HomeMy WebLinkAboutItem #57 - Discussion Item0 Mutt.41
1991 APR -5
f JORGE L. FERNANDEZ (Q) 599
City Attorney . ""';,;; Telecopier: (3051 579.3399
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
11
April 4, 1991
Kent Harrison Robbins, Esquire
1124 Washington Avenue
Miami Beach, Florida 33139
Re: Carol Joseph v. City of Miami, et al
USDC Case No. 89-1233-Civ-ARONOVITZ
Your letter dated March 25, 1991 .
Dear Mr. Robbins:
This is in response to your request that a copy of your
letter dated March 25, 1991 containing your settlement demand be
forwarded to the Mayor and Commission for their consideration. I
have taken the liberty of following protocol by forwarding the
letter to the City Manager's Office, which schedules all public
hearings and personal appearances before the Commission. Someone
from the City Manager's Office will be in contact with you
relative to when you are to appear before the Commission.
In forwarding your request to appear before the City
Commission, please be advised that this office will advise the
City Commission, as it has in the past, not to discuss this
matter in the context of a public meeting in that there is
ongoing litigation. For strategic reasons, any such discussions
would be detrimental to the interests of the City and wholly
inappropriate given the posture of the case.
In regard to your settlement demand, let me add that it is
one of the most absurd requests that I have ever read, especially
in light of the fact that it is my understanding that your client
was ultimately found guilty on one of the drug charges resulting
in his probation on the burglary charge being violated. Under
these facts and for a variety of other reasons, there is no basis
in law or in fact for your damage claim as stated in your letter.
OFFICE OF THE CITY ATTORNEY/1100 AmeriFirst Building/One Southeast Third Avenue/Miami, Florida 33131
..I1SGVSS100i
91- 543-1
Page 2 April 41'1991
Kent Harrison Robbins,.Esquire Carol Joseph v. City
Notwithstanding my position on the matter, I will forward
your request to the City Manager for further action. -�
LMF/cm/P127
cc: Jorge L. Fernandez, City Attorney
Cesar H. Odio, City Manager
OW M . 1'�'
sistanCity Attorney
91-- 543.1
Z
KENT HARRISON ROBBINS
ATTORNEY AT LAW
1224 WASHINGTON AVENUE
MIAMI BEACH, FLORIDA 33139
(305) 532-0500
March 25, 1991
C
M48 16 10 27 4W
91
Leon M. Firtel
Assistant City Attorney
1000 Amerifirst Building
One Southeast Third Avenue
Miami, Florida 33131
Re: Joseph v. City of Miami
Case No. 89-1233-CTV-Aronovitz
Dear Mr. Firtel,
This letter is written for settlement purposes only.
Carol Joseph will settle his case against the City
of
Miami and
its employees'as follows:
1. For wrongful police shooting
$
250,000.00
2. For unconstitutional police
interrogation
$
25,000.00
3. For illegal police search and seizure of
home
$
25,000.00
4. For unconstitutional interference with
right to subpoena witnesses
$
25,000.00
5. For unconstitutional interference with
right to a jury trial
$
25,000.00
6. For attorney fees
$
175,000.00
7, For costs
$
25,000.00
This offer is open for ten (10) days from your receipt of this
letter.
91- 543- t
..
Leon M. Firtel
March 25, 1951
Page 2
Please promptly forward a copy of this letter to the Mayor and
Commission for their consideration. I also request that you
place this settlement offer on the Commission agenda and advise
me of the date of hearing.
V tru ours,
a4-1
ENT H ISON ROBBINS
KHR:dr
Certified mail - return receipt requested