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Res. No. 069-08-12666WHEREAS, the City Commission of the City of South Miami approved Resolution No. 14-05-11993 authorizing payment of City Attorney non-retainer attorneys' fees and costs; and, WHEREAS, Nagin Gallop Figueredo, P.A., submitted invoices to the City for legal services rendered, and costs advanced, for the period ending April 28, 2008, in the amount of $41,175.13; and, WHEREAS, as of April 29, 2008, the existing balance in city attorney account no. 001-1500-514-34-10, litigation, special projects and costs, is $40,848.71; the existing balance in city attorney account no. 001-1500-514-34-52, code enforcement, is $15,357.50; the existing balance in city attorney account no. 001-1.500-514-34-54, litigation reserve, is $34,197.82 and WHEREAS, the office of the City Attorney recommends payment of the attached invoices. Section 1. The invoices for attorneys' fees and costs received from Nagin Gallop Figueredo, P.A., in the total amount of $41,175.13 are approved for payment; charging $5,000.11 to account no. 001-1500-514-34-10, litigation, special projects and costs; charging $2,000.00 to account no. 001-1500-514-34-52, code enforcement; and charging $34,175.02 to account no. 001-1500-514-34-54, litigation reserve. Section 2. This resolution shall take effect immediately upon approval. ATTEST: arl� CLERK 1!: Additions shown by underlining and deletions shown by ever-st-FiWng. Res. No. 69-08-12666 Luis_ ueredo Nagin Gallop Figueredo, P.A. Office of the City Attorney 5�M COMMISSION VOTE: 5-0 Mayor Feliu: Yea Vice Mayor Beasley: Yea Commissioner Beckman: Yea Commissioner Wiscomb: Yea Commissioner Palmer: Yea CITY OF SOUTH MIAMI 6130 Sunset Drive, South Miami, Florida 33143 Vendor: Network Reporting Finance Department Req. No. 12, FY 2007-08 Item No. Quantity Description and Specifications Account Number Unit Price Total Legal, Non-Retainer 001-1500-514-34-10 $379.45 $379.45 1 Legal, Non-Retainer 001-1500-514-34-10 1 $194.65 $194.65 —2 -3 1 Lega 1 1, Non-Retainer 001-1500-514-34-10 $371.05 $371.05 TOTAL $945.15 Purchase Order No. Terms/Discount I Hereby Certify That The Above Material, Equipment, Or Service Is Essential And A Proper Request Against The Codes Charp-e Coding of Accounts Approved Sufficiency of Appropriation Balances Verified (Except As Otherwise Noted) Finance Department Purchases as Above Approved and Issuance of Purchase Order Authorized ...'Wo oP NETWORK REPORTING VO-6 ar r 4* NWA 1711agler Street .Suite 1200 N Ro Ida 33fn Miami, Florl 305-35$-81$8 Vax:865-368-8187 0 RT H. James Montalvo, Esquire Nagin, Gallop, Fligueredo, P.A. 18001 Old Cutter Road Suite 556 Miami, FL 33157 Tax ID: 20-0113967 H. James Montalvo, Esquire Nagin, Gallop, Figueredo, P.A. 18001 Old Cutler Road Suite 556 Miami, FL 33157 R visit' a Phone: Fax: Please detach bottom portion and return with payment. Remit To: Network Reporting Corporation 44 West Flagler Street Suite 1200 Miami, FL 33130 Invoice No. 12466 Invoice Date 4/16/2008 Total Due $ 379.45 Job No. 15095 BU ID 1 -MAIN Case No. 06-11289 CA 10 Case Name Dabby Properties vs. The City of South Miami 01 NETWORK REPORTING 44, West Flagler.Stme-t, Suite 1.200 Miami, RQr3ja 33-(34 1.11 Vie, 988'_359-8188 C) R-� H. James Montalvo, Esquire Nagin, Gallop, Figueredo, P.A. 18001 Old Cutler Road Suite 556 Miami, FL 33157 12472 4/1612008 14904 Invoice Date ....... ... 4/4/2008 06-11289 CA 10 Dabby Properties vs, The City of South Miami .......... . Due upon receipt Tax ID: 20-0113967 Phone- Fax: Please detach bottom portion and return with payment. H. James Montalvo, Esquire Nagin, Gallop, Figueredo, P.A. 18001 Old Cutler Road Suite 556 Miami, FL 33157 Remit To, Network Reporting Corporation 44 West Flagler Street Suite 1200 Miami, FL 33130 Invoice No. 'Ell Invoice Date 4/16/2008 Total Due $ 194.65 I'd %T! V. W.Vwmt ust n 6Z�. iXha(h, 1-H . ..... .. .. VVBN . .... .... I . .. . .. .. ... . . j4*L', iii:1 I . . .... .. t. H� f E "Zil 7 R tl i. Tax ID: 20-0113967 Phone- Fax: Please detach bottom portion and return with payment. H. James Montalvo, Esquire Nagin, Gallop, Figueredo, P.A. 18001 Old Cutler Road Suite 556 Miami, FL 33157 Remit To, Network Reporting Corporation 44 West Flagler Street Suite 1200 Miami, FL 33130 Invoice No. 12472 Invoice Date 4/16/2008 Total Due $ 194.65 Job No. 14904 BU ID 1 -MAIM Case No. 06-11289 CA 10 Case Name Dabby Properties vs. The City of South Miami -WO NETWORK REPGRTIN'G 44X"est1lagler 8treet'.Sldto 1200 Miami, FloriL33130 " 305 - 358- 8188F=305 -358 -8187 9; T611"Flre� 988'-368_8168 0 H. James Montalvo, Esquire Nagin, Gallop, Figueredo, P.A. 18001 Old Cutler Road Suite 556 Tax ID: 20-0113967 H. James Montalvo, Esquire Nagin, Gallop, Figueredo, P.A. 18001 Old Cutler Road Suite 556 Miami, FL 33157 I N V 0 1 C E Dabby Properties vs. The City of South Miami "00 Due upon receipt 00 21?1 Please detach bottom portion and retvrn with payment. Invoice No. 12469 Invoice Date 4/16/2008 Total Due $ 371.05 Phone: Fax: Job No. 14903 Remit To: Network Reporting Corporation BU ID 1 -MAIN 44 West Flagler Street Case No. 06-11289 CA 10 Suite 1200 Case Name Dabby Properties vs. The City of South Miarn Miami, FL 33130 CITY OF SOUTH MIAMI 6130 Sunset Drive, South Miami, Florida: 33143 Vendor: Lott & Levine Finance Depwtmeiit Req. No. 13, FY 2007-2008 Date: April 29, 2008 TOTAL Purchase Order No. TermslDiscount I Hereby Certify That The Above Material, Equipment, Or Service Is Essential And A Proper Request Against The Codes Charge Coding of Accounts Approved Purchases as Above Approved and Issuance of Purchase Order Authorized Sufficiency of Appropriation Balances Verified (Except As Otherwise Noted) City Manager Finance Department Quantity Description and Specifications Account Number Unit Price Total Item: No, Legal, Non-Retainer 001-1500-514-34-10 $870.93 $870.93 TOTAL Purchase Order No. TermslDiscount I Hereby Certify That The Above Material, Equipment, Or Service Is Essential And A Proper Request Against The Codes Charge Coding of Accounts Approved Purchases as Above Approved and Issuance of Purchase Order Authorized Sufficiency of Appropriation Balances Verified (Except As Otherwise Noted) City Manager Finance Department LOTT & LEVINE DADELAND CENTRE, SUITE 1014 91.55 SOUTH DADELAND BOULEVARD MAW FLORIDA 33156 CITY OF SOUTH MIAMI EVE A. BOUTSIS, ESQ, OFFICE OF THE CITY ATTORNEY 18001 OLD CUTLER RD, SUITE 556 PALMETTO BAY, FL 33157 April 17, 2008 Reference No. 8986 For Professional Services Concerning: Matter Number: CITY4.05085 Title: TITLE OPINION YMCA PROPERTY 4300 SW 58 AVENUE Hours 07111107 'UPDATED TAX ASSESSOR INFORMATION AND VERIFICATION OF CURRENT OWNER OF PROPERTY AND ENCROACHING CBS WALL; PREPARED GRANT OF LICENSE AGREEMENT. 4.00 — ------ --- ----- — Total Hours and Fees: 4.00 $780.00 r,',OSTS ADVANCED Date Description Cost Amount 12/19/05 Disbursement to: FEDERAL EXPRESS. ' TO FIGUEREDO, 12/1 $24.74 12/19/05 Disbursement to: NOW COURIER: TO FIGUEREDO, 12/5 $16.05 07/21/07 Disbursement to: FEDERAL EXPRESS: TO BOUTSIS, 7/11/07 $15.14 08/07107 Disbursement to: ATTORNEYS TITLE INSURANCE: TITLE $35.00 SEARCH ------------ Total Costs: $90.93 Matter Summary: Total Fees: $780.00 Total Cost: $90.93 ------------ Sub-Total Current Fees and Costs: $870.93 Amount Due: , $870.93 PAYMENT IS DUE ON OR BEFORE MAY 5, 2008. PLEASE INCLUDE THE BILL OR REFERENCE NUMBER ON YOUR REMITTANCE. THANK YOU. CITY OF SOUTH MIAMI 6130 Sunset Drive, South Miami, Florida 33143 Vendor: Friedman, Lombardi & Olson I I Req. No. 14, FY 2007-2008 Finance Department Item No. Quantity Description and Specifications Account Number Unit Price Total Other Contractual Service/ 001-1500-514-34-10 $344.00 $344.00 Litigation — Special Projects and Costs TOTAL Purchase Order No. I Terms/Discount I Hereby Certify That The Above Material, Equipment, Or Service Is Essential And A Proper Request Against The Codes Charge Codino, of Accounts Approved ZD Purchases as Above Approved and Issuance of Purchase Order Authorized Sufficiency of Appropriation Balances Verified (Except As Otherwise Noted) Finance Department City Manager Friedman, Lombardi & Olson 19 West Flagler Street IS Suite 924 Monday, April 28, 2008 130956MN Miami, Ft. 33130 Phone: (305) 371-6677 Fax: (305) 374-5292 H. James Montalvo, Esq. Nagin, Gallop & Figueredo 18001 Old Cutler Road Suite 556 Miami, FIL 33157 Phone: (305) 854-b3b6 t-ax: k6uo) 004-0,50-1 Witness: Multiple Witnesses Case: Dabby Properties v City of South Miami . ..... ......... .... Venue: Case #: 06 11289 CA 10 Date: 112/3/2007 ........ .. . Start Time: 10:30 AM ........ . ........ End Time: 3:00 PM Reporter: Zoill Alonso Claim #: File #: 12 Expedited Copy Transcript -Trudy Pollack 32 $153.60 Expedite , d ... Copy Transcript . . . . . . . J . u . I . i . a n . Chang .. 33 $158.40 Delivery 1 $32.00 Sub Total $344.00 Payments $0.00 Balance Due $344.00 Fed. I.D. # 59-078 5873 Please send all correspondence to the above address. CITY OF SOUTH MIAMI 6130 Sunset Drive, South Miami, Florida 33143 Vendor: NAGIN GALLOP & FIGUEREDO, P.A. Req. No. 15, FY 2007-11 mmmlfffxa� Finance Department item No. Quantity Description and Specifications Account Number Unit Price Total L eg 41, Non-Retainer 001-1500-514-34-10 $5,000.11 $5,000.11. Legal, Non - Retainer 001-1500-514-34-52 $2,000.00 $2,000.00 3 1 Legal, Non-Retainer 001-1500-514-34-54 $34,175.02 $34,175.02 F— TOTAL $41,175.131 Purchase Order No. TermslDiscount I I Hereby Certify That The Above Material, Equipment, Or Service Is Essential And A Proper Request Against The Codes Charge Coding of Accounts Approved Purchases as Above Approved and Issuance of Purchase Order Authorized Sufficiency of Appropriation Balances Verified (Except As Otherwise Noted) Finance Department City Manager 18001 Old Cutler Road - Fifth Floor Telephone: (305) 854-5353 . Miami, Florida 33157-6417 Facsimile: (305) 854-5351 April 29, 2008 Ajibola Balogun Acting City Manager CITY OF SOUTH MIAMI 6130 Sunset Drive South Miami, Florida 33143 Re: . STATEMENTS FOR PROFESSIONAL SERVICES — Retainer and Non-Retainer for the City of South Miami Dear Mr, Balogun: Enclosed are our invoices for professional services rendered and for costs advanced for the period ending April 28, 2008, in the amount of $41,175.13 and requisition no. 15 FY 2007-08. 1 have tabulated the amounts currently due on each individual file as follows: City Attorney Account No. 001-1500-514-34-10, Other Contractual Services/Litigation, -Special Projects and Costs. Account balance as of April 29, 2008 is $40,848.71 0022-001 General Municipal Prof'l Services $ 0.00 Invoice No. 19564 dated 4128108 Disburesments 162.18 Total Due 162.18 0022-083 Planning Board Prof'l Services 1,600.00 Invoice No. 19565 dated 4128108 Disburesments 5.00 Total Due 1,605.00 0022-190 CSM Health Facilities Prof'l Services 15.00 Invoice No. 19568 dated 4128108 Disburesments 0.00 Total Due 15.00 0022-192 Valencia Condominiums v. CSM Prof'l Services 40.00 Invoice No. 19569 dated 4128108 Disbursements 17.92 Total Due 57.92 0022-196 Doug Baker Arbitration Prof'l Services 37.50 Invoice No. 19570 dated 4128108 Disbursements 53.41 Total Due 90.91. 0022-199 Ray Manucy Prof'l Services 260.00 Invoice No. 19571 dated 4128108 Disburesments 2.50 Total Due 262.50 Ajibola Balogun, Acting City Manager CITY OF SOUTH MIAMI April 29, 2008 0022-201 Rene Guim. v. City of South Miami Prof'l Services $ 1,280.00 Invoice No. 19572 dated 4128108 Disbursements 446.60 Total Due 11726.60 0022 -202 Environmental Quality Control Prof'l Services $ 1,080.00 Invoice No. 19573 dated 4128108 Disburesments 0.00 Total Due 1,080.00 Total $ 5.000.11 -, City Attorney Account No. 001-1500-514-34-52, Other Contractual Services/Code Enforcement. Account balance as of April 29, 2008 is $15,357.50 0022-137 Special Master Hearings Prof'l Services 2,000.00 Invoice No. 19566 dated 4128108 Disburesments 0.00 Total Due 2 p0x0 Total 2,000.00 City Attorney Accoi n No. 001-1500-514-34-54, Other Contractual Services/Litigation Reserve. Account balance as of April 29, 2008 is $34,197.82 0022-182 Dabby Properties Prof'l Services $ 30,845.00 Invoice No. 19575 dated 4128108 Disbursements 3,330.02 Total Due 341.75.02 Total 34,175.02 Grand Total 41,175.1,3 Do not hesitate to call me if you have any questions regarding these statements. LRF:reh Enclosures cc: Mayor and City Commission Very truly yours, Iguere Page 2 of 2 NAGINGALLOPFIGUEREDOP& Attorneys 6 Counselors 18001 Old Cutler Road, Suite 556 Miami, Florida 33157 Telephone: (305) 854-5353 Facsimile: (305) 854-5351 April 28, 2008 Ajibola Balogun Matter ID: 0022-001 City Manager General Municipal City of South Miami 6130 Sunset Drive Invoice Number 19564 City of South Miami, FL 33143 Expenses 3/3/2008 Mileage - City Hall 8.64 3/7/2008 Database Legal research 5.68 3/10/2008 Mileage - City Hall 8.64 3/31/2008 Mileage - City Hall 8.64 4/7/2008 Mileage - City Hall 8.64 4/11/2008 Mileage - City Hall 8.64 4/14/2008 Mileage - City Hall 8.64 4/21/2008 Mileage - City Hall 8.64 4/22/2008 Mileage - Downtown 19.20 4424/2008 Photocopies for the month of April 2008. 41.50 4/2512008 Telefacs'imile charge for the month of April 2008. 24.75 4/25/2008 Postage Charge for the month of April 2008. 10.57 Sub-total-Exlyenses- 162.18 Payments 4/7/2008 Payment Check No. 61353 137.23 Sub-total Payments: 137.23 Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1.5% per month will be charged if payment is not received within 30 days. Nagin Gallop Figueredo P.A. Matter 10: 0022-001 Statement No.: 19564 Page: 2 For Professional Services For Disbursements Incurred Current Balance: Previous Balance: Payments - Thank you 0.00 162.18 162.18 137.23 137.23 Total Due 162.18 invoice Number: 19564 To be property credited, please indicate Invoice Number above on your remittance check. Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest ata rate of 1.5% per month will be charged If payment is not received within 30 days. NAGIN GALLOP FIGUEREDO P.A. Attorneys & Counselors 18001 Old Cutler Road, Suite 556 Telephone: (305) 854-5353 Ajibola Balogun City Manager City of South Miami 6130 Sunset Drive City of South Miami, FL 33143 Miami, Florida 33457 Facsimile: (305) 854-5351 April 28, 2008 Matter ID:. 0022-083 Planning Board Invoice Number 19565 Hours 4/11/2008 LRF Meeting with Comm. Jay Beckman and Mr. Sandy Youkills re: EAR 3.00 project.. 4/15/2008 LRF Meeting with Mr. Youkills on EAR and M-Cycle. 2.00 4/21/2008 EAB Prepared for and attended P&Z EAR meeting; telephone conference 3.00 with Mr. Youkilis, telephone conference with Mr. Stephen David regarding EAR. Total Professional Services Rate Summary Luis R. Figueredo 5.00 hours at $ 200.00/hr 1,000.00 Eve A. Boutsis 3,00 hours at $ 200.00/hr 600.00 Total hours: 8.00 Expenses 4/7/2008 Photocopies 5.00 Sub-total Expenses: 5.00 Payments 4/7/2008 Payment Check No. 61353 180.00 Sub-total Payments: 180.00 Amount 600.00 of Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a, rate of t.5% per month will be charged if payment is not received within 30 days. NagInGallop Figueredo P.A. Matter ID: 0022-083 Statement No.: 19566 For Professional Services For Disbursements Incurred Current Balance: Previous Balance: Payments - Thank you Total Due Invoice Number: 19565 To be properly credited, please indicate Invoice Number . above on yo ur remittance check. Page: 2 1,600,00 5.00 1,605.00 180.00 180.00 1,605.00 Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1.5% per month will be charged if payment is not received within 30 days. INAGINGALLOPFIGUEREDO P.A. Attorneys & Counselors 18001 Old Cutler Road, Suite 556 Miami, Florida 33167 Telephone: (305) 854-5353 Facsimile: (305) 854-5851 April 28, 2008 Ajibola Balogun Matter ID: 0022-137 City Manager Special Master Hearings City of South Miami 6130 Sunset Drive Invoice Number 19566 City of South Miami, FL 33143 Rate Summary Eve A. Boutsis Payments 4/7/2008 Payment 10.00 hours at $ Total hours: 10.00 Check No. 61353 200.00/hr Sub-total Payments: M**_W* 4,182.50 Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate o €1.5% per month Will be charged if payment is not received within 30 days. Hours Amount 3/25/2008 EAB Meeting with Ms. Carol Bynum, Ms. Eva Rosa, and Mr. Dario 1.56 Mom, Gonzalez regarding document production for subpoehw, and attention to pending code compliance matters. 4/3/2008 EAB Attended final summary judgment relating to csm liens and 3.00 600.00 foreclosure of same. 4/17/2008 EAB Attention to code enforcement matter and communications by Mr. 0.40 80.00 Juan Albian, attorney for appellant; follow up with staff regarding same. 4/18/2008 EAB Communications with Mr. Alblan counsel for code enforcement 0.60 1210.00 appellant; discussion with Ms. Rosa regarding same; meeting with Mr. Ajibola Balogun regarding special master contracts; and revised resolutions regarding same. 4/23/2008 EAB Prepark for and attended pre-hearing meeting with staff in 4.50 900.00 anticipation of hearings, and attended special master hearing. Total Professional Services 2,000.00 Rate Summary Eve A. Boutsis Payments 4/7/2008 Payment 10.00 hours at $ Total hours: 10.00 Check No. 61353 200.00/hr Sub-total Payments: M**_W* 4,182.50 Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate o €1.5% per month Will be charged if payment is not received within 30 days. Nagin Gallop 5igueredo P.A. Matter ID: 0022-137 Statement No.: 19566 Page: 2 For Professional Services 2,000.00 For Disbursements Incurred 0.00 Current Balance: Previous Balance: Payments - Thank you 2,000.00 4,182.50 4,182.50 Total Due 2,000.Ok Invoice Number: 19566 To be properly credited, please indicate Invoice Number above on your remittance check. Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1,5% per month will be charged if payment is not received within 30 days. I� �� /�z� [W��u��U��0��0l11��0`� Attorneys & Counselors 18001 Old Cutler ROad, Suite 556 MG[Oi. Florida 33157 Telephone: ( April 2l2OD8 AjibnlaBalngun Matter ID: O022-1O2 city manage{ Dobm Properties vCSMand Qh/ of South Miami Invoice Number 1AS75 G13O Sunset Drive City of South Miami, FL 33143 028/2008 HJM Received Notice of'Deposition ofMRPcorporate representative and of 3.10 62U0 Mark Richman (l1); received and na\ievw»d telephone voiommal|from Plaintiff's counsel KX: Reiss (0.1); received and reviewed e-mail correspondence from Mr. Reiss (I1);nehewved transcript ofAttorney Client Session (O^4); continued preparing Motion for Summary Judgment (2.4), 031/2008 HJM Continued reviewing file for deposition and for Motion for Summary 2,70 540.00 Judgment (2.3); ReVeedmnd reviewed Amended Mediation Report (0.1)| Received and reviewed e-mail correspondence from P|minUfFa counsel re: Motion to Consolidate (0.1); Received and reviewed Plaintiffs correspondence to Court attaching Notices ofWithdrawing Motion to Consolidate (O.2)' 4/1/2008 HJK8 Conducted pre dapopreparation of Building Official Gonzalez (2.0) 8.70 1.340.00 telephone conference with yWRP counsel J. Hanson re: depositions Paymamis due upon receipt. Please notifyuawithin1Udays of receipt of any questions you have regarding this invoice. Interest ata rate of 1.5% per month w Ill be charged If payrnent is not received w ithin 30 days. Hours Amount 024M08 HJM Prepared second lettertoPlaintiffs counsel re: deposition schedules 4.80 960.00 (.2). Cbmmenced rWewing file for preparation of deposition-prep sessions for interim Planning and Zoning Director Mr. Sandy YouNUs and Mr. Luis Figuemdo(4.6)^ 3/25/2008 HJk8 Received and n*%hevmadK4odirdor'e Mediation Report (0,1); Received 1.90 380.00 and reviewed Notices of Taking Deposition (0'1); Received and ne,0nvmed e-mail correspondence from Plaintiffs counsel re: depostart times (0.1); reviewed file |n preparation for dapo'pnepsession with Building official Mr, Dario Gonzalez, 3/2E�2D�8 HJK8 ReceAvedendn*� dP|ain��eAmondedNo�ceofT�k\ng swvn �80 G�O0O . , Deposition; continued na,�einQ file iD preparation for deposition. 3/27/2008 HJKA Continued reviewing file and voluminous set of documents |n 5'50 1,100.00 preparation for depositions of Mr. H0meredo. Mr. YoukiUo and Mr. Gonzalez. 3/27Y2008 EAB Legal research re: lobbying, registration, lawyer responsibilities and 0'70 140.00 duty to disclose. 028/2008 HJM Received Notice of'Deposition ofMRPcorporate representative and of 3.10 62U0 Mark Richman (l1); received and na\ievw»d telephone voiommal|from Plaintiff's counsel KX: Reiss (0.1); received and reviewed e-mail correspondence from Mr. Reiss (I1);nehewved transcript ofAttorney Client Session (O^4); continued preparing Motion for Summary Judgment (2.4), 031/2008 HJM Continued reviewing file for deposition and for Motion for Summary 2,70 540.00 Judgment (2.3); ReVeedmnd reviewed Amended Mediation Report (0.1)| Received and reviewed e-mail correspondence from P|minUfFa counsel re: Motion to Consolidate (0.1); Received and reviewed Plaintiffs correspondence to Court attaching Notices ofWithdrawing Motion to Consolidate (O.2)' 4/1/2008 HJK8 Conducted pre dapopreparation of Building Official Gonzalez (2.0) 8.70 1.340.00 telephone conference with yWRP counsel J. Hanson re: depositions Paymamis due upon receipt. Please notifyuawithin1Udays of receipt of any questions you have regarding this invoice. Interest ata rate of 1.5% per month w Ill be charged If payrnent is not received w ithin 30 days. NagimGa\lop Figueredo P.A. Matter ID: 0O22-182 Statement No': 19575 Page: 2 kl8\ received and reviewed e-mail correspondence from Plaintiffs counsel re: J./Ukale} re: depositions Kl1tconducted preparation mf Planning and Zoning Director Mr. YoukiUa(2.8)| telephone conference with Plaintiffs counsel re: agreed order on vacating prior order (0'1); received and naxicwved proposed agreed order for Plaintiffs counsel (O.1); continued preparing dupnoutUnmfor n*-depo session with Mr. FiguoredoiU anticipation of Mr. Flguareddn deposition (1.3). 4/2J2008 HJM Received and neNuiamed correspondence from Plaintiffs to Court re: 4.20 840.00 agreed order and attachments (}.2)| travel to and attend continuation of pre-deposition preparation session mf Mr. Gonzalez ai City of South Miami (1.0); tnae|to and attend continuation ofpre-deposition preparation session of Mr. Youki|inat City of South Miami (2.G);travel with wdtn6aetupremises of facility to inspect same (U./)' 4/3/2008 HJM Conducted addKionalpre-depo preparation session with Mr. Youk\|is 2,00 400.00 prior to deposition (2.0); travel to and attended of Mr. Ymuki|iaat offices of Plaintiffs counsel (5.0); conducted telephone conference with Mr. Gonzalez re: deposition preparation nasnion (0.[);nWewved file in preparation of Mr. Gonzalez' deposition (],3)| necohed and rWewed Ptaintiffs Re-Notice ofDeposition of Mark Richman (0.1); 4/4/2008 HJK8 Reoaived and reviewed Agreed order nn Motion for Clarification from 4`30 86008 County (0.1); Received and nWowved correspondence from Plaintiffs counsel Mt Schulman concerning upublic naoonda request (0.2); Conducted conference With Mr. G[)nzo|ezin preparation for his deposition (2.0)| Traveled to and attended deposition of Mr. Gonzalez (2.0). 4/612008 HJM Conducted prep session with fact witness Mr. Flgumredo 6.00 1,360.00 and reviewed voluminous files with K8: Figuansdu. 4/6/2008 LRF Preparation With K4: yWonteUvo for deposition. 6.80 1.300.00 ' 4/712008 HJKA Travel to and attend deposition of Mr. Figuanedo(4.5); Reviewed file 6,40 1`280.00 prior to deposition cd Mr. Figunnadn(D.8); Prepared correspondence to Mr. Schulman re: public records request and review file (O.3); Prepared for deposition of Mark Richman (O.8), 4/772008 LRF Preparation and attendance at deposition aoowitness. 5.08 1.000.00 4/712008 EAB Analyzed loan documents and attention to closing; attended closing. 3.50 700l0 4/8/2008 HJM Travel to and attend deposition of Mark Richman, indixAdually and as 6.00 1'200.00 corporate representative of MRP(3.0); Received and rmhewe e-mail correspondence from Plaintiffs counsel re: conducting e meeting to discuss the pna-tho| stipulation; reviewed Case Management order K0.4\| prepared e-mail correspondence tnyWRP counsel, 0c Hanson, re: same (}.1): reviewed deposition transcript of Frank and Karen Payment is due upon receipt Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at rate of 1.5% per month w Ill be charged 9 payrnant is not received within 30 days, Megin Gallop FiguerednP�L Matter ID: 0022482 Statement No.: 19575 Page: 3 Dabbv and two transcripts nf Stuart Auerbaokin for k8ot�m�xSummary Judgment (2.0); n*mievwad the Complex Business UdoationRU|es for purposes of filing pre-trial stipulation (l6). 4/0/2008 HJk8 Conducted legal research to update prior research on|nterpnabsUonof 7.10 1.420.00 easement agreements (4.3); Received and na�iexede-mail correspondence from Plaintiff counsel, Robin Scott, na� meeting to review pre-trial stipulation (].1); ReVevwaddieocxary responses from Plaintiff included RequentinrAdm\osn{onm and Answer to Interrogatories in support of preparing the Motion for Summary Judgment (1.4); Continued reviewed Mr. Awedbaokhth|nd deposition t(anecdpt(1'3). ' 4/10/2008 HJK8 Received and FeWevmadPledntiffs corrected Notice nf Hearing onJoint 5.60 1,120l0 Motion for Continuance of Trial (U.1);AeosAwad and reviewed Notice of Hearing, Status Conference and Pre-Trial Conference from Plaintiffs counsel (O.1); Continued conducting legal research on issues nf1\ whether consideration pald for easement has en effect nn conoiden�ionof its use (3.4)|2)VVhethar inconvenience ed�neie enough for increased damages; kl8\3) whether Court can look ak easement's purpose tu expand the use of the easement (O.8);4Q whether Court has the discretion to expand the use of easement vAth extrinsic eWdanoa;(].8); whether fire-safety issues affect the termination of the easement ().8); whether modern times can bea factor \n expanding the inifio| intent for the easement (1,8). 4/11/2008 HJK8 Received and reviewed Mr. FigUeredds deposition transcript and 0.60 1,920.O0 attached exhibits (1,5)| Received and n*\4ev*od deposition transcript of Mr. YnukiUo and Mr. Gonzalez (2.D); Received and reviewed Notice of Filing (0.1); continued conducting legal research on issue of abandoning the right to easement and whether temporary non-use cf easement causes abandonment (2.0); researched whether standard nf proof for abandonment was clear and convincing evidence ur preponderance ofthe eWdenoe(D.4)| continued conducting legal research on cases for termination of easement hghts(1.3);continued conducting legal research on the legality ofpnrWding tax abatements tnnuo|denta/dovalopm,oin expectance for compensation urother benefits and whether third parties maintain standing to challenge the . tax abatements (2,3). 4/11/2008 S8 Pdnted and provided caselaw for Mr. Montalvo on easement issue. 0.80 00.00 4/14/2008 HJK8 Continued whdng and preparing Motion for Summary Judgment (5.5); 7.80 1.560.00 continued updating the research on issue (f standing concerning tax ,issues (1.8); continued oheppanjizinO all cases (O.S). 4/14/2008 SS Prepared notice uf filing ofdepoe0on transcripts for Mr. Monialvo| 1.40 105.00 �onnmdL�xisdmts��anyaaa�hot�W� K8onto{vnb request; pulled pe ' additional cases from Laxiodatabase. 4/16/2008 HJK8 Received and Reviewed deposition transcript oYK8RP(1.3);Continued , 9.70 1.040.00 Payment is due upon receipt. Flease notify us within 10 days of receipt of any questions you have regarding this invoice. interest atu rate of1.5va per momh will bncharged ifpaynmntis not received wlithin8odays. Nmgin Gallop Figoere6oP.8. Mafter ID: 0022-182 Statement No.: 19575 reviewed Mr. YouNUe deposition transcript (0-5); Continued updating legal research on exhaustion of administrative remedies cases regarding Count K/(1'8)| continued updating legal research on defenses to Plaintiffs Unity cf Title arguments (1.2); Reviewed files tn compile and update exhibits tu attach to Motion for Summary Judgment (0.6); Continued finalizing concise statement cfundisputed facts (3.8); Reviewed Miami-Dade County Fire Code for reference to width requirements for accessory (J.5). HJK8 Continued undUmdbedK8nUon�v�un�ma� 11 AD 4/1G/20D8 preparing """y.^"`^. , Concise Statement of Undisputed Facts and Memorandum of Law emU.0)|Rmdizedexhi�te for �Ung(l4) � �mkedandReWevmadP|aJnthMs proposed Joint Pre-Trial SUmulsUon (1.0); Received and Reviewed Plaintiffs draft exhibit list (l4); Received and Reviewed Plaintiffs draft witness list (0.2); Received and Fevievw*dvoicemai| from MRP and J. Hanson 9D.1). 4/16/2008 GS Assisted K8: k8onba|vo with completion of motion for summary 6.30 judgment, reviewed document and checked all exhibits for accuracy; created table nf authorities and prepared binder of all cases cited. 4/17/2008 HJM Travel to and attend pre-trial stipulation conference with Plaintiffs 11.28 counsel and K4RP counsel e2 Plaintiffs counsel's offices (9.6); Conducted conference prior to pre-trital stipulation conference with counsel for0YRP (O.G); Prepared revisions and additions toPlaintiffs proposed draft of the pre-trial stipulation (5.2); Prepared the City's w(Itneea list (0.4)| Prepared objections to Plaintiffs exhibits 0.5\; Prepared City's exhibit list (1.D)| Received exhibits listed onexhibit list (D.5); Prepared e'maf correspondence to Plaintiffs counsel re: exhibits and witness list (O,2); Reviewed the Business Ut}Oot|on Sections procedural m|eo regarding prp-thsUstipulations (0.4). ` 4/1772008 SG Completed binder including all authorities oited|n motion for (IQO summary judgment for Mr. W1nnfakm| created second copy ofbinder; performed VVeotmw database research for oeoo|sw. 4/18/20 08 HJN1 Completed revisions/additions to Plaintiffs draft ofJoint Pretrial 8.20 Stipulation (1.0)| Prepared multiple correspondence toPlaintiffs counsel R. Scott re: revisions (0.2); Received and reviewed K8RP's revisions/corrections toPn*Tred Stipulation (D.4); Completed and reviewed binders for City's exhibits (0.2)| Received and reviewed 'additional draft of proposal joint PreTriW Stipulation for Plaintiffs counsel with revisions (D.4); Reviewed table of cases (D.8); Conducted conference call with Plaintiffs counsel and MRPcounsel re: PneDia| Stipulation (0,5)| Performed additional revisions to PnaTha( Stipulation; Received and R%ievwad three Motions for Summary Judgment and exhibits and read cases cited therein for KARPun Plaintiffs 4th Amended Complaint (3.6); Received and Rm6ewed another revised draft for Plaintiffs counsel to finalize same k).6\; Conducted additional conference call with k8: Scott 0.2A; Prepared Page: 4 P�Lyrnent is due upon recelpt. Reasemotify us within 10 days of receipt of any questions you have regarding this invoice. interest at rate of 1.5% per rrK)nth w ill be charged if payrrent is not received w ithin 30 days. NaQin Gallop Figu��A. Amended Witness List kI1\; Received and Reviewed e-mail from Fqsdnt�soounae b000u�kl1� Received and correspondence e-mail correspondence from K8Rob counsel to Court (l1); Received and Reviewed e-mail correspondence andattamhmentto Court (0.1). 4/21/2008 GS Performed legal h worked binders containing caselaw [\gO 67.50 cited inmotion for summary judgment; underlined quoted portions and provided tuMr. Monto|vo for naiewv 4/22/2008 HJM Raookmd and ne\\ewvod e-mail correspondence from Court re: 5,10 1,020.00 Commencement of Trial (O.1); Commence preparing Trial Memorandum (4.8); Prepared Correspondence to Plaintiffs counsel re: Clifford Shulman (O.2). 4/28/2008 HJM Conducted telephone conference with MRP counsel J, Hanson re: 0.80 160.00 Judge Stettin (0.2); Prepared e-mail correspondence toCourt re: J. St tlin (0.1); Prepared e-mail correspondence for Plaintiffs counsel A. Dimond re: Clifford Schulman (l1); Prepared letter tnA. Dimond re: Clifford 8ohu|[nand and disputed issues (0.4). 4/23/2008 GS Printed caoa|aw and pnmidodha Mr. &1onto|vo. 0.10 7.50 Total Professional 8eNoem 30,84500 Rate Summary H. James Montalvo 134.70 hours at $ 200,00h 26,940.00 Luis FiFi 11.00 hours at $ 200.00hr 2,360.00 Eve A.8outois 4.2O hours sd$ 200,00/hr 840.00* Susan Snavely 8.4O hours mt$ 75.00/hr 705.00 Total hours: 160,10 Expenses 3/11/2008 Database Legal research 384.98 3/11/2008 Database Legal research . 15 3/18/208 Tolls 'Mediations 2.00 ` 8110/2008 Court reporter - Attorney-Client Session 602.00 4/212008 Mileage 'Depo prep meneUuna for Sandy YoukUiaand 11.04 Dario Gonzalez 4�20� MUea�'D��iU��Gan�Y��|is 2OQ3 ' Payrrienis due upon receipt Please nof4yomw Rhin 1O days of receipt of any quention you have regarding this invoice. Interest ata rate of 1.5% per n-ionth w ill be charged If payment is not received w Rhin 30 days. Nagin Gallop Figueredo P.A. Matter ID: 0022-182 Statement No.: 19575 4/4/2008 Mileage - Deposition of Dario Gonzalez 20.93 4/7/2008 Mileage.- Deposition of Luis Figueredo 20.93 4/10/2008 Book - Private Land Use Arrangments 195.00 4/1312008 Transcripts 803.30 4/15/2008 butside, copy job - Copies of 24X36 Drawings 32.10 4/16/2008 Parking Charge - Travel to Courthouse 1.00 4/16/2008 Outside copy job - Copies of Drawings - Reduced 3210 4/16/2008 Mileage - Travel to Courthouse 17.61 4/17/2008 Mileage - Travel to Greenberg Traurg 16.41 4/21/2008 Mileage - Courthouse for Pretrial Conference 17.61 4/21/2008 Tolls - Courthouse for Pretrial Conference 3.50 4/21/2008 Parking Charge - Courthouse for Pretrial Conference 3.75 4/24/2008 Photocopies for the month of April 2008. 662.25 4/25/2008 Postage Charge for the month of April 2008. 10.43 4/25/2008 Talefacsimile charge for the month of April 2008. 75,00 Sub-total Expenses: 3,330,02 Payments 4/7/2008 Payment Check No. 61353 10,287.25 Sub-total Payments: 10,287.25 �.aE, Payment is due upon receipt Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1.5% per month w ill be charged If payment is not received within 30 days. Nagin Gallop Figueredo P.A. Matter ID: 0022-182 Statement No.- 19575 For Professional Services For Disbursements Incurred Current Balance: Previous Balance: Payments - Thank you Total Due Invoice Number: 19575 To be properly credited, please indicate Invoice Number above on your remittance check. Page. 7 30,845.00 3,330.02 34,175.02 10,287.25 10,287.25 34,175,02 Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice, Interest ata rate of 1,5% per month will be charged I payrnantis not received within 30 days. NAGINGALLOPFIG'UEREDO PA. Attorneys & Counselors 18001 Old Cutler Road, Suite 656 Telephone: (305) 854-5353 Ajibola Balogun City Manager City of South Miami 6130 Sunset Drive City of South Miami, FL 33143 Miami, Florida 33157 Facsimile: (305) 854-5351 April 28, 2008 Matter ID: 0022-190 City of South Miami Health Invoice Number 19568 Hours 312412008 HJM Telephone conference with Plaintiff's counsel re: garnishment. 0.10 Total Professional Services Rate Summary H. James Montalvo 0,10 hours at $ 150.00/hr 15.00 Total hours: 0,10 Payments 3/25/2008 Payment Check No. 61247 For Professional Services For Disbursements Incurred Current Balance: Previous Balance: Payments - Thank you Sub-total Payments: Total Due 33.23 33.23 Invoice Number: 19568 To be properly credited, please indicate Invoice Number above on your remittance check. Amount 15.00 15.00 15.00 0.00 15.00 33.23 33.23 15.00 Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest ata rate of 1.5% per month will be charged if payment is not received within 30 days., NAGINGALLOPFiGUERED0 P.A. Attorneys & Counselors 18001 Old Cutler Road, Suite 556 Telephone: (305) 854-5353 Ajibola Balogun City Manager City of South Miami 6130 Sunset Drive City of South Miami, FL 33143 Miami, Florida 33157 Facsimile: (305) 854-5351 April 28, 2008 Matter ID: 0022-192 Valencia Condominiums v. City Invoice Number 19569 Hours 4/9/2008 HJM Received and reviewed e-mail correspondence from Plaintiff's 0.10 counsel, Mr. Paul Lipton, and prepared response to same. 4/11/2008 HJM Received and reviewed Notice of Hearing on City's Motion to Dismiss. 0.10 Rate Summary H. James Montalvo, Expenses 3/19/2008 Payments 4/7/2008 Total Professional Services 0.20 hours at $ 200.00/hr Total hours: 0.20 Database Legal research MAE$ 17.92 Sub-total Expenses: 17.92 Payment Check No. 61353 200.00 Sub-total Payments: 200.00 Amount 20.00 20.00 Payment is due upon receipt. Please notify us Within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1.5% per month will be charged if payment is not received within 30 days. Matter ID: 0022-192 Statement No.: 19569 For Professional Services For Disbursements Incurred Current Balance: Previous Balance: Payments - Thank you Total Due Invoice Number: 19569 To be properly credited, please indicate Invoice Number above on your remittance check. Page: 2 40.00 17.92 57.92 200.00 200.00 57.92 Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a . rate of 1.5% per month will be charged if payment is not received Within 30 days. P NAGIN GALLOP FIGUEREDO. . A. - - _-- ----- Attorneys & Counselors 18001 Old Cutler Road, Suite 556 Telephone: (305) 854-5353 Ajibola Balogun City Manager City of South Miami 6130 Sunset Drive City of South Miami, FL 33143 Miami, Florida 33157 Facsimile: (305) 854-5351 April 28, 2008 Matter ID: 0022-196 Doug Baker Arbitration Invoice Number 19570 Hours Amount 3/24/2008 SS Performed Westlaw database research to obtain arbitration decisions 0.50 37.50 at Mr. Montalvo's request. Total Professional Services 37.50 Rate Summary Susan Snavely Expenses 0.50 hours at $ 75.00/hr 37.50 Total hours: 0.50 4/2/2008 Database Legal research 53.00 4/25/2008 Postage Charge for the month of April 2008. 0.41 Sub-total Expenses: 53.41 Payments 4/7/2008 Payment Check No. 61353 502.85 Sub-total Payments: 502.85 Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this Invoice. Interest at a rate of 1.5% per month will be charged if payment is not received within 30 days. Nagin Gallop Figueredo P.A. Matter ID: 0022-196 Statement No.: 19570 For Professional Services For Disbursements Incurred Current Balance: Previous Balance: Payments - Thank you Total Due Invoice Number: 19570 To be properly credited, please indicate Invoice Number above on your remittance check. M-M-1 37-50 53.41 90.91 502.85 502.85 A101 U11 Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this Invoice- Interest at a rate of 1.5% per month will be charged it payment is not received within 30 days. NAGIN GALLOP FIGU'EREDO PA. Attorneys & Counselors 18001 Old Cutler Road, Suite 556 Telephone: (305) 854-5353 Alibola Balogun City Manager City of South Miami 6.134 Sunset Drive City of South Miami, FL 33143 Miami, Florida 33157 Facsimile: (305) 854-5351 April 28, 2008 Matter ID: 0022-199 Ray Manucy Invoice Number 19571 Hours Amount 4/23/2008 HJM Prepared Motion to Dismiss (0.5); Conducted legal research on 1.30 266.00 standing issues and notice requests issues (0.5); Prepared letter to Valet Service re: indemnification (0.3). Rate Summary H. James Montalvo 1.30 hours at $ Total hours: 1.30 Expenses 4/2412008 Photocopies for the month of April 2008. Payments 3/25/2008 Payment Check No. 61247 Total Professional Services 260.00 200.00/hr Sub-total Expenses: Sub-total Payments: U-71M 2.50 2.50 40.58 40.58 Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1.5% per month will be charged it payment is not received within 30 days. Nagin Gallop Figueredo P.A. Matter ID: 0022-199 Statement No.: 19571 Page: 2 For Professional Services For Disbursements Incurred Current Balance: Previous Balance: Payments - Thank you 260.00 2,50 262.50 40.58 40.58 Total Due 262.50 Invoice Number: 19671 To be properly credited, please indicate Invoice Number above on your remittance check. Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1.5% per month will be charged if payment is not received Within 30 days. NAGINGALLOPFIGUEREDO P.A. Attorneys & Counselors 18001 Old Cutler Road, Suite 556 Miami, Florida 33157 Telephone: (305) 864-5353 Facsimile: (305) 854-5351 April 28, 2008 Ajibola Balogun Matter ID: 0022-201 City Manager Rene Guirn v. City of South City of South Miami 6130 Sunset Drive Invoice Number 19572 City of South Miami, FL 33143 4/18/2008 HJM Received and Reviewed Guim's Third Request for Production to Sola 0.20 40.00 (0.1); Received and Reviewed Palmer's Notice of Hearing on Motion payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1.5% per month will be charged if payment Is not received within 30 days. . Hours Amount 3/26/2008 HJM Received and. reviewed Plaintiff's 1 st Request for Production to 0.40 80.00 Commissioner Velma Palmer and 2nd Set of Interrogatories to Sola and Palmer. 3/28/2008 HJM Received Plaintiff's exhibits 1 and 2;'Plaintiff's Notice of Serving 0.50 100.00 Answers to Palmer's 1st and 2nd Interrogatories; Plaintiff's response to Palmer's 1 st Request for Production and e-mail correspondence from Plaintiff's counsel. - 3/31/2008 HJM Received and reviewed Ethics Commission opinion to Velma Palmer. 0.30 60.00 4/2/2008 HJM Received and reviewed correspondence from counsel for Gulm to 0.10 20.00 counsel for Palmer concerning the original jurat pages. 4/3/2008 HJM Received and reviewed Miami Dade County's Answers to First Set of 0.40 80.00 Interrogatories. 4/412008 HJM Received and reviewed Defendant Palmer's Answers to Plaintiff's 2nd 0.30 60.00 Set of Interrogatories (0.2); Received and reviewed Defendant Palme . r's response to Plaintiff's First Request for Production (0.3). 4/10/2008 HJM Received and reviewed correspondence from Palmer's counsel to 0.30 60-00 Court with request for special set hearing on Motion to Dismiss Amended Complaint (0.1); Received and reviewed Palmer 3rd Set of Interrogatories to Plaintiff (0.2). 4/14/2008 HJM Received and reviewed correspondence from Plaintiff's counsel re: 0.10 20.00 Hearing on Motion to Dismiss. 4/15/2008 HJM Received and Reviewed Plaintiff's Third Set of Interrogatories to 1.20 240.00 Palmer and Sola and Notice of Service of Same (0,2); Received and Reviewed Palmer's Motion to Dismiss (0.4); Received and Reviewed Gulm's Second Request for Production to Palmer and Sola (0.1); Received and Reviewed Sola's response to Plaintiff's First Request for Production (0.1); Received and Reviewed Sola's Answers to Plaintiff's Second Set of Interrogatories (0.4). 4/18/2008 HJM Received and Reviewed Guim's Third Request for Production to Sola 0.20 40.00 (0.1); Received and Reviewed Palmer's Notice of Hearing on Motion payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1.5% per month will be charged if payment Is not received within 30 days. . Nagin Gallop Figueredo P.A. Matter ID- 0022-201 Statement No-- 19572 Total Professional Services Rate Summary H. James Montalvo 6.40 hours at $ 200.00/hr Total hours: 6.40 Expenses 3/3/2008 3/3/2008 3/4/2008 3/10/2008 4124/2008 4/25/2008 4125/2008 Payments 4/7/2008 Database Legal research Photocopies the month of March 2008. Database Legal research Database Legal research Photocopies for the month of April 2008. Telefacsimile charge for the month of April 2008. Postage Charge for the month of April 2008. Sub-total Expenses: 1,280.00 367.68 8.00 21.04 10.06 7.50 29.25 3.07 F, IM . *X^*U Payment Check No. 61353 963.41 Sub-total Payments: 963.41 Page: 2 20.00 400-00 60.00 40.00 1,280-00 Payment is due upon receipt. Please notify us Within 10 days of receipt of any questions you have regarding this invoice. interest at a rate of 1.5% per month will be charged if payment is not received Within 30 days. to Dismiss (0.1). /21/2008 HJM Received and reviewed Palmer's Notice of Hearing on Motion to 0.10 Dismiss. 41/93/2008 HJM Conducted conference with Mr. Ajibola Balogun and Mr. Rudy de la ZOO Torre. /23/2008 HJM Received and reviewed Guim's.Answers to Palmer's Third set of 0.30 Interrogatories. ,195/2008 HJM Received and reviewed Palmer's additional responses to Plaintiff's 0,20 interrogatories. Total Professional Services Rate Summary H. James Montalvo 6.40 hours at $ 200.00/hr Total hours: 6.40 Expenses 3/3/2008 3/3/2008 3/4/2008 3/10/2008 4124/2008 4/25/2008 4125/2008 Payments 4/7/2008 Database Legal research Photocopies the month of March 2008. Database Legal research Database Legal research Photocopies for the month of April 2008. Telefacsimile charge for the month of April 2008. Postage Charge for the month of April 2008. Sub-total Expenses: 1,280.00 367.68 8.00 21.04 10.06 7.50 29.25 3.07 F, IM . *X^*U Payment Check No. 61353 963.41 Sub-total Payments: 963.41 Page: 2 20.00 400-00 60.00 40.00 1,280-00 Payment is due upon receipt. Please notify us Within 10 days of receipt of any questions you have regarding this invoice. interest at a rate of 1.5% per month will be charged if payment is not received Within 30 days. Naciln Gallop Figueredo P.A. Matter ID: 0022-201 Statement No.: 19572. For Professional Services . For Disbursements Incurred Current Balance: Previous Balance: Paym'ents - Thank you Total Due Invoice Number: 19572 To be properly credited, please indicate Invoice Number above on your remittance check. Page: 3 1,280.00 446.60 1,726.60 963.41 963.41 1,726.60 Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1,5% per month will be charged if payment is not received within 30 days.- NNGIN- GALLOPFIGUEREDOPA. Attorneys & Counselors 18001 Old Cutler Road, Suite 556 Miami, Florida 33157 Telephone: (305) 854-5353 Facsimile: (305) 854-5351 April 28, 2008 Ajibola Balogun Matter ID: 0022-202 City Manager Environmental Quality Control City of South Miami Invoice Number 19573 6130 Sunset Drive City of South Miami, FL 33143 Hours Amount 3/1112008 HSK Study staff report for environmental quality control board, emails 1.50 300.00 regarding meeting with City Manager Ajibola Balogun, and engineer Jose Olivo at South Miami City Hall in re South Miami petition for second extension of time for resident water connection to water supply. 3112/2008 HSK Conference with Luis FIgueredo regarding City of South Miami 0.50 100.00 petition before environmental quality control board, review of environmental resources management staff report, telephone conference with South Miami city manager; in re South Miami Petition for second extension of time for residents to connect to water supply. 3/13/2008 HSK Attendance at hearing before environmental quality control board with 3.40 680.00 Mr. Balogun and Jose Olivio; in re petition for second extension of time for residents to connect to water supply. Rate Summary Henry S. Kaplan Total Professional Services 1,080.00 5.40 hours at $ .20,0.00/hr Total hours: 5.40 Payment is due upon receipt. Please notify us Within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1.5% per month will be charged if payment is no± received within 30 days. Nagin Gallop Figueredo P.A. Matter ID: 0022-202 Statement NO.' 19573 For Professional 8ervilcm For Disbursements Incurred Current Balance: Previous Balance: Payments - Thank you invoice Number: 18573 To be properly credited, please indicate Invoice Number above on your remittance check. Page: 2 1,080.00 0.00 1'O8U'0D 0.00 0.00 ----' 1,080.00 have ��k��mo�� Pnymm�� due upon 10 days of receipt of any questions you rate of 1.5% per month will be charged if payment is not received within 30 days. NAGINGALLOPFIGUERED0 PA. Attorneys & Counselors 18001 Old Cutler Road, Suite 556 Telephone: (305) 854-5353 Aiibola Balogun City Manager City of South Miami 6130 Sunset Drive City of South Miami, FL 33143 3/24/2008 HJM 3/25/2008 HJM 3/26/2008 HJM 3/27/2008 HJM 3/27/2008 EAB 3/28/2008 HJM 3/31/2008 4/1/2008 HJM HJM Miami, Florida 33157 Facsimile: (305) 854-5351 April 28, 2003 Matter ID: 0022-182 Dabby Properties v GSM and Invoice Number 19575 Hours Prepared second letter to Plaintiff's counsel re: deposition schedules 4.80 (.2), Commenced reviewing file for preparation of deposition-prep sessions for interim Planning and Zoning Director Mr. Sandy Youkilis, and Mr. Luis Figueredo (4.6). Received and reviewed Mediator's Mediation Report (0.1); Received 1.90 and reviewed Notices of Taking Deposition (0.1); Received and reviewed e-mail correspondence from Plaintiff's counsel re: depo start times (0.1); reviewed file in preparation for depo-prep session with Building official Mr. Dario Gonzalez. Received and reviewed Plaintiff's Amended Notice of Taking Deposition; continued revising file in preparation for deposition. Continued reviewing file and voluminous set of documents in preparation for depositions of Mr. Figueredo, Mr. Youkills and Mr. Gonzalez. Legal research re, lobbying, registration, lawyer responsibilities and duty to disclose. Received Notice of Deposition of MRP corporate representative and of Mark Richman (0.1); received and reviewed telephone voicemall from Plaintiff's counsel Mr. Reiss (0.1); received and reviewed e-mail correspondence from Mr, Reiss (0.1); reviewed transcript of Attorney Client Session (0.4); continued preparing Motion for Summary Judgment (2.4). Continued reviewing file for deposition and for Motion for Summary Judgment (2.3); Received and reviewed Amended Mediation Report (0.1); Received and reviewed e-mail correspondence from Plaintiff's counsel re: Motion to Consolidate (0.1); Received and reviewed Plaintiff's correspondence to Court attaching Notices of Withdrawing Motion to Consolidate (0.2). Conducted pre depo preparation of Building official Gonzalez (2.0) telephone conference with MRP counsel J. Hanson re: depositions (0.3); received and reviewed e-mail correspondence from Plaintiff's counsel re: J. Alkalel re: depositions (0.1); conducted pre-depo 3.30 5.50 0.70 3.10 2.70 W-11 Amount 960.00 380-00 660.00 1,100.00 140.00 620-00 540.00 Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1.5% per month will be charged if payment is not received within 30 days. Nagin Gallop Figueredo P.A. Matter 11): 0022-182 Statement No.: 19575 Page: 2 4/2/2008 4/3/2008 4/4/2008 4/6/2008 4/6/2008 4/7/2008 preparation of Planning and Zoning Director Mr. Youkilis (2.8); telephone conference with Plaintiff's counsel re: agreed order on vacating prior order (01); received and reviewed proposed agreed order for Plaintiff's counsel (0-1); continued preparing depo outline for pre-depo session with Mr. Figueredo in anticipation of Mr. Figueredo's deposition (1.3). HJM Received and reviewed correspondence from Plaintiff's to Court re: agreed order and attachments (0.2); travel to and attend continuation of pre-deposition preparation session of Mr. Gonzalez at City of South Miami (1,0); travel to and attend continuation of pre-deposition preparation session of Mr. Youkilis at City of South Miami (2.6); travel with witness to premises of facility to inspect same (0.4). HJM Conducted additional pre-depo preparation session with Mr. Youkilis prior to deposition (2.0); travel to and attended deposition of Mr. Youkilis at offices of Plaintiff's counsel (5.0); conducted telephone conference with Mr. Gonzalez re: deposition preparation session (0.2); reviewed file in preparation of Mr. Gonzalez` deposition (0.3); received and reviewed Plaintiff's Re-Notice of Deposition of Mark Richman (0.1). HJM Received and reviewed Agreed order on Motion for Clarification from County (0.1); Received and reviewed correspondence from Plaintiff's counsel Mr. Schulman concerning a public records request (0.2); Conducted conference with Mr. GOnzalez in preparation for his deposition (2.0); Traveled to and attended deposition of Mr. Gonzalez (2.0). HJM Conducted pre-depo prep session with fact witness Mr. Figueredo and reviewed voluminous files with Mr. Figueredo. LRF Preparation with Mr. Montalvo for deposition. EW0411 No 4.30 F-U ## 6.80 1,360-00 6.80 1,360.00 HJM Travel to and attend deposition of Mr. Figueredo (4.6); Reviewed file 6.40 prior to deposition of Mr. Figueredo (0.8); Prepared correspondence to Mr. Schulman re: public records request and review file (0.3); Prepared for deposition of Mark Richman (0.8). 4/7/2008 LRF Preparation and attendance at deposition as a witness. 91WAM EAB Analyzed loan documents and attention to closing; attended closing. HJM Travel to and attend deposition of Mark Richman, individually and as corporate representative of MRP (3.0); Received and reviewed e-mail correspondence from Plaintiff's counsel re: conducting a meeting to discuss the pre-trial stipulation; reviewed Case Management order (0.4); prepared e-mail correspondence to MRP counsel, Mr. Hanson, re: same (0.1); reviewed deposition transcript of Frank and Karen DRbby and two transcripts of Stuart Auerback in preparation for Motion for Summary Judgment (2.0); reviewed the Complex Business Litigation Rules for purposes of filing a pre-trial stipulation (0.5). 5.00 3.50 6.00 HJM Conducted legal research to update prior research on interpretation of 7.10 1,280.00 1,000.00 700-00 1,200.00 1,420.00 Payment is due upon roceipt Please notify us vvithin 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1.5% per month Will be charged if payment is not received Within 30 days. Nagin Gallop Figueredo P.A. Matter ID: 0022-182 Statement No.: 19575 easement agreements (4.3); Received and reviewed e -mail correspondence from Plaintiff counsel, Robin Scott, re: meeting to review pre-trial stipulation (0.1); Reviewed discovery responses from Plaintiff included Request for Admisssions and Answer to Interrogatories in support of preparing the Motion for Summary Judgment (1.4); Continued reviewed Mr. Awerback's third deposition transcript (1.3). 4/10/2008 HJM Received and reviewed Plaintiff's corrected Notice of Hearing on Joint 5.60 Motion for Continuance of Trial (0.1); Received and reviewed Notice of Hearing, Status Conference and Pre-Trial Conference from Plaintiff's counsel (0.1); Continued conducting legal research on issues of 1 1) whether consideration paid for easement has an effect on consideration of its use (0.4); 2) Whether inconvenience alone is enough for increased damages; (0.8) 3) whether Court can look at easernerif s purpose to expand the use of the easement (0.8); 4) whether Court has the discretion to expand the use of easement with extrinsic evidence; (0,8); whether fire-safety issues affect the termination of the easement (0.8); whether modern times can be a factor in expanding the initial intent for the easement (1.8). 4/11/2008 HJM Received and reviewed Mr. Figueredo's deposition transcript and 9.60 attached exhibits (1.5); Received and reviewed deposition transcript of Mr. Youkills and Mr. Gonzalez (2.0); Received and reviewed Notice of Filing (o.1); continued conducting legal research on issue of abandoning the right to easement and whether temporary non-use of easement causes abandonment (2.0); researched whether standard of proof for abandonment was clear and convincing evidence or preponderance of the evidence (0.4); continued conducting legal research on cases for termination of easement rights(I.3); continued conducting legal research on the legality of providing tax abatements to residents/developers in expectance for compensation or other benefits and whether third parties maintain standing. to challenge the tax abatements (2-3). 4111/2008 Ss Printed and provided caselaw for Mr. Montalvo on easement issue. 0.80 4/14/2008 HJM Continued writing and preparing Motion for Summary Judgment (5.5); 7.80 continued updating the research on issue of standing concerning tax issues (1.8); continued sheppardizing all cases (0.5). 4/14/2008 SS Prepared notice of filing of deposition transcri pts for Mr. Montalvo; 1.40 performed Lexis database research at Mr. Montalvo's request; pulled additional cases from Lexis database. 4/15/2008 HJM Received and Reviewed deposition transcript of MRP (1.3); Continued 9.70 reviewed Mr. Youkilis deposition transcript (0.5); Continued updating legal research on exhaustion of administrative remedies cases regarding Count IV (1.8); continued updating legal research on defenses to Plaintiff's Unity of Title arguments (1.2); Reviewed files to compile and update exhibits to attach to Motion for Summary Judgment (0.6); Continued finalizing concise statement of undisputed facts (3,8); Reviewed Miami-Dade County Fire Code for reference to Page- 3 1,120.00 1 60.00 1,560.00 105,00 1,940.00 Payment is due upon receipt. Please notily us within 10 days of receipt of any quest! ons you have regarding this invoice. interest at a rate of 1,5% per month will be charged if payment is not received within 30 days, Nagin Gallop Pigueredo P.A. Matter 10: 0022-182 Statement NO.: 19575 Page: 4 width requirements for accessory (0.5). 4/16/2008 HJM Continued preparing and finalized Motion for Summary Judgment, 11.90 Facts and Memorandum of Law 2,380-00 Concise Statement of Undisputed (8.8); Sheppardize all cases (1.0); Finalized exhibits for filing (0.4) Received and Reviewed Plaintiff's proposed Joint Pre-Trial Stipulation (1.0); Received and Reviewed Plaintiff's draft exhibit list (0.4); Received and Reviewed Plaintiff's draft witness list (0.2); Received and Reviewed voicemall from MRP and J. Hanson 90.1). 4/16/2008 SS Assisted Mr. Montalvo with completion of motion for summary 5.30 document and checked all exhibits for accuracy; 397-50 judgment, reviewed created table of authorities and prepared binder of all cases cited. 4/17/2008 HJM Travel to and attend pre-trial stipulation conference with Plaintiff's 11.20 MRP counsel at Plaintiff's counsel's offices (2.5); 2,240.00 counsel and Conducted conference prior to pre-trial stipulation conference with counsel for MRP (0.5); Prepared revisions and additions to Plaintiff's proposed draft of the pre-trial stipulation (5.2); Prepared the City's witness list (0.4); Prepared objections to Plaintiff's exhibits (0.5); Prepared City's exhibit list (1.0); Received exhibits listed on exhibit list (0.5); Prepared e-mail correspondence to Plaintiff's counsel re: exhibits and witness list (0.2); Reviewed the Business Litigation Sections procedural rules regarding pre-trial stipulations (0,4). 4/17/2008 SS Completed binder including all authorities cited in motion for 0.90 summary judgment for Mr. Montalvo; created second copy of binder; 67.50 performed Westlaw database research for caselaw. 4/18/2008 HJM Completed 'revisions/additions to Plaintiff's draft of Joint Pretrial 8.20 Prepared multiple correspondence to Plaintiff's 1,640,00 Stipulation (1.0); counsel R. Scott re: revisions (02); Received and reviewed MRP's. revisions/corrections to PreTrial Stipulation (0.4); Completed and reviewed binders for City's exhibits (0.2); Received and reviewed additional draft of proposal joint PreTrial Stipulation for Plaintiff's counsel with revisions (0.4); Reviewed table of cases (0.8); with Plaintiff's counsel and MRP counsel Conducted conference call re: PreTrial Stipulation (0.5); Performed additional revisions to PreTrial Stipulation; Received and Reviewed three Motions for Summary Judgment and exhibits and read cases cited therein for MRP on Plaintiff's 4th Amended Complaint (3.6); Received and Reviewed another revised draft for Plaintiff's counsel to finalize same (0.5); call with Mr. Scott (0.2); Prepared Conducted additional conference Amended Witness List (0.1); Received and Reviewed e-mail correspondence from Plaintiff's counsel to court (0.1); Received and from MRp's counsel to Court (0.1); Reviewed e-mail correspondence Received and Reviewed e-mall correspondence and attachment to Court (0.1). 0.90 SS Performed legal research; worked on binders containing caselaw 67.50 4/2112008 cited in motion for summary judgment; underlined quoted portions and provided to Mr. Montalvo for review. Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1,5% per month will be charged if payment is not received Within 30 days. Nagin Gallop Figueredo P.A. Matter ID: 0022-182 Statement No.: 1.9575 4/22/2008 HJM Received and reviewed e. -mail -mail -correspondence from Court re: 5.10 of Trial (0.1); Commence preparing Trial 1,020-00 Commencement Memorandum (4-8); Prepared Correspondence to Plaintiff's counsel 3/11/2008 re: Clifford Shulman (0.2). 397-15 e with MRP counsel J. Hanson re: 0.80 4/23/2008 HJM Conducted telephone conference Prepared e-mail correspondence to Court re: J. 160.00 Judge Stettin (0.2); Stettin (0.1); Prepared e -mail correspondence for Plaintiff's counsel A. 3/18/2008 Dimond re: Clifford Schulman (01); Prepared letter to A. Dimond re: Clifford Schulmand and disputed issues (0.4). Court reporter - Attorney-Client Session 4/23/2008 SS Printed caselaw and provided to Mr. Montalvo . W 0 7,50 Total Professional Services 30,845.00 Rate Summary H. James Montalvo 134.70 hours at $ 200.00/hr 26,940.00 Dario Gonzalez Luis R. Figueredo 11.80 hours at $ 200.00/hr 2,360.00 413/2008 Eve A. Boutsis 4.20 hours at $ 200.00/hr 840.00 20.93 Susan Snavely 9.40 hours at $ 75.00/hr 705-00 Mileage - Deposition of Dario Gonzalez N Total hours: 160.10 Expenses 3/11/2008 Database Legal research 384.98 3/11/2008 Database Legal research 397-15 2.00 3/18/2008 Tolls - Mediations 3/18/2008 Court reporter - Attorney-Client Session 602.00 4/2/2008 Mileage - Depo prep sessions for Sandy Youkilis and 11-.04 Dario Gonzalez 413/2008 Mileage - Deposition of Sandy Youkilis 20.93 4/4/2008 Mileage - Deposition of Dario Gonzalez 20.93 4/7/2008 Mileage - Deposition of Luis Figueredo 20.93 4/10/2008 Book - Private Land Use Arrangments 195,00 803.30 4/13/2008 Transcripts 4/15/2008 Outside copy job - Copies of 24X36 Drawings 32.10 4/16/2008 Parking Charge - Travel to Courthouse 1.00 Payment is due upon receipt Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1,5% per month will be charged it payment is not received within 30 days. Nagin Gallop Figueredo P.A. Sub-total Expenses: 3,330.02 Payments 10,287.25 4/7/2008 Payment Check No. 61353 Sub-total Payments: 10,287.25 For Professional Services 30,845.00 For Disbursements Incurred 3,330.02 Current Balance: 34,175.02 Previous Balance: 10,287.25 Payments - Thank you 10,287.25 Total Due 34,175.02 Invoice Number: 19575 To be properly credited, please indicate Invoice Number above on your remittance check. Payment is due upon receipt. Please notify ' us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1.6%. per month will be charged if payment is not received within 30 days. Matter lb: 0022-182 Statement NO.: 19575 Page: 6 4/16i2008 Outside copy job -: Copies of Drawings - Reduced 32.10 4/16/2008 Mileage - Travel to Courthouse 17.61 4/17/2008 -Mileage - Travel to Greenberg Traurig 16.41 4/21/9008 Mileage - Courthouse for Pretrial Conference 17.61 4/21/2008 Tolls - Courthouse for Pretrial Conference 3.50 4/21/2008 Parking Charge - Courthouse for Pretrial Conference 3.75 4/24/2008 Photocopies for the month of April 2008. 662.25 4/25/2008 Postage Charge for the month of April 2008. 10.43 4/25/2008 Telefacsimile charge for the month of April 2008. 75.00 Sub-total Expenses: 3,330.02 Payments 10,287.25 4/7/2008 Payment Check No. 61353 Sub-total Payments: 10,287.25 For Professional Services 30,845.00 For Disbursements Incurred 3,330.02 Current Balance: 34,175.02 Previous Balance: 10,287.25 Payments - Thank you 10,287.25 Total Due 34,175.02 Invoice Number: 19575 To be properly credited, please indicate Invoice Number above on your remittance check. Payment is due upon receipt. Please notify ' us within 10 days of receipt of any questions you have regarding this invoice. Interest at a rate of 1.6%. per month will be charged if payment is not received within 30 days.