CEB Minutes 12/13/1996
1996
Code
Enforcement
Board
December 13, 1996
December 13, 1996
TRANSCRIPT OF THE MEETING OF THE
CODE ENFORCEMENT BOARD
Naples, Florida, December 13, 1996
LET IT BE REMEMBERED, that the Collier County Code Enforcement
Board met on this date at 8:35 a.m. in REGULAR SESSION in Building "F"
of the Government Complex, East Naples, Florida, with the following
members present:
CHAIRPERSON: M. Jean Rawson
Jim Allen
Mireya Louviere
Celia Deifik
Louis Laforet
Richard McCormick
ABSENT: Charles Andrews
ALSO PRESENT:
Ramiro Manalich, Chief Asst. County Attorney
Shirley Jean McEachern, Asst. County Attorney
Maria E. Cruz, Code Enforcement Specialist
Vince Cautero, Community Development and Enviromental
Services Administrator
Linda Sullivan, Code Enforcement Director
Frank X. Kowalski, Esq., Attorney for the CEB
William Hazzard, Esq., Attorney for LBBPOA
Page 1
December 13, 1996
CHAIRPERSON RAWSON: We'll go on the record now. The
Collier County Code Enforcement Board will come to order. Let's have
the roll call starting with my left.
MR. McCORMICK: Richard McCormick.
MR. LAFORET: Lou Laforet.
MS. DEIFIK: Celia Deifik.
CHAIRPERSON RAWSON: Jean Rawson.
MS. LOUVIERE: Mireya Louviere.
MR. ALLEN: Jim Allen.
CHAIRPERSON RAWSON: For the record, Charlie Andrews,
our other board member, called me this morning at 7:30, and he is ill
and cannot be here today. Fortunately, we have the rest of the board
here today; so we can at least have a quorum. I realize, of course,
that he's one of the four that was hearing the case of Board of County
Commissioners versus Lely Barefoot Beach Property Owners' Association,
but he is unable to be here today, which sort of points out our
continuing frustrations with having a four-person board hearing
something. He apologizes, and I believe he's really ill.
So the purpose of the meeting today, as announced
yesterday, is to ascertain several issues. And you attorneys can
correct me if I'm wrong, but I think the issues are: number one,
whether the seven-person board will hear this case or whether you want
to go back and have the same four-person board -- that's been a
problem getting all four of us together -- continue to hear the rest
of this case. And assuming we get past that first issue, the second
issue would be whether the board that hears it is going to start over,
if it was the seven-person.board, or read the transcripts from the
first day's testimony and that I'm sure we'll have legal opinions from
each-side on both of those issues, and the board's attorney will
advise us as well. So the county, I guess, we'll start with you, your
position on those issues.
MR. MANALICH: Good morning, Madam Chairman, members of
the board, opposing counsel. For the record, Ramiro Manalich, chief
assistant county attorney, along with Shirley Jean McEachern,
assistant county attorney. I had been requested by Miss Sullivan that
either Mr. Cautero, the development services director, or herself
could make a brief comment prior to my beginning, if that's okay with
the board and opposing counsel.
MR. HAZZARD: I object. I have absolutely no idea what
the -- the purpose of this would be. If it's related to this case,
then I would suggest that we get on with the matter that's before the
board on this case today in the method that we anticipated doing it
yesterday. If it's unrelated to this case -- and certainly the board -
needs to hear from these folks in relate -- in relation to some
housekeeping matter -- then certainly the board should hear it.
MR. MANALICH: I think it's in relation to the
scheduling of this matter; is that correct, Mr. Cautero?
MR. CAUTERO: That's correct, Madam Chairman.
CHAIRPERSON RAWSON: It's not -- in regard to the
scheduling of this matter and those board members who were not here
yesterday, be advised that we've found about five days in January to
Page 2
December 13, 1996
hear this case which we'll discuss later, especially if you're going
to hear this case. But at any rate, Mr. Hazzard, apparently it has to
do with the scheduling of this particular case. In view of that, do
you still have an objection to his making a comment?
MR. HAZZARD: Why don't we do it at the appropriate time
after the -- the attorneys have done what it is that you've asked us
to come here to do today.
CHAIRPERSON RAWSON: Any response?
MR. MANALICH: I think that's at your discretion, Madam
Chairman, as you know, the limited nature of the request that Mr.
Cautero has made.
CHAIRPERSON RAWSON: Well, I --
MR. MANALICH: Because I would just mention one other
thing, which is under the ordinance, 92-80, the code enforcement
official, which he is the ultimate person in that regard as Miss
Sullivan's supervisor, does have the ability to request of the
chairman and the board matters of scheduling hearings. So I would
cite that as my authority for him to begin this morning on that
limited scope.
CHAIRPERSON RAWSON: Well, in terms of scheduling this
matter, you know, I'm -- I'm happy to hear what he -- he has to say;
so why don't you go ahead.
MR. CAUTERO: Thank you, ma'am. Vince Cautero for the
record, community development and environmental services
administrator. One of the issues that I talked with Mr. Manalich
about and my code enforcement staff was to attempt to resolve the
matter as quick as possible, and I know that the board wants to do
that as well. My recommendation to you would be to vote in the
affi~ative to allow the entire board to be eligible to be able to
hear this matter.
MR. HAZZARD: Madam Chairman, this is entirely out of
line. This is not about scheduling. This is an opinion of what the
board should do, and this is an attempt to influence the board through
some sort of testimony by a county official. I would strenuously
object and renew my objection to this line of commentary.
CHAIRPERSON RAWSON: Well, in terms of your presentation
of your argument to Mr. Manalich for or against the issue, whether or
not the full board or the four-person board, you certainly have the
right to call him as a witness. Why don't we do it that way.
MR. MANALICH: Mr. Cautero, do you want to proceed in
that manner, or do you want me to simply address the board on the
limited issues first and then return to you?
MR. CAUTERO: Well, I just want to make a statement. My
- recollection from reading the ordinance is that this is not a court of
law. This is a board under the direction of the Board of County
Commissioners. And my frustration is becoming increasingly apparent,
and I would just like to make a statement to this board and make a
request. And if I can't do that in a very professional manner, then
what is my role here? That's all I'll attempt to do; so I'd like to
proceed.
MR. MANALICH: Why don't we swear him in then as a
Page 3
December 13, 1996
witness.
MR. CAUTERO:
MR. MANALICH:
Pardon me?
I think the chairman has mentioned that
CHAIRPERSON RAWSON: It's a good idea.
MR. MANALICH: -- to have you sworn in.
CHAIRPERSON RAWSON: To have you sworn in and identify
yourself by name and position, and then say what you want to say.
THEREUPON,
VINCENT CAUTERO,
a witness, having been first duly sworn, upon his oath, testified as
follows:
DIRECT EXAMINATION
BY MR. MANALICH:
Q. Good morning. Please state your name for the record.
A. Vincent Cautero.
Q. Mr. Cautero, how are you employed?
A. I'm employed by Collier County government as their
community development and environmental services administrator.
Q. In that capacity do you exercise supervisory function
over Ms. Sullivan as code enforcement director?
A. I do.
Q. Are you aware that under Ordinance 92-80 the code
enforcement official, whom you supervise, has the ability to address
the board and/or the chairman with regard to scheduling of code
enforcement matters?
A. I am.
Q. And is -- are you here in that capacity today?
A~-.' Yes, sir.
Q. Okay. Do you have a brief statement that you'd like to
make regarding the scheduling of this matter?
A. Yes, I would. I had a discussion with -- several
discussions with my superior, Mr. Neil Dorrill, who has requested that
I request of this board that the case be heard as soon as possible and
brought to closure. And my request of you is to attempt to schedule
this meeting either next -- this hearing next week or the first week
in January and attempt to bring it to closure. Staff will -- will be
available for all these hearings; I will see to that. And we will
attempt to find a meeting room if this room is not available.
The Board of County Commissioners has requested of me as
well that the -- the hearing be brought -- be brought to closure, and
I'm sure that you're aware of that, too, from your discussions with
staff as well as perhaps what you read in the media. So I -- I would-
just urge you to try to bring this this case to closure as soon as
possible, and that's the nature of my request, and thank you for
hearing me.
CHAIRPERSON RAWSON: Thank you.
Q. Do you have anything else to add, or is that all?
A. That's all.
MR. MANALICH: Okay. Madam Chairman, I don't know if
Mr. Hazzard has any cross-examination.
Page 4
December 13, 1996
MR. HAZZARD: I have just a few questions.
CROSS-EXAMINATION
BY MR. HAZZARD:
Q. Mr. Cautero, you mentioned that the Board of County
Commissioners has requested you to make this statement here this
morning?
A. No, sir.
Q. Okay. What exactly was it the Board of County
Commissioners had requested you to --
MR. MANALICH: Objection, Your Honor. That's
mischaracterizing the testimony. I believe he mentioned the county
manager.
MR. HAZZARD: I distinctly heard you mention the Board
of County Commissioners, did you not?
A. Yes, I said the Board of County Commissioners.
Q. And my question is, what is it that the Board of County
Commissioners has requested you to do?
A. The Board of County Commissioners wishes for the docket
for the Code Enforcement Board to be cleared as soon as possible.
Q. Okay. You also mentioned discussions that staff has had
with members of this board, and what discussions were you referring to
about that?
MR. MANALICH: Objection. I don't recall that testimony
either.
Q. Do you recall mentioning discussions just a few moments
ago that staff has had with members of this board?
A. Yes.
Q. And would you please tell me what discussions you're
referring to that ~he code enforcement staff has had with members of
this board?
A. A conversation I had with Miss Rawson.
Q. Is it your understanding that members of the Code
Enforcement Board staff are allowed to communicate with members of
this board about the subject matter of this case outside of the public
forum?
A. I was referring to my conversation with Miss Rawson.
MR. HAZZARD: I have nothing further. Thank you.
MR. MANALICH: Madam Chairman, redirect.
REDIRECT EXAMINATION
BY MR. MANALICH:
Q. Mr. Cautero, your contact with Miss Rawson was in
regards to scheduling; is that not correct?
A. That's correct.
Q. It was no.t about the substance of this case?
A. No, sir.
MR. MANALICH: Thank you.
CHAIRPERSON RAWSON: Well, I have one further question,
and that conversation that we had was five minutes ago in the hall
walking into this room; is that correct?
MR. CAUTERO: Yes, ma'am.
CHAIRPERSON RAWSON: Thank you.
Page 5
December 13, 1996
MR. MANALICH: Madam Chairman, if I could then at this
point just address the three issues you had mentioned allowing for
Mr. Hazzard to respond after that. Obviously you've heard from the
code enforcement official supervisor regarding the need and the
frustration -- regarding need for closure in this case, and obviously
you're well aware of that. This matter has been pending since July of
this year and for various reasons has still dragged on to this point.
Mr. Andrews' illness today and the absence yesterday
illustrates what we think amounts to impossibility of having this
hearing with the four members. At this point we believe the proper
course and what we would recommend to this board is to reinstitute the
seven-member board for this case. That will assure that we can
achieve a quorum. In addition, we believe that the case should be
commenced over again with presentation of witnesses from the
beginning. However, anticipating objection from opposing counsel,
what we would suggest to be maximum in fairness here would be that we
allow, if that is opposing counsel's request, for the transcript of
the one-day hearing that was held in July to be admitted into evidence
in this case even though we're going to start over, and that .
transcript could be used by either side for impeachment or for
substantive evidence, whatever is preferred.
We would also echo Mr. Cautero's comments with regard to
proceedings on this quickly, and we would suggest that next week,
which is the week prior to the Christmas holiday week, would be the
most appropriate and that we would suggest that would be the date. We
believe, anticipating objection that was mentioned yesterday, that any
prejudice here really washes out because, if anything, we believe the
county was more prejudiced by this sequence of events than the
responaent. It is the county that is seeking enforcement. The
respondent, I think, is quite happy with the status quo. The county
has waited patiently.
In addition, in -- in an evidentiary regard, the county
has, I think, been, if anything, more prejudiced because we are the
ones that our case in chief was revealed. The only thing that I think
opposing counsel has lost is possibly some cross-examination, and
we're even willing to allow that to come in as it originally occurred
through the transcript. So we believe -- and Mr. Kowalski and
Mr. Hazzard will have to respond on the case law, but we would cite
two cases that have been shared among all of the counsel here this
morning, and that is Veasey versus Board of Public Instruction of Palm
Beach County found at 247 So. 2d, 80; and Sheffey versus Futch found
at 250 So. 2d, 907, for the point that these cases hold that even when
board members are absent .for a case, they could even review a
transcript and based on that transcript reach a decision. Here
obviously we're not even going that far. We're saying let's just
start anew and have all the board members listen to this. Thank you.
MR. LAFORET: Counsel--
MR. MANALICH: Oh, one other comment.
MR~ LAFORET: May I ask Mr. Cautero a question? I
realize that -- may I ask him a question?
MR. MANALICH: Let me just -- yes. That will be up to
Page 6
December 13, 1996
the chairman, Mr. Laforet.
MR. LAFORET: Mrs. Chairman.
MR. MANALICH: If I can just make one other point and
then get out of the way --
CHAIRPERSON RAWSON: Go ahead.
MR. MANALICH: which is I want to emphasis, because
these cases do address -- at least the Veasey case does address moving
forward on transcripts or otherwise when there's a case impossibility,
and we believe impossibility has been met here because we have had now
the passage of six months of time. We've had two attempts at a quorum
with four members, and additionally today we have another illness. So
we think that the impossibility has been shown. Thank you.
CHAIRPERSON RAWSON: Thank you. Mr. Laforet, why don't
you go ahead and ask the question of Mr. Cautero.
MR. LAFORET: Mr. Cautero, if I understand you
correctly, you're suggesting, proposing, that we have seven members on
the board to avoid any problems in the hearings. We had seven members
on the board, and the reason we're having problems in hearing is three
of them didn't show up --
MR. CAUTERO: I realize that.
MR. LAFORET: -- which only left us four.
MR. CAUTERO: I understand. And I've been told by the
attorneys that --
MR. LAFORET: So--
MR. CAUTERO: I'm sorry, s~r.
MR. LAFORET: All right. Now, that being the case, I
hope you're not criticizing the efforts of the remaining four of us to
expedite this case and do it as expeditiously as we could. We did the
very- best we could, for your information.
MR. CAUTERO: I'm criticizing no one. All I'm saying is
that the attorneys have advised me that up until today the discussions
were centered around the original four members who were here for the
original Lely case.
MR. LAFORET: Now, do we have --
MR. CAUTERO: And what I was attempting to do was
support Mr. Manalich's recommendation that the entire board be
eligible to hear it, and that's -- that's all I'm saying, because four
members only heard it in July, and'due to some -- due to legal
concerns that I've been told, those four people were only eligible to
only hear it yesterday and the month or two prior, and at those two
meetings a quorum was unable to be reached. Seven -- if the entire
board is eligible to hear it, which is my hope that you'll do, then
you won't have a quorum problem. But I'm criticizing no one. I will -
tell you that the Board of County Commissioners is criticizing me,
though.
MR. LAFORET: But then do we have any assurances that
the thing won't reoccur with the same three members that created the
situation in the first place?
MR. CAUTERO: No. You don't, but if you have seven
eligible. you can get four.
MR. LAFORET: Thank you.
Page 7
December 13, 1996
MS. LOUVIERE: I am totally confused because a while
back this issue was discussed by this board, and this board voted that
all members should be allowed to vote on this matter, that we would
review the transcript. and we would all have a voice on it. There was
concerns from this board, specifically me, as far as getting four
people together. We all want to resolve this. And I'm with you; the
whole board needs to hear this.
CHAIRPERSON RAWSON: Well, let's hear from Mr. Hazzard.
MR. McCORMICK: Let me ask a question before Mr. Hazzard
not to cut him off, but can somebody -- maybe I'll ask our chair
first or our counsel. Tell me where we are with this case.
CHAIRPERSON RAWSON: We've only heard one day --
MR. McCORMICK: You only had one hearing, and that was
in July?
CHAIRPERSON RAWSON: Correct. We've had one day of
testimony, and that's it. We've been unable to meet the quorum of the
four of us on every subsequent occasion.
MR. McCORMICK: Which means we had opening statements
and a couple witnesses?
CHAIRPERSON RAWSON: Correct. And we have a transcript,
typed transcript, of that.
MR. McCORMICK: Okay.
MR. HAZZARD: Madam Chairman, I'd like to begin by
calling Miss Sullivan as a witness. Would you swear the witness,
please.
rHEREUPON,
LINDA SULLIVAN,
a witness, having been first duly sworn, upon her oath, testified as
fo-llows:
MR. MANALICH: Madam Chairman, before opposing counsel
begins, I would take the position that I have no objection to Miss
Sullivan being called for a witness provided that it is for the
limited scope of the matter of scheduling, just as Mr. Cautero was
called with that limitation. And I'd'ask opposing counsel if he could
make a brief offer of proof as to what it is that he's seeking from
this witness.
MR. HAZZARD: It -- it certainly relates to the issues
that are at hand before the board this morning.
CHAIRPERSON RAWSON: Well, I think Mr. Manalich referred
to scheduling issues. I guess the only issue, really, before us right
now is whether the four or the seven
MR. HAZZARD: Well, Mr. Cautero has suggested that the
board start over with seven members, and I'd like to explore that with-
. Miss Sullivan.
MR. MANALICH: No objection to those areas of inquiry.
CHAIRPERSON RAWSON: Fine.
MR. MANALICH: Thank you.
DIRECT EXAMINATION
BY MR. HAZZARD:
Q. Miss Sullivan, could you state your position with
20llier County, please.
Page 8
December 13, 1996
A. I'm the Collier County code enforcement director.
Q. Miss Sullivan, in that capacity are you familiar with
the codes of Collier County that govern these proceedings?
A. Yes, sir.
Q. And is it your office that has issued the notice of
violation that's at question in these proceedings?
A. Yes, sir.
Q. Is there anything, to your knowledge, within the codes
that govern these proceedings that calls for a start-over process?
A. No, sir. there isn't, but I don't think there's anything
that prohibits it either.
Q. Is there anything within your knowledge of the codes of
-- of Collier County that govern this proceeding that allows your
office to withdraw the notice of violation that has been filed in this
case, refile it, and bring it in front of a seven-member Code
Enforcement Board anew?
A. Again, I don't know whether -- I don't think it's
prohibited. I think it's -- it's a -- probably a -- a matter of law,
which I don't think anybody's been able to resolve this -- this issue
of the seven- or four-member board. Do you have any --
Q. Well, I'll ask the questions while you're under
examination, if you don't mind.
But why have you not simply -- if -- if it's Collier
County's desire to proceed in this case anew with a seven-member
board, why have you not withdrawn the pending notice of violation and
simply issued a new one and save us all this problem?
A. I don't see how that would solve the problem legally,
Mr. Hazzard. I don't think it's necessary.
~.-., Wouldn't withdrawing the current notice of violation and
issuing a new one bring this matter in front of this board, all seven
members, anew, fresh from the start?
A. I don't have an answer to that. I'd have to consult our
attorney on that.
MR. HAZZARD: I have no further questions for Miss
Sullivan. Madam Chairman
CHAIRPERSON RAWSON: Based on those questions, I should
probably, before you give your statement, ask Mr. Manalich if you have
any cross-examination of Miss Sullivan.
MR. MANALICH: No, thank you.
CHAIRPERSON RAWSON: Okay. Mr. Hazzard.
MR. HAZZARD: Madam Chairman, I think I'll begin with
addressing Ms. -- is it Louviere? Am I pronouncing your name properly
MS. LOUVIERE: It's Louviere.
MR. HAZZARD: -- Miss Louviere's comment concerning why
is it that the board is not simply coming to hear this -- this matter
as a matter of course, and that, frankly, is because when we initially
heard this case in July when there were only four members present.
Counsel for the county at that time, Mr. Bryant; myself; and the
members present agreed that we would continue that case with the four
members and that the four members would see that case through to
Page 9.
December 13, 1996
conclusion. And it's simply my position that an agreement is an
agreement. It was an agreement among counsel and this board, and we
should follow through on it. Now, it's not surprising to me that the
county wants to renege on that agreement. You will see as you examine
this case that it is full of agreements that the county has reneged on
MR. MANALICH: Objection. Objection, Madam Chairman.
MR. HAZZARD: -- but I believe --
MR. MANALICH: Objection to reference --
MS. LOUVIERE: Let's just stick to the subject.
MR. MANALICH: Madam Chairman, I would object and move
to strike the last comment regarding the county's conduct in the case
in chief and the substantive matter. I have no problem with opposing
counsel referring to matters of the composition of this board, but
matters of the substance of the case, I don't think, are appropriate
at this time.
CHAIRPERSON RAWSON: This is, Mr. Hazzard, opening
statement or argument, legal argument, if you will. And I think the
board is intelligent enough to be able to focus on the issue, and the
issue is only whether a four-person or a seven-person board should
hear this case. So if you would confine your remarks just to that
issue, please.
MR. HAZZARD: Yes, Madam Chairman. So I believe that a
four-person board should hear this case, because it was committed
among counsel and this board that a four-person board would hear this
=ase. We would be done with this issue had -- on July 25th had we
said let's come back in August at the regularly scheduled board
meeting and see who's here and conduct the hearing, and then let's
come-Back at the regularly scheduled board hearing in September if
we're not done and conclude there. And if we're not done in
September, let's come back at the regularly scheduled board meeting in
October. And I find it incredible that this board is being criticized
or that Mr. Cautero is being criticized by any member of the county
commission, because this board is comprised of volunteers who have
committed to be here on a day a month to hear these cases and to think
that we need to move everybody's schedule around and try to match
seven people's schedules next week, the week before Christmas, not to
mention the difficulty that I'm going to have getting my witnesses
present.
As I mentioned yesterday, the county's witnesses seem to
be chiefly county employees. The county attorney call for those
witnesses to be present, and they're going to be here. My witnesses
are not employed by me, and they're not employed by my clients, and
- they come on availability. And I need some notice to those people to
let them know, if they can, when to block out their schedules so that
they can come and testify in front of this board.
Now, in terms of four or seven, my argument is entirely
a deal's a deal, and I would expect this board to -- to respect the
integrity of that deal. But the case that Mr. Manalich mentioned,
Veasey versus the Board of Public Instruction, discusses situations of
impossibility and the kinds of impossibility that the -- the case
Page 10
December 13, 1996
discusses, what if a board members dies before a final decision is
reached, but after six months of testimony? Must the new board start
over? This is hardly likely. Well, I would agree, of course not.
That would be ridiculous. But we don't have a situation of
impossibility here. Each member of this board has the regularly
scheduled meetings of this board blocked out on their calendars. And
if we schedule this hearing to resume at the regularly scheduled
meeting of this board in January, you're going to be here and you're
going to hear testimony. If we don't conclude in January, then we
come back at the regularly scheduled meeting in February.
Now we have tried yesterday to juggle a number of
calendars and the room calendar, and we have found some dates in
January that are -- that are back to back or pretty close to back to
back, and I am willing to go forward with those dates that we
discussed yesterday. But I believe that the criticism aimed at this
board for being unable to show up under extraordinary circumstances is
unfair, and I do not think that we have a situation of impossibility
that says we have to scratch everything that's gone on and -- and
start over.
Now, an additional reason why we don't need to start
over. I believe that it is perfectly appropriate if you determine
that seven members of the board should continue the case. I believe
it's perfectly appropriate for those members of the board who are
adding in to read the transcripts, to review the exhibits, and not put
my clients through the expense of repreparing for the first day of
hearing that we had back on July the 25th. If you do decide to start
over, then I would respectfully request that the county pay the costs
that my clients have incurred thus far, because it's certainly not my
c~ient's fault that we need to start over. We're willing to resume
the hearing from where things left off July 25th and count on the
members of the board to get up to speed, if you will, by reading the
transcript and reviewing the exhibits. We do not think there's any
cause at all to move this case next week. And personally I cannot
appear the first week of January, because I have a five-day jury trial
that starts on January the 7th, and I owe it to the client that I am
representing in that case to spend that first week in January
preparing. Thank you, Madam Chairman.
MS. LOUVIERE: Can I ask a quick question before you
leave the podium?
MR. HAZZARD: Yes, ma' am.
MS. LOUVIERE: What is your ultimate goal in this case?
MR. HAZZARD: My ultimate goal is to resolve this case
and get it back into the courthouse across the street where it
belongs.
MS. LOUVIERE: Okay. Resolve this case.
MR. HAZZARD: Absolutely.
MS. LOUVIERE: So you shouldn't -- even though you
haven't got -- you haven't been able to resolve it in the past, you
should be totally open to have as many people listening to this case
and vote on it and resolve it.
MR. HAZZARD: And as I expressed, if it is this board's
Page 11
December 13, 1996
pleasure to add additional members, then we would like to do that
without bringing the four members that were present in July through a
rehash of the first day's testimony.
MS. LOUVIERE: I just wanted to hear you say that.
MR. ALLEN: Mr. Hazzard, I've got a question, please.
MR. HAZZARD: Yes, sir.
MR. ALLEN: In the event the board finds that we don't
take your side and we -- and we choose the county's side --
MR. HAZZARD: Yes, sir.
MR. ALLEN: -- okay, would you appeal this?
MR. HAZZARD: Absolutely.
MR. ALLEN: So you're wasting our time.
MS. LOUVIERE: Yeah.
MR. HAZZARD: Let me please address that. I filed a
case in the Circuit Court of Collier County in January of 1994 about
this subject. Fourteen months later the Collier County Code
Enforcement Board filed this notice of violation and brought this
procedure to you. It is not my client's desire to be in front of this
board. As I said in my opening statement, the only reason we are in
front of this board is so that Collier County can gain some sort of
advantage or upper hand that they have cooked up in the court case --
MR. MANALICH: Objection--
MR. HAZZARD: -- that is going across the street.
MR. MANALICH: -- argumentative.
MR. HAZZARD: Well, it was in my opening statement, and
you read it there then, and I will count on you to do that. But it is
not my client's choice to be in front of this forum. Fourteen months
prior to getting in front of this forum, we were in the courthouse in
C6Il~er County across the street, and that's where we belong. Am I
wasting this board's time? I didn't bring this hearing, sir. Collier
County brought this hearing. If the board's time is being wasted,
it's being wasted by Collier County.
CHAIRPERSON RAWSON: Can you tell us the status of the
civil case?
MR. HAZZARD: The civil case, the county filed a motion
to dismiss. It was denied by the judge in May of 1994. The Collier
-- the county responded by filing a -- a second motion to dismiss,
and argument on that motion has not been heard. The State of Florida
has intervened in the case. It's sued both my clients and -- and
Collier County, and it's complained an intervention. It's a pending
court case. Depositions are going on. You know, the status is
ongoing.
CHAIRPERSON RAWSON: Thank you.
MS. LOUVIERE: So whether -- whether a four-member board
or a seven-member board hears this case, you intend to appeal our
decision?
MR. HAZZARD: Well, does your statement preassume
assume in advance that you're going to find against my clients?
MS. LOUVIERE: No, of course not. Why would you assume
that?
MR. HAZZARD: Because you asked me if I intend to
Page 12
December 13, 1996
appeal, and that's something that, frankly, I don't have an ability to
decide at this time unless I know the outcome. And, of course, you
know, I guess it's a common misconception among folks that you
automatically get to appeal things. You have to have some basis for
appeal, and if there's a basis for appeal and the decision goes
against my clients, then I would certainly avail my clients of all the
all the remedies.
MS. LOUVIERE: All right. Thank you. I don't have any
MR. ALLEN: One more comment,
sincerely apologize for yesterday.
that -- the only pump truck in the
MR. HAZZARD: I understand.
MR. ALLEN: Anyway, flying back home last night, I put a
pencil to what it's actually going to take to move the guardhouse.
MR. HAZZARD: Yes, sir.
MR. ALLEN: And the real money to pick the guardhouse up
and move it back to where it should be moved is $11,800.
MR. HAZZARD: There's a question of where is that place
that it should go.
MR. ALLEN: I'm just saying this little bit -- amount of
money to move that guardhouse where it could be legally positioned,
okay, is probably less than the attorney fees. So I mean
MS. LOUVIERE: Always.
MR. ALLEN: So, I mean, I'm just trying to look at a
thing rationally saying if the remedy is cheaper than the fees, why
not do the remedy.
MR. HAZZARD: Sir, our position is that it is legally
p6si~roned where it is today. Do you have a different position?
MR. ALLEN: Yes, sir, I do. According to the PUD, it's
not where it's supposed to be.
. MR. HAZZARD: Well, I'm very concerned to hear that
that's your position without my clients even being able to put forward
any evidence in this matter. Does anyone else have any questions for
me?
MS. LOUVIERE: $11,800 to move it --
MR. KOWALSKI: Excuse me, Madam Chairman, I was under
the impression that the purpose of the argument here this morning
related to whether four or seven members were going to hear this
matter.
CHAIRPERSON RAWSON: That's correct. And -- and we'll
limit our comments to that.
Before I ask Mr. Manalich if he has a response in
rebuttal, let me say this: I would like to divide these two -- two
issues. The first is whether we're going to have the four-person or
the seven-person board. Then having that one decided, then we'll talk
about and vote on whether or not we're going to start over or whether
or not we're going to review the transcripts. I think that's a
separate issue.
And then just one final comment to Mr. Hazzard. This
board doesn't have as much authority as you might think we do, and we
Mr. Hazzard. I really
I was really stuck in a scenario
Bahamas broke down Monday morning.
Page 13
December 13, 1996
don't have the authority to order costs. I appreciate your argument,
but we don't have that authority.
MR. HAZZARD: It's certainly a fairness issue that I'd
like this board to keep in mind, the costs associated with starting
over, I mean, my client has already spent to come here on day one.
Finally, Madam Chairman, I would simply like to point
out to the board that no one has given you any legal authority for
this starting-over theory.
CHAIRPERSON RAWSON: Well, I understand.
MR. HAZZARD: No authority as a do-over
CHAIRPERSON RAWSON: I understand. I'm going to ask our
attorney to help us with that in a moment.
MR. HAZZARD: Thank you.
CHAIRPERSON RAWSON: But let me ask Mr.. Manalich if he
has anything in rebuttal.
MR. MANALICH: Indeed, I do, a couple of things. First
of all, we have requested the seven-member board because we believe
that under the Veasey case and the other case that I cited, we have
reached in de facto impossibility here. When you look at the passage
of time, the effort~ made, the illnesses, etc., we do think we meet
that legal test of impossi.bility. And, again, I would repeat that we
don't believe there's really any significant prejudice that doesn't
balance out for both sides if we have the seven versus the four.
Secondly, I think we can perhaps expedite this. I
thought I heard opposing coUnsel say that he was willing to move
forward on the transcript with the seven. If that's a stipulation
he's willing to enter at t~is time, we're certainly willing to do
that.
---MR. HAZZARD: Madam Chairman, my statement, just so
we're clear, is that I believe that the agreement was to proceed with
four members, and the county should honor that agreement. However, if
it's this board's pleasure to proceed with seven members, then we
believe that it would be a waste of four board members' time and
effort and my client's time and money to do a rehash of day one. We
should proceed -- if it's -- if the choice is seven, we should proceed
with the additional three people counted on to get up to speed on the
case, read the transcript, review the exhibits, etc.
CHAIRPERSON RAWSON: I understand your position,
Mr. Hazzard. That's why I think we should divide those up, and we're
going to vote on them separately. We'll start with whether it's going
to be four or seven. I guess the answer, Mr. Manalich, is there's not
a stipulation of seven people here.
MR. MANALICH: Well, in any event, we're willing to be
.as accommodating and flexible as possible. And we are willing to
limit the evidence here in terms of the first day of testimony to be
had through the transcript. We would pick up the hearing with the
redirect of Dennis Mazzone --
CHAIRPERSON RAWSON: Well, let's do this
HR~ MANALICH: -- with the seven.
CHAIRPERSON RAWSON: Let's vote on the first, and then
uaybe you guys can reach a stipulation depending on what the outcome
Page 14
December 13, 1996
of the vote is as to the second issue.
MR. MANALICH: Okay. I had just one other point that
relates to that. Mr. Hazzard mentioned the agreement that was made by
Mr. Bryant, our predecessor counsel. And I think at the time that
certainly, in order to avoid this type of, you know, discussion, I
think given that we had the first day of hearing, it was certainly
reasonable at that time to enter into that agreement. However, I
would submit that as a matter of contract law, impossibility and
changed circumstances have changed the underlying basis for that
agreement. You now have a situation here where everybody is being
stYmied in this process, both Mr. Hazzard's ability to attain justice,
as well as the county's. So we think there are significant
impossibility and changed circumstances to warrant that agreement no
longer being in effect. I mean, it was held in effect for six months
and over three attempts. So our -- I guess you wanted, Madam
Chairman, to first address the four- versus seven-member issue.
CHAIRPERSON RAWSON: I think so.
MR. MANALICH: And as stated, it is our request, and we
move to have the seven, and we'll address the issues further aft~r you
vote on that.
CHAIRPERSON RAWSON: Thank you.
MR. LAFORET: Shouldn't you
CHAIRPERSON RAWSON: Before we get into a discussion
about whether or not we're going to have the four-person board or the
seven of us hear, we're not going to determine whether or not we're
starting over or whether or not we're going to read the transcripts,
only whether or not seven p~rsons has the right to hear a case that's
already started and has already had one day of testimony heard among
four_ ..But before we have that discussion, I'd like to ask our
attorney, Mr. Kowalski, if he could shed any light on this for the
members of this board.
MR. KOWALSKI: I'll try to do that. As you know, this
-- this issue has been lurking for some time now; so we have had the
opportunity to -- to research it. I also have -- appreciate the input
from both Mr. Hazzard and Mr. Manalich because I've -- I've shared the
legal authorities that I've found with them and -- and had discussions
with them to help me to form an .opinion to advise you.
The authorities that I found were the -- are the ones
that were cited by Mr. Manalich in his argument; that's Veasey and
Sheffey. Both of those legal authorities address the question of
whether a member who was not physically present at a portion of an
evidentiary hearing would be entitled to vote on the ultimate issue
based upon having read the transcript. That appears to be the second
question that you mayor may not get to, depending upon your
resolution of the first one.
So let me address the first one only tangentially in
relation to those authorities, and that is to say that those
authorities imply that there would be a more strict standard of
review. In other words, there -- it would be -- a court would look
more scrutinously at a situation where a board allowed members to
-eview a transcript and participate in a vote than the Court would if
Page 15
December 13, 1996
the matter were to be recommenced, in my opinion. I think that the
recommencement of a hearing is -- is similar to a mistrial 'in the
courthouse. I've been in situations where a mistrial has been created
by error committed by the trial judge when it has been not invited in
any way by counsel. And I would analogize Mr. -- the county's
position here as requesting a mistrial based upon the fact that
circumstances make it difficult or impossible to proceed with the four
members. I'm not sure that the standard of impossibility needs to be
met. I think the mere fact that it has -- if the board determines
that it has become impractical to proceed with only four members, then
I think that -- that you can -- you can either recommence or __ or
continue at the point that you left off by reference to the
transcript. And we'll discuss that issue if you get to it as the
second issue.
On the -- on the issue of contract law, whether there
was an agreement to proceed with only four members, I think it would
be fair to characterize that procedurally as a stipulation between the
parties that both would be willing to proceed with four members unlike
a contract between two private citizens who have full authority to
enter into an agreement that doesn't violate public policy.
The parties cannot determine for this forum how many
members are going to hear the case. That's the decision that the
board had to make in July, and the board made it in part based upon
the fact that there was no objection or consent by both of the parties
before it, but it's not a matter of contract between them. It's a
atter of the decision of the board as to how it wants to proceed.
So based on all that, ~t would be my opinion that a
seven-member board would be entitled to hear this case in one fashion
or an~ther. I think, though, although this goes outside the scope of
the legal question I was asked, I think Mr. Laforet put his finger on
a potential problem if you decide to utilize seven members. If I am
taking his idea correctly, he -- he was suggesting, gee, we've had
trouble getting four people here. If we have a seven-member board,
are we going -- is it going to be easier to get those four members
plus three additional members here for each of the days' hearings?
And if we don't, what's going to happen when it comes time for a
decision and some of the seven members have not attended all the days'
hearings? I don't know whether that is a question or a problem that
you all want to consider when you make this decision.
MR. McCORMICK: I have a couple of questions for
Mr. Kowalski.
CHAIRPERSON RAWSON: That was going to be my next
comment: Who has a question? Go ahead.
MR. LAFORET: Go ahead. Go ahead.
MR. McCORMICK: You said that it was the board's
decision in July to hear this with four people. To me it seems that
we've been here before. In August when the full board was back we
discussed this; and I don't recall if we took a vote, but it seemed to
me that the entire board was in agreement that it would be impractical
to think that four people could carry through and hear a couple more
'ys' testimony and all reach the same conclusion. So the legal
Page 16
authority to me at that time -- it was common sense. It wasn't going
to work, and we discussed that. And if I recall, you said that you
didn't think that was the right course to take and that you were going
to talk to the county and you were going to talk to Mr. Hazzard and
you were going to advise us again as to whether we should have seven
people involved or four people. Could -- what's transpired, and how
did that get resolved, and why are we now looking at seven people?
MR. KOWALSKI: That's a good question. At __ at the
time that -- that I discussed this with both the county and the Lely
residents, their counsel both opposed going to a seven-member
participation. What has changed since then, well, number __ number
one, is that the objection of at least one of those parties has been
removed. Number two, continuing efforts to move this case along with
only four members have been unsuccessful. In August we're talking
about just one month after the hearing had commenced, and now we're
five or six months down the road.
The third thing that is changed is that at -_ at that
time we were looking at picking exclusively the option of __ of
resuming where we left off and having the absent members review the
transcript. And that was something that both the county and the
residents particularly objected to, whether reading a transcript would
enable somebody to develop a familiarity with the evidence sufficient
to be able to vote. And our concern was -- was with that aspect of
the procedure.
The option of starting anew, I don't believe, was
1dressed at that time. So those -- those are the __ the changed
~ircumstances which lead me to -- to give you a little different
guidance today than what I didn't know.
- . MR. McCORMICK: Thanks . That's a good answer . That
clears it up.
CHAIRPERSON RAWSON: Any other questions for
MR. LAFORET: Counselor, are we bound in our board
strictly to adhere to legal precedence?
MR. KOWALSKI: This board's -- the procedure that the
board uses in conducting its hearings are not the same strict
procedures that a court uses when it conducts a hearing in the court
of law. So strict rules relating to evidence and hearsay and things
like that do not apply in this forum in the same way that they do in
the courtroom.
But -- but on a question of whether you are entitled to
recommence a hearing, that -- you need to follow the law as
scrupulously as possible, because those -- those involve the
constitutional rights of both parties to this action. And if the case
law says that the constitution dictates a particular course of action
for you and you do not follow that course of action and it is __ it is
taken in front of a court to review your action, whatever you have
done will be invalidated by the court on constitutional grounds. So
the procedures that the boards use -- board uses are not the same as
the court procedures, but the -- but the authorities of law regarding
your constitutional obligations must be observed.
MS. DEIFIK: Are you saying that we have __
December 13, 1996
Page 17
MR. LAFORET: Excuse me. I haven't finished yet.
MS. DEIFIK: Sorry.
MR. LAFORET: Do I recall correctly that you cited a
physical absence as being cause for reconsideration? It occurs I
would like your opinion on this. It occurs to me that the only
physical absence in all of these things has been one member of the
board. The rest have been not physical, but business reasons. So
part of the reasons for our delays and -- and continuances have been
not physical, but a matter of choice, election, which is not a
physical reason.
And, secondly, nobody this morning has mentioned the
principal reason for the delay in the hearing of this case is the
inability to obtain prompt access to a hearing space. Now, that is
the principal reason. Four of us or three of us showing up every
other time could have finished this case by now had facilities been
available for us to meet in. The reason there's been one-month
delays, six-weeks delays is because we didn't have anyplace to meet
in. So I would appreciate for the record -- just going on the record
and thank you for your response.
MR. KOWALSKI: I think those are sage comments. The--
the only modification or a comment that I would make about them other
than to -- to endorse them, is to note that where only three members
arrived, you can't -- you can't convene a session because you don't
have a quorum. But I don't think that that invalidates much of what
you said, Mr. Laforet.
MR. LAFORET: Thank you.
CHAIRPERSON RAWSON: Any further questions for our
attorney?
-.MS.. DEIFIK: I just -- one quick question. If we do
decide to have a seven-member board, do we have the power to have
everyone start over? I mean, that -- that question Mr. Hazzard
raised, and it seems to me a valid question.
MS. LOUVIERE: I thought we were going to just discuss
first whether or not to go for the seven -- four- to seven-member
board to hear this case, and then the second item we were going to
discuss was going to be whether or not we could use the transcript or
start again.
CHAIRPERSON RAWSON: Well -- well, that's true, and
that's exactly the way I said we'll vote on it. However, I think Miss
Deifik's question probably should be answered, because it might help
her in ascertaining how to vote on the first question. If we started
over or read the transcript, what does the seven-person board __
assuming that would be this board's pleasure, what do they have the
power to do?
. MR. KOWALSKI: My -- my opinion on that to you will be
that neither side has the right to any particular jUdge, any
particUlar forum, any particular members or number of members to
decide a matter regardless of how it commenced and that when
cirCUlllStances make it impractical to proceed under the original basis.
you can, at your oPtion, either recommence from ab initio, from the
br-inning, or you can pick up where you left off. And under the case
DeCember 13, 1996
Page 18
authorities I have found, the members who were not physically present
at the prior hearing participate after having read the transcript.
MS. DEIFIK: That -- I think that answers my question.
I just have one other question that perhaps you can help us with as We
go along. And probably the great God of lawyers will strike me dead
as I say this, but it was my understanding __ I think Mr. Cautero's
statement was a good one -- that this is not a court of law and that,
you know, we're getting too bogged down sometimes in procedural
issues. I think we need to give both parties due process,
particularly citizens who are, you know, confronted by the might of
the county. But I would like to see us take the reigns and move
things along more as a board, and that's where I'm looking for some
guidance so that we don't drag. Do you understand what I'm saying?
Can -- do we have the power to -- to say we're not going to get caught
up in the minutia, that you might get caught up in a federal court or
circuit court? This is a board; let's move along.
MR. KOWALSKI: Well, all I can say is that __ is that
when you get down to -- I think the way you move the case along or
where that arises would be in terms of the presentation of evidence
and the argument of counsel. I think that you're giving __ you are
given more leeway as a quasi-judicial board than a trial court would
be given in terms of moving -- moving matters along. And I __ as you
know as an attorney, Miss Deifik, that moving the arguments of counsel
along is -- is -- is a lot easier to do than moving the evidence
along. But I would be happy to assist if -- at any point in trying to
ve both parties along in terms of the presentation of the case.
MR. MANALICH: Madam Chairman, may I address the board.
CHAIRPERSON RAWSON: Yes.
-MR.. '-MANALICH: Just briefly, to the extent it will
assist this discussion and resolution of this matter, the county is
Willing to be flexible. We are willing, if you decide to vote for
seven members, that -- we do Want that, because we think we've reached
the point here where we need to get on with this with a sufficient
number of members here voting. But if you agree on the seven, we are
willing to go forward on the transcript and not rehash the first day.
We are willing to start over, if that's the board's preference.
Whatever the board prefers, we will do.
We are Willing -~ I believe opposing counsel is
concerned about starting over as opposed to picking up the
transcriPt. We think the case law and your own attorney advised that
seven members could pick up that transcript, and we'd pick up the
presentation from where the transcript left off.
CHAIRPERSON RAWSON: In view of the fact that
Mr. Manalich has made a statement, do you have anything you want to
say, Mr. Hazzard?
MR. HAZZARD: I think I already stated my position on
that iSsue, but I appreciate your offer. Thank you.
CHAIRPERSON RAWSON: Any further discussion by this
board?
MR. LAFORET: Yes. I have one statement to make. I
I '-'ink it should be impressed on all this legal talent that we don't
DeCember 13, 1996
Page 19
nake binding decisions. We make recommendations to the board, and
it's the board of commissioners who make the decisions. So in view of
cases already -- civil cases already pending, I have a feeling that
whatever we decide, just or unjust, is garbage. In the first place,
it can be overridden by the commissioners. In the second place,
theY're going to go to civil court anyway. So I can't see the great
emphasis on all this legal doctrine. I agree with my compatriot
here. Let's do it and get it done.
MR. HAZZARD: Madam Chairman, I -_ I respect Mr.
Laforet's pOSition on that. However, I would urge this board to take
seriously the charge that you have in reviewing this case, to
carefully review the transcript, if that's what happens, to carefully
review the exhibits, the testimony of witnesses, because what you do
does matter, because it relates to standards of review that will be
applied should this case be appealed by either side. However, I do
believe that it's at this board's pleasure to hear cases. And if you
Want to throw this one out and send us to the courthouse, we'd be glad
to have you do that.
MR. MANALICH: Madam Chairman, I Won't argue my cause.
I'll just refer to what was brought up, and that is __ Mr. Laforet, my
understanding of law on this is that your decision here as a
quaSi-judicial body is quite important in the sense that the Board of
County Commissioners will not be reviewing this case. This case will
go to circuit COurt if any side chooses to appeal. So obviously your
decision is very important.
The second thing in relation to that, I just want to
L_~ng up something that occurred earlier, which is, I know Mr. Hazzard
had expressed a concern regarding comments that Mr. Allen had made
earlie~. -. And I just wanted to reemphasize with all of the board
members, both on our behalf, and I think I speak also for Mr. Hazzard
on this, which is I think we both would encourage you to keep an open
mind about this matter. Wait to hear all the evidence from both
sides. Do not in any way predispose or prejUdge this. Agree with us
both to hear this matter to its conclusion, and then at that point
when you're properly in deliberation, then form your conclusions.
CHAIRPERSON RAWSON: Thank you, Mr. Manalich. I
appreciate those comments. I was going to make the same to the
board. And I do consider that this board's decision is very
important, and I know that -- and I urge board members, whether it's
four or seven, to take this very seriously, to listen to the evidence
carefully, and to render a fair decision. And I'll probably say that
again in the course of this hearing. Any further discussion on
whether we have four or seven members?
MR. MCCORMICK: I would just comment that __ almost
reiterating what our attorney said and -- and also what I believe we
talked about in August, that we don't choose what cases come before
us, but once they are here, it is within OUr arena and within OUr
ability to hear them as -- as We see and to try and bring them to
resolution as we see fit. And I I think that it's perfectly within
our -- our judgment to -- to add on the other members of the board and
go ';.th seven. It's--
December 13, 1996
Page 20
MS. DEIFIK: Is that a motion?
MR. MCCORMICK: It's not -- when I wake up in the
morning and think of my things to do, this isn't USually on the list.
But I'll make a motion that we have seven members of the board hear
this case.
MS. LOUVIERE: I second it.
MR. HAzZARD: Madam Chainnan, can I just for a point of
clarification -- I'm sUre you don't intend to lead Us into a bind that
if seven people are not here we can't go forward.
CHAIRPERSON RAWSON: No, Mr. Hazzard.
MR. HAZZARD: A full board and whoever is here at that
time, is that more the gist of it?
CHAIRPERSON RAWSON: I apologize to the court reporter
because I know I spoke at the same time that you Were speaking. I
think that the essence of the motion -- and I'll ask Mr. MCCormick to
be SUre that I'm correct -- is that a seven-member board is eligible
to hear the case rather than only the four who heard the first day of
testimony. Obviously we go back to the rules and look and see if We
have a quorum present and so forth. But we're only talking about
eligibility here; is that correct, Mr. McCormick?
MR. MCCORMICK: Yes, I'll amend the motion.
CHAIRPERSON RAWSON: It's been moved and seconded that
the full board be eligible to hear the case of Board of County
Commissioners versus Lely Barefoot Beach Property OWners' Association,
Inc., and Lely Barefoot Beach Masters' Association, Inc. Is there any
f -ther discussion on this motion?
MS. DEIFIK: I'd like to second the amendment to the
motion.
CHAIRPERSON RAWSON:
MS. DEIFIK: That's
CHAIRPERSON RAWSON:
that motion?
If not, then I'll call for the vote. All in favor of
the motion, signify by saYing aye.
CHAIRPERSON RAWSON: All oPPOsed?
MR. LAFORET: No .
CHAIRPERSON RAWSON: The motion carries 5 to 1. I have
to be careful about my mathematics and counting. The motion carries.
The full board will be eligible to hear the case of Board of County
Commissioners versus Lely Barefoot Beach.
Now, let's get to the next iSsue, which is whether this
board starts OVer or whether this board reads the transcript from the
first day, being Cognizant of the fact that all of the board members
were not present on that first day. And I'll entertain arguments or
stipulations or whatever the attorneys wish to tell this board.
MR. HAZZARD: I'll rely on my previous statement. I
think my Position is clear that take it from transcript.
MR. MANALICH: We are willing to go from the transcriPt
and proceed from where the transcript left off.
CHAIRPERSON RA"'SON: Fine. Then I'll consider that to
oe ? stipulation between the parties that the members of this board
December 13, 1996
Thank you.
for the record.
Is there any further discussion on
Page 21
dll be provided with, if they have not already been provided with,
cranscripts of that first full day of hearing and that they will read
that transcript very carefully and that they will be prepared to
proceed forward from that day.
MS. LOUVIERE, Is it POssible to ask for additional
information in order for me to be more educated on this matter? I'd
like a copy of the POD. I'd also like a copy of the master plan that
currently reflects where the gUardhouse is, and I __ I'm assuming the
POD contains a master plan that reflected where it was proposed to be
located.
CHAIRPERSON RAWSON, Well, let me -- let me just say
this, all the evidence that.was introduced on the first day of
testimony should be provided to all of the board members, if it hasn't
been already. And I think Some of the things that she's requesting is
probably already in evidence; is -- is that not correct?
MR. HAZZARD, Madam Chainnan, it is. I f YOU'll recall
from the first day of hearing, I provided notebooks that contain
various exhibits to the -- to the board members who were present, and
I have identical notebooks for those two board members here today
three board members here today who were not present July 25th. I'll
give those to you before we leave so that you can review them.
In addition, Madam Chainnan, I -_ I think it's incumbent
upon the board members if there is something in the transcript as you
read it that's unclear, I don't think that you're in any way
prohibited from inquiring about that. And I believe that if the board
s i I'd like to hear from -- or if a board member asked to hear from
a ~rticular witness who Was heard again, if the rest of the board was
inclined to do so, I think that may be proper if there's a question
,that you have that you need to clear up. That's __ that's at least
how I read the cases that Mr. Kowalski has provided us with.
CHAIRPERSON RAWSON, Well, I don't disagree with yOU,
Mr. Hazzard. And all of the exhibits that were already introduced
into evidence, including the packet from the county that Was in OUr
book, should be provided to be read along with the transcript of the
first day'S proceeding so that everybody is up to speed and ready for
the second day of testimony.
MR. MANALICH: Madam Chairman __
CHAIRPERSON RAWSON: Yes.
MR. MANALICH, -- if I'm correct, and I believe what the
members will have accessibility to are being provided, is the
transcript and the exhibits that were introduced. I don't believe
there would be anything beyond that.
CHAIRPERSON RAWSON: That's correct.
MR. MANALICH, Now, with regard to that body of
material, I would suggest the documentary portion of those exhibits,
which are the majority of them, I believe, can certainly be reproduced
by whoever for you to have to review and read. . Now, there are some
graphics that were prepared that obviouSly I don't think can be
ceproduced, and I'm open to any suggestions as to how you Want to
landle that. They are available in the clerk's office. Mr. Hazzard,
10 Y . have any Objection to any of them individually gOing down to
DeCember 13, 1996
Page 22
:eview those -- those materials?
MR. HAZZARD: Frankly -- no objection __ I think it
would be inCumbent upon each of you to go and review the materials so
that you can have a thorough understanding of what transpired on day
one.
MR. MANALICH: I would submit, though, that would have
to be done, I believe, individually for the purpose of the Sunshine
Law.
CHAIRPERSON RAWSON: Certainly.
MR. KOWALSKI: May -- may I make a suggestion, Madam
Chairman. I would suggest that the party that introduced each exhibit
be responsible for providing copies of those exhibits to board
members. For the most part, that would be the county, but it may
but it may be that the respondent has also introduced an exhibit, as I
recall.
MR. HAZZARD: I'm prepared to do that now.
CHAIRPERSON RAWSON: I think -- I think he gave us a
whole book.
MS. DEIFIK: Maria, I gave you back my transcript.
MS. CRUZ: Sorry.
MS. DEIFIK: I gave you back my transcript because I
thought I wasn't going to hear it.
CHAIRPERSON RAWSON: Well, we'll be SUre that all the
board members are prepared and that they have all the exhibits and
that they have the -- the right individually to go to the clerk's
'ice and review the graphics. And, you know, again, I'm going to
Q~onish all of you about the'Sunshine Law, not to discuss this case.
This case is much too important, and my concern has always been that
. We don'~"make an error procedurally that if this case goes on appeal,
as the attorneys have told us it might, then it goes on the
substantive issue, not the procedural issue. So I'll _~ I'll just
admonish you all to be very careful not to discuss this case with each
other or with anyone else and also to listen carefUlly to all the
evidence presented, to do a good job of reviewing the transcript and
looking at the evidence presented on the first day, to have an open
mind, and to render a fair decision based only on the evidence that's
presented before this board.
Now let's get into the -- the area of schedUling. And
for the record my brief conversation in the hallway with Mr. Caut
Mr. Cautero before this meeting Was about scheduling. And he let me
know that he was going to go on the record and request that we do this
either next week or the first week in January. My response to him was
that I appreciated the frustrations, and we all shared in those
frustrations, but that the -- those of us that were here yesterday,
which did not include Some of the members of the board today __ and so
we need to have this discussion -- had already picked some days in
January. And we'll have this discussion today, but we've already got
some days picked out that looks to me like they might work, that this
case can get heard in its entirety, that this case can finally render
-- this board can finally render a decision. And for my fellow board
mer' 'rs that were not here yesterday, the attorneys and the board
DeCember 13, 1996
Page 23
members that were present yesterday, including Mr. Andrews, were
looking at the days of January 22nd all day, January 23rd until 3:30;
January 27th all day, January 29th all day, January 30th, if needed,
until 3:30. I have been assured that this room will be made
available. Now, do We need to take a break for the other board
members that are present to check their schedules?
MS. LOUVIERE: I'm sorry. Could you say the dates just
one more time.
CHAIRPERSON RAWSON: Yes. January 22nd starting at 8:30
and going until the end of the day __
MS. LOUVIERE: Okay.
CHAIRPERSON RAWSON:
which is a Thursday __
MS. LOUVIERE: Uh-huh.
CHAIRPERSON RAWSON: going until 3: 30. And for the
record, I'm the reason it's only going to 3:30. I teach a class in
Fort Myers, and I apOlogize, but I. have to leave, and I don't Want to
miss any testimony; January 27th starting at 8:30 all day; January
29th starting at 8:30 all day, and if needed, January 30th until
3:30.
Certainly with almost five days this board will be able
to hear all the evidence and render a fair decision. Now, do you need
to take a break to check with your respective offices as to your
availability?
MS. DEIFIK: I believe that all those days would __ I __
oan make -- make my schedule so that I can be here, but I would like
~~ make a quick phone call just to be sure.
MR. MANALICH: Madam Chairman
-MS,"DEIFIK: How many days is it going to take to finish
this case?
MR. MANALICH: Madam Chairman, a
I'll answer that with my next point.
taking the break. Before we do that,
to look at those dates that were just
ones that were discussed yesterday.
CHAIRPERSON RAWSON: Yes.
MR. MANALICH: However, I want to reiterate and
emphasize that on the behalf of the county, the county'S position is
that it feels an urgency to get on with this case and would like this
board to consider next week.
CHAIRPERSON RAWSON: I understand. And I'm not
unmindful of that, and I'm not unsympathetic to that, but as I said on
the record yesterday and I will repeat, you know, that I'm flYing out
of Naples, Florida, next Wednesday at 4:20. And so, you know, at
least I know that I will be unavailable, and it is __ was my
understanding that Mr. Hazzard said he had some problems with some of
his witnesses being available for the week before Christmas. And that
led us SUbsequently into lOOking at January.
MR. MANALICH: Well, before we go on from there,
understand YOur comments about next week. That still
du' .'9 New Year's. It also leaves then the first few
December 13, 1996
in this room; January 23rd,
couple of things
The first one is because you're
I think you're taking the break
mentioned, and those were the
I
leaves the week
weeks of
Page 24
December 13, 1996
January. Now, I understand Mr. Hazzard has a five-day jury trial. I
believe it's starting the 7th of January. And that I understand, and
we don't quarrel with that at all. And that he would maybe need
preparation before that, we don't quarrel with that. But that still
leaves the week of the 16th, I believe it is, Monday --
CHAIRPERSON RAWSON: It's the week of the 13th and
MR. MANALICH: Thirteenth?
CHAIRPERSON RAWSON: -- as I recall our discussion
yesterday, Mr. Hazzard has a jury trial five days starting January
7th. I know that this affects me, and it probably affects Ms.
Deifik. Judge Hayes' trial docket is the two weeks of January 7th and
January 13th, and I know I personally have three trials on that
docket. So -- and I know that one of them is not going to settle, and
I do not want to have to call this board at the last minute and say,
oh, guess what? I'm in Judge Hayes' trial today, and I can"t come. I
do not want this case to be delayed, and I want to be here to hear
every word everybody has to say. So I think that's why we then ended
up with the week of the 20th and the 27th, and we all cleared our
calendars.
So I'm not unmindful of the county's concerns. And--
and we're going to do our best to get this done, but we don't want to
be in a position that we've been in the last subsequent hearings when
we don't have a quorum and -- and you guys come and you're ready to go
and you-all have your exhibits here and I walk in and I have to say
somebody's not here and we don't have a quorum. I don't want that to
nappen again. I want to move this case along. So we're trying to
find days that we're reasonably sure that we'll have a quorum here.
Yes.
-. .- MR. ALLEN: I have a question. I apologize again for
not being here yesterday. Is there a specific reason that -- that
this thing is going to stretch out for five more days? Why can't it
be condensed into a day?
MS. LOUVIERE: And that's -- that's a good point. And I
find that these case -- these cases that are presented to us are very,
very long. And I've noticed and I have asked before; the Board of
County Commissioners limits the time that witnesses can -- can be
heard and limits the questioning time. And I am -- I am going to ask
that can we look at this, please. Why can't we have a timer and limit
the presentation by the -- by the attorneys and limit the
question-and-answer periods? I mean, some of these things, I have
listened, sat on these boards for four and five hours and listened to
what opaque is and have not been able to stop this person from wasting
some of my precious lifetime. I mean, I'm sorry. That's how I feel -
about this.
MR. HAZZARD: Madam Chairman, it would be my view -- of
course, I don't know what the county's case is to be presented. And I
share your frustration, and I will let -- I just as a matter of of
courtesy tell you that I've written to a county commissioner and
proposed some suggestions to govern this process and expedite it
because, frankly, there are some things that could be done. Now, I
don't think we want to impose things mid-case. However, given that
Page 25
December 13, 1996
we're not starting over, I personally don't envision us needing all
five days. It's -- it's my view that when the county is done with its
case -- and I don't know how many more witnesses the county has,
because I'm not privy to that information. I don't know obviously who
those witnesses are; so I can't begin to estimate how long it will
take to examine or cross-examine. But I believe when the county is
done with its case, I have, I.think, six witnesses to put on. Two I
expect to be fairly short, and four I would expect to try to hold my
presentation short, but I cannot speak for how long the county's
cross-examination will run.
CHAIRPERSON RAWSON: How long --
MR. HAZZARD: That's the best estimate --
MS. LOUVIERE: Can you tell us how long each -- each
witness is going to be up there?
MS. DEIFIK: How many days are we going to be here?
MR. HAZZARD: I -- I can't estimate that for you,
because I don't --
MS. DEIFIK: Just for your case.
MR. HAZZARD: My case I would expect I would need two
days just guessing at what I think would take cross-examination.
MS. DEIFIK: Mr. Manalich, how many days or how many
fractions of a day do you need to finish your case?
MR. MANALICH: We have at this point three witnesses in
addition to Mr. Mazzone who will be on redirect when we resume. We
would estimate, dependency -- the great unknown for us is his
cross-examination. I think we don't -- we don't know on those
witnesses how long he will.take but --
MS. DEIFIK: You're taking a half to a full day?
- ...- MR. MANALICH: I would say we're looking for us between
a day and two days, probably most likely a day to a day and a half.
MS. DEIFIK: Okay. Can I just make a statement: not to
beat a dead horse. And, Madam Chairman, you can hit me if you want.
One of the things that I've observed in the past -- and this must be a
frustration that judges experience, is -- please, gentlemen and
ladies, remember that we all are intelligent people, and we do
understand what you say to us. I have noticed in the past that many.
of you feel the need, either in your argument or with your witnesses,
to revisit a point again and again and again. We heard it. We know
it. We understand it. We do have a grade-school education. Thank
you.
MS. LOUVIERE: And -- and I know in this case -~ and you
have changed a lot along the lines in this case; so we cannot limit --
it would be not fair to go ahead and start setting time limits at thi~
time to your witness and to your statements, but I would like this
board to start looking at limiting the time that people can get up
there and the time that -- that we can ask questions. The Board of
County Commissioners does it. Why can't we? We have -- commissioners
are very upset that this board has a six-month backlog. We are taking
way too long. They have made another code board. There's no reason
why these cases have to drag on the time that they do. It -- it is --
it's ridiculous.
Page 26
December 13, 1996
MR. HAZZARD: Madam Chairman, if I -- just in response,
I -- I share your concern. And, Miss Deifik, you understand the court
system and the differences between the court system and here. But one
major problem that I see in this board, frankly, is not knowing who
the witnesses are going to be, not exchanging information. This is a
hide-the-ball proceeding as opposed to a court case which is a
no-balIs-hidden proceeding. Whoever sits down at that witness stand
when Mr. Manalich begins to question them will be a surprise to me. I
don't know who they are. I don't know anything about them, and I will
be thinking on my feet to ask them questions. You will have to
forgive me if I stray, because I don't know what they're going to
say. I haven't had the opportunity to depose them like I do in a
court case. I don't come in knowing the subject of their testimony,
knowing the depth of their knowledge about it. And the county
attorneys, of course, have that same problem when I present my
witnesses.
These are the kinds of reforms that I think, personally,
should be considered by this board. There should be some stipulations
in advance of the hearing. The attorneys should be able to sit down
and say, here are the witnesses I'm going to present, and here's what
they're going to talk about, both sides exchange that information. We
could very easily adopt for this board a program similar to what you
do in court where you submit a pretrial statement. Here are the facts
that we agree on, and you don't need to hear testimony about those
facts because everybody agrees. There are a number of things that can
~e done. I would urge you to look at those. I would urge you to urge
county commissioners to look at those, including people that are
supposed to do that. That could really expedite matters in front of
tnis-board. Thank you.
MS. McEACHERN: Madam Chairman, I'm Shirley Jean
McEachern, assistant county attorney. On behalf of the county, we
reiterate our offer that we made, that Mr. Manalich and I made when we
took over this case, that we're more than happy to disclose our
witnesses to Mr. Hazzard. That offer was made to him before, and it
was rejected, and we make it here again today.
MR. HAZZARD: Naturally the offer comes too late, and
what you need to know is that I requested that information prior to
the start of the hearing and was denied. The position that I'm in now
is, okay, Hazzard, you already know who half our witnesses are by
virtue of they've already given testimony. Now we want to know all
your witnesses. You referenced let's not change the process in the
middle. This is the process we're stuck with. This is the process
that I've been dealt, and we'll go forward and --
MS. DEIFIK: No. You referenced let's not change the
process and then -- how can it --
MS. LOUVIERE: No, sir --
MS. DEIFIK: Yeah. How can it possibly hurt you now to
know who their witnesses are going to be in January and you disclose
your wibnesses as to who you're going to put on in January, and
everybody will be up to speed by the time we come here in January, and
lue process will be met?
Page 27
December 13, 1996
MR. HAZZARD: If -- if it's the board's inclination that
we do that and you direct us to do that, obviously that's what we'll
do.
MS. DEIFIK: I do.
MS. LOUVIERE: I so second.
MR. HAZZARD: But the issue, the fairness issue, is that
I did not know in advance of the first day of hearing who the county
witnesses were going to be. I did not know all of the county
witnesses, and the county will now know who all my witnesses are when
I didn't have that same information available at the outset, and
that's my only point.
CHAIRPERSON RAWSON: Well, let's -- let's do this, a
couple things. We're going to put on the agenda for the board's
knowledge for January the Code Enforcement Board rules and
regulations; they've really never been passed. We've been following
some that we've used that probably need some edification, and so I
appreciate your comments, Mr. Hazzard, and your jsuggestions. I think
that they are well-made, and I agree with you. There is a process
that ought to be implemented and ought to be right in our rules and
regulations. And so we're going to have that discussion at our
regularly scheduled board meeting in January, and we're hopefully
going to get some rules and regulations that we've approved, and then
we'll get the county commissioners hopefully to approve.
, Now, in terms of whether or not we have to have an
exchange of witnesses at this point in the proceedings, before we have
~ discussion further now that I've heard a motion and a second, I need
to ask our attorney for his opinion.
MR. KOWALSKI: It seems to me that there would be
preJudice to the respondent if he was obligated to disclose all his
witnesses having commenced his cross-examination without that
knowledge. I think that that -- the frustration that the board feels
can -- can be addressed by adopting rules and regulations applicable
from the commencement of every case here forward, but I can't
recommend that that procedure be implemented at this point in the
middle of this case.
MS. DEIFIK: I thought they already had to do that
because there's already a rule and a procedure whereby they have to,
so many days in advance, present their packet and provide so many
copies to be distributed to the board.
MR. HAZZARD: Miss Deifik, I -- I have to be completely
honest with you. From the outset of this case, I have tried to find
the rules and procedures that --that govern this proceeding, and I
have been unable to do so. I have not inquired of this set of counse~
but did inquire of Mr. Bryant prior to the outset of the hearing in
July and was told we don't have any. And for the record I did offer
at that time, let's -- let's make some -- let's exchange witness
lists, etc. That offer was declined.
MS. LOUVIERE: I -- I thank you for your -- your
cammentsJ but I believe in an effort to expedite this -- and the Board
of County Commissioners wants us to expedite this -- I'm going to
3tand with my -- my motion -- my second to Miss Deifik.
Page 28
December 13, 1996
MS. DEIFIK: Well, I'm going to withdraw my motion,
though, based on what Mr. Kowalski is saying, because I agree with
Miss Rawson that if we're going to do this, let's do it right. Let's
have the circuit court reverse us on substance or affirm us .on
substance, not on procedural screw-ups, and let's get a set of rules
so this doesn't happen again.
CHAIRPERSON RAWSON: Yes, Miss Sullivan.
MS. SULLIVAN: Madam Chairman, Mr. Hazzard has indicated
that he would probably need two days. Mr. Manalich had indicated that
he might need 1 1/2 to 2 days. That's four days. I believe we have
five days scheduled.
CHAIRPERSON RAWSON: Correct.
MS. SULLIVAN: We have a regularly scheduled meeting
that's a very important case on the 23rd. If that's the case, could
we limit this hearing to four days and have our regularly scheduled
hearing on the 23rd?
CHAIRPERSON RAWSON: We -- we have a case scheduled --
that's our regular --
MS. SULLIVAN: That's our regular hearing. That's going
to put us behind again if we don't do that.
MR. McCORMICK: Can we change that regularly scheduled
hearing to the 30th so we can hear this case four consecutive days?
MS. SULLIVAN: The only thing that -- I thought about
that. It was bothering me.
CHAIRPERSON RAWSON: You noticed everybody?
MS. SULLIVAN: No, we haven't. No, we haven't. We can
do that but --
CHAIRPERSON RAWSON: Why don't you -- why don't we do
tfiis." Well, we're going to take a break in a minute, make sure that
the five days are okay with everybody. If we could notice the people
for that other case to the 30th, then hopefully based on what the two
attorneys are telling us today, we can complete this case on the 22nd,
23rd, 27th, and 29th. And then on the 30th we could have our
regularly scheduled board meeting and that next case.
MS. SULLIVAN: That would be fine. I can notice later
but not earlier.
CHAIRPERSON RAWSON: Okay. Well, did you have something
else you wanted to say?
MR. MANALICH: Just a brief clarification which Miss
McEachern already alluded to. We have no quarrel with Mr. Hazzard's
constructive suggestions for future improvements and how prehearing
proceedings can occur, and we would welcome and look forward to
working with everyone here in that regard. For the purposes of this .
hearing, we just want you to be clear that the counsel that are here
today, myself and Ms. McEachern on behalf of the county, inherited a
situation here as far as what had transpired prior to the first date
of hearing --
MS. DEIFIK: But then let's all work together and be
fair and -- and move forward.
MR. MANALICH: Agreed. What I'm saying is that I want
you to understand that the counsel you have before you here today,
Page 29
December 13, 1996
myself and Miss McEachern, did offer when we took over this case to
have that exchange of witnesses. Now, I understand Mr. Hazzard's
fairness argument. I'm not here to --
MR. LAFORET: Excuse me. I'm trying to listen to this.
MR. MANALICH: I'm not here to quarrel with that. I
just want you to understand what the position of --
CHAIRPERSON RAWSON: I unders tand. And we are aware
that it was Mr. Bryant and that you two weren't even present. Before
we go off the record to take a short break to check our schedules, let
me say this since we're talking about rules and regulations. Miss
Sullivan, the -- our regular attorney is Mr. Yovanovich, and I think
that right now is a real good time for us to direct him to take a look
at the rules and regulations that were prepared some years ago and
that were never really approved, give him the benefit of the
discussions that we've had today, and see if he can't come up with a
draft for some new rules and regulations for this board, because I
think it's long overdue. I would agree. Well, let's take
MS. LOUVIERE: Can you -- Jean, that's a great idea.
Hold on for just three seconds, and I'll be done. Can you give him a
time when he has to have this to us?
CHAIRPERSON RAWSON: We want to put this on the January
30th agenda.
MR. LAFORET: Before you take a break
CHAIRPERSON RAWSON: Yes.
MR. LAFORET: -- with due respect for all the legal
:alent here, I haven't heard anybody mention the situation that may
arise if one side or the other want to get a rebuttal witness in.
Now, is this going to be -~ is this customary? Is it going to be
accepted?
CHAIRPERSON RAWSON: Well, yes.
MR. LAFORET: You're going to delay it two or three
weeks.
CHAIRPERSON RAWSON: Well, rebuttal witnesses are
certainly permissible, and I wouldn't not let them testify. Based on
-- that's a good question. And based on the fact that there might be
rebuttal witnesses, do you still think we can finish this case, and
that would be your rebuttal, in four days?
MR. MANALICH: One moment.
MR. LAFORET: I would suggest if outside experts are
required, you're not going to get them overnight, and they're not
going to know what they're talking about until they have time to
examine it.
MS. SULLIVAN: Madam Chairman, I don't think I have any
authority to direct the board's attorney to do that. Would you
CHAIRPERSON RAWSON: Oh, don't you?
MS. SULLIVAN: Would you give him a call?
CHAIRPERSON RAWSON: Well--
MS. SULLIVAN: I've scheduled it for January. I have it
on the agenda ~
CHAIRPERSON RAWSON: Okay. I guess that's my call
~hen. I apologize. I'll call him and direct him --
Page 30
December 13, 1996
MS. SULLIVAN: Thank you.
CHAIRPERSON RAWSON: -- on behalf of this board. Thank
you.
MR. MANALICH: With regard to rebuttal, obviously when
you don't have the exchange of information ahead of time for either
side, it makes it even more difficult to forecast whether there will
be any rebuttal and to what extent there will be any. For that reason
ideally if we had the five days, I don't foresee a problem even
fitting in the rebuttal. When you get to four, depending how the two
cases in chief go, it may be pushing it.
CHAIRPERSON RAWSON: We understand that. If we noticed
everybody for our regular-scheduled board meeting and we have a case
ready to go on the 30th, that we'll find ourselves finishing this case
up in February, which is what I really truly wanted to avoid. So I'll
just let you both know, and I think I said this yesterday, that I'm
going to do everything in my power, while not limiting people's
testimony or the right to speak before this board, to move this thing
along.
MR. MANALICH: Because I look at now -- I mean,
Mr. Hazzard estimated two days for his presentation. I'm estimating a
day to a day and a half for the county's, maybe closer to a day. I
mean, on the other hand, depending on the length of cross-examination,
it could go further than that, but I really think between a day and a
day and a half at the most, but that would still put us within
sufficient days to do whatever rebuttal I would have and then he would
have.
CHAIRPERSON RAWSON: Well, we'll start right on time, I
can a~sure you that, and we'll move it right along.
_.- Let's take a break till 10: 15, and everybody check your
schedules and see what your availability is for those dates that we've
mentioned. And then when we come back, remind me; we need to approve
the minutes of October 30th. The board will be in recess for ten
minutes.
(A short break was held.)
CHAIRPERSON RAWSON: Okay. Let's go back on the
record. Code Enforcement Board of Collier County is back in session.
Before the break I requested that the members of the board that are
present here today check their calendars to see what their
availability are for those five days in January, knowing that
Mr. Andrews was here yesterday and he'd already checked his calendar
and he was available on those days. Anybody have a conflict on any of
those days?
MR. ALLEN: I do, Jean.
CHAIRPERSON RAWSON: Yes, Mr. Allen.
MR. ALLEN: I can be here one week or the other, but
every other week I rotate with Bill in the Bahamas. So if we can
condense this hearing into three days, I can be here either week and
any amount of days either week, but I cannot be here two consecutive
wee-ks .
MS. SULLIVAN: Madam Chairman, I don't think it will
matter as long as we have a quorum and he can read the transcript for
Page 31
December 13, 1996
che day that he's not here.
CHAIRPERSON RAWSON: Which brings up the next item. I
mean, I would urge everybody to be here every day, of course, because
we need to have a quorum to vote. And I would think, Mr. Allen, that
probably the most important day would be the day of the vote, which
should be the second week or the last week of January. Now, we
probably need to have a discussion and an agreement, hopefully,
between the attorneys as to, since we know that we'll be here at least
four days, what happens if we have seven members here on the 22nd, six
members here on the 23rd, a different six on the 27th, and a different
six on the 29th, the day, hopefully, that we're going to vote on this
issue? Do we have a resolution as to that problem? And I will ask
all the attorneys, including the board's attorney, for their opinion
on that matter.
MR. HAZZARD: Madam Chairman, I think it, frankly, is
going to be impossible to coordinate seven calendars, attorneys'
calendars, room availability, and that sort of thing. I think that
what we need to do is make arrangements for daily transcripts from the
court reporter. I -- we had a little bit of discussion on the break
about this issue. I -- I don't think opposing counsel is opposed to
that at all. I would urge the members of the board to focus on the
latter part of the hearing so that you can be present to -- to vote as
opposed to, you know, having been present to hear testimony and then
not being able to vote, and then just simply urge members of the board
to read the daily transcripts and get themselves back up to speed if
;hey've had to miss a day. And if we can reach agreement that that
the last day of the hearing or the anticipated voting day will be fill
in the blank --
---CHAIRPERSON RAWSON: The 29th, I hope.
MR. HAZZARD: -- perhaps that will be good for planning
purposes for each member of the board.
CHAIRPERSON RAWSON: I'm looking at the afternoon of
January 29th. Well, is that okay with you, Mr. Manalich, if we had
that problem? And obviously it's -- we're going to have that problem
with Mr. Allen, we know, and he's reading the -- well, no, he was here
for the first day of hearing, but he may be in a position that some of
the other board members are now in that he will have to read
transcripts.
MR. MANALICH: No objection to that.
CHAIRPERSON RAWSON: Okay.
MR. MANALICH: No. My only question would be daily
transcripts, I believe, are, as they should be, an additional extra
cost for that production. Is there any question about how that will
- be paid for?
CHAIRPERSON RAWSON: This board can't make those
decisions.
MR. MANALICH: Okay.
MS. DEIFIK: Can't the parties agree to split it to
expedite this?
MR. MANALICH: I guess we'll take it up between us.
CHAIRPERSON RAWSON: I checked with the court reporter,
Page 32
December 13, 1996
and daily transcripts are certainly an option that she can deliver.
And so any board member who misses any day of testimony be advised
that the daily transcript will be available for you to review, and you
need to contact probably me or Barb Donovan and be sure that you've
read it before the hearing starts on the next day.
COURT REPORTER: Jean, I would need to know in advance
before we even take it down that you're going to need it, because I
have to have back-to-back reporters. I would need to know -- if
somebody was going to need it, I'd need to know, like, at least a day
or two in advance before it's even going to be cut.
CHAIRPERSON RAWSON: Well, assuming that Mr. Allen's
going to be gone the week of the 20th of January, he'll be in the
Bahamas then, so I can say the 22nd and the 23rd we'll need it.
Hopefully we'll have a full contingency that last week.
COURT REPORTER: Mr. Allen, can I get your phone number
just to verify that with you before -- ahead of time.
MR. ALLEN: 591-1243.
CHAIRPERSON RAWSON: According to the rules of the coun
the Code Enforcement Board, whether they're approved or not, that
I -- that I've been following, anyone who is going to be absent is to
notify the chair, and that's been the procedure in the past. And so
I've gotten those phone calls when -- or letters when you're not going
to be here. I would appreciate knowing from any member of the -- of
the board if you're going to be unavailable on any of those days as
far in advance as possible. I know, you know, you wake up sick. I
mean, you can call me at home. Then I need to let the court reporter
know, obviously, as soon as possible.
MR. MANALICH: Madam Chairman, perhaps if we could take
just a very short five-minute break. And I am concerned about whether
the cost -- I don't want to enter -- enter into an agreement here
where you're expecting that we're going to have these daily
transcripts. This is going to be an onerous burden on the code
enforcement budget. I'm thinking maybe if we take a five-minute break
and discuss between opposing counsel --
MS. SULLIVAN: Well, I don't think it's necessary. I'm
pretty much charged with paying all the costs. It's already been
burdensome. I may have to get a budget transfer. What I would like
to know, if you could tell me how much per trans -- give me some kind
of ballpark figure so that I'll know if I have to go get a budget
transfer. Is that possible?
MR. MANALICH: I think this question is directed to the
court reporter.
COURT REPORTER: It depends on how long you go during
the day, how many breaks you take -- ·
MS . SULLIVAN: How about a maximum?
COURT REPORTER: -- how fast they talk. I would have to
go back and figure out a typical -- look at a typical code enforcement
day, how long it goes. You'd have to give me the length of day you're
going to do. Is it from 8:30 till 5 and an hour lunch?
"!S. SULLIVAN: Let's say the maximum for a full day.
COURT REPORTER: 8:30 to 5, an hour for lunch, a break
Page 33
December 13, 1996
in the morning, a break in the afternoon. I'd have to get back with
you. And you want it the next morning, or you when would you want
it by?
MR. ALLEN: That was my question. You're going to
provide it that-night delivery or next-day delivery?
MS. SULLIVAN: That's not necessary.
MS. DEIFIK: You want to think about a weekend.
CHAIRPERSON RAWSON: Mr. Allen would only need it by the
weekend if he'll be -- so it will be ready on the 27th, and you come
back on what day?
MR. ALLEN: Sa turday .
COURT REPORTER: So how many days is that?
CHAIRPERSON RAWSON: Well, then you've got
MR. ALLEN: Two days.
CHAIRPERSON RAWSON: -- two days, the 24th and the
25th.
MS. SULLIVAN:
thousand dollars?
what?
COURT REPORTER:
be one and a half the
have to check and get
estimate.
MS. SULLIVAN: Wouldn't it be okay as long as all of the
board members reviewed all the transcripts before the vote?
MR. ALLEN: Could we do it more economically? Can we do
a tape recorder versus a transcript? Would that work for everybody
v~~~u~ spend the money?
CHAIRPERSON RAWSON:
on the tape recorder.
MS. SULLIVAN: I guess what I'm saying, if we don't have
to have them that night or within two days or something, as long as we
have them before the vote, that would probably save me money i~ we can
do that.
CHAIRPERSON RAWSON: Well, that's very possible. We can
probably be assured that everybody had them by the 28th, and that way
everybody would be up to speed.
MS. DEIFIK: Madam Chairman. Barbara, I recall your
firm marketing at one time a procedure whereby you -- you used a
computer and it was automatically transcribed?
CHAIRPERSON RAWSON: I just asked her about that, Miss
Deifik, and that's not going to be a possibility, although I'd love to
think that we're going to be as sophisticated as they are in the O. Ji.
case.
MS. DEIFIK: She tried to sell it to me.
CHAIRPERSON RAWSON: Well, that's wonderful. I just
tried to have this -- I mean, I just had this discussion with her at
the break, and some day we're going to be that automated, and I can't
wait. but it won't be this January.
MS. DEIFIK: Okay. Then can I ask a second question.
If we are forced to produce these transcripts, what's the possibility
I guess my question is, am I talking a
Ten thousand dollars? A million dollars?
Or
All right. within two days, it would
normal rate, although it's in our contract. I'd
back with you, and it would be just purely an
Somebody has to transcribe what's
Page 34
December 13, 1996
that board members could get them on disks to make them a little built
less unwieldy?
COURT REPORTER: That's not a problem at all. We
provide them to the county on ASCII. Now, I will tell you I could do
the real-time, but I would need lots of breaks, and I would absolutely
have to have you talk slowly, everybody, and one at a time. And that
is an option. But that is not what happens in the board meeting, and
that is why we switch out reporters half days. One of my real-time
reporters is leaving, but if -- I mean, that is a possibility, but I'd
need lots of breaks.
CHAIRPERSON RAWSON: We can go with the transcripts, and
in order to, you know, expedite the matter and save the county some
money and make it easier for you, I think that if we had all the
transcripts from the 22nd, 23rd, and 27th to us by the 28th, then
we're going to resume on the 29th.. Everybody will be up to speed, and
hopefully that's the day we're going to have a vote.
MR. McCORMICK: Let me ask one thing. I sort of
instigated setting up that regular hearing on the 30th instead of the
23rd. Would it be better if we, again, flip that around so that
Mr. Allen would only miss the 22nd, and then we'd have those three
days on the second week consecutively?
MR. MANALICH: One other thought, Madam Chairman, which
is, I believe this room is equipped to audiovisual tapes of these
meetings like the Board of County Commissioners. I don't know if that
would be another alternative but --
MS. DEIFIK: I'd have to brush my hair every day.
You're asking too much.
MR. MANALICH: But the other concern I would have, I
guess; is I don't know if Mr. Hazzard's intent was that they receive a
transcript every night or if it just be before the vote.
MR. HAZZARD: I think you need to receive a transcript
in ad -- in ad -- in enough time in.advance as to allow you to make an
informed decision. You know, that's certainly up to you all. I don't
mean to suggest any type of schedule in that regard. I would just
mention that while it takes eight hours to watch a eight-hour
videotape, it takes far less to read a transcript of an eight-hour
day; so I do really think that the transcript is the way to go.
MS. SULLIVAN: Madam Chairman, I don't think that it's a
problem, because the Board of County Commissioners wants to move the
case. And if they have to do a budget transfer, I think they'll do
it.
CHAIRPERSON RAWSON: Well, I think that we just need the
transcripts available to us on the 28th. And even though I fully
intend to be here on every single day, you know, I would probably
enjoy reading back over the transcripts on the 28th, too; so we can
make them available to the whole board. And then on the 29th we
really should all be up to speed, and that would be the big day all
seven of us need to be here.
MR~ MANALICH: Well, that would be my question, is do we
necessarily have to incur these expenditures if everyone were to
attend --
Page 35
December 13, 1996
CHAIRPERSON RAWSON: No.
MR. MANALICH: -- every day.
CHAIRPERSON RAWSON: Of course not.
MR. MANALICH: So it would only be for those days where
one or more is absent.
CHAIRPERSON RAWSON: Certainly.
MR. HAZZARD: And Madam Chairman, I think
Mr. McCormick's suggestion was a good one. If we know that Mr. Allen
is definitely unavailable on the 23rd, perhaps the board would want to
consider moving whatever that other item is that was set for the 30th
to the 23rd so that we could make our final day in this case the 30th,
and Mr. Allen could be present for the 27th, 29th, and 30th, and then
the -- then the -- the absentee problem and transcript problem that we
know about now only applies to the 22nd.
CHAIRPERSON RAWSON: Tha t 's fine. We would be hearing
this case on the 22nd, another case on the 23rd, and back to this case
again on the 27th, you know, which is kind of the way I live my
litigious life every day anyway, but just so the board knows that
you're going to have to shift gears if we do this. Do you have a
preference, Miss Sullivan?
MS. SULLIVAN: I don't care. Either way will give me
plenty of time to notice it. It doesn't matter.
MR. MANALICH: So the days available will be the 22nd,
27th, 29th, and 30th?
CHAIRPERSON RAWSON: If we -- if we notice this other
case for the 23rd, yeah.
MR. HAZZARD: And, Madam Chairman, just as one other
point, can I take it as gospel that we won't get to my witnesses on
the-22nd so that I don't have to have people available until the
27th? In other words, if it's -- if it's 4:30 on the 22nd and the
county's done, will the board not look to me to say, put your first
witness on, Hazzard, or, you know, can we simply say your first
witness will not start earlier than --
CHAIRPERSON RAWSON: Well, I think that question is
better directed to Mr. Manalich. Based on what he said earlier, I
think you can probably assume he's going to take all day on the 22nd.
MR. MANALICH: Well, I think we -- depending on the
extent of the cross-examination, I think direct examination-wise it's
very possible we could finish before the end of the day that first
day. But it's when you factor in the cross-examination; that's what
leads me to say it could go beyond one day.
MS. DEIFIK: Can we use this room past five o'clock?
I'd like to get this done.
MS. SULLIVAN: I told the clerk that we'd probably need
-- there's some more meetings, regularly scheduled meetings in here
that they really don't want to put off; so what we're going to do is
close that part off. So the room will be available to us all day.
MS. DEIFIK: Okay. My question is, let's say that --
that we're all ready, willing, and able to go until six or seven
o'clock in order to get a portion of the case concluded. And in order
to conclude in the time available, I'm willing to stay
Page 36
December 13, 1996
MS. SULLIVAN: It was my understanding that they were
just going to clear it, not have anybody else in here that can't be
accommodated in that back room; so we're okay.
CHAIRPERSON RAWSON: Okay.
MS. DEIFIK: So -- so my point would be
MS. LOUVIERE: Can we have cocktails?
MS. SULLIVAN: I don't have any problem with that
either.
MR. HAZ ZARD : So moved.
MR. ALLEN: Make that a motion.
MS. DEIFIK: I have learned from -- from the judges over
the years why they won't give day certains, because things never go as
planned. And if Mr. Manalich rests at two o'clock, I want to go
forward with Mr. Hazzard's witnesses in the -- witnesses and --
MR. MANALICH: Let me put it this way. I think the
direct we have for the three witnesses in addition to Mr. Mazzone
would finish before the end of the day on the 22nd. But when you
factor in cross-examination, that's where I don't know --
CHAIRPERSON RAWSON: You probably ought to have one on
call.
MR. HAZZARD: Okay.
CHAIRPERSON RAWSON: All right. Now, procedure --
procedurally -- well, let me ask the two attorneys, because I want to
ask our attorney to talk to this board a little bit. We're all set on
the schedule, and we're set on -- hopefully nobody will miss except
Mr. Allen on the 22nd, and the rest of us will be here on the rest of
the days, and God willing, .we' re going to get this case done on the
29th. Anything else from either attorney?
- ..- MR. MANALICH: Well, I thought I heard the 30th.
CHAIRPERSON RAWSON: The 30th, I apologize.
MR. MANALICH: The 23rd will not be heard.
CHAIRPERSON RAWSON: That's correct. That's true, the
30th. Now I'd like to ask the board's attorney to procedurally give
-- give this board some advice as to reading of transcripts and any
other thing that you think we should know to prepare ourselves for
doing a good job in January.
MR. KOWALSKI: Thank you, Madam Chairman. This -- this
obviously is a little different procedure for the board. Yeah, I know
you recall that -- that we struggled. We attorneys struggled for some
time before I was comfortable in concluding that this board would
legally be entitled to proceed based upon reading the transcript. But
the -- the case authorities, legal authorities that I reviewed which
persuaded me of that, make it clear that it will be necessary for eactt
of you members to either be present during the trial time or read the
transcript for the portion of time that you"re missing. And so one --
one of your assignments for the members who were not present at the
July hearing, the other members are going to be required to review the
transcript and also the exhibits that were introduced into evidence
and just state very simply on the record that you did, in fact, make
that review. Okay? And -- and I'm going to suggest that if there are
other times -- and we know that there will be at least one conflict
Page 37
December 13, 1996
when some members are not present, that -- that you
on the record that you have, prior to your ultimate
matter, been present or reviewed the transcript for
Okay?
The other thing that I wanted to remind you is that
we're going in, finally, next month into the second day of a hearing.
The law looks at it like, gee, we met yesterday, and now we got a
hearing again today. And you -- you'll have a tendency, I think, to
review the transcript, read it, haven't heard the testimony at all or
you heard it months ago, and you'll have a tendency to want to come in
to the January meeting and discuss what you read in the transcript.
But I'm going to encourage you not to do that, because you wouldn't
begin to discuss the evidence in a case after you've only heard a
portion of the evidence. Your discussion of the evidence should wait
until you've heard all of the evidence, and then as a board you
deliberate about what you've heard and what you might want to
conclude. And so I discourage you from wanting to discuss the
transcript when you reconvene. The only exception to that would be
that if -- if one of you members feels that it is extremely important
to get one of those two witnesses back so that you as a board member
can ask an additional question, that would be acceptable. Aside from
that, let's just proceed as though -- as though you're in the second
day of a hearing and get going and get the ball running, and when we
come back here next time, we just pick up where we left off.
The last thing that I wanted to mention is that I know
that some of you are -- inevitably we will all begin to form
preliminary impressions du~ing the course of a case and wait until the
conclusion of the case to form definite conclusions. And I know that
--that your minds are racing in terms of thinking what might be some
practical resolutions to the issues that are going to -- that are
being presented here. But I do encourage you not to vocalize any
preliminary impressions that you may have made, because it could
conceivably give the appearance of your prejudging the case. Now, I
haven't heard anything at these hearings to lead me to believe that
any member has prejudged the case, but I do caution you to stick
strictly, almost like a judge would, to hearing the evidence and not
commenting on the evidence during the course of the hearing. Okay?
CHAIRPERSON RAWSON: Thank you very much for those
comments. Now, anything else further on the Lely Barefoot Beach
case?
MR. ALLEN :
Chairman.
CHAIRPERSON RAWSON: Yes.
MR. ALLEN: Would it be easier, first, and more
economical to call me like we talked about doing yesterday?
CHAIRPERSON RAWSON: Apparently not, Mr. Allen, because
we were told we had to use the pay phone to call you. And I know that
you want --
MR. ALLEN: A lot of quarters.
CHAIRPERSON RAWSON: I know you were sitting by your
Jhone in the Bahamas 'wondering why I didn't call.
make a statement
vote on this
the entire time.
I've just got one more question, Madam
Page 38
pecember 13, 1996
~urposes of hearing the next day's testimony of Board of County
Commissioners versus Lely Barefoot Beach Property Owners~
Association. All of the members who have not read the transcript of
the first day, and I might even say those of you who were here and
have copies of that transcript,. review it, and be here at 8: 30 ready
to go and ready to hear the evidence.
Anything else further to come before this board? If
not, we will stand adjourned.
*****
,
There being no further business for the good of the County, the
meeting was adjourned by order of the Chair at 10:45 a.m.
COLLIER COUNTY CODE ENFORCEMENT BOARD
/YJ~ ~ '
M. J RAWSON, CHAIRPERSON
TRANSCRIPT PREPARED ON BEHALF OF DONOVAN COURT REPORTING
BY: Barbara A. Donovan
Page 40