
of video depositions referenced in companion
motions for protective order in the above
referenced case. Copies have also been sent to
Joanne O'Connor and Robert Sweetapple.
Respectfully, Louis Roeder.
I was away last week, but my JA called Mr.
Roeder's office on June 8th and said, "set this
for hearing," and we've heard nothing, so I'm
inclined to send this back unless there's
something I missed.
MR. TAYLOR: Your Honor, what's the case
number on that?
THE COURT: 13CA17717.
MR. TAYLOR: Okay. Thank you.
THE COURT: All right. So I'll hold it a
couple more days. If you can give me any
clarification or I get a call back from the
office that they're setting it for hearing, then
I'll hold on to it. Whether I'll put it into my
computer and look at the video depositions I
don't know because I haven't seen the motion, I
haven't reviewed the motion it's attached to. I
wasn't going to review that unless I knew it was
set for hearing, so we'll see what happens next.
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All right. Thank you, folks. Have a good day.
MR. TAYLOR: Thank you.
MS. O'CONNOR: Thank you.
(The hearing concluded at 3:10 p.m.)
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PROCEEDINGS
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CERTIFICATE
STATE OF FLORIDA )
COUNTY OF PALM BEACH )
June 16, 2015
44
I, JENNIFER D. DiLORENZO, Shorthand
Reporter, certify that I was authorized to and did
stenographically report the foregoing proceedings and
that the transcript is a true and complete record of
my stenographic notes.
Dated this 7th day of July, 2015.
C?e A - 'b' 0?')At--7P
JENNIFER D. DiLORENZO,
COURT REPORTER
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10:16,20
13
25th
$
29:1
17:21
28:7
36:1,7
18:2,5,7
$1.54
13CA17717
8:19,25
41:22
3
9:7 12:24
42:14
1.130(b)(6)
13:3,6,
15
3
16,21
4:16,19
25:15,19
16:1,21
22:13
26:8,10
17:5
4:16
19 36:5
25:17,25
28:11,12
19:21
36:14
21:5
17:11
11
30 (b) (6)
$39
2015
119
3:3
15th
25:21
19:23
22:12
27:12
$39.23
39:9
14:8
35:25
17:11
300
17:8
16
11:22
3:3
330
1
16th
14:13
16:3
3:10
1
43:4
10:16,20
25:16
2
26:21
28:7
2
10:15
1,200
25:14
39:17
28:7,8
1.130(b)(6)
20
27:21
6:17
10
2014
34:14,15,
4:16
19 36:5
11:23
100
14:8
21:5
17:11
11
29:1
35:21,24
2015
119
3:3
24:11,13
23
35:16
19:23
37:4,5
25
12
14:8
35:25
17:11
36:7
4
4
14:23
25:16,20
26:8,10
28:14,15
400
19:12
2 1: 4
5
5
28:15
548
29:12
549
28:24
29:15,17,
22 30:2,
June 16, 2015
Index: $1.54 -additional
8,14
31:3,11,
14,23
33:20
35:3 36:8
551
29:13
C
6
28:18
30:25
3 1: 1
7
7
30:3,4,14
31:14,16
8
8
31:15,16
33:13
800
19:12
8th
41:11
42:8
9
9
14:23
17:10
33:21,22,
23
A
ability
10:7
absolute
5:10
absolutely
5:16 6:2
9:10 16:8
29:24
3 7: 2
acceptable
33:16
access
20:20
accuracy
18:6
Acquisition
3:1,5,14
4:3 26:2
Act
17:16
20:19
38:17,23
action
22:23
actions
20:16
21:9
23:15
actual
5:3 6:15,
22 13:16
17:18
19:24
25:11
additional
24:21
27:3
33:15
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
PROCEEDINGS
CG ACQUISITION
vs. TOWN OF
GULFSTREAM
June 16, 2015
Index: address -care
34:24
40:22
appearing
41:4
belief
address
allegation
3:14
attorney's
30:1,25
33:3,19
25:18
8:21,24
area
36:17
addressing
9:19
7:12
37:13
believes
17:20
7.19 27.2
40:16
areas
August
18:6
5:15,19
39:9
bill
adequate
20:15
19:19
29:2
6:2 7:25
authority
10:24
administratallegations
argue
3:20
billing
ive
21:24
19:7
avoid
17:6
17:7
27:2 29:9
argument
14:6,17
bit
advance
31:19
9:3 15:8
aware
7:12
37:22
allege
19:1,2,6
10:19
blanket
advised
15:19
assert
5:22 6:9
14:11,13
33:24
28:23
B
blind
17:13
alleging
assertion
32:2
18:4
23:12
5:10
back
break
affects
allowed
assessments
4:7 11:23
41:20
8:10
34:13
24:23
41:12
bring
affidavit
35:23
assume
42:10,18
40:2,13
21:1
amended
12:8
background
broader
27:15
8:17
22:18
27:6,17
7:12
39:7
11:14,18
assuming
banning
12:23
Brunson
agree
12:3,9
6:10
38:15
16:24
13:2,8
40:3
20:11
31:17
based
budgets
attached
5:22
amending
3:8,9
16:25
32.2
25:15
30:14
33:23
14:24
19:2 22:2
39:25
amount
22:17
23:15,20
C
40:3,4
13:12
26:1
24:3 25:1
agreed
17:6
31:18
36:3,11
call
29:23
19:22
32:8,10,
basically
41:9,10
36:13
20:5 23:7
21 42:23
7:7 24:10
42:18
39:24
32:15,16
attachment
32:11
called
agreeing
anymore
Ym
32:20
basis
42:7
9:6 16:18
4:13
attachments
11:4
15:13
camera
agreement
3:20
12:18
39:3
36:23
apologize
attempts
19:13
38:13
29'25
candor
agrees
30:5
30:25
24:24
40:23
appearances
31:10
3:11
behalf
care
ahead
attorney
13:14
18:17
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. corn
PROCEEDINGS
CG ACQUISITION vs. TOWN OF
GULFSTREAM
June 16, 2015
Index: Carriage -count
Carriage
28:16
23:18
32:9,11,
copying
27:20
Chapter
27 17
20 33:24
8:19 13:6
case
24:11
cleverly
complete
corporate
3:10,25
35:18
13:25
6:9
4:2 5:2,
4:5 5:1,
37:4,5
client
completely
4,6,18
2,4,22
charge
4:12,25
13:13
6:5 8:9
6:17,18,
13:7,16,
5:4 7:18
19:12
21:18,22
22'24
21 23:7
10:11
27:5,14,
7:2,20
compliance
20
8:15
charged
16:14
19:14
23:14
corporation
10:10
19:20
24'17
computer
27;25
20:15
23:2
32:18
41:8
22:9'17
charges
42:1,21
correct
23:16
client's
7:16
24:2
32:16
37:3
conceding
11:24
25:14
Christopher
15:5,6
12;2
code
26:3
41:21
15:14,24
32:22
concern
30:19
circumstanc
20:23
17:19
36:11
collect
24;9
38:14
e8
35:1
concluded
25:24
4:8 18:18
39:11,2419:3
comment
22:14
27:22
41:2,1543:4
39:19
37:1
35:5
42:4,12
confused
36:18
claim
commingled
cases
9:8 10:4
35:8
22:22
correctly
4:8 15:21
16:24
confusion
8:23
20:24companion
19:14
11:12
corresponds
21:14
22:21
42.2
constructic
nce
22:18
34:9
company
14:24
28.20
35:22
3:1,6
n
39:14,17
36:16
5:12
32:14
cost
contemplate
10:25
cents
claiming
comparison
15:3,18
19:23
23:1,19
4:11
s
38:24
17:18
CG
claims
complaining
18:7,12
3:1,5,14
10:2
21:9
content
20:5
4:2 26:240:24
15:21
24:8,23
Complaint
challenge
18:14,21
7:15,17
continued
costs
9:23 10:7
20:16
11:14,15,
33:24
32:15,18
11:1
clarificati
16,18
copies
counsel
17:19
on
12:23
23:2
3:11 4:10
20:2,3
42:18
13:2,8
42:1,4
13:9 22:4
challenging
clear
21:25
copy
36:20,22
17:2527`1
5:5 15:15
6:18,23
count
19:24
16:16
29.10
25:12
7:16
20:431:18
22:5
8:16,17
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
PROCEEDINGS
CG ACQUISITION
vs. TOWN OF
GULFSTREAM
June 16, 2015
Index: counts -documents
10:20
19:13
deposit
discovery
11:8,21
20:4,8,10
D
17:15
6:10,11,
13:14
21:11
deposition
15 7:12
14:5,7,
22:16
8:14 9:5
date
4:15,17,
17,18
23:4,17
10:1
15:19
18,20,24
15:15
24:1,3,
14:1,6
6:2,23
18:15
12,20
day
15:11,23
22:11
19:16
25:9,13,
18:24
16:16
20:3,14
22,25
29:1 43:1
depositions
18:21
21:10
26:4,7,
days
5:24
20:12
23:12,17
10,14,17,
42:17
6:10,14,
24:17
24:25
20 27:10,
20 19:9
25:3,8
25:8 27:1
19,23
decide
21:12,13,
31:13
28:22,23
28:6,11,
40:15
17 22:5
dispositive
30:4,8
14,18,2042:2,21
defect
20:25
32:25
29:12,17,
22:25
designated
33:4,22,
19,25
5:8,18
dispute
25
30:14,17,
Defendant
12:9 17:1
21 31:21
4:1 7:22
64 284
::
18:5,8,11
counts
32.8
8:17 13:4
determinati
39:1
10:18
24:22
33:3,17
30:1
on
disrespectf
26:25
34:2,8,
Defendant's
37:5,21
ul
28:10
13,20,22
3:9
determine
39:17
35:2,20
7:13
couple
36:7,14,
defense
division
40:6,14
16,19
10:7,8,9
determining
39:14
42:17
37:8,10,
deficient
18:16
document
court
11,17,20,
19:4
difference
25:20
3:5,15,18
25 38:3,
delay
33:11
30:12
5:6,13,17
7'18
23:20
digital
31:9
6:1,4,7,
39:12,21
42:1
documentati
25 7:13,
40:9
delayed
21,25
41:17,21,
7:10
direct
on
8:4,13
25 42:14,
demonstrate
25:11
8:19
16
10:13
9:1,8,21
s
directors
13:5,11
10:15,22
cover
20:18
27:8
23:24,25
11:9,11,
36:6
denial
disagrees
30:20
24 12:3,
37:25
20:20
7:19
32:22
8.20
41:7,23
33:1
13:23
deny
disallow
35:18
14:18,21
covered
4:10
35:24
15:1,15
35:22
documents
depending
discoverabl
3:8 7:4,6
16:4,15,
creates
28:9
23 17:10,
16:12
e
9:14,17,
24 18:4,
depose
10'6
18 11:20,
10,17
4:2 5:3
30:22
23 17:18
36:3
24:5,24
ESQUIRE 800.211.DEPO (3376)
S 0 L u* 1 0„ S EsquireSolutions.com
PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
27:3
27:8
18:7,12
29:7,22
Enclosed
20:5 23:7
30:2,6,9
41:25
evidence
31:3,6,
10,11,20
encompassed
21:6 39:5
33:5,15,
36:8
exemption
19 34:24
39:11
enjoining
35:6,21
24:10
exemptions
37:12
38:18
39:2
enter
23:5
Exhibit
dollar
14:25
23:8
entities
25:23
8:8
drag
26:11,13,
22:7,9
entitled
14,17
5:14 7:22
draw
8:13 21:8
exhibits
4:11
24:18
31:17
drive
26:23
33:14,18
41:7 42:1
29:21
exist
31:12
24:25
duces
34:10
31:20
25:11
26:2
36:23
existed
entitlement
9:18
duplication
17:18
6:1 37:21
existence
entitles
33:15
29:19
exists
E
entity
23:25
8:8
earlier
expect
22:11
entry
14:6
educate
39:9
expedition
40:17
essentially
4:23
effect
3:24 8:18
expeditions
10:2022:6
8:7 11:2
19:24
33:13,16
32:21
expenses
either/or
17:17
estimate
34:6,7
10:24
extent
Eleven
11:22
20:14
34:22,23
12:10,11,
extremely
eliminate
12,15
5:23,25
14:1 28:7
14:10
15:19,25
employees
16:1,22
ESQUIRE
June 16, 2015
Index: dollar -frankly
12 11:15,
16
Filing
fact 25:14
11:21 find
12:15 41:25
13:17,20
14:15 finds
16:12 37:11
18:5
22:24
facts
4:21 6:13
22:8,13
factual
12:9 17:1
failing
6:9
fair
21:20
fashion
3 0: 10
favor
37:11
fee
8:19
36:23
37:22
fees
11:6
19:19
35:1,4,16
36:17
37:4,13,
21
Fifteen
36:15
figure
32:18
filed
3:25 4:3,
fine
37:23
40:20
firm
38:21
fishing
4:22 22:6
flash
42:1
flatly
23:13
Florida
24:11
folks
43:1
forget
41:3
form
20:20
40:24
found
31:10
foundation
28:12
Fourteen
36:9
frame
10:3
f rankly
4:24 5:21
800.211.DEPO (3376)
EsquireSolutions. com
PROCEEDINGS June 16, 2015
CG ACQUISITION vs. TOWN OF GULFSTREAM Index: front..intdcacies
front
grab
hearing
34:7
39:20
14:12
41:18
7:23 21:7
35:12
inappropria
22:19
27:10
37:2,23
grounds
to
31:22
24:4 25:2
37:13,22
42:12
24:23
fund
40:2
hour -and -a-
grouped
41:10
inclined
32:14
half
22:23
42:9,19,
42:10
funds
gases
25 43:4
6:ly
including
29:3 35:8
hourly
9:12 13:4
helpful
36:9,21
36:24
future
19:17
25:5
indication
20:19
Gulf
henceforwar
hous
26:7
ur17,19
9:1 20:1
d
17:7
individual
G
22:44
23:6
22:13
8:9
32:12,15
35:17
Hillsindividuals
hundreds
Gadd
41:15,22
27.21
27:
8:5
27:7
6:18
Gulfstream
history
information
gain
3:2,6,17
36:9
=
10:2
8:22 23:6
hold
27:9,17
gather
42:16,20
33:8,9,13
30:5
guys
i.e.
40:21
honest
21:4
injunction
31:2,10
13:8
23:5,15
idea
gathering
g
Honor
30:9
injunctive
j
17:17
3:13,23
34:24
20:14
33:7
4:6 5:20
22:21
happen
identities
gave
6:3,9,24
23:3,9
17:20
37:16
7:14,24
8:9
24:2,10,
18:12
happened
8:2,16
11
15,25
20:5
4:16 37:6
9:10
14:17,19
inquire
generally
happy
12:22
23:13,17
5:14
34:15
38:5,7
14:4,5
25:8 27:1
29:21
15:24
28:10,23
30:24
give
harass
16:6
30:5,8
31:13
4:25
17:4,22
32:25
inquiry
42:17
22:10
19:6,17
33:4
25:6
giving
hard
20:13
111
instance
11:5
32:24
22:1
20:14
31:2
good
39:18
23:11
21:10
intended
24:9,19
27:1
28:2
harm
25:5
29:6
41:17
20:20
27;22
immediately
interrupt
43:1
heard
29:18,24
11:17
39:12
gotcha
41:11
30:16
in -camera
intricacies
30:10
42:9
32:11
38:24
39:15
33:10
ESQUI 10E Esquire Sol tions.com)
PROCEEDINGS
CG ACQUISITION vs. TOWN OF
GULFSTREAM
June 16, 2015
Index: invoices -motion
invoices
18
lead
39:2
materials
38:20
judgment
39:20
long
40:22
involves
21:6
leave
40:23
matter
38:15
27:11
36:7
3:1 19:18
long-term
irrelevant
37:15
legally
40:10
27:6
6:21
June
19:20
30:19
lot
38:23
19:12
3:3 11:23
letter
12:13
issue
14:8 16:3
13:6
22:5
meant
9:11,12,
17:11,21
19:25
24:13
22:7,9,10
13 12:4,
18:5,7
41:7,23
26:12
41:11
Louie
32:16,17
14,22
42:8
light
42:6
13:1,17
meat
22:24
15:7,16
39:22
16:12,18
g
likelihood
M
18:15
20:19
met
21:14
20:8,9
42
limit
made
24:12
42:24
22:16
minute
29:9 37:7
23:9 30:7
18: 2,23
18:22,23
28:2
Knowing
41:18
issues
18:10
limited
21.24
7:2,3,13,
6:12
28:25
minutes
15 9:21
knowledge
36:21
30:5
4:20
15:12
21:23
41:10
22:13
24:21
35:15
limiting
main
missed
28:1
36:1
23:3
4 0:16
24:14
5:15
42:11
item
limits
make
mistaken
L
5:10 19:1
5:12
27:17,18
5:23
35:9,10
20:11
40:10
money
lack
24:16
makes
32:19
items
19:4
32:12
33:1
26:5 32:2
24:24
list
38:21
25:16
37:20
monies
large
26:12
making
35:7
20:22
14:2
J
listed
month
lasted
5:15
manner
21:4
4:17
39:9,10
9:16
JA
months
41:9 42:7
late
litigation
16:711
,
16:2
12:12
36:9
marathons
18:23
Joanne
law
living
22:6
40:6,15
3:16 42:5
3:10 5:5,
39:15
Martin
moot
judge
22 6:17
11:10
25:14
locked
4:18
37:7
38:14
30:19
27:23
Marty
motion
40:7,14,
38:21
log
27:14
3:7,8,19,
ESQUIRE Esqu �eSolut o800.21 I.DEPOn�
s.com
PROCEEDINGS June 16, 2015
CG ACQUISITION vs. TOWN OF GULFSTREAM Index: motions.. pertains
22,25
4:3,6
20:25
21:16
42:22,23
motions
21:14
42:3
motivation
6:20
motive
6:15
move
20:24
37:24
moving
4 0: 12
N
nature
32:2
necessarily
22:3
Nick
3:13
non-
production
23:18
35:21
noncomplian
ce
16:25
18:14
20:18
notice
6:22
13:21
15:3
25:14,21
26:2
number
10:4
15:20,21
21:13
26:3
42:13
numbered
26:1
U
O'boyle
4:18
21:21
27:14
28:1
O'connor
3:16 9:1
10:18
11:10,12
12:2,7
14:4,20,
23 15:14
16:9,20
18:16
20:11,13
22:3
24:20
25:4,12,
19,24
26:6,9,
12,16,18,
22,24
27:22
28:5,8,
12,15,19,
22 29:15
30:4
31:16,24
32:4
33:10,12,
22 34:15,
17,23
35:5
36:2,5,
13,15,18
37:20,23
38:2,5,9,
12 40:8
41:15,19
42:5 43:3
O'Connor I
24:17
37:14
O'hare
4 1: 22
object
35:13
office
42:8,19
officers
27:8
offset
32:17
Oftedal
40:18
ongoing
38:23
open
7:11 8:1
18:21
opening
31:8
opposing
4:10
opposition
14:25
order
3:7 4:1,
4,7,9,10,
12,16
5:22 6:10
14:6,17
21:15
38:4,6,8
39:24
40:5,23
42:3
originally
11:14
Orlando
41:4
outlining
21:2
outstanding
38:1
overestimat
e
24:8
FZ
p.m.
43:4
pages
11:22
14:13
25:16
38:25
paid
8:20,25
13:12
16:2
paired
22:22
paper
19:22
paragraph
14:23
17:10
35:21
paragraphs
26:1
parcel
31:5
part
24:2
31:4,5
34:8
35:13
parties
41:3
party
30:18,19
past
18:22
22:2
pattern
20:18
32:12
pay
34:3,10,
11
payment
17:15
34:5
pending
10:2
15:21
18:22
perfectly
22:2
period
8:7
permit
32:15
permitted
17:15
person
39:10
pertained
4:21
pertaining
6:13
pertains
6:20 11:7
ESQUIRE 800.211.DEPO (3376)
. o � . . o � , EsquireSolutions.com
PROCEEDINGS
CG ACQUISITION vs. TOWN OF
GULFSTREAM
June 16, 2015
Index: picked -received
32:25
precludes
7:4 9:14,
16:19
10:11
picked
16:16
15 13:5
17:15
questions
21:18
preference
18:11
20:17, 19,
19:10
40:19
23:14,24
20,21
Plaintiff
31:12
21:3 24:6
3:12 9:20
premature
33:5,19
28:23
R
14:11
37:8,19
29:5 30:6
producing
17:13,14
prematurely
31:6
32:6
raise
20:21
11:17
36:10
32:17
21:19,23
product
38:15,16,
38:13
27:2
prepare
38:17,22
23 41:5
35:15
38:4,5,7
raised
production
pull
36:20
prepared
24:8
14:2
18:16
Plaintiff's
17:13
raising
3:6,8
prolong
purpose
10:6,10
presupposes
4:24
26:18,20
29'2
16:10,11rate
29:5,20,
35:25
proof
36:24
prior
7:19,21,
25
pleadings
4:6 21:6
22 32:11
purposes
read
9:2
37:123:19
15:23
14:3
proposal
pled
privilege
40:4
pursuant
reading
11:19
39:214:22
27'20
23:16
proposed
privileged
40:23
29:4 31:7
ready
point
39:2
38:16
41:12
19:18
protective
28:9 36:3
problem
3:7 4:1,
pursuing
reason
34:18
4,7,9,10,
16:24
4:3 5:17,
position
34:2,4,6
proceeding
12 5:22
put
20 18:20
35:7
32:7
6:9 21:15
24:16
33:23
42:3
27:12
35:13,14
37:3,7
Proceedings
provide
29:9 41:8
reasonable
possessed
3'1
6:18
42:20
7:10 8:10
14:13
process
11:20
12:5,18
possession
34:25
provided
Q
18:19
30:10
39:23
10:13
reasonablan
possibly
produce
14:9,10
quashed
ass
32:3
8:18,24
18:6
6:23
15:17
9:23
potential
13:11
providing
question
receipts
39:10,20
17:2,14
20:17
12:14
31:25
practice
24:7
public
13:20
32:1
20:25
27:5,24
3:24 4:5,
16:5 36:1
received
35:18
21 6:14
39:3
3:7,9
practices
37:1241:1,17
B:6 10:4
10:1,14
22:3
produced
14:9
questioning
11:2
ESQUIRE 800.211.DEPO (3376)
6 0 l Y i 1 0 X 9 EsquireSolutions.com
PROCEEDINGS
CG ACQUISITION vs. TOWN OF GULFSTREAM
15:3,6,8
16:7,10
18:2,12
19:11
21:3,4
2 9: 3
record
14:3
36:10
records
3:24 4:5,
21 6:14
7:18 8:6,
25 10:5
14:9,14
16:19
17:14,16
20:17,19,
21 21:3
23:13
24:6
27:16
28:24
29:5 30:7
32:6
35:14
38:16,17,
23 41:5
redacted
38:18,22
redactions
38:15
referenced
42:2,4
refers
30:18
reflect
38:22
refusal
11:20
refute
21:5
relate
24:22,23
26:10
31:22
33:18
related
25:8 27:7
29:22
31:3,16
41:2
relates
31:14
36:8
relating
10:2
relation
35:20
relationshi
p
36:20
relevance
15:22
36:11
relevant
28:21
relief
20:15
22:21
23:3,9
24:2,10,
15 25:1
remain
8:1
remedy
23:4
replete
27:2
replied
7:17
represent
21:11
representat
ive
4:2 5:2,
4,7,18
6:5
21:19,22
27:5,12,
14,20
representin
g
41:5
request
3:25 4:22
6:11,14
7:5 12:1
14:2,9,
10,16
16:18
17:12
19:16
24:1
25:20
28:24
29:5 30:7
31:7,9,23
32:6
33:4,8
34:3,5
35:5
38:16
requestor
6:16,21
requestors
41:6
requests
8:6 10:5
19:11
21:3
23:21
28:25
35:22
36:10
38:1
resolution
June 16, 2015
Index: record -scope
29:4
respect
20:17
Respectfull
y
42:6
respond
8:22
10:22
14:15
responded
10:23,25
11:19,21
23:25
response
3:9 7:8,
10 8:5,11
9:4,9,16,
19,25
10:12
11:4,15,
25 12:4
13:19,24
14:8
15:9,17
16:20
17:11,12,
21 18:2,
19 19:3,
8,14,25
27:10,16
28:17
33:4
responses
5:14
responsive
14:14
17:14
30:1,6,12
31:11
33:15
rest
4:22
result
4:15
retainer
36:23
retention
36:21
revenue
32:17
review
35:4,16
38:24
39:21
42:24
reviewed
42:23
reviews
38:18
revise
33:12
Ring
5:11
21:21
27:13,24
28:4
Robert
42:5
Roeder
41:23,24
42:6
Roeder's
42:8
rush
40:11
s
scenario
5:1
scope
5:24
OESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
PROCEEDINGS
CG ACQUISITION vs. TOWN OF
GULFSTREAM
June 16, 2015
Index: seek -Taylor
seek
similar
27:25
stuff
25:1
4:8 8:8
12:13
T
start
33:13
simple
3:11
15:20
seeking
3:24 4:4,
26:21
24:13
table
5:3 19:7
5 19:18
subject
15:12
stated
23:10,14
simply
13:25
30:8 32:7
talking
seeks
4:22
submit
10:15,16
states
4:1
32:18
11:17
39:19
7.17
send
single
12:7
taped
stating
38:22
12:11,13,
21:15
41:8
13:6
39:4,7
15 15:18,
situations
40:22
Taylor
25 39:23
statute
40:5
4:13
12:6,19
submits
3:13,19,
41:12
sort
18:1427:15
23 5:8,
42:10
18:24
19:15
16,20
30:10
submitted
6:3,6,8
sense
36:24
Statutes
39:3
7:14,24
40:10
24:11
subpoena
8:2,12,15
separately
sou ht
g
stipulate
6:22 26:2
9:7,10
3:21
29:1
9:3 14:14
10:9,17,
sounds
15:2
suggest
19 11:7,
September
35:2
37:11,15
39:22
13 12:22
4:8,16
39:13
suggested
15:2,24
22.12
stipulating
16:5,14,
8:4 9:2
set
source
12:24,25
17 17:4,
41:9
29:3
stipulation
suggests
gg
22 18:1,8
42:8,25
specific
9:6 14:7
33:6
19:6,17
6:21
15:4
summary
20:7,9
setting
18:15
20:10
21:6
21:12
42:19
32:14
24:21
27:10
22:1
short
apecificall
25:2,4
support
23:11,23
8:6 10:3
26.25
24:9,19
41:20
y
28:10
17.7
26:19
6:17
36:4,12
33:3,14,
29:18,23,
show
19:1,15
18 39:11
24 30:15,
32:12,21
21:18
stipulation
supporting
16,18
35:6
speed
s
3:20
32:1,5,10
showing
40:14
13:25
33:6,11
34:1
supposed
17:6
34:7,12,
end
s pend
28:3
19:21
Stream
16,18,21
33:1
9:19 20:1
Sweetapple
35:12
33:1
sign
22:4
39:7 42:5
36:4
40:1,24
spent
32:12,1537:1,9,14
Sweetapple'
32.23
35:17
38:11,13
significant
spokesman
41:15,22
s
38:21
40:23
17:16
41:24
ESQUIRE 800.211.DEPO (3376)
Esquire Solutions. com
PROCEEDINGS June 16, 2015
CG ACQUISITION vs. TOWN OF GULFSTREAM Index: Taylors -William
42:12,15
43:2
Taylor Ia
25:13
26:7
tecum
25:11
26:2
tee
21:13,16
telling
9:6 15:16
16:17
18:25
21:20
22:25
24:14
tells
25:15
Ten
34:16,17,
20
terms
8:10 10:6
34:25
39:4
thing
15:25
18:24
23:12
25:10
36:25
41:11
things
24:15
32:2,23
4 0: 12
thinking
21:19
31:1
thought
14:1 40:9
thumb
41:7
time
8:7,22
10:3,4
12:21
13:18
17:16
18:13
21:3 33:7
4 0: 22
timeliness
9:11,12,
25 10:12
13:1
19:4,5,25
2 0: 3
28:16
timely
7:9 9:16,
20 10:22
12:5
13:19
14:9,16
16:7,11,
13 17:2
18:20
19:8
timing
7:9 8:11
15:10
today
4:12
19:22
22:20
24:2,3,14
26:4
37:15
40:21
told
10:23
21:12
30:23
topica
25:6,15,
17 26:8
28:13
totality
19:3
39:18
Town
3:2,6,17
7:6 8:21
14:15
16:6,25
17:1,12
18:4,17
21:1,2
22:4
23:1,6
29:3
41:22
Town's
11:15
14:8
17:11
2 0: 16
trace
29:3
tracked
35:8
transcripts
22:18
transfer
33:2
trial
7:23
true
9:13
truthful
23:22
24:5
turned
22:6
30:13
U
umbrella
36:6
understand
7:2 9:22
15:1
34:25
39:13,25
40:1,3
understands
ble
22:2
understandi
ng
7:5
Understood
16:4
34:12
unlawful
11:20
33:25
unreasonabl
e
15:9 20:6
23:20
34:4
unreasonabl
y
7:11
unredacted
38:19
untimely
9:4,9
11:3
V
valid
10:10
vice-
president
5:11
27:13
video
42:2,21
violated
37:6
violating
24:11
volume
23:20
W
wait
12:19
28:2
40:17
41:16
waited
12:17
waiving
9:3 15:8
19:2
walk
25:6
walked
31:19
week
18:23
19:11
21:5 42:7
weeks
11:25
12:4,18,
19
whatsoever
22:8
William
ESQUIRE 800.211.DEPO (33 76)
6 0 1 U 1 0 X 5 EsquireSolutions.com
PROCEEDINGS June 16, 2015
CG ACQUISITION vs. TOWN OF GULFSTREAM Index: withholding..zoning
5:11
withholding
33:25
words
7:9 18:16
work
38:17,22
works
39:23
40:19
wrong
25:10
Y
years
6:17
zoning
35:3,16
ESQUIRE 800.211.DEPO (3376)
6 0 L U. 1 0 M, Esquire Solutions. com