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Agenda 09/12/2023 Item #16K 3 (Written consent waiving any conflict that the Board may have with the law firm Baker, Donelson, Bearman, Caldwell & Berkowitz, P.C.)09/12/2023 EXECUTIVE SUMMARY Recommendation to approve and provide informed, written consent waiving any conflict that the Board may have with the law firm Baker, Donelson, Bearman, Caldwell & Berkowitz, P.C. (“Baker Donelson”), under its Retention Agreement with Baker Donelson to provide specialized FEMA services, regarding Baker Donelson providing unrelated representation to CitySwitch, LLC in connection with that entity’s efforts to seek proposed zoning and construction of a wireless facility to be located in Collier County. ____________________________________________________________________________________ OBJECTIVE: To obtain approval and authorization to provide a written waiver as to any conflict of interest relating to Baker Donelson, who currently represents the Board under a Retention Agreement to provide specialized Federal Emergency Management Agency (“FEMA”) legal services, so that Baker Donelson may represent CitySwitch, LLC in connection with that company’s efforts to seek proposed zoning and construction of a wireless facility to be located in Collier County. CONSIDERATIONS: The County Attorney's Office is recommending that the Board approve a written waiver of a conflict of interest allowing its retained specialized FEMA Counsel, Baker Donelson, to provide representation to its client CitySwitch, LLC in efforts to seek proposed zoning related to the future construction of a wireless facility to be located in Collier County. CitySwitch is a Georgia based privately held owner and developer of tower s and other specialized wireless infrastructure operating throughout the United States. CitySwitch is registered to do business in the State of Florida with the Department of State, Division of Corporations. On August 24, 2023, Baker Donelson contacted the County Attorney’s Office requesting the County provide a written waiver to a conflict of interest arising out of : (1) its representation of CitySwitch in connection with a proposed wireless facility to be located in Collier County, and on such future matters unrelated to the County; and (b) the continued representation of the County on present and future matters unrelated to the proposed wireless facility. A copy of Baker Donelson’s proposed informed consent to waiver of conflict correspondence dated August 24, 2023 is attached to this request. The Rules Regulating the Florida Bar (Rule 4-1.7) govern the conflict that arises as a result of Baker Donelson’s contractual relationship with the County under the current Retention Agreement (most recently extended on March 9, 2021 - Agenda Item 16.K.3) and its desired representation of CitySwitch. Although an attorney is generally prohibited from representing one client when the representation will be directly adverse to another client, the representation is allowable if each affected client gives its informed consent, confirmed in writing. Baker Donelson is not currently handling any FEMA matters under its Retention Agreement with the County but even if it were, such representation would not place it in a position that would be directly adverse to the County if Baker Donelson also represents CitySwitch on an unrelated wireless zoning petition before the County. The County Attorney’s Office reasonably believes Baker Donelson can provide competent and dili gent representation to the County and CitySwitch, that such representation is not prohibited by law, and does not materially impair Baker Donelson’s professional obligations to the County. The County Attorney's Office recommends that the Board consent to Baker Donelson’s representation of CitySwitch, LLC in connection with the proposed zoning and construction of a wireless facility to be located in the County, and that it authorize the Office of the County Attorney to sign and return the attached Waiver of Conflict Interest consent letter. FISCAL IMPACT: None. GROWTH MANAGEMENT IMPACT: There is no Growth Management Impact associated with this Executive Summary. LEGAL CONSIDERATIONS: This item is approved as to form and legality, and requires majority vote for Board approval.-SRT 16.K.3 Packet Pg. 1285 09/12/2023 RECOMMENDATION: That the Board approve and provide informed, written consent waiving any conflict that the Board may have with the law firm Baker, Donelson, Bearman, Caldwell & Berkowitz, P.C. under its Retention Agreement with Baker Donelson to provide specialized FEMA services, regarding Baker Donelson providing unrelated representation to CitySwitch, LLC in connection with that entity’s efforts to seek proposed zoning and construction of a wireless facility to be located in Collier County, and to authorize the Office of the County Attorney to sign and return the attached Waiver of Conflict of Interest correspondence. Prepared by: Scott R. Teach, Deputy County Attorney ATTACHMENT(S) 1. Baker Donelson waiver request to Collier County (PDF) 16.K.3 Packet Pg. 1286 09/12/2023 COLLIER COUNTY Board of County Commissioners Item Number: 16.K.3 Doc ID: 26497 Item Summary: Recommendation to approve and provide informed, written consent waiving any conflict that the Board may have with the law firm Baker, Donelson, Bearman, Caldwell & Berkowitz, P.C. (“Baker Donelson”), under its Retention Agreement with Baker Donelson to provide specialized FEMA services, regarding Baker Donelson providing unrelated representation to CitySwitch, LLC in connection with that entity’s efforts to se ek proposed zoning and construction of a wireless facility to be located in Collier County. Meeting Date: 09/12/2023 Prepared by: Title: Legal Assistant – County Attorney's Office Name: Rosa Villarreal 08/30/2023 4:14 PM Submitted by: Title: County Attorney – County Attorney's Office Name: Jeffrey A. Klatzkow 08/30/2023 4:14 PM Approved By: Review: County Attorney's Office Scott Teach Level 2 Attorney Review Completed 08/30/2023 4:18 PM County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 08/31/2023 8:36 AM Office of Management and Budget Debra Windsor Level 3 OMB Gatekeeper Review Completed 08/31/2023 3:54 PM Office of Management and Budget Christopher Johnson Additional Reviewer Completed 09/05/2023 11:24 AM County Manager's Office Amy Patterson Level 4 County Manager Review Completed 09/05/2023 12:57 PM Board of County Commissioners Geoffrey Willig Meeting Pending 09/12/2023 9:00 AM 16.K.3 Packet Pg. 1287 901 K STREET N.W., SUITE 900 WASHINGTON D.C. 20001 •••••••••••••••••••••••••••••••••••••••••••• • • • • • • • • • •••••••••••••••••••••••••••••••••••••••••••••••••••••• ALABAMA • FLORIDA • GEORGIA • LOUISIANA • MARYLAND • MISSISSIPPI • SOUTH CAROLINA • TENNESSEE • TEXAS • VIRGINIA • WASHINGTON, D.C. ERNEST B. ABBOTT Direct Dial: 202-508-3425 E-Mail Address: eabbott@bakerdonelson.com August 24, 2023 By Email: Scott.Teach@colliercountyfl.gov Scott R. Teach Deputy County Attorney Collier County, Florida 3229 Tamiami Trail East, 8th Floor Naples, FL 34112 Re: Waiver of Conflicts Dear Scott: Baker, Donelson, Bearman, Caldwell & Berkowitz, P.C. (Baker Donelson) has been asked to represent CitySwitch, LLC (“CitySwitch”) in connection with the proposed zoning and construction of a wireless facility to be located in Collier County, Florida (the “County”). As you know, Baker Donelson represents and has represented the county on a number of matters relating to eligibility for federal disaster assistance reimbursing of work or costs incurred by the County in responding to and recovering from major disasters declared by the President. We are writing this letter to request your written informed consent to (a) our representation of CitySwitch in connection with the proposed wireless facility, and on such future matters unrelated to the County; and (b) our continued representation of the County on present and future matters unrelated to the proposed wireless facility. As you know, the Florida Bar rules generally prohibit a lawyer from representing a client if the representation will be directly adverse to another client or there is a substantial risk that the representation will be materially limited by the lawyer's responsibilities to another client, a former client or a third person or by a personal interest of the lawyer. RPC 4-1.7(a). This general 16.K.3.a Packet Pg. 1288 Attachment: Baker Donelson waiver request to Collier County (26497 : Approve and provide informed written consent waiving conflict between Scott R. Teach August 24, 2023 Page 2 prohibition may be waived by clients’ informed written consent, provided that (1) the lawyer reasonably believes that the lawyer will be able to provide competent and diligent representation to each affected client; (2) the representation is not prohibited by law; and (3) the representation does not involve the assertion of a position adverse to another client when the lawyer represents both clients in the same proceeding before a tribunal. RPC 4-1.7(b). In accordance with the rules regulating The Florida Bar, our proposed representation of Cityswitch is conditioned upon both parties’ informed written consent to the engagement and waiver of potential conflicts. Separately, we have discussed our engagement with CitySwitch, explained the implications, and asked for its written consent. If CitySwitch declines to consent, then Baker Donelson will decline the matter and not represent it. We have concluded that our representation of CitySwitch in connection with the proposed wireless facility will not adversely affect or be adversely affected by our relationship with the County and that our representation of the County on unrelated FEMA disaster assistance issues will not adversely affect or be adversely affected by our relationship with CitySwitch. Our work for the County has involved seeking and protecting FEMA reimbursement of costs incurred by the County as a result of disasters and emergencies declared by the President. Accordingly, we may properly represent CitySwitch and the County as outlined herein so long as CitySwitch and the County waive the conflicts of interest and consent to the representation as outlined herein. Thank you for your assistance and cooperation. Please feel free to contact me if you have any additional questions. Very truly yours, BAKER, DONELSON, BEARMAN, CALDWELL & BERKOWITZ, PC Ernest B. Abbott, Of Counsel 16.K.3.a Packet Pg. 1289 Attachment: Baker Donelson waiver request to Collier County (26497 : Approve and provide informed written consent waiving conflict between Scott R. Teach August 24, 2023 Page 3 WAIVER OF CONFLICT OF INTEREST For purposes of Rule 4-1.7 of the Rules Regulating The Florida Bar, the undersigned, on behalf of Collier County, Florida, hereby consents to Baker Donelson’s representation of CitySwitch in connection with the proposed zoning and construction of a wireless facility to be located in Collier County. This waiver of conflict of interest is signed by me after consultation with Baker Donelson and consultation with the County’s other advisors regarding this matter. This waiver is granted under the authority delegated by the Board of County Commissioners to the County Attorney. Collier County, Florida By: _________________________ As its _______________________ Date: _______________________ 16.K.3.a Packet Pg. 1290 Attachment: Baker Donelson waiver request to Collier County (26497 : Approve and provide informed written consent waiving conflict between