HomeMy WebLinkAboutMinutes 06-02-2009CITY COUNCIL REGULAR MEETING
CITY HALL ANNEX
111 Polk Avenue, Cape Canaveral, Florida
TUESDAY
June 2, 2009
6:00 PM
MINUTES
CALL TO ORDER: The Chair called the Meeting to Order at 7 P.M.
ROLL CALL:
Council Members Present:
Mayor Pro Tem
Council Member
Mayor
Council Member
Council Member
Others Present:
City Manager
City Attorney
City Clerk
Recreation Director
Public Works Director
Assistant Public Works Director
Building Official
Planning and Development Director
REPORTS:
City Manager
Bob Hoog
Buzz Petsos
Rocky Randels
Shannon Roberts
Betty Walsh
Bennett Boucher
Anthony Garganese
Susan Stills
Robert Lefever
Walter Bandish
Jeff Ratliff
Todd Morley
Barry Brown
• The City Manager introduced Cocoa Beach Vice Mayor Kevin Pruitt, who provided
some insight on the annual Fourth of July fireworks show in Cocoa Beach. He
conveyed how Cocoa Beach had difficulty obtaining a barge in the past, but they now
have obtained a certified barge. Vice Mayor Pruitt informed that Ron Jon's Surf Shop
will continue to be the premier sponsor. He informed that the City of Cocoa Beach was
attempting to coordinate funding in order to make this a repeatable event.
Vice Mayor Pruitt informed that they currently had $43,000 and he asked the Council if
the City of Cape Canaveral could contribute to this year's fireworks event. Mayor Pro
Tem Hoog offered a personal commitment from Hoog Electric and said that he would
also seek contributions from other organizations too. Mr. Petsos added that all of
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 2 of 17
also seek contributions from other organizations too. Mr. Petsos added that all of
Council should seek contributions. Vice Mayor Pruitt informed that the Cocoa Beach
Commission would make their final decisions on the event at their Commission
Meeting on Thursday, June 4th.
Mr. Petsos asked if he had contacted the Cocoa Beach Area Chamber of Commerce.
Vice Mayor Pruitt affirmed that he did. Vice Mayor Pruitt informed that the City of
Cocoa Beach set aside $15,000 in their previous Budget for this event. Mr. Leo
Nicholas asked if there were any interest in contributing from the Tourist Development
Council. Vice Mayor Pruitt replied that the event, although
it would attract tourists, was mainly a focal point of interest for residents.
Mayor Randels informed how Cape Canaveral also received a request from the City of
Melbourne. Ms. Roberts mentioned that Cape Canaveral residents would enjoy the
fireworks and a contribution from Cape Canaveral would present a branding
opportunity in using the City's name in the headline. Vice Mayor Pruitt responded that
he would need to seek approval from the Commission before adding Cape Canaveral
to the event headline. Ms. Walsh mentioned how people were disappointed last year
that there were no fireworks.
Mayor Pro Tem Hoog pointed out how a central fireworks show in Brevard County
uniting the efforts of Cocoa Beach and the City of Melbourne and others who provide
fireworks events. Mr. Petsos stated that he, like Mayor Pro Tem Hoog, would be
happy to assist with fundraising. Mr. Tom Garboski, of Surf Drive, recommended that
the City provide the funds with the agreement that the event be held in Cape
Canaveral every other year. However, discussion brought out that the area that a
barge would need was not in the City.
Mr. Boucher informed that the Council was at liberty to use money from the General
Fund Reserve Fund; however, he cautioned that the Council would be required to
make some important budgetary decisions in the coming year. Ms. Walsh asked Vice
Mayor Pruitt for the specifics on how someone would make a contribution to the
fireworks event. Vice Mayor Pruitt stated that checks could be made payable to:
Cocoa Beach -Cape Canaveral Fourth of July Fireworks Show mailed to Cocoa Beach
City Hall, ATTN: Fireworks Show, 2 South Orlando Avenue, or donations could be
dropped off at the Cocoa Beach City Hall and obtain a receipt.
Mayor Randels clarified that the City would commit $10,000 with the help of donations
from the residents. Ms. Walsh clarified that Cocoa Beach would need to notify Cape
Canaveral of the difference in the donations received from what was still needed. Ms.
Roberts emphasized the branding opportunity for the Cape Canaveral name to be
included in the event as the Cocoa Beach -Cape Canaveral Fireworks Show. Mayor
Randels restated that the City would commit to the $10,000 with donations from the
residents.
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 3 of 17
Ms. Roberts asked if there would be any problem with the Commission having a jointly -
named fireworks. Vice Mayor Pruitt responded that he would bring up the concept of a
jointly -named event at the Cocoa Beach City Commission Meeting on Thursday, June
4th; however, he said that he did not foresee a problem. In conclusion, Ms. Roberts
replied that funds would not be forwarded to Cocoa Beach unless the Commission was
in favor of receiving the funds based on the jointly -name concept.
A motion was made by Ms. Roberts and seconded by Mayor Randels to Commit
$10,000 for the Cocoa Beach -Cape Canaveral Fireworks Display for the Month of
July 2009. The vote on the motion carried 5-0 with voting as follows: Mayor
Pro Tem Hoog, For; Mr. Petsos, For; Mayor Randels, For; Ms. Roberts, For and
Ms. Walsh, For.
Mr. Boucher distributed the sign -in sheet from the Solid Waste Proposal Pre -
Conference Meeting. There were 14 Vendors in attendance. Mr. Boucher informed
that he would send out an Addendum to the Proposal in the upcoming week and
clarified that his Office was the clearinghouse for all Proposal information. Ms.
Roberts asked if the Vendors thought the requirements were reasonable. Mr. Boucher
replied that they went through the documents page -by -page.
Mr. Boucher asked the Council where they desired to hold the Space Coast League
of Cities dinner next April. Mayor Pro Tem Hoog informed that Ron Jon's Cape
Caribe Resort has a restaurant. Mr. John Grandlich, on behalf of the Ron Jon Resort,
informed that the hotel has a restaurant operated by a tenant; however he could speak
with the owners and obtain their capacity number and provide that information to the
City. The Space Coast League of Cities dinner is scheduled for April 12, 2010. Mayor
Randels asked that Mr. Grandlich notify the City Manager's Office when he gets the
capacity information.
Mr. Boucher distributed a request by Public Works related to three locations that had
Stormwater pipe damage. Jeff Ratliff, Assistant Public Works Director, distributed
photos related to the damage. He explained how the pipe had come apart at two
locations and in two places at one location. Mr. Ratliff stated that they planned to
replace the entire pipe and the inlets on Lincoln Avenue.
MOTION FOR AN ADD-ON ITEM
A motion was made by Ms. Roberts and seconded by Mr. Petsos for an Add -On
Item for Emergency Repairs to Lincoln/ Ridgewood Avenue and Columbia Drive.
The vote on the motion carried 5-0 with voting as follows: Mayor Pro Tem
Hoog, For; Mr. Petsos, For; Mayor Randels, For; Ms. Roberts, For and Ms.
Walsh, For.
• Mr. Petsos asked Mr. Bandish if the pricing from Atlantic Development were in line
with all pricing he found. Mr. Bandish replied that he pursued joint use with the City
of Cocoa and the Town of Indialantic who have standing contracts with Atlantic
Development for repairs. Ms. Roberts asked if there were other anticipated problem
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 4 of 17
areas related to the condition of any other stormwater system in the City. Mr.
Bandish replied that they were aggressively working to televise the lines. Ms.
Roberts said that this brings to mind the Master Stormwater System Plan which she
hoped would provide a broader picture of the condition of the City infrastructure.
Mayor Pro Tem Hoog asked how often these piggyback Bids were reviewed for
comparative pricing. Mr. Bandish replied that he worked with the Town of
Indialantic, City of Cocoa, and City of Rockledge who reviewed their Bids every
three years. Mayor Pro Tem Hoog conveyed that there might be a company who is
in need of the work and could do it at a lower cost. Mr. Bandish assured that Atlantic
Development was a trusted vendor. Mr. Bandish noted that Atlantic Development
were the lowest in pricing for the inlets. Mayor Pro Tem Hoog asked if the City
planned to make repairs in Harbor Heights. Mr. Bandish replied that Public Works is
working on the north -south line and conducting an aggressive investigation of the
main line. Ms. Walsh asked if the City ever negotiated cost estimates with vendors.
Mr. Bandish replied that at times the vendor might reduce pricing; however, it would
depend on the type of work required.
A motion was made by Ms. Roberts and seconded by Mr. Petsos to Perform
the Emergency Repairs for Atlantic Development in the Amount of $38,000.
The vote on the motion carried 5-0 with voting as follows: Mayor Pro Tem
Hoog, For; Mr. Petsos, For; Mayor Randels, For; Ms. Roberts, For and Ms.
Walsh, For.
• Mr. Boucher reminded of the upcoming Workshop between the City Council and
the Sheriffs Office on Tuesday, June 9th beginning at 5:30 P.M.
• Mr. Boucher distributed his reply from the State Attorney's Office related to the
alleged Sunshine Law violation for Mayor Randels and Council Members Roberts
and Walsh. The State Attorney's Office opined that the spirit and intent of the
technical requirements of the Sunshine Law were not followed when the Mayor and
two City Council Members continued to discuss matters that had not completely
resolved within the timeframe of the properly noticed Meeting. The State Attorney's
Office would not, however, issue any sanctions against the Council Members and
advised the Council to refrain from such conduct in the future.
• Mr. Boucher recognized the City Clerk for 15 years of employment with the City.
STAFF
Recreation Director
• Mr. Lefever announced the Movie in the Park for Friday, June 5th, "Hotel for
Dogs."
• Mr. Boucher commended Mr. Lefever on a successful Board Member
Appreciation Dinner on Saturday, May 30th.
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 5 of 17
Public Works Director
• No report.
Assistant Public Works Director
• No report.
Planning and Development Director
• Mr. Brown reported that Space Coast Government Television is currently
broadcasting the First Visioning Workshop Meeting of May 14th. Air Times:
Monday, June 1st, Thursday, June 4 at 8 A.M. and Tuesday, June 9th at 1 P.M.
Air time information is available to the public on the City web site.
• Mr. Brown announced the next Visioning Workshop on Thursday, June 11th at
6 P.M. at the Radisson Resort at the Pavilion Room, west of the Conference
Center.
• Mr. Brown also announced that the new flyer, a television air time schedule,
and a summary of the first Workshop Meeting, with the likes, dislikes, and
comments of the video that was shown at the First Meeting would be available on
the City web site. There will also be a Visioning Workshop outline to provide
more detail about the upcoming Workshops. Mr. Brown announced that he had
flyers available for City Council and the audience.
• Mr. Petsos thanked Mr. Brown and Mr. Morley for the weekly reports that they
supply to the Council.
Building Official
• No report.
City Clerk
• No report.
City Attorney
• No report.
Business & Cultural Development Board Report
• No report.
AUDIENCE TO BE HEARD:
6:30 p.m. — 6:50 p.m.
• Mr. Frank Kuhn addressed the Council saying that based on the information that
he received from the Mayor that the City Manager earns over $150,000 for a City of
1.9 square miles and that supervises six employees. Mr. Kuhn also stated how, at
no time, had he ever heard of an indefinite contract such as that for the City
Manager. Mr. Kuhn also stated that he contacted NASA and he asked how a City
Clerk earns $75,000. Mr. Kuhn stated during his time at work, salaries were done
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 6 of 17
based on the number of people supervised. Mr. Kuhn stated that he could not
believe the salaries the City pays when some people in this City work two jobs to
earn $40,000. Mr. Kuhn stated that the Mayor told him that Cape Canaveral
compared its salaries with Satellite Beach. However, when he called Satellite
Beach, they responded that they were unaware of it. Mr. Kuhn stated that there
were also no other cities that pays as much for Law Enforcement either.
Mr. Leo Nicholas reminded that he had asked at the previous City Council Meeting
about security from the Sheriff's Office at Canaveral Port Authority. He had
heard that the Port was not going to renew the Sheriffs contract this year and he
asked how this would impact the City's financial obligation. The City Manager
replied that the Port has a two-year contract with the Sheriffs Office. The Port was
working to gain better control of some secure areas through private security and
they would probably use the Sheriffs Office for the open areas.
CONSENT AGENDA:
6:50 p.m. — 7:00 p.m.
Motion to Approve: City Council Workshop Meeting Minutes of May 5, 2009
and Regular Meeting Minutes of May 5, 2009 and May 19, 2009.
2. Motion to Approve: Annual Renewal of Professional Services Agreement
with Professional Diversified Services, Inc. for Mowing & Maintenance of
City Landscaped Areas.
3. Motion to Approve: Stormwater Pipe Repairs and Inlet Replacements in the
Amount of $6,350.
4. Motion to Approve: Outdoor Entertainment Permit — Movie at Manatee Park,
Recreation Department.
Ms. Walsh requested to review Item No. 1.
Ms. Roberts requested to remove Items No. 2 and 4.
A motion was made by Ms. Roberts and seconded by Mr. Petsos to Approve
Consent Agenda Item No. 3. The vote on the motion carried 5-0 with voting as
follows: Mayor Pro Tem Hoog, For; Mr. Petsos, For; Mayor Randels, For; Ms.
Roberts, For and Ms. Walsh, For.
Ms. Walsh stated that she reviewed and agreed with the corrections that Ms. Roberts
made to the May 19th Meeting Minutes. Ms. Walsh referred to the Regular Meeting
Minutes of May 5th and requested a verbatim transcript of the first section related to the
Sunshine Law issue. Mayor Randels clarified that the verbatim section in request was
under the City Manager's report related to a Breach in Public Trust up to the Second
bullet which reads, "Staff attended an Economic Stimulus Meeting." Ms. Roberts
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 7 of 17
acknowledged her amendments to the May 5th Meeting Minutes in addition to Ms.
Walsh's request.
Attorney Garganese reviewed for clarification that Ms. Walsh was seeking a verbatim of
the portion of the Meeting which related to the City Manager's allegation of a breach of
Public Trust and not the part which involved the tape that the City Manager played
during that time. Ms. Walsh clarified and affirmed that she was seeking a verbatim of
the discussion which related to the audio only.
Motion to Approve: City Council Workshop Meeting Minutes of May 5, 2009 and
Regular Meeting Minutes of May 5, 2009 and May 19, 2009.
A motion was made by Ms. Roberts and seconded by Mayor Pro Tem Hoog to
Approve the City Council Workshop Meeting Minutes of May 5th and the City
Council Regular Meeting Minutes of May 19th with the Proposed Changes
submitted by Ms. Roberts. The vote on the motion carried 5-0 with voting as
follows: Mayor Pro Tem Hoog, For; Mr. Petsos, For; Mayor Randels, For; Ms.
Roberts, For and Ms. Walsh, For.
A motion was made by Ms. Walsh and seconded by Ms. Roberts for the City Clerk
to Provide a Verbatim Transcript of the May 5th Regular Meeting Minutes — the
First Topic Proposed by the City Manager up to the Second Bullet and to Include
Ms. Roberts Amendments for the Remainder of the May 5th Regular Meeting
Minutes. The vote on the motion carried 5-0 with voting as follows: Mayor Pro
Tem Hoog, For; Mr. Petsos, For; Mayor Randels, For; Ms. Roberts, For and Ms.
Walsh, For.
Attorney Garganese reminded that the May 5th Regular Meeting Minutes would
need to come back to the City Council for approval.
2. Motion to Approve: Annual Renewal of Professional Services Agreement with
Professional Diversified Services, Inc. for Mowing & Maintenance of City
Landscaped Areas.
Ms. Roberts asked Mr. Bandish for feedback from the community since this company
began working with the City. Mr. Bandish replied that the service has been satisfactory
and an enhancement over past service. Ms. Roberts asked if there were any additional
service areas or the same area. Mr. Bandish responded all the same areas.
4. Motion to Approve: Outdoor Entertainment Permit — Movie at Manatee Park,
Recreation Department.
Mr. Lefever affirmed for Ms. Roberts that he distributed notices to the Home Owners
Associations adjacent to Manatee Sanctuary Park prior to outdoor events telling them of
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 8 of 17
when he plans to hold an outdoor event, and he also invites them to come and enjoy the
event.
A motion was made by Ms. Roberts and seconded by Ms. Walsh to Approve Items
No. 2 and 4. The vote on the motion carried 5-0 with voting as follows: Mayor Pro
Tem Hoog, For; Mr. Petsos, For; Mayor Randels, For; Ms. Roberts, For and Ms.
Walsh, For.
ORDINANCE: Second Public Hearing:
7:00 p.m. — 7:15 p.m.
5. Motion to Adopt: Ordinance No. 06-2009; Economic Development Ad
Valorem Tax Exemption.
Attorney Garganese read Ordinance No. 06-2009 by title.
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF CAPE CANAVERAL,
BREVARD COUNTY, FLORIDA; PROVIDING FOR A REFERENDUM ELECTION AND
BALLOT LANGUAGE FOR AN ELECTION TO BE SCHEDULED BY THE CITY
COUNCIL; PROVIDING FOR AN ECONOMIC DEVELOPMENT AD VALOREM TAX
EXEMPTION PURSUANT TO SECTION 196.1995, FLORIDA STATUES; PROVIDING
FOR COORDINATION WITH THE SUPERVISOR OF ELECTIONS; PROVIDING FOR
SEVERABILITY AND AN EFFECTIVE DATE.
Mr. Nicholas asked if this Referendum negates or supersedes any previous
Referendums. Attorney Garganese explained that this would give the City Council
authorization to consider an application to abate ad valorem taxes on a case-by-case,
property -by -property basis for new business and expansions of existing businesses as
those terms are defined in the Florida Statutes for Economic Development. Attorney
Garganese clarified that the tax rate is imposed by Referendum. The maximum ad
valorem tax abatement that could be granted by the City is within ten years, anywhere
from one percent to one hundred percent of the ad valorem taxes that are imposed by
the City on that particular piece of property.
Attorney Garganese conveyed how this could be used to attract new businesses into
the City. He planned to discuss this further under his presentation and how the City
could create a "brown field," or economic incentive development area. This would
complement it in attracting new businesses.
Mr. Tom Garboski, of Surf Drive, asked if these economic development agreements
would be binding. Attorney Garganese explained how the City establishes an ad
valorem tax rate for the City; that rate generates a variable number of dollars for each
parcel of land in the City. A property owner would apply and would take a variable
number of dollars, for example, $10,000 and the City Council for a period of one to ten
years can reduce that tax from $1.00 to up to $10,000. Attorney Garganese explained
that the abatement could not reduce the tax lower than what the property owner was
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 9 of 17
paying [ in taxes] in any particular year. Attorney Garganese replied to Mr. Dunn that
this would not apply to vacation rentals. Attorney Garganese explained how in a new
commercial community it creates ten new jobs at a minimum. The type of business
would need to meet the Statutory requirements.
Ms. Roberts referred to the bottom of Page 2 and expressed her concern that the voter
needs to understand why the Referendum was being proposed. Attorney Garganese
replied that this was a question which under State Law must present the question word-
for-word. Ms. Walsh expressed her appreciation for Ms. Roberts' intent for the voter's
to understand the Referendum, and she also expressed the importance of letting the
residents know that the reason behind the Ordinance was so that the City could
compete for and create jobs here in Cape Canaveral. Attorney Garganese informed
that the Council would have the ability prior to the election to send out information
regarding this question explaining its details. However, depending on how the Governor
adopts further legislation, the Council would not be able to advocate the Referendum.
A motion was made by Mr. Petsos and seconded by Mayor Pro Tem Hoog to
Approve Ordinance No. 06-2009; Economic Development Ad Valorem Tax
Exemption at First Reading. The vote on the motion carried 5-0 with voting as
follows: Mayor Pro Tem Hoog, For; Mr. Petsos, For; Mayor Randels, For; Ms.
Roberts, For and Ms. Walsh, For.
ORDINANCE: First Public Hearing:
7:15 p.m. — 8:15 p.m.
6. Motion to Approve: Ordinance No. 05-2009; Sign Code Ordinance.
Attorney Garganese read Ordinance No. 05-2009 by title.
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF CAPE CANAVERAL,
FLORIDA, ADOPTING A NEW CHAPTER 94, SIGNS, OF THE CODE OF ORDINANCES;
PROVIDING FOR THE PURPOSE AND SCOPE OF THE CHAPTER, DEFINITIONS, THE
REGULATION OF TEMPORARY SIGNS, SIGN APPLICATION, PERMIT, INSPECTION
PROCEDURES, ZONING DISTRICT RESTRICTIONS, SIZE, TYPE AND PLACEMENT
REQUIREMENTS; PROVIDING FOR ENFORCEMENT REGULATIONS; PROVIDING A
STATEMENT OF VIEW POINT NEUTRAL INTENT RELATIVE TO MESSAGES ON
SIGNS; PROVIDING FOR OTHER MISCELLANEOUS AMENDMENTS; AMENDING
APPENDIX B SCHEDULE OF FEES RELATED TO SIGN PERMIT FEES; MAKING
CONFORMING AMENDMENTS TO THE CITY CODE; PROVIDING FOR REPEAL OF
PRIOR INCONSISTENT ORDINANCES AND RESOLUTIONS, INCORPORATION INTO
THE CODE, SEVERABILITY, AND EFFECTIVE DATE.
Mayor Randels clarified that this would make the signs non -content based and considered
for size and location only. Ms. Walsh questioned if the Memo from the Planning and
Zoning Board raised many issue at their March 25th Meeting and she asked if these were
reflected in the revised Draft. Ms. Joyce Hamilton contended that some of the
amendments were not reflected in the Draft, specifically those relating to the height of the
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 10 of 17
monument sign. Mayor Pro Tem Hoog explained that Ms. Hamilton was referring to the
20 -foot maximum height and that the monument would allow the electronic sign and under
the Code, the City limits that to 10 -feet high. Ms. Roberts replied that the intent was to
keep the signage low.
Todd Morley, Building Official, recollected that 10 -feet were suggested as a good size for a
monument sign. Ms. Hamilton stated her recollection that 10 -feet could not be seen over
some of the cars. Mayor Randels asked if Ms. Hamilton desired to see a 20 -foot
monument sign; however, the City Attorney stated that 20 -feet were not what the Local
Planning Agency recommended.
Mr. David Schirtzinger stated his recollection of a maximum height of 20 -feet for an
electronic sign; however, a monument sign was discussed at no higher than 10 -feet.
Mayor Pro Tem Hoog brought out how 20 -feet should stipulate whether it refers to the top
or the bottom of the sign which, based on the measurement, would allow more footage.
Ms. Hamilton referred to Page 1, Third Whereas and Pages 26 through 28, Viewpoint
Neutral, and summarized how this provision eliminated off -premise signs by removing
content. Ms. Hamilton emphasized that the City could not regulate for content; therefore,
the City was allowing a vendor to display advertising content on their premises for another
business off -premises.
Attorney Garganese conveyed that this Code does not regulate viewpoint and content
which means that no regulation would occur based on content. He stated that the City
could look at the content and determine whether it was off -premise and on -premise but the
City could not regulate the sign. Mr. Morley conveyed that the City could only make a
visual assumption that what was advertised relates to the property. Ms. Hamilton stated
that some direction was needed to ascertain if it were an off- premise sign. Attorney
Garganese referred to the bottom of Page 5 for a definition of an off -or -on premises sign.
Mr. Morley explained that content -neutral; and viewpoint -neutral was not regulated until
the City passed the threshold of whether it was related to the property.
Mr. Boucher stated that the signage was regulated based on off -premise, or on -premise.
Mr. Nicholas stated that more clarification was needed because another Building Official
may interpret it differently. Attorney Garganese explained for the Council, referring to the
bottom of Page 5, that there were specific definitions in the Code for on -premise and off -
premise signs, for example:
Attorney Garganese stated that the things to look for would be: 1) if the content of the sign
is identifying an activity conducted on the property, or 2) the products or services that are
sold. Discussion followed on adding additional language to Section 94-115 to clarify what
is expected after Mayor Randels asked Mr. Morley if he could put the procedures that he
follows into a flow chart. Discussion concluded that the definitions were at all times
applicable.
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 11 of 17
Ms. Hamilton referred back to Pages 21 to 28 that the digital signage height should read
20 -feet. Ms. Roberts stated that the intent of the digital signage and the monument
signage was to bring them low. Mayor Pro Tem Hoog referred to a 30 -foot pole sign and
asked how a business could incorporate an electronic sign into that pole sign. Mayor
Randels replied if the sign were reduced to 20 -feet. Attorney Garganese related that pole
signs are prohibited pursuant to 94-6 (aa) unless the City Manager determines because of
physical characteristics that the property can accommodate a monument sign. Ms.
Roberts stated that it was not the City's intent to have tall digital signs. Ms. Walsh pointed
out that there was not a sunset date.
Mayor Pro Tem Hoog brought out the unfairness to the existing signs which were above
8 to 10 -feet which would not be able to utilize a digital sign. He stated that he would not be
in favor of an Ordinance that did not help businesses with their signage. Mr. Boucher
clarified that the Ordinance reads that if a business has a hardship obtaining a monument
sign for their property; they could obtain a 20 -foot pole sign with an electronic message
board. City Council contended that this was not their intent. Mr. Boucher referred to Code
Section 94-78 (b), Hardship. Mayor Pro Tem Hoog stated that the current discussion was
related to existing pole signs which did not meet Code and were non -conforming.
Mr. John Johanson clarified that what the City Attorney said was the Board's intent. Mr.
Johanson conveyed that the only addition to the language was the City Attorney
suggested a sunset of three to five years and if the Council desired they could do so.
If the businesses could not physically comply with the Ordinance, they could apply for the
Exception. Mr. Johanson explained how a business could apply for an electronic sign
within the 20 -feet of the existing pole sign. Mayor Pro Tem Hoog stated that up to this
point, he did not see it written in the Code. Mr. Boucher referred to Code Section 94-78(a)
which read, "an electronic sign may be incorporated into a 20 -foot pole sign."
Mayor Pro Tem Hoog brought out that a 30 -foot, non -conforming„ pole sign could
incorporate an electronic sign into that pole sign but no higher than the line of
demarcation. Mr. Morley referred to Code Section 94-78 (a) offering this suggested
language, "However, if the property cannot accommodate a monument sign by
reason of.... an electronic sign may be incorporated into a pole sign, but such
electronic sign shall not exceed 20 -feet to the top of the electronic sign."
[Underlining indicates the added language.] Mr. Morley stated that the top of the electronic
sign could not exceed 20 -feet. Ms. Walsh asked for the square footage of the electronic
sign. Mr. Morley stated that the square footage could not exceed the maximum allowed
area combined.
Attorney Garganese explained, for example, given existing pole sign which exceeds 20 -
feet, if they desire an electronic sign, under a Hardship: 1) the City could allow them to
incorporate the electronic sign into the existing pole sign which exceeds 20 -feet, or 2) the
City could require them to install a new pole sign not to exceed 20 -feet and then to permit
the electronic sign that way. Mr. Petsos brought out another option of lowering a 30 -foot
sign.
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 12 of 17
Attorney Garganese advised that the Council could continue their discussion on the First
Public Hearing on June 16th. No further advertisement is required.
A motion was made by Ms. Roberts and seconded by Mayor Randels to Continue
the Public Hearing Regarding the Sign Code Ordinance at the City Council Regular
Meeting on June 16th at 6:00 P.M. The vote on the motion carried 5-0 with voting
as follows: Mayor Pro Tem Hoog, For; Mr. Petsos, For; Mayor Randels, For; Ms.
Roberts, For and Ms. Walsh, For.
RESOLUTION:
8:15 p.m. — 8:30 p.m.
7. Motion to Approve: Resolution No. 2009-17; Supporting the Brevard County
Tourist Development Council's "Space Coast Wayfinding Initiative."
Attorney Garganese Resolution No. 2009-17 by title.
A RESOLUTION OF THE CITY OF CAPE CANAVERAL, BREVARD COUNTY, FLORIDA,
TO SUPPORT THE BREVARD COUNTY TOURIST DEVELOPMENT COUNCIL'S
"SPACE COAST WAYFINDING INITIATIVE" AND TO PROVIDE THE RESOURCES
NECESSARY FOR INSTALLING AND MAINTAINING DISTINCTIVE THEME SIGNAGE
WITHIN THE CITY TO ASSIST MOTORISTS, BICYCLISTS AND PEDESTRIANS IN
NAVIGATING AROUND THE SPACE COAST AND LOCATING KEY TOURIST
DESTINATIONS
Mayor Randels stated that Brevard County would be the first County in the nation to
implement the Wayfinding Signs. He conveyed how funds have been set aside by the
Tourist Development Council to pay for this; however, municipalities shall have the final
approval as to whether signs shall be installed within their City limits. Mayor Pro Tem
Hoog brought up that the Council voted against this in the past. Mr. Petsos stated that he
was in favor of the Whereas Clause which provided cities with final approval.
A motion was made by Ms. Roberts and seconded by Mayor Randels to Approve
Resolution No. 2009-17; Supporting the Brevard County Tourist Development
Council's "Space Coast Wayfinding Initiative". The vote on the motion carried 5-0
with voting as follows: Mayor Pro Tem Hoog, For; Mr. Petsos, For; Mayor
Randels, For; Ms. Roberts, For and Ms. Walsh, For.
CONSIDERATIONS:
8:30 p.m. — 9:00 p.m.
8. Motion to Approve: Application for Satisfaction or Release of Code
Enforcement Lien, John Ribar and Rick Kendust, 210 Canaveral Beach
Boulevard.
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 13 of 17
Mayor Randels recounted that Mr. Ribar came before the Code Enforcement Board on
April 23rd and he was requesting the Council to mitigate the fine. Mayor Randels noted
that the trees were an invasive species; however, Mr. Ribar did not obtain a permit. Mr.
Morley conveyed that he noted the three different types of penalties: 1) depth -breadth -
height [dbh], per -inch, 2) a land clearing penalty per 100 -square foot cleared, 3) and a fine
for failure to obtain a permit. Mr. Morley disclosed that Staff cost estimates were also
included. Ms. Roberts questioned if the City were addressing land clearing penalty and
then the fine.
Mayor Pro Tem Hoog pointed out how some of the violators appeared to go outside of the
intent of the Ordinance, by offering mitigation for the trees, when making restitution for a
violation. He stated that most of the violators pleaded ignorance of the Law and he
preferred to treat everyone the same. Mayor Pro Tem Hoog conveyed that he would not
be in favor of a motion to reduce the Lien unless it was to recoup Staff costs.
Ms. Walsh questioned if this was related to the removal of an invasive tree and was told
that the tree caused damaged to their sidewalk. Ms. Walsh asked if this related to a code
other than the tree code, Chapter 102. Mr. Morley replied that Chapter 34-97 did not
speak of permitting, but Chapter 102 does. Mr. Morley ascertained that all tree removal
requires a permit. Attorney Garganese explained that Chapter 34 was a Maintenance
Standard and the Chapter 102 violations related to failure to obtain a permit. For the
record, the City Attorney asked if the applicant were in the audience.
Mr. John Ribar stated that the trees in question were Australian pines at 210 Canaveral
Beach Blvd. He is the owner of 210, 212, 214, and 216 Canaveral Beach Blvd which he
has owned for 25 years. He explained that he had to replace the sewer laterals over the
years and these trees affected the sewer lines for up to 200 -feet. Mr. Ribar stated that he
was not attempting to cause a hardship; he desired to clean up an area. Mr. Morley
replied to Mr. Petsos that if Mr. Ribar had come in for a permit, he would have been given
one. Mr. Morley replied that there was no cost for removing an invasive tree. Mr. Morley
assured that if someone from his Department could not go out to identify if the tree were
invasive tree, he would seek help from the City Arborist.
Mr. Dave Schirtzinger conveyed that the tree permit fees were excessive. Mr. Boucher
reminded the Council that based on the Code, if they denied Mr. Ribar's request, he could
not come back to the Council for one year. Ms. Walsh asked if a permit were needed for
Brazilian pepper trees and she conveyed that she received a different answer from the
Plant people [the Streets -Maintenance Department.] Ms. Walsh conveyed that this
creates confusion.
Mr. Donald Dunn, Planning and Zoning Board Member, brought out that obtaining a permit
was important whether the tree was invasive or not. Mr. Petsos clarified that he was not
advocating a stricter penalty for removing an invasive species. Attorney Garganese stated
that the issue for the Council is to consider whether or not the $750 fine should be reduced
cer or satisfied. The factors the Code requires the Council to consider were: 1) the gravity of
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 14 of 17
the violation, 2) the time the violator took to come into compliance, 3) the accrued amount
of the Code Enforcement fine, 4) previous or subsequent Code violations, 5) any financial
hardship, and 6) any mitigating circumstances why this violation occurred.
Mr. Nicholas asked why the Administrative costs were so high. Mayor Pro Tem Hoog
replied that all of the fees were compiled around Code Enforcement Board action since
August 14, 2008.
A motion was made by Ms. Roberts and seconded by Mayor Pro Tem Hoog to
Extend the Meeting Time Until 10:30 P.M. The vote on the motion carried 5-0 with
voting as follows: Mayor Pro Tem Hoog, For; Mr. Petsos, For; Mayor Randels,
For; Ms. Roberts, For and Ms. Walsh, For.
Mr. John Porter expressed that he understood that permits were not obtained and the
parties involved were in violation of removing the said invasive species; however, he
expressed his concern that the punishment did not fit the violation. He stated that the City
Attorney had presented mitigating reasons why the Council should consider administering
Staff costs only. Mr. Porter stated that he and the other applicants did not remove Oaks,
Bay, or other beneficial trees. He asked the Council to not set a precedent for paying fines
for removing invasive species. Ms. Roberts clarified that the precedent reference was for
cases before those presented tonight and the Council was attempting to be consistent until
a thorough review of the Tree Ordinance could be administered.
Mayor Pro Tem Hoog stated that he only desired to recoup Staffs time and he expressed
his disagreement with the Ordinance. Mr. Ribar conveyed his concern with the lengthy
process and the amount of Staff time incurred and questioned why Council could not
simply make the necessary change to the Code. Ms. Walsh questioned the difference in
the use of Section 102 and Section 34-97. Mr. Morley defined the use of the two: 1)
Section 102 referred to Tree removal, and 2) Section 34 referred to Property Maintenance
Standards.
Attorney Garganese explained that Chapter 34 required to all property owners to maintain
their property under certain standards. However, a penalty must be imposed for a failure
to obtain a permit. Attorney Garganese explained further that the Council could take into
consideration: 1) these trees were causing property damage and from a maintenance
standpoint were removed; however, this did not eliminate the need of obtaining a permit,
and 2) the intent of the tree Code is to encourage the protection of the maximum number
of viable trees listed in the desirable species list, further the intent of the tree code is to
further protect trees native to Central Florida. Attorney Garganese stated that an applicant
can appeal to the Council for a release or reduction of Lien after adjudication which is the
circuit breaker in the violation system. He stated that the Council has been consistent in
seeking the costs to the City subsequent to Code Enforcement violations.
Mr. Petsos inquired about the necessity of three Code Enforcement Hearings. Mr. Morley
explained the first was Notice of Hearing and the second to receive a Satisfaction or
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 15 of 17
Reduction of Lien. Mr. Ribar conveyed that one Meeting of the Code Board was tabled
because they entered the same type of discussion as the Council related to providing a
penalty.
A motion was made by Mayor Randels and seconded by Mr. Petsos to Deny the
Application for the Reduction or Cancellation of Code Enforcement Lien, for John
Ribar and Rick A. Kendust, 210 Canaveral Beach Boulevard.
No Action Was Taken on This Motion.
Mr. Petsos withdrew his Second to the Motion saying that he made it based on
thinking that there was a permit fee for this and he believed that the penalty should
only relate to Staff time. Attorney Garganese stated, for the record, that the Second
belonged to the Council until its Disposition. He explained that the Council could withdraw
the motion by unanimous consent. Mayor Pro Tem Hoog questioned the changing of
Staff time rate. Mr. Morley replied that two different costs related to two combined persons
Staff time for one incident and only one person working on the other. Mayor Randels
asked if there were unanimous support to withdraw the Motion.
Mr. Boucher stated that Mr. Ribar conveyed that he had mitigating circumstances and
the Code Enforcement Board recommended reducing the cost to Staff time. Mayor Pro
Tem Hoog requested a change to the Section of the Code relating to the additional Staff
of an applicant seeking a Reduction before the Code Enforcement Board when this
already occurs with the Council.
Attorney Garganese stated, for the record, that Mr. Ribar has 30 days to make the
payment and if this were not done, the amount would return to the original
amount of the Lien.
A motion was made by Ms. Roberts and seconded by Mayor Pro Tem Hoog to
Extend the Meeting Time Until Items 8, 9, and 10 were Completed. The vote on
the motion carried 5-0 with voting as follows: Mayor Pro Tem Hoog, For; Mr.
Petsos, For; Mayor Randels, For; Ms. Roberts, For and Ms. Walsh, For.
A motion was made by Mr. Petsos and seconded by Mayor Pro Tem Hoog to
Reduce the Cost of the Code Enforcement Lien, for John Ribar and Rick Kendust,
210 Canaveral Beach Boulevard to $364.28. The vote on the motion carried 5-0
with voting as follows: Mayor Pro Tem Hoog, For; Mr. Petsos, For; Mayor
Randels, For; Ms. Roberts, For and Ms. Walsh, For.
9. Motion to Approve: Application for Satisfaction or Release of a Pending Code
Enforcement Lien, Supra Color Enterprises, Inc., Vacant Lot North of 6615 N.
Atlantic Avenue (A1 A).
Mr. Morley informed that this Satisfaction and Release would be called a "Pending" issue
since his Department had no time to record it in an effort to expedite it. Mr. Petsos clarified
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 16 of 17
that these were invasive Brazilian pepper trees. Mr. Porter, speaking on behalf of Mr. Kurt
Tezel, explained how he had someone use a Johnson tractor on his property, not a root
rake, and he also contacted Mr. Kurt Tezel to have the same company remove the
Brazilian peppers on Mr. Tezel's property. Mr. Porter admitted their mistake of not
obtaining a permit which incurred a fine. However, he stated that only the Brazilian
peppers were removed, not Live Oaks, Bay, or Palm trees. Mr. Porter emphasized that
not obtaining the permit was the violation; however, they did not damage any beneficial
trees.
Mr. Porter restated that the punishment did not fit the violation. Mayor Randels stated that
the charge was for land clearing. Mr. Porter stated that they removed Brazilian peppers
and a root rake was not used. Mr. Porter replied to Ms. Roberts that Dennis Clements,
Acting Building Official at the time, Duree Alexander, Code Enforcement Officer and also
Kay McKee, Street/ Maintenance Supervisor physically visited the property.
Ms. Roberts conveyed the dramatic results of the property's appearance after the tree
removal. Mr. Porter affirmed that the appearance changed due to the pepper tree removal,
but even after obtaining a permit the results would have been the same. Mr. Porter stated
that he had no problem paying for Staff time. Mr. Johanson assured that the person using
the land clearing equipment was very knowledgeable of trees.
A motion was made by Mayor Pro Tem Hoog and seconded by Ms. Walsh to Reduce
the Application for Code Enforcement Lien Supra Color Enterprises, Inc., Vacant
Lot North of 6615 N. Atlantic Avenue (A1A) to Staff Costs of $730.84. The vote on
the motion carried 5-0 with voting as follows: Mayor Pro Tem Hoog, For; Mr.
Petsos, For; Mayor Randels, For; Ms. Roberts, For and Ms. Walsh, For.
10. Motion to Approve: Application for Satisfaction or Release of Code
Enforcement Pending Lien, Banana River, L. P. a/k/a Banana River of
Delaware, Ltd., c/o Helen M. Ward, R. A., North Atlantic Avenue Properties.
Mr. Porter stated, for the record, that the only difference in his case and Mr. Tezel's was
that he had a tree survey performed which would permit the City to identify all of the trees
on his property.
A motion was made by Mayor Pro Tem Hoog and seconded by Mr. Petsos to Satisfy
this Pending Lien Banana River, L. P. a/k/a Banana River of Delaware, Ltd., c/o
Helen M. Ward, R. A., North Atlantic Avenue Properties in the Amount of $730.84.
The vote on the motion carried 5-0 with voting as follows: Mayor Pro Tem Hoog,
For; Mr. Petsos, For; Mayor Randels, For; Ms. Roberts, For and Ms. Walsh, For.
Due to the lateness of the hour, the following Items were not discussed.
DISCUSSION:
9:00 p.m. — 9:15 p.m.
City of Cape Canaveral, Florida
City Council Regular Meeting
June 2, 2009
Page 17 of 17
11. Municipal Economic Development Powers
REPORTS:
9:15 P.M. — 10:00 P.M.
12. Council Reports
ADJOURNMENT:
There being no further business, the Meeting adjourned at 11:00 P.M
Rocky Randels, MAYOR
Susan Stills, CMC, CITY CLERK
OFFICE OF THE STATE ATTORNEY
EIGHTEENTH JUDICIAL CIRCUIT OF FLORIDA
BREVARD AND SEMINOLE COUNTIES
Viera Office
2725 Judge Fran Jamieson Way
Bidg. D
Viera, FL 32940
(407) 617-7510
Seminole County Office
100 East First Street
Sanford, FL. 32771
(407) 322-7534
Titusville Office
400 S. Street
Titusville, FL 32780
(407) 264-6933
Seminole Juvenile Center
190 N. Bush Blvd.
Sanford, FL. 32773
(407) 323-2500
NORMAN R. WOLFINGER
STATE ATTORNEY
Reply To:
Viera
June 1, 2009
Mr. Bennett Boucher
City Manager
City of Cape Canaveral
P.O. Box 326
Cape Canaveral, Florida 32920-0326
Re: Sunshine Law
Dear Boucher:
In response to your letter of May 12, 2009, forwarding a written request by the mayor to
have the State Attorney investigate the alleged Sunshine Law Violation, this office does not see a
need for further investigation of the incident beyond a review of the recording of the April 7,
2009 meeting. However, it is the opinion of this office that the spirit, intent, and technical
requirements of that law were not followed when the mayor and two counsel members continued
to discuss matters that had not been completely resolved within the time frame of the properly
noticed meeting.
The Sunshine Law applies to any gathering, whether formal or casual, of two or more
members of the same board or commission to discuss some matter on which foreseeable action
will be taken by the public board or commission. Although the council members may have
believed that they were just talking about procedures or methods to better gather information; for
council meetings to run more efficiently and timely; or possible forms to gather information for
evaluations, these were all matters that the counsel discussed that evening in their meeting and
were issues that had not been fully resolved.
In the case at hand the discussion was limited to these areas and did not show any intent
to willfully ignore the Sunshine Law or to deprive the public of input on these issues. However,
just because a sanction may not be warranted under these circumstances does not mean that the
Sunshine Law is to be taken lightly. Conversation between counsel members about city business
outside the public forum of a properly noticed meeting should not occur. We trust that by
bringing this matter for review, parties will refrain from such conduct in the future.
Mr. Boucher
June 1, 2009
Page 2
Thank you for the opportunity to review this matter and provide assistance to the City of
Cape Canaveral.
Sincerely,
NORMAN R. WOLFINGER
STATE ATTORNEY
BY:
ROBERT WAYNE HOLMES
ASSISTANT STATE ATTORNEY
CHIEF OF OPERATIONS
RWH:clr
IM
Re.
CITY OF CAPE CANAVERAL COUNCIL MEETING
ATTORNEY/CLIENT SESSION
(C(Ony
CXe- Close d -
TRIPLE J INVESTMENTS, LLC
CITY OF CAPE CANAVERAL ATTORNEY/CLIENT
SESSION held on June 2, 2009, at the City
Hall Annex, 111 Polk Avenue, Cape
Canaveral, Florida, beginning at the hour
of 5:45 p.m.
APPEARANCES:
City Council Members:
City Manager:
City Attorneys:
L
Mayor Rocky Randels
Mayor Pro Ten Bob Hoog
Commissioner Buzz Petsos
Commissioner Shannon Roberts
Commissioner Betty Walsh
Bennett Boucher
Anthony A. Garganese, Esq.
Debra S. Babb-Nutcher, Esq.
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(Proceedings held June 2, 2009)
MAYOR RANDELS: I would like to call this
meeting to order, and it will start as an open
meeting, and the persons expected to -- would this
be the proper place to tell who's here?
MR. GARGANESE: Yes.
MAYOR RANDELS: The persons scheduled to be in
attendance are myself, Mayor Rocky Randels; Mayor
Pro Tem, Bob Hoog; Council Members Betty Walsh,
Buzz Petsos and Shannon Roberts; City Manager
Bennett Boucher; and City Attorney Anthony
Garganese and Assistant City Attorney Debra
Babb-Nutcher. And they are all present as stated,
and also a court reporter is present. And I'll
next go to you.
MR. GARGANESE: Mayor, thank you very much.
The purpose of this meeting is to call an
Attorney/Client Session regarding the case Triple J
Investments, LLC, versus City of Cape Canaveral,
Case Number 608-CV-283-ORL-22DAB, that's currently
before the Federal District Court in Orlando. The
estimated time of the attorney/client session would
be approximately 30 to 45 minutes.
At this point -- actually, let me just say
before that, I need the advice and direction
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regarding possible settlement negotiations and
litigation strategy moving forward in this case.
At this point it would be appropriate to close
the open portion of the meeting and let the record
reflect that there are no members of the public
present during the attorney/client session.
This is now officially a closed session, at
which point I would like to turn the matter over to
the Assistant City Attorney, Debra Babb-Nutcher, to
tell you where we are status -wise in this case and
also to advise the City Council regarding a
settlement offer that we received from the
Plaintiff's attorney.
Prior to the attorney/client session we
provided you a summary of the Plaintiff's
allegations in this complaint, as well as some
information regarding some discovery, as well as
providing you a copy of the May 13, 2009, letter
from Plaintiff's attorney, Sheldon Stevens,
proposing a settlement of this case, so that gets,
you know, at least the Council up to speed
regarding those matters and Debra won't get into
that so much, so we'll get right into probably the
meat and bones, since you have had an opportunity
to review that documentation.
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Debra?
MS. BABB-NUTCHER: We are kind of in the early
stages of the discovery phase. Because we're in
Federal Court things move fairly quickly, and we
have had -- we have done some written discovery
where we have asked them to answer some questions.
We have gotten some documents from them. They set
a lot of depositions in the case.
Two depositions were taken so far. Harry
Pearson and Earl McMillan were taken just a couple
of weeks ago. They decided to cancel the rest of
the depositions. They had about four or five other
depositions they wanted to take of other board
members, and they called to cancel -- Plaintiff's
attorney called to cancel and wanted to discuss
settlement.
You have a copy of the letter that they had
previously sent making a demand for $80,000 in the
case. They have had -- we have had some
discussions with their attorney that they were
looking really for perhaps their attorney fees in
the Writ of Certiorari action.
In terms of the progress of the federal
case -- as you know, this is now a federal case.
We removed it to Federal Court. We don't have a
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whole lot of time for discovery, so the fact that
they have canceled their depositions tells me a
couple of things: Number one, they want to settle;
number two, I'm also getting the impression that
they don't want to spend a lot of money on
attorney fees.
And because we're in Federal Court, we have
definite deadlines. We have a discovery deadline
in August, meaning all discovery must be done in
August. Meaning, again, they have got to hurry up
and finish their discovery, take their depositions.
We need to take any depositions we might want
to take within the next few months, which is
expensive. It's expensive to do that. I myself
have put this case in the posture of getting it
ready for what's called the Motion for Summary
Judgment. I have probably got about 15 pages of a
Motion for Summary Judgment already drafted.
We typically don't file a summary judgment
motion until you get all your discovery done. I
feel pretty comfortable with where we are in the
case in terms of success on the summary judgment
motion. It's just a matter of getting the
depositions done and any further discovery done,
which, again, for both sides is going to cost some
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money, and everyone is mindful of the expenses that
are involved.
I have done a summary of the allegations.
This is not my opinion of their case in any way.
This is not our opinion. This is just me taking
their Complaint and their Answers to
Interrogatories. I simply sent them a list of
questions saying please give me your support for
this allegation, please give me an explanation of
that allegation, and this is me summarizing what
they are stating.
And if you have any questions about their
arguments or their allegations, I can try and
answer them for you. If you have any questions
about how the City can rebut those allegations, I
feel very comfortable that we can rebut all of
their allegations. I do.
The case law is pretty solid -- the federal
case law is pretty solid. What they are asking for
in my opinion is not compensable. They are -- they
feel like they are wronged, I imagine, and they
feel like because they won on the Writ of
Certiorari that somehow that should translate to
damages, but it doesn't.
Because you get a court to overturn a decision
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of one of your boards does not necessarily equate
with now you have to pay us money damages, and
there was specific federal case law on this point.
They are not entitled to damages simply because a
court decided that the Board of Adjustment made a
wrong decision.
Now, the only thing we would possibly have an
issue with is if there is some kind of bias or
extreme arbitrary, unreasonable, capricious actions
by the board members. And, again, I have dug
through the transcripts, I have gone through the
meeting minutes, and that arbitrary, capricious
conduct is in my opinion just not there. That kind
of boils down their arguments and how I would
respond to their arguments with a summary judgment
motion.
I can answer any further questions you might
have about the substance of their arguments or the
substance of what our rebuttal would be, but I
think the bottom line for me as the person
litigating the case is I feel very comfortable with
the City's defense in the case.
I feel that we can win the case; however, it's
expensive. It's expensive to litigate in Federal
Court. It's expensive to take depositions. Even
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if I'm not taking depositions, I'm still sitting
there in the depositions for a couple of hours.
I'm asking questions as well, and at some point I'm
going to have to take depositions of some of the
principals of Triple J, so we are always mindful of
the fees and costs that are going to be involved in
the litigation. Even if we were comfortable with
where we are in defending the case, that is
something we take into consideration.
MAYOR RANDELS: Debra, did I detect in the
beginning of your opening statement that perhaps
you could read the offering figure was not really a
bottom-line figure?
MS. BABB-NUTCHER: I think that that was a
starting point. I think that there was -- that was
something to get the ball rolling.
MAYOR RANDELS: Okay. Probably on the high
side or -- certainly can't go up after you make an
offer of lower amount?
MS. BABB-NUTCHER: I have never seen it,
but --
MAYOR RANDELS: Would that be realistic
expenses that actually have been incurred by their
firm?
MS. BABB-NUTCHER: Well, personally, I think
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it is doubtful that they have expended $80,000 in
attorney fees. I don't know. I don't know what
he's billing by the hour. But it's certainly a
consideration.
I don't know that it would be appropriate to
ask them, you know, How much exactly did you spend
on the Writ of Certiorari, the point where you feel
like you won? You won because you appealed the
Board of Adjustment decision and you won on that.
It may be appropriate for us to ask them:
Well, let us know. Did you spend $12,000?
$15,000? How much did you spend on the actual Writ
of Certiorari? And maybe that would be a more
appropriate figure to look at than this $80,000
figure which doesn't appear --
MAYOR RANDELS: Let me stop speaking and I'll
pass to them in a moment. But is it customary that
a counteroffer is ever made in these situations?
MS. BABB-NUTCHER: If we want to try and
resolve the case, then we would want to make a
counteroffer, yes.
MR. GARGANESE: I think what you're hearing
from our side is that given the allegations in this
case, the City has a strong defense based on the
allegations that have been made. We have an offer
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to settle at eighty thousand. The City Council can
continue litigating this case, in which case we'll
posture it to the point where we think the City
will likely prevail, unless something comes up in
discovery that we're not aware of today based on
the allegations.
Alternatively, if you all wanted to make a
decision to make a counteroffer to settle this case
for some dollar amount, then, you know, you are
free to go ahead and do that to try to resolve the
case, avoid any additional litigation expenses,
avoid the possibility that something may come up in
discovery that we're not aware of right now that
could be damaging to the City. I don't know if
there is anything out there, but you never know.
So that's where you are.
MAYOR RANDELS: Okay.
MR. GARGANESE: So, Mayor, to answer your
question, it depends on the Council what you want
to do. If you're interested in settling, then you
need to come up with a good counteroffer, and we'll
bring it back to the other side and see if we can
settle the case.
MAYOR
RANDELS:
I'll
start this way
and go to
the right.
Mayor Pro
Tem,
you have some
thoughts
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on this?
MAYOR PRO TEM HOOG: Well, my feelings on this
personally if our attorneys -- and I'm directing
this directly to you, because I have directed them
many times in the past. I have been to many of the
P&Z meetings, many of the Board of Adjustment
meetings. Those I have a personal interest in
because of the quasi -boards that we have, and I
have asked and asked and asked that when these guys
get offtrack -- I'm not saying that I sit here and
I'm perfect by any means, but I sit and I listen to
those board members get off into areas where they
shouldn't go, even if it's down into the Community
Appearance Board asking for a site plan. They have
no business asking for that type of thing. And
these people, PH, and I read these allegations --
are these all on tape?
MS. BABB-NUTCHER: I cannot substantiate their
allegations. Their allegations are excessive.
MAYOR PRO TEM HOOG: Some of the statements
that are in here, if they were stated in the open
public meeting, that's where the attorney should
step in and say, "Wait a minute, you're stepping
out of the box."
They have no right to go against making a
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special exception not heard or not being valid
under the pretenses that they come in and their
packages meet all the criteria, how can the board
say no?
And then to have statements made that, you
know, Cathy Barnes, she would never vote for
another special exception. She has that
prerogative to do that, but what's her reason? Not
just because -- I guess you have those answers. I
don't know.
MS. BABB-NUTCHER: On the Cathy Barnes
comment, I was not able to find anything where she
had said that.
COMMISSIONER ROBERTS: I think consistent with
what Bob's saying, though, having attended some of
those PH meetings, a lot of what is recorded -- I
mean the recording would be different than what you
pick up on the written minutes.
MS. BABB-NUTCHER: We got transcripts of all
of the meeting minutes that they are alleging --
they have alleged, you know, five or six meetings'
minutes where there are what they claim are
inappropriate comments, and I have read through
every single verbatim transcript, and we've had
Susan Chapman type up the transcript of every
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meeting that they have told us is a meeting where
improper statements were made, and there were
statements made such as, "This property should have
been rezoned R1 a long time ago." I don't think
there is anything wrong with that statement.
Considering the role of the P&Z, what is wrong
with their general statements that this should not
be commercial property, the City should have
rezoned that a long time ago? That is not an
arbitrary or capricious or an abuse of discretion.
That's included within their role -- from my
opinion that's included.
And it always comes right down to the
compatibility issue, which in this case
compatibility was the whole issue on this
particular application.
MAYOR PRO TEM HOOG: Let's just go down to the
Earl McMillan statement, page two, the last
comment: "Earl had a personal conflict with
Mr. Morgan, Sr., when Mr. Morgan was building
official." Now, he, I assume, personally stated
this -to John Johanson after the meeting.
MS. BABB-NUTCHER: And Earl denies that. He
stated in deposition --
MAYOR PRO TEM HOOG: He denies that?
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MS. BABB-NUTCHER: He directly was asked that
question by Mr. Stevens: "Did you make this
statement to John Johanson?"
And he said, "No, I did not make the statement
that I have a personal conflict" --
MAYOR PRO TEM HOOG: So there we have one
person denying they said something to another
person, and the person that was denied was the
gentleman that is in question that has the lawsuit
against the City. So it's capricious, like you
say. I guess that's the right term.
I've sat in many of those meetings, and my
point is Mr. Garganese, Ms. Latorre, they let this
stuff get to the point of here we are today. When
they go making statements, you know, like "I'm not
going to vote for that because I don't like it,"
well, that's not the reason we're sitting here.
MS. BABB-NUTCHER: They haven't made that
statement.
COMMISSIONER ROBERTS
I have been in the same
meetings.
MAYOR PRO TEM HOOG: I've seen many of this
take place. I have seen the chairperson say, "I
don't like your project." That's where our
attorney should say, "Wait a minute."
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COMMISSIONER ROBERTS: It's there.
MS. BABB-NUTCHER: It's not in any of the
transcripts that they have directed us to.
MAYOR PRO TEM HOOG: You don't get all the
transcripts then.
MS. BABB-NUTCHER: But I'm framed by the
allegations in their lawsuit, and they are now
framed by the allegations in the lawsuit.
MAYOR PRO TEM HOOG: What you need to do,
then, ma'am, is get the actual meeting minutes and
listen to it yourself, because it's stated in
there. The transcripts may not show that.
MS. BABB-NUTCHER: I have. We have the discs
as well.
MAYOR PRO TEM HOOG: Well, there is a lot of
times when I have sat and I have heard this and I
have gone right in the next morning to
Mr. Boucher's office, which he can sit here and
deny, and say, yes, he has come into my office with
this same problem, and we wouldn't be here hearing
this kind of stuff.
MS. BABB-NUTCHER: Well, I --
MR. GARGANESE: Let's look at it this way.
There are allegations that have been made in the
complaint. We're going through discovery trying to
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determine whether they could substantiate the
allegations, that's number one.
Number two, even if they were able to
substantiate the allegations, do they rise to a
level of a constitutional violation where they
should be compensated, which is the legal aspect of
it.
And what we're telling you is there are a lot
of allegations going on, some of which just don't
show up in the transcript of the voice recording of
the meeting or in the minutes. And we have a
deposition where one of the board members is asked
point-blank, "Did you make that statement?"
And the board member testifies, "No."
Okay. So all of this stuff, all this factual
gathering, they are trying to prove their
allegations, and we're telling you in some cases
it's not being proved.
You know, as you know, Bob, and I'm not
disagreeing with you, you know, we advise the
boards constantly: You got to comply -- apply the
criteria. You know, can we control what an
individual board member says in the middle of a
meeting? Absolutely not.
But we have trained the board members, you're
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absolutely right, they need to be making decisions
based on criteria that's in the code. You know
that they in this case, they applied for a special
exception; that special exception was denied by the
Board of Adjustment. They appealed -- that's what
the Writ of Certiorari is -- and they prevailed.
And we brought it to the City Council, and the
City Council decided three to two not to appeal the
Court's decision. And then, you know, they filed
the federal lawsuit. And so the question -- I
mean, you know as well as I do, you sat through
these Planning & Zoning Board meetings, there are
some personal issues going on between some of the
board members and Mr. Johanson, who actually sits
on the Board.
And whether they rise to, again, a
constitutional deprivation of some sort that's
compensable, when you look at it through those eye
glasses, the answer is at this juncture, no.
MS. BABB-NUTCHER: And as the litigation
attorney, I look at how this is presented to the
Court, and you all may have some knowledge about
things that have gone on outside of the record or
at other meetings, but I am driven by the
allegations, and the allegations frame the case,
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and it is too late for them at this stage of the
case to change their allegations.
So I have my framework, and I don't deny that
you all have more knowledge than I do, but I come
from the perspective of the litigation attorney who
presents the evidence to the Court, and that from
the evidence that I have had, yes, there is
conversations saying that this property should have
been rezoned a long time ago; yes, there is
conversations that we shouldn't be allowing special
exceptions granted like giving away candy. In
fact, I believe you said similar statements.
But those kind of statements in my opinion,
based upon my research of the law, don't rise to
the level of a constitutional deprivation. From
what I have seen, and I don't deny there is
probably more out there, but based on the
allegations, what I have seen does not rise to the
level where they should be compensated for a loss
of a federal right.
MR. GARGANESE: So with that said, under these
circumstances do you want to make a monetary
counteroffer to try to settle this case? And, you
know, if you want to do that, we'll go ahead and
bring that to them. This case is being covered by
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insurance. You're getting a defense. I believe
the City does not have a deductible --
MS. BABB-NUTCHER: Right.
MR. GARGANESE: -- in this case. Your
insurance carrier just to do away with this case
would likely throw maybe ten or fifteen thousand,
somewhere around there, at this case for
settlement, or maybe based on our discussions with
them a little bit more.
What do you all want to do? We'll do whatever
you want. This case if you remember, Bob, prior to
the Board of Adjustment making a decision, the
property owner came to the City: "Do you want to
buy the property? Here's what we paid for it, plus
the cost of engineering costs we got into it, we'll
sell the property to the City."
This case from the get -go has been problematic
before the Board of Adjustment even made a
decision. It's your call.
COMMISSIONER PETSOS: I think you answered
some of my question, which was are we in contact
with the League of Cities who are underwriting
this?
MR. GARGANESE: I have been.
COMMISSIONER PETSOS: Because I wasn't sure
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whether they felt it was appropriate to settle or
whether they thought it was more appropriate to
continue on. Because I'm sure you're talking to
the insurance side and the attorney side, so what
is their opinion?
MR. GARGANESE: Their opinion right now is
that the case is defensible and they would be
willing to put somewhere between, say, the ten and
twenty thousand range to settle this case if the
Council wanted to pursue it. If the Council said,
"We don't want to pursue it," the insurance company
will defend the City through Motion for Summary
Judgment; or if it gets to trial, through trial, if
that's what you all wanted to do.
So you're kind of -- Florida League of Cities
is really good at that. They want to know what you
all think. You need to tell us.
COMMISSIONER PETSOS: The second part of my
question --
MAYOR RANDELS: Keep going.
COMMISSIONER PETSOS: -- and maybe it's a
little history for me, and everybody else knows and
I'm out in the dark, but we did elect not to
appeal. How come it continued on and that we did
not just find a way to pay them their attorney's
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fees at that point in time and be over and done
with it?
MR. GARGANESE: That's a very good question.
Because under Florida law, when you appeal a zoning
decision, and the Circuit Court overturns the
City's decision, the zoning decision, there is no
right to -- there is no right to attorney fees or
reimbursement of costs. That's the law in Florida.
When you file a Writ of Cert appealing that
decision, if you win, there is no right. I mean
everyone must have read in the paper -- it happens
all the time -- the City of Melbourne was recently
overturned by the Circuit Court, and now they are
considering whether they want to appeal or what
they are going to do with that application. But
there is no right to attorney fees.
COMMISSIONER PETSOS: So that was their
rationale or their reasoning for having to go to
Federal Court?
MAYOR RANDELS: No, we chose Federal Court.
MR. GARGANESE: No. They filed another
lawsuit after the City Council decided not to
appeal.
COMMISSIONER PETSOS: Right.
MR. GARGANESE: And then we -- you know, we
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brought that to the Council, and in our opinion
because they were raising federal constitutional
issues, our opinion was to go to Federal Court.
That's --
COMMISSIONER PETSOS: Well, we had no choice
at that point because they had taken it to that
level of the Federal Court.
MR. GARGANESE: They filed the other lawsuit.
They filed two lawsuits. They appealed the
decision of the Board of Adjustment; that was
overturned by the Circuit Court. That case ended.
And then they filed the second lawsuit.
MAYOR PRO TEM HOOG: They were given a writ of
mandate -- or we were given a writ of mandate, and
we didn't follow through with it. That's when the
other lawsuit got filed.
MR. GARGANESE: There was a delay, a small --
there was a little delay.
MAYOR PRO TEM HOOG: About a year almost,
right?
COMMISSIONER PETSOS: Three months, I think,
October to February.
MR. GARGANESE: And there is a story there
too. I mean --
COMMISSIONER WALSH: What is the timeline on
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that? I mean when it's given to the city versus
when they --
MAYOR PRO TEM HOOG: A question about who was
going to pay for the other fees that were incurred
for another hearing, and we never would pay.
MS. BABB-NUTCHER: There is factual issues on
that, but that was -- the attorney/client session
where you all decided not to appeal was October 1,
2007, and when they actually had the hearing was
3/24/08.
MR. GARGANESE: When they decided not to
appeal, the mandate was issued, what, a little time
after that, so there was a couple of months between
the time that the appeal rights were over and it
went to the Board of Adjustment, and there is some
factual issues as to, you know, why it didn't go.
Bennett was speaking with one of the principals of
Triple J, and there may have been a
misunderstanding.
Bennett was trying to coordinate a hearing
date, and not until they filed the lawsuit did we
realize that, by golly, they wanted the matter
resolved right away, and there is a factual issue
there. Bennett can speak to that, because I didn't
have personal conversations with any of the
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(W 25
principals about scheduling the Board of Adjustment
hearing.
Our legal opinion was once the Court overturns
the Board of Adjustment, the matter has to go back
to the Board of Adjustment, who then rules on
remand, and there is case law that says while it
might be a little bit perfunctory, it needs to go
back to the Board, and --
MS. BABB-NUTCHER: Right, it's not automatic.
It's not an automatic thing.
MAYOR RANDELS: Go ahead.
COMMISSIONER PETSOS: The only other thing, it
wasn't a question, more a comment. I do agree even
though maybe state law says they are not entitled
to any attorney fees or anything, I feel the
reasonable thing would have been to pay them the
attorney fees since they won, and if that comes up
to that $12,000 figure or somewhere in there, if
the League of Cities is willing to try to dispense
of this for fifteen or twenty thousand, then I
would agree with that figure.
MAYOR RANDELS: Shannon, do you have some
observations? And then go to Betty.
COMMISSIONER ROBERTS: Well, I like what Buzz
just said. I think that would be the appropriate
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way to go. And I think another opportunity for
us -- maybe as a postscript to this is some lessons
learned relative to trying to help maybe some
improvements that they suggested here I think to --
with regard to the board training, which you had
talked about.
I know that we continue to be sensitive to
that, as well as the time elements, and I think
that comes up with our major improvement agenda,
too, with some of the things we're trying to do
with documentation, tightening some of our time
frames.
I was a little unclear with regard to the
natural steps that they would be taking as it
relates to the City after the decision was
overturned. In other words what would have been
the normal next step? Would they -- they would
have normally gone back to the Board of Adjustment?
MR. GARGANESE: Absolutely.
COMMISSIONER ROBERTS: And their point was
they needed to repeat the fees, to do that again;
is that correct?
MR. GARGANESE: Well, it would be -- when the
Circuit Court overturned the Board of Adjustment
and the Council decided not to appeal, their
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application for special exception became live
again, where the City then could act on it on
remand.
So when the Council decided they didn't want
to appeal, we waited for the 30 -day time period for
appeal to expire. I sent the manager an e-mail
saying that it's now ready to be put on the Board
of Adjustment agenda, so they are advised that the
Court overturned the decision, and then they can
render a decision on the application. Because the
application became live again for the City to act
upon, and then, you know, then there is some
factual issues there where Bennett was talking to
one of the principals about scheduling that Board
of Adjustment meeting, but it was always the City's
intent to put that application, to put it back
before the Board of Adjustment.
COMMISSIONER ROBERTS: Bennett, I know you
offered to explain a little bit. Can you help us?
CITY MANAGER BOUCHER: We had it ready to go.
There was e-mails and documentation to show that
the city attorney, staff, and everybody were
scheduling this meeting. And I had a conversation
with Mr. Morgan, Sr., and he told me to hold off
because he wanted to explore his options, and being
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a former council member, I said, "Okay. Go explore
your options." Because they had a commercial
option that they had thrown out on the table
previously.
So being the condition of the market and the
way it was at that time, I didn't know what they
were going to do with the property. So when he
told me to hold off, I said, okay, and took his
word, and down the road they file a lawsuit.
COMMISSIONER WALSH: So a verbal conversation
you had?
CITY MANAGER BOUCHER: Right. But I
documented in e-mail to my staff, so it was
documented. So as soon as I got that, I sent an
e-mail out to staff saying to hold up, and I had a
conversation with Mr. Morgan, and so --
MS. BABB-NUTCHER: I believe the building
official had a conversation as well.
CITY MANAGER BOUCHER: Building official,
Ms. Chapman.
MS. BABB-NUTCHER: Similar conversation,
similar type conversation.
COMMISSIONER PETSOS: Not to interrupt, but
were there any conversations there? Because in
here they refer to having to go through the process
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again and also additional fees.
CITY MANAGER BOUCHER: That was never brought
to my attention. It was always to reschedule and
talking to Ms. Chapman about the allegation she
denies ever doing.
COMMISSIONER PETSOS: Never going to rPn»irP
them to pay
CITY MANAGER BOUCHER: Right.
MS. BABB-NUTCHER: Because it wouldn't make
sense. Because it was going before the Board of
Adjustment, the fees would have already been paid.
COMMISSIONER PETSOS: Right.
CITY MANAGER BOUCHER: And we have done this
before with other Board of Adjustments. Like when
we had Patriots Park remanded back to us by the
Court, we didn't have to do anything other than --
MR. GARGANESE: That's inappropriate. You
don't consider the application anew after the
Circuit Court overturns. You have to then make the
decision based on the Court's opinion.
MAYOR PRO TEM HOOG: So what I'm hearing from
Ms. McNabb --
MS. BABB-NUTCHER: Nutcher.
MAYOR PRO TEM HOOG: I'm sorry.
MS. BABB-NUTCHER: That's all right.
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MAYOR PRO TEM HOOG: On page two it says, "In
October of 2007 Susan Chapman contacted
Mr. Morgan," and this is in reference to reapplying
for a special exception. "Mr. Morgan was told to
reapply, and there was a discussion about paying
extra fees." Who brought up that discussion?
MS. BABB-NUTCHER: This is the allegation they
have made.
CITY MANAGER BOUCHER: That's their
allegation.
MS. BABB-NUTCHER: This is just their
allegation.
CITY MANAGER BOUCHER: That's their
allegation. Susan Chapman is denying that
allegation.
MS. BABE-NUTCHER: Plus the e-mails.
MAYOR PRO TEM HOOG: The only thing we got is
kind of just between two people and nothing --
MS. BABB-NUTCHER: We have Mr. Boucher's
e-mail that documents --
CITY MANAGER BOUCHER: I have my e-mails, my
documentation, so --
MS. BABB-NUTCHER: Which was very good to
have.
CITY MANAGER BOUCHER: Yes.
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MR. GARGANESE: I mean it's contemporaneous.
I can remember the e-mail. I just got off the
phone or just got done talking to Jim Morgan, and
it's contemporaneous.
CITY MANAGER BOUCHER: Right.
COMMISSIONER ROBERTS: Then if -- Betty -- I
wanted to ask Bennett, what do you think it would
be?
CITY MANAGER BOUCHER: Well, you know,
subsequently we gave them the approval, and they
recently got an extension. My feeling is they are
in a catch-22 right now, because on the first count
the judge won't let them go after attorney fees
or --
MS. BABB-NUTCHER: Well, the judge --
basically, their first count is dismissed, and --
CITY MANAGER BOUCHER: And he withheld
adjudication of attorney's fees until we were done
with the second count, so they can't even try to
get attorney fees on the first count until the
second count, which we're working on now, is
disposed of.
Can you give them in a nutshell what the
second count is about and what they have to try to
prove to achieve success in that count?
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MS. BABB-NUTCHER: The second count is kind of
the meat of their complaint. It's alleging the
substantive due -process violation and procedural
due -process violation, and essentially they are
arguing that they didn't get a fair shot is what
the bottom line is, and they are basing it on the
fact that there was some bias alleged, bias with
certain board members; namely, Mr. McMillan
asserting that Mr. McMillan had a personal issue
with Mr. Morgan, alleged bias with Lamar Russell,
who is a P&Z member, and you should know is not a
final decision maker, which is an important concept
to understand, because he can think whatever he
wants, but he's not a final decision maker. It's
the final decision makers that matter in a federal
case.
So Mr. Russell made these comments on how
basically he doesn't like these special exceptions
in Cl; he thought it was a bad idea that we had
commercial there; that the property should have
been rezoned. And their argument is he was
predisposed to deny us because he just didn't want
to grant any more special exceptions in C1 --
that's essentially their argument -- and you're
denying us our fundamental constitutional rights to
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develop this property the way we want to develop
it, and you have denied us our procedural
due -process rights because we did not get a fair
and impartial decision maker.
MR. GARGANESE: At this point I just want to
bring up and remind the Council of an issue, and I
brought it up during my presentation when we were
talking about processes, okay?
Your Planning & Zoning Board not only serves
in an advisory capacity on quasi-judicial matters
like special exceptions, but they are also your
Planning Board.
So when all this was going on about this
specific application, you had your Planning &
Zoning Board and the Council talking about
eliminating special exceptions in commercial areas,
so you have comments made by Planning & Zoning
Board members when they got their planning hat on
that's being confused with, well, here's a Planning
& Zoning Board member, now I got my Quasi -Judicial
Advisory Board hat on, and they are sitting in both
capacities. That caused some confusion --
MS. BABB-NUTCHER: Yes.
MR. GARGANESE: -- in the record, no question
about it. And I advised the Council that in terms
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of processes, I don't think a Planning Board should
be an Advisory Board on Quasi -Judicial Matters for
that reason. They are mixing the Planning and the
Quasi -Judicial capacity.
MS. BABB-NUTCHER: And we have a good account
of a timeline. We have gone through a bunch of the
meeting minutes on workshops that were done and
agenda -item discussion, agenda items that were
done, and it matches up real nicely. Starting with
in 2005, this issue of special exception in C1
zoning was on a roll. The ball started rolling in
about 2005, about a year before their application
came forward. So that was already a discussion in
the City before they even made their application.
COMMISSIONER ROBERTS: I remember that they
were probably anticipating approval, because I
guess the City had been somewhat lenient on the
special exceptions up until then, so that kind of
got them caught right in the middle at that time
period, as I recall.
MR. GARGANESE: The timing of it I have no
doubt caused, I think, some confusion.
MAYOR PRO TEM HOOG: All of our special
exceptions in C1 zoning was basically geared
towards the moratorium on AlA, and we kind of kept
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impressing that it wasn't North Atlantic, wasn't
North Atlantic --
MR. GARGANESE: There was some discussion
about having North Atlantic --
MAYOR PRO TEM HOOG: Right, it was at that
time, but kept gearing back to --
COMMISSIONER ROBERTS: And didn't the
Development Board want to have North Atlantic
commercial, as I recall? So it was very confusing.
That's the reason I like the idea --
MAYOR PRO TEM HOOG: I sat through all the
meetings. I'm not convinced --
COMMISSIONER ROBERTS: I did, too, because we
were very interested in that --
MAYOR PRO TEM HOOG: -- there wasn't some bias
in there, because I sat and listened to it.
MR. GARGANESE: It's a contributing factor.
MAYOR PRO TEM HOOG: Mr. Russell controls that
board, as we all can sit here and well know that.
What Mr. Russell says, usually the Board does.
Just recently and since John Johanson has been
on that Board, I have noticed that Mr. Russell
doesn't have control on that Board anymore. But
Harry Pearson is somebody that he doesn't control,
and Mr. Friedman and Mr. Johanson. The rest of the
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people, if Lamar says no, it's no. If Lamar says
yes, it's yes. And I have sat through them Board
meetings, and I'm not convinced that it's not
biased.
MAYOR RANDELS: Betty, do you have some - I'm
sorry.
MAYOR PRO TEM HOOG: Our attorneys can do what
they need to do, but I don't think you're going to
get a favorable ruling, personally. I really
don't.
MAYOR RANDELS: Betty, some thoughts? You
weren't privy to all this going on two, three, four
years ago, but from what you read, what do you
think?
COMMISSIONER WALSH: I just have a question
about the Board of Adjustment. It sounds like
years ago when they made a decision it was the
decision, and something has changed since then
where now it can come in front of Council first; is
that true?
MS. BABB-NUTCHER: Right. At the time they
were the final decision maker and the only appeal
was to Circuit Court.
COMMISSIONER WALSH: Okay. That clears up a
little bit, because I'm sitting here and, like,
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wait a minute. Also, with the settlement we were
talking about maybe going -- I heard both Buzz and
Shannon say, and I kind of agree with it, if you go
back with a counter -settlement, there is other
things in here that they have noted. Is this
something we would have to also do or should be
doing, where they talk about additional
considerations regarding orientation and training
of Board members and things like that?
MS. BABB-NUTCHER: It would depend on how we
wanted to phrase the settlement offer. If we
wanted to phrase the settlement offer in terms of:
"We will offer you ten thousand dollars, a full
release, you dismiss the case, and we're done. We
don't do anything else you suggested."
Or, "We offer you five thousand dollars and
then we'll put on a nice presentation to all the
boards explaining proper" --
MAYOR PRO TEM HOOG: That needs to be done
regardless.
MS. BABB-NUTCHER: Well, we have done it.
MAYOR PRO TEM HOOG: But I have raised holy
hell, and I'm going to tell you about that since I
have been on this Council for six years, that these
boards need to be more in line with what they are
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supposed to do; not what their opinion was and what
the public criteria is hollering and going on.
They have a criteria to operate out of, not their
opinion and not what the public wants, and that's
why we're sitting here tonight.
COMMISSIONER ROBERTS: I disagree with that.
MAYOR PRO TEM HOOG: I sat through that
meeting and that meeting of Harbor Heights --
COMMISSIONER ROBERTS: You're absolutely right
on that one.
MAYOR PRO TEM HOOG: -- and that one was
basically what everything was based on, and it's
right there in factual print. Lamar Russell lives
there and he stated, "We should have zoned that a
long time ago." And he's probably right, but
that's still an opinion that everybody was
listening to, and it was stated publicly, and I was
sitting right in the audience.
And, yes, I'm looking at where -- I'm accused,
I guess, along with Buzz and the other Council
member, Leo Nicholas, Rocky Randels, we were all
there.
But it's not my policy as a Council member to
stand up and say, "You are out of order." That's
up to that gentleman right over there to do that,
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or you, or whoever is sitting in that seat. And
that's why we get into these positions, and this
isn't the first one we have had like this.
We have had Mr. Sauerman and other people in
here, and we have been basically in a lawsuit ever
since the last three years. It seems like we're
never out of lawsuits. We're getting just like
Cocoa Beach was eight years ago, ten years ago,
whatever. I am tired of hearing these people say
what their opinion is. Leave your opinion at home
when you come up here.
MS. BABB-NUTCHER: I understand that. A lot
of their opinion comes down to the bottom line that
was before them, which was compatibility. When a
Board member says, "This should have been R1," it
has to do with compatibility, which absolutely is
one of their prime criteria that they should have
considered. It's not compatible --
MAYOR PRO TEM HOOG: This is about as
incompatible as you can get. You got an R1 sitting
right there, you got an R3 sitting there, and now
you got a C1 over there that could be developed C1,
and I can tell you if they come in here and wanted
to put an office building there, they would be --
MR. GARGANESE: They can do it.
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MAYOR PRO TEM HOOG: They would be denied. At
that time they would have been denied, I can
guarantee it.
MAYOR RANDELS: Betty, you had some more
opinions, some finishing things?
COMMISSIONER WALSH: No, it sounds to me
like -- let me just ask this question. If we move
forward with the counter -settlement and they accept
it, then basically that's what happens? They
accept it, this goes away? They can still move
forward, because they have an extension on that
property, and they can continue to do whatever
their --
MR. GARGANESE: Their application was approved
after it came back from the appeal. They also
applied for a plat, replat. That was approved.
You know, they are ready to go. Whenever they are
ready to build, they have their permits, and I
think maybe they have, what, a one-year
extension -- Council granted a one-year extension
on their --
CITY MANAGER BOUCHER: The special exception.
MR. GARGANESE: -- on the exception, which is
allowed under the code. So they are ready to go.
If you want to settle and they accept the
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settlement, we would memorialize it in writing and
bring it back to you for a final decision, and in
which case if everybody approves, it's done.
MAYOR PRO TEM HOOG: What happens if they
don't?
MR. GARGANESE: Then we're going to finish up
with the discovery, take the rest of the
depositions. We're going to file a Motion for
Summary Judgment, and we'll wait for the Federal
Court to rule on our Motion for Summary Judgment.
If we prevail, then they can decide what they
want to do. If we don't prevail on the Motion for
Summary Judgment, then the case will be tried.
MS. BABB-NUTCHER: They might counteroffer.
MR. GARGANESE: Or they could counter. There
is also the counteroffer.
MAYOR PRO TEM HOOG: What kind of costs do we
incur after tonight, lets put it that way, before
you go to trial? What is the cost incurred to the
City or our insurance company?
MR. GARGANESE: Yeah, there is going to be
attorney fees and costs. They will have attorney
fees for doing the discovery and preparing the
necessary motions. There will be court reporter
fees because all of the depositions will have to be
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transcribed, and there will be more legal research
fees.
I mean litigation is not cheap. It's not for
the faint of heart either. It's just it is what it
is. And, you know, if you want to direct a
monetary settlement to this, just give us that
advice, and we'll try to negotiate that settlement,
with the understanding that the insurance carrier
is probably not going to put -- going to probably
put ten to twenty in this, maximum, if that, and if
they come back with a counteroffer at fifty, you
need to be willing to come up with the difference.
COMMISSIONER PETSOS: Or litigate?
MR. GARGANESE: Or litigate.
COMMISSIONER PETSOS: And that's what I was
going to ask. If they did come back with a
counter, we would have to get the buy -in from the
insurance company or they would say, "Hey, we don't
agree with that. We want to continue on with the
case or you guys come up with the difference"?
MR. GARGANESE: Right. The carrier will come
back and say, "Yeah, we'll put this in; otherwise
we're comfortable with litigating." And they
control the litigation under your insurance
contract. They --
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COMMISSIONER PETSOS: And I have heard both of
you mention, and you kind of got concurrence, that
the League's attorney agrees that this is a pretty
good case on our side --
MR. GARGANESE: Yeah.
COMMISSIONER PETSOS: -- to win?
MR. GARGANESE: Yeah, at its current posture,
yes.
COMMISSIONER WALSH: If we win, what do we
get?
MR. GARGANESE: Success on the lawsuit,
basically. Which unfortunately municipalities and
local government, counties, they basically defend
their position, and if they prevail, you know, you
prevail. You don't get attorney fees and costs
reimbursed to you. That's the way the system is
set up.
MAYOR RANDELS: Any more pertinent questions?
And I got a couple.
MS. BABB-NUTCHER: One more thing. The
Federal Court will require us to go to mediation at
some point, so even if we don't informally settle
the case, I filed a summary judgment, and it will
take a while to get a decision. It always does in
Federal Court. At some point we will be required
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to go to mediation, so that's still a potential for
settlement out there.
MAYOR RANDELS: Okay.
MAYOR PRO TEM HOOG: Can I ask --
MAYOR RANDELS: Sure.
MAYOR PRO TEM HOOG: Let's say that we tell
them that the counteroffer is twelve thousand or
twenty thousand, whatever the League decides it
wants to do with this, and they say no. So our
next step is we proceed on until mediation, and
Lord only knows when that's going to be, and then
we surpass the cost of their demand of $80,000,
what happens then? What responsibility of this is
the City's?
MR. GARGANESE: Nothing, other than to defend
the case.
MAYOR PRO TEM HOOG: And the League is going
to keep carrying on and they will carry this out to
the end?
MS. BABB-NUTCHER: They have in mind -- the
League has in mind what they -- a range that they
would be willing to settle, and anything above
that, they don't think it's worth it. Now, what --
MAYOR PRO TEM HOOG: That didn't answer my
question.
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MS. BABB-NUTCHER: What this Council can do is
give us a number, and we can negotiate up to that
number.
MAYOR PRO TEM HOOG: We have already exceeded
their demand of what they want now.
MS. BABB-NUTCHER: It's irrelevant what their
demand is.
MAYOR PRO TEM HOOG: I don't think it's
irrelevant.
MS. BABB-NUTCHER: Well, it's irrelevant in
the lawsuit and irrelevant in terms of any impact
on the City if we don't accept their $80,000. It
doesn't matter.
MAYOR PRO TEM HOOG: We're going on your
"ifs." You're standing there saying "if, if."
You're going on your "ifs."
MS. BABB-NUTCHER: Yes.
MR. GARGANESE: Well, we're --
MAYOR PRO TEM HOOG: I realize nothing is
guaranteed.
MR. GARGANESE: Nothing is guaranteed, and a
lot of times in litigation we have to read the
crystal ball. We have to give you our professional
judgment based on years of experience litigating in
Federal Court, "I think this might happen. Or if
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this happens, that's the nature of the beast." If
I knew exactly how this case would play out from
start to finish --
MAYOR PRO TEM HOOG: If I remember correctly,
Anthony, when we started this, you had a pretty
sure thing in your hand, and we lost.
MR. GARGANESE: On what?
MAYOR PRO TEM HOOG: On this case before it
ever went to the judge panel, to the panel of three
judges.
MR. GARGANESE: I didn't say "sure thing." I
mean they appealed the decision of the Board of
Adjustment.
MAYOR PRO TEM HOOG: You talked like we had --
MR. GARGANESE: It was a compatibility issue
there, and the Court didn't see it the way the
Board did. And the Court didn't see it the way the
Melbourne City Council ruled on that apartment
complex the other day. I thought there was an
appealable issue even after the Court ruled, which
I advised the Council. I wasn't saying there was a
strong appealable issue at that stage, but there
was an appealable issue on the Court's ruling.
MAYOR PRO TEM HOOG: I think anytime we have
boards, and I'm putting my neck out on the noose,
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and anytime we got boards, and the boards sit up
here and make decisions like this, it's going to
come back and bite us, because we have criteria
that you have to meet, and the boards walked out of
that criteria and said, "This is what we want and
this is what we're going to do and this is how it's
going to be," and I don't think -- how can you
defend that? How can you defend it?
MR. GARGANESE: Well, the Board's rationale
was -- just to remind everybody, there were two
detached single-family homes on either side of this
property, and they wanted to put a three- or
four -unit townhome in between two single-family
homes, you know. And Harbor Heights 1, Harbor
Heights 2, that whole issue of what's single-family
detached and what's not.
You go back to the time when they approved
this detached single-family home special exception
on the property adjacent to it, it created this
other property in the donut hole property --
MAYOR PRO TEM HOOG: You're talking about a
totally different district on the other side of the
fence.
MR. GARGANESE:
I
know.
But
you had detached
single-family homes
on
both
sides.
Could
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reasonable people disagree whether that was --
MAYOR PRO TEM HOOG: I'm well aware of the
whole case from day one to today. But, you know,
you can't say, well, because it's over there, that
has nothing to do with this over here. And they
did.
They really screwed up when they put an R1 in
there in my opinion personally. It has no bearing
on the case to me whatsoever. Because it's
commercial, you get special exceptions, of which I
got a very popular opinion on those, so here we
are.
And, you know, the other side of that fence
has no bearing on what's over here. And I know I
sat and listened --
MR. GARGANESE: This has been a bizarre
circumstance for the Board of Adjustment.
MAYOR PRO TEM HOOG: Most definitely.
MR. GARGANESE: They had to make that decision
whether they were going to allow a three -unit
townhome project in between two single-family
detached homes, or face the possibility where
somebody could put a 7 -Eleven on that property
under the City's zoning decisions that were made
decades ago.
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MAYOR PRO TEM HOOG
it up to.
That's what they opened
MR. GARGANESE: Those were the cards that were
dealt.
MAYOR PRO TEM HOOG: I would be thinking that
three or four homes, ten homes would be more
compatible than a 7 -Eleven store there.
MR. GARGANESE: It's a compatibility --
MAYOR PRO TEM HOOG: That's where I'm coming
from. I look at how it came about, what it is, and
I think any simple-minded judge would look at it
and think, They screwed up.
MS. BABB-NUTCHER: Thankfully we have a
federal judge, not a simple --
MAYOR PRO TEM HOOG: I'm saying any
simple-minded judge would come up with that
opinion. He wouldn't have to be a rocket scientist
to figure it out.
MAYOR RANDELS: Let me see if I can get a
summary here.
MR. GARGANESE: History is important, and I
understand that.
COMMISSIONER ROBERTS: Betty has a question.
MAYOR RANDELS: I'm sorry, Betty.
COMMISSIONER WALSH: One more question. They
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are asking for eighty thousand. I think what I
heard is that the League of Cities isn't willing to
pay the eighty thousand for settlement. They
basically are making a lower number or potentially
going through with litigating, following through
with litigation. I think that's where we're at.
MAYOR RANDELS: I think that's correct.
MR. GARGANESE: That's correct, that's the
feedback we're getting.
COMMISSIONER WALSH: So our decisinn bPrP is
do we want to go back with a counter -settlement or
do we want to say no and move on to litigation;
right?
MAYOR RANDELS: I think that's probably the
summary that I had in mind. I have got two or
three thoughts here. I view it a little
differently. I feel very confident that your firm
would prevail as it goes on up the line based on
what I read and what I see. But I don't see it as
a win or lose situation, which is kind of what the
Court system is, you won or you lost. And I read
them books.
I see it more as a right and a wrong
situation, because these are people -- we're
people, this is a community, and what is right and
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what is wrong, it becomes a moral issue to me;
rather than take it to court and say, okay, who did
and who didn't.
And I would like to point out two, three
things in here, and I'm not very wise in this, but
I'm just reading a little bit here: "It's
interesting to note," and I'm -- want to tell you
where I'm reading from. This is from the Circuit
Court of the 18th Judicial Circuit, State of
Florida, that comes back to us.
And it says: "It's interesting to note that
the City's own zoning ordinance defines a
townhouse," which is what they wanted to build.
Our ordinance says it's a single-family
dwelling unit. You don't want to hear this, but it
does say that. And it doesn't say anything about
whether it's detached or attached.
MS. BABB-NUTCHER: Correct.
MAYOR RANDELS: Now --
COMMISSIONER WALSH: It's in there.
MAYOR RANDELS: -- in my humble opinion that
property was C1, no question, it was C1,
commercially zoned, and a single-family home was
permissible by special exception.
MS. BABB-NUTCHER: Yes.
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MAYOR RANDELS: Out of them three lots there,
one of them had already been given a special
exception to put a single-family home on it right
next to this one.
MS. BABB-NUTCHER: Three of them had.
MAYOR RANDELS: Yep. So here we are. The
rest of all that commercial land has been given
single-family home special exceptions.
MS. BABB-NUTCHER: Yes.
MAYOR RANDELS: One remaining lot, our
ordinance says, Yes, it is permissible by special
exception whether it's detached or attached,
single-family, real clear. These people asked for
it.
MS. BABB-NUTCHER: Well, it doesn't say
whether it's detached or attached. It doesn't say
whether it's this or that.
MAYOR PRO TEM HOOG: Just specifies it as a
single-family home.
MS. BABB-NUTCHER: Townhouse. Doesn't say
"townhomes" or "townhouses". It defines
"townhouse" as a single-family dwelling.
MAYOR RANDELS: Are you relying on that to be
the determining --
MS. BABB-NUTCHER: I think the Court was
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wrong.
MAYOR RANDELS: Okay. Well, I don't know if I
want to pay to prove them wrong.
MS. BABB-NUTCHER: It doesn't matter.
MR. GARGANESE: That doesn't matter. It's
water under the bridge. We talked about that
during that other attorney/client session where the
Court partially quoted some of the code provisions.
MAYOR PRO TEM HOOG: Well, what makes it
change? What would be making it change? You say,
you know, you went -- well --
MAYOR RANDELS: While he's thinking, I'm
reading now from the Planning & Zoning Board
meeting minutes of May 11, 2005, and I'm reading
the last paragraph on page two, and it states:
"Lamar Russell discussed rezoning by special
exception. Todd Peetes commented that the City has
not rezoned, only allowed a different type of use.
"Anthony Garganese explained that if the
applicant meets the criteria for a special
exception, consistent with the comprehensive plan,
then he is entitled to the special exception.
"He further explained that the City has
historically granted residential use in the C1
zoning district, which is considered a policy
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decision."
Now, that was at the Planning & Zoning meeting
only a short while ago. I guess all this together
tells me that I hear us as a group saying, for
whatever reason it is, whether to save money,
morally, legally, or whatever, there is probably no
doubt you can prevail in the end, but I get the
feeling that we really don't want to see the end of
this movie go that way; and if so, we feel that
perhaps a settlement amount would be a
consideration, and I hear us saying, yes, we'll
take the lessons with the Board; we'll take
whatever it takes, make it as attractive as
possible, but I don't think we want to spend two
years and see the end of this movie, if I read the
board right.
MR. GARGANESE: That's the reading that I'm
getting from Council. Of course you can't vote in
the attorney/client session, but I have a question
for you.
MAYOR RANDELS: Yes, sir.
MR. GARGANESE: Because it's going to set the
parameters of our counteroffer.
MAYOR RANDELS: Certainly does.
MR. GARGANESE: We know the League wants to
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put some money on the table, and there are limits
to what they are willing to put on the table. We
send that to the plaintiffs, and the plaintiffs
come back with a counteroffer of forty, you know,
does this Council want to give me any more money to
play with in settlement negotiations or are we just
playing with the League's money?
MAYOR PRO TEM HOOG: My question is --
MAYOR RANDELS: Go ahead.
MAYOR PRO TEM HOOG: My question would be, do
we get to confer with you before we do anything
else? If this counteroffer from the League goes to
them and they refuse it and they come back, do we
get another bite of the apple?
MR. GARGANESE: Absolutely.
COMMISSIONER PETSOS: I would rather wait
until we get
MR. GARGANESE: You'd rather wait?
MAYOR PRO TEM HOOG: Yes, sir, that's how I
feel. I'm not comfortable with this at all.
MAYOR RANDELS: Okay. I know we can't vote,
but I seem to detect a consensus that -- and if
somebody doesn't detect the same thing -- that we
would like to go ahead and accept the League's
offer of what it would be --
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MR. GARGANESE: We'll work solely with the
insurance carrier to try to come up with a
settlement, final settlement of the case, which of
course would come back to you. I can't promise you
that with that dollar amount we're going to have to
play with with the League that the Plaintiffs are
going to accept it. But if they don't accept it
and make a counteroffer, we'll come back to you
with the counteroffer, and then we can decide what
you want to do.
MS. BABB-NUTCHER: Do you want to include
training? I mean that's not something the League
is going to recommend or not. They would look to
you if you wanted to do that.
MAYOR PRO TEM HOOG: Why would that be a cost
factor? We can do that ourselves.
COMMISSIONER PETSOS: We have done some of
that already --
MS. BABB-NUTCHER: If that's something we want
to throw in.
COMMISSIONER PETSOS: We just need to
reinforce a little bit more on that.
MR. GARGANESE: Ironically, we gave special
exception training, I think, in 2006.
MAYOR PRO TEM HOOG: They don't seem to pay
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attention though.
MR. GARGANESE: We do our best, Bob. I mean
that's all I can tell you. We try to train --
MAYOR PRO TEM HOOG: Therefore you need to
stop them.
COMMISSIONER PETSOS: Can you talk to them
like you talk to Frank?
MAYOR PRO TEM HOOG: That's my point. When
the meeting gets out of hand --
MR. GARGANESE: If you're telling me you want
to be treated like that, I'll be right on your case
every time.
MAYOR PRO TEM HOOG: I have sat and watched
Kate sit there and totally ignore stuff going on
that should have been stopped a half hour before it
started. And that's where the problem is.
MR. GARGANESE: We'll take that under
advisement and --
COMMISSIONER PETSOS: Stop being nice. Start
being like an attorney.
MR. GARGANESE: We try to work with the
boards, and, you know --
MAYOR PRO TEM HOOG: I have to admit the
Community Appearance Board I went to, Mr. Bowman
asked for a site plan, and she got off her computer
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and says, "We're not -- that's not in your realm,
stay away from that." And I admired her. I wanted
to get up and clap, because that's the first time I
have ever seen it happen.
MAYOR RANDELS: I think we view your job is to
keep us out of trouble and keep our feet out of our
mouth, and I can speak from experience here on
that. I would like to be told to shut up. With
that in mind --
CITY MANAGER BOUCHER: Hold on. On the
settlement, I think our insurance paperwork with
the League in a rider, that I think the League has
the authority when they take on a case to settle
without Council's approval under a certain amount,
so if it's within this amount we're talking about,
they have the right under our policy just to go
ahead and do the deal without Council approval.
COMMISSIONER PETSOS: That's fine at this
point. I think we agreed we would like to see it
settled.
MAYOR PRO TEM HOOG: If they settle it, that's
fine; if not, we still got to deal with it.
MR. GARGANESE: My apologies, I'll bring that
back to you, given the direction that you have
given me, and maybe if they say they are willing to
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r
;Ja
accept that, that dollar amount, you know, I'll
report back to you, of course, but -- and we'll
keep you apprised.
MAYOR RANDELS: Any further thoughts before we
close this attorney/client portion of the meeting?
COMMISSIONER PETSOS: No. But the Shuttle
should be going over any minute now.
MAYOR RANDELS: I would like to close the --
COMMISSIONER ROBERTS: Just two things. If
you want to go out and look --
MAYOR RANDELS: I'm going to close the meeting
then.
MR. GARGANESE: Is this regarding the lawsuit?
COMMISSIONER ROBERTS: Yes. Two things real
quickly, I just want to go back. What happens if
they do negotiate again, and you say everything
will be okay, it will go back. They have the
right, then, to build the townhouses or whatever --
do they still have to go back to the Board of
Adjustment?
CITY MANAGER BOUCHER: No. They have all
their approvals.
COMMISSIONER ROBERTS: So they are all set.
They are ready to go?
MR. GARGANESE: They are ready to go.
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COMMISSIONER ROBERTS: And the only other
question was the mediation opportunity at the
federal level, if we keep going, you know, they do
cite in here upwards of four hundred thousand
dollars of what they estimate their loss to be. So
that's the only thing that I am concerned about, if
you get to the federal level, if they take it that
far, you know, there are other -- there may be a
much higher mediated amount.
COMMISSIONER WALSH: That's to date, so we
don't know how that's going to go up.
MAYOR RANDELS: Okay. Some of these is
what -ifs. I'm going to take the chair's liberty
and say the attorney/client portion of the meeting
is closed, and the public and the attorney/client
session will commence.
The meeting is closed at 6:45.
(Thereupon, at 6:45 p.m.,
the testimony was concluded.)
FLORIDA REPORTING SPECIALISTS, INC.
1 (800) 881-2127
CERTIFICATE OF REPORTER
I, Linda C. Houellemont, being a Registered
Professional Reporter, do hereby certify that I was
authorized to and did stenographically report the
foregoing proceedings, pages 1 through 60, inclusive,
and that the transcript is a true and accurate
transcription of said proceedings.
DATED this 12th day of June, A.D., 2009.
LINDA C. HOUELLEMONT
Court Reporter
FLORIDA REPORTING SPECIALISTS, INC.
1 (800) 881-2127
cn
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28/19 35/23 50/8 50/9
circumstance [1] 47/17
circumstances [1] 18/22
cite [1] 59/4
Cities [4] 19/22 20/15 24/19 49/2
city [39] 1/1 1/9 1/9 1/15 1/19 1/21
2/10 2/11 2/12 2/19 3/9 3/11 6/15
9/24 10/1 10/3 10/14 13/8 14/10 17/
17/8 19/2 19/13 19/16 20/12 21/12
21/22 23/1 25/15 26/2 26/11 26/22
33/14 33/17 40/20 44/12 45/18 52/1'.
52/23
City's [6] 7/22 21/6 26/15 43/14
47/2450/12
claim [1] 12/22
clap [1] 57/3
clear [1] 51/13
clears [1] 35/24
client [12] 1/2 1/9 2/18 2/22 3/6
3/14 23/7 52/7 53/19 58/5 59/14
59/15
close [4] 3/3 58/5 58/8 58/11
closed [3] 3/7 59/15 59/17
Cocoa [1] 38/8
code [3] 17/2 39/24 52/8
come [21] 10/12 10/21 12/2 15/19
18/4 20/24 35/19 38/11 38/23 41/11
41/12 41/16 41/20 41/21 46/3 48/16
54/4 54/13 55/2 55/4 55/8
comes [6] 10/4 13/13 24/17 25/9
38/1350/10
comfortable [6] 5/21 6/16 7/21 8/7
41/2354/20
coming [1] 48/9
commence [1] 59/16
comment [3] 12/12 13/19 24/13
commented [1] 52/17
comments [3] 12/23 31/17 32/17
commercial [7] 13/8 27/2 31/20
32/16 34/9 47/10 51/7
commercially [1] 50/23
Commissioner [3] 1/16 1/17 1/17
community [3] 11/13 49/25 56/24
company [3] 20/11 40/20 41/18
compatibility [6] 13/14 13/15 38/14
38/16 45/15 48/8
compatible [2] 38/18 48/7
compensable [2] 6/20 17/18
compensated [2] 16/6 18/19
complaint [4] 3/16 6/6 15/25 31/2
complex [1] 45/19
comply [1] 16/21
comprehensive [1] 52/21
computer [1] 56/25
concept [1] 31/12
concerned [1] 59/6
concluded [1] 59/20
concurrence [1] 42/2
condition [1] 27/5
conduct [1] 7/13
confer [1] 54/11
confident [1] 49/17
conflict [2] 13/19 14/5
confused [1] 32/19
confusing [1] 34/9
confusion [2] 32/22 33/22
consensus [1] 54/22
consider [1] 28/18
consideration [3] 8/9 9/4 53/11
considerations [1] 36/8
considered [2] 38/18 52/25
considering [2] 13/6 21/14
consistent [2] 12/14 52/21
constantly [1] 16/21
constitutional [5] 16/5 17/17 18/15
22/231/25
contact [1] 19/21
contacted [1] 29/2
contemporaneous [2] 30/1 30/4
continue [5] 10/2 20/3 25/7 39/12
41/19
continued [1] 20/24
contract [1] 41/25
contributing [1] 34/17
control [4] 16/22 34/23 34/24 41/24
controls [1] 34/18
conversation [6] 26/23 27/10 27/16
27/18 27/21 27/22
conversations [4] 18/8 18/10 23/25
27/24
convinced [2] 34/12 35/3
coordinate [1] 23/20
copy [2] 3/18 4/17
correct [4] 25/22 49/7 49/8 50/18
correctly [1] 45/4
cost [5] 5/25 19/15 40/19 43/12
55/15
costs [6] 8/6 19/15 21/8 40/17 40/22
42/15
could [8] 8/12 10/14 16/1 26/2
38/22 40/15 46/25 47/23
council [30] 1/1 1/15 2/9 3/11 3/21
10/1 10/19 17/7 17/8 20/10 20/10
21/22 22/1 25/25 26/4 27/1 32/6
32/15 32/25 35/19 36/24 37/20 37/23
39/20 44/1 45/18 45/21 53/18 54/5
57/17
Council's [1] 57/14
count [8] 30/12 30/16 30/19 30/20
30/21 30/24 30/25 31/1
counter [5] 36/4 39/8 40/15 41/17
49/11
counter -settlement [3] 36/4 39/8
A
C
counter -settlement... [1] 49/11
counteroffer [14] 9/18 9/21 10/8
10/21 18/23 40/14 40/16 41/11 43/7
53/23 54/4 54/12 55/8 55/9
counties [1] 42/13
couple [5] 4/10 5/3 8/2 23/13 42/19
course [3] 53/18 55/4 58/2
court [37] 2/14 2/21 4/4 4/25 5/7
6/25 7/5 7/25 17/22 18/6 21/5 21/13
21/19 21/20 22/3 22/7 22/11 24/3
25/24 26/9 28/16 28/19 35/23 40/10
40/24 42/21 42/25 44/25 45/16 45/1;
45/20 49/21 50/2 50/9 51/25 52/8
60/13
Court's [3] 17/9 28/20 45/23
covered [1] 18/25
created [1] 46/19
criteria [9] 12/3 16/22 17/2 37/2
37/3 38/17 46/3 46/5 52/20
crystal [1] 44/23
current [1] 42/7
currently [1] 2/20
customary [1] 9/17
D
damages [3] 6/24 7/2 7/4
damaging [1] 10/14
dark [1] 20/23
date [2] 23/21 59/10
DATED [1] 60/10
day [4] 26/5 45/19 47/3 60/10
deadline [1] 5/8
deadlines [1] 5/8
deal [2] 57/17 57/22
dealt [1] 48/4
Debra [6] 1/22 2/12 3/9 3/22 4/1
8/10
decades [1] 47/25
decide [2] 40/11 55/9
decided [8] 4/11 7/5 17/8 21/22
23/8 23/11 25/25 26/4
decides [1] 43/8
decision [29] 6/25 7/6 9/9 10/8 17/!
19/12 19/19 21/5 21/6 21/6 21/10
22/10 25/15 26/9 26/10 28/20 31/12
31/14 31/15 32/4 35/17 35/18 35/22
40/2 42/24 45/12 47/19 49/10 53/1
decision maker [1] 32/4
decisions [3] 17/146/2 47/24
deductible [1] 19/2
defend [5] 20/12 42/13 43/15 46/8
46/8
defending [1] 8/8
defense [3] 7/22 9/24 19/1
defensible [1] 20/7
defines [2] 50/12 51/21
definite [1] 5/8
definitely [1] 47/18
delay [2] 22/17 22/18
demand [4] 4/18 43/12 44/5 44/7
denied [5] 14/8 17/4 32/2 39/1 39/2
denies [3] 13/23 13/25 28/5
deny [4] 15/19 18/3 18/16 31/22
denying [3] 14/7 29/14 31/25
depend [1] 36/10
depends [1] 10/19
deposition [2] 13/24 16/12
depositions [14] 4/8 4/9 4/12 4/13
5/2 5/11 5/12 5/24 7/25 8/1 8/2 8/4
40/840/25
[2] 17/17 18/15
detached [8] 46/11 46/16 46/18
46/24 47/22 50/17 51/12 51/16
detect [3] 8/10 54/22 54/23
determine [1] 16/1
determining [1] 51/24
develop [2] 32/1 32/1
developed [1] 38/22
Development [1] 34/8
difference [2] 41/12 41/20
different [3] 12/17 46/22 52/18
differently [1] 49/17
direct [1] 41/5
directed [2] 11/4 15/3
directing [1] 11/3
direction [2] 2/25 57/24
directly [2] 11/4 14/1
disagree [2] 37/6 47/1
disagreeing [1] 16/20
discovery [14] 3/17 4/3 4/5 5/1 5/8
5/9 5/11 5/20 5/24 10/5 10/13 15/25
40/740/23
discretion [1] 13/10
discs [1] 15/13
discuss [1] 4/15
discussed [1] 52/16
discussion [5] 29/5 29/6 33/8 33/13
34/3
discussions [2] 4/20 19/8
dismiss [1] 36/14
dismissed [1] 30/16
dispense [1] 24/19
disposed [1] 30/22
district [3] 2/21 46/22 52/25
documentation [4] 3/25 25/11
26/21 29/22
documented [2] 27/13 27/14
documents [2] 4/7 29/20
doesn't [13] 6/24 9/15 31/18 34/23
34/24 44/13 50/16 51/15 51/16 51/2
52/4 52/5 54/23
doing [3] 28/5 36/7 40/23
dollar [3] 10/9 55/5 58/1
dollars [3] 36/13 36/16 59/5
done [17] 4/5 5/9 5/20 5/24 5/24
6/3 21/1 28/13 30/3 30/18 33/7 33/9
36/14 36/19 36/21 40/3 55/17
donut [1] 46/20
doubt [2] 33/22 53/7
doubtful [1] 9/1
down [6] 7/14 11/13 13/13 13/17
27/938/13
drafted [1] 5/18
driven [1] 17/24
due [3] 31/3 31/4 32/3
due -process [3] 31/3 31/4 32/3
dug [1] 7/10
e-mail [5] 26/6 27/13 27/15 29/20
30/2
e-mails [3] 26/21 29/16 29/21
Earl [4] 4/10 13/18 13/19 13/23
early [1] 4/2
eight [1] 38/8
eighty [3] 10/1 49/1 49/3
either [2] 41/4 46/11
elect [1] 20/23
elements [1] 25/8
Eleven [2] 47/23 48/7
eliminating [1] 32/16
else [3] 20/22 36/15 54/12
end [4] 43/19 53/7 53/8 53/15
ended [1] 22/11
engineering [1] 19/15
entitled [3] 7/4 24/14 52/22
equate [1] 7/1
Esq [2] 1/21 1/22
essentially [2] 31/4 31/24
estimate [1] 59/5
estimated [1] 2/22
even [10] 7/25 8/7 11/13 16/3 19/18
24/13 30/19 33/14 42/22 45/20
every [3] 12/24 12/25 56/12
everybody [5] 20/22 26/22 37/16
40/346/10
everyone [2] 6/1 21/11
everything [2] 37/12 58/16
evidence [2] 18/6 18/7
exactly [2] 9/6 45/2
exceeded [1] 44/4
exception [17] 12/1 12/7 17/4 17/4
26/1 29/4 33/10 39/22 39/23 46/18
50/24 51/3 51/12 52/17 52/21 52/22
55/24
exceptions [9] 18/11 31/18 31/23
32/11 32/16 33/18 33/24 47/10 51/8
excessive [1] 11/19
expected [1] 2/4
expended [1] 9/1
expenses [3] 6/1 8/23 10/11
expensive [5] 5/14 5/14 7/24 7/24
7/25
experience [2] 44/24 57/7
expire [1] 26/6
explain [1] 26/19
explained [2] 52/19 52/23
explaining [1] 36/18
explanation [1] 6/9
explore [2] 26/25 27/1
extension [4] 30/11 39/11 39/20
39/20
extra [1] 29/6
extreme [1] 7/9
eve r11 17/18
F
face [1] 47/22
fact [3] 5/1 18/12 31/7
factor [2] 34/17 55/16
factual [6] 16/15 23/6 23/16 23/23
26/1337/13
faint [1] 41/4
fair [2] 31/5 32/3
fairly [1] 4/4
family [13] 46/11 46/13 46/15 46/18
46/25 47/21 50/14 50/23 51/3 51/8
51/13 51/19 51/22
far [2] 4/9 59/8
favorable [1] 35/9
February [1] 22/22
federal [24] 2/21 4/4 4/23 4/24 4/25
5/7 6/18 7/3 7/24 17/10 18/20 21/19
21/20 22/2 22/3 22/7 31/15 40/9
42/21 42/25 44/25 48/14 59/3 59/7
feedback [1] 49/9
feel [11] 5/21 6/16 6/21 6/22 7/21
7/23 9/7 24/15 49/17 53/9 54/20
feeling [2] 30/11 53/8
feelings [1] 11/2
fees [22] 4/21 5/6 8/6 9/2 21/1 21/7
21/16 23/4 24/15 24/17 25/21 28/1
28/11 29/6 30/13 30/18 30/20 40/22
40/23 40/25 41/2 42/15
feet [1] 57/6
felt [1] 20/1
fence [2] 46/23 47/13
few [1] 5/13
F
fifteen [2] 19/6 24/20
fifty [1] 41/11
figure [7] 8/12 8/13 9/14 9/15 24/1E
24/2148/18
file [4] 5/19 21/9 27/9 40/8
filed [8] 17/9 21/21 22/8 22/9 22/12
22/16 23/21 42/23
final [6] 31/12 31/14 31/15 35/22
40/255/3
find [2] 12/12 20/25
fine [2] 57/18 57/22
finish [3] 5/11 40/6 45/3
finishing [1] 39/5
firm [2] 8/24 49/17
five [3] 4/12 12/21 36/16
Florida [5] 1/10 20/15 21/4 21/8
50/10
follow [1] 22/15
following [1] 49/5
foregoing [1] 60/7
former [1] 27/1
forty [1] 54/4
forward [4] 3/2 33/13 39/8 39/11
four [5] 4/12 35/12 46/13 48/6 59/4
four -unit [1] 46/13
frame [1] 17/25
framed [2] 15/6 15/8
frames [1] 25/12
framework [1] 18/3
Frank [1] 56/7
free [1] 10/10
Friedman [1] 34/25
front [1] 35/19
full [1] 36/13
fundamental [1] 31/25
G
Garganese [4] 1/21 2/12 14/13
52/19
gathering [1] 16/16
gave [2] 30/10 55/23
geared [1] 33/24
gearing [1] 34/6
general [1] 13/7
gentleman [2] 14/9 37/25
get -go [1] 19/17
gets [3] 3/20 20/13 56/9
getting [7] 5/4 5/15 5/23 19/1 38/7
49/953/18
give [7] 6/8 6/9 30/23 41/6 44/2
44/2354/5
given [8] 9/23 22/13 22/14 23/1
51/2 51/7 57/24 57/25
giving [1] 18/11
glasses [1] 17/19
goes [3] 39/10 49/18 54/12
golly [1] 23/22
gone [5] 7/11 15/17 17/23 25/18
33/6
good [6] 10/21 20/16 21/3 29/23
33/542/4
gotten [1] 4/7
government [1] 42/13
grant [1] 31/23
granted [3] 18/11 39/20 52/24
group [1] 53/4
guarantee [1] 39/3
guaranteed [2] 44/20 44/21
guess [5] 12/9 14/11 33/17 37/20
53/3
[2] 11/9 41/20
H
half [1] 56/15
Hall [1] 1/10
hand [2] 45/6 56/9
happen [2] 44/25 57/4
happens [6] 21/11 39/9 40/4 43/13
45/1 58/15
Harbor [3] 37/8 46/14 46/14
Harry [2] 4/9 34/24
hat (2] 32/18 32/21
haven't [1] 14/18
having [4] 12/15 21/18 27/25 34/4
he's [4] 9/3 31/14 37/15 52/12
hear [3] 50/15 53/4 53/11
heard [5] 12/1 15/16 36/2 42/1 49/2
hearing [8] 9/22 15/20 23/5 23/9
23/20 24/2 28/21 38/9
heart [1] 41/4
Heights [3] 37/8 46/14 46/15
held [2] 1/9 2/1
hell [1] 36/23
help [2] 25/3 26/19
here's [2] 19/14 32/19
hereby [1] 60/5
Hey [1] 41/18
high [1] 8/17
higher [1] 59/9
historically [1] 52/24
history [2] 20/22 48/21
hold [4] 26/24 27/8 27/15 57/10
hole [1] 46/20
hollering [1] 37/2
holy [1] 36/22
home [6] 38/10 46/18 50/23 51/3
51/851/19
homes [6] 46/11 46/14 46/25 47/22
48/648/6
Hoog [2] 1/16 2/9
Houellemont [2] 60/4 60/12
hour [3] 1/10 9/3 56/15
hours [1] 8/2
however [1] 7/23
humble [1] 50/21
hundred [1] 59/4
I
I'll [6] 2/14 9/16 10/24 56/11 57/23
58/1
I've [2] 14/12 14/22
idea [2] 31/19 34/10
ifs [3] 44/15 44/16 59/13
ignore [1] 56/14
imagine [1] 6/21
impact [1] 44/11
impartial [1] 32/4
important [2] 31/12 48/21
impressing [1] 34/1
impression [1] 5/4
improper [1] 13/2
improvement [1] 25/9
improvements [1] 25/4
inappropriate [2] 12/23 28/17
include [1] 55/11
included [2] 13/11 13/12
inclusive [1] 60/7
incompatible [1] 38/20
incur [1] 40/18
incurred [3] 8/23 23/4 40/19
individual [1] 16/23
informally [1] 42/22
information [1] 3/17
insurance [10] 19/1 19/5 20/4 20/1]
40/20 41/8 41/18 41/24 55/2 57/11
intent [1] 26/16
interest [1] 11/7
interested [2] 10/20 34/14
interesting [2] 50/7 50/11
Interrogatories [1] 6/7
interrupt [1] 27/23
INVESTMENTS [2] 1/6 2/19
involved [2] 6/2 8/6
Ironically [1] 55/23
irrelevant [4] 44/6 44/9 44/10 44/11
isn't [2] 38/3 49/2
issue [13] 7/8 13/14 13/15 23/23
31/9 32/6 33/10 45/15 45/20 45/22
45/23 46/15 50/1
issued [1] 23/12
issues [5] 17/13 22/3 23/6 23/16
26/13
item [1] 33/8
items [1] 33/8
Pim [1] 30/3
job [1] 57/5
Pohanson [5] 13/22 14/3 17/14
34/2134/25
John [3] 13/22 14/3 34/21
Iudge [6] 30/13 30/15 45/9 48/11
48/1448/16
udges [1] 45/10
udgment [11] 5/17 5/18 5/19 5/22
7/15 20/13 40/9 40/10 40/13 42/23
44/24
udicial [5] 32/10 32/20 33/2 33/4
50/9
uncture [1] 17/19
1A
Kate [1] 56/14
keep [6] 20/20 43/18 57/6 57/6 58/3
59/3
kept [2] 33/25 34/6
kind [14] 4/2 7/8 7/13 15/21 18/13
20/15 29/18 31/1 33/18 33/25 36/3
40/17 42/2 49/20
knew [1] 45/2
knowledge [2] 17/22 18/4
L
Lamar [5] 31/10 35/1 35/1 37/13
52/16
land [1] 51/7
last [3] 13/18 38/6 52/15
late [1] 18/1
Latorre [1] 14/13
law [8] 6/18 6/19 7/3 18/14 21/4
21/8 24/6 24/14
lawsuit [14] 14/9 15/7 15/8 17/10
21/22 22/8 22/12 22/16 23/21 27/9
38/5 42/11 44/11 58/13
lawsuits [2] 22/9 38/7
League [13] 19/22 20/15 24/19 43/8
43/17 43/21 49/2 53/25 54/12 55/6
55/12 57/12 57/12
League's [3] 42/3 54/7 54/24
learned [1] 25/3
least [1] 3/21
Leave [1] 38/10
legal [3] 16/6 24/3 41/1
legally [1] 53/6
lenient [1] 33/17
L
24/14 25/2 25/3 36/2 39/19 57/25
Leo [1] 37/21
Mayor [7] 1/15 1/16 2/8 2/8 2/16
10/18 10/25
lessons [2] 25/2 53/12
McMillan [4] 4/10 13/18 31/8 31/9
let [8] 2/24 3/4 9/11 9/16 14/13
McNabb [1] 28/22
30/13 39/7 48/19
mean [10] 12/17 17/11 21/10 22/24
Let's [3] 13/17 15/23 43/6
23/1 30/141/3 45/12 55/12 56/2
lets [1] 40/18
meaning [2] 5/9 5/10
letter [2] 3/18 4/17
means [1] 11/11
level [6] 16/5 18/15 18/19 22/7 59/3
meat [2] 3/24 31/2
59/7
mediated [1] 59/9
liberty [1] 59/13
mediation [4] 42/21 43/1 43/10 59/;
likely [2] 10/4 19/6
meet [2] 12/3 46/4
limits [1] 54/1
Linda [2] 60/4 60/12
meeting [26] 1/1 2/3 2/4 2/17 3/4
7/12 11/22 12/20 13/1 13/1 13/22
line [6] 7/20 8/13 31/6 36/25 38/13
15/10 16/11 16/24 26/15 26/23 33/7
49/18
list [1] 6/7
37/8 37/8 52/14 53/2 56/9 58/5 58/1
listen [2] 11/11 15/11
59/14 59/17
meetings [9] 11/6 11/7 12/16 14/12
listened [2] 34/16 47/15
14/21 17/12 17/24 34/12 35/3
listening [1] 37/17
meetings' [1] 12/21
litigate [3] 7/24 41/13 41/14
meets [1] 52/20
litigating [5] 7/21 10/2 41/23 44/24
Melbourne [2] 21/12 45/18
49/5
Mitigation [10] 3/2 8/7 10/11 17/20
member [8] 16/14 16/23 27/1 31/11
32/20 37/21 37/23 38/15
18/5 41/3 41/24 44/22 49/6 49/12
members [12] 1/15 2/9 3/5 4/14
little [11] 19/9 20/22 22/18 23/12
7/10 11/12 16/12 16/25 17/14 31/8
24/7 25/13 26/19 35/25 49/16 50/6
32/1836/9
55/22
memorialize [1] 40/1
live [2] 26/1 26/11
mention [1] 42/2
lives [1] 37/13
middle [2] 16/23 33/19
LLC [2] 1/6 2/19
might [5] 5/12 7/17 24/7 40/14
local [1] 42/13
44/25
long [4] 13/4 13/9 18/9 37/15
mind [4] 43/20 43/21 49/15 57/9
look [8] 9/14 15/23 17/18 17/21
minded [2] 48/11 48/16
48/10 48/11 55/13 58/10
mindful [2] 6/1 8/5
looking [2] 4/21 37/19
minute [4] 11/23 14/25 36/1 58/7
Lord [1] 43/11
minutes [9] 2/23 7/12 12/18 12/20
lose [1] 49/20
12/22 15/10 16/11 33/7 52/14
loss [2] 18/19 59/5
misunderstanding [1] 23/19
lost [2] 45/6 49/21
mixing [1] 33/3
lot [9] 4/8 5/1 5/5 12/16 15/15 16/8
moment [1] 9/17
38/12 44/22 51/10
monetary [2] 18/22 41/6
lots [1] 51/1
money [7] 5/5 6/1 7/2 53/5 54/1
lower r2l 8/19 49/4
54/5 54/7
M
months [3] 5/13 22/21 23/13
...---t r4 7 cn i.
made [15] 7/5 9/18 9/25 12/5 13/2
13/3 14/18 15/24 19/18 29/8 31/17
32/17 33/14 35/17 47/24
mail [5] 26/6 27/13 27/15 29/20
30/2
mails [3] 26/21 29/16 29/21
major [1] 25/9
maker [4] 31/12 31/14 32/4 35/22
makers [1] 31/15
makes [1] 52/9
making [7] 4/18 11/25 14/15 17/1
19/12 49/4 52/10
manager [3] 1/19 2/10 26/6
mandate [3) 22/14 22/14 23/12
many [5] 11/5 11/5 11/6 14/12
14/22
market [1] 27/5
matches [1] 33/9
matter [8] 3/8 5/23 23/22 24/4
31/15 44/13 52/4 52/5
matters [3] 3/22 32/10 33/2
maximum [1] 41/10
may [8] 3/18 9/10 10/12 15/12
17/22 23/18 52/14 59/8
May 11 [1] 52/14
May 13 [1] 3/18
maybe [10] 9/13 19/6 19/8 20/21
morally Cl] 53/6
moratorium [1] 33/25
Morgan [8] 13/20 13/20 26/24 27/16
29/3 29/4 30/3 31/10
morning [1] 15/17
motion [9] 5/16 5/18 5/20 5/23 7/16
20/12 40/8 40/10 40/12
motions [1] 40/24
mouth [1] 57/7
move [4] 4/4 39/7 39/10 49/12
movie [2] 53/9 53/15
moving [1] 3/2
Mr [1] 14/2
Mr. [21] 13/20 13/20 14/13 15/18
17/14 26/24 27/16 29/3 29/4 29/19
31/8 31/9 31/10 31/17 34/18 34/20
34/22 34/25 34/25 38/4 56/24
Mr. Boucher's [2] 15/18 29/19
Mr. Bowman [1] 56/24
Mr. Friedman [1] 34/25
Mr. Garganese [1] 14/13
Mr. Johanson [2] 17/14 34/25
Mr. McMillan [2] 31/8 31/9
Mr. Morgan [7] 13/20 13/20 26/24
27/16 29/3 29/4 31/10
Mr. Russell [4] 31/17 34/18 34/20
34/22
Mr. Sauerman [1] 38/4
Ms. [4] 14/13 27/20 28/4 28/22
Ms. Chapman [2] 27/20 28/4
Ms. Latorre [1] 14/13
Ms. McNabb [1] 28/22
much [5] 2/16 3/23 9/6 9/12 59/9
municipalities [1] 42/12
must [2] 5/9 21/11
N
namely [1] 31/8
natural [1] 25/14
nature [1] 45/1
necessarily [1] 7/1
necessary [1] 40/24
neck [1] 45/25
need [11] 2/25 5/12 10/21 15/9 17/1
20/17 35/8 36/25 41/12 55/21 56/4
needed [1] 25/21
needs [2] 24/7 36/19
negotiate [3] 41/7 44/2 58/16
negotiations [2] 3/1 54/6
never [7] 8/20 10/15 12/6 23/5 28/2
28/638/7
next [6] 2/15 5/13 15/17 25/17
43/1051/4
nice [2] 36/17 56/19
nicely [1] 33/9
Nicholas [1] 37/21
noose [1] 45/25
normal [1] 25/17
normally [1] 25/18
North [4] 34/1 34/2 34/4 34/8
note [2] 50/7 50/11
noted [1] 36/5
nothing [5] 29/18 43/15 44/19 44/21
47/5
noticed [1] 34/22
number [8] 2/20 5/3 5/4 16/2 16/3
44/2 44/3 49/4
Nutcher [4] 1/22 2/13 3/9 28/23
PC
observations [1] 24/23
October [3] 22/22 23/8 29/2
October 1 [1] 23/8
off [5] 11/12 26/24 27/8 30/2 56/25
offer [8] 3/12 8/19 9/25 36/11 36/12
36/13 36/16 54/25
offered [1] 26/19
offering [1] 8/12
office [3] 15/18 15/19 38/24
official [3] 13/21 27/18 27/19
officially [1] 3/7
offtrack [1] 11/10
once [1] 24/3
one-year [2] 39/19 39/20
open [3] 2/3 3/4 11/21
opened [1] 48/1
opening [1] 8/11
operate [1] 37/3
opinion [22] 6/4 6/5 6/20 7/13
13/12 18/13 20/5 20/6 22/1 22/3 24/3
28/20 37/1 37/4 37/16 38/10 38/10
38/13 47/8 47/11 48/17 50/21
opinions [1] 39/5
opportunity [3] 3/24 25/1 59/2
option [1] 27/3
options [2] 26/25 27/2
order [2] 2/3 37/24
ordinance [3] 50/12 50/14 51/11
orientation [1] 36/8
CEJ
ORL [1] 2/20
Orlando [1] 2/21
otherwise [1] 41/22
our [29] 6/5 7/19 9/23 11/3 14/24
19/8 22/1 22/3 24/3 25/9 25/11 31/2
32/2 33/23 35/7 40/10 40/20 42/4
43/9 44/23 49/10 50/14 51/10 53/23
56/2 57/6 57/6 57/11 57/16
ourselves [1] 55/16
outside [1] 17/23
overturn [1] 6/25
overturned [5] 21/13 22/11 25/16
25/2426/9
overturns [3] 21/5 24/3 28/19
own [1] 50/12
P
p.m [2] 1/11 59/19
packages [1] 12/3
page [3] 13/18 29/1 52/15
pages [2] 5/17 60/7
paid [2] 19/14 28/11
panel [2] 45/9 45/9
paper [1] 21/11
paperwork [1] 57/11
paragraph [1] 52/15
parameters [1] 53/23
Park [1] 28/15
part [1] 20/18
partially [1] 52/8
particular [1] 13/16
pass[1] 9/17
past [1] 11/5
Patriots [1] 28/15
pay [9] 7/2 20/25 23/4 23/5 24/16
28/7 49/3 52/3 55/25
paying [1] 29/5
Pearson [2] 4/10 34/24
Peetes [1] 52/17
people [9] 11/16 29/18 35/1 38/4
38/9 47/1 49/24 49/25 51/13
perfect [1] 11/11
perfunctory [1] 24/7
perhaps [3] 4/21 8/11 53/10
period [2] 26/5 33/20
permissible [2] 50/24 51/11
permits [1] 39/18
person [4] 7/20 14/7 14/8 14/8
personal [6] 11/7 13/19 14/5 17/13
23/2531/9
personally [5] 8/25 11/3 13/21 35/9
47/8
persons [2] 2/4 2/7
perspective [1] 18/5
pertinent [1] 42/18
Petsos [2] 1/16 2/10
phase [1] 4/3
phone [1] 30/3
phrase [2] 36/11 36/12
pick [1] 12/18
place [2] 2/5 14/23
Plaintiff's [4] 3/13 3/15 3/19 4/14
plaintiffs [3] 54/3 54/3 55/6
plan [3] 11/14 52/21 56/25
planning [11] 17/12 32/9 32/12
32/14 32/17 32/18 32/19 33/1 33/3
52/13 53/2
plat [1] 39/16
play [3] 45/2 54/6 55/6
playing [1] 54/7
plus [2] 19/14 29/16
point [20] 2/24 3/3 3/8 7/3 8/3 8/15
9/7 10/3 14/13 14/14 16/13 21/1 22/E
25/20 32/5 42/22 42/25 50/4 56/8
57/19
point-blank [1] 16/13
policy [3] 37/23 52/25 57/16
Polk [1] 1/10
popular [1] 47/11
portion [3] 3/4 58/5 59/14
position [1] 42/14
positions [1] 38/2
possibility [2] 10/12 47/22
possible [2] 3/1 53/14
possibly [1] 7/7
postscript [1] 25/2
posture [3] 5/15 10/3 42/7
potential [1] 43/1
potentially [1] 49/4
predisposed [1] 31/22
preparing [1] 40/23
prerogative [1] 12/8
present [3] 2/13 2/14 3/6
presentation [2] 32/7 36/17
presented [1] 17/21
presents [1] 18/6
pretenses [1] 12/2
pretty [5] 5/21 6/18 6/19 42/3 45/5
prevail [7] 10/4 40/11 40/12 42/14
42/15 49/18 53/7
prevailed [1] 17/6
previously [2] 4/18 27/4
prime [1] 38/17
principals [4] 8/5 23/17 24/1 26/14
print [1] 37/13
prior [2] 3/14 19/11
privy [1] 35/12
Pro [3] 1/16 2/9 10/25
problem [2] 15/20 56/16
problematic [1] 19/17
procedural [2] 31/3 32/2
proceed [1] 43/10
proceedings [3] 2/1 60/7 60/9
process [4] 27/25 31/3 31/4 32/3
processes [2] 32/8 33/1
professional [2] 44/23 60/5
progress [1] 4/23
project [2] 14/24 47/21
promise [1] 55/4
proper [2] 2/5 36/18
property [16] 13/3 13/8 18/8 19/13
19/14 19/16 27/7 31/20 32/1 39/12
46/12 46/19 46/20 46/20 47/23 50/2
proposing [1] 3/20
prove [3] 16/16 30/25 52/3
proved [1] 16/18
provided [1] 3/15
providing [1] 3/18
provisions [1] 52/8
public [5] 3/5 11/22 37/2 37/4 59/15
publicly [1] 37/17
purpose [1] 2/17
pursue [2] 20/10 20/11
put [17] 5/15 20/8 26/7 26/16 26/16
36/17 38/24 40/18 41/9 41/10 41/22
46/12 47/7 47/23 51/3 54/1 54/2
quasi [5] 11/8 32/10 32/20 33/2
33/4
quasi -boards [1] 11/8
quasi-judicial [4] 32/10 32/20 33/2
33/4
question [20] 10/19 14/2 14/9 17/1
19/21 20/19 21/3 23/3 24/13 32/24
35/15 39/7 43/25 48/23 48/25 50/22
53/19 54/8 54/10 59/2
luestions [7] 4/6 6/8 6/12 6/14 7/17
8/342/18
luickly [2] 4/4 58/15
3
Rl [4] 13/4 38/15 38/20 47/7
R3 [1] 38/21
raised [1] 36/22
raising [1] 22/2
Randels [3] 1/15 2/8 37/21
range [2] 20/9 43/21
rather [3] 50/2 54/16 54/18
rationale [2] 21/18 46/9
Re [i] 1/5
read [9] 8/12 11/16 12/23 21/11
35/13 44/22 49/19 49/21 53/15
reading [5] 50/6 50/8 52/13 52/14
53/17
ready [8] 5/16 26/7 26/20 39/17
39/18 39/24 58/24 58/25
real [3] 33/9 51/13 58/14
realistic [1] 8/22
realize [2] 23/22 44/19
realm [1] 57/1
reapply [1] 29/5
reapplying [1] 29/3
reason [5] 12/8 14/17 33/3 34/10
53/5
reasonable [2] 24/16 47/1
reasoning [1] 21/18
rebut [2] 6/15 6/16
rebuttal [1] 7/19
recall [2] 33/20 34/9
received [1] 3/12
recently [3] 21/12 30/11 34/21
recommend [1] 55/13
record [3] 3/4 17/23 32/24
recorded [1] 12/16
recording [2] 12/17 16/10
refer (1] 27/25
reference [1] 29/3
reflect [1] 3/5
refuse [1] 54/13
regard [2] 25/5 25/13
regarding [7] 2/18 3/1 3/11 3/17
3/22 36/8 58/13
regardless [1] 36/20
Registered [1] 60/4
reimbursed [1] 42/16
reimbursement [1] 21/8
reinforce [1] 55/22
relates [1] 25/15
relative [1] 25/3
release [1] 36/14
relying [1] 51/23
remaining [1] 51/10
remand [2] 24/6 26/3
remanded [1] 28/15
remember [4] 19/11 30/2 33/15
45/4
remind [2] 32/6 46/10
removed [1] 4/25
render [1] 26/10
repeat [1] 25/21
replat [1] 39/16
report [2] 58/2 60/6
reporter [5] 2/14 40/24 60/2 60/5
60/13
require [2] 28/6 42/21
required [1] 42/25
[A
R
reschedule [1] 28/3
research [2] 18/14 41/1
residential [1] 52/24
resolve [2] 9/20 10/10
resolved [1] 23/23
respond [1] 7/15
responsibility [1] 43/13
rest [4] 4/11 34/25 40/7 51/7
review [1] 3/25
rezoned [5] 13/4 13/9 18/9 31/21
52/18
rezoning [1] 52/16
rider [1] 57/12
rights [3] 23/14 31/2532/3
rise [4] 16/4 17/16 18/14 18/18
road [1] 27/9
Roberts [2] 1/17 2/10
rocket [1] 48/17
Rocky [3] 1/15 2/8 37/21
role [2] 13/6 13/11
roll [i] 33/11
rolling [2] 8/16 33/11
rule [1] 40/10
ruled [2] 45/18 45/20
rules [1] 24/5
ruling [2] 35/9 45/23
Russell [7] 31/10 31/17 34/18 34/20
same [3] 14/20 15/20 54/23
sat [9] 14/12 15/16 17/11 34/11
34/16 35/2 37/7 47/15 56/13
Sauerman [1] 38/4
save [1] 53/5
saying [11] 6/8 11/10 12/15 18/8
26/7 27/15 44/15 45/21 48/15 53/4
53/11
says [12] 16/23 24/6 24/14 29/1
34/20 35/1 35/1 38/15 50/11 50/14
51/11 57/1
scheduled [1] 2/7
scheduling [3] 24/1 26/14 26/23
scientist [1] 48/17
screwed [2] 47/7 48/12
seat [1] 38/1
second [6] 20/18 22/12 30/19 30/21
30/2431/1
see [10] 10/22 45/16 45/17 48/19
49/19 49/19 49/23 53/8 53/15 57/19
seem [2] 54/22 55/25
seems [1] 38/6
seen [6] 8/20 14/22 14/23 18/16
18/1857/4
sell [1] 19/16
send [1] 54/3
sense [1] 28/10
sensitive [1] 25/7
sent [4] 4/18 6/7 26/6 27/14
serves [1] 32/9
session [11] 1/2 1/9 2/18 2/22 3/6
3/7 3/14 23/7 52/7 53/19 59/16
set [4] 4/7 42/17 53/22 58/23
settle [12] 5/3 10/1 10/8 10/23
18/23 20/1 20/9 39/25 42/22 43/22
57/1357/21
settled [1] 57/20
settlement [21] 3/1 3/12 3/20 4/16
19/8 36/1 36/4 36/11 36/12 39/8 40/:
41/6 41/7 43/2 49/3 49/11 53/10 54/1
55/3 55/3 57/11
settling [1] 10/20
bnannon [4] 1/1/ 2/1U 24/22 36/3
Sheldon [1] 3/19
short [1] 53/3
shot [1] 31/5
should [18] 6/23 11/22 13/3 13/7
13/8 14/25 16/6 18/8 18/19 31/11
31/20 33/1 36/6 37/14 38/15 38/17
56/1558/7
shouldn't [2] 11/13 18/10
show [3] 15/12 16/10 26/21
shut [1] 57/8
Shuttle [1] 58/6
side [9] 8/18 9/23 10/22 20/4 20/4
42/4 46/11 46/22 47/13
sides [2] 5/25 46/25
similar [3] 18/12 27/21 27/22
simple [3] 48/11 48/14 48/16
simple-minded [2] 48/11 48/16
simply [2] 6/7 7/4
since [6] 3/24 24/17 34/21 35/18
36/2338/6
single [14] 12/24 46/11 46/13 46/15
46/18 46/25 47/21 50/14 50/23 51/3
51/8 51/13 51/19 51/22
single-family [13] 46/1146/13
46/15 46/18 46/25 47/21 50/14 50/2:
51/3 51/8 51/13 51/19 51/22
sit [6] 11/10 11/11 15/18 34/19 46/1
56/14
site [2] 11/14 56/25
sits [1] 17/14
sitting [9] 8/1 14/17 32/21 35/25
37/5 37/18 38/1 38/20 38/21
situation [2] 49/20 49/24
situations [1] 9/18
six [2] 12/21 36/24
small [1] 22/17
solely [1] 55/1
solid [2] 6/18 6/19
somebody [3] 34/24 47/23 54/23
somehow [1] 6/23
something [9] 8/9 8/16 10/4 10/12
14/7 35/18 36/6 55/12 55/19
somewhat [1] 33/17
somewhere [3] 19/7 20/8 24/18
soon [1] 27/14
sorry [3] 28/24 35/6 48/24
sort [1] 17/17
sounds [2] 35/16 39/6
speak [2] 23/24 57/7
speaking [2] 9/16 23/17
special [25] 12/1 12/7 17/3 17/4
18/10 26/1 29/4 31/18 31/23 32/11
32/16 33/10 33/18 33/23 39/22 46/18
47/10 50/24 51/2 51/8 51/11 52/16
52/20 52/22 55/23
specific [2] 7/3 32/14
specifies [1] 51/18
speed [i] 3/21
spend [5] 5/5 9/6 9/11 9/12 53/14
Sr [2] 13/20 26/24
staff [3] 26/22 27/13 27/15
stage [2] 18/1 45/22
stages [1] 4/3
stand [1] 37/24
standing [1] 44/15
start [4] 2/3 10/24 45/3 56/19
started [3] 33/11 45/5 56/16
starting [2] 8/15 33/9
state [2] 24/14 50/9
stated [7] 2/13 11/21 13/21 13/24
15/11 37/14 37/17
statement [7] 8/11 13/5 13/18 14/3
14/4 14/19 16/13
statements [8] 11/20 12/5 13/2 13/3
13/7 14/15 18/12 18/13
states [1] 52/15
stating [1] 6/11
status [1] 3/10
status -wise [1] 3/10
stay [1] 57/2
stenographically [1] 60/6
step [3] 11/23 25/17 43/10
stepping [1] 11/23
steps [1] 25/14
Stevens [2] 3/19 14/2
stop [3] 9/16 56/5 56/19
stopped [1] 56/15
store [1] 48/7
story [1] 22/23
strategy [1] 3/2
strong [2] 9/24 45/22
stuff [4] 14/14 15/21 16/15 56/14
subsequently [1] 30/10
substance [2] 7/18 7/19
substantiate [3] 11/18 16/1 16/4
substantive [1] 31/3
success [3] 5/22 30/25 42/11
such [1] 13/3
suggested [2] 25/4 36/15
summarizing [1] 6/10
summary [14] 3/15 5/16 5/18 5/19
5/22 6/3 7/15 20/12 40/9 40/10 40/13
42/23 48/20 49/15
support [1] 6/8
supposed [1] 37/1
sure [5] 19/25 20/3 43/5 45/6 45/11
surpass [1] 43/12
Susan [3] 12/25 29/2 29/14
table [3] 27/3 54/1 54/2
take [17] 4/13 5/11 5/12 5/13 7/25
8/4 8/9 14/23 40/7 42/24 50/2 53/12
53/12 56/17 57/13 59/7 59/13
taken [3] 4/9 4/10 22/6
takes [1] 53/13
taking [3] 6/5 8/1 25/14
talk [3] 36/7 56/6 56/7
talked [3] 25/6 45/14 52/6
talking [9] 20/3 26/13 28/4 30/3
32/8 32/15 36/2 46/21 57/15
tape [1] 11/17
tell [8] 2/5 3/10 20/17 36/23 38/23
43/6 50/7 56/3
telling [3] 16/8 16/17 56/10
tells [2] 5/2 53/4
Tem [2] 2/9 10/25
ten [7] 1/16 19/6 20/8 36/13 38/8
41/1048/6
term [1] 14/11
terms [5] 4/23 5/22 32/25 36/12
44/11
testifies [1] 16/14
testimony [1] 59/20
thank [1] 2/16
Thankfully [1] 48/13
Therefore [1] 56/4
Thereupon [1] 59/19
thing [11] 7/7 11/15 24/10 24/12
24/16 29/17 42/20 45/6 45/11 54/23
59/6
things [10] 4/4 5/3 17/23 25/10 36/5
36/9 39/5 50/5 58/9 58/14
think [40] 7/20 8/14 8/15 8/25 9/22
10/3 12/14 13/4 19/20 20/17 22/21
24/25 25/1 25/4 25/8 30/7 31/13 33/1
IM
14
think... [22] 33/22 35/8 35/14 39/19
43/23 44/8 44/25 45/24 46/7 48/11
48/12 49/149/6 49/7 49/14 51/25
53/14 55/24 57/5 57/11 57/12 57/19
thinking [2] 48/5 52/12
though [3] 12/15 24/14 56/1
thought [3] 20/2 31/19 45/19
thoughts [4] 10/25 35/11 49/16 58/4
thousand [11] 10/1 19/6 20/9 24/20
36/13 36/16 43/7 43/8 49/1 49/3 59/,e
three [12] 17/8 22/21 35/12 38/6
45/9 46/12 47/20 48/6 49/16 50/4
51/1 51/5
three -unit [1] 47/20
throw [2] 19/6 55/20
thrown [1] 27/3
tightening [1] 25/11
time [21] 2/22 5/1 13/4 13/9 18/9
21/1 21/12 23/12 23/14 25/8 25/11
26/5 27/6 33/19 34/6 35/21 37/15
39/2 46/17 56/12 57/3
timeline [2] 22/25 33/6
times [3] 11/5 15/16 44/22
(timing [1] 33/21
tired [1] 38/9
today [3] 10/5 14/14 47/3
Todd [1] 52/17
together [1] 53/3
tonight [2] 37/5 40/18
too [4] 18/1 22/24 25/10 34/13
took [1] 27/8
totally [2] 46/22 56/14
towards [1] 33/25
townhome [2] 46/13 47/21
townhomes [1] 51/21
townhouse [3] 50/13 51/20 51/22
townhouses [2] 51/21 58/18
train [1] 56/3
trained [1] 16/25
training [4] 25/5 36/8 55/12 55/24
transcribed [1] 41/1
transcript [4] 12/24 12/25 16/10
60/8
transcription [1] 60/9
transcripts [5] 7/11 12/19 15/3 15/5
15/12
translate [1] 6/23
treated [1] 56/11
trial [3] 20/13 20/13 40/19
tried [1] 40/13
TRIPLE [4] 1/6 2/18 8/5 23/18
trouble [1] 57/6
true [2] 35/20 60/8
try [11] 6/13 9/19 10/10 18/23 24/1
30/19 30/24 41/7 55/2 56/3 56/21
trying [5] 15/25 16/16 23/20 25/3
25/10
turn [1] 3/8
twelve [1] 43/7
twenty [4] 20/9 24/20 41/10 43/8
two [18] 4/9 5/4 13/18 16/3 17/8
22/9 29/1 29/18 35/12 46/10 46/13
47/21 49/15 50/4 52/15 53/14 58/9
58/14
type [4] 11/15 12/25 27/22 52/18
U
unclear [1] 25/13
under [10] 12/2 18/21 21/4 39/24
41/24 47/24 52/6 56/17 57/14 57/16
understand [3] 31/13 38/12 48/22
unaerstanamg LIJ 41A3
underwriting [1] 19/22
unfortunately [1] 42/12
unit [3] 46/13 47/20 50/15
unless [1] 10/4
unreasonable [1] 7/9
until [7] 5/20 23/21 30/18 30/20
33/18 43/10 54/17
upon [2] 18/14 26/12
upwards [1] 59/4
us [20] 7/2 9/10 9/11 13/1 15/3
20/17 25/2 26/19 28/15 31/22 31/25
32/2 41/6 42/21 44/2 46/3 50/10 53/
53/11 57/6
use [2] 52/18 52/24
V
lid [1] 12/1
rbal[1] 27/10
rbatim [1] 12/24
rsus [2] 2/19 23/1
;w [2] 49/16 57/5
dation [3] 16/5 31/3 31/4
ice [1] 16/10
(wait [6] 11/23 14/25 36/1 40/9
54/1654/18
waited [1] 26/5
walked [1] 46/4
Walsh [2] 1/17 2/9
want [39] 5/3 5/5 5/12 9/19 9/20
10/19 18/22 18/24 19/10 19/11 19/1:
20/11 20/16 21/14 26/4 31/22 32/1
32/5 34/8 39/25 40/12 41/5 41/19
44/5 46/5 49/11 49/12 50/7 50/15
52/3 53/8 53/14 54/5 55/10 55/11
55/19 56/10 58/10 58/15
wanted [15] 4/13 4/15 10/7 20/10
20/14 23/22 26/25 30/7 36/11 36/12
38/23 46/12 50/13 55/14 57/2
wants [4] 31/14 37/4 43/9 53/25
wasn't [6] 19/25 24/13 34/1 34/1
34/1545/21
watched [1] 56/13
water [1] 52/6
way [12] 6/4 10/24 15/23 20/25
25/1 27/6 32/140/18 42/16 45/16
45/1753/9
we'll [16] 3/23 10/2 10/21 18/24
19/10 19/15 36/17 40/9 41/7 41/22
53/11 53/12 55/1 55/8 56/17 58/2
we're [26] 4/3 5/7 10/5 10/13 14/17
15/25 16/8 16/17 25/10 30/21 36/14
37/5 38/6 38/7 40/6 40/8 41/23 44/1,
44/18 46/6 49/6 49/9 49/24 55/5 57/:
57/15
we've [1] 12/24
weeks [1] 4/11
went [4] 23/15 45/9 52/11 56/24
weren't [1] 35/12
what's [5] 5/16 12/8 46/15 46/16
47/14
what -ifs [1] 59/13
whatever [9] 19/10 31/13 38/9
39/12 43/8 53/5 53/6 53/13 58/18
whatsoever [1] 47/9
Whenever [1] 39/17
whether [12] 16/1 17/16 20/1 20/2
21/14 47/1 47/20 50/17 51/12 51/16
51/17 53/5
while [4] 24/6 42/24 52/12 53/3
wnO VPJ 1//14 Its/5 ly/LL LS/S L4/5
29/6 31/11 50/2 50/3
who's [1] 2/5
whoever [1] 38/1
whole [4] 5/1 13/15 46/15 47/3
why [4] 23/16 37/5 38/2 55/15
will [17] 2/3 10/4 20/12 36/13 40/13
40/22 40/24 40/25 41/1 41/21 42/21
42/23 42/25 43/18 58/17 58/17 59/16
willing [7] 20/8 24/19 41/12 43/22
49/2 54/2 57/25
win [5] 7/23 21/10 42/6 42/9 49/20
wise [2] 3/10 50/5
withheld [1] 30/17
within [3] 5/13 13/11 57/15
without [2] 57/14 57/17
won [6] 6/22 9/8 9/8 9/9 24/17
49/21
won't [2] 3/22 30/13
word [1] 27/9
words [1] 25/16
work [2] 55/1 56/21
working [1] 30/21
workshops [1] 33/7
worth [1] 43/23
wouldn't [3] 15/20 28/9 48/17
writ [8] 4/22 6/22 9/7 9/12 17/6
21/9 22/13 22/14
writing [1] 40/1
written [2] 4/5 12/18
wrong [7] 7/6 13/5 13/6 49/23 50/1
52/1 52/3
reah [4] 40/21 41/22 42/5 42/7
rear [4] 22/19 33/12 39/19 39/20
rears [8] 35/13 35/17 36/24 38/6
38/8 38/8 44/24 53/15
rep [1] 51/6
rou'd [1] 54/18
Z
zoned [2] 37/14 50/23
zoning [14] 17/12 21/4 21/6 32/9
32/15 32/17 32/20 33/11 33/24 47/24
50/12 52/13 52/25 53/2