HomeMy Public PortalAboutMorgan Transcript excerpt 5/25/161
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 9:14-CV-81250-KAM
MARTIN E. O'BOYLE,
Plaintiff,
V.
ROBERT A. SWEETAPPLE and MAYOR
SCOTT MORGAN,
Defendants.
- - - - - - - - - - - - - - - x
EXCERPT OF PROCEEDINGS
DEPOSITION OF SCOTT MORGAN
TAKEN ON BEHALF OF THE PLAINTIFF
Wednesday, May 25, 2016
Daughters Reporting, Inc.
1515 North Federal Highway
Suite 300
Boca Raton, Florida 33432
9:30 a.m. - 5:45 p.m.
Reported by Felecia Curreri, RPR
Notary Public, State of Florida
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 APPEARANCES ON BEHALF OF THE PLAINTIFF
2 Martin E. O'Boyle, Pro Se
1280 West Newport Center Drive
3 Deerfield Beach, Florida 33442
Michelle Baez, Esquire
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APPEARANCES ON BEHALF OF THE DEFENDANT SWEETAPPLE
Cole, Scott & Kissane
1645 Palm Beach Lakes Boulevard
Second Floor
West Palm Beach, Florida 33401
BY: JOSHUA A. GOLDSTEIN, ESQUIRE
Tel: 561-681-5523
Email: Joshua.Goldstein@csklegal.com
APPEARANCES ON BEHALF OF THE DEFENDANT MORGAN
Johnson, Anselmo, Murdoch, Burke,
Piper & Hochman, P.A.
2455 East Sunrise Boulevard
Suite 1000
Fort Lauderdale, Florida 33304
BY: JEFFREY L. HOCHMAN, ESQUIRE
Tel: 954-463-0100
Email: hochman@jamgg.com
Also Present:
Chris O'Hare
Robert Sweetapple
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
FA
9
1 THE COURT REPORTER: Do you swear or
2 affirm that the testimony you are about to
3 give will be the truth, the whole truth, and
4 nothing but the truth?
5 THE WITNESS: Yes.
6 Thereupon --
7 SCOTT MORGAN
8 was called as a witness by the Plaintiff and,
9 having been first duly sworn, testified as follows:
10 DIRECT EXAMINATION
11 * * * * *
12 BY MR. O'BOYLE:
13 Q. There's a plethora of information in this
14 RICO complaint. As you can see, it's probably over
15 an inch thick. The pieces to this. They couldn't
16 have come from you, they couldn't have come from
17 your lawyer, lawyers, but they had to come from a
18 third -party who then related to you or to your
19 lawyers. Had to come.
20 If I'm wrong, you'll correct me. That
21 person that I said had to come from them, who was
22 that, if there was somebody?
23 A. I don't know what you mean by pieces and
24 I've already told you that I don't think I'm going
25 to answer any other questions on the RICO case. I
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 believe that we've covered that which I think may
2 in some way be responsive to questions you have on
3 this particular action, and I'm very uncomfortable
4 about further questioning on the details of an
5 ongoing RICO litigation.
6 Q. I hear you, but this, the RICO litigation,
7 is very much a part of the litigation that we're
8 here this morning.
9 MR. HOCHMAN: Mr. O'Boyle, did you also
10 notice the other lawyers, that the witness
11 mentioned, in your notice of taking this video
12 deposition?
13 MR. O'BOYLE: I'm sorry, did you -- what
14 was that?
15 MR. HOCHMAN: The witness indicated that
16 he was uncomfortable talking about the RICO
17 lawsuit because his attorneys in that matter
18 were not here. And now my question to you
19 was, have a copy of your notice, which looks
20 like it was issued on May 18, 2016, issued by
21 you for Scott Morgan's deposition today which
22 is Wednesday, May 25, and I've looked at the
23 service list and it does not have any other
24 lawyers that were noticed for the deposition.
25 Is this the valid notice or did you
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Fort Lauderdale, Florida 954-755-6401
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1 actually provide notice to any other lawyer?
2 MR. O'BOYLE: I can't answer you. My
3 office -- my office handled that. I assume it
4 was done appropriately. But if it's not done
5 appropriately and you want to try to have it
6 set aside, then do it.
7 MR. HOCHMAN: I'm just asking you a
8 question whether or not any other lawyer,
9 besides my office and Mr. Goldstein's office,
10 was notified about potential questioning of
11 this witness about the RICO matter.
12
MR.
O'BOYLE:
Why don't you ask them and
13
let's go
on with
the deposition.
14
MR.
HOCHMAN:
Well, they didn't issue the
15
notice,
you did.
16
MR.
O'BOYLE:
I understand.
17
MR.
HOCHMAN:
I just want to confirm no
18
other lawyer
was noticed, correct?
19
MR.
O'BOYLE:
I'm -- first of all, I don't
20
know, and
if I did,
I wouldn't answer it
21
anyway.
22
MR.
HOCHMAN:
Okay. Thank you.
23
BY MR.
O'BOYLE:
24
Q.
The RICO
complaint,
we just can't get that
25
off of
our mind,
isn't that
a stinger missile
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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2
3
4
5
6
7
8
9
10
I
shooting a fly?
MR. HOCHMAN
THE WITNESS
Mr. O'Boyle.
BY MR. O'BOYLE:
Objection to form.
I don't know what you mean,
Q. Okay. A public records case is a -- I
don't want to underestimate the importance of it,
but it's a nothing kind of case compared to a RICO
case. A typical public records case, except for
the Town of Gulf Stream, usually runs 12 to 1500,
11 in that area, $2,000, depending. In this case,
12 when I say in this case, in the RICO case, which,
13 as you announced, the whole basis of it was to
14 eliminate the thousand cuts and have one suit
15 that's gone on, sort of put everything else in the
16
corral. That's the way I took it,
meaning this
17
RICO suit is
going to
get rid of all
these other
18
suits and we're
going
to get all of
our money back
19
and life is
good. Do
you remember
saying anything
20
at all like
that?
21
MR.
HOCHMAN:
Objection to
form.
22
THE
WITNESS:
I certainly
take issue with
23
the way
you phrase
that entire
colloquy or
24
soliloquy,
I guess,
is the way
to describe it.
25
The
RICO action
was a way
of dealing with
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1 wrongful abuse of public records filings and
2 public records lawsuits to end, not only the
3 ones that were filed, but the ones to be filed
4 in the future, which we were at risk, not only
5 to us, but to all municipalities, municipal
6 contractors throughout the state, as I have
7 explained, and which I think is detailed in
8 the complaint.
9 The purpose is not to stop public records
10 requests or public records lawsuits, the
11 purpose of the RICO was because what had been
12 identified was a criminal activity, an
13 enterprise designed to defraud and extort
14 money from municipalities and contractors that
15 was in excess of that to which they would
16 statutorily, as a plaintiff, be entitled and
17 that money would be funneled back through a
18 group of organizations and individuals that
19 primarily you oversaw and from which you and
20 others would profit.
21 That's the basis of RICO. That is the
22 racketeering in RICO and I do believe that.
23 It's not to stop public records requests, it's
24 to stop your criminal activity.
25 MR. HOCHMAN: Madam Court Reporter, can I
Daughters Reporting, Inc.
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1 have a, rather than order the entire
2 transcript, I want a couple of pages before
3 the question and the response.
4 Thank you.
5 + +
6 BY MR. O'BOYLE:
7 Q. Okay. And, again, I don't want to -- I
8 want to get through the deposition, but if you
9 continue this, we'll have to -- we'll have to
10 cease.
11 Does rule of law prohibit any number of
12 public records suits to be filed?
13 MR. HOCHMAN: Objection to form.
14 MR. GOLDSTEIN: Join.
15 THE WITNESS: I don't know.
16 You're asking is there a law against
17 filing public records requests?
18 BY MR. O'BOYLE:
19 Q. A number of them. As an example, if I
20 filed 10,000 of them with the Town of Gulf Stream,
21 is that okay?
22 MR. HOCHMAN: Objection to form.
23 THE WITNESS: It may or may not be okay.
24 You blend your questions together and I've
25 already explained why your actions in
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 connection with many of the public records
2 lawsuits you've brought are unlawful.
3 So, again, we're engaging in some sort of
4 speculation, but I am not aware of a law and
5 I'm not a Florida lawyer, but I'm not aware of
6 a law that puts a limit on public records
7 lawsuits.
8 BY MR. O'BOYLE:
9 Q. Would it be correct to say that if someone
10 filed 10,000 requests this afternoon, that it would
11 be done without issue? When I say without issue,
12 from the Town's point of view, they would just, I
13 guess, have intake and whatever their process is
14 and then they would begin to fulfill them?
15 MR. HOCHMAN: Objection to form. That was
16 asked and answered.
17 THE WITNESS: You've asked me that
18 question. I've answered that question.
19 BY MR. O'BOYLE:
20
Q. Let's
go with
a hundred
thousand.
21
MR.
HOCHMAN:
Objection
to form.
22 THE WITNESS: I'm going to say it one more
23 time, Mr. O'Boyle, and then I will refer back
24 to the transcript any time you ask it again.
25 The Town of Gulf Stream, as most other
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 municipalities,
I believe
all municipalities
2 in Florida, have
policies
in place by which
3 they respond to
public records
requests.
4 Whether you file
or someone
else files one or
5 a dozen or more,
those are
responded to per
6 the policy.
7 BY MR. O'BOYLE:
8 Q. Okay. But that, I don't think, addressed
9 a hundred thousand that I just mentioned.
10 MR. HOCHMAN: Objection to form; asked and
11 answered.
12 THE WITNESS: I think it did.
13 BY MR. O'BOYLE:
14 Q. Okay. Madam --
15 A. It's not up to the -- it's not up to the
16 municipality to say here is a number that's
17 acceptable, here is a number that's not acceptable.
18 Municipalities respond to public records requests.
19 However, as was evident here, if there is evidence
20 of fraud, extortion, other racketeering activities,
21 which there was, then the Town, which is using
22 public money to respond to public records requests,
23 to defend public records lawsuits, then it is our
24 responsibility as a Town to defend against that
25 criminal abuse. So there's two separate things
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 going on.
2 Q. I still -- and maybe my hearing is worse
3 than I thought, but I still have not heard how the
4 actions of Martin O'Boyle, Christopher O'Hare,
5 William Wright, Jonathan O'Boyle --
6 THE COURT REPORTER: Can you slow down,
7 please?
8
Q.
MR. O'BOYLE: I'm sorry.
9
word used by the
MR. HOCHMAN: And also before he rephrases
10
the
question, I'd like another expert which
11
was
the question that was posed to him about
12
the
number of public records requests about
13
two
pages ago, and then the witness's
14
response, please.
15
That will be excerpt number two.
16
17 BY MR. O'BOYLE:
18
Q.
Extortion seems to
be a
word used by the
19
Town.
What does extortion
mean?
20 A. Again, I can't give you a dictionary or
21 Blacks Law Dictionary of it or even a statutory
22 definition, but in my mind, extortion is what your
23 organizations and your enterprises have been doing,
24 that is, you were filing public records requests
25 and lawsuits in a fashion that was designed to
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 create an
issue where there
would
be a failure to
2 comply or
a delay to comply
or in
some other way --
3 I believe
Chandler described
it as
a kill shot that
4 is almost a guarantee failure that would allow a
5 threat or a filing of a lawsuit and then you could
6 try to secure amounts of money in excess of that
7 which would be statutorily permitted under the
8 threat of a lawsuit or a barrage of public records
9 requests for a barrage of lawsuits, but all
10 designed to obtain the illegal fee. That's how I
11 in interpret the extortion definition relative to
12 you. That may not be an exact definition.
13 MR. HOCHMAN: Can I have an excerpt of
14 that set of question and answer as the third
15 excerpt I am requesting?
16
17 BY MR. O'BOYLE:
18 Q. And Mr. Richman said that all the lawsuits
19 are nothing more than vehicles to extort fees; do
20 you agree with that?
21 MR. HOCHMAN: Objection to form.
22 Specificity.
23 THE WITNESS: I gave you what I say and I
24 have said it multiple times today and, that
25 is, those lawsuits are a part of a criminal
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 enterprise that went beyond Gulf Stream across
2 the state, went beyond the Town of Gulf Stream
3 to municipalities and contractors across the
4 state, and it was designed to extort, not just
5 fees, but fees in excess of that which is
6 allowed under law.
7 MR. HOCHMAN: I'd ask for another excerpt,
8 please, I guess number four.
9 + * +
10 BY MR. O'BOYLE:
11 Q. As I understand the law, and I'm not a
12 lawyer, I'm a layman at best, you need to have
13 authority from the commission or the commission has
14 to vote and authorize somebody to take action,
15 otherwise it would be willy-nilly, correct?
16 A. I don't believe that's correct.
17 Q. Okay. Tell me what's wrong, where I went
18 astray.
19 A. The Town takes many actions without
20 commission directive, so your statement is
21 inaccurate.
22 Q. Have you ever looked at your charter?
23 A. I don't know if I have.
24 MR. HOCHMAN: I'm sorry, Mr. O'Boyle,
25 what's going too fast for you?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1
MR. O'BOYLE: My heart.
2
MR. HOCHMAN: I don't understand.
3
MR. O'BOYLE: Okay.
4
BY MR.
O'BOYLE:
5
Q.
Freda Defasi, do you remember her?
6
A.
I believe Freda was one of the clerks at
7
the Town
of Gulf Stream.
8
Q.
And?
9
A.
And what?
10
Q.
You said was.
11
A.
She's no longer there.
12
Q.
Okay. Do you know where she is?
13
A.
I do not.
14
Q.
Okay. And Kelly Avery is the one there
15
now, correct?
16
A.
She is a clerk at --
17
Q.
Pardon?
18
A.
She's a clerk for Gulf Stream Town, yes.
19
Q.
Well, she thinks she's an accountant, but
20
maybe
that's what she thinks.
21
MR. HOCHMAN: Let me move to strike the
22
statement as not a question.
23
MR. GOLDSTEIN: Joined.
24
BY MR.
O'BOYLE:
25
Q.
Has Joel Chandler ever told you, and when
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 I say you, anyone in the Town, either you or
2 others, that you might have notice of -- that it
3 was a bad thing to file a RICO suit against Chris
4 O'Hare?
5 MR. HOCHMAN: Objection to form.
6 THE WITNESS: He has not told me that.
7 BY MR. O'BOYLE:
8 Q. Do you know if he's told anyone that?
9 A. I don't know.
10 Q. Do you remember Chris O'Hare showing up at
11 the commission meeting with a letter written by
12 Joel Chandler saying Chris is a great guy, he's
13 done absolutely nothing wrong, and these are my
14 words now, turn him loose; do you remember?
15 A. I recall a letter to some affect of that,
16 yes.
17
Q.
Why didn't
you turn him loose?
18
A.
I'm sorry?
19
Q.
Why didn't
you say, you know, Joel is the
20
one who had
the most
knowledge early on, or at
21
least he
claims to,
he doesn't want Chris to be --
22
he doesn't
want any
more pain to be inflicted upon
23
Chris and
I thought
he made a very warm plea to the
24
commission
and the
commission, I assume, has never
25
taken any
action on
that; would that be correct?
Daughters Reporting, Inc.
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1 MR. HOCHMAN: Objection to form; compound.
2 MR. GOLDSTEIN: Joined. Nor did I see the
3 relevance of this line of questioning.
4 THE WITNESS: Taken action on what?
5 BY MR. O'BOYLE:
6 Q. On the letter.
7 Example. If I send you a letter, I might
8 say something and you do nothing about it, that
9 means you didn't take any action on it.
10 A. I don't recall specifically, but I believe
11 the letter was either read or it was -- a copy
12 given to the commissioners, each of them. I don't
13 recall. Some action was taken.
14 Q. What would that action have been?
15 A. It would have been read.
16 Q. Mr. O'Hare would have read it?
17 A. I don't recall if he read it or provided
18 copies to the commissioners to read it. I vaguely
19 remember something like a letter, as you described.
20 Q. Okay. The public records requests. It
21 seems to me that the Town is spending a literal
22 fortune and it reminds me of killing a fly with a
23 stinger missile and I'm talking about the RICO suit
24 as applies to records requests.
25 Have you or other members of the Town
Daughters Reporting, Inc.
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1 commission ever got together and said we got to
2 figure a way to resolve this, we're spending too
3 much of the taxpayers' money, we have to figure a
4 solution, otherwise, of course, it goes on for
5 hundreds of years? Did the commission ever discuss
6 this at all?
7
MR.
HOCHMAN: Objection to form.
8
MR.
GOLDSTEIN: Joined.
9
THE
WITNESS: Well, there were a couple of
10
comments
and questions in that question. The
11
commissioners,
as you know, can only get
12
together
at the commission meeting and the
13
issue of
litigation has come up several times
14
and has
always been, I believe, unanimously
15
voted in
support of the defense and the RICO
16
action as
they presently sit. So, yes, it has
17
been considered
in those meetings.
18 BY MR. O'BOYLE:
19
Q. And rejected?
20
A. Well, what was
rejected? No,
it was
21
supported to continue
the defense of the
actions
22
filed against the Town
to continue the
RICO action,
23
which is an action by
the Town against
others.
24
MR. HOCHMAN:
Mr. O'Boyle, I'm going to
25
ask you for a one -minute break. I
have a call
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 from my home about my meeting at 5 o'clock, so
2 I need to just take one minute off the record.
3 (A brief recess was taken, after which the
4 following proceedings were had:)
5 MR. HOCHMAN: Sorry for the interruption.
6 We're back on the record.
7 MR. O'BOYLE: Counsel, as you know, when
8 we go off the record and on the record, it
9 requires both sides to do so.
10
MR.
HOCHMAN:
I'm not aware of that.
11
MR.
O'BOYLE:
Okay.
12 MR. HOCHMAN: I was just making a
13 statement for the record that we're back on
14 the record. If you disagree then, if you want
15 to go back off the record, we can.
16 MR. O'BOYLE: No. No, I don't want to,
17 but --
18
MR. HOCHMAN:
It was really just to help
19
the court reporter
know whether or not she
20
should be typing or
not. Really it was only
21
with respect to the
court reporter so she
22
knows her function,
rather than trying to
23
control the proceedings.
It was really just a
24
communication, a clarification
for her.
25
MR. O'BOYLE:
I appreciate the lesson.
Daughters Reporting, Inc.
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1 BY MR. O'BOYLE:
2 Q. Who is the town attorney or town council
3 or town solicitor? I don't know what the proper
4 term is. Is it the Sweetapple firm or
5 Mr. Sweetapple? Is it the Jones or Jones Foster
6 firm or Mr. Randolph or is it the Richman Greer
7 firm or Mr. Richman?
8 MR. HOCHMAN: Objection to form.
9 MR. GOLDSTEIN: Joined.
10 THE WITNESS: Did you say town attorney?
11 BY MR. O'BOYLE:
12 Q. Yes.
13 A. For what?
14 Q. Isn't there a town attorney?
15 A. Well, that's a pretty broad term. Our
16 municipal attorney, the one who attends our ARPB
17 and commission meetings, assists with municipal
18 matters, ordinance drafting and the like, would be
19 Jones Foster, John Randolph or Tom Baird, I
20 believe, do most of that work.
21 Q. Which one of the three, Foster, Baird or
22 -- Jones Foster, Tom Baird or Skip Randolph, which
23 one of the three?
24 A. Which one of the three what?
25 Q. Are the town, whatever you call it, town
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1 attorney, municipal attorney, whatever you called
2 it.
3 A. Well, you have a law firm and attorneys
4 within the law firm will provide different
5 services. You, I believe, asked to know who the
6 municipal attorney, if you will, so I can
7 distinguish that type of attorney from a litigation
8 attorney, insurance defense attorney, like
9 Mr. Hochman, and others.
10 Jones Foster would be the municipal firm
11 from which Mr. Baird and Mr. Randolph provide the
12 services of attending our meetings and doing what I
13 call municipal general work, which is ordinance
14 drafting, assistance in that regard, if that's what
15 you are asking.
16 Q. Well, what I'm asking is, who is the, and,
17 again, I might not be using the proper phrase, I'm
18 just going to use town attorney. I know you used a
19 different term, municipal attorney. Who is the
20 town attorney for Gulf Stream?
21 A. I think you just asked me that three times
22 and I think I've just tried to explain it to you
23 three times.
24
Q.
I'm
a
little
slow.
Please indulge me.
25
A.
Mr.
O'Boyle,
I just
told you several
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1 seconds ago that we have a number of attorneys. We
2 went through this at the beginning of the
3 deposition. We have Jones Foster, we have
4 Sweetapple Varkas, Richman Greer, Weiss Serota, I
5 mentioned the other one in Gary Resnick's firm.
6 So when you say town attorney, I think you
7 need to be more specific. I thought you were
8 talking about the attorneys who advise the Town on
9 what are commonly known as municipal matters,
10 differentiating them from litigation or other type
11 matters, but perhaps I misunderstood you.
12
Q. The
day you
were sworn in, was the town
13
attorney and,
again,
I'm not sure I'm using the
14
same phrase,
but I think
we know what each other
15
means, was the town attorney
Skip Randolph,
16
Mr. Sweetapple
or Mr.
Richman?
17
MR.
HOCHMAN:
Objection to form.
18
THE
WITNESS:
The law firm that
19 represented the Town was Jones Foster.
20 Mr. Randolph, who was the primary attorney
21 providing the municipal, as I described,
22 services. Mr. Randolph would often bring in a
23 different lawyer, if he felt that expertise
24 was required.
25 So I'm not quite sure what you mean by
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1 town attorney because we have so many
2 different attorneys, but I'm trying to give
3 you an explanation of the Jones Foster law
4 firm which provides those municipal services
5 and also litigation services.
6 BY MR. O'BOYLE:
7 Q. When you were sworn in, was there any
8 other attorney there for that particular meeting
9 other than Mr. Randolph? And when I say -- I don't
10 mean out in the audience, I mean with the
11 commissioners.
12 A. I don't believe so.
13 Q. Okay. The next meeting, which would be a
14 month later, was there any other attorney besides
15 Mr. Randolph?
16 A. I don't recall whether it was Randolph,
17 Baird or neither.
18
Q.
Okay. And you were on the ARPB before
19
that, correct?
20
A.
That's correct.
21
Q.
And when
you were
on the ARPB, who was,
22
I'm going
to say,
the town
attorney, but the lawyer
23
who was
up on the
dais and
sat at the far end, I
24
guess it
would be
the west
end, who was the
25
attorney
there?
Daughters Reporting, Inc.
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1 A. Which meeting?
2 Q. Anyone. Most of them.
3 A. Most of them, the Jones Foster lawyer who
4 would attend the ARPB meeting was Skip Randolph.
5 Q. Okay.
6 A. Occasionally it would be someone else.
7 Q. Okay. Well, was the town lawyer Skip
8 Randolph or Jones Foster?
9 A. I'm not going to answer that question
10 again, I've answered this question multiple times
11 for you, Mr. O'Boyle.
12 Q. No, sir, you have not.
13 A. I just told you that we have multiple law
14 firms and lawyers providing services for the Town
15 of Gulf Stream. I went through those law firms. I
16 went through some of the services that they
17 provide.
18
Q. Okay.
But you
didn't answer my question.
19
MR. HOCHMAN:
I'm going to ask for another
20
excerpt now.
This
is going to be the fifth
21
excerpt now.
It's
going to start about ten
22
pages back when he
originally asked the
23
question of
who is
the town attorney, all
24
those pages
through
here when the witness gave
25
his answer.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 (The deposition concluded at 5:45 p.m.)
2 CERTIFICATE OF OATH
03
4 THE STATE OF FLORIDA
5 COUNTY OF PALM BEACH
6
7 I, Felecia Curreri, Registered
8 Professional Reporter, Notary Public, State of
9 Florida, certify that SCOTT MORGAN personally
10 appeared before me on the 25th day of May, 2016 and
11 was duly sworn.
12
13
14 Signed this 2nd day of June, 201E
15
16 IL C't'CCLM-Qin'
17
24
FELECIA CURRERI, RPR
18 Notary Public - State of Florida
19
20 Accompanied by Counsel
21
22
23
24
25
Jeffrey L. Hochman, Esq.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
25
1 CERTIFICATE OF REPORTER
2
3 STATE OF FLORIDA
4 COUNTY OF PALM BEACH
5
6 I, FELECIA CURRERI, Registered
Professional Reporter, certify that I was
7 authorized to and did stenographically report the
deposition of SCOTT MORGAN; that a review of the
8 transcript was not requested; and that the
transcript, 3 through 23, is a true and complete
9 record of my stenographic notes.
10 I further certify that I am not a
relative, employee, attorney, or counsel of any of
11 the parties, nor am I a relative or employee of any
of the parties' attorney or counsel connected with
12 the action, nor am I financially interested in the
action.
13 The foregoing certification of this
transcript does not apply to any reproduction of
14 the same by and means unless under the direct
control and/or direction of the certifying
15 reporter.
16
D D jh�is 2n day of June, 2016.
17 lX�( Com- UAkPA.,
18
19 Felecia Curreri, RPR
Registered Professional Reporter
20
21
22
23
24
25
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
A
a.m 1:19
absolutely 15:13
abuse 7:1 10:25
acceptable 10:17
10:17
Accompanied
24:20
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anyway 5:21
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Avery 14:14
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18:10
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22:17
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2:1,6,12
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13:16 14:6
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22:12
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call 17:25 19:25
20:13
called 3:8 20:1
case 1:3 3:25 6:6
6:8,9,9,11,12
6:12
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Center 2:2
certainly 6:22
CERTIFICATE
24:2 25:1
certification
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certify 24:9 25:6
25:10
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Chandler 12:3
14:25 15:12
charter 13:22
Chris 2:20 15:3
15:10,12,21,23
Christopher
11:4
claims 15:21
clarification
18:24
clerk 14:16,18
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Cole 2:7
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come 3:16,16,17
3:19,21 17:13
comments 17:10
commission
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15:11,24,24
17:1,5,12
19:17
commissioners
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22:11
commonly 21:9
communication
18:24
compared 6:8
complaint 3:14
5:24 7:8
complete 25:8
comply 12:2,2
compound 16:1
concluded 24:1
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connection 9:1
considered
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continue 8:9
17:21,22
contractors 7:6
7:14 13:3
control 18:23
25:14
copies 16:18
copy4:19 16:11
corral 6:16
correct3:20
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
E
13:16 14:15
15:25 22:19,20
council 19:2
counsel 18:7
24:20 25:10,11
COUNTY 24:5
25:4
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course 17:4
court 1:1 3:1
7:25 11:6
18:19,21
covered 4:1
create 12:1
criminal 7:12,24
10:25 12:25
Curreri 1:23
24:7,17 25:6
25:19
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IM
dais 22:23
DATED 25:16
Daughters 1:16
day 21:12 24:10
24:14 25:16
dealing 6:25
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Defasi 14:5
defend 10:23,24
DEFENDANT
2:6,12
Defendants 1:10
defense 17:15,21
20:8
definition 11:22
12:11,12
defraud 7:13
delay 12:2
depending 6:11
deposition 1:14
4:12,21,24
5:13 8:8 21:3
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describe 6:24
described 12:3
16:19 21:21
designed 7:13
11:25 12:10
13:4
detailed 7:7
details 4:4
dictionary 11:20
11:21
different 20:4,19
21:23 22:2
differentiating
21:10
direct 3:10 25:14
direction 25:14
directive 13:20
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discuss 17:5
distinguish 20:7
DISTRICT 1:1
1:1
doing 11:23
20:12
dozen 10:5
drafting 19:18
20:14
Drive 2:2
duly 3:9 24:11
E
E 1:5 2:2
early 15:20
East 2:14
either 15:1 16:11
eliminate 6:14
Email 2:10,17
employee 25:10
25:11
engaging 9:3
enterprise 7:13
13:1
enterprises
11:23
entire 6:23 8:1
entitled 7:16
Esq 24:20
Esquire 2:3,9,16
evidence 10:19
evident 10: 19
exact 12:12
EXAMINATI...
3:10
example 8:19
16:7
excerptl:12
11:15 12:13,15
13:7 23:20,21
excess 7:15 12:6
13:5
expert 11:10
expertise 21:23
explain 20:22
explained 7:7
8:25
explanation 22:3
extort 7:13
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extortion 10:20
11:18,19,22
12:11
failure 12:1,4
far 22:23
fashion 11:25
fast 13:25
Federal 1:17
fee 12:10
fees 12:19 13:5,5
Felecia 1:23 24:7
24:17 25:6,19
felt 21:23
fifth 23:20
figure 17:2,3
file 10:4 15:3
filed 7:3,3 8:12
8:20 9:10
17:22
files 10:4
filing 8:17 11:24
12:5
filings 7:1
financially 25:12
firm 19:4,6,7
20:3,4,10 21:5
21:18 22:4
firms 23:14,15
first 3:9 5:19
Floor 2:8
Florida 1:1,18
1:24 2:3,9,15
9:5 10:2 24:4,9
24:18 25:3
fly 6:1 16:22
following 18:4
follows 3:9
foregoing 25:13
form 6:2,21 8:13
8:22 9:15,21
10:10 12:21
15:5 16:1 17:7
19:8 21:17
Fort 2:15
fortune 16:22
Foster 19:5,19
19:21,22 20:10
21:3,19 22:3
23:3,8
four 13:8
fraud 10:20
Freda 14:5,6
fulfill 9:14
function 18:22
funneled 7:17
further 4:4
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future 7:4
G
Gary 21:5
genera120:13
give 3:3 11:20
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go 5:13 9:20
18:8,15
goes 17:4
going 3:24 6:17
6:18 9:22 11:1
13:25 17:24
20:18 22:22
23:9,19,20,21
GOLDSTEIN
2:9 8:14 14:23
16:2 17:8 19:9
Goldstein's 5:9
good 6:19
great 15:12
Greer 19:6 21:4
group 7:18
guarantee 12:4
guess 6:24 9:13
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Gulf 6:10 8:20
9:25 13:1,2
14:7,18 20:20
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guy 15:12
H
handled 5:3
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heard 11:3
hearing 11:2
heart 14:1
help 18:18
Highway 1:17
Hochman 2:14
2:16 4:9,15 5:7
5:14,17,22 6:2
6:21 7:25 8:13
8:22 9:15,21
10:10 11:9
12:13,21 13:7
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15:5 16:1 17:7
17:24 18:5,10
18:12,18 19:8
20:9 21:17
23:19 24:20
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2:17
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identified 7:12
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
2
illegal 12:10
importance 6:7
inaccurate 13:21
inch 3:15
indicated 4:15
individuals 7:18
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inflicted 15:22
information
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J
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Joel 14:25 15:12
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Johnson 2:13
Join 8:14
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16:2 17:8 19:9
Jonathan 11:5
Jones 19:5,5,19
19:22 20:10
21:3,19 22:3
23:3,8
JOSHUA 2:9
Joshua.Goldst...
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June 24:14
25:16
K
Kelly 14:14
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20:5,18 21:14
knowledge 15:20
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knows 18:22
L 2:16 24:20
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law 8:11,16 9:4
9:6 11:21 13:6
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21:18 22:3
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lawsuit 4:17
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9:2,7 10:23
11:25 12:9,18
12:25
lawyer 3:17 5:1
5:8,18 9:5
13:12 21:23
22:22 23:3,7
lawyers 3:17,19
4:10,24 23:14
layman 13:12
lesson 18:25
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16:6,7,11,19
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17:13 20:7
21:10 22:5
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longer 14:11
looked 4:22
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loose 15:14,17
Madam 7:25
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Martin 1:5 2:2
11:4
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21:9,11
MAYOR 1:8
mean 3:23 6:3
11:19 21:25
22:10,10
meaning 6:16
means 16:9
21:15 25:14
meeting 15:11
17:12 18:1
22:8,13 23:1,4
meetings 17:17
19:17 20:12
members 16:25
mentioned 4:11
10:9 21:5
Michelle 2:3
mind 5:25 11:22
minute 18:2
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misunderstood
21:11
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7:17 10:22
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month 22:14
MORGAN 1:9
1:14 2:12 3:7
24:9 25:7
Morgan's 4:21
morning 4:8
move 14:21
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23:10,13
municipal 7:5
19:16,17 20:1
20:6,10,13,19
21:9,2122:4
municipalities
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10:18 13:3
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21:7
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never 15:24
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North 1:17
Notary 1:24 24:8
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notes 25:9
notice 4:10,11
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10:16,17 11:12
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3:12 4:9,13 5:2
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6:4,5 8:6,18
9:8,19,23 10:7
10:13 11:4,5,8
11:17 12:17
13:10,24 14:1
14:3,4,24 15:7
16:5 17:18,24
18:7,11,16,25
19:1,1120:25
22:6 23:11
o'clock 18:1
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14:3,12,14
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part 4:7 12:25
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
�1
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Present 2:19
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11:24 12:9
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6:25 7:11,21
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Skip 19:22 21:15
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Specificity 12:22
speculation 9:4
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start23:21
state 1:24 7:6
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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Tell 13:17
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Tom 19:19,22
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19:10,14,25,25
20:18,20 21:6
21:8,12,15,19
22:1,22 23:7
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Town's 9:12
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truth 3:3,3,4
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two 10:25 11:13
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went 13:1,2,17
21:2 23:15,16
west 2:2,9 22:24
William 11:5
willy-nilly 13:15
witness 3:5,8
4:10,15 5:11
6:3,22 8:15,23
9:17,22 10:12
12:23 15:6
16:4 17:9
19:10 21:18
23:24
witness's 11:13
word 11:18
words 15:14
work 19:20
20:13
worse 11:2
wouldn't 5:20
Wright 11:5
written 15:11
wrong 3:20
13:17 15:13
wrongful 7:1
x 1:11
years 17:5
Z
10,000 8:20 9:10
1000 2:15
12 6:10
1280 2:2
1500 6:10
15151:17
1645 2:8
18 4:20
2
2,000 6:11
20161:15 4:20
24:10,14 25:16
23 25:8
24552:14
251:15 4:22
25th 24:10
2nd 24:14 25:16
3 25:8
3001:17
33304 2:15
334012:9
33432 1:18
33442 2:3
5
5 18:1
5:451:19 24:1
561-681-5523
2:10
6
8
9
9:14 -CV -8125...
1:3
9:301:19
954-463-0100
2:16
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
5