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2. That the Defendant THE CITY OF LAUDERDALE LAKES
COMMUNITY REDEVELOPMENT AGENCY (hereinafter referred to as
LLCRA) is an entity created as both corporate and politic by the CITY
OF LAUDERDALE LAKES, pursuant to 163.356(1) Florida Statutes.
3. That the Defendants CITY OF LAUDERDALE LAKES (hereinafter
referred to as LLCITY or LAUDERDALE LAKES) is a municipal
corporation located entirely within Broward County, Florida.
4. That the Plaintiff LAW OFFICES OF DAVID A. FRANKEL, P.A. is a
professional association, incorporated and doing business in the State
of Florida and Broward County.
5. That Plaintiff TIMOTHY CHAZ STEVENS is a resident of Broward
County, and is otherwise sui juris.
FACTS COMMON TO ALL CAUSES OF ACTION
6. That LAUDERDALE LAKES and the LLCRA are both legal entities
subject to, and specifically included within the intended scope and
purpose of Chapter 119, Florida Statutes.
7. That pursuant to 119.01(1) Florida Statutes:
It is the policy of this state that all state, county, and municipalrecords are open for personal inspection and copying by anyperson. Providing access to public records is a duty of eachagency.
8. That the costs to be charged by Defendants for compliance of their duty
herein, associated with both copying and duplication in any medium,
are proscribed in 119.07, Florida Statutes, as follows:
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(4) The custodian of public records shall furnish a copy or acertified copy of the record upon payment of the fee prescribed bylaw.
If a fee is not prescribed by law, the following fees areauthorized:
1. Up to 15 cents per one-sided copy for duplicated copies ofnot more than 14 inches by 81/2inches;2. No more than an additional 5 cents for each two-sided
copy; and3. For all other copies, the actual cost of duplication of the
publicrecord.Actual cost of duplication is defined as the cost of the material and
supplies used to duplicate the public record, but does not include the labor cost
and overhead cost associated with such duplication. 119.011(1), Florida
Statutes.
9. ThatDefendants are further obligated by 119.07(1)(c) which states: a
custodian of public records and his or her designee must acknowledge
requests to inspect or copy records promptly and respond to such
requests in good faith. A good faith response includes making
reasonable efforts to determine from other officers or employees within
the agency whether such a record exists and, if so, the location at
which the record can be accessed.
10.That pursuant to Chapter 119, Florida Statutes, Defendants are
required to specifically state the basis upon which they refuse to
produce any records requested. Subsection 119.07(1)(e), FloridaStatutes states:
If the person who has custody of a public record contendsthat all or part of the record is exempt from inspection andcopying, he or she shall state the basis of the exemption thathe or she contends is applicable to the record, including the
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statutory citation to an exemption created or afforded bystatute.
11. That as more specifically set forth below Defendants have violated
Chapter 119, Florida Statutes in both word and spirit by failing to
provide transparency to municipal government function by:
a. failing to promptly acknowledge and respond to Plaintiffs requests
in good faith. 119.07(1)(c), Florida Statutes.
b. outright failure to produce records requested by Plaintiffs and/or
withholding records without citation or claim of any lawful
exemption. 119.07(1)(e), Florida Statutes.
c. attempting to thwart and restrain Plaintiffs from gaining access to
public records by imposing illegal fees and costs for duplication
and/or inspection thereof. 119.07(4), Florida Statutes.
Requests designated from Law Offices of David A. Frankel, P.A.
12. That during the period February 25, 2013 to May 12, 2013 Plaintiff, the
Law Offices of David A. Frankel, P.A. (Frankel) submitted to the
Defendants LLCRA, and LLCITY, three separate letters containing
multiple requests for public records within the scope and purview of
Chapter 119, Florida States. (each separate request treated separately
below)
(1st request)
13. That on February 25, 2013 Plaintiff submitted a public records request
pursuant to Chapter 119, Florida Statutes seeking records and
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materials pertaining to compensation or any monies paid to members of
the Board of Commissioners of the LLCRA as reimbursement for
expenditures made on behalf of the LLCR. 1 Pursuant to
163.356(3)(a), Florida Statutes, A commissioner shall receive no
compensation for services, but is entitled to the necessary expenses,
including travel expenses, incurred in the discharge of duties. (a copy
attached hereto as exhibit A)
14. That in response to this request for this material (herein after referred to
as reimbursement material) Defendants provided Plaintiffs with a CD
containing the written minutes of meetings for the years 2008 to 2012,
none of which contained any information remotely connected or
pertaining to what was requested.
15. That Defendants having failed to provide any material in response to
this request Plaintiffs made a second request on April 20, 2013 (copy
attached herein as exhibit B). Defendants still failing to comply with
this request Plaintiffs threatened suit, and on or about June 1, 2013
received partial compliance from Defendants; receiving incomplete
documentation of reimbursement for expenses made pursuant to
163.356(3)(a), Florida Statutes.
16. That also on February 25, 2013 Plaintiffs requested a copy of an audit
report commissioned by LLCITY and LLCRA regarding the
1The terms records and materials used in this complaint refer to the broadly statedlanguage in the requests themselves, i.e. all records, documents, notes ledgers, emails,lists, to capture all available information. See actual requests for specific informationrequested.
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disappearance of monies from the accounts of the LLCRA. This audit is
commonly referred to as the Kessler Report. Thereafter Defendants
provided to Plaintiffs a partial copy of the report, excluding without
explanation 61 exhibits referenced and contained in the report. These
exhibits were not made available until June 17, 2013 after Plaintiffs
threatened suit.
(2nd request)
17. That on April 5, 2013 Plaintiffs submitted a request to Defendants
pursuant to Chapter 119, Florida Statutes seeking copies of all
contracts entered into by the LLCRA for improvement or maintenance
projects in an amount greater than $50,000, for the years 2008 to the
present. (copy attached hereto as exhibit C) Defendants failed to
provide any material whatsoever in response to this request. After
demand and threat of suit by letter on June 6, 2013 Defendants
provided only two contracts and three purchase orders. Based on
credible information it is believed that Defendants have failed to fully
and lawfully comply with that request.
(3rd request)
18. That on April, 2013 Plaintiffs submitted a request to Defendants
pursuant to Chapter 119, Florida Statutes seeking copies of all
documents and communications for all LLCRA public requests for bid
offers pertaining to projects as described above in paragraph 17; as
well as all documents and communications pertaining to all reciprocal
bid offers received. Defendants have failed to provide any material in
response to this request.
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(4th request)
19. That on April 12, 2013 Plaintiffs submitted a request to Defendants
pursuant to Chapter 119, Florida Statutes seeking copies of all
documents and communications for projects as described above in
paragraph 17 where the LLCRA did not solicit any competitive bids.
This request also sought the names of all persons and/or entities with
whom the LLCRA entered into any such agreement formally or
informally. Defendants have failed to provide any material whatsoever
in response to this request.
(5th Request)
20. That on May 12, 2013 Plaintiffs submitted a request to Defendants
pursuant to Chapter 119, Florida Statutes seeking a real estate
appraisal conducted by the firm Anderson & Carr, Inc. submitted to
Defendants in connection with the sale of property owned by the
LLCRA and sold to the LLCity. This property is commonly referred to
as the Ireland property. In addition this same request sought all back-
up material regarding the acceptance and approval of the selling price
for that property including all memoranda, notes, emails and
communications.
21. Defendants have failed to provide any material whatsoever in response
to this request.
Requests designated from Timothy Chaz Stevens
(6th request)
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22. That on May 5, 2012 Plaintiff Timothy Chaz Stevens (Stevens)
submitted a request to Defendant LLCity pursuant to Chapter 119,
Florida Statutes seeking, since 2010, copies (NOT RESEARCH) of
City Manager Jon Allens City issued credit card statements.
23. That included in the information furnished to Stevens by LLCity
pursuant to the request set forth in paragraph 22 above were copies of
two months of credit card statements. Thus LLCity failed to furnish at
least 38 months of credit card statements for the card issued to City
manager Jon Allen as requested. Additionally LLCity failed to claim any
exemption for the records withheld as required by 119.07(e), Florida
Statutes.
(7th request)
24. That on August 16, 2012 Plaintiff Stevens made a public records
request to the City pursuant to Chapter 119, Florida Statutes, stating:
For the past year, copies of all emails sent from Hazeline Carson to
me. I am looking for an electronic archive. In response to this request
Stevens received copies of 25 emails. Based on personal knowledge
and electronic data Stevens alleges herein that LLCity has failed to
comply with this request by withholding the remaining requested
emails. Additionally LLCity failed to claim any exemption for the records
withheld as required by 119.07(e), Florida Statutes.
(8th request)
25. That on or about late 2011 or early 2012 Plaintiff Stevens made a
separate request to LLCity pursuant to Chapter 119, Florida Statutes,
seeking to inspect :
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a. all employments files of female subordinates of City Manager
Jonathan Allen (including department heads).
b. for the preceding three years, all travel records of those female
subordinates and City Manager Jonathan Allen.
c. for the preceding three years, all salary increases granted to those
female subordinates.
27. That in response to the request to inspect the material set forth in paragraph
26 above, Stevens was informed by LLCity that prepayment of $776.65
would be required for the inspection.
(9th request)
28. That on or about late 2011 or early 2012 Plaintiff Stevens made a separate
request to LLCity pursuant to Chapter 119, Florida Statutes, seeking to
inspect copies of LLCity records pertaining to disciplinary action(s) related to:
a. any complaints filed by former employee Sue Campbell with regards to
possible inappropriate contact between Jonathan Allen and female
staffers.
b. filed against former employee Sue Campbell
c. any complaints filed by former employee Geri Peterkin with regards to
possible inappropriate contact.
29. That in response to the public records request to inspect the material set
forth in paragraph 28 above, Stevens was informed that prepayment of
$180.00 would be required for the inspection
(10th request)
30. That on or about late 2011 or early 2012 Plaintiff Stevens made a separate
request to the City pursuant to Chapter 119, Florida Statutes, seeking
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during that period, 3 months of records, for July, August and September of
2010 were not provided. Additionally, of the remaining 56 months of
records provided, 35 were incomplete; missing available information
identifying to whom reimbursements were made.
b. complete documentation for at least 21 instances of payments to
Commissioners and/or staff of the LLCRA.
c. all LLCRA bank or credit card records, statements and receipts for each
person issued, authorized, or who used such a bank or credit card, for the
years 2008 until the present per the request.
40. That by failing to acknowledge Plaintiffs request, failing to comply with the
request promptly and without unnecessary delay, and by failing to provide all
available public information in regard to this request Defendants have
violated Chapter 119, Florida Statutes.
COUNT II(2nd request)
(violation of Chapter 119, Florida Statutes)
41. That Plaintiffs re-allege and incorporate by reference paragraphs 1 though 39
above as if specifically set forth herein.
42. That on April 5, 2013 Plaintiffs specifically requested:
a complete and accurate list of all contracts entered into bythe LLCRA for any construction services or material, or otherservices; including maintenance, refitting, refurbishing, or anysimilar activity, for projects approved, undertaken (jointly orsingularly) or sanctioned by the LLCRA for more that $50,000for the years 2008 until present.
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Defendants failed to respond to the request or claim any statutory
exemption, and did not produce any material in accord therewith.
After a second request and threat of suit, Defendants on June 17,
2013, did furnish Plaintiffs with:
a. a list of three projects with corresponding purchase orders:
i. 2010 IBI Group, Inc. 9/22/2010 $57500 Town Center
ii. 2012 Cornerstone Paving 6/1/12 $125,000 parking lot
iii. 2012 Arje Holdings LLC 5/30/12 $250,000 BM&F
b. copies of two contracts:
i. October 19, 2010 Commercial Faade Improvement ProgramLoan Agreement
ii. February 8, 2012 Lauderdale Lakes CRA Contract forConstruction of Library Parking Lot.
43. That based on common knowledge of LLCRA activity since 2008 there
exist multiple projects falling into the parameters set forth in paragraph
41 above for which Defendants failed to provide public information.
44. That by failing to acknowledge Plaintiffs request, failing to comply with the
request promptly and without unnecessary delay, and by failing to provide all
available public information in regard to this request Defendants have
violated Chapter 119, Florida Statutes.
COUNT III(3rd request)
(violation of Chapter 119, Florida Statutes)
45. That Plaintiffs re-allege and incorporate by reference paragraphs 1 though
43 above as if specifically set forth herein.
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50. That by failing to acknowledge Plaintiffs request, failing to claim any statutory
exemption, and failing to comply with the request promptly and without
unnecessary delay Defendants have violated Chapter 119, Florida Statutes.
COUNT V(5th request)
(violation of Chapter 119, Florida Statutes)
51. That Plaintiffs re-allege and incorporate by reference paragraphs 1 though 49
above as if specifically set forth herein.
52. That on May 12, 2013 Plaintiffs submitted to Defendants a public records
request pursuant to Chapter 119, Florida Statutes seeking:
A copy of the real estate appraisal conducted by Anderson andCarr, Inc. for the Ireland property upon which the LLCRA basedits offer of purchase price.
and further
all back up material regarding the acceptance and approval ofthe appraisal value determined by Anderson & Carr for thepurchase of this property. This should include all memoranda,notes, emails, and communications.
Defendants have failed to acknowledge this request, claim statutory
exemption, or to comply with this request.
53. That by failing to acknowledge Plaintiffs request, failing to claim any statutory
exemption, and failing to comply with the request promptly and without
unnecessary delay Defendants have violated Chapter 119, Florida Statutes.
COUNT VI(6th request)
(violation of Chapter 119, Florida Statutes)
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54. That Plaintiffs re-allege and incorporate by reference paragraphs 1 though 52
above as if specifically set forth herein.
55. That as stated above in paragraph 22 Plaintiffs sought credit card records for
cards issued to City manager Jonathan Allen since 2010. In contravention of
Florida public record laws Defendants failed to comply with Plaintiffs lawful
request by withholding a substantial portion of the records without having
claimed any lawful exemption. Additionally, Defendants sought to prevent
Plaintiffs access to the information sought by imposing an unlawful charge
intended to dissuade Plaintiffs from pursuing their request.
56. That by failing to furnish all the records sought, failing to claim any statutory
exemption for the material withheld, and by attempting to prevent Plaintiffs
access to the information with an artificially and/or unlawful fee, Defendants
have violated Chapter 119, Florida Statutes.
COUNT VII(7th request)
(violation of Chapter 119, Florida Statutes)
57. That Plaintiffs re-allege and incorporate by reference paragraphs 1 though
55 above as if specifically set forth herein.
58. That as previously set forth with particularity in paragraph 25 above Plaintiffs
have sought complete public records encompassing all emails between
Hazeline Carson and Plaintiff Stevens. Plaintiffs have personal knowledge
that the 25 emails produced in response to this request is not complete and
that Defendants have failed to fully comply.
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59. That having failed to fully comply with the request for these emails and
having not claimed any legal exemption for the materials withheld
Defendants have violated Chapter 119, Florida Statutes.
COUNT VIII(8th request)
(violation of Chapter 119, Florida Statutes)
60. That Plaintiffs re-allege and incorporate by reference paragraphs 1 though
58 above as if specifically set forth herein.
61. That as previously set forth with particularity in paragraph 26 above Plaintiffs
sought to inspect the personnel files, salary increases and travel records of
specified employees, designated as female subordinates of City Manager
Jon Allen.
62. That in response to that request Defendants have sought to unlawfully
prevent the inspection of these records by demanding an unreasonable and
artificially created fee that must be paid by Plaintiffs.
63. That Defendants attempt to prevent or dissuade Plaintiffs from the inspection
of these public records be imposition of an unlawful fee is a violation of
Chapter 119, Florida Statutes.
COUNT IX(9th request)
(violation of Chapter 119, Florida Statutes)
64. That Plaintiffs re-allege and incorporate by reference paragraphs 1 though
62 above as if specifically set forth herein.
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65. That as previously set forth with particularity in paragraph 28 above Plaintiffs
sought records form Defendants department of Human Resources, or other
custodian, of complaints involving two female subordinates of City Manager
Jon Allen, either by or against those employees.
66. That in response to that request Defendants have sought to unlawfully
prevent Plaintiffs from gaining access to these records by demanding an
unreasonable and artificially created fee that must be paid by Plaintiffs.
67. That Defendants attempt to prevent or dissuade Plaintiffs from the inspection
of these public records by imposition of an unlawful fee is a violation of
Chapter 119, Florida Statutes.
COUNT X(10th request)
(violation of Chapter 119, Florida Statutes)
68. That Plaintiffs re-allege and incorporate by reference paragraphs 1 though
66 above as if specifically set forth herein.
69. That as previously set forth with particularity in paragraph 30 above Plaintiffs
sought copies of emails that contained one or more words specified therein.
70. That in response to that request Defendants have sought to unlawfully
prevent Plaintiffs from gaining access to these emails by demanding an
unreasonable and artificially created fee that must be paid by Plaintiffs.
71. That Defendants attempt to prevent or dissuade Plaintiffs from gaining
access to these public records by imposition of an unlawful fee is a violation
of Chapter 119, Florida Statutes.
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COUNT XI(11th request)
(violation of Chapter 119, Florida Statutes)
72. That Plaintiffs re-allege and incorporate by reference paragraphs 1 though
70 above as if specifically set forth herein.
73. That as previously set forth with particularity in paragraph 32 above Plaintiffs
sought copies of credit card statements for Defendant LLCitys purchases
from seven retail vendors with whom City does business.
74. That in response to that request Defendants have sought to unlawfully
prevent the inspection of these records by demanding an unreasonable and
artificially created fee that must be paid by Plaintiffs.
75. That Defendants attempt to prevent or dissuade Plaintiffs from the inspection
of these public records by imposition of an unlawful fee is a violation of
Chapter 119, Florida Statutes.
COUNT XII(12th request)
(violation of Chapter 119, Florida Statutes)
76. That Plaintiffs re-allege and incorporate by reference paragraphs 1 though
74 above as if specifically set forth herein.
77. That as previously set forth with particularity in paragraph 34 above Plaintiffs
sought to inspect the personnel file of City Manager Jonathan Allen.
78. That in response to that request Defendants have sought to unlawfully
prevent the inspection of these records by demanding an unreasonable and
artificially created fee that must be paid by Plaintiffs.
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79. That Defendants attempt to prevent or dissuade Plaintiffs from the inspection
of these public records by imposition of an unlawful fee is a violation of
Chapter 119, Florida Statutes.
COUNT XIII(13th request)
(violation of Chapter 119, Florida Statutes)
80. That Plaintiffs re-allege and incorporate by reference paragraphs 1 though
78 above as if specifically set forth herein.
81. That as previously set forth with particularity in paragraph 34 above Plaintiffs
sought an electronic copy the personnel file of Citys employee Marie Elianor.
82. That in response to that request Defendants have sought to unlawfully
prevent access to the personnel file of Marie Elianor by demanding an
unreasonable and artificially created fee that must be paid by Plaintiffs.
83. That Defendants attempt to prevent or dissuade Plaintiffs from gaining a copy
of these public records by imposition of an unlawful fee is a violation of
Chapter 119, Florida Statutes.
COUNT XIV
(equitable relief)
84. That Plaintiffs re-allege and incorporate by reference paragraphs 1 though
78 above as if specifically set forth herein.
85. That Plaintiffs herein seek to invoke the equitable jurisdiction of this Court for
issuance of a Writ of Mandamus compelling Defendants to immediate
release forthwith, and make available to Plaintiffs all materials sought.
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86. That Defendants should be mandated to release, produce, and make
available, each and every record, document, memorandum, report, list, item,
file and/or material requested by Plaintiffs as specifically set forth above in
their entirety.
87. That equitable relief in this fashion is needed to prevent Defendants from co
violating the mandates of Chapter 119, Florida Statutes in a continuing effort
to avoid transparency in government both now and in the future.
COUNT XV
(equitable relief)
88. That Plaintiffs re-allege and incorporate by reference paragraphs 1 though
85 above as if specifically set forth herein.
89. That Plaintiffs herein seek injunctive relief from the Court, and for issuance of
a Writ of Prohibition to prevent further violation of 119.07(4) and
119.011(1), Florida Statutes, compelling Defendants to cease the imposition
of unlawful and exorbitant fees in conjunction with Plaintiffs public records
requests.
90. That without this equitable relief the Defendants will continue to use this
method of obstruction in an ongoing attempt to prevent Plaintiffs access to
public records.
COUNT XVI
(equitable relief)
91. That Plaintiffs re-allege and incorporate by reference paragraphs 1 though
89 above as if specifically set forth herein.
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b. injunctive relief enjoining Defendants from further obstruction, and violation
of Chapter 119, Florida Statutes upon further presentation of public records
requests by Plaintiffs.
c. Imposition of self executing penalties to be assessed against Defendants
for future violation of any public records request by Plaintiffs.
d. calculation of copying fees to be charged for the records requested
previously and henceforth, based solely on the actual cost of duplication
as required by law.
e. damages in an amount equal to unlawful fees previously paid by Plaintiffs
for records received.
f. assessment of all reasonable costs and attorneys fees to be paid by
Defendants
g. all other relief as the Court deems proper and just.
Submitted this 28th day of June, 2013 by,
/s/ David A. Frankel
DAVID A. FRANKEL,Esq.
Law Offices of David A. Frankel, P.A.20 South Esat 20th StreetFort Lauderdale, Florida 33316
(954) 557-2244Fla. Bar No. 741779designated email- [email protected]
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IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUITIN AND FOR BROWARD COUNTY
LAW OFFICES OF DAVID A. FRANKEL, P.A.
a Florida professional association, and
TIMOTHY CHAZ STEVENSan individual,
Case No:Plaintiffs
Div:vs.
THE CITY OF LAUDERDALE LAKES,
a municipal corporation, and
THE CITY OF LAUDERDALE LAKES,COMMUNITY REDEVELOPMENT AGENCY,
a corporate municipal subdivision
Defendants._______________________________________/
SUMMONSService on a municipal corporation
TO: Mr. Jonathan Allen as City Manager, of and forCity of Lauderdale Lakes4300 NW 36th StreetLauderdale Lakes, FL 33319
IMPORTANT
A lawsuit has been filed against you. You have 20 calendar days after thissummons is served on you to file a written response to the attached Complaint inthis Court. A phone call will not protect you; your written response including theabove case number and named parties, must be filed if you want the Court tohear your case. If you do not file your response on time, you may lose the case,and your wages, money, and property may thereafter be taken without furtherwarning from the Court. There are other legal requirements. You may want tocall an attorney referral service or a legal aid office listed in the phone book).
If you choose to file a written response yourself, at the same time you fileyour written response to the Court, you must also mail or take a carbon copy or
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photocopy of your written response to the Plaintiff/Plaintiffs Attorney namedbelow.
DAVID A. FRANKEL, ESQUIRE20 South east 20th Street
Fort Lauderdale, Florida 33316(954) [email protected]
THE STATE OF FLORIDA
TO EACH SHERIFF OF THE STATE: You are commanded to serve thisSummons and a copy of the Complaint in this lawsuit on the above-named
Defendant.
DATED ON _________________________, 2013
HOWARD C. FORMAN
By:______________________________Deputy Clerk
(SEAL)
IN ACCORDANCE WITH THE AMERICANS WITH DISABILITIES ACT OF1990 (ADA), DISABLED PERSONS WHO, BECAUSE OF THEIRDISABILITIES, NEED SPECIAL ACCOMMONDATION TO PARTICIPATE INTHIS PROCEEDING SHOULD CONTACT THE ADA COORDINATOR AT 201SE 6TH STREET, ROOM 136, FORT LAUDERDALE, FLORIDA 33301 ORTELEPHONE VOICE/TDD (954) 831-6364 NOT LATER THAN FIVE BUSINESSDAYS PRIOR TO SUCH PROCEEDING.
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IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUITIN AND FOR BROWARD COUNTY
LAW OFFICES OF DAVID A. FRANKEL, P.A.
a Florida professional association, and
TIMOTHY CHAZ STEVENSan individual,
Case No:Plaintiffs
Div:vs.
THE CITY OF LAUDERDALE LAKES,
a municipal corporation, and
THE CITY OF LAUDERDALE LAKES,COMMUNITY REDEVELOPMENT AGENCY,
a corporate municipal subdivision
Defendants._______________________________________/
SUMMONSService on a municipal corporation
TO: Mr. Gary Rogers, Executive Director, of and forCity of Lauderdale Lakes Community Redevelopment Agency4300 NW 36th Street
Lauderdale Lakes, FL 33319
IMPORTANT
A lawsuit has been filed against you. You have 20 calendar days after thissummons is served on you to file a written response to the attached Complaint inthis Court. A phone call will not protect you; your written response including theabove case number and named parties, must be filed if you want the Court to
hear your case. If you do not file your response on time, you may lose the case,and your wages, money, and property may thereafter be taken without furtherwarning from the Court. There are other legal requirements. You may want tocall an attorney referral service or a legal aid office listed in the phone book).
If you choose to file a written response yourself, at the same time you fileyour written response to the Court, you must also mail or take a carbon copy or
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photocopy of your written response to the Plaintiff/Plaintiffs Attorney namedbelow.
DAVID A. FRANKEL, ESQUIRE20 South East 20th Street
Fort Lauderdale, Florida 33316(954) [email protected]
THE STATE OF FLORIDA
TO EACH SHERIFF OF THE STATE: You are commanded to serve thisSummons and a copy of the Complaint in this lawsuit on the above-named
Defendant.
DATED ON _________________________, 2013
HOWARD C. FORMAN
By:______________________________Deputy Clerk
(SEAL)
IN ACCORDANCE WITH THE AMERICANS WITH DISABILITIES ACT OF1990 (ADA), DISABLED PERSONS WHO, BECAUSE OF THEIRDISABILITIES, NEED SPECIAL ACCOMMONDATION TO PARTICIPATE INTHIS PROCEEDING SHOULD CONTACT THE ADA COORDINATOR AT 201SE 6TH STREET, ROOM 136, FORT LAUDERDALE, FLORIDA 33301 ORTELEPHONE VOICE/TDD (954) 831-6364 NOT LATER THAN FIVE BUSINESSDAYS PRIOR TO SUCH PROCEEDING.