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FW Privileged and Confidential Metro South - Commissioner E-mail SearchPlease review the following email and let me know which documents we have and have not produced asap Thanks From: Pepe, Thomas F. Sent: Thursday, February 21, 2013 10:31 AM To: Steven J. Alexander Subject: Privileged and Confidential Metro South - Commissioner E-mail Search Importance: High Privileged and Confidential Steve, please let me know if the City has any of the documents, listed below as having not been produced. Also please provide Andrea Amigo with the items that the defense team needs for its expert and as listed below. Thank you. Very truly yours, Thomas F. Pepe City Attorney City of South Miami 1450 Madruga Avenue, Ste 202, Coral Gables, Florida 33146 Tel: (305) 667-2564 Fax: (305) 341-0584 E-mail: tpepe@southmiamifl.gov ATTENTION: This e-mail may contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the addressee named above. If you are not the intended receiver, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this e-mail in error, please immediately notify us by telephone, call collect if outside of your area code and delete this e-mail. We will reimburse you for the cost of your long distance call. Thank you. Please also note: All e-mails to and from this e-mail site are kept as a public record. Your e-mail communications, including your e-mail address may be disclosed to the public and media at any time pursuant to Florida Statutes, ch. 119. ________________________________ From: Andrea Amigo [aamigo@RRBPA.COM] Sent: Thursday, February 21, 2013 10:12 AM To: Pepe, Thomas F. Cc: Lyman H. Reynolds, Jr. Subject: RE: Metro South - Commissioner E-mail Search Mr. Pepe, Thank you for taking the time to speak with me this morning regarding the Metro case. This will confirm that the City Clerk has set aside the P&Z records for Metro’s inspection and copying. As discussed, Green’s office has already reviewed these records back in October 2012, but has not picked them up. We will note this in our response to Metro’s request for production. Per your request, please see the list of documents we still need to respond to Metro’s request for production: 3. All documents relating to any request for funding or tax credits by or for, or the awarding of funding to, Plaintiff or the Project, including but not limited to Community Development Block Grant (CDBG) funding, and any documents relating to any denials or withholding of such funding and penalties against Plaintiff in connection with any such funding. 4. All documents relating to any requests for CDBG funding by, or the awarding of CDBG funding to, any other community-based organization or community development corporation. 5. All correspondence between Defendant and either Plaintiff or the Project. 6. All newspaper articles, press releases, and documents related thereto relating to Plaintiff or the Project. 7. All statements, whether written or oral, and affidavits of any person relating to any of the facts alleged in Plaintiffs amended complaint. 9. All other documents relating to Plaintiff, the Project, and any persons related thereto. 13. All records relating to the development of affordable senior apartments proposed by Plaintiff. 14. All correspondence regarding the development of affordable senior apartments proposed by Plaintiff. 15. All legal opinions or legal memoranda regarding the development of affordable senior apartments proposed by Plaintiff. Please note that we need the following records for our defense and to send to our expert for her review: 1. City of South Miami’s approved meeting minutes and agendas for 1/31/12, 3/20/12, 3/27/12, 4/17/12, 5/1/12, 5/15/12, 8/7/12, and 8/21/12 2. Videos of City of South Miami Commission Meetings for 3/20/12, 3/27/12, 4/17/12, 5/112, 5/15/12, 8/21/12 3. Videos of Planning Board Meeting 2/28/12 4. City of South Miami’s City Commission Meeting After Action Summaries for 3/27/12, 4/17/12, 5/1/12, 5/15/12, 8/7/12, 8/21/12 Thank you for your assistance with this matter. We look forward to hearing from you on the status of these documents as our response to Metro’s request for production is due by 3/4/13 Should you have any questions, please contact my office. Andrea Amigo 470 Columbia Drive • Suite C101 West Palm Beach, FL 33409 Tel: (561) 688-6560 Fax: (561) 688-2343 aamigo@RRBPA.COM / www.rrbpa.com NOTICE TO RECIPIENT: This e-mail message and any attachment to this e-mail message contains confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, or use or disseminate this e-mail or any attachments to it. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at 561-688-6560 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by Roberts, Reynolds, Bedard & Tuzzio, PLLC. From: Pepe, Thomas F. [mailto:TPepe@southmiamifl.gov] Sent: Thursday, February 21, 2013 9:30 AM To: Steven J. Alexander Cc: Brimo, Christopher; Andrea Amigo; Lyman H. Reynolds, Jr. Subject: Metro South - Commissioner E-mail Search Thank you. I will advise the City's defense attorneys by forwarding this email string to them. Very truly yours, Thomas F. Pepe City Attorney City of South Miami 1450 Madruga Avenue, Ste 202, Coral Gables, Florida 33146 Tel: (305) 667-2564 Fax: (305) 341-0584 E-mail: tpepe@southmiamifl.gov ATTENTION: This e-mail may contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the addressee named above. If you are not the intended receiver, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this e-mail in error, please immediately notify us by telephone, call collect if outside of your area code and delete this e-mail. We will reimburse you for the cost of your long distance call. Thank you. Please also note: All e-mails to and from this e-mail site are kept as a public record. Your e-mail communications, including your e-mail address may be disclosed to the public and media at any time pursuant to Florida Statutes, ch. 119. ________________________________ From: Steven J. Alexander Sent: Wednesday, February 13, 2013 2:11 PM To: Pepe, Thomas F. Cc: Brimo, Christopher; Steven J. Alexander Subject: Fwd: Metro South - Commissioner E-mail Search Mr. Pepe Please see the attached per your prior email reminder on this issue. If you have any questions please contact me or Mr. Brimo. Thanks Steven Begin forwarded message: From: "Brimo, Christopher" <CBrimo@southmiamifl.gov> To: "Steven J. Alexander" <SAlexander@southmiamifl.gov> Cc: "Pepe, Thomas F." <TPepe@southmiamifl.gov> Subject: RE: Metro South - Commissioner E-mail Search Mr. Alexander: Per your request please review the following. Ms. Stacy Linton and two of her associates with James K. Green Esq., met with me on Tuesday October 2, 2012, to review Planning & Zoning Department files that were requested in Metro South public records request letter (including the items listed in your email). All the files were made available for their review, of which they tagged copies they wanted reproduced. My department produced copies of all documents that were requested on that day. Please refer to the attached list of files. Requested materials were delivered to the City Clerk on October 4, 2012 with the reproduction costs. The Clerks office would contact Mr. Green for document pickup. There was also request by Ms. Linton for copies of video from two Planning Board hearings, unrelated to the Metro South development. Copies of these two DVD's were mailed directly to Ms. Linton with copies also going to the City's defense team and City Attorney. I sent an email to Mr. Pepe on October 3, 2012 advising of the additional request. The City Clerk's office provided me today with a copy of a fax transmission from October 17, 2012 to James K. Green, P.A. advising that the Planning & Zoning materials requested by his associates were available for pickup. I have attached the documents provided by the City Clerk. Please advise if you require additional information. Thank you. Chris Christopher Brimo, AICP Planning Director City of South Miami 6130 Sunset Drive South Miami, FL 33143 Tel: (305) 663-6326/6327 [Southmiamiseal 1x1][120px-Tree_City_USA2] [email] The City of South Miami is a public entity, subject to Chapter 119 of the Florida Statutes concerning public records. E-mail messages and their attachments are covered under such laws and thus subject to disclosure. All e-mail sent to and received at this address, is captured by our servers and kept as a public record. From: Steven J. Alexander Sent: Wednesday, February 13, 2013 9:25 AM To: Brimo, Christopher; Menendez, Maria M. Subject: FW: Metro South - Commissioner E-mail Search Can either of you give e an update on the status of the request enumerated below? 1. All records relating to an "Ordinance amending Section 20-8.9 of the Land Development Code titled Special Exceptions within the TODD district, in order to include additional criteria for defining large scale developments; providing conditions for review and approval; providing for the expiration and extension of approvals. 3/5 (City Manager-Planning & Zoning)." 2. All correspondence regarding an "Ordinance amending Section 20-8.9 of the Land Development Code titled Special Exceptions within the TODD district, in order to include additional criteria for defining large scale developments; providing conditions for review and approval; providing for the expiration and extension of approvals. 3/5 (City Manager-Planning & Zoning)." 3. All legal opinions or legal memoranda regarding an "Ordinance amending Section 20-8.9 of the Land Development Code titled Special Exceptions within the TODD district, in order to include additional criteria for defining large scale developments; providing conditions for review and approval; providing for the expiration and extension of approvals. 3/5 (City Manager-Planning & Zoning)." 4. All records relating to the rezoning request submitted by Metro South Senior Apartments Limited Partnership for the 6,700 square foot rear portion of the site that comprises 6101 Sunset Drive, Folio #09-4025-011-0100. 5. All correspondence regarding the rezoning request submitted by Metro South Senior Apartments Limited Partnership for the 6,700 square foot rear portion of the site that comprises 6101 Sunset Drive, Folio #09-4025-011-0100. 6. All legal opinions or legal memoranda regarding the rezoning request submitted by Metro South Senior Apartments Limited Partnership for the 6,700 square foot rear portion of the site that comprises 6101 Sunset Drive, Folio #09-4025-011-0100. 7. Please provide all calendars and visitors' logs for Philip K. Stoddard, Valerie Newman, Walter A. Harris, Bob Welsh, Jr., Josh Liebman, Hector Mirabile, Thomas Pepe, Christopher Brimo, Luigi Vitalini, Dean Whitman, Claudia Hauri, Jorge Cruz, Sally B. Philips, James Dundorf, Yvonne Beckman and/or their staffs between January 1, 2011 and present kept anywhere. 8. Please provide a current zoning map of the City. 9. Any and all records relating to or referencing the United States Census or the Department of Housing and Urban Development since January 1, 2008. 10. If any of the records requested above have been destroyed, please provide any and all records authorizing the destruction thereof. Thanks From: Pepe, Thomas F. Sent: Tuesday, February 12, 2013 6:51 PM To: jameskgreen@bellsouth.net<mailto:jameskgreen@bellsouth.net>; 'Boulris, Amy' Cc: aamigo@rrbpa.com<mailto:aamigo@rrbpa.com>; lreynolds@rrbpa.com<mailto:lreynolds@rrbpa.com>; Steven J. Alexander Subject: RE: Metro South - Commissioner E-mail Search Thank you for your response. We are proceeding diligently to review the more than 21,000 emails and associated documents produced for our review to filter out the privileged documents. I believe that we have released approximately 12,000 of those documents to date and they have been transferred to the shared folder on Relativity to which your team has access. I will forward your email to the new City Manager to check on the production of the items that are not emails. Very truly yours, Thomas F. Pepe City Attorney City of South Miami 1450 Madruga Avenue, Ste 202, Coral Gables, Florida 33146 Tel: (305) 667-2564 Fax: (305) 341-0584 E-mail: tpepe@southmiamifl.gov<mailto:tpepe@southmiamifl.gov> ATTENTION: This e-mail may contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the addressee named above. If you are not the intended receiver, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this e-mail in error, please immediately notify us by telephone, call collect if outside of your area code and delete this e-mail. We will reimburse you for the cost of your long distance call. Thank you. Please also note: All e-mails to and from this e-mail site are kept as a public record. Your e-mail communications, including your e-mail address may be disclosed to the public and media at any time pursuant to Florida Statutes, ch. 119. ________________________________ From: James K. Green [campeon@bellsouth.net] Sent: Tuesday, February 12, 2013 6:39 PM To: Pepe, Thomas F.; jameskgreen@bellsouth.net<mailto:jameskgreen@bellsouth.net>; 'Boulris, Amy' Cc: aamigo@rrbpa.com<mailto:aamigo@rrbpa.com>; lreynolds@rrbpa.com<mailto:lreynolds@rrbpa.com> Subject: RE: Metro South - Commissioner E-mail Search Dear Mr. Pepe: This is response to your email dates February 1, 2013 asking: “I noticed that your "First Request for Production" appears to request the same e-mails that were requested in you[r] public record request. May I presume that our current process of producing those emails will be tantamount to a formal response to the 1st request for production? Would this also be true of our response to the other items that have previously been produced in response to your public record request?” As to your first question, we still haven’t received all (or most) emails responsive to our public request dated August 22, 2012, especially emails on private accounts where most commissioners have not consented to the requested searches. That said, footnote one of the First Request for Production addresses compliance with that request by commissioners who consented to execution of the agreed term search by Credence on their personal computers prior to serving the First Request for Production. Further, the First Request for Production is submitted under the Federal Rules of Civil Procedure which imposes a continuing duty to supplement. That noted, there will be no requirement that the City duplicate in its Response to our First Request for Production that which has been produced in response to our public records request. As to your second question, you mention “other items that have previously been produced in response to your public record request.” I am not sure what you mean by “other items.” The public records request has been pending for more than five months, and all we've received is minutes of meetings and city manager reports with some attachments, and some of the emails from the City’s server. I don't think we received all (or any) of the following: 1. All records relating to an "Ordinance amending Section 20-8.9 of the Land Development Code titled Special Exceptions within the TODD district, in order to include additional criteria for defining large scale developments; providing conditions for review and approval; providing for the expiration and extension of approvals. 3/5 (City Manager-Planning & Zoning)." 2. All correspondence regarding an "Ordinance amending Section 20-8.9 of the Land Development Code titled Special Exceptions within the TODD district, in order to include additional criteria for defining large scale developments; providing conditions for review and approval; providing for the expiration and extension of approvals. 3/5 (City Manager-Planning & Zoning)." 3. All legal opinions or legal memoranda regarding an "Ordinance amending Section 20-8.9 of the Land Development Code titled Special Exceptions within the TODD district, in order to include additional criteria for defining large scale developments; providing conditions for review and approval; providing for the expiration and extension of approvals. 3/5 (City Manager-Planning & Zoning)." 4. All records relating to the rezoning request submitted by Metro South Senior Apartments Limited Partnership for the 6,700 square foot rear portion of the site that comprises 6101 Sunset Drive, Folio #09-4025-011-0100. 5. All correspondence regarding the rezoning request submitted by Metro South Senior Apartments Limited Partnership for the 6,700 square foot rear portion of the site that comprises 6101 Sunset Drive, Folio #09-4025-011-0100. 6. All legal opinions or legal memoranda regarding the rezoning request submitted by Metro South Senior Apartments Limited Partnership for the 6,700 square foot rear portion of the site that comprises 6101 Sunset Drive, Folio #09-4025-011-0100. 7. Please provide all calendars and visitors' logs for Philip K. Stoddard, Valerie Newman, Walter A. Harris, Bob Welsh, Jr., Josh Liebman, Hector Mirabile, Thomas Pepe, Christopher Brimo, Luigi Vitalini, Dean Whitman, Claudia Hauri, Jorge Cruz, Sally B. Philips, James Dundorf, Yvonne Beckman and/or their staffs between January 1, 2011 and present kept anywhere. 8. Please provide a current zoning map of the City. 9. Any and all records relating to or referencing the United States Census or the Department of Housing and Urban Development since January 1, 2008. 10. If any of the records requested above have been destroyed, please provide any and all records authorizing the destruction thereof. James K. Green, Esq. JAMES K. GREEN, P.A. Suite 1650, Esperantè 222 Lakeview Ave. West Palm Beach, FL 33401 Telephone: 561-659-2029 Facsimile: 561-655-1357 Email: jkg@jameskgreenlaw.com<mailto:jkg@jameskgreenlaw.com> jameskgreenlaw.com P Please consider the environment before printing this e-mail. NOTICE: This electronic mail transmission from the law firm of James K. Green, P.A. may constitute an attorney-client communication that is confidential and privileged at law. It is not intended for transmission to, or receipt by, any unauthorized persons. If so, any review, dissemination, or copying of this email is prohibited. If you have received this electronic mail transmission in error, please delete it from your system without copying it, and notify the sender by reply e-mail, so that our address record can be corrected. Incoming emails are filtered which may delay receipt. U.S. Treasury Regulation Circular 230 requires us to advise you that written communications issued by us are not intended to be and cannot be relied upon to avoid penalties that may be imposed by the Internal Revenue Service. From: Pepe, Thomas F. [mailto:TPepe@southmiamifl.gov] Sent: Friday, February 01, 2013 4:49 PM To: jameskgreen@bellsouth.net<mailto:jameskgreen@bellsouth.net>; 'Boulris, Amy' Cc: aamigo@rrbpa.com<mailto:aamigo@rrbpa.com>; lreynolds@rrbpa.com<mailto:lreynolds@rrbpa.com> Subject: RE: Metro South - Commissioner E-mail Search Dear Mr. Green: I noticed that your "First Request for Production" appears to request the same e-mails that were requested in you public record request. May I presume that our current process of producing those emails will be tantamount to a formal response to the 1st request for production? Would this also be true of our response to the other items that have previously been produced in response to your public record request? Very truly yours, Thomas F. Pepe City Attorney City of South Miami 1450 Madruga Avenue, Ste 202, Coral Gables, Florida 33146 Tel: (305) 667-2564 Fax: (305) 341-0584 E-mail: tpepe@southmiamifl.gov<mailto:tpepe@southmiamifl.gov> ATTENTION: This e-mail may contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the addressee named above. If you are not the intended receiver, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this e-mail in error, please immediately notify us by telephone, call collect if outside of your area code and delete this e-mail. We will reimburse you for the cost of your long distance call. Thank you. Please also note: All e-mails to and from this e-mail site are kept as a public record. Your e-mail communications, including your e-mail address may be disclosed to the public and media at any time pursuant to Florida Statutes, ch. 119. ________________________________ From: James K. Green [campeon@bellsouth.net] Sent: Friday, February 01, 2013 3:28 PM To: Pepe, Thomas F.; 'Boulris, Amy' Cc: jameskgreen@bellsouth.net<mailto:jameskgreen@bellsouth.net> Subject: RE: Metro South - Commissioner E-mail Search Mr. Pepe, Attached please find the requests for production. James K. Green, Esq. JAMES K. GREEN, P.A. Suite 1650, Esperantè 222 Lakeview Ave. West Palm Beach, FL 33401 Telephone: (561) 659-2029 www.jameskgreenlaw.com<http://www.jameskgreenlaw.com> From: Pepe, Thomas F. [mailto:TPepe@southmiamifl.gov] Sent: Friday, February 01, 2013 3:26 PM To: Boulris, Amy Cc: jameskgreen@bellsouth.net<mailto:jameskgreen@bellsouth.net> Subject: RE: Metro South - Commissioner E-mail Search Dear Ms. Boulris: Commissioners Harris and Welsh have agreed to have Credence do the search of their private email addresses under the confidentiality agreement. I cannot advise you of the scheduled inspection date of the commissioners' emails or the retrieval, review and production of any responsive emails stored on their devices until Credence has the emails. Neither you nor Credence have provided me with the procedure that needs to be followed to accomplish this task. Please let me know what Commissioners Harris and Welsh need to do. Please send me a copy of the request for production of public records stored on the Commissioners' personal devices that you filed in the federal case. Please also send me a copy of the subpoenas to non-consenting Commissioners. I had previously requested a confirmation on the search terms for transmission to the commission members and board members so that they can comply with your public records request, but you failed to provide it to me. As I previously explained to you, the original spread sheet is too confusing because it contains duplicate search terms and irrelevant information. I sent you a revised spread sheet for your approval but never got a satisfactory response. Please confirm that the revised and simplified search term spread sheet is satisfactory so that I can have the members of the city commission and the planning board comply with the public records request. Since you are not having the entire database "imaged" for our redaction of privileged documents, I cannot guarantee the time frame previously agreed upon. If the entire database is not imaged, it will take longer to review the documents since there will be an additional step to image each document before reviewing it. You can either save money or time; it depends on what is more important to you. Very truly yours, Thomas F. Pepe City Attorney City of South Miami 1450 Madruga Avenue, Ste 202, Coral Gables, Florida 33146 Tel: (305) 667-2564 Fax: (305) 341-0584 E-mail: tpepe@southmiamifl.gov<mailto:tpepe@southmiamifl.gov> ATTENTION: This e-mail may contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the addressee named above. If you are not the intended receiver, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this e-mail in error, please immediately notify us by telephone, call collect if outside of your area code and delete this e-mail. We will reimburse you for the cost of your long distance call. Thank you. Please also note: All e-mails to and from this e-mail site are kept as a public record. Your e-mail communications, including your e-mail address may be disclosed to the public and media at any time pursuant to Florida Statutes, ch. 119. ________________________________ From: Boulris, Amy [ABoulris@gunster.com] Sent: Friday, February 01, 2013 7:58 AM To: Pepe, Thomas F. Cc: jameskgreen@bellsouth.net<mailto:jameskgreen@bellsouth.net> Subject: Re: Metro South - Commissioner E-mail Search Thanks for this confirmation, Mr. Pepe. By copy to Mr. Green, this will confirm that, as a result of their compliance with public records laws, subpoenas will not be directed at this time to Commissioners Harris and Welsh. That said, please advise us of the scheduled inspection date, so that we are comfortable retrieval, review and production of any responsive emails stored on their devices will be produced timely. Regarding your review prior to production, we contemplated that any search results would be subject to the same treatment as public records stored on the City's main database, allowing you to review and redact where appropriate prior to production. Yesterday a request for production directed to ESI public records stored on Commissioners' personal devices was filed in the federal case. A motion to shorten time for that production will be filed shortly as well as subpoenas to non-consenting Commissioners. We trust you have counseled Commissioners about preservation of records and generally about the consequences of spoliation (whether intentional or inadvertent). We are putting the stipulated terms into filable form and will send over for your execution (though it will not be filed unless necessary to enforcement). Meanwhile, we understand that the de-duplicated database was successfully uploaded by Credence and that you were able to have additional training with that actual data. We also understand that Credence was able to clarify that the entire database does not need to be "imaged" in order for you to redact partially privileged documents, since that can be done on a document-by-document basis within Credence (this is why I could not approve the thousands of dollars of additional expense for imaging the whole database). We look forward to a release of non-privileged emails by the end of business today. Sincerely, [cid:image008.png@01CE09E3.1DBC02D0] Amy Brigham Boulris | Shareholder 2 South Biscayne Boulevard, Suite #3400 Miami, FL 33131-1897 P (305) 376-6062 gunster.com<http://www.gunster.com/> | aboulris@gunster.com<mailto:aboulris@gunster.com> From: <Pepe>, "TPepe@southmiamifl.gov<mailto:TPepe@southmiamifl.gov>" <TPepe@southmiamifl.gov<mailto:TPepe@southmiamifl.gov>> Date: Thursday, January 31, 2013 11:02 AM To: Amy Boulris <aboulris@gunster.com<mailto:aboulris@gunster.com>> Cc: "Harris, Walter" <WHarris@southmiamifl.gov<mailto:WHarris@southmiamifl.gov>>, "Welsh, Bob" <BWelsh@southmiamifl.gov<mailto:BWelsh@southmiamifl.gov>> Subject: RE: Metro South - Commissioner E-mail Search Commissioner Harris and Welsh have agreed to have Credence do the search of their private email addresses under the confidentiality agreement. However, only their emails that are related to city business would be discoverable as a public record and, therefore, they would need to come into my office and redact all the private emails. Very truly yours, Thomas F. Pepe City Attorney City of South Miami 1450 Madruga Avenue, Ste 202, Coral Gables, Florida 33146 Tel: (305) 667-2564 Fax: (305) 341-0584 E-mail: tpepe@southmiamifl.gov<mailto:tpepe@southmiamifl.gov> ATTENTION: This e-mail may contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the addressee named above. If you are not the intended receiver, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this e-mail in error, please immediately notify us by telephone, call collect if outside of your area code and delete this e-mail. We will reimburse you for the cost of your long distance call. Thank you. Please also note: All e-mails to and from this e-mail site are kept as a public record. Your e-mail communications, including your e-mail address may be disclosed to the public and media at any time pursuant to Florida Statutes, ch. 119. ________________________________ From: Boulris, Amy [ABoulris@gunster.com<mailto:ABoulris@gunster.com>] Sent: Thursday, January 31, 2013 10:36 AM To: Pepe, Thomas F. Subject: FW: Metro South - Commissioner E-mail Search Mr. Pepe, I received no response to the email below yesterday. We will assume that no commissioners have consented to the term search by Credence and will govern ourselves accordingly. If you did attempt to reply and if this is incorrect, please contact me immediately. [cid:image008.png@01CE09E3.1DBC02D0] Amy Brigham Boulris | Shareholder 2 South Biscayne Boulevard, Suite #3400 Miami, FL 33131-1897 P (305) 376-6062 gunster.com<http://www.gunster.com/> | aboulris@gunster.com<mailto:aboulris@gunster.com> From: <Boulris>, Amy Boulris <aboulris@gunster.com<mailto:aboulris@gunster.com>> Date: Wednesday, January 30, 2013 1:46 PM To: "TPepe@southmiamifl.gov<mailto:TPepe@southmiamifl.gov>" <TPepe@southmiamifl.gov<mailto:TPepe@southmiamifl.gov>> Cc: 'Ryan Gleason' <RGleason@credencecorp.com<mailto:RGleason@credencecorp.com>> Subject: RE: Metro South - Commissioner E-mail Search Mr. Pepe, I have been away from my office several days in connection with a trial in Jacksonville, and am just now seeing your email below. Metro has not stipulated to what is proposed there. Metro stipulated to have a Credence IT professional search personal devices housing case-relevant public records (records within the search terms previously utilized to search the City’s main database). Metro insisted on this because it cannot be sure that commission members and planning board members know how to accurately run the searches, harvest search results without corruption, and make copies in usable format. This needs to be done by IT professionals, just as the term search of the City’s database was done. By the end of business today, please advise which commissioners and planning board members have consented to execution of the agreed term search by Credence, and the dates upon which the searches have been scheduled to occur. This will allow us to direct appropriate subpoenas or other forms of discovery to non-consenting public records custodians in the federal litigation. We request the dates of scheduled searches for consenting records custodians so we can assess whether harvesting, review, and production can be done in the stipulated time frame (45 days from your 1/18/13 email). Federal discovery papers are currently being drafted and will be filed by the end of the week. The City’s response to this email (or any lack thereof) will inform those filings. Sincerely, [http://gunsternet/myBizCardSignature/images/glogoflbiz.jpg] Amy Brigham Boulris | Shareholder 2 South Biscayne Boulevard, Suite #3400 Miami, FL 33131-1897 P (305) 376-6062 gunster.com<http://www.gunster.com/> | aboulris@gunster.com<mailto:aboulris@gunster.com> From: Pepe, Thomas F. [mailto:TPepe@southmiamifl.gov] Sent: Friday, January 25, 2013 12:06 PM To: Boulris, Amy Cc: James K. Green; Stoddard, Philip K. Subject: RE: Metro South - Commissioner E-mail Search Dear Ms. Boulris: There has been a lot of confusion regarding the spread sheet. I now understand that the spread sheet that I previously sent you was created by IDC to show how it did its initial search and the results of its final search. It contains irrelevant columns of numbers and the books/sheets are duplicated. In order to make it simpler I have reduced the spread sheet to one page and it is attached. Please confirm that the one page is what the commission members and planning board members are supposed to be using to search their private e-mail accounts. Very truly yours, Thomas F. Pepe City Attorney City of South Miami 1450 Madruga Avenue, Ste 202, Coral Gables, Florida 33146 Tel: (305) 667-2564 Fax: (305) 341-0584 E-mail: tpepe@southmiamifl.gov<mailto:tpepe@southmiamifl.gov> ATTENTION: This e-mail may contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the addressee named above. If you are not the intended receiver, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this e-mail in error, please immediately notify us by telephone, call collect if outside of your area code and delete this e-mail. We will reimburse you for the cost of your long distance call. Thank you. Please also note: All e-mails to and from this e-mail site are kept as a public record. Your e-mail communications, including your e-mail address may be disclosed to the public and media at any time pursuant to Florida Statutes, ch. 119. ________________________________ From: Boulris, Amy [ABoulris@gunster.com<mailto:ABoulris@gunster.com>] Sent: Tuesday, January 22, 2013 11:08 AM To: Pepe, Thomas F. Cc: James K. Green Subject: Re: Metro South - Commissioner E-mail Search Mr. Pepe, I am doing my civic duty reporting for jury duty today, thus my rather short iPad response from the jury pool room. Thank you for relaying Conmissioner Walsh's willingness to cooperate. We will need to coordinate the search with Credence per the stip terms - please contact Ryan Gleason with the necessary information to allow Credence access. The mayor's questions are understandable, however we would need credence to perform the search ans our team decide relevance. It is also apparent that the mayor does not know that many of the terms (in fact the ones mentioned on his question) were used as limiting terms within results for initial search terms, as you know from our meetings and correspondence about how the city's mainframe would be searched. The mayor may not have the software or IT training to execute this search properly. Please recommend the stipulated approach to him and remind him there is a confidentiality agreement in place with Credence. We do appreciate his apparent interest in cooperating. Regards, Amy On Jan 22, 2013, at 10:45 AM, "Pepe, Thomas F." <TPepe@southmiamifl.gov<mailto:TPepe@southmiamifl.gov>> wrote: Dear Ms. Boulris: Commissioner Welsh has agreed to use Credence. The Mayor has the following questions: I have begun the task and I can complete it one of two ways: 1. Use each search term, then screen by hand for anything possibly relevant to their interests. 2. Use each search term and give them a massive dump of everything. We are talking thousands of messages that have nothing to do their project. Method #1 is working, but taking some time. Method #2 is insane, because words like "stop" and "block" and "deal" are so generic as to hit half my email database. It would take forever to screen out the potentially objectionable or personal stuff that gets into this account. I prefer method #1 as more efficient for all parties concerned. Am I required to use method #2? Please provide me with an answer to the Mayor's questions. Very truly yours, Thomas F. Pepe City Attorney City of South Miami 1450 Madruga Avenue, Ste 202, Coral Gables, Florida 33146 Tel: (305) 667-2564 Fax: (305) 341-0584 E-mail: tpepe@southmiamifl.gov<mailto:tpepe@southmiamifl.gov> ATTENTION: This e-mail may contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the addressee named above. If you are not the intended receiver, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this e-mail in error, please immediately notify us by telephone, call collect if outside of your area code and delete this e-mail. We will reimburse you for the cost of your long distance call. Thank you. Please also note: All e-mails to and from this e-mail site are kept as a public record. Your e-mail communications, including your e-mail address may be disclosed to the public and media at any time pursuant to Florida Statutes, ch. 119. ________________________________ Tax Advice Disclosure: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein. Click the following hyperlink to view the complete Gunster IRS Disclosure & Confidentiality note. http://www.gunster.com/terms-of-use/ Amy Cc: <a href="mailto:jameskgreen@bellsouth.net" target="_blank">jameskgreen@bellsouth.net</a><<a href="mailto:jameskgreen@bellsouth.net" target="_blank">mailto:jameskgreen@bellsouth.net</a> > Subject: RE: Metro South - Commissioner E-mail Search Dear Ms. Boulris: Commissioners Harris and Welsh have agreed to have Credence do the search of their private email addresses under the confidentiality agreement.  I cannot advise you of the scheduled inspection date of the commissioners' emails or the retrieval, review and production of any responsive emails stored on their devices until Credence has the emails.  Neither you nor Credence have provided me with the procedure that needs to be followed to accomplish this task. Please let me know what Commissioners Harris and Welsh need to do. Please send me a copy of the request for production of public records stored on the  Commissioners' personal devices that you filed in the federal case. Please also send me a copy of the subpoenas to non-consenting Commissioners. I had previously requested a confirmation on the search terms for transmission to the commission members and board members so that they can comply with your public records request, but you failed to provide it to me.  As I previously explained to you, the original spread sheet is too confusing because it contains duplicate search terms and irrelevant information.  I sent you a revised spread sheet for your approval but never got a satisfactory response.  Please confirm that the revised and simplified search term spread sheet is satisfactory so that I can have the members of the city commission and the planning board comply with the public records request. Since you are not having the entire database "imaged" for our redaction of privileged documents, I cannot guarantee the time frame previously agreed upon.  If the entire database is not imaged, it will take longer to review the documents since there will be an additional step to image each document before reviewing it.  You can either save money or time; it depends on what is more important to you. Very truly yours, Thomas F. Pepe City Attorney City of South Miami 1450 Madruga Avenue, Ste 202, Coral Gables, Florida 33146 Tel: (305) 667-2564 Fax: (305) 341-0584 E-mail: <a href="mailto:tpepe@southmiamifl.gov" target="_blank">tpepe@southmiamifl.gov</a><<a href="mailto:tpepe@southmiamifl.gov" target="_blank">mailto:tpepe@southmiamifl.gov</a>> ATTENTION: This e-mail may contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the addressee named above. If you are not the intended receiver, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this e-mail in error, please immediately notify us by telephone, call collect if outside of your area code and delete this e-mail. We will reimburse you for the cost of your long distance call. Thank you. Please also note:  All e-mails to and from this e-mail site are kept as a public record.  Your e-mail communications, including your e-mail address may be disclosed to the public and media at any time pursuant to Florida Statutes, ch. 119. ________________________________ From: Boulris, Amy [<a href="mailto:ABoulris@gunster.com" target="_blank">ABoulris@gunster.com</a>] Sent: Friday, February 01, 2013 7:58 AM To: Pepe, Thomas F. Cc: <a href="mailto:jameskgreen@bell south.net" target="_blank">jameskgreen@bellsouth.net</a><<a href="mailto:jameskgreen@bellsouth.net" target="_blank">mailto:jameskgreen@bellsouth.net</a>> Subject: Re: Metro South - Commissioner E-mail Search Thanks for this confirmation, Mr. Pepe. By copy to Mr. Green, this will confirm that, as a result of their compliance with public records laws, subpoenas will not be directed at this time to Commissioners Harris and Welsh.  That said, please advise us of the scheduled inspection date, so that we are comfortable retrieval, review and production of any responsive emails stored on their devices will be produced timely.  Regarding your review prior to production, we contemplated that any search results would be subject to the same treatment as public records stored on the City's main database, allowing you to review and redact where appropriate prior to production. Yesterday a request for production directed to ESI public records stored on Commissioners' personal devices was filed in the federal case.  A motion to shorten time for that production will be filed shortly as well as subpoenas to non-consenting Commissioners.  We trust you have counseled Commissioners about preservation of records and generally about the consequences of spoliation (whether intentional or inadvertent). We are putting the stipulated terms into filable form and will send over for your execution (though it will not be filed unless necessary to enforcement).  Meanwhile, we understand that the de-duplicated database was successfully uploaded by Credence and that you were able to have additional training with that actual data.  We also understand that Credence was able to clarify that the entire database does not need to be "imaged" in order for you to redact partially privileged documents, since that can be done on a document-by-document basis within Credence (this is why I could not approve the thousands of dollars of additional expense for imaging the whole database).  We look forward to a release of non-privileged emails by the end of business today. Sincerely, [cid:image008.<a href="mailto:png@01CE09E3.1DBC02D0" target="_blank">png@ 01CE09E3.1DBC02D0</a>]    Amy Brigham Boulris | Shareholder                      2 South Biscayne Boulevard, Suite #3400                     Miami, FL 33131-1897                      P (305) 376-6062           &nbsp ;         <a href="http://gunster.com" target="_blank">gunster.com</a><<a href="http://www.gunster.com/" target="_blank">http://www.gunster.com/</a>&gt ;   |   <a href="mailto:aboulris@gunster.com" target="_blank">aboulris@gunster.com</a><<a href="mailto:aboulris@gunster.com" target="_blank">mailto:aboulris@gunster.com</a>> From: <Pepe>, "<a href="mailto:TPepe@southmiamifl.gov" target="_blank">TPepe@southmiamifl.gov</a><<a href="mailto:TPepe@southmiamifl.gov" target="_blank">mailto:TPepe@southmiami fl.gov</a>>" <<a href="mailto:TPepe@southmiamifl.gov" target="_blank">TPepe@southmiamifl.gov</a><<a href="mailto:TPepe@southmiamifl.gov" target="_blank">mailto:TPepe@southmiamifl.gov</a >>> Date: Thursday, January 31, 2013 11:02 AM To: Amy Boulris <<a href="mailto:aboulris@gunster.com" target="_blank">aboulris@gunster.com</a><<a href="mailto:aboulris@gunster.com" target="_blank">mailto:aboulris@gunster.com</a>>> Cc: "Harris, Walter" <<a href="mailto:WHarris@southmiamifl.gov" target="_blank">WHarris@southmiamifl.gov</a><<a href="mailto:WHarris@southmiamifl.gov" target="_blank">mailto:WHarris@southmiamifl.gov</a>>>, "Welsh, Bob" <<a href="mailto:BWelsh@southmiamifl.gov" target="_blank">BWelsh@southmia mifl.gov</a><<a href="mailto:BWelsh@southmiamifl.gov" target="_blank">mailto:BWelsh@southmiamifl.gov</a>>> Subject: RE: Metro South - Commissioner E-mail Search Com missioner Harris and Welsh have agreed to have Credence do the search of their private email addresses under the confidentiality agreement.  However, only their emails that are related to city business would be discoverable as a public record and, therefore, they would need to come into my office and redact all the private emails. Very truly yours, Thomas F. Pepe City Attorney City of South Miami 1450 Madruga Avenue, Ste 202, Coral Gables, Florida 33146 Tel: (305) 667-2564 Fax: (305) 341-0584 E-mail: <a href="mailto:tpepe@southmia mifl.gov" target="_blank">tpepe@southmiamifl.gov</a><<a href="mailto:tpepe@southmiamifl.gov" target="_blank">mailto:tpepe@southmiamifl.gov</a>> ATTENTION: This e-mail may contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the addressee named above. If you are not the intended receiver, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this e-mail in error, please immediately notify us by telephone, call collect if outside of your area code and delete this e-mail. We will reimburse you for the cost of your long distance call. Thank you. Please also note:  All e-mails to and from this e-mail site are kept as a public record.  Your e-mail communications, including your e-mail address may be disclosed to the public and media at any time pursuant to Florida Statutes, ch. 119. ________________________________ From: Boulris, Amy [<a href="mailto:ABoulris@gunster.com" target="_blank">ABoulris@gunster.com</a><<a href="mailto:ABoulris@gunster.com" target="_blank">mailto:ABoulris@gunster.com</a>>] Sent: Thursday, January 31, 2013 10:36 AM To: Pepe, Thomas F. Subject: FW: Metro South - Commissioner E-mail Search Mr. Pepe, I received no response to the email below yesterday.   We will assume that no commissioners have consented to the term search by Credence and will govern ourselves accordingly.  If you did attempt to reply and if this is incorrect, please contact me immediately. [cid:image008.<a href="mailto:png@01CE09E3.1DBC02D0" target="_blank">png@01CE09E3.1DBC02D0</a>]        & nbsp;  Amy Brigham Boulris | Shareholder                     2 South Biscayne Boulevard, Suite #3400                     Miami, FL 33131-1897    &n bsp;                P (305) 376-6062              & nbsp;      <a href="http://gunster.com" target="_blank">gunster.com</a><<a href="http://www.gunster.com/" target="_blank">http://www.gunster.com/</a>>   |   <a href="mailto:aboulris@gunster.com" target="_blank">aboulris@gunster.com</a><<a href="mailto:aboulris@gunster.com" target="_blank">mailto:aboulris@gunster.com</a>> From: <Boulris>, Amy Boulris <<a href="mailto:aboulris@gunster.com" target="_blank">aboulris@gunster.com</a><<a href="mailto:aboulris@gunster.com" target="_blank">mailto:aboulris@gu nster.com</a>>> Date: Wednesday, January 30, 2013 1:46 PM To: "<a href="mailto:TPepe@southmiamifl.gov" target="_blank">TPepe@southmiamifl.gov</a><<a href="mailto:TPepe@southmiamif l.gov" target="_blank">mailto:TPepe@southmiamifl.gov</a>>" <<a href="mailto:TPepe@southmiamifl.gov" target="_blank">TPepe@southmiamifl.gov</a><<a href="mailto:TPepe@southmiamifl.gov" target="_blank">mailto:TPepe@southmiamifl.gov</a>>> Cc: 'Ryan Gleason' <<a href="mailto:RGleason@credencecorp.com" target="_blank">RGleason@credencecorp.com</a><<a href="mailto:RGleaso n@credencecorp.com" target="_blank">mailto:RGleason@credencecorp.com</a>>> Subject: RE: Metro South - Commissioner E-mail Search Mr. Pepe, I have been away from my office several days in connection with a trial in Jacksonville, and am just now seeing your email below. Metro has not stipulated to what is proposed there. Metro stipulated to have a Credence IT professional search personal devices housing case-relevant public records (records within the search terms previously utilized to search the City’s main database).  Metro insisted on this because it cannot be sure that commission members and planning board members know how to accurately run the searches, harvest search results without corruption, and make copies in usable format.   This needs to be done by IT professionals, just as the term search of the City’s database was done. By the end of business today, please advise which commissioners and planning board members have consented to execution of the agreed term search by Credence, and the dates upon which the searches have been scheduled to occur.  This will allow us to direct appropriate subpoenas or other forms of discovery to non-consenting public records custodians in the federal litigation.  We request the dates of scheduled searches for consenting records custodians so we can assess whether harvesting, review, and production can be done in the stipulated time frame (45 days from your 1/18/13 email).   Federal discovery papers are currently being drafted and will be filed by the end of the week.  The City’s response to this email (or any lack thereof) will inform those filings. Sincerely, [<a href="http://gunsternet/myBizCardSignature/images/glogoflbiz.jpg" target="_blank">http://gunsternet/myBizCardSignature/images /glogoflbiz.jpg</a>]                     Amy Brigham Boulris | Shareholder                      2 South Biscayne Boulevard, Suite #3400                      Miami, FL 33131-1897                   & nbsp; P (305) 376-6062                     <a href="http://gunster.com" target="_blank">gun ster.com</a><<a href="http://www.gunster.com/" target="_blank">http://www.gunster.com/</a>>   |   <a href="mailto:aboulris@gunster.com" target="_blank">aboulris@gunster.com< /a><<a href="mailto:aboulris@gunster.com" target="_blank">mailto:aboulris@gunster.com</a>> From: Pepe, Thomas F. [<a href="mailto:TPepe@southmiamifl.gov" target="_blank">mailto:TPepe@sou thmiamifl.gov</a>] Sent: Friday, January 25, 2013 12:06 PM To: Boulris, Amy Cc: James K. Green; Stoddard, Philip K. Subject: RE: Metro South - Commissioner E-mail Search Dear Ms. Boulris: There has been a lot of confusion regarding the spread sheet.  I now understand that the spread sheet that I previously sent you was created by IDC to show how it did its initial search and the results of its final search.  It contains irrelevant columns of numbers and the books/sheets are duplicated.  In order to make it simpler I have reduced the spread sheet to one page and it is attached.  Please confirm that the one page is what the commission members and planning board members are supposed to be using to search their private e-mail accounts. Very truly yours, Thomas F. Pepe City Attorney City of South Miami 1450 Madruga Avenue, Ste 202, Coral Gables, Florida 33146 Tel: (305) 667-2564 Fax: (305) 341-0584 E-mail: <a href="mailto:tpepe@southmiamifl.gov" target="_blank">tpepe@southmiamifl.gov</a><<a href="mailto:tpepe@southmiamifl.gov" target="_blank">mailto:tpepe@southmiamifl.gov</a>> ATTENTION: This e-mail may contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the addressee named above. If you are not the intended receiver, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this e-mail in error, please immediately notify us by telephone, call collect if outside of your area code and delete this e-mail. We will reimburse you for the cost of your long distance call. Thank you. Please also note:  All e-mails to and from this e-mail site are kept as a public record.  Your e-mail communications, including your e-mail address may be disclosed to the public and media at any time pursuant to Florida Statutes, ch. 119. ________________________________ From: Boulris, Amy [<a href="mailto:ABoulris@gunster.com" target="_blank">ABoulris@gunster.com</a>& lt;<a href="mailto:ABoulris@gunster.com" target="_blank">mailto:ABoulris@gunster.com</a>>] Sent: Tuesday, January 22, 2013 11:08 AM To: Pepe, Thomas F. Cc: James K. Green Subject: Re: Metro South - Commissioner E-mail Search Mr. Pepe, I am doing my civic duty reporting for jury duty today, thus my rather short iPad response from the jury pool room. Thank you for relaying Conmissioner Walsh's willingness to cooperate.  We will need to coordinate the search with Credence per the stip terms - please contact Ryan Gleason with the necessary information to allow Credence access. The mayor's questions are understandable, however we would need credence to perform the search ans our team decide relevance.  It is also apparent that the mayor does not know that many of the terms (in fact the ones mentioned on his question) were used as limiting terms within results for initial search terms, as you know from our meetings and correspondence about how the city's mainframe would be searched. The mayor may not have the software or IT training to execute this search properly.  Please recommend the stipulated approach to him and remind him there is a confidentiality agreement in place with Credence.  We do appreciate his apparent interest in cooperating. Regards, Am y On Jan 22, 2013, at 10:45 AM, "Pepe, Thomas F." <<a href="mailto:TPepe@southmiamifl.gov" target="_blank">TPepe@southmiamifl.gov</a><<a href="mailto:TPepe@southmiamifl.gov" target="_blank">mailto:TPepe@southmiamifl.gov</a>>> wrote: Dear Ms. Boulris: Commissioner Welsh has agreed to use Credence. The Mayor has the following questions: I have begun the task and I can complete it one of two ways: 1. Use each search term, then screen by hand for anything possibly relevant to their interests. 2. Use each search term and give them a massive dump of everything. We are talking thousands of messages that have nothing to do their project. Method #1 is working, but taking some time. Method #2 is insane, because words like "stop" and "block" and "deal" are so generic as to hit half my email database. It would take forever to screen out the potentially objectionable or personal stuff that gets into this account. I prefer method #1 as more efficient for all parties concerned. Am I required to use method #2? Please provide me with an answer to the Mayor's questions. Very truly yours, Thomas F. Pepe City Attorney City of South Miami 1450 Madruga Avenue, Ste 202, Coral Gables, Florida 33146 Tel: (305) 667-2564 Fax: (305) 341-0584 E-mail: <a href="mailto:tpepe@southmiamifl.gov" target="_blank">tpepe@southmiamifl.gov</a><<a href="mailto:tpepe@southmiamifl .gov" target="_blank">mailto:tpepe@southmiamifl.gov</a>> ATTENTION: This e-mail may contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the addressee named above. If you are not the intended receiver, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this e-mail in error, please immediately notify us by telephone, call collect if outside of your area code and delete this e-mail. We will reimburse you for the cost of your long distance call. Thank you. Please also note:  All e-mails to and from this e-mail site are kept as a public record.  Your e-mail communications, including your e-mail address may be disclosed to the public and media at any time pursuant to Florida Statutes, ch. 119. ________________________________ Tax Advice Disclosure: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein. Click the following hyperlink to view the complete Gunster IRS Disclosure & Confidentiality note. <a href="http://www.gunster.com/terms-of-use/" target="_blank">http://www.gunster.com/terms-of-use/</a><o:p></o:p></div></blockquote></div></div></div></div></div></div></div></div></body></html>