05-06-08 Item 171
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RESOLUTION NO.
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 $41,175.13; CHARGING $5,000.11
TO ACCOUNT NO. 001 - 1500 - 514- 34 -10, LITIGATION SPECIAL
PROJECTS AND COSTS; CHARGING $2,000.00 TO ACCOUNT NO. 001-
1500- 514- 34 -52, CODE ENFORCEMENT; AND CHARGING $34,197.82 TO
ACCOUNT NO. 001 - 1500 - 514- 34 -54, LITIGATION RESERVE; PROVIDING
AN EFFECTIVE DATE.
WHEREAS, the City Commission of the City of South Miami approved Resolution No.
14 -05 -11993 authorizing payment of City Attorney non - retainer attorneys' fees and costs; and,
WHEREAS, Nagin Gallop Figueredo, P.A., submitted invoices to the City for legal
services rendered, and costs advanced, for the period ending April 28, 2008, in the amount of
$41,175.13; and,
WHEREAS, as of April 29, 2008, the existing balance in city attorney account no. 001-
1500- 514- 34 -10, litigation, special projects and costs, is $40,848.71; the existing balance in city
attorney account no. 001- 1500 - 514- 34 -52, code enforcement, is $15,357.50; the existing balance
in city attorney account no. 001 - 1500 - 514- 34 -54, litigation reserve, is $34,197.82 and
WHEREAS, the office of 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 costs received from Nagin Gallop
Figueredo, P.A., in the total amount of $41,175.13 are approved for payment; charging $5,000.11
to account no. 001- 1500 - 514- 34 -10, litigation, special projects and costs; charging $2,000.00 to
account no. 001 - 1500 - 514- 34 -52, code enforcement; and charging $34,175.02 to account no. 001-
1500- 514- 34 -54, litigation reserve.
Section 2. This resolution shall take effect immediately upon approval.
PASSED AND ADOPTED this day of May, 2008.
ATTEST:
CITY CLERK
READ AND APPROVED AS TO FORM:
Luis R. Figueredo
Nagin Gallop Figueredo, P.A.
Office of the City Attorney
APPROVED:
MAYOR
COMMISSION VOTE:
Mayor Feliu:
Vice Mayor Beasley:
Commissioner Wiscombe:
Commissioner Palmer:
Commissioner Beckman:
Additions shown by underlining and deletions shown by evern g.
iq
CITY OF SOUTH MIAMI
6130 Sunset Drive, South Miami, Florida 33143
Vendor: Network Reporting
Finance Department
Req. No. 12, FY 2007 -08
Date: April 29, 2008
Item
No.
Quantity
Description and
Specifications
Account Number
Unit Price
Total
1
1
Legal, Non - Retainer
001 -1500- 514 -34 -10
$379.45
$379.45
2
1
Legal, Non - Retainer
001- 1500 - 514 -34 -10
$194.65
$194.65
.3
1
Legal, Non - Retainer
001 -1500- 514 -34 -10
$371.05
$371.05
TOTAL
$945.15
Purchase Order No. Terms/Discount
I Hereby Certify That The
Above Material, Equipment,
Or Service Is Essential And A
Proper Request Against The
Codes Charge ,
Coding of Accounts Approved
Sufficiency of Appropriation
Balances Verified (Except As
Otherwise Noted)
Finance Department
Purchases as Above Approved
and Issuance of Purchase Order
Authorized
.' O.
NETWORK REPORTING
' `
44 Vrd'st Flaglor'Stteet,.Saite 1200
—
%iiarni, Florida 331:34
��l'O
(j
306 - 358 -8188 Fax:805 -358 -8187
loll Frce 88$
RTiti�
-365 -818$
H. James Montalvo, Esquire
Nagin, Gallop, Figueredo, P.A.
18001 Old Cutler Road
Suite 556
M; ', M I ZI fr'7
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Tax ID: 20- 0113967
H. James Montalvo, Esquire
Nagin, Gallop, Figueredo, P.A.
18001 Old Cutler Road
Suite 556
Miami, FL 33157
Phone: Fax:
Please detach bottom portion and return with payment.
Invoice No. 12466
Invoice Date 4/16/2008
Total Due $ 379.45
0
Job No. 15095
Remit To: Network Reporting Corporation BU ID 1 -MAIN
44 West Flagler Street Case No. 06 -11289 CA 10
Suite 1200
Miami, Fl. 33130 Case Name Dabby Properties vs. The City of South Miami
'
NETWORK REPORTING
12472
4/16/2008 14904
Nk;
06-11289 CA 10
Nuami, 11,Qrida 3�iao
Dabby Properties vs. The City of South Miami
16e 888�-3'68-8188
11.11
H. James ho, Esquire
Nagk\GaUnp Rguenedo P.A.
180O1 Old Cutler Road
Suite 556
Miami, FL331S7
ANSG
g.
Tax ID: 20-0113967
H. James Muntalvo, Esquire
Nagin, Gallop, Rgueredo P.A.
18OD1 Old Cutler Road
Suite 556
Miami, FL331S7
. Phone: Fax
Please detach bottom portion and return with payment.
'
Invoice No. 12472
Invoice Date 4/16/3008 `
.
Total Due : $ 194.65
Job No. � 14904
Remit To: Network Reporting Corporation BU ID 1-MAIN
44 West FlaglerStwset
Case No. 06-11289CA10
Suite 1200
Miami, FL 33130 'Case Name Dabby Properties vs. The City of South Miami
12472
4/16/2008 14904
4/4/2008
06-11289 CA 10
Dabby Properties vs. The City of South Miami
Due upon receipt
. Phone: Fax
Please detach bottom portion and return with payment.
'
Invoice No. 12472
Invoice Date 4/16/3008 `
.
Total Due : $ 194.65
Job No. � 14904
Remit To: Network Reporting Corporation BU ID 1-MAIN
44 West FlaglerStwset
Case No. 06-11289CA10
Suite 1200
Miami, FL 33130 'Case Name Dabby Properties vs. The City of South Miami
W
r
NETWORK REPORTING
ob Ma -
44:VPest Flagler'treat,.6iiite 7.7.00
— -
Miami, Florida 33130
-
305- 358 -8188 Pax 305 -358 -8187
1011 FieB 888=358
4/3/2008
-8188
H. James Montalvo, Esquire
Nagin, Gallop, Figueredo, P.A.
18001 Old Cutler Road
Suite 556
Miami, FL 33157
4,
Invoice io
12469
ob Ma -
12469
4/1612008
14903
Jlgb Date
Case No
4/3/2008
06-11289 CA 10
' Case Name
Dabby Properties vs. The City of South Miami
-
Payment Terms _
Due upon receipt
Tax ID: 20- 0113967 Phone: Fax:
Please detach bottom portion and return with payment.
H. James Montalvo, Esquire
Nagin, Gallop, Figueredo, P.A.
18001 Old Cutler Road
Suite 556
Miami, FL 33157
Remit To: Network Reporting Corporation
44 West Hagler Street
Suite 1200
Miami, FL 33130
Invoice No.
12469
Invoice Date
4/16/2008
Total Due
$ 371.05
Job No.
14903
BU ID
1 -MAIN
Case No.
06 -11289 CA 10
Case Name
Dabby Properties vs. The City of South Miami
CITY OF SOUTH MIAMI
6130 Sunset Drive, South Miami, Florida 33143
Vendor: Lott & Levine
Finance Department
Reg. No. 13, FY 2007 -2008
Date: April 29, 2008
Item
Description and
No.
Quantity
Specifications
Account Number
Unit Price
Total
1
1
Legal, Non - Retainer
001 -1500- 514 -34 -10
$870.93
$870.93
TOTAL $870.93
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 "
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
City Manager
LOTT & LEVINE
DADELAND CENTRE, SUITE 1014
91.55 SOUTH DADELAND BOULEVARD
MIAMI, FLORIDA 33156 April 17, 2008
CITY OF SOUTH MIAMI Reference No. 8986
EVE A. BOUTSIS, ESQ.
OFFICE OF THE CITY ATTORNEY
18001 OLD CUTLER RD, SUITE 556
PALMETTO BAY, FL 33157
For Professional Services Concerning:
Matter Number: CITY4.05085 Title: TITLE OPINION YMCA PROPERTY
4300 SW 58 AVENUE
Hours
07/11/07
UPDATED TAX ASSESSOR INFORMATION
AND VERIFICATION OF CURRENT OWNER
OF PROPERTY AND ENCROACHING CBS
WALL; PREPARED GRANT OF LICENSE
AGREEMENT. 4.00
Total Hours and Fees: 4.00
$780.00
COSTS ADVANCED
Date
Description
Cost Amount
12/19/05
Disbursement to: FEDERAL EXPRESS: TO FIGUEREDO, 12 /1
$24.74
12/19/05
Disbursement to: NOW COURIER: TO FIGUEREDO, 12/5
$16.05
07/21/07
Disbursement to: FEDERAL EXPRESS: TO BOUTSIS, 7/11/07
$15.14
08/07/07
Disbursement to: ATTORNEY'S TITLE INSURANCE: TITLE
SEARCH
$35.00
Total Costs:
$9093
Matter Summary:
Total Fees: $780.00
Total Cost: $90.93
Sub -Total Current Fees and Costs: $870.93
Amount Due: $87093
PAYMENT IS DUE ON OR BEFORE MAY 5, 2008.
PLEASE INCLUDE THE BILL OR REFERENCE NUMBER ON YOUR REMITTANCE.
THANK YOU.
CITY OF SOUTH MIAMI
6130 Sunset Drive, South Miami, Florida 33143
Vendor: Friedman, Lombardi & Olson Req. No. 14, FY 2007 -2008
Date: April 29, 2008
Finance Department
Item
No..
Quantity_
Description and
Specifications
Account Number
Unit Price
Total
1
1
Other Contractual Service/
001 - 1500 - 514 -34 -10
$344.00
$344.00
Litigation — Special
Projects and Costs
-- n0�01 ��==[ 11
Purchase Order No. I Terms/Discount
I Hereby Certify That The
Above Material, Equipment,
Or Service Is Essential And A
Proper Request Against The
Codes Charge __01
of
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
City Manager
Friedman, Lombardi & Olson r Invoice
......
Phone: (305) 371 -6677 Fax: (305) 374 -5292
N. James Montalvo, Esq.
Nagin, Gallop & Figueredo
18001 Old Cutler Road
Suite 556
Miami, FL 33157
Phone: (305) 664 -5353 t-ax:
Witness: Multiple Witnesses
Case: Dabby Properties v City of South Miami
Venue:
Case #: 06 11289 CA 10
.......................... .... .
Date: 12/3/2007
Start Time: 10:30 AM
_..... .. ....
._.......__.. .
End Time: 3:00 PM
Reporter: Zoili Alonso
Claim #:
.._...._ ... ...... ................_.... ..
File #: 923
z � 4
Expedited Copy Transcript -Trudy Pollack
32
$153 60
.. .....
Expedited Copy Transcript - Julian Chang
33
..............._$32.00....
$158.40
..._....._............ _... ................ _._... __...........................
Delivery
Sub Total
$344.00
Payments
$0.00
Balance Due
$344.00
Fed. I.D. # 59 -078 5873
Please send all correspondence to the above address.
CITY OF SOUTH MIAMI .
6130 Sunset Drive, South Miami, Florida 33143
Vendor: NAGIN GALLOP & FIGUEREDO, P.A. Req. No. 15, FY 2007 -08
Date: April 29, 2008
Finance Department
Item
No.
Quantity
Description and
Specifications
Account Number
Unit Price
Total
1
1
Leg Non- Retainer
001 -1500- 514 -34 -10
$5,000.11
$5,000.11
2
1
Legal, Non - Retainer
001 -1500- 514 -34 -52
$2,000.00
$2,000.00
3
1
Legal, Non - Retainer
0014500- 514 -34 -54
$34,175.02
$34,175.02
TOTAL
$41,175.13
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
Coding of Accounts Approved
Sufficiency of Appropriation
Balances Verified (Except As
Otherwise Noted)
Finance De artment
Purchases as Above Approved
and Issuance of Purchase Order
Authorized
180010 ld Cutler Road - Fifth Floor
Telephone: (305) 854 -5353 . Miami, Florida 33157 -6417 Facsimile: (305) 854 -5351
April 29, 2008
Ajibola Balogun
Acting City Manager
CITY OF SOUTH MIAMI
6130 Sunset Drive
South Miami, Florida 33143
Re: STATEMENTS FOR PROFESSIONAL SERVICES Retainer and
Non - Retainer for the City of South Miami
Dear Mr. Balogun:
Enclosed are our invoices for professional services rendered and for costs advanced for
the period ending April 28, 2008, in the amount of $41,175.13 and requisition no. 15 FY
2007 -08. I have tabulated the amounts currently due on each individual file as follows:
City Attorney Account No. 001- 1500 - 51434 -10, Other Contractual Services/Litigation,
Special Projects and Costs. Account balance as of April 29, 2008 is $40,848.71
0022 -001
General Municipal
Prof'I Services
$
0.00
Invoice No. 19564 dated 4128108
Disburesments
162.18
Total Due
162.18
0022 -083
Planning Board
Prof'l Services
$
1,600.00
Invoice No. 19565 dated 4128108
Disburesments
5.00
Total Due
17605.00
0022 -190
CSM Health Facilities
Prof'1 Services
$
15.00
Invoice No. 19568 dated 4128108
Disburesments
0.00
Total Due
15.00
0022 -192
Valencia Condominiums v. CSM
Prof I Services
$
40.00
Invoice No. 19569 dated 4128108
Disbursements
17.92
Total Due
57.92
0022 -196
Doug Baker Arbitration
Prof'l Services
37.50
Invoice No. 19570 dated 4128108
Disbursements
53.41
Total Due
90.91,
0022 -199
Ray Manucy
Prof I Services
$
260.00
Invoice No. 19571 dated 4128108
Disburesments
2.50
Total Due
262.50
Ajibola Balogun, Acting City Manager
CITY OF SOUTH MIAMI
April 29, 2008
0022 -201
Rene Guim v. City of South Miami
Prof'l Services
$
1,280.00
Invoice No. 19572 dated 4128108
Disbursements
446.60
Total Due
1726.60
0022 -202
Environmental Quality Control
Prof'1 Services
$
1,080.40
Invoice No. 19573 dated 4128108
Disburesments
0.00
Total Due
1,080.00
Total
$
5,000.11
City Attorney Account No. 001 -1500- 514- 34 -52, Other Contractual Services /Code
Enforcement. Account balance as of April 29, 2008 is $15,357.50
0022-137
Special Master Hearings
Prof'l Services
2,000.00,
Invoice No. 19566 dated 4128108
Disburesments
0.00
Total Due
29000.00
Total
29000.00
City Attorney Account No. 001 - 1500 - 514- 34 -54, Other Contractual Services/Litigation
Reserve. Account balance as of April 29, 2008 is $34,197.82
0022182
Dabby Properties
Prof'l Services
$
30,845.00
Invoice No. 19575 dated 4128108
Disbursements
3,330.02
Total Due
34175.02
Total
$343,175.02
Grand Total
41,175.13
Do not hesitate to call me if you have any questions regarding these statements.
LRF:reh
Enclosures
cc: Mayor and City Commission
Very truly yours,
L ' iguere
Page 2 of 2
NAGIN GALLOP FIGUEREDOPA.
Attorneys & Counselors
18001 Old Cutler Road, Suite 556 Miami, Florida 33157
Telephone: (305) 854 -5353 Facsimile: (305) 854 -5351
Apri128, 2008
Ajibola Balogun Matter ID: 0022 -001
City Manager General Municipal
City of South Miami
6130 Sunset Drive Invoice Number 19.564
City of South Miami, FL 33143
Expenses
3/3/2008
Mileage - City Hall
8.64
3/7/2008
Database Legal research
5.68
3/10/2008
Mileage - City Hall
8.64
3/31/2008
Mileage - City Hall
8.64
4/7/2008
Mileage - City Hall
8.64
4/11/2008
Mileage - City Hall
8.64
4/14/2008
Mileage - City Hall
8.64
4/21/2008
Mileage - City Hall
8.64
4/22/2008
Mileage - Downtown
19.20
4/24/2008
Photocopies for the month of April 2008.
41.50
4/25/2008
Telefacsmile charge for the month of April 2008.
24.75
4/25/2008
Postage Charge for the month of April 2008.
10.57
Sub -total Expenses:
162.18
Payments
4/7/2008 Payment Check No. 61353 137.23
Sub -total Payments: 137.23
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Nagin Gallop Figueredo P.A.
Matter ID: 0022 -001 Statement No.: 19564
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Total Due
Invoice Number: 19564
To be properly credited, please indicate Invoice Number above on your remittance check.
Page: 2
0.00
162.18
162.18
137.23
137.23
162.18
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 FIGUEREDOPA.
Attorneys & Counselors
18001 Old Cutler Road, Suite 556
Telephone: (305) 854 -5353
Ajibola Balogun
City Manager
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Miami, Florida 33157
Facsimile: (305) 854 -5351
April 28, 2008
Matter ID:. 0022-083
Planning Board
Invoice Number 19565
Hours Amount
4/11/2008 LRF Meeting with Comm. Jay Beckman and Mr..Sandy Youkilis re: EAR 3.00 600.00
project.
4/15/2008 LRF Meeting with Mr. Youkilis on EAR and M- Cycle. 2.00 400.00
4/21/2008 EAB Prepared for and attended P &Z EAR meeting; telephone conference 3.00 600.00
with Mr. Youkilis, telephone conference with Mr. Stephen David
regarding EAR.
Rate Summary
Luis R. Figueredo
Eve A. Boutsis
Expenses
4/7/2008 Photocopies
Payments
4/7/2008 Payment
5.00 hours at $
3.00 hours at $
Total hours: 8.00
Check No. 61353
Total Professional Services 1,600.00
200.00 /hr
200.00 /hr
Sub -total Expenses:
Sub -total Payments:
1,000.00
600.00
5,00
5.00
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.
Matter ID: 0022 -083 Statement No.: 19565
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Total Due
Invoice Number: 19565
To be properly credited, please indicate Invoice Number above on your remittance check.
Page: 2
1,600.00
5.00
1,605.00
180.00
180.00
1,605.00
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
NAGIN GALLGPFIGUERED®PA.
Attorneys & Counselors
18001 Old Cutler Road, Suite 556 Miami, Florida 33157
Telephone: (305) 854 -5353 Facsimile: (305) 854 -5351
April 28, 2008
Ajibola Balogun Matter ID: 0022 -137
City Manager Special Master Hearings
City of South Miami
6130 Sunset Drive Invoice Number 19566
City of South Miami, FL 33143
Rate Summary
Eve A. Boutsis
Payments
4/7/2008 Payment
10.00 hours at $
Total hours:. 10.00
Check No. 61353
200.00 /hr
Sub -total Payments
2,000.00
4,182.50
4,182.50
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice, interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Hours Amount
3/25/2008
EAB • Meeting with Ms. Carol Bynum, Ms. Eva Rosa, and Mr. Dario
1.50 300.00
Gonzalez regarding document production for subpoena; and attention
to pending code compliance matters.
4/3/2008
EAB Attended final summary judgment relating to csm liens and
3.00 600.00
foreclosure of same.
4/17/2008
EAB Attention to code enforcement matter and communications by Mr.
0.40 80.00
Juan Albian, attorney for appellant; follow up with staff regarding
same.
4/18/2008
EAB Communications with Mr. Albian, counsel for code enforcement
0.60 120.00
appellant; discussion with Ms. Rosa regarding same; meeting with
Mr. Ajibola Balogun regarding special master contracts; and revised
resolutions regarding same.
4/23/2008
EAB Prepared for and attended pre - hearing meeting with staff in
4.50 900.00
anticipation of hearings, and attended special master hearing.
Total Professional Services 2,000.00
Rate Summary
Eve A. Boutsis
Payments
4/7/2008 Payment
10.00 hours at $
Total hours:. 10.00
Check No. 61353
200.00 /hr
Sub -total Payments
2,000.00
4,182.50
4,182.50
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice, interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Nagin Gallop Figueredo P.A.
Matter ID: 0022 -137 Statement No.: 19566
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Total Due
Invoice Number: 19566
To be properly credited, please indicate Invoice Number above on your remittance check.
Page: 2
2,000.00
0.00
2,000.00
4,182.50
4,182.50
2,000.00
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 FIGUEREDOP.A.
Attorneys & Counselors
18001 Old Cutler Road, Suite 556 Miami, Florida 33157
Telephone: (305) 854 -5353
Ajibola Balogun
City Manager
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Facsimile: (305) 854 -5351
April 28, 2008
Matter ID: 0022 -182
Dabby Properties vCSM and
Invoice Number 19575
Hours Amount
3/24/2008 HJM Prepared second letter to Plaintiffs counsel re: deposition schedules 4.80 960.00
(.2). Commenced reviewing file for preparation of deposition -prep
sessions for interim Planning and Zoning Director Mr. 'Sandy Youkilis
and Mr. Luis Figueredo (4.6).
3/25/2008 HJM Received and reviewed Mediator's Mediation Report (0.1); Received 1.90 380.00
and reviewed Notices of Taking Deposition (0.1); Received and
reviewed e-mail correspondence from Plaintiffs counsel re: depo start
times (0.1); reviewed file in preparation for depo -prep session with
Building official Mr. Dario Gonzalez.
3/2612008 HJM Received and reviewed Plaintiffs Amended Notice of Taking 3.30 660.00
Deposition; continued revising file in preparation for deposition.
3/27/2008 HJM Continued reviewing file and voluminous set of documents in 5.50 1,100.00
preparation for depositions of Mr. Figueredo, Mr. Youkilis and Mr.
Gonzalez.
3/27/2008 EAB Legal research re: lobbying, registration, lawyer responsibilities and 0.70 140.00
duty to disclose.
3/28/2008 HJM Received Notice of Deposition of MRP corporate representative and of 3.10 620.00
Mark Richman (01); received and reviewed telephone voicemail from
Plaintiffs counsel Mr. Reiss (0.1); received and reviewed e-mail
correspondence from Mr. Reiss (0.1); retiewed transcript of Attorney
Client Session (0.4); continued preparing Motion for Summary
Judgment (2.4).
3/31/2008 HJM Continued reviewing file for deposition and for Motion for Summary 2.70 540.00
Judgment (2.3); Received and reviewed Amended Mediation Report
(0.1); Received and retiewed e-mail correspondence from Plaintiffs
counsel re: Motion to Consolidate (0.1); Received and reviewed
Plaintiffs correspondence to Court attaching Notices of Withdrawing
Motion to Consolidate (0.2).
4/1/2008 HJM Conducted pre depo preparation of Building Official Gonzalez (2.0) 6.70 1,340.00
telephone conference with MRP counsel J. Hanson re: depositions
Payment is due upon receipt. Please notify us w ithin 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of i.5% per month w III be charged if payment is not received w ithin 30 days.
Nagin Gallop Figueredo P.A.
Matter ID: 0022 -182 Statement No.: 19575 Page: 2
(0.3); received and reviewed e-mail correspondence from Plaintiffs
counsel re: J. Alkalel re: depositions (0.1); conducted pre -depo
preparation of Planning and Zoning Director Mr. Youkilis (2.8);
telephone conference with Plaintiffs counsel re: agreed order on
vacating prior order (0.1); received and reviewed proposed agreed
order for Plaintiffs counsel (0.1); continued preparing depo outline for
pre -depo session with Mr. Figueredo in anticipation of Mr. Figueredo's
deposition (1.3).
4/212008 HJM Received and reviewed correspondence from Plaintiffs to Court re: '4.20 840.00
agreed order and attachments (0.2); travel to and attend continuation
of pre - deposition preparation session of Mr. Gonzalez at City of
South Miami (1.0); travel to and attend continuation of pre - deposition
preparation session of Mr. Youkilis at City of South Miami (2.6); travel
with witness to premises of facility to inspect same (0.4).
4/3/2008 HJM Conducted additional pre -depo preparation session with Mr. Youkilis .2.00 400-00
prior to deposition (2.0); travel to and attended deposition of Mr.
Youkilis at offices of Plaintiffs counsel (5.0); conducted telephone
conference with Mr. Gonzalez re: deposition preparation session
(0.2); reviewed file in preparation of Mr. Gonzalez' deposition (0.3);
received and reviewed Plaintiffs Re- Notice of Deposition of Mark
Richman (0.1):
4/4/2008 HJM Received and reviewed Agreed order on Motion for Clarification from 4.30 860.00
County (0.1); Received and reviewed correspondence from Plaintiffs
counsel Mr. Schulman concerning a public records request (0.2);
Conducted conference with Mr. GOnzalez in preparation for his
deposition (2.0); Traveled to and attended deposition of Mr. Gonzalez
4/6/2008
HJM Conducted pre -depo prep session with fact witness Mr. Figueredo
6.80 1,360.00
and reviewed voluminous files with Mr. Figueredo.
4/6/2008
LRF Preparation with Mr. Montalvo for deposition.
6.80 1,360.00
4/7/2008
HJM Travel to and attend deposition of Mr. Figueredo (4.5); Reviewed file
6.40 1,280.00
prior to deposition of Mr. Figueredo (0.8); Prepared correspondence
to Mr. Schulman re: public records request and review file (0.3);
Prepared for deposition of Mark Richman (0.8).
4/7/2008
LRF Preparation and attendance at deposition as a witness.
5.00 1,000.00
4/7/2008
EAB Analyzed loan documents and attention to closing; attended closing.
3.50 700.00
4/8/2008 HJM Travel to and attend deposition of Mark Richman, individually and as 6.00 1,200.00
corporate representative of MRP (3.0); Received and reviewed e-mail
correspondence from Plaintiffs counsel re: conducting a meeting to
discuss the pre -trial stipulation; reviewed Case Management order
(0.4); prepared e-mail correspondence to MRP counsel, Mr. Hanson,
re: same (0.1); reviewed deposition transcript of Frank and Karen
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month w ill be charged if payment is not received within 30 days.
Nagin Gallop Figueredo P.A.
Matter ID: 0022 -182 Statement No.: 19575 Page: 3
Dabby and two transcripts of Stuart Auerback in preparation for
Motion for Summary Judgment (2.0); reviewed the Complex Business
Litigation Rules for purposes of filing a pre -trial stipulation (0.5).
4/9/2008 HJM Conducted legal research.to update prior research on interpretation of 7.10 1,420.00
easement agreements (4.3); Received and reviewed e-mail
correspondence from Plaintiff counsel, Robin Scott, re: meeting to
review pre -trial stipulation (0.1); Reviewed discovery responses from
Plaintiff included Request for Admisssions and Answer to
Interrogatories in support of preparing the Motion for Summary
Judgment (1.4); Continued reviewed Mr. Awerback's third deposition
transcript (1.3).
4/10/2008
HJM Received and reviewed Plaintiffs corrected Notice of Hearing on Joint
5.60 1,120.00
Motion for Continuance of Trial (0.1); Received and reviewed Notice of
Hearing, Status Conference and Pre -Trial Conference from Plaintiffs
counsel (0.1); Continued conducting legal research on issues of 1)
whether consideration paid for easement has an effect on
consideration of its use (0.4); 2) Whether inconvenience alone is
enough for increased damages; (0.8) 3) whether Court can look at
easement's purpose to expand the use of the easement (0.8); 4)
whether Court has the discretion to expand the use of easement with
extrinsic evidence; (0.8); whether fire - safety issues affect the
termination of the easement (0.8); whether modern times can be a
factor in expanding the initial intent for the easement (1.8).
4/11/2008
HJM Received and reviewed Mr. Figueredo's deposition transcript and
9.60 1,920.00
attached exhibits (1.5); Received and renewed deposition transcript
of Mr. Youkilis and Mr. Gonzalez (2.0); Received and reviewed Notice
of Filing (0.1); continued conducting legal research on issue of
abandoning the right to easement and whether temporary non -use of
easement causes abandonment (2.0); researched whether standard
of proof for abandonment was clear and convincing evidence or
preponderance of the evidence (0.4); continued conducting legal
research on cases for termination of easement rights(1.3); continued
conducting legal research on the legality of providing tax abatements
to residents /developers in expectance for compensation or other
benefits and whether third parties maintain standing to challenge the
tax abatements (2.3).
4/11/2008
SS Printed and provided caselaw for Mr. Montalvo on easement issue.
0.80 60.00
4/14/2008
HJM Continued writing and preparing Motion for Summary Judgment (5.5);
7.80 1,560.00
continued updating the research on issue of standing concerning tax
issues (1.8); continued sheppardizing all cases (0.5).
4/14/2008
SS Prepared notice of filing of deposition transcripts for Mr. Montalvo;
1.40 105.00
performed Lexis database research at Mr. Montalvo's request; pulled
additional cases from Lexis database.
4/15/2008
HJM Received and Reviewed deposition transcript of MRP (1.3); Continued
9.70 1,940.00
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Nagin Gallop Figueredo P.A.
Matter ID: 0022 -182 Statement No.: 19575
reviewed Mr. Youkilis deposition transcript (0.5); Continued updating
legal research on exhaustion of administrative remedies cases
regarding Count 1V (1.8); continued updating legal research on
defenses to Plaintiffs Unity of Title arguments (1.2); Reviewed files to
compile and update exhibits to attach to Motion for Summary
Judgment (0.6); Continued finalizing concise statement of undisputed
facts (3.8); Reviewed Miami -Dade County Fire Code for reference to
width requirements for accessory (0.5).
4/16/2008 HJM Continued preparing and finalized Motion for Summary Judgment, 11.90
Concise Statement of Undisputed Facts and Memorandum of Law
(8.8); Sheppardize all cases (1.0); Finalized exhibits for filing (0.4)
Received and Reviewed Plaintiffs proposed Joint Pre Trial Stipulation
(1.0); Received and Reviewed Plaintiffs draft exhibit list (0.4);
Received and Reviewed Plaintiff's draft witness list (0.2); Received
and Reviewed voicemail from MRP and J. Hanson 90.1).
4/16/2008 SS Assisted Mr. Montalvo with completion of motion for summary 5.30
judgment, reviewed document and checked all exhibits for accuracy;
created table of authorities and prepared binder of ail cases cited.
4/1712008 HJM Travel to and attend pre -trial stipulation conference with Plaintiffs 11.20
counsel and MRP counsel at Plaintiffs counsel's offices (2.5);
Conducted conference prior to pre -trial stipulation conference with
counsel for MRP (0.5); Prepared revisions and additions to Plaintiffs
proposed draft of the pre -trial stipulation (5.2); Prepared the City's
witness list (0.4); Prepared objections to Plaintiffs exhibits (0.5);
Prepared City's exhibit list (1.0); Received exhibits listed on exhibit
list (0.5); Prepared e-mail correspondence to Plaintiffs counsel, re:
exhibits and witness list (0.2); Reviewed the Business Litigation
Sections procedural rules regarding pre -trial stipulations (0.4).
4/17/2008 SS Completed binder including all authorities cited in motion for 0.90
summary judgment for Mr. Montalvo; created second copy of binder;
performed Westlaw database research for caselaw.
4/18/2008 HJM Completed revisions /additions to Plaintiffs draft of Joint Pretrial . 8.20
Stipulation (1.0); Prepared multiple correspondence to Plaintiffs
counsel R. Scott re: revisions (0.2); Received and reviewed MRP's
revisions /corrections to PreTrial Stipulation (0.4); Completed and
reviewed binders for City's exhibits (0.2); Received and reviewed
'additional draft of proposal joint PreTrial Stipulation for Plaintiffs
counsel with revisions (0.4); Reviewed table of cases (0.8);
Conducted conference call with Plaintiffs counsel and MRP counsel
re: PreTrial Stipulation (0.5); Performed additional revisions to PreTrial
Stipulation; Received and Reviewed three Motions for Summary
Judgment and exhibits and read cases cited therein for MRP on
Plaintiffs 4th Amended Complaint (3.6); Received and Reviewed
another revised draft for Plaintiffs counsel to finalize same (0.5);
Conducted additional conference call with Mr. Scott (0.2); Prepared
Page: 4
2,380.00
397.50
2,240.00
67.50
1,640.00
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 w ill be charged it payment is not received within 30 days.
Nagin Gallop Figueredo P.A.
Matter ID: 0022 -182 Statement No.: 19575 Page: 5
Amended Witness List (0.1); Received and Reviewed e-mail R
correspondence from Plaintiffs counsel to court (0.1); Received and
Reviewed e-mail correspondence from MRp's counsel to Court (0.1);
Received and Reviewed e-mail correspondence and attachment to
Court (0.1).
4/21/2008 SS Performed legal research; worked on binders containing caselaw 0.90 67.50
cited in motion for summary judgment; underlined quoted portions
and provided to Mr. Montalvo for review.
4/22/2008 HJM Received and reviewed e-mail correspondence from Court re: 5.10 1,020.00
Commencement of Trial (0.1); Commence preparing Trial
Memorandum (4.8); Prepared Correspondence to Plaintiffs counsel
re: Clifford Shulman (0.2).
4/23/2008 HJM Conducted telephone conference with MRP counsel J. Hanson re: 0.80 160.00
Judge Stettin (0.2); Prepared e-mail correspondence to Court re: J.
Stetlin (0.1); Prepared e-mail correspondence for Plaintiffs counsel A.
Dimond re: Clifford Schulman (0.1); Prepared letter to A. Dimond re:
Clifford Schulmand and disputed issues (0.4).
4/23/2008 SS Printed caselaw and provided to Mr. Montalvo. 0.10 7.50
Total Professional Services 30,845.00
Rate Summary
Payment is due upon receipt. Please notify us w ithin 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month w ill be charged if payment is not received w ithin 30 days.
H. James Montalvo 134.70 hours at $
200.00 /hr
26,940.00
Luis R. Figueredo 11.80 hours at $
200.00 1hr
2,360.00
Eve A. Soutsis 4.20 hours at $
200.00 /hr
840.00
Susan Snavely 9.40 hours at $
75.001hr
705.00
Total hours: 160.10
Expenses
3/11/2008
Database Legal research
384.98
3/11/2008
Database Legal research
397.15
3/18/2008
Tolls - Mediations
2.00
3/18/2008
Court reporter - Attorney - Client Session
602.00
4/2/2008
Mileage - Depo prep sessions for Sandy Youkilis
and
11.04
Dario Gonzalez
4/3/2008
Mileage - Deposition of Sandy Youkilis
20.93
Payment is due upon receipt. Please notify us w ithin 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month w ill be charged if payment is not received w ithin 30 days.
Nagin Gallop Figueredo P.A.
Matter ID: 0022 -182 Statement No.: 19575
4/4/2008
Mileage - Deposition of Dario Gonzalez
20.93
4/7/2008
Mileage - Deposition of Luis Figueredo
20.93
4/10/2008
Book - Private Land Use Arrangments
195.00
4/13/2008
Transcripts
803.30
4/15/2008
Outside copy job - Copies of 24X36 Drawings
32.10
4/16/2008
Parking Charge - Travel to Courthouse
1.00
4/16/2008
Outside copy job - Copies of Drawings - Reduced
32.10
4/16/2008
Mileage - Travel to Courthouse
17.61
4/17/2008
Mileage - Travel to Greenberg Traurig
16.41
4/21/2008
Mileage - Courthouse for Pretrial Conference
17.61
4/21/2008
Tolls - Courthouse for Pretrial Conference
3.50
4/21/2008
Parking Charge - Courthouse for Pretrial Conference
3.75
4/24/2008
Photocopies for the month of April 2008.
662.25
4/25/2008
Postage Charge for the month of April 2008.
10.43
4/25/2008
Telefacsimile charge for the month of April 2008.
75.00
Sub total Expenses:
3,330.02
Payments
4/7/2008
Payment Check No. 61353
10,287.25
Sub -total Payments: 10,287.25
Page: 6
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month w ill be charged if payment is not received w Rhin 30 days.
Nagin Gallop Figueredo P.A.
Matter ID: 0022 -182 Statement No.. 19575 Page: 7
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Tota I Due
Invoice Number: 19575
To be properly credited, please indicate Invoice Number above on your remittance check.
30, 845.00
3,330-02
34,175.02
10,287.25
10, 287.25
34,175.02
Payment is due upon receipt. Please notify us w ithin 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged K payment is not received w ithin 30 days.
NAGIN GALLOP FIGUEREDOPA,
Attorneys & Counselors
18001 Old Cutler Road, Suite 556
Telephone: (305) 854 -5353
Ajibola Balogun
City Manager
City of South Miami
6130 Sunset Drive
City of South Miami, FI_ 33143
Miami, Florida 33157
Facsimile: (305) 854 -5351
April 28, 2008
Matter ID: 0022 -190
City of South Miami Health
Invoice Number 19568
Hours
3/24/2008 HJM Telephone conference with Plaintiff's counsel re: garnishment. 0.10
Rate Summary
H. James Montalvo
Payments
3/25/2008 Payment
0.10 hours at $
Total hours: 0.10
Check No. 61247
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Total Professional Services
150.00 /hr
Sub -total Payments:
Total Due
15.00
33.23
33.23
Invoice Number: 19568
To be properly credited, please indicate Invoice Number above on your remittance check.
Amount
15.00
15.00
15.00
0.00
15.00
33.23
33.23
15.00
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
NAGIN GALLOP FIGUEREDOP.A.
Attorneys & Counselors
18001 'Old Cutler Road, Suite 556 Miami, Florida 33157
Telephone: (305) 854 -5353 Facsimile: (305) 8545351
April 28, 2008
Ajibola Balogun Matter ID: 0022 -192
City Manager Valencia Condominiums v.,City
City of South Miami
6130 Sunset Drive Invoice Number 19569
City of South Miami, FL 33143
Hours Amount
4/9/2008 HJM Received and reviewed e-mail correspondence from Plaintiff's 0.10 20.00
counsel, Mr. Paul Lipton, and prepared response to same.
4/11/2008 HJM Received and reviewed Notice of Hearing on City's Motion to Dismiss. 0.10 20.00
Total Professional Services 40.00
Rate Summary
H. James Montalvo
Total hours:
Expenses
3/19/2008 Database Legal research
0.20 hours at $
0.20
Payments
4/712008 Payment Check No. 61353
200.00 /hr
40.00
17.92
Sub -total Expenses: 17.92
200.00
Sub -total Payments: 200.00
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Nagin Gallop Figueredo P.A.
Matter ID: 0022 -192 Statement No.: 19569
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Total Due
invoice Number: 19569
To be properly credited, please indicate Invoice Number above on your remittance check.
Page: 2
40.00
17.92
57.92
200.00
200.00
57.92
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
NAGIN GALLOPFIGUEREDO .A.
Attorneys & Counselors
18001 Old Cutler Road, Suite 556 Miami, Florida 33157
Telephone: (305) 854 -5353 Facsimile: (305) 854 -5351
April 28, 2008
Ajibola Salogun Matter ID: 0022 -196
City Manager Doug Baker Arbitration
City of South Miami
6130 Sunset Drive Invoice Number 19570
City of South Miami, FL 33143
Hours Amount
3/24/2008 SS Performed Westlaw database research to obtain arbitration decisions 0.50 37.50
at Mr. Montalvo's request.
Rate Summary
Total Professional. Services 37.50
Susan Snavely 0.50 hours at $ 75.00 /hr 37.50
Total hours: 0.50
Expenses
4/2/2008 Database Legal research 53.00
4/25/2008 Postage Charge for the month of April 2008. 0.41
Sub -total Expenses: 53.41
Payments
4/7/2008 Payment Check No. 61353 502.85
Sub -total Payments: 502.85
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days. ,
Nagin Gallop Figueredo P.A.
Matter ID: 0022 -196 Statement No.: 19570 Page: 2
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Total Due
Invoice Number: 19570
To be properly credited, please indicate invoice Number above on your remittance check.
37.50
53.41
90.91
502.85
502.85
90.91
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 GALLOPFIGUEREDOPA.
Attorneys & Counselors
18001 Old Cutler Road, Suite 556 Miami, Florida 33157
Telephone: (305) 854 -5353 Facsimile: (305) 854 -5351
April 28, 2008
Ajibola Balogun Matter ID: 0022 -199
City Manager Ray Manucy
City of South Miami
6130 Sunset Drive Invoice Number 19571
City of South Miami, FL 33143
Hours Amount
4/23/2008 HJM Prepared Motion to Dismiss (0.5); Conducted legal research on 1.30 260.00
standing issues and notice requests issues (0.5); Prepared letter to
Valet Service re: indemnification (0.3).
Total Professional Services 260.00
Rate Summary
H. James Montalvo 1.30 hours at $ 200.00/hr 260.00
Total hours: 1.30
Expenses
4/24/2008 Photocopies for the month of April 2008. 2.50
Sub -total Expenses: 2.50
Payments
3/25/2008 Payment Check No. 61247 40.58
Sub -total Payments: 40.58
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Nagin Gallop Figueredo P.A.
Matter ID: 0022 -199 Statement No.: 19571 page: 2
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
260.00
2.50
262.50
40.58
40.58
Total Due 262.50
Invoice Number: 19571
To be properly credited, please indicate Invoice Number above on your remittance check.
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
NAGIN GALLOP FIGUEREDOP&
Attorneys & Counselors
18001 Old Cutler Road, Suite 556
Telephone: (305) 854 -5353
Ajibola Balogun
City Manager
City of South Miami
6130 Sunset Drive
City of South Miami, FL 33143
Miami, Florida 33157
Facsimile: (305) 854 -5351
April 28, 2008
Matter ID: 0022 -201
Rene Guim v. City of South
Invoice Number 19572
4/10/2008 HJM Received and reviewed correspondence from Palmer's counsel to 0.30
Court with request for special set hearing on Motion to Dismiss
Amended Complaint (0.1); Received and reviewed Palmer 3rd Set of
Interrogatories to Plaintiff (0.2).
4/14/2008 HJM Received and reviewed correspondence from Plaintiff's counsel re: 0.10
Hearing on Motion to Dismiss.
4/15/2008 HJM Received and Reviewed Plaintiff's Third Set of Interrogatories to 1.20
Palmer and Sola and Notice of Service of Same (0.2); Received and
Reviewed Palmer's Motion to Dismiss (0.4); Received and Reviewed
Guim's Second Request for Production to Palmer and Sola (0.1);
Received and Reviewed Sofa's response to Plaintiff's First Request for
Production (0.1); Received and Reviewed Sola's Answers to Plaintiff's
Second Set of Interrogatories (0.4).
Amount
80.00
100.00
60.00
20.00
80.00
60.00
60.00
20.00
240.00
4/18/2008 HJM Received and Reviewed Guim's Third Request for Production to Sola 0.20 40.00
(0.1); Received and Reviewed Palmer's Notice of Hearing on Motion
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Hours
3/2612008
HJM Received and. reviewed Plaintiff's 1st Request for Production to
0.40
I
Commissioner Velma Palmer and 2nd Set of interrogatories to Sola
and Palmer.
3/28/2008
HJM Received Plaintiff's exhibits 1 and 2; Plaintiff's Notice of Serving
0.50
Answers to Palmer's 1st and 2nd Interrogatories; Plaintiff's response
to Palmer's 1st Request for Production and e-mail correspondence
from Plaintiff's counsel.
3/31/2008
HJM Received and reviewed Ethics Commission opinion to Velma Palmer.
0.30
4/2/2008
HJM Received and reviewed correspondence from counsel for Guim to
0.10
counsel for Palmer concerning the original jurat pages.
4/3/2008
HJM Received and reviewed Miami Dade County's Answers to First Set of
0.40
Interrogatories.
4/4/2008
HJM Received and reviewed Defendant Palmer's Answers to Plaintiff's 2nd
0.30
Set of Interrogatories (0.2); Received and reviewed Defendant
Palmer's response to Plaintiff's First Request for Production (0.3).
4/10/2008 HJM Received and reviewed correspondence from Palmer's counsel to 0.30
Court with request for special set hearing on Motion to Dismiss
Amended Complaint (0.1); Received and reviewed Palmer 3rd Set of
Interrogatories to Plaintiff (0.2).
4/14/2008 HJM Received and reviewed correspondence from Plaintiff's counsel re: 0.10
Hearing on Motion to Dismiss.
4/15/2008 HJM Received and Reviewed Plaintiff's Third Set of Interrogatories to 1.20
Palmer and Sola and Notice of Service of Same (0.2); Received and
Reviewed Palmer's Motion to Dismiss (0.4); Received and Reviewed
Guim's Second Request for Production to Palmer and Sola (0.1);
Received and Reviewed Sofa's response to Plaintiff's First Request for
Production (0.1); Received and Reviewed Sola's Answers to Plaintiff's
Second Set of Interrogatories (0.4).
Amount
80.00
100.00
60.00
20.00
80.00
60.00
60.00
20.00
240.00
4/18/2008 HJM Received and Reviewed Guim's Third Request for Production to Sola 0.20 40.00
(0.1); Received and Reviewed Palmer's Notice of Hearing on Motion
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Nagin Gallop Figueredo P.A.
Matter ID: 0022 -201 Statement No.: 19572
Page: 2
20.00
400.00
60.00
40.00
1,280.00
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
to Dismiss (0.1).
4/21/2008
HJM Received and reviewed Palmer's Notice of Hearing on Motion to
0.10
Dismiss.
Conducted with Mr. Ajibola Balogun and Mr. Rudy de la
2.00
4/23/2008
HJM conference
Torre.
4/23/2008
HJM Received and reviewed Guim's Answers to Palmer's Third set of
0.30
Interrogatories.
4/25/2008
HJM Received and reviewed Palmer's additional responses to Plaintiff's
0.20
interrogatories.
Total Professional Services
Rate Summary
H. James Montalvo 6.40 hours at $ 200.00/hr 1,280.00
Total hours: 6.40
Expenses
3/3/2008
Database Legal research
367.68
3/3/2008
Photocopies the month of March 2008.
8.00
3/4/2008
Database Legal research
21.04
3/10/2008
Database Legal research
10.06
4/24/2008
Photocopies for the month of April 2008.
7.50
4/25/2008
Telefacsimile charge for the month of April 2008.
29.25
4/25/2008
Postage Charge for the month of April 2008.
3.07
Sub -total Expenses:
446 -60
Payments
963.41
4/7/2008
Payment Check No. 61353
Sub -total Payments:
963.41
Page: 2
20.00
400.00
60.00
40.00
1,280.00
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Nagin Gallop Figueredo P.A.
Matter ID: 0022 -201 Statement No.: 19572
For Professional Services .
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Total Due
Invoice Number: 19572
To be properly credited, please indicate Invoice Number above on your remittance check.
Page: 3
1,280.00
446.60
1,726-.60
963.41
963.41
1,726.60
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
NAGIN GALLOPFIGUEREDOP.A.
Attorneys & Counselors
18001 Old Cutler Road, Suite 556 Miami, Florida 33157
Telephone: (305) 854 -5353 Facsimile: (305) 854 -5351
April 28, 2008
Ajibola Balogun Matter ID: 0022 -202
City Manager Environmental Quality Control
City of South Miami
6130 Sunset Drive invoice Number 19573
City of South Miami, FL 33143
Hours Amount
3/11/2008 HSK Study staff report for environmental quality control board, emails 1.50 300.00
regarding meeting with City Manager Ajibola Balogun, and engineer
Jose Olivo at South Miami City Hall in re South Miami petition for
second extension of time for resident water connection to water
supply.
3/12/2008 HSK Conference with Luis Figueredo regarding City of South Miami 0.50 100.00
petition before environmental quality control board, review of
environmental resources management staff report, telephone
conference with South Miami city manager; in re South Miami
Petition for second extension of time for residents to connect to water
supply
3/13/2008 HSK Attendance at hearing before environmental quality control board with 3.40 680.00
Mr. Balogun and Jose Olivio; in re petition for second extension of
time for residents to connect to water supply.
Rate Summary
Henry S. Kaplan
Total Professional Services 1,080.00
5.40 hours at $ 200.00 /hr
Total hours: 5.40
1,080.00
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Nagin Gallop Figueredo P.A.
Matter ID: 0022 -202 Statement No.: 19573
For Professional Services
For Disbursements Incurred
Current Balance:
Previous Balance:
Payments - Thank you
Total Due
Invoice Number: 19573
To be properly credited, please indicate Invoice Number above on your remittance check.
Page: 2
1,080.00
0.00
1,080.00
0.00
0.00
1,080.00
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 FI GUEREDOPA.
Attorneys & Counselors
18001 Old Cutler Road, Suite 556 Miami, Florida 33157
Telephone: (305) 854 -5353 Facsimile: (305) 854 -5351
April 28, 2008
Ajibola Balogun Matter ID: 0022 -182
City Manager Dabby Properties v GSM and
City of South Miami
Invoice Number 19575
6130 Sunset Drive
City of South Miami, FL 33143
Hours
Amount
3/24/2008 HJM
Prepared second letter to Plaintiff's counsel re: deposition schedules 4.80
.960.00
(2). Commenced reviewing file for preparation of deposition -prep
Zoning Director Mr. Sandy Youkilis
sessions for interim Planning and
and Mr. Luis Figueredo (4.6).
3/25/2008 HJM
Received and reviewed Mediator's Mediation Report (0.1); Received 1.90
380.00
and reviewed Notices of Taking Deposition (0.1); Received and
reviewed e-mail correspondence from Plaintiff's counsel re: depo start
times (0.1); reviewed file in preparation for depo -prep session with
Building official Mr. Dario Gonzalez.
3/26/2008 HJM
Received and reviewed Plaintiff's Amended Notice of Taking 3.30
660.00
Deposition; continued revising file in preparation for deposition.
3/27/2008 HJM
Y ukiil st 5.50
Mr. Figueredo,o documents
P and Mr.
1,100.00
preparation for depositions of
Gonzalez.
3/27/2008 EAB
Legal research re: lobbying, registration, lawyer responsibilities and . 0.70
140.00
duty to disclose.
3/28/2008 HJM
Received Notice of Deposition of MRP corporate representative and of 3.10
620.00
Mark Richman (0.1); received and reviewed telephone voicemail from
Plaintiff's counsel Mr. Reiss (0.1); received and reviewed e-mail
correspondence from Mr. Reiss (0.1); reviewed transcript of Attorney
Client Session (0.4); continued preparing Motion for Summary
Judgment (2.4).
3/31/2008 HJM
Continued reviewing file for deposition and for Motion for Summary 2.70
Received and reviewed Amended Mediation Report
540.00
Judgment (2.3);
(0.1); Received and reviewed e-mail correspondence from Plaintiff's
re: Motion to Consolidate (0.1); Received and reviewed
counsel
Plaintiff's correspondence to Court attaching Notices of Withdrawing
Motion to Consolidate (0.2).
4/1/2008 HJM
Conducted pre depo preparation of Building Official Gonzalez (2.0) 6.70
1,340.00
telephone conference with MRP counsel J. Hanson re: depositions
(0.3); received and reviewed e-mail correspondence from Plaintiff's
counsel re: J. Alkalel re: depositions (0.1); conducted pre -depo
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Nagin Gallop Figueredo P.A.
Matter ID: 0022 -182 Statement No.: 19575 Page: 2
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.
preparation of Planning and Zoning Director Mr. Youkilis (2.8);
telephone conference with Plaintiff's counsel re: agreed order on
received and reviewed proposed agreed
vacating prior order (01);
order for Plaintiff's counsel (0.1); continued preparing depo outline for
pre -depo session with Mr. Figueredo in anticipation of Mr. Figueredo's
deposition (1.3).
4/2/2008
HJM Received and reviewed correspondence from Plaintiff's to Court re: 4.20 840.00
(0.2); travel to and attend continuation
agreed order and attachments
of pre - deposition preparation session of Mr. Gonzalez at City of
South Miami (1.0); travel to and attend continuation of pre - deposition
Mr. Youkilis at City of South Miami (2.6); travel
preparation session of
with witness to premises of facility to inspect same (0.4).
4/3/2008
HJM Conducted additional pre =depo preparation session with Mr. Youkilis 2.00 400.00
travel to and attended deposition of Mr.
prior to deposition (2.0);
Youkilis at offices of Plaintiff's counsel (5.0); conducted telephone
conference with Mr. Gonzalez re: deposition preparation session
file in of Mr. Gonzalez' deposition (0.3);
(0.2); reviewed preparation
received and reviewed Plaintiff's Re- Notice of Deposition of Mark
Richman (0.1).
4/4/2008
HJM Received and reviewed Agreed order on Motion for Clarification from
reviewed correspondence from Plaintiff's
4.30 860.00
County (0.1); Received and
counsel Mr. Schulman concerning a public records request (0.2);
Conducted conference with Mr. GOnzalez in preparation for his
deposition (2.0); Traveled to and attended deposition of Mr. Gonzalez
(20).
4/6/2008
HJM Conducted pre -depo prep session with fact witness Mr. Figueredo
6.80 1,360.00
and reviewed voluminous files with Mr. Figueredo.
4/6/2008
LRF Preparation with Mr. Montalvo for deposition.
6,80 1,360.00
4/7/2008
HJM Travel to and attend deposition of Mr. Figueredo (4.5); Reviewed file
Figueredo (0.8); Prepared correspondence
6.40 1,280.00
prior to deposition of Mr.
Schulman re: records request and review file (0.3);
to Mr. public
Prepared for deposition of Mark Richman (0.8).
417/2008
LRF Preparation and attendance at deposition as a witness.
5.00 1,000.00
4/7/2008
EAB Analyzed loan documents and attention to closing; attended closing.
3.50 700.00
4/8/2008
HJM Travel to and attend deposition of Mark Richman, individually and as
of MRP (3.0); Received and reviewed e-mail
6.00 1,200.00
corporate representative
correspondence from Plaintiff's counsel re: conducting a meeting to
discuss the pre -trial stipulation; reviewed Case Management order
(0.4); prepared e-mail correspondence to MRP counsel, Mr. Hanson,
re: same (0.1); reviewed deposition transcript of Frank and Karen
Dabby and two transcripts of Stuart Auerback in preparation for
Motion for Summary Judgment (2.0); reviewed the Complex Business
Rules for of filing a pre-trial stipulation (0.5).
Litigation purposes
4/9/2008
HJM Conducted legal research to update prior research on interpretation of
7.10 1,420.00
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Nagin Gallop Figueredo P.A.
- Matter 1D: 0022 -182 Statement No.: 19575
Page: 3
4/10/2008
4111/2008
HJM
HJM,
4/1'112008
SS
4/14/2008
HJM
4/14/2008
SS
4/15/2008
HJM
easement agreements (4.3); Received and reviewed a -mail
correspondence from Plaintiff counsel, Robin Scott, re: meeting to
review pre -trial stipulation (0.1); Reviewed discovery responses from
Plaintiff included Request for Admisssions and Answer to
Interrogatories in support of preparing the Motion for Summary
Judgment (1.4); Continued reviewed Mr. Awerback's third deposition
transcript (1.3).
Received and reviewed Plaintiff's corrected Notice of Hearing on Joint
Motion for Continuance of Trial (0.1); Received and reviewed Notice of
Hearing, Status Conference and Pre -Trial Conference from Plaintiff's
counsel (0.1); Continued conducting legal research on issues of 1)
whether consideration paid for easement has an effect on
consideration of its use (0.4); 2) Whether inconvenience alone is
enough for increased damages; (0.8) 3) whether Court can look at
easement's purpose to expand the use of the easement (0.8); 4)
whether Court has the discretion to expand the use of easement with
extrinsic evidence; (0.8); whether fire - safety issues-affect the
termination of the easement (0.8); whether modern times can be a
factor in expanding the initial intent for the easement (1.8).
Received and reviewed Mr. Figueredo's deposition transcript and
attached exhibits (1.5); Received and reviewed deposition transcript
of Mr. Youkilis and Mr. Gonzalez (2A); Received and reviewed Notice
of Filing (0.1); continued conducting legal research on issue of
abandoning the right to easement and whether temporary non -use of
easement causes abandonment (2.0); researched whether standard
of proof for abandonment was clear and convincing evidence or
preponderance of the evidence (0.4); continued conducting legal
research on cases for termination of easement rights(1.3); continued
conducting legal research on the legality of providing tax abatements
to residents /developers in expectance for compensation or other
benefits and whether third parties maintain standing. to challenge the
tax abatements (2.3).
Printed and provided caseiaw for Mr. Montalvo on easement issue..
5.60
Continued writing and preparing Motion for Summary Judgment (5.5);
continued updating the research on issue of standing concerning tax
issues (1.8); continued sheppardizing all cases (0.5).
Prepared notice of filing of deposition transcripts for Mr. Montalvo;
performed Lexis database research at Mr. Montalvo's request; pulled
additional cases from Lexis database.
Received and Reviewed deposition transcript of MRP (1.3); Continued
reviewed Mr. Youkilis deposition transcript (0.5); Continued updating
legal research on exhaustion of administrative remedies cases
regarding Count IV (1.8); continued updating legal research on
defenses to Plaintiff's Unity of Title arguments (1.2); Reviewed files to
compile and update exhibits to attach to Motion for Summary
Judgment (0.6); Continued finalizing concise statement of undisputed
facts (3.8); Reviewed Miami -Dade County Fire Code for reference to
• M
1,120.00
1,920.00
0.80
60.00
7,80
1,560.00
1.40
105.00
9.70 1,940.00
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Nagin Gallop Figueredo P.A.
Matter 113: 0022 -182 Statement No.: 19575
Page: 4
width requirements for accessory (0.5).
4/16/2008
HJM Continued preparing and finalized Motion for Summary Judgment, 11.90
Facts and Memorandum of Law
2,380.00
Concise Statement of Undisputed
all cases (1.0); Finalized exhibits for filing (0.4)
(8.8); Sheppardize
Received and Reviewed Plaintiff's proposed Joint Pre -Trial Stipulation
(1.0); Received and Reviewed Plaintiff's draft exhibit list (0.4);
Received and Reviewed Plaintiff's draft witness list (0.2); Received
and Reviewed voicemail from MRP and J. Hanson 90.1).
4/16/2008
SS Assisted Mr. Montalvo with completion of motion for summary 5.30
judgment, reviewed document and checked all exhibits for accuracy;
397.50
created table of authorities and prepared binder of all cases cited.
4117/2008
HJM Travel to and attend pre -trial stipulation conference with Plaintiff's 11.20
MRP at Plaintiff's counsel's offices (2.5);
2,240.00
counsel and counsel
Conducted conference prior to pre -trial stipulation conference with
counsel for MRP (0.5); Prepared revisions and additions to Plaintiff's
proposed draft of the pre -trial stipulation (5.2); Prepared the City's
Prepared objections to Plaintiff's exhibits (0.5);
witness list (0.4);
Prepared City's exhibit list (1.0); Received exhibits listed on exhibit
list (0.5); Prepared e-mail correspondence to Plaintiff's counsel re:
exhibits and witness list (0.2); Reviewed the Business Litigation
rules regarding pre -trial stipulations (0.4).
4/17/2008
Sections procedural
SS Completed binder including all authorities cited in motion for 0.90
Mr. Montalvo; created second copy of binder;
67.50
summary judgment for
performed Westlaw database research for caselaw.
4/18/2008
HJM Completed revisions /additions to Plaintiff's draft of Joint Pretrial 8.20
Stipulation (1.0); Prepared multiple correspondence to Plaintiff's
1,640.00
counsel R. Scott re: revisions (0.2); Received and revieweeddMRPP's.
to PreTrial Stipulation (0.4); Completed and
revisions /corrections
reviewed binders for City's exhibits (0.2); Received and reviewed
additional draft of proposal joint PreTrial Stipulation for Plaintiff's
(0.4); Reviewed table of cases (0.8);
counsel with revisions
Conducted conference call with Plaintiff's counsel and MRP counsel
Performed additional revisions to PreTrial
re: PreTrial Stipulation (0.5);
Stipulation; Received-and-Reviewed three Motions for Summary
Judgment and exhibits and read cases cited therein for MRP on
Amended Complaint (3.6); Received and Reviewed
Plaintiff's 4th
another revised draft for Plaintiff's counsel to finalize same (0.5).;
Conducted additional conference call with Mr. Scott (0.2); Prepared
Amended Witness List (0.1); Received and Reviewed e-mail
Plaintiff's counsel to court (0.1); Received and
correspondence from
Reviewed e-mail correspondence from MRp's counsel. to Court (0.1);
Received and Reviewed e-mail correspondence and attachment to
4/21/2008
Court (0.1).
SS Performed legal research; worked on binders containing ca seiaw 0.90
underlined quoted portions
67.50
cited in motion for summary judgment;
and provided to Mr. Montalvo for review.
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Nagin Gallop Figueredo P.A. .
Database Legal research
Matter ID: 0022 -182 Statement No.: 19575
Page: 5
4/22/2008 HJM Received and reviewed e-mail correspondence from Court re: 5.10`
of Trial (0.1); Commence preparing Trial
1,020.00
Commencement
Memorandum (4.8); Prepared Correspondence to Plaintiff's counsel
re: Clifford Shulman (0.2).
3/18/2008
HJM Conducted telephone conference with MRP counsel J. Hanson re: 0.80
160.00
4/23/2008
Judge Stettin (0.2); Prepared e-mail correspondence to Court re: J.
Court reporter - Attorney- Client Session
Stettin (0.1); Prepared e-mail correspondence for Plaintiff's counsel A.
4/2/2008
Dimond re: Clifford Schulman (0.1); Prepared letter to A. Dimond re:
11.04
Clifford Schulmand and disputed issues (0.4).
Dario Gonzalez
4/23/2008 SS Printed caselaw and provided to Mr. Montalvo. 0.10
7.50
Total Professional Services
30,845.00
Rate Summary
H. James Montalvo 134.70 hours at $ 200.00 1hr 26,940.00
Mileage - Deposition of Dario Gonzalez
Luis R. Figueredo 11.80 hours at $ 200.00 /hr 2,360.00
4/7/2008
Eve A. Boutsis 4.20 hours at $ 200.00 /hr 840.00
20.93
Susan Snavely 9.40 hours at $ 75.00 /hr 705.00
Book - Private Land Use Arrangments
0
Total hours: 160.10
Expenses
3/11/2008
Database Legal research
384.98
3/11/2008
Database Legal research
397.15
2.00
3/18/2008
Tolls - Mediations
3/18!2008
Court reporter - Attorney- Client Session
602.00
4/2/2008
Mileage - Depo prep sessions for Sandy Youkilis and
11.04
Dario Gonzalez
4/3/2008
Mileage - Deposition of Sandy Youkilis
20.93
4/4/2008
Mileage - Deposition of Dario Gonzalez
20.93
4/7/2008
Mileage - Deposition of Luis Figueredo
20.93
4/10/2008
Book - Private Land Use Arrangments
195,00.
803.30
4/13/2008
Transcripts
4/15/2008
Outside copy job - Copies of 24X36 Drawings
32.10
4/16/2008
Parking Charge - Travel to Courthouse
1.00
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Nagin Gallop Figueredo P.A.
Sub -total Expenses: . 3,330.02
Payments
4/7/2008 Payment Check No. 61353 10,287.25
Sub -total Payments: 10,287.25
For Professional Services 30,845.00
For Disbursements Incurred 3,330.02
Current Balance: 34,175.02
Previous Balance: 10,287.25
Payments - Thank you 10,287`25_
Total Due 34,175.02
Invoice Number: 19575
To be properly credited, please indicate Invoice Number above on your remittance check.
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.
Matter ID: 0022 -182 Statement No.: 19575
Page: 6
4/16/2008
Outside copy job - Copies of Drawings - Reduced
32.10
4/16/2008
Mileage - Travel to Courthouse
17.61
4/17/2008
Mileage -Travel to Greenberg Traurig
16.41
4/21/2008
Mileage - Courthouse for Pretrial Conference
17.61
4/21/2008
Tolls - Courthouse for Pretrial Conference
3.50
4/21/2008
Parking Charge - Courthouse for Pretrial Conference
3.75
4/24/2008
Photocopies for the month of April 2008.
662.25
4/25/2008
Postage Charge for the month of April 2008.
10.43
4/25/2008
Telefacsimile charge for the month of April 2008.
75.00
Sub -total Expenses: . 3,330.02
Payments
4/7/2008 Payment Check No. 61353 10,287.25
Sub -total Payments: 10,287.25
For Professional Services 30,845.00
For Disbursements Incurred 3,330.02
Current Balance: 34,175.02
Previous Balance: 10,287.25
Payments - Thank you 10,287`25_
Total Due 34,175.02
Invoice Number: 19575
To be properly credited, please indicate Invoice Number above on your remittance check.
Payment is due upon receipt. Please notify us within 10 days of receipt of any questions you have regarding this invoice. Interest at a
rate of 1.5% per month will be charged if payment is not received within 30 days.