Res. No. 165-03-11715r T
RESOLUTIONNO. 165-03-11715
WHEREAS, the office of the city attorney, Nagin Gallop Figueredo, P.A.,
submitted invoices to the City for legal services rendered, and costs advanced, for
the period pending August 31. 2003, in the amount of $45,783,96; and,
WHEREAS, the city attorney requests the mayor and city commission to
aL[t]101'iZC the use of -funds in the cash reserve to pay the unfunded balance.
NOW THEREFORE BE IT RESOLVED BY THE MAYOR AND CITY
COMMISSION OFTHE CITY OF SOUTH MIAMI, FLORIDA:
Section 1. The use of cash reserve is authorized to pay the uuftindcd
total balance due for attorneys' fees and costs in the amount of $45,783,96.
Section 2. The Finance Director is directed to pay the balance due,
Section 3, This resolution shall take effect immediately upon approval,
PASSED AND ADOPTED this 16 thday of September, 2003.
CITY CLERK.
READ AND APPROVED AS TO FORM:
CITY ATTORNEY
A "TITI f- A TT- T •
\\02si-vplaNv\l)i-olaw\DoCL]jiieiits\0022\DAJ\19329.doc - Reso - N(J F' September 2003 Statements
Additions shown by underlinijig and deletions shown by iwe s 4kiii#.
i AGIN GALLOP FIGUEREDO'k
Attorneys Counselors
3225 Aviation Avenue - Third Floor
Telephone: (305) 854 -5353 Miami, Florida 33133 -4741 Facsimile: (305) 854 -5351
September 10, 2003
Hakeem Oshikoya
Finance Director
CITY OF SOUTH MIAMI
6130 Sunset Drive
South Miami, Florida 33143
Re: STATEMENTS FOR PROFESSIONAL SERVICES
City of South Miami
Dear Mr. Oshikoya:
Enclosed are our statements for professional services rendered and for costs advanced
for the period ending August 31, 2003, in the amount of $45,783.96, and requisition no. 155.
I have tabulated the amounts currently due on each individual file as follows:
0022 -027 Bruce v. CSM
Statement No. 14775 dated 09109103
0022 -095 Lazaro Tabares — EEOC Claim
Statement No. 14664 dated 09109103
0022 -101 Hampton Pre - Determination
Statement No. 14665 dated 09109103
0022 -113 Forfeiture of 1991 Nissan 300zx
Statement No. 14666 dated 09109103
Profl Services $ 15,841.00
Disbursements 2,036.47
Total Due 17,877.47
Prof 1 Services $ 60.00
Disbursements 15.17
Total Due 75.17
Prof 1 Services $ 52.50
Disbursements 0.00
Total Due 52.50
Prof 1 Services $ 180.00
Disbursements 12.00
Total Due 192.00
r I
Hakeem Oshikoya, Finance Director
CITY OF SOUTH MIAMI
September 10, 2003
Page 2 of 2
0022 -124 Maria Anduiza — EEOC Claim
Statement No. 14669 dated 09109103
0022 -128 Maria S. Anduiza v. City of South Miami
Statement No. 14672 dated 09109103
Prof 1 Services $ 70.00
Disbursements 0.00
Total Due 70.00
Prof 1 Services $ 262.50
Disbursements 9.75
Total Due 272.25
0022 -129 Mark Richman Properties v. City of South, Prof 1 Services $ 227.50
Miami Disbursements 492.37
Statement No. 14776 dated 09109103 Total Due 719.87
0022 -131 Dynabilt v. City of South Miami Profl Services $ 0.00
Statement No. 14675 dated 09109103 Disbursements 120.00
Total Due 120.00
0022 -136 Rosenbaum v. City of South Miami Profl Services $ 315.00
Statement No. 14679 dated 09109103 Disbursements 12.00
Total Due 327.00
0022 -140 TK Promotions v. City of South Miami Prof, 1 Services $ 25,383.75
Statement No. 14681 dated 09109103 Disbursements 693.95
Total Due 265077.70
CURRENT TOTAL DUE
$ 45,78196
Do not hesitate to call me if you have any questions regarding these statements.
Very truly yours,
Earl G. Gallop
EGG:daj
Enclosures
cc: Mayor and City Commission
CITY OF SOUTH MIAMI
6130 Sunset Drive, South Miami, Florida 33143
Vendor: NAGIN GALLOP & FIGUEREDO, P.A. Req. No. 155
Date: September 10, 2003
Finance Department
Item
No.
Quantity
Description and
Specifications
Account Number
Unit Price
Total
1
0
Real Estate /Foreclosure
1500 -514 -3435
0.00
0.00
2
8
Legal, Non - Retainer
1500 -514 -3410
27,714.49
27,714.49
3
1
Forfeitures
608 -1910- 521 -3100
192.00
192.00
4
1
Code Enforcement
1500 -514 -3452
17,877.47
17,877.47
TOTAL
545,783.96
Purchase Order No Terms /Discount
I Hereby Certify That The
Above Material, Equipment,
Or Service Is Essential And A
Proper Request Against The
Codes Charge
Head of Department
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
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FI GUEREDOP".
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Payments
08/13/2003 Payment Ck#41899
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -002
Real Estate & Contracts
Statement No. 14654
1,767.50
Sub -total Payments: 11767.50
For
Professional Services
0.00
days of receipt of any
For
Disbursements Incurred
0.00
of 1.5% per month will
Current Balance: 0.00
Previous Balance: 16,905.00
Payments - Thank you 11767.50
Total Due 15,137.50
To be properly credited, please indicate Statement Number 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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDOPA.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -003
Williamson Foreclosure
Statement No. 14655
Total Due
To be properly credited, please indicate Statement Number on your remittance check.
0.00
0.00
0.00
492.00
ce
492.00
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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDOP.A.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -023
Parking garage contract
Statement No. 14657
For Professional Services 0.00
For Disbursements Incurred 0.00
Current Balance: 0.00
Previous Balance: 70.00
Payments - Thank you 0.00
Total Due 70.00
To be properly credited, please indicate Statement Number 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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDO1'".
Attorneys & Counselors
3225 Aviation Avenue, Suite 301 Miami, Florida 33133
Telephone: (305) 854 -5353 Facsimile: (305) 854 -5351
September 9, 2003
Hakeem Oshikoya Matter ID: 0022 -027
Finance Director Bruce v. Code Enforcement
City of South Miami
6130 Sunset Drive Statement No. 14775
City of South Miami, FL 33143
Hours Amount
07/11/2003
EGG Attention to pre -trial preparation.
1.50 262.50
07/14/2003
EAB Analysis of docket sheet and identified documents to be pulled
0.30 52.50
month will
from docket.
30 days.
07/16/2003
JMP Retrieved copies of pleadings from Circuit Court.
1.00 20.00
07/18/2003
EGG Prepared status report to comm'n; reviewed file.
0.60 0.00
07/21/2003
EAB Analysis of defendant's pretrial compliance; drafted
2.50 437.50
correspondence to Comm'r McCrae, Mayor Feliu, Vice Mayor
Russell, Ms. Lama, Mr. Youkilis, Ms. Bynum; legal research on
defense of selective enforcement; drafted memorandum on
selective enforcement, and drafted letter to Mr. Lorenzen regarding
deposition of one of his employees and stipulations.
07/22/2003
EAB Analysis of Sgt. Rodriguez's surveillance, and vehicle issues;
2.00 350.00
telephone conference with Mr. Mike Spivack regarding trial
preparation; email communication with Ms. Bynum regarding
citations; legal research on motions in limine; and drafted letter to
our witnesses regarding upcoming trial date and availability.
07/24/2003
EAB Drafted motion in limine on issue of selective enforcement.
1.50 262.50
07/26/2003
EGG Final preparation of motion in limine to exclude any evidence or
0.30 52.50
argument relating to selective enforcement.
07/28/2003
EGG Telephone conference with Mr. Lorenzen regarding settlement
0.30 52.50
possibility and attention to further handling needs.
07/28/2003
EAB Finalized motion in limine, coordinated deposition date of Mr. Gary
0.40 70.00
Ward, witness identified by defendant.
07/29/2003
EAB Telephone conference with process server regarding opposing
0.40 70.00
counsel's refusal to accept service of process on behalf of their
witness, Mr. Ward; analysis of 12/20/02 court order; and drafted
letter to opposing counsel on intent to exclude Mr. Ward as witness
at trial.
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. CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -027 Statement No.: 14775 Page: 2
07/29/2003 JMP Filed notice of hearing at Circuit Court. 0.75 15.00
08/04/2003 EAB Began preparing exhibits for trial; organized trial book; telephone 0.50 87.50
conference with Mr. Walker regarding deposition testimony.
08/05/2003 EAB Telephone conference with vice -mayor Mary Scott Russell 0.20 35.00
regarding deposition preparation.
08/06/2003 EAB Drafted letter to Ms. Gillis regarding expiration of settlement 0.40 70.00
agreement; and coordinating rescheduling of vice mayor Russell's
deposition.
08/06/2003 EAB Legal research on protective orders and drafted protective order 2.00 350.00
for Mr. David Walker and vice mayor Mary Scott Russell.
08108/2003 EAB Telephone conference with Ms. Leslie Gillis regarding protective 0.20 35.00
order motions.
08/10/2003 EAB Trial preparation. 5.00 875.00
08/11/2003 EAB Witness preparation, meeting with Ms. Rosa, Mr. Walker; 5.00 875.00
telephone conferences with and drafted letters to witnesses
regarding deposition preparation, trial attendance, etc; completed
re- notice of deposition.
08/12/2003 EAB Analyzed code enforcement files on 6800 SW 64th Street; 7.00 11225.00
assisted Ms. Rosa in preparing index for file, and going over file
records, photographs and citations; trial preparation with Mr.
Struder, and Ms. Rosa; attempted trial preparation with U -Haul and
other third party expert witnesses; e-mail communication with vice
mayor russell.
08/13/2003 EGG Trial preparation. 1.50 262.50
08/13/2003 EAB Meeting with code enforcement and testifying officers to prepare 8.00 1,400.00
them for trial; meeting with vice mayor Russell to prepare her for
her deposition; continued working on trial brief; and interviewed
third party witnesses at U -Haul, Ford and Dodge.
08/14/2003 EAB Telephone conference with Mr. Solovsky regarding service of 5.00 875.00
subpoena; continued deposition preparation, witness preparation,
drafting trial brief; strategy with Mr. Gallop; telephone conference
with Ms. Rosa and Mr. Struder regarding bruce trial; continued
preparation of trial notebook.
08/15/2003 EAB Prepared witnesses for and attended depositions of vice mayor 8.00 1,400.00
Russell, Mr. Walker; canceled deposition of Mr. Gary Ward,
issued renotice of hearing; and attention to trial preparation.
08/15/2003 JMP Obtained original copy of pictures for 1/21,1/22,5/12. Made copies 2.00 40.00
of pics at Black Copy Service and returned original pics to David
Struger at CSM. Ronetta Taylor certified the copies, I then
returned them to NGF.
08/16/2003 EAB Drafted motion in limine regarding admissions and continued trial 5.00 875.00
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. CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -027 Statement No.: 14775 Page: 3
preparation; meeting with Mr. Bruce Solovsky in anticipation for
trial.
08/17/2003 EAB Continued trial preparation, revised trial brief, drafted questions for 9.00 11575.00
expert witnesses.
08/18/2003 EGG Attention to preparation to deposition of Mr. WArd and trial 0.30 52.50
strategy.
08/18/2003 EAB Attention to trial preparation; drafted correspondence to witnesses 1 0.00 11750.00
coordinating their testimony; prepared exhibits for trial; prepared
for and attended deposition of Mr. Ward; and continued to draft
opening statement.
08/18/2003 JMP Pick up certified copy of picture from Ronetta Taylor at CSM. 0.75 15.00
08/19/2003 EAB Attended meeting with Sgt. Ruben Rodriguez, Det. Michael 10.00 11750.00
Stroface to prepare them for trial; meeting with Officers Mr.
Struder, Ms. Carol Bynum, and Ms. Rosa to prepare them for trial;
and trial preparation.
08/19/2003
NDH
Reviewed and analyzed trial brief prepared by Ms. Boutsis;
2.00
350.00
hours
at
conferred Ms. Boutsis re: the same.
0.00
/hr .
08/20/2003
EGG
Attended trial; trial preparation for next day.
10.00
11750.00
08/20/2003
EAB
Attended trial, pre -trial preparation, and post first day of trial
14.00
21450.00
research, preparation, analysis of evidence and exhibits entered
Eve
A.
Boutsis
into the record.
hours
08/20/2003
NDH
Conferred with Ms. Boutsis re: trial and specifically failure to
1.00
175.00
respond to admissions; commenced research and analysis of case
law re: failure to repsond to admissions.
08/20/2003
NDH
Conferred with Mr. Gallop and Ms. Boutsis re: status of trial and
5.50
962.50
additional research to conduct; researched and analyzed case law
re: applicability of the declaratory judgment act; drafted
memorandum for Mr. Gallop re: the same.
08/21/2003
EGG
Prepared for and attended trial.
4.00
700.00
08/21/2003
EAB
Prepared for cross examination of witness, revised trial brief,
6.00
11050.00
prepared response to oral argument on availability of declaratory
action; attended final day of trial.
Rate Summary
Total Professional Services 22,630.00
Discount: - 61789.00
Earl
G.
Gallop
0.60
hours
at
$
0.00
/hr .
0.00
Earl
G.
Gallop
17.90
hours
at
$175.00/hr
31132.50
Eve
A.
Boutsis
102.40
hours
at
$175.00/hr
171920.00
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.
Expenses
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -027 Statement No.: 14775
Nakia D. Henry
Jennifer M. Penichet
8.50
hours
at
$175.001hr
Mileage
4.50
hours
at
$
20.00
/hr
Total hours: 133.90
Payments
08/13/2003 Payment Ck#41899
Sub -total Expenses:
Sub -total Payments:
1,487.50
90.00
116.50
130.48
31.25
9.00
176.55
120.00
24.61
58.00
250.90
48.15
58.00
74.90
58.00
58.00
164.13
600.00
58.00
21036.47
1,084.71
1,084.71
Page: 4
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.
Parking Charge
Legal research
Mileage
07/14/2003
Outside copy job
08/13/2003
Outside copy job
08/15/2003
Witness Fee
08/19/2003
Outside copy job
08/19/2003
Service of Process
08/19/2003
Court reporter
08/19/2003
Outside copy job
08/19/2003
Service of Process
08/19/2003
Outside copy job
08/19/2003
Service of Process
08/19/2003
Service of Process
08120/2003
Court reporter - Taken on July 22, 2003
08/21/2003
Court reporter
08/2812003
Service of Process
Payments
08/13/2003 Payment Ck#41899
Sub -total Expenses:
Sub -total Payments:
1,487.50
90.00
116.50
130.48
31.25
9.00
176.55
120.00
24.61
58.00
250.90
48.15
58.00
74.90
58.00
58.00
164.13
600.00
58.00
21036.47
1,084.71
1,084.71
Page: 4
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.
1 1
0 1
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -027 Statement No.: 14775 Page: 5
For
Professional Services
15,841.00
regarding this invoice. Interest at a rate of
For
Disbursements Incurred
21036.47
30 days.
Current Balance: 17,877.47
Previous Balance: 21084.71
Payments - Thank you 11084.71
Total Due 18,877.47
To be properly credited, please indicate Statement Number 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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDO PA.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID-. 0022 -055
Purchase of 7800 SW 59th
Statement No. 14660
For
Professional Services
0.00
questions you have
For
Disbursements Incurred
0.00
be charged if payment is
Current Balance: 0.00
Previous Balance: 157.50
Payments - Thank you 0.00
Total Due 157.50
To be properly credited, please indicate Statement Number 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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDOP.A.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Payments
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -061
NRA, et al. vs. City of South
Statement No. 14661
08104/2003 Payment Ck#41772 297.50
08/13/2003 Payment Ck#41899 437.50
Sub -total Payments: 735.00
For Professional Services 0.00
For Disbursements Incurred 0.00
Current Balance: 0.00
Previous Balance: 770.00
Payments - Thank you 735.00
Total Due 35.00
To be properly credited, please indicate Statement Number 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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDOP.A.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Payments
08/04/2003
Payment Ck#41772
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -083
Planning Board
Statement No. 14662
700.00
Sub -total Payments:
Total Due
700.00
To be properly credited, please indicate Statement Number on your remittance check.
0.00
0.00
0.00
1,995.00
700.00
1,295.00
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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDOP".
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -095
Lazaro D. Tabares - EEOC
Statement No. 14664
Hours
08/14/2003 EAB Telephone conference with Mr. McDuff regarding plaintiffs request 0.40
to admit new evidence; coordinated delivery of supporting
documentation and provided information to Mr. McDuff per his
request.
Rate Summary
Expenses
08/26/2003
Payments
08/04/2003
09/03/2003
Eve A. Boutsis
Total hours:
Federal express
Total Professional Services
0.40 hours at $150.00 /hr
,� ,
Sub -total Expenses:
Payment Ck#41772
Payment Ck#42035($6,149.95)
Sub -total Payments:
60.00
15.17
15.17
30.19
270.00
300.19
Amount
60.00
60.00
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.
I I 1 0 1 1
Nagin Gallop Figueredo P.A. CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -095 Statement No.: 14664 Page: 2
For Professional Services 60.00
For Disbursements Incurred 15.17
Current Balance: 75.17
Previous Balance: 660.19
Payments - Thank you 300.19
Total Due 435.17
To be properly credited, please indicate Statement Number 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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP P.A.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -101
Hampton Pre - Determination
Statement No. 14665
Hours
08/19/2003 EAB Drafted letter to AAA canceling arbitration. 0.30
Total Professional Services
Rate Summary
Eve A. Boutsis 0.30 hours at $175.00/hr 52.50
Total hours: 0.30
Payments
08/04/2003 Payment Ck#41772 105.00
09103/2003 Payment Ck#42035($6,149.95) 297.50
Sub -total Payments: 402.50
Amount
52.50
52.50
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
of
1.5% per
month will
be charged if payment is
not received within
30 days.
Nagin Gallop Figueredo P.A. CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -101 Statement No.: 14665 Page: 2
For
Professional Services
52.50
days of receipt of any
For
Disbursements Incurred
0.00
month will
Current Balance:
52.50
Previous Balance: 402.50
Payments - Thank you 402.50
Total Due 52.50
To be properly credited, please indicate Statement Number 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
e
r 3
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDO P.A.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
08/14/2003
Rate Summary
Expenses
Payments
09/03/2003
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -113
Forfeiture of 1991 Nissan 300zx
Statement No. 14666
Hours
EAB Prepared for and attended hearing on motion for final default 1.80
judgment.
Total Professional Services
Eve A. Boutsis 1.80 hours at $100.00 /hr 180.00
Total hours:
Parking Charge
1.80
Sub -total Expenses:
Payment Ck#42035($6,149.95)
Sub -total Payments:
12.00
12.00
443.50
443.50
Amount
180.00
180.00
Payment is due upon receipt. Please notify us within
10
days of receipt of any
questions you have
e
r 3
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDO P.A.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
08/14/2003
Rate Summary
Expenses
Payments
09/03/2003
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -113
Forfeiture of 1991 Nissan 300zx
Statement No. 14666
Hours
EAB Prepared for and attended hearing on motion for final default 1.80
judgment.
Total Professional Services
Eve A. Boutsis 1.80 hours at $100.00 /hr 180.00
Total hours:
Parking Charge
1.80
Sub -total Expenses:
Payment Ck#42035($6,149.95)
Sub -total Payments:
12.00
12.00
443.50
443.50
Amount
180.00
180.00
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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -113 Statement No.: 14666 Page: 2
For Professional Services 180.00
For Disbursements Incurred 12.00
Current Balance: 192.00
Previous Balance: 593.50
Payments - Thank you 443.50
Total Due 342.00
To be properly credited, please indicate Statement Number 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.
a
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDOP.A.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -123
Labor - PBA Police Lieutenants
Statement No. 14668
Total Due
To be properly credited, please indicate Statement Number on your remittance check.
0.00
0.00
0.00
35.00
0.00
35.00
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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDO PA.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -124
Maria Anduiza EEOC Claim
Statement No. 14669
Hours
08/06/2003 EAB Received and analyzed no cause determination by FCHR and 0.40
issued public record request for all documents submitted to FCHR
by Ms. Anduiza, including her affidavit.
Rate Summary
Total Professional Services
Eve A. Boutsis 0.40 hours at $175.00/hr 70.00
Total hours: 0.40
Payments
08/04/2003 Payment Ck#41772 21701.21
Sub -total Payments: 21701.21
Amount
70.00
70.00
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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022424 Statement No.: 14669 Page: 2
For
Professional Services
70.00
days of receipt of any
For
Disbursements Incurred
0.00
of 1.5% per month will
Current Balance:
70.00
Previous Balance: 51919.95
Payments - Thank you 21701.21
Total Due 31288.74
To be properly credited, please indicate Statement Number 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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDOP.A..
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Payments
08/04/2003 Payment Ck#41772
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -125
John Hampton EEOC Claim
Statement No. 14670
135.74
Sub -total Payments: 135.74
For Professional Services 0.00
For Disbursements Incurred 0.00
Current Balance: 0.00
Previous Balance: 11220.74
Payments - Thank you 135.74
Total Due 11085.00
To be properly credited, please indicate Statement Number 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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDO PA.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Payments
08/0412003 Payment Ck#41772
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -126
Deborah Benfield EEOC Claim
Statement No. 14671
375.44
Sub -total Payments:
Total Due
375.44
To be properly credited, please indicate Statement Number on your remittance check.
0.00
us within
0.00
days of receipt of any
questions you have
regarding this invoice. Interest at a
0.00
month will
602.94
charged if payment is
375.44
30 days.
227.50
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 of 1.5% per
month will
be
charged if payment is
not received within
30 days.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDOP.A.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
08/28/2003
Rate Summary
Expenses
08/13/2003
Payments
08/04/2003
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -128
Maria S. Anduiza v. City of
Statement No. 14672
Hours
EAB Began drafting motion for summary judgment. 1.50
Total Professional Services
Eve A. Boutsis 1.50 hours at $175.00/hr 262.50
Total hours:
Outside copy job
Payment Ck#41772
1.50
9.75
Sub -total Expenses: 9.75
5,970.00
Sub -total Payments: 51970.00
Amount
262.50
262.50
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 of 1.5%
per
month will
be
charged
if payment is
not received within
30 days.
Nagin Gallop Figueredo P.A. CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -128 Statement No.: 14672 Page: 2
For Professional Services 262.50
For Disbursements Incurred 9.75
Current Balance:
27225
Previous Balance: 21,061.61
Payments - Thank you 51970.00
Total Due 151363.86
To be properly credited, please indicate Statement Number 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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDORA.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -129
Mark Richman Properties v. City
Statement No. 14776
Hours Amount
08/04/2003 LRF Teleconference with Mr. McArdle. 0.30 52.50
08/1812003 EGG Reviewed deft's discovery requests. 1.00 175.00
Total Professional Services 227.50
Rate Summary
Earl G. Gallop 1.00 hours at $175.00/hr 175.00
Expenses
08/20/2003
Payments
09/03/2003
Luis R. Figueredo 0.30 hours at $175.00/hr
Total hours: 1.30
Court reporter - Taken on July 22, 2003
Sub -total Expenses:
Payment Ck#42035($6,149.95)
Sub -total Payments
52.50
492.37
492.37
297.50
297.50
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 of
1.5% per
month will
be charged if payment is not received within
30 days.
Nagin Gallop Figueredo P.A.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -129 Statement No.: 14776
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Total Due
To be properly credited, please indicate Statement Number on your remittance check.
Page: 2
227.50
492.37
719.87
5,915.00
297.50
6,337.37
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.
6
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDOP.A.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Payments
08/04/2003
Payment Ck#41772
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -130
OPEIU v. City of South Miami
Statement No. 14674
Sub -total Payments:
Total Due
87.50
87.50
To be properly credited, please indicate Statement Number on your remittance check.
0.00
0.00
0.00
560.00
87.50
472.50
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
of 1.5% per
month will
be
charged if payment is
not received within
30 days.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDO PA.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Expenses
08/28/2003 Service of Process
Payments
08/04/2003 Payment
For Professional Services
.C%N
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -131
Dynabilt v. City of South Miami
Statement No. 14675
120.00
Sub -total Expenses: 120.00
735.00
Sub -total Payments: 735.00
Total Due
To be properly credited, please indicate Statement Number on your remittance check.
&I i
120.00
120.00
1,498.90
735.00
883.90
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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDOP.A.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Payments
08/04/2003
Payment Ck#41772
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -132
Jeffrey Griffin Arbitration
Statement No. 14676
297.50
Sub -total Payments: 297.50
For Professional Services 0.00
For Disbursements Incurred 0.00
Current Balance: 0.00
Previous Balance: 700.00
Payments - Thank you 297.50
Total Due 402.50
To be properly credited, please indicate Statement Number 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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDOP.A.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Payments
08/04/2003 Payment Ck#41772
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -133
Max Valdes Arbitration
Statement No. 14677
630.00
Sub -total Payments:
Total Due
630.00
To be properly credited, please indicate Statement Number on your remittance check.
0.00
0.00
0.00
980.00
630.00
350.00
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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDOP.A.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -136
Rosenbaum v. CSM
Statement No. 14679
Hours
08/01/2003 EAB Drafted correspondence to Mr. Shubin's partner regarding proposed 0.40
hearing date and protective order motion.
08/04/2003 EAB E -mail communication with Mr. Sandy Youkilis and telephone 0.30
conference with Mr. Mario Garcia -Serra of Greenberg Traurig
regarding discovery issues.
08/13/2003 EGG Attention to further handling needs. 0.30
08/18/2003
08/28/2003
Rate Summary
Expenses
EGG Reviewed plaintiffs motion for default against various defendants, 0.50
inclucing city of South Miami, and motion for default judgment on
count V, public records act claim; reviewed correspondence
between parties; telephone conference with Mr. Ricard Lorber to
schedule appointment to review response to public recods request
and to discuss case.
EAB Discussion with Mr. Gallop regarding litigation issues. 0.30
Total Professional Services
Earl G. Gallop 0.80 hours at $175.00/hr 140.00
Eve A. Boutsis
Total hours:
Parking Charge
1.00 hours at $175.00/hr 175.00
1.80
12.00
Sub -total Expenses: 12.00
Amount
70.00
52.50
52.50
87.50
52.50
315.00
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. CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -136 Statement No.: 14679 Page: 2
For Professional Services 315.00
For Disbursements Incurred 12.00
Current Balance: 327.00
Previous Balance: 31400.75
Payments - Thank you 0.00
Total Due 31727.75
To be properly credited, please indicate Statement Number 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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDOPA.
Attorneys & Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments "Thank you
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -138
U.S. Bank Nat'l Assoc. v. CSM,
Statement No. 14680
Total Due
To be properly credited, please indicate Statement Number on your remittance check.
0.00
0.00
0.00
61.25
0.00
61.25
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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
NAGIN GALLOP FIGUEREDOP. A.
Attorneys Fa Counselors
3225 Aviation Avenue, Suite 301
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Miami, Florida 33133
Facsimile: (305) 854 -5351
September 9, 2003
Matter ID: 0022 -140
TK Promotions v. City of South
Statement No. 14681
Hours Amount
08/05/2003 EAB Telephone conference with Mr. Sandy Youkilis regarding "Booby 3.00 525.00
Trap" and adult entertainment caselaw; analysis of BMS parking
agreement; telephone conference with mayor Feliu, vice -mayor
Russell, Comm'r McCrea in anticipation of comm'n agenda and
meeting; drafted affidavit regarding July 8, 2003 P &Z meeting;
telephone conference with Ms. Davis regarding first amendment
and Booby Trap sign application; telephone conference with Mr.
Youkilis regarding parking lease issues and rejection of short term
lease.
08/07/2003 EAB Legal research on state statutes prohibiting adult entertainment 2.50 437.50
establishments within 2,500 feet of a school; telephone
conferences with Mr. Youkilis regarding JRE Lee school location;
inspected area and mapped out mileage from JRE Lee to Steel
location, analysis of occupational license issues; telephone
conference with concerned residents regarding their request for
mandamus and offer to indemnification the city etc.
08/08/2003 EAB Analysis of draft letter by Mr. Youkilis to Booby Trap, and analysis 0.20 35.00
of 2,500 foot map from JRE Lee School.
08113/2003 EGG Attention to legal issues concerning establishment of adult 1.50 262.50
entertainment use; conferred with Mr. Figueredo; telephone
conferences with Ms. Davis and Mr. Youkilis.
08/13/2003 EAB Legal research for other municipal codes on adult entertainment. 0.40 70.00
08/14/2003 EGG Analyzed adult entertainment statutes; telephone conferences with 3.40 595.00
mayor Feliu and comm'r. Wiscombe; attended meeting with Mr.
Aronson, counsel for establishment and considered fact and legal
arguments regarding lawfulness of adult entertainment use; began
analyzing federal decisional authorities regarding limitation on city
powers to prohibit or limit use.
08/15/2003 EGG Attended meeting with Mr. Aronson, counsel for TK Promotions, 1.00 175.00
Inc. regarding legal defenses to enforcement of sec. 847.0134.
08/15/2003
EAB Legal research per vice
mayor Russell's
request on Leon County 1.00 175.00
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. CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022A40 Statement No.: 14681 Page: 2
and Tallahassee adult entertainment ordinances and litigation.
08/15/2003 EAB Attention to adult entertainment statutes, case law and telephone 0.50 87.50
conference with crimes investigation unit of state attorney's office.
08/18/2003 EGG Reviewed federal decisional authorities and prepared memorandum 4.50 787.50
regarding recommendations for handling adult entertainment
matter; attended meeting with mayor Feliu, Ms. Davis, chief
Watson, det. Robinson and Mr. Youkilis and provided legal advice
and recommendations for handling matter; directed chief Watson
and det. Robinson to not make arrests.
08/19/2003 EGG Telephone conferences with mayor and all comm'rs regarding adult 6.00 11050.00
entertainment and other matters; attended meeting with ass't. state
attorneys regarding prosecution of criminal violation for operating
adult establishment and lewd and lascivious behavior; additional
review of decisional authorities.
08/20/2003 NDH Researched and analyzed case law re: examples of zoning 6.20 11085.00
regulations that are similar to South Miami zoning regulation;
powers of municipalities, including deference in drafting zoning
regulations, general rules of law to uphold a zoning regulation, and
challenge to the constitutionality of the zoning regulation.
08/2112003
EGG Attention to building permit issues for adult entertainment
3.00 525.00
days of receipt of any
establishment; advised against seeking injunction concerning
regarding this invoice. Interest at a
rate of 1.5% per
unpermitted partition in bathroom. telephone conference with Ms.
be
charged if payment is
Davis, Ms. Lama, Mr. Martinez regarding outstanding permits;
30 days.
telephone conference with ASA Nozick and det. Wagner regarding
policing operation; attention to federal injunction law suit.
08/21/2003
EGG Analyzed emergency motion for temporary restraining order.
1.20 210.00
08/21/2003
EAB Legal research on nonconforming uses and adult entertainment.
4.00 700.00
08/21/2003
NDH Completed research re: examples of zoning regulations that are
5.50 962.50
similar to South Miami zoning regulation; powers of municipalities,
including deference in drafting zoning regulations, general rules of
law to uphold a zoning regulation, and challenge to the
constitutionality of the zoning regulation; drafted memorandum re:
the same.
08/22/2003 EGG Analyzed complaint for preliminary and permanent injunction and 6.00 13050.00
declaratory judgment; prepared for and attended hearing with judge
Gold; reviewed order denying motion for temporary restraining
order; reviewed order and briefing schedule of motion for preliminary
injunction; commenced trial preparation.
08/23/2003 EGG Prepared for trial; telephone conference with Mr. Rogow. 7.00 11225.00
08/23/2003 EAB Legal research on first amendment issues; preliminary injunction; 12.00 21100.00
prior restraint; nonconforming uses; zoning restrictions; etc;
telephone conference with Mr. Youkilis, Comm'r McCrae, Ms.
Davis, Ms. Taylor, Mr. Basu, Vice Mayor Russell
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.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -140 Statement No.: 14681
Page: 3
08/24/2003 EGG
Prepared comprehensive memorandum in opposition to plaintiffs
8.00 11400.00
10 days of receipt of any
motion for preliminary injunction; telephone conferences with mayor
regarding this invoice. Interest at a
rate
Feliu, vice mayor Russell, and comm'rs. and received authorization
month will
be charged if payment is
to engage Mr. Bruce Rogow as special counsel; attention to
30 days.
evidence; analyzed decisional authorities.
08/24/2003 EAB
Legal research on preliminary injunction standard, facts needed to
12.00 21100.00
prove each of four elements; telephone conference with Mr.
Oshikoya regarding occupational licenses; email communications
with staff in anticipation of litigation; telephone conference with Mr.
Subrata Basu regarding zoning issues; continued legal research on
First Amendment prior restraint, time, place and manner
restrictions, and case law cited by plaintiff; and prepared
memorandum to file.
08/24/2003 NDH
Completed research and analysis of case law re: the proper
5.75 11006.25
measurement standard for Section 893.13, Fla. Stat. (1991).
08/25/2003 EGG
Telephone conference with Mr. Charlie Johnson regarding
7.40 11295.00
intervention by state attorney and providing affidavit that plaintiff was
advised that SA will not prosecute until certain legal issues are
resolved; attention to affidavits and other evidence; telephone
conference with Mr. Aaronson about possible stipulation and
voluntary withdrawal of motion for injunction; telephone conference
with Mr. Limeaux, Deputy Attorney General, regarding intervention
by AG; attention to further handling needs; prepared affidavits and
comprehensive memorandum for filing.
08/25/2003 EAB
Meeting with staff at city hall and delegated evidentiary
15.00 2,625.00
assignments; began compiling exhibits; drafted affidavits for Ms.
Taylor, Mr. Basu, Mr. YOukilis, Mr. Oshikoya, Sgt. Rodriguez, Det.
Stroface, Capt. Feldman, Lt. Salerno; telephone conferences with
all affiants in order to draft affidavits; and continued legal research.
08/25/2003 NDH
Drafted and completed proper measurement standard
3.50 612.50
memorandum for Mr. Gallop
08/25/2003 NDH
Researched and analyzed case law re: judicial notice; drafted and
2.00 350.00
prepared judicial notice memorandum
08/26/2003 EGG
Telephone conferences with Kathleen Von Hoene, ass't. attorney
8.40 11470.00
general, George LeMieux, deputy ass't. attorney general, Charles
Johnson, chief, organized crime unit, regarding intervention of
Attorney General and State Attorney in proceeding; prepared
opening statement; final preparation of witness and exhibit list;
prepared affidavits of witnesses; prepared Rule 11 letter; attended
meeting with opposing counsel and demanded withdrawal of
complaint and motion for preliminary injunction; attended
conference with judge Gold; attended attorney - client meeting.
08/26/2003 EAB
Finalized exhibits; telephone conference with FPL and WASD;
8.00 11400.00
attended deposition of Lt. Dan Salerno; meeting with Sgt.
Rodriguez and Det. Stroface and revised their affidavits; telephone
conference with Ms. Davis, Mr. YOukilis, Mr. Oshikoya, Capt.
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. CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -140 Statement No.: 14681 Page: 4
Feldman, Ms. Taylor regarding exhibits; assisted in revising
nonconforming use memorandum.
08/27/2003 EGG Analyzed recent federal judicial authorities regarding time, place 1.00 175.00
and manner restrictions on adult nude dancing cabarets.
08/27/2003 EAB Telephone conference with witnesses (Ms. Davis, Mr. Youkilis, 1.50 262.50
Capt. Feldman, Lt. Salerno, Mr. Oshikoya, Mr. Basu, Mayor Feliu,
etc.) informing them that hearing was canceled, provided update.
08/28/2003 EGG E -mail to commis. in response to constituent inquiry. 0.20 35.00
08/28/2003 EGG Analyzed amended complaint, with particular attention to 2.10 367.50
constitutional claims; telephone conference with Mr. C. Johnson,
ASA, calls to Ms. Kathryn Fernandez Rundell, State Attorney, Mr.
George Limueux, Deputy Attorney General, and Mr. Bruce Rogow.
08/28/2003 EAB Attended meeting with ATF representatives. 0.30 52.50
08/28/2003 EAB Telephone conference with Mr. David Hope, county attorney, 0.30 52.50
regarding adult entertainment ordinance.
08/29/2003 EGG Responded to e-mail about handling of case; telephone conference 0.70 122.50
with comm'r. McCrea regarding litigation strategy and further
handling needs; telephone conference with Bruce Rogow.
Rate Summary
Expenses
Total Professional Services
Earl G. Gallop 61.40 hours at $175.00/hr 10,745.00
Eve A. Boutsis 60.70 hours at $175.00/hr 10,622.50
Nakia D. Henry 22.95 hours at $175.00/hr 41016.25
Total hours: 145.05
Parking Charge
08/25/2003 Service of Process - Four Parties - TWN,
FPL, Miami -Dade Water Sewer, Miami
News Times
08/26/2003 Court reporter
08/26/2003 Court reporter
08/28/2003 Outside copy job
13.25
409.00
83.70
161.25
26.75
25,383.75
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.
c
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -140 Statement No.: 14681 Page: 5
Sub -total Expenses: 693.95
For
Professional Services
251383.75
10
For
Disbursements Incurred
693.95
rate
Current Balance: 26,077.70
Previous Balance: 0.00
Payments - Thank you 0.00
Total Due 26,077.70
To be properly credited, please indicate Statement Number 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
0
NAGIN GALLOP FIGUEREDOP `
Attoriaeys 6- Counselors
3225 Aviation Avenue - Third Floor
Telephone: (305) 854 -5353
Hakeem Oshikoya
Finance Director
CITY OF SOUTH MIAMI
6130 Sunset Drive
South Miami, Florida 33143
Miami, Florida 33133 -4741
September 10, 2003
Facsimile: (305) 854 -5351
Re: STATEMENTS FOR PROFESSIONAL SERVICES
City of South Miami
Dear Mr. Oshikoya:
Enclosed are our statements for professional services rendered and for costs advanced
for the period ending August 31, 2003, in the amount of $45,783.96, and requisition no. 155.
I have tabulated the amounts currently due on each individual file as follows:
0022 -027 Bruce v. CSM Prof 1 Services $ 15,841.00
Statement No. 14775 dated 09109103 Disbursements 2,036.47
Total Due 17,877.47
0022 -095 Lazaro Tabares — EEOC Claim Prof 1 Services $ 60.00
Statement No. 14664 dated 09109103 Disbursements 15.17
Total Due 75.17
0022 -101 Hampton Pre - Determination Prof 1 Services $ 52.50
Statement No. 14665 dated 09109103 Disbursements 0.00
Total Due 52.50
0022 -113 Forfeiture of 1991 Nissan 300zx Prof l Services $ 180.00
Ktnto7110 r'7 t Nn l J666i rintod 09/09/() 3 Dishirroements 12.00