Res. No. 183-03-11733k
C
RESOLUTION NO. 183-03-11733
A RESOLUTION OF THE MAYOR AND CITY COMMISSION
OF THE CITY OF SOUTH MIAMI, FLORIDA, RELATING TO
ATTORNEYS' FEES; APPROVING ATTORNEYS' FEES FOR
NAGIN GALLOP FIGUEREDO, P.A. IN THE AMOUNT OF
$23,911.24; CHARGING $770.28 TO ACCOUNT NO. 1500 -514-
3435, REAL PROPERTY /FORECLOSURE; CHARGING
$20,440.69 TO ACCOUNT NO, 1500 -514 -3410, LEGAL
SERVICES, NON - RETAINER; CHARGING $8.00 TO ACCOUNT
NO. 615 - 1910 -521 -3100, PROFESSIONAL SERVICES,
FORFEITURES; AND CHARGING $2,692.27 TO ACCOUNT
NO, 1500 -514 -3452, CODE ENFORCEMENT; PROVIDING AN
EFFECTIVE DATE.
WHEREAS, the City Commission of the City of South Miami approved
Resolution No. 99 -94 -9500, as amended by Resolution No. 217 -97- 10187,
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
September 30, 2003, in the amount of $23,911.24; and,
WHEREAS, the City Attorney recommends payment of the attached
invoices.
NOW THEREFORE BE IT RESOLVED BY THE MAYOR AND CITY
COMMISSION OF THE CITY OF SOUTH MIAMI, FLORIDA:
Section 1. The invoices for attorneys' fees and
Nagin Gallop Figueredo, P.A., in the total amount of $23,91
payment and charging $770.28 to account no.
estate /foreclosure; charging $20,440.69 to account no. 1500
retainer; charging $8.00 to account no. 615- 1910 -521 -3100,
forfeitures; and charging $2,692.27 to account no.
enforcement.
Section 2.
costs received from
1.24, are approved for
1500 -514 -3435, real
-514 -3410, legal, non-
professional services,
1500-514-3452, code
This resolution shall take effect immediately upon approval.
Additions shown by underlining and deletions shown by ovel-StF�ni;kiii .
PASSED AND ADOPTED this 21 stday of October, 2003.
ATTEST:
PY C 71E, R K
READ AND APPROVED AS TO FORM:
CITY ATTORNEY
A 'DD-D "I TU TA .
COMMISSION VOTE:
4-0
Mayor Feliu:
Yea
Vice Mayor Russell:
Yea
Commissioner Wiscombe:
Yea
Commissioner Bethel:
Yea
Commissioner McCrea: out
of room
\\02srvplaw\pi-olaw\Documeiits\0022\DAJ\19617.doc -Reno - NGF October Non- Retainer Statements
Telephone: (305) 854 -5353
A
NAGIN GALLOP FIGUEREDOIA.
Attorneys & Counselors
3225 Aviation Avenue - Third Floor
Miami, Florida 33133 -4741
October 10, 2003
Hakeem Oshikoya
Finance Director
CITY OF SOUTH MIAMI
6130 Sunset Drive
South Miami, Florida 33143
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 September 30, 2003, in the amount of $23,911.24, and requisition no. 2,
FY 2003 -04. I have tabulated the amounts currently due on each individual file as follows:
0022 -002 Real Estate & Contracts
Statement No. 14811 dated 10109103
0022 -027 Bruce v. CSM
Statement No. 14805 dated 10109103
0022 -046 Merrick v. City of South Miami
Statement No. 14815 dated 10109103
0022 -083 Planning Board
Statement No. 14818 dated 10109103
Prof 1 Services $ 175.00
Disbursements 595.28
Total Due 770.28
Prof 1 Services $ 2,712.50
Disbursements -20.23
Total Due 25692.27
Prof l Services $ 37.50
Disbursements 0.00
Total Due 37.50
Prof 1 Services $ 665.00
Disbursements 0.00
Total Due 665.00
1
Hakeem Oshikoya, Finance Director
CITY OF SOUTH MIAMI
October 10, 2003
Page 2 of 3
0022 -095 Lazaro Tabares — EEOC Prof 1 Services $ 45.00
Statement No. 14819 dated 10109103 Disbursements 0.00
Total Due 45.00
0022 -113 Forfeiture of 1991 Nissan 300zx Prof 1 Services $ 0.00
Statement No. 14821 dated 10109103 Disbursements 8.00
Total Due 8.00
0022 -128 Maria S. Anduiza v. City of South Miami Prof 1 Services $ 175.00
Statement No. 14826 dated 10109103 Disbursements 0.00
Total Due 175.00
0022 -129 Mark Richman Properties v. City of South Profl Services $ 3,675.00
Miami Disbursements 6.00
Statement No. 14827 dated 10109103 Total Due 35681.00
0022 -136 Rosenbaum v. City of South Miami Profl Services $ 647.50
Statement No. 14832 dated 10109103 Disbursements 0.00
Total Due 647.50
0022 -137 Special Master Hearings Prof 1 Services $ 700.00
Statement No. 14833 dated 10109103 Disbursements 0.00
Total Due 700.00
0022 -139 Hampton v. City of South Miami Prof 1 Services $ 52.50
Statement No. 14835 dated 10109103 Disbursements 0.00
Total Due 52.50
0022 -140 TK Promotions v. City of South Miami Prof 1 Services $ 14,882.50
Statement No. 14836 dated 10109103 Disbursements 307.94
Total Due 13,702.19
0022 -141 Gregory Feldman v. City of South Miami Prof 1 Services $ 735.00
Statement No. 14837 dated 10109103 Disbursements 0.00
Total Due 735.00
CURRENT TOTAL DUE $ 23,911.24
Hakeem Oshikoya, Finance Director
CITY OF SOUTH MIAMI
October 10, 2003
Page 3 of 3
Do not hesitate to call me if you have any questions regarding these statements.
Very truly yours,
I G�II�2-
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. 2, FY 2003 -04
Date: October 10, 2003
Finance Department
Item
No.
Quantity
Description and
Specifications
Account Number
Unit Price
Total
1
1
Real Estate /Foreclosure
1500 -514 -3435
770.28
770.28
2
10
Legal, Non - Retainer
1500 -514 -3410
205440.69
20,440.69
3
1
Forfeitures
608 - 1910 -521 -3100
8.00
8.00
4
1
Code Enforcement
1500 -514 -3452
25692.27
2,692.27
TOTAL
$23991114
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 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
Miami, Florida 33133
Facsimile: (305) 854 -5351
October 9, 2003
Matter ID: 0022 -002
Real Estate & Contracts
Statement No. 14811
Hours Amount
09/30/2003 EAB Began revising affidavit as to compliance with parking requirements 1.00 175.00
for off -site parking; and email communications with Mr. Youkilis
regarding this matter.
Rate Summary
Expenses
Total Professional Services 175.00
Eve A. Boutsis 1.00 hours at $175.00/hr 175.00
Total hours: 1.00
Legal research 595.28
Sub -total Expenses: 595.28
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 -002 Statement No.: 14811 Page: 2
For
Professional Services
,
days of receipt of any
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -002 Statement No.: 14811 Page: 2
For
Professional Services
175.00
days of receipt of any
For
Disbursements Incurred
595.28
month will
Current Balance: 770.28
Previous Balance: 15,137.50
Payments - Thank you 0.00
Total Due 151907.78
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
October 9, 2003
Matter ID: 0022 -003
Williamson Foreclosure
Statement No. 14812
For Professional Services 0.00
For Disbursements Incurred 0.00
Current Balance:
0.00
Previous Balance: 492.00
Payments - Thank you 0.00
Total Due 492.00
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 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
October 1, 2003
Matter ID: 0022 -027
Bruce v. Code Enforcement
Statement No. 14805
Eve A. Boutsis 14.50 hours at $175.00/hr 21537.50
Total hours: 15.50
Amount
175.00
210.00
350.00
787.50
875.00
70.00
245.00
21712.50
Payment is due upon receipt. Please notify
us within
Hours
09/22/2003 EGG
Analyzed final declaratory judgment order.
1.00
09122/2003 EAB
Attention to Bruce final declaratory judgment order; and provided
1.20
charged if payment is
update to client and staff.
30 days.
09/24/2003 EAB
Legal research on contract prevailing party attorney's fees award;
2.00
prepared memorandum to file; conducted property appraisal
investigation; and drafted communication to Mr. Dirk Lorenzen
regarding 10-day compliance period under Judge King's final
declaratory judgment ruling.
09/25/2003 EAB
Legal research on entitlement to fees and what is a reasonable fee;
4.50
analysis of billing and prepared memorandum on this item.
09/29/2003 EAB
Drafted motion for attorney's fees, affidavits in support of fees for
5.00
Ms. Boutsis, Mr. Gallop and Mr. Dellagloria; and analyzed billing.
09/30/2003 EAB
Analysis of photographs taken by Mr. Struder and drafted
0.40
noncompliance letter to Mr. Lorenzen; and telephone conference
with Mr. Lorenzen regarding his client's request for re- hearing.
09/30/2003 EAB
Legal research on collection of costs pursuant to Uniform
1.40
Guidelines on Taxation of Costs; and drafted memorandum to file.
Total Professional Services
Rate Summary
Earl G.
Gallop 1.00 hours at $175.00/hr 175.00
Eve A. Boutsis 14.50 hours at $175.00/hr 21537.50
Total hours: 15.50
Amount
175.00
210.00
350.00
787.50
875.00
70.00
245.00
21712.50
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.
0
i
Nagin Gallop Figueredo P.A. CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -027 Statement No.: 14805 Page: 2
Expenses
Courier charge 37.77
09/30/2003 Service of Process -58.00
Sub -total Expenses: -20.23
Payments
10/07/2003 Payment Ck#42638 171877.47
Sub -total Payments: 171877.47
For Professional Services 21712.50
For Disbursements Incurred -20.23
Current Balance: 21692.27
Previous Balance: 187877.47
Payments - Thank you 171877.47
Total Due 31692.27
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
Miami, Florida 33133
Facsimile: (305) 854 -5351
October 9, 2003
Matter ID: 0022 -046
Merrick v. City of South Miami
Statement No. 14815
Hours Amount
09/19/2003 EAB Received FDLE report and issued letter to Mr. Parsons confirming 0.30 37.50
change in FDLE report.
Total Professional Services 37.50
Rate Summary
Eve A. Boutsis 0.30 hours at $125.00/hr 37.50
Total hours: 0.30
For
Professional Services
37.50
10
For
Disbursements Incurred
0.00
rate
Current Balance: 37.50
Previous Balance: 0.00
Payments - Thank you 0.00
Total Due 37.50
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 FI GUERE D OP.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
09/24/2003
Payment Ck#42286 ($20,561.30)
Miami, Florida 33133
Facsimile: (305) 854 -5351
October 9, 2003
Matter ID: 0022 -055
Purchase of 7800 SW 59th
Sub -total Payments
Statement No. 14816
105.00
105.00
For Professional Services 0.00
For Disbursements Incurred 0.00
Current Balance:
0.00
Previous Balance: 157.50
Payments - Thank you 105.00
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.
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
October 9, 2003
Matter ID: 0022 -083
Planning Board
Statement No. 14818
Hours Amount
08/26/2003 LRF Reviewed planning director's report concerning Epiphany; 1.80 315.00
conference with Mr. Gallop; prepared response to City Manager;
and teleconference with Maria Davis regarding same.
09/08/2003 LRF Reviewed various memos from Mr. Youkilis; reviewed land 2.00 350.00
development code; and responded to several inquiries from staff.
Total Professional Services 665.00
Rate Summary
Luis R. Figueredo 3.80 hours at $175.00/hr 665.00
Total hours: 3.80
Payments
09/24/2003 Payment Ck#42286 ($20,561.30) 11295.00
Sub -total Payments: 11295.00
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.
r
Nagin Gallop Figueredo P.A.
f 4
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -083 Statement No.: 14818
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
665.00
0.00
665.00
1,295.00
1,295.00
665.00
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
October 9, 2003
Matter ID: 0022 -095
Lazaro D. Tabares - EEOC
Statement No. 14819
Hours Amount
09/25/2003 EAB Telephone conference with Mr. Rick McDuff regarding settlement of 0.30 45.00
federal litigation and prepared memorandum to file.
Total Professional Services 45.00
Rate Summary
Eve A. Boutsis 0.30 hours at $150.00 /hr 45.00
Total hours: 0.30
Payments
10/07/2003 Payment Ck#42638 75.17
09/24/2003 Payment Ck#42286 ($20,561.30) 360.00
Sub -total Payments: 435.17
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 -095 Statement No.: 14819
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
45.00
0.00
45.00
435.17
435.17
45.00
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
Expenses
Parking Charge
09/23/2003 Certified Copy
Payments
09/23/2003 Payment Ck#42162
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Miami, Florida 33133
Facsimile: (305) 854 -5351
October 9, 2003
Matter ID: 0022 -113
Forfeiture of 1991 Nissan 300zx
Statement No. 14821
6.00
'r i ff
Sub -total Expenses: 8.00
150.00
Sub -total Payments: 150.00
0.00
8.00
8.00
342.00
150.00
Total Due 200.00
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 %a 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
October 9, 2003
Matter ID: 0022 -128
Maria S. Anduiza v. City of
Statement No. 14826
Hours Amount
09/22/2003 EAB Research on summary judgment standard in state court and under 1.00 175.00
Florida Whistleblower action.
Total Professional Services 175.00
Rate Summary
Eve A. Boutsis 1.00 hours at $175.00/hr 175.00
Total hours: 1.00
Payments
10/07/2003 Payment Ck#42638 272.25
09/24/2003 Payment Ck#42286 ($20,561.30) 41197.00
Sub -total Payments: 41469.25
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.
i
Nagin Gallop Figueredo P.A.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -128 Statement No.: 14826 Page: 2
For Professional Services 175.00
For Disbursements Incurred 0.00
Current Balance:
175.00
Previous Balance: 15,363.86
Payments - Thank you 4,469.25
Total Due 11,069.61
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.
"Z
NAGIN ALL FIGUEREDOPA,
Attorneys & Counselors
Payment is due upon receipt, Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest aW
rate of 1 .5% per month will be charged if payment is not received within 30 days. I
Hours Amount
08/08/2003
LRF Researched land use code regarding sinage issue and
3.00 525.00
teleconference with Sandy Youkilis regarding basis for denying
temporary sign.
08111/2003
LRF Responded to Hakeem Oshikoya's query regarding parking garage
0,70 122.50
loan.
08/13/2003
LRF Teleconference with George McArdle regarding loan; and prepared
0,90 157,50
e-mail response to Mayors inquiry.
08/14/2003
LRF Meeting with Hakeem Oshikoya, Ajibola Balogun, and George
130 227.50
McArdle; and responded to Mayor Feliu's inquiry,
08121/2003
LRF Responded to Comm'r Wiscombe's query regarding Mark Richman
0.40 70.00
Project.
08/28/2003
LRF Reviewed responses to request for production.
0.50 87,50
09/0212003
DAJ Telephone conference with Mr. Sandy Youkilis regarding the
0,20 15.00
request for production of documents propounded on the city by
MRP; e-mail to Ms. Ronefta Taylor, Mr. Hakeem Oshikoya and Mr.
Youkilis regarding same and need to coordinate a meeting for
sometime on Thursday, September 4, 2003 for Ms. Boutsis to
meet with everyone to go through their respective files on this
matter.
09/05/2003
EAB Coordinating meeting with staff regarding documents responsive to
0.40 70.00
discovery requests.
09/08/2003
EAB Meeting with Mr. Youkilis, Mr. Weiner, Ms. Hussein regarding
2.50 437.50
documents responsive to plaintiffs first request for production.
09/08/2003
DAJ Met with Mr. Luis Figueredo and reviewed three boxes of parking
1.00 75.00
garage files to determine what documents would be responsive to
plaintiffs first request for production; and pulled documents to be
produced.
09/09/2003
EAB Prepared memorandum to file providing update on discovery
0.20 35.00
Payment is due upon receipt, Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest aW
rate of 1 .5% per month will be charged if payment is not received within 30 days. I
Nagin Gallop Figueredo P.A.
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -129 Statement No.: 14827
Page: 2
09/29/2003 DAJ Prepared indexes to four boxes that will be produced to MRP 1.50 112.50
pursuant to their first request for production.
Rate Summary
Total Professional Services
Luis
response efforts.
Figueredo
09/09/2003
EAB Reviewed and revised draft interrogatory responses and documents
1.00 175.00
at
to be produced to plaintiff.
21432.50
09/09/2003
DAJ Revised final draft of discovery responses; and e- mailed same to
0.30 22.50
5.60
Mr. Weinger.
hours
09/10/2003
LRF Prepared revisions and finalized confidentiality and
1.50 262.50
non - circumvention agreement.
09/12/2003
LRF Teleconference with Mr. Weinger.
0.50 87.50
09/15/2003
EAB E -mail communications with Comm'r McCrea, Mayor Feliu, Vice
0.50 87.50
Mayor Russell, Ms. Davis, Mr. Oshikoya, and Mr. Gremet Reyes
regarding a -mails and production of a -mails responsive to MRP
matter; and began analysis of email production by Ms. Hussein,
Mr. Youkilis and Mr. Subrata Basu.
09/16/2003
LRF Worked on matters relating to request for production; reviewed files
2.00 350.00
to ensure privileged documents are not produced.
09/16/2003
EAB Attention to production issues and began separating attorney - client
1.00 175.00
and work product privileged communications; and prepared e-mail
communication to Comm'r Wiscombe and Mayor Feliu.
09/16/2003
DAJ Printed a -mails received from Commissioner Dan McCrea; provided
0.50 37.50
e -mails to Ms. Boutsis for her review as to privilege; and redacted
e -mails that contained my name so that they can be produced.
09/18/2003
LRF Worked on case management matters relating to MRP litigation.
1.30 227.50
09/25/2003
LRF Status conference with Mr. Gallop; and teleconference with Mr.
0.70 122.50
McArdle to discuss initiation of settlement negotiations.
09/26/2003
LRF Teleconference with Comm'r Wiscombe; teleconference with Mark
1.10 192.50
Richman regarding settlement of pending litigation; and
teleconference with Maria Davis' office.
09/29/2003 DAJ Prepared indexes to four boxes that will be produced to MRP 1.50 112.50
pursuant to their first request for production.
Rate Summary
Total Professional Services
Luis
R.
Figueredo
13.90
regarding this invoice. Interest at a
hours
at
$175.00/hr
21432.50
Eve
A.
Boutsis
5.60
hours
at
$175.00/hr
980.00
Debra A. Jester 3.50 hours at $ 75.00 /hr 262.50
Total hours: 23.00
3,675.00
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.
r w
Nagin Gallop Figueredo P.A.
Expenses
Payments
09/24/2003
10/07/2003
Mileage
Payment
Payment
f
CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022429 Statement No.: 14827 Page: 3
6.00
Sub -total Expenses: 6.00
Ck#42286 ($20,561.30) 31255.00
Ck#42638 719.87
Sub -total Payments: 31974.87
For
Professional Services
31675.00
10 days of receipt of any
For
Disbursements Incurred
6.00
of 1.5% per
Current Balance: 31681.00
Previous Balance: 61337.37
Payments - Thank you 31974.87
Total Due 61043.50
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 Miami, Florida 33133
Telephone: (305) 854 -5353 Facsimile: (305) 854 -5351
October 9, 2003
Hakeem Oshikoya Matter ID: 0022 -136
Finance Director Rosenbaum v. CSM
City of South Miami
6130 Sunset Drive Statement No. 14832
City of South Miami, FL 33143
Hours Amount
09/03/2003
EGG
Telephone conference with Mr. Shubin regarding alleged omitted
1.00
175.00
at
$175.00/hr
documents in response to public records request; prepared
of 1.5% per
Eve
A.
Boutsis
stipulation and communications with Ms. Davis, Mr. Youkilis and
hours
at
$175.00/hr
385.00
Mr. Ohsikoya.
09/04/2003
EGG
Reviewed parking agreements and occupational licenses; further
0.40
70.00
handling instructions to Ms. Boutsis.
09/05/2003
EAB
E -mail communications with city staff in order to coordinate
0.40
70.00
production of documents responsive to newest request pursuant to
section 119.07, Fla. Stat. claim.
09/08/2003
EAB
Meeting with Mr. Chalvire, Ms. Taylor, Mr. Reyes, Mr. Weiner, and
1.40
245.00
Mr. Youkilis regarding public record request and occupational
license pre- requisites for off site parking compliance.
09/09/2003
EAB
Prepared memorandum to file on public records request and
0.40
70.00
procedures for verifying compliance with occupational license
prerequisites.
09/29/2003
EGG
Reviewed re- notice of hearing on motion for judgment on the
0.10
17.50
pleadings.
Rate Summary
Total Professional Services 647.50
Earl
G.
Gallop
1.50
hours
at
$175.00/hr
262.50
of 1.5% per
Eve
A.
Boutsis
2.20
hours
at
$175.00/hr
385.00
Total hours: 3.70
Payments
10/07/2003 Payment Ck#42638 327.00
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.: 14832 Page: 2
09/24/2003 Payment Ck#42286 ($20,561.30) 595.00
Sub -total Payments: 922.00
For
Professional Services
647.50
questions you have
For
Disbursements Incurred
0.00
be charged if payment is
Current Balance:
647.50
Previous Balance: 31727.75
Payments - Thank you 922.00
Total Due 31453.25
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
Miami, Florida 33133
Facsimile: (305) 854 -5351
October 9, 2003
Matter ID: 0022 -137
Special Master Hearings
Statement No. 14833
Hours Amount
09/18/2003 EAB Attended special master hearings. 4.00 700.00
Total Professional Services 700.00
Rate Summary
Eve A. Boutsis 4.00 hours at $175.00/hr 700.00
Total hours: 4.00
For Professional Services 700.00
For Disbursements Incurred 0.00
Current Balance: 700.00
Previous Balance: 0.00
Payments - Thank you 0.00
Total Due 700.00
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 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
09/09/2003
Rate Summary
Miami, Florida 33133
Facsimile: (305) 854 -5351
October 9, 2003
Matter ID: 0022 -139
Hampton v. City of South Miami,
Statement No. 14835
Hours
EGG Reviewed city's notice of removal of action to federal district court, 0.30
and answer and affirmative defenses.
Earl G. Gallop
Total hours:
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Total Professional Services
0.30 hours at $175.00/hr
0.30
Total Due
52.50
To be properly credited, please indicate Statement Number on your remittance check.
Amount
52.50
52.50
52.50
0.00
52.50
0.00
0.00
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.
P.A.
NA GI GALLOP I E
N FGUREDO
Attorneys & Counselors
0 rMs
Facsimile: (305) 854-5351
October 9, 2003
Matter ID: 0022-140
TK Promotions v. City of Soul
Hours Amount
08/06/2003
LRF Worked with Sandy Youkilis on regulatory issues relating to adult
4.00 700.00
entertainment and reviewed adult entertainment ordinances from
other jurisdictions.
08/07/2003
LRF Worked on statutory and legal basis for regulating adult
2.90 507.50
entertainment and 5922 S. Dixie Highway site.
08/11/2003
LRF Reviewed letter from Dan Aronson regarding sinage issue and
1,00 175.00
teleconference with Sandy Youkilis.
08/12/2003
LRF Researched zoning and land use issues.
5.90 1,032.50
08/13/2003
LRF Reviewed adult entertainment ordinance; revised ordinance; and
4.80 840.00
teleconference with Sandy Youkilis regarding ordinance and sinage
issues.
08/14/2003
LRF Teleconference with Sandy Youkilis regarding Florida law and
0.40 70.00
matters relating to Booby Trap.
08/15/2003
LRF Met with Dan Aronson; researched Florida statute concerning 2500
2.30 402.50
ft. distance requirement; teleconferences with Mayor Feliu and
Comm'r Wiscombe; and teleconference with Sandy Youkilis.
08/17/2003
LRF Reviewed cases concerning zoning issues related to adult
2.00 350,00
entertainment.
08/18/2003
LRF Teleconference with Dan Aronson; teleconference with state
3.80 665.00
attorney; and met with Maria Davis, Earl Gallop; Chief Watson and
Mayor Feliu.
08/19/2003
LRF Meeting with Comm'r McCrae; attended board hearing regarding
7.60 1,330.00
Booby Trap sinage; met with Dan Aronson; conference with Mr.
Gallop; researched legal issues; and worked on legal memoranda.
08/20/2003
LRF Reviewed cases on zoning and first amendment issues;
4.90 857.50
teleconference with Sandy Youkilis regarding survey and related
matters; and teleconference with Maria Davis regarding compliance
issues and enforcement options.
Fayment 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.
H
Na gin Gallop Figueredo P.A. CONFIDENTIAL - ATTORNEY/CLIENT PRIVILEGED
Matter ID: 0022-140 Statement No.: 14836 Page: 2
08121/2003
LRF Worked on legal memoranda; teleconferences with Dan Aronson;
6.80 1,190,00
reviewed motion for preliminary injunction; and teleconference with
Maria Davis.
08/27/2003
LRF Teleconference with Maria Davis; conference with Ms. Boutsis;
140 595.00
worked on legal issues related to evidentiary hearing; and
conference with Mr. Gallop regarding pending matters.
08/28/2003
LRF Responded to e-mail from CommT McCrae.
0.60 105.00
08/2812003
LRF Telephone conference with Comm'r McCrae.
030 122.50
08/29/2003
LRF Meeting with Mayor Feliu regarding status of enforcement.
1.50 26150
09/04/2003
EGG Telephone calls to Ms. Katheryn Fernandez-Rundell, State
7.80 1,365.00
Attorney, Ms. Kathleen Von Hannay, Bureau Chief, Civil Division,
Florida Attorney General, Mr. George Limieux, Deputy Attorney
General, Mr. Charles Johnson, Chief, Organized Crime Unit, SAO;
e-mail to Mr. Oshikoya requesting issuance of retainer check to
Mr. Rogow; prepared answer and affirmative defenses
09/05/2003
EGG Reviewed district court judge's compliance and scheduling order.
0.30 52.50
09/05/2003
EGG Reviewed legal research regarding requesting award of attorney's
020 35,00
fees under sec. 42 USC 1988 by prevailing defendant,
09105/2003
EAB Legal research on whether city needs to request an award of
2.00 350.00
attorney's fees as prevailing defendant under 42 USC 1988; and
statutory authority requiring the State Attorney to be joined as
party due to constitutional challenge of state statute section
847.0134, Fla. Stat.
09/08/2003
EA B Legal research on chapter 16, Fla. Stat., and case law as to
2.00 350.00
powers and duties of Florida Attorney General; legal research on
standard for award defendant attorney's fees pursuant to 42 USC
sec. 1988.
09/09/2003
EGG Final preparation of answer and affirmative defenses; service and
0.50 87.50
filed same.
09110/2003
EA B Received assignment regarding prohibition on uses and exclusion
2.00 350.00
from municipal boundaries; and began legal research and analysis
of the case law on prohibited uses.
09/10/2003
JB Court run District Court to file defendant's answer to complaint.
0.50 25.00
09111/2003
EAB Legal research on cases regarding exclusionary zoning.
3.00 525.00
09/12/2003
EGG Preparing strategy memo.
2.00 350.00
09112/2003
EA B Legal research and analysis of case law on exclusionary zoning.
1.50 262.50
09/15/2003
EGG Telephone conference with John Pericles, State Attorney's Office,
2.90 507.50
prepared litigation strategy; analyzed judicial authorities.
09/15/2003
EA B Finalized research on exclusionary zoning and strict scrutiny
4.00 700.00
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 -140 Statement No.: 14836 Page: 3
analysis of zoning ordinances that impinge upon a fundamental
right; and drafted memorandum to file.
09/18/2003 EGG Attention to providing governor's assistant, Ms. Rodriguez, with 0.20 35.00
pleadings.
09/19/2003 EGG Telephone conferences with Ms. Raquel Rodriguez, ass't. general 0.40 70.00
counsel, Governor's office, regarding intervention in action by
Attorney General; with Ms. Kathleen Von Hoene regarding same;
with mayor Feliu, vice mayor Russell and commissioners.
09/24/2003 EGG Prepared for and attended rule 16 scheduling conference with 2.50 437.50
opposing counsel; initiated settlement discussions.
09/2512003 EGG Analyzed recent federal ripeness decision involving 1 st amendment 0.50 87.50
claim under statute where enforcement is not threatened and
evaluated use of case as authority for motion to dismiss.
09/30/2003 EGG Attended meeting with mayor Feliu and Ms. Davis regarding 0.50 87.50
settlement strategy.
Total Professional Services 14,882.50
Discount: - 11488.25
Rate Summary
Earl G. Gallop 17.80 hours at $175.00/hr 31115.00
Luis R. Figueredo 52.60 hours at $175.00 /hr 9,205.00
Eve A. Boutsis 14.50 hours at $175.00/hr 27537.50
Jordan Braswell 0.50 hours at $ 50.00 /hr 25.00
Total hours: 85.40
Expenses
Mileage 3.00
Courier charge 38.00
Legal research 266.94
Sub -total Expenses: 307.94
Payments
10/07/2003 Payment Ck#42638 26,077.70
Sub -total Payments: 26,077.70
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.: 14836 Page: 4
For
Professional Services
13,394.25
10
For
Disbursements Incurred
307.94
rate
Current Balance:
13,702.19
Previous Balance: 26,077.70
Payments - Thank you 26,077.70
Total Due 13,702.19
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 - ATTORNEYICLIENT 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
Miami, Florida 33133
Facsimile: (305) 854 -5351
October 9, 2003
Matter ID: 0022 -141
Gregory Feldman v. City of
Statement No. 14837
Hours
09/15/2003 EAB Analysis of complaint; section 112.532 and 112.534, Fla.Stat., and 0.70
causes of action identified by Capt. Feldman; and prepared
memorandum to file.
09116/2003 EGG Analyzed compliant for mandamus, injunctive relief and damages 2.50
for violation of federal civil rights statute, 42 USC 1983; evaluated
desirability of removal of action to federal district court; attention to
insurance coverage for claims and provision of defense by FLC;
checked to verify complaint transmitted to FLC, date of
transmission and time for filing notice of removal; telephone
conferences with Mr. Morrison, FLC, and confirmed coverage and
assignement of defense to Mr. McDuff, with Mr. McDuff regarding
removal of action to federal district court; transmitted e-mail
communication to comm'rs. and Ms. Davis.
09/24/2003 EGG Instructions to work attorney regarding initiating settlement 0.30
discussions and preparing a tolling and standstill agreement.
09/25/2003 EAB Telephone conference with Mr. Neil Flaxman regarding possible 0.40
stay; telephone conference with Mr. McDuff; and prepared
memorandum to file on stay issue.
09/26/2003 EAB Drafted letter to Mr. Flaxman and e- mailed update to Mr. McDuff. 0.30
Total Professional Services
Rate Summary
Earl G. Gallop 2.80 hours at $175.00/hr 490.00
Eve A. Boutsis 1.40 hours at $175.00/hr 245.00
Total hours: 4.20
Amount
122.50
437.50
52.50
70.00
52.50
735.00
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.
U v
0
Nagin Gallop Figueredo P.A. CONFIDENTIAL - ATTORNEY /CLIENT PRIVILEGED
Matter ID: 0022 -141 Statement No.: 14837 Page: 2
For Professional Services 735.00
For Disbursements Incurred 0.00
Current Balance:
735.00
Previous Balance: 0.00
Payments - Thank you 0.00
T
Total Due 735.00
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.