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05-06-08 Item 171 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27, 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 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 n G, S ! _. -_... i _ f I R f;I . . 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I _ ..J .. .7.. _ ., ._.__ �_ ' _.. .. . r ..... ii "i7� 2'I "[::•:: r.:ii:7 _,. f:ci...._, .. ................---........:. ... 5 -,. ....r.]r I.I..,.... .. r .,. .... .........:.... is �:i`�;�;;: r...:.: .:.... . 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.