HomeMy WebLinkAboutItem #15 - Discussion Item.1
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TELEPHONE (305)
379-2261
374.0544
FAX 381-6869
Mr. Cesar H. Odio
City Manager, City of Miami
3500 Pan American Drive
Miami, Florida 33133
LAW OFFICES
LEONARD H. RUBIN
SUITE 1125, ALFRED 1. duPONT BUILDING
169 EAST FLAGLER STREET
MIAM1, FLORIDA 33131
30 March 1995
Re: Reyes v. City of Miami; Circuit Court for Dade
County. Appellate Division, Case No. 93-008 AP
Dear Mr. Odio:
C�
BOARD CERTIFIED CIVIL TRIAL LAWYER
BOARD CERTIFIED MARITAL LAW
TRACTICE W CRIMINAL LAW
MEMBER NEW YORK BAR
On behalf of my client, Manuel Reyes, I request that the following two matters be placed
upon the City of Miami Commission Agenda on May 11, 1995:
1. My motion to tax appellate costs of $1,006.00, as is more fully set forth in my letter
dated 11 November 1994 to the City Clerk, a copy of which I attach for facility of your reference
(Exhibit I ;
2. My motion to adopt the Mandate of the Circuit Court for Dade County, as is more
fully set forth in my letter dated 21 November 1994 to the City Clerk, a copy of which I attach for
facility of your reference as Composite Exhibit 2.
Both Exhibits 1 and 2 were sent to the City Attorney.
A letter acknowledging receipt of Exhibits 1 and 2 was sent to me by the City Clerk on
November 23, 1994, and I attach a copy thereof for facility of your reference as Exhibit 3.
On 28 December 19941 filed my Lobbyist Annual Financial Report, a copy of which letter
and Report are attached hereto for facility of your reference as Composite Exhibit 4.
Very truly yours
LHR:mm
Enclosures
cc: Office of the City Attorney
Suite 300, Dupont Plaza Center
300 Biscayne Blvd. Way
Miami, FL 33131
Ms. Eivi Gallastegui
Agenda Coordinator
e
LEONARD H. RUBIN
ISGuSS ice`- _
410.ff
LAW OFFICES
LEONARU H. RUBIN
SUITE 1125, ALFRED I. duPONT BUILDINO
_ 169 EAST FLAOLER STREET
MIAMI, FLORIDA 33131
TELEPHONE (305)
379.2261
374.0544
FAX 381.6869
11 November 1994
BOARD CERTIFIED CIVIL TRIAL LAWYER
BOARD CERTIFIED MARITAL LAW
PRACTICE IN CRIMINAL LAW
MEMBER NEW YORK BAR
City of Miami
Office of The City Clerk
3500 Pan American Drive ,
Miami, Florida 33133
Attn: Matty Hirai,
City Clerk
Res Reyes v. The City of Miami;
Circuit Court for Dade County,
Appellate Division. Case #93-008 AP
Dear Ms. Hirai:
On October 21, 1994, the Circuit Court for Dade County,
Appellate Division filed its Opinion reversing the City of Miami in
the above -styled matter. I enclose a copy of that Opinion.
This appeal was prosecuted in the Circuit Court for Dade
County, pursuant to the Florida Rules of Appellate Procedure. Under
those rules, the prevailing party shall tax costs in the lower
.tribunal on motion served within 30 days. after issuance of the
_mandate. (See Rule 9.400).
Since the Miami City Commission is the "lower tribunal" in
this matter, please accept this letter as my motion to tax
appellate costs, which costs consist of the followings
1. On November 10, 1992 I paid
your filing fee for my client's
appeal to the Miami City Commission
in the amount of -- $ 400.00
(paid by check No. 1749 of Leonard
H. Rubin, copy attached)
2. On November 18, 1992 I paid for copies
of the tape recording of the Zoning
Appeal before the City of Miami Hearing
Board in the amount of -- 16.00
(receipt No. 67663 of the City of Miami
is attached)
OX) %- / 95- 57.5.1 .3
:rt
•
City of Miami
November 11, 1994
Page 2
4.
5.
On December 10, 1992, court reporter
Friedman, Lombardi & Gendron attended the
Miami City Commission Appeal hearing,
for which the reporter charged $100.00
for attendance, and $130.00 for a trans-
cript in the total amount of --
(copies of statements attached with
copy of check #1780 of Leonard H. Rubin)
On January 6, 1993 I paid the Clerk of
The Circuit Court a filing fee for this
appeal in the amount of --
(copy of check No. 1787 of Leonard H.
Rubin is attached)
On October 29, 1993 I received the
statement from the City of Miami for a
transcript of the zoning appeal before
the City of Miami Hearing Board in the
amount of --
(attached is a copy of check No. 1944
of Leonard H Rubin in a e t th f
230.00
75.00
285.00
p ym n ereo )
Total $ 1,006.00
I would appreciate it if you would inform me as to a mutually
convenient date for this matter to appear on the City Commission
Agenda so that I can be reimbursed for the appellate costs which I
.have advanced in this matter.
I have previously filed my Lobbyist Annual Financial Report Of
Lobbying Expenditures And Source Of Funds for 1994, and I would
appreciate it if,you would advise whether you still have that on
record and whether I must file an additional form for 1995 in the
event that I cannot get on an Agenda during 1994.
I am sending a true copy of this letter and the exhibits to
the City Attorney, Suite 300, DuPont Plaza Center, 300 Biscayne
Boulevard Way, Miami, Florida 33131. Finally, I am having my
signature and the contents of this letter, with exhibits verified,
under oath.
Very trul : -yours,
LEO H. RDBIN
95- 5115.1
City of Miami
November 11, 1994
Page 3
STATE OF FLORIDA )
SS
COUNTY OF DADE j
BEFORE ME,, the undersigned authority, personally appeared
LEONARD H* ,RDBIN, he being personally known to me, and after being
first duly sworn, he did depose and state that he signed the above
and foregoing letter, and stated that the matters contained herein,
and the exhibits annexed hereto are true and correct.
SWORN TO AND SUBSCRIBED before me at Miami, Florida, this 11 -1 14
dale of November, 1994.
oo
Nota Public, St a of Florida
at JLarge
Printed name of Notary Public
cc: Katherine S. Pecko, Esq.
Assistant City Attorney
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ALFRED I. DU PONT BLDG.
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MIAMI, FLORIDA 33130 FRIEDMAN,
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LOMBARDI & GENDRON
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General Reporting
TELEPHONE: 371.8877
�L EONARD H. RUB I N, ESQ.
INVOICE. DATE EMPLOYEII Lf '
59.078.5073
ALFRED I. duPONT BLDG.,
12/17/92
SUITE 1125
INVOICE NUmmin
MIAMI, FL 33131
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99/43879 PG. i
PLEASE
REFERENCE THIS INVCIICE NUMBER
WHEN REMIrmc
00 DATE TAKEN :
REFERENCE
CHARGES
RE: 'REYES
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ATTENDANCE TO 7 : 30
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MIAMI, FLORIDA 33130 FRIEDMAN, LOMBARDI & GENDRON Dal1rGorMmn 1980-
General Reporting TELEPHONE: 371.667
�LEONARD H. RUB I N, ESQ.
ALFRED I. duPONT BLDG. ,
SUITE 1125
MIAMI, FL 33131
DATE TAKEN
12/10/
REFERENCE
RE: IN RE: REYES
45
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PAY TO TI IE
INVOICE DAIE.
I.MPLOY
12/29/92
sq•a7o•5
INVOICE NUMIJUII
99/44077
FAG:
PLEASE REFERENCE" rIIIS INVC11(11•
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WHEN RL•MIIIINO
LEONARD H. RUBIN
ALFRED I. DU PONT BLDG.'`
MIAMI, FL 33131
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CESAR H. 0010 a 'b'Ij YS°" P. 0. sox 33070a
�p MIAMI. [1OR10A 33233-0708
CITY MANAGER CC P 306-250-5400
•••+� fAX 305-285-1835
October 290 1993'
BILL TO: Leonard Rubin, Attny.
169 East Flagler Street r
Suite 1125
Miami,.Florida 33131
Professional Services rendered from' Monday, October 18 thru
October 28, 1993•
Translation and Typing for a total of nineteen (19) hours at $15•
per hour.
Amount due $285.00
4 If you have any questions, please free to contact me at 250-5321.
Sincerely,
Aerta A. Dav s
LEONARD N. RUDIN 194 4
ALFhEb 1. DU PONT BLDG,
MIAMI. FL 33131 —
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• LAW OFFICES
LEONAR,D H. RUBIN
SUITE 1125, ALFRED 1, duPONT BUILDING
169 EAST FLAGLER STREET
MIAMI, FLORIDA 33131
BOARD CERTIFIED CIVIL TRIAL LAWYER
TELEPHONE (305) BOARD CERTIFIED MARITAL LAW
379-2261 MACTICE IN CRIMINAL LAW
374.0544 21 November 1994
FAX 391.6"9 MEMBER NEW YORK BAR
Via Fax #858-1610 and Mail
City of Miami
Office of The City Clerk
3500 Pan American Drive
Miami, Florida 33133
Attn: Matty Hirai,
City Clerk
Re: Reyes 'v. The City of Miami;
Circuit Court for Dade County,
Ap"llate Division, Case 193-008 AP
Dear Ms. Hirai:
On November 14, 19941, the Circuit Court for Dade County,
Appellate Division, in Appeal No. 93-008 AP, entered its Mandate,
a copy of which I attach.
Please consider this as my clients motion to adopt the
Mandate, and for a Resolution from the Miami City Commission on
behalf of.Manuel Reyes, pursuant to said Mandate and the Opinion
filed October 21, 1994 in the Appellate Division of the Circuit
Court for Dade County, Florida.
I am sending a copy of this letter to you by fax (858-1610) as
well as by mail, and I'm sending a copy to the City Attorney by fax
(579-3399) as well as by mail.
Since
LEONARD H. RUBIN
LHR: mm
cc: City Attorney
(Via Fax #579-3399 and Mail)
1�uevler�+
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_ MANDATE FROM CIRCUIT COURT
APPELLATE DIVISION
ELEVENTH JUDICIAL CIRCUIT
DADE COUNTY, FLORIDA
APPEALS NO. 93--008AP
MANUEL REYES
APPELLAJVT/'PET I T I ONER
vs -
CITY OF MIAMI
APPELLEURESPONDENT
This cause having been brought to this Court by appeal, and after due
consideration the Court having Issued Its opinion;
YOU ARE HEREBY OCNMArDED that such further proceedings be had In said
cause In accordance with the opinion of this COURT attached hereto and
Inoorporated as part of this order, and with the rules of procedure and
laws of the STATE OF FLORIDA.
Case Number(s) 92-82O
WITNESS the Honorable Murray Goldman, Administrative Judge of the
Appellate Division of the Circuit Court of the Eleventh Judicial Circuit of
Florida and the seal of the said Circuit Court at Miami, this 14TH day of
NOVEMBER, 1994.
HARVEY RUVIN,
Clerk of the Circuit Court of
the Eleventh Judicial Circuit
In and for Dade County. -"
/ 4 A 0 I
By:
OLIX P CIA,
Deputy erk c
i
RIOT FINAL UNTIL TIME EXPIRES
TO FILE REHEARING MOTION
AND, IF FILED, DISPOSED
MANUEL REYES
Appellant,
v .
THE CITY OF MIAMI
Appellee.
IN • THE ,CIRCUIT COURT OF THE
11TH JUDICIAL CIRCUIT IN AND
FOR DADE COUNTY, FLORIDA
APPELLATE DIVISION
Case No. 93-008
r�
- - DERD
NOV 0 8 1994 - M
1/�C1.101 0UCull • t,
& County Courts s
OPINION FILED October 21, 1994
An appeal from Resolution 92-820 of the City of Miami, City
Commission, Dade County, Florida.
Leonard H. Rubin for the Appellant, XATHRYN S.- PECKO., Assistant
City Attorney, for the Appellee.
Before Robbie M. Barr, Jennifer Bailey, and Alan S. Gold, J.J.
ALAN S. GOLD, JUDGE.
Appellant, Manuel Reyes, appeals from Zoning Resolution Number
I92-820 of the City of Miami, which denied Appellant's appeal from
the City s Zoning Board and upheld the issuance of a Class I
Special Permit for a pool hall with three tables in connection with
a private club for profit, subject 'to certain additional
onditions, including that (1) the hours of operation be from 10:00
Cn e,
cn ,.,A.M. to 9:00 P.M., six days a week excluding Sundays, and (2) a
CD 8security guard licensed, uniformed and armed at all times be on the
• cs
.9: premises while it is opened for business (hereinafter
tCO
"conditions"). Appellant contends that the conditions are in
violation of Sec' -ion 1306 of the City of Miami Zoning Code and are
RECORDED 1
OCT 24 1994 116555Pc07 95—
64
414y,
unsupported by competent, substantial evidence of record. We find
merit in Appellant's arguments and reverse.
The *Appellant filed his application for Class I Special Permit
to operate a three table pool room at 304 S.W. 8th Avenue, Miami,
Florida. The Zoning Administrator granted the permit as -being in
compliance with the City's zoning ordinances, subject to the
limitations that the use include no video games, no -food
preparation, no beer, wine or liquor - to be sold on the premises and
no activities outside the enclosed premises. Prior to issuing the
permit, the Zoning Administrator was advised by the City Attorney
that he lacked discretion to deny the permit based on assumed
criminal or disruptive activity by a prior tenant of the premises,
with the same type operation, if the application otherwise met all
applicable land use regulations.
After the permit was granted, an adjacent business owner, as
an aggrieved party, filed an appeal of the permit to the City's
Zoning Board. By Resolution ZB 113-92, the Zoning Board, following
notice and public hearing, denied the appeal, but imposed
additional conditions on'the Class I Special Permit, two of which
were the subject of the Appellant's appeal to the City of Miami
Commission. Neither the Zoning Board nor the City Commission set
forth the reasons for the conditions, although, evidently, they
were imposed in response to concerns heard from objectors during
1-o the hearing before the Zoning Board.
. ,g=-
ICO The City's resolution under appeal is the result of a quasi-
judicial process concerning the issuance of a permit. Jennings v.
2
1RF.F.1i.AE9 OKI 9 5 - 515 f
f
11L P,
r
Dade County, 589 So.2d 1337, 1343 (Fla. 3d DCA 1991) (Ferguson J.
concurring) . As such, it is to be scrutinized on appeal by non -
deferential judicial standards. Id. at n.3; Bd. of Cty Com'rs of
Brevard v. Snyder, 627 So. 2d 469, 475 (Fla. 1993); City of Apopka
v. Orange County,, 299 So. 2d 657 (Fla. 4th DCA 1974). At the
circuit level, the reviewing court must consider whether due
process was afforded, whether the administrative body applied the
correct rule of law, and whether its administrative findings and
judgment are supported by competent, substantial evidence. City of
Deerfield Beach v. Valiant, 419 So. 2d 624 (Fla. 1982);
Educ.Dev.Ctr. v. Zoning Board of Appeals, 541 So. 2d 106, 108 (Fla.
1989). In so doing, the circuit court may not reweigh the evidence
nor substitute its judgment for the administrative agency. Id.
First, although a local government is not ordinarily required
to make findings of fact in support of its decisions., see City
Com'rs of Brevard v. Snyder, supra, 627 So. 2d at 476, the City, by
its own zoning ordinance, required that any conditions or
safeguards "...be supported by stated reasons therefor, based on
such conditions and standards...." Having adopted such a
requirement, the City was obligated to follow its own procedural
-- requirements when the Zoning Board, and, subsequently the City
.Cn
� Cn Commission, imposed the conditions in question. Gulf & Eastern
�Development Co r. v. City of Fort Lauderdale, 354 So. 2d 57, 61
. (Fla. 1978). Its failure to do so in its motion or resolution
results in a violation of the City's own ordinance.
U1
Second, the record before the Zoning Board and the City
/ 1 0 t 3
OFF,7 R°C so 9 5 — 51511
Commission 'fails- to contain competent, substanti�i- evidence
establishing asubstantial relationship between the conditions
imposed and the need to be regulated. It is fundamental, and long
established, that there must be a substantial and reasonable
relationship between the need for the zoning restriction and the
public health, safety, morals or welfare to justify -interference by
exercise of the police power, with an owner's right to enjoyment of
Property. City of Miami Beach v. Lachman, 71 So. 2d'148 (F1a.
1948).'Without such a substantial relationship, the zoning action
is in violation of basic substantive due process rights. This
fundamental constitutional protection is also reflected in Section
1306 of the City of Miami Zoning Code where conditions or
limitations are prohibited beyond that which is. reasonably
necessary to accomplish the purpose for which the safeguard is
Imposed. -
'It is undisputed that the Appellant established before the
Zoning Administrator and the Zoning Board that the application for
Class 'I Special Permit complied with all substantive and procedural
requirements of the City's land development regulations. At this
point, the burdenshiftedto the City to demonstrate that the
,additional conditions were reasonably necessary for the
accomplishment of a legitimate governmental purpose. Cty Com'rs of
Ln
~o ` - Brevard v. Synder, supra, 627 So. 2d at 476. As indicated, no such
evidence sufficiently appears of record. Instead, the record
'CO establishes that the conditions are arbitrary and discriminatory.
Cr) The condition that this three table poolhall be restricted in
4
(QUIwREC BKI
1 CCCCnnn-1r9
17
its hours of operation from 10:00 A.M. to 9:00 P.M., six days a
week,. is directly contrary to the City's own ordinance which
governs the operation of all other poolhalls in the City of Miami.
As noted in the City's own brief, with exceptions not applicable
here, Section 5-11 City of Miami Code, mandates that poolrooms be
closed no later than midnight and reopen no earlier than 8:00 A.M.
Answer Brief of Appellee, page 3. The record fails to establish by
_competent, substantial evidence any reasonable necessity to single
.out this one small business for such disproportionate treatment
other than the neighbors unsubstantiated fear that Appellant will
permit illegal activities on the premises as did the former tenant.
As to this matter, the City's own attorney correctly advised the
Zoning Administrator that the requested Class I Special Permit
could not be denied based on assumed criminal or disruptive
activity.
Similarly, the condition requiring "an armed, uniformed and
licensed security guard at all times" is likewise unsupported by
competent, substantial evidence demonstrating a substantial and
reasonable necessity between the condition imposed and the need the
City seeks to regulate. The City conceded at oral argument that no
City ordinance of general applicability imposes such an obligation
I i;on other poolrooms, regardless of the number of tables involved,
Nonetheless, the City argues such conditions may be imposed on a
.CO
O case by case basis under Section 1305.8 of the City of Miami Zoning
'00 Code which pertains to the "control of adverse effects generally,."
~ Such a broad reliance on'thisgenerally worded section of the
5
LOF-F eEc.OX1 9 5 - 515.1
I [CCCornIC0
At
zoning code is in direct conflict with the well established
principle that all persons similarly situated should be able to
obtain a permit approval upon meeting uniform standards. See City
Nat'l Bank of Miami v. City of Coral Springs, 474 So. 2d 984, 634,
(Fla. 4th DCA 1985); City of Lauderdale Lakes v. Corn, 427 So.2d
239 (Fla. 4th DCA 1983); Park of Commerce v. City of Delray Beach,
606 So. 2d 633, 634 (Fla. 4th DCA 1992). Otherwiser the official
app:roval or denial of such a permit -would depend upon the whim or
caprice of the public body involved. Property owners are entitled
to notice of the conditions they must meet in order to improve
their property in ..accord with the existing zoning and other
development regulations of government. Park of Commerce v. City of
Delray Beach, supra, 606 So. 2d 633, 635. As stated in the Park of
Commerce case by the Fourth District Court of. Appeal, "[t]hose
conditions should be set out in clearly stated regulations.
Compliance with those regulations ations should be capable of objective
determination in an administrative proceeding." Id.
Accordingly, we reverse and remand to the City of Miami to
enter the Class I permit in question,, absent the two conditions in
question.
ROBBIE M. BARR AND JENNIFER BAILEY, J.J., CONCUR.
COPIES FURNISHED TO:
I*a.% PICOUNSEL OF RECORD AND
Cn' ..:TO ANY PARTY NOT REPRESENTED
-_J R11
.CD
1C0
I t-
100
95- 51511
6 � y
-7 r m
- 00!�l
November 23, 1994
Leonard H. Rubin, Esq.
Suite 1125, Alfred I. duPont Building
169 East Fiagler Street
Miami, Florida 33131 -
RE: REYES V. THE CITY OF MIAMI; CIRCUIT COURT FOR DADE COUNTY, APPELLATE
f DIVISION, CASE #93-008 AP
f Dear Mr. Rubin:
Pursuant to your request we hereby acknowledge receipt of your letters dated November 11,
1994 and November 21,1994 related to the above -captioned case.
We have also, pursuant to your request, routed your letters to the members of the City
Commission.
Sincerely,
o07: VMHirai
U City Clerk
95" 515 , /
Ex//iRi
T 3
LAW OPSCES
LEONARD H. Rum
SUITE 1125. ALFRED 1. duPONT BUILDINO
169 EAST FLAMER STREET
MIAMI, FLORIDA 33131
28 December 1994
BOARD CERTIFIED CIVIL TRIAL LAWYER
BOARD CERTIFIED MARITAL LAW
PRACTICE IN CRIMINAL LAW
MEMBER NEW YORK BAR
City of Miami -City Hall
j- Office of the City Clerk
I 3500 Pan American Drive
Miami, Florida 33133
Attn: Hayaee Regueyra
Re: Lobbyist Annual Financial Report
' Dear Ms. Regueyra:
Enclosed is original and one copy of my Lobbyist Annual
Financial Report. I would appreciate it if you would acknowledge
receipt on the copy, and return it to me in the enclosed self-
addressed and stamped envelope.
Thank you for your courtesy in this regard.
Sin
r
LEONARD H. RUBIN
LHR:mm
LHSBPWvor&W1 i
GDMPBS/7� �1'f�/&T 44
95,I
CiTY OF MiAMI d
Reporting period covered:
i January 1,1994 through ---
December 31, 1994
LOBBYIST ANNUAL FINANCIAL REPORT OF
LOBBYING EXPENDITURES AND SOURCE OF FUNDS
NOTE: Report trust be filed with the City Clerk by January 10, 1995. If the
space provided Is Insufficient, accompanying schedules should be
attached.' Please be reminded this reDort must be filed even If you
had no expen ores.
• M
STATE OF FLORIDA )
COUNTY OF DADE ) SS _
C17Y OF MIAMI )
Before me, the
�� undersigned authority, personally appeared (PRINT YOUR NAME
HERE) 400,W h /y .+P #AZAI who, by first being duty sworn on oath, deposes and
states that the attached Information disclosed herein, or otherwise contained In any other forms attached
hereto, Is true and correct:
1. The lobbyist submits to the City Clerk's Office the following list of all lobbying expenditures as well
as the sources from which such expenditures have Incurred In the period commencing on the first
day of January, 1994, through December 31, 1994.
II. a. General Expenditures. +
NOTE: The statement of expenditures in this Subsection ("General
Expenditures") shall include, but not be limited to, all expenses made or
incurred, of any nature whatsoever, for or on behalf of the lobbyist, and ,
shall also include the dollar amount for said expenses, 9 any.
NATURE OR KIND OF
NAME & ADDRESS EXPENDITURE FOR OR
ITEM AMOUNT OF PERSON PAID ON BEHALF OF LOBBYIST
�0
2. $
3.
4. $
(NOTE: ENTER "NONE" IF THERE WERE NO EXPENDITURES.)
414 f+,Y
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1
b. tiospltailhl Expenditures. '
NOTE: lbe dollar amount of expenses! If any, set forth in this Subsection
('Hospitality Expenditures) shag De Itemized, hereinbelow: .
LODGING MEALS,
ENTERTAINMENT NAME AND ADDRESS
I�ii 1 AMOUNT AND TRAVEL OF GUEST, IF ANY
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2. a
�.
a. s
Ill. Source of Funds.
NOTE: this portion of the lobbyist form shall contain the sources of the cited
expenditures.
NAME AND ADDRESS OF PERSON, FIRM, !
ITEM AND/OR ORGANIZATION MAKING FUNDS AVAILABLE
2.
9.
Lobbyist g a urso
State or Florlds On this the 2 day or 19 . berore me.
the undersigned ota llc or the to or lorida, personally appeared
7t7
County or. IName(s) of Indlvidual(s) who appeared before notaryl —�
NOTARY PUBLIC and whose name(s) Is/are subscribed to the within Instrument, and he/she/
SEAL OF OFFICE: they acknowledge that he/she/they executed It.
WITNESS my hano and o dal seal.
Rr Gs�% NOTARY PUBl.Z• S?A'(E OF FLORIDA
MWTAMEDEL
tOM1 0 Sfl0 NOTARY P BLIC, STATE OFF ()RID
^ti MAY �t%s
'••.� ++� (Name of Notary Public; rMnt. Stamp, or Type as Commissioned.)
•� 8TIpersonally known to me, or
® Produced Iderltincatlon:
`f (Type or Identitics,ion Produced)
{�j DID take an oath, or (] DID NOT lake an qqi r r