Agenda 01/12/2016 Item #16K 5 1/12/2016 16.K.5.
EXECUTIVE SUMMARY
Recommendation to approve a Budget Amendment to satisfy the Final Judgment in the
matter styled Penny Phillippi v. Collier County (Second DCA Case No. 2D14-5805 and
Circuit Court Case No. 14-0416CA) and approve all necessary budget amendments.
OBJECTIVE: To satisfy Court Ordered Final Judgment in litigation.
CONSIDERATIONS: The Plaintiff, Penny Phillippi, is the former Executive Director of the
Immokalee Community Redevelopment Area ("CRA"). The Plaintiff filed her Complaint on or
about February 20, 2014 alleging that Collier County, as the governing body of the CRA Board,
breached her Employment Agreement with the County. At the time that Ms. Phillippi's
Employment Agreement was set to expire, the Parties extended the terms of the Agreement to
December 3, 2015 and amended the terms of the Agreement to increase Ms. Phillippi's salary
and to modify the termination and severance provision. Following the extension, the Board of
County Commissioners properly reconsidered the item and voted to rescind the extension from
three years to one year and provided the opportunity for Ms. Phillippi to continue to work
month-to-month pending her acceptance of the offer. Approximately one week later, Ms.
Phillippi provided her written resignation to Collier County. Despite the voluntary resignation,
Ms. Phillippi filed her lawsuit alleging breach of contract.
The Parties each filed Motions for Summary Judgment to have the case considered on its merits
before trial, and Ms. Phillippi was successful. The Court appeared to not consider the validity of
the County's Reconsideration Ordinance and further ignored Ms. Phillippi's voluntary
resignation. The Court awarded Ms. Phillippi her alleged damages, attorneys' fees, and statutory
interest. The County appealed the Final Summary Judgment. The Second District Court
Appeals affirmed the Final Summary Judgment and awarded Ms. Phillippi her appellate
attorneys' fees. No further appeals are pending. The total amount now due to the Plaintiff
pursuant to the Court's Order is $80,527.94.
FISCAL IMPACT: A budget amendment moving funds from Unincorporated Area General
Fund (111) reserves to Fund (111) other G & A in the amount of$80,600 is required to pay this
judgment.
GROWTH MANAGEMENT IMPACT: None.
RECOMMENDATION: That the Board approves a Budget Amendment to satisfy the Final
Judgment matter styled Penny Phillippi v. Collier County (Second DCA Case No. 2D14-5805
and Circuit Court Case No. 14-0416CA)and approve all necessary budget amendments.
PREPARED BY: Colleen M. Greene, Assistant County Attorney
Attachments: (1) Finaf Summary Judgment Order dated November 14, 2014; (2) Appellate
Court Order affirming the Final Summary Judgment Order dated December 9, 2015; (3)
Appellate Court Order granting Attorneys' Fees dated December 9, 2015; (4) Invoice of Fees
Joseph D. Stewart, P.A.; and(5) Calculations through December 14, 2015.
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1/12/201616.K.5.
COLLIER COUNTY
Board of County Commissioners
Item Number: 16.16.K.16.K.5.
Item Summary: Recommendation to approve a Budget Amendment to satisfy the Final
Judgment in the matter styled Penny Phillippi v. Collier County (Second DCA Case No. 2D14-
5805 and Circuit Court Case No. 14-0416CA) and approve all necessary budget amendments.
Meeting Date: 1/12/2016
Prepared By
Name:NeetVirginia
Title: Legal Assistant/Paralegal, CAO Office Administration
12/29/2015 3:35:20 PM
Submitted by
Title: Assistant County Attorney, CAO General Services
Name: GreeneColleen
12/29/2015 3:35:21 PM
Approved By
Name: GreeneColleen
Title: Assistant County Attorney, CAO General Services
Date: 12/29/2015 4:13:09 PM
Name: KlatzkowJeff
Title: County Attorney,
Date: 12/30/2015 1:09:53 PM
Name: IsacksonMark
Title: Division Director-Corp Fin &Mgmt Svc, Office of Management&Budget
Date: 1/4/2016 9:00:21 AM
Name: CasalanguidaNick
Title: Deputy County Manager, County Managers Office
Date: 1/4/2016 10:06:06 AM
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*** 5052977 RCLERK OFGTHE6CIRCUIT COURT11COLLLIER4COUNTY FLORIDA 1 *y 1/12/2016 16.K.5.
REC $10.00
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY,FLORIDA CIRCUIT CIVIL
PENNY PHILLIPPI,
Plaintiff, Case No. 2014 CA 416
ra
VS. f 1., _c- C?
r-_
n ,-
COLLIER COUNTY,a political = -
subdivision of the State of Florida, �' `
r'>
Defendant. !? cn
CD
FINAI,Jt$.ro., .ity . air t l NT
Pursuant to the Order d.ted 0 . . - _ ,2014, : antin: lai tiff,PENNY PHILLIPPI's
Motion for Final Summary J •g -nt it is h= -:y
ORDERED,ADJUD E 1� ' < <� ��..
''' _
1. The Plaintiff,PE 1 r,; - .r _ a ' =�•vey I�r efendant,COLLIER
COUNTY,a political subdivi '6"*. the State of Flori. ,,,,•e.u� 42,394.20,plus prejudgment
l" A
interest from January 22,2013 t' ;it October 23,2015 in ount of$3,526.28 for a total of
$45,920.48, for which let execution e. M;r -• 'II•• - r amount shall bear interest from the
date of this Order at the statutory rate of inter-
2. The Court awards attorney fees pursuant to Florida Statute §448.08 and reserves
jurisdiction as to the determine of the amount attorney's fees and taxable costs. g-
DONE AND ORDERED in Chambers at Naples,Collier County,Florida on this the / 1
day of November,2014. -
JAM.. . S 0
CI';► IT COURT JUDGE
Conformed copies electronically provided to:
Greg Wood,Esquire(gwoods @lawfirmnaples.com)
Coleen M. Greene,Esquire(colleengreene @colliergov.net)
Joseph D. Stewart,Esquire Qstewar @jdslegal.com)
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NOT FINAL UNTIL TIME EXPIRES TO FILE REHEARING
MOTION AND, IF FILED, DETERMINED
IN THE DISTRICT COURT OF APPE4 S
OF FLORIDA
-�
SECOND DISTRICT t,, - rn
N
COLLIER COUNTY, a political )
subdivision of the State of Florida, )
Appellant, )
v. ) Case No. 2D14-5805
)
PENNY PHILLIPPI, )
)
Appellee. )
)
Opinion filed December 9, 2015.
Appeal from the Circuit Court for Collier
County; James R. Shenko, Judge.
Colleen M. Greene of Collier County
Attorney's Office, Naples and Gregory N.
Woods of Woods, Weidenmiller, Michetti &
Rudnick, P.L., Naples, for Appellant.
Joseph D. Stewart of Joseph D. Stewart,
P.A., Naples, for Appellee.
PER CURIAM.
We dismiss Collier County's appeal of the circuit court's order granting
Penny Phillippi entitlement to recover her attorney's fees, because the order reserved
jurisdiction to determine the amount. See Mcllveen v. Mcilveen, 644 So. 2d 612, 612
(Fla. 2d DCA 1994) ("[A]n order which only determines the right to attorney's fees
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1/12/2016 16.K.5.
without setting the amount is a nonappealable, nonfinal order."). We affirm on all other
issues raised in this appeal. See Collier Ctv. v. Curry, 166 So. 3d 967 (Fla. 2d DCA
2015); cf. City of Miami v. Bus Benches Co., 174 So. 2d 49, 52-53 (Fla. 3d DCA 1965)
("A municipality is bound to recognize its contracts, the same as an individual and one,
party to a contract with a municipality, is entitled to the constitutional protection against
impairment of it if the municipality attempts to unilaterally change its obligations under a
valid agreement." (citations omitted)).
Affirmed in part; dismissed in part.
WALLACE, CRENSHAW, and LUCAS, JJ., Concur.
- 2 -
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IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
SECOND DISTRtCT, POST OFFICE BOX 327, LAKELAND, FL 33802-0327
December 9, 2015
CASE NO.: 2D14-5805
L.T. No. : 14-0416-CA
Collier County v. Penny Phillippi
Appellant/ Petitioner(s), Appellee / Respondent(s). -�
BY ORDER OF THE COURT: — 1-11
a
--4'T:
Appellee filed a motion for appellate attorney's fees pursuant to section 4408,
Florida Statutes. Appellee's motion for fees is granted in an amount to be determin Pby gym
the trial court. o -�
I HEREBY CERTIFY that the foregoing is a true copy of the original court order.
Served:
Gregory N. Woods, Esq. Colleen M. Greene, Esq. Joseph D. Stewart, Esq.
Dwight E. Brock, Clerk
sg
Ma Elizabeth Kuenzel l,kt, tiV4,,�
Clerk
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JOSEPH D. STEWART, P.A.
Suite 302 1/12/2016 16.K.5.
2671 Airport Road South
Naples, Florida 34112
Telephone: 239-775-4450
Facsimile: 239-775-8581
Tax Identification#65-0564413
Page: 1
Penny Phillipi 12/14/2015
ACCOUNT NO: 469-001M
Statement No: 1
Phillipi v. Collier County
DRAFT STATEMENT
HOURS
1/16/2014 JDS Review documents and telephone conference with Penny. 0.80 360.00
1/17/2014 JDS Telephone conference with Mr.Wood Draft email. 0.20 90.00
1/24/2014 JDS Receipt and review email; receipt and review accomplishments, Draft email. 0.20 90.00
1/27/2014 JDS begin drafting lawsuit; Draft email. 0.90 405.00
JDS additional drafting of complaint 0.70 315.00
1/28/2014 JDS Receipt and review email; Draft email. 0.10 4. J
JDS Finished drafting the complaint, re-review the minutes of the various commission
meetings. 1.30 585.00
PK Review initial draft of Complaint; Make revisions and adjustments; Scan in
documents to computer file. 0.60 105.00
1/29/2014 JDS Additional changes to the complaint, draft email 0.30 135.00
JDS Additional amendments to the complaint; draft email. 0.30 135.00
1/30/2014 JDS Receipt and review email; Draft email. 0.10 45.00
2/01/2014 JDS Receipt and review email with performance evaluations; Draft email. 0.30 135.00
JDS Receipt and review extensive history on employment, draft email. 0.30 135.00
JDS amend complaint 0.10 45.00
2/03/2014 JDS review board of directors minutes. 0.20 90.00
2/06/2014 JDS Receipt and review email; Draft email., Draft affidavit 0.30 135.00
JDS Receipt and review email; Draft email. 0.10 45.00
JDS Continue drafting affidavit after reviewing underlying documents, instructions to staff 0.50 225.00
JDS Receipt and review email; Draft email. 0.10 45.00
2/07/2014 JP revisions to complaint and affidavit and e-mail to client regarding same. 0.10 7.50
2/11/2014 JDS Receipt and review email; Draft email. 0.10 45.00
2/18/2014 JDS Receipt and review email; Draft email. 0.10 • ,
2/20/2014 JDS final review of the complaint and attachments., draft correspondence, telephone
conference with woods 0.40 180.00
JDS ; Draft email. Packet Page-2302- 0.10 45.00
Page: 2
Penny Phillipi 015
1/12/2016 16.K.5
Statement No: 1
Phillipi v. Collier County
HOURS
JDS Receipt and review email regarding acceptance of complaint; Draft email. 0.10 45.00
JP revisions to complaint; draft acceptance of service; e-file complaint with court;
confirmation of same from the clerk; e-mail to client advising complaint had been
filed. 0.30 22.50
2/21/2014 JP Receipt and review email from Attorney Woods regarding acceptance of complaint;
draft Acceptance of Service for County Attorney Klatzkow; draft correspondence to
Attorney Klatzkow regarding same. 0.30 22.50
2/24/2014 JP Receipt and review email from attorney Woods regarding complaint and acceptance
and my reply to him regarding same. 0.10 7.50
JP Receipt and review of e-mail from court regarding executed Acceptance of Service;
e-mail from Attorney Woods regarding same and my response to him. 0.10 7.50
JDS Receipt and review email; Draft email. 0.10 45.00
2/25/2014 JDS Receipt and review email; Draft email. 0.10 45.00
3/01/2014 JDS Receipt and review affidavit, draft motion for summary judgment, draft email 0.60 270.00
3/03/2014 JDS Receipt and review email; Draft email. 0.10 45.00
JDS Receipt and review email; Draft email. 0.10 45.00
3/C 114 JDS Office conference with client 0.80 360.00
3/05/2014 JDS telephone conference with Greg Woods re: consolidation 0.10 45.00
3/09/2014 JDS Receipt and review email; Draft email. 0.10 45.00
3/14/2014 JDS Receipt and review answer and affirmative defenses, draft email 0.30 135.00
3/15/2014 JDS legal research regarding extent of damages (split 1/2 with Curry's case) 0.60 270.00
3/17/2014 JDS Additional legal research on measure of damages and discussion with employment
lawyers regarding same (1/2 time included) 0.60 270.00
5/14/2014 JP instructions from Mr. Stewart; revise complaint; draft Notice of Unavailability 0.20 15.00
5/15/2014 JDS review affidavit, review payment-Thank you.stubs, amend affidavit, review affidavit
of HR 0.40 180.00
JDS review file, review previous affidavit, review payment stub and HR affidavit in Chris
case and amend affidavit and draft detailed email to client regarding the differences. 0.40 180.00
5/22/2014 JDS amend affidavit, office conference with jp 0.30 135.00
5/30/2014 JP revisions to affidavit 0.30 22.50
5/31/2014 JDS ; Draft email. 0.10 45.00
JDS ; Draft email. 0.10 45.00
3/i 114 JDS amend motion for sj, amend affidavit 0.20 90.00
3/02/2014 JP e-mail to client re draft Affidavit; 0.10 7.50
JP revisions to Motion for Summary Judgment 0.20 15.00
JP revision to Motion for Summary Jud Packet Page-2303--mail to client; 0.20 15.00
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Penny Phillipi 1/12/2016 16.K 5.0 5
Statement No: 1
Phillipi v. Collier County
HOURS
6/04/2014 JDS Receipt and review email; Draft email. 0.20 90.00
6/24/2014 JP instructions from Mr. Stewart; e-mail to Mr.Woods regarding deposition of
Commissioners; 0.20 15.00
7/01/2014 JP Receipt and review email from County Attorneys office re deposition dates for
Commissioners; reply e-mail to County Attorney; e-mail to client regarding same. 0.20 15.00
7/02/2014 JDS Receipt and review email; Draft email. 0.10 45.00
JDS Receipt and review email; Draft email re: depos 0.10 45.00
7/17/2014 JP check court file for Judge reassignment; check JACS for available hearing dates
with Judge Shenko; e-mail to County Attorneys office regarding status of deposition
dates and obtaining a hearing date for our msj; 0.20 15.00
JDS Receipt and review email; Draft email. 0.10 45.00
7/18/2014 JDS Receipt and review email; Draft email. 0.10 45.00
7/21/2014 JDS Receipt and review email; Draft email. 0.10 45.00
JDS Receipt and review email; Draft email. 0.10 45.00
7/22/2014 JDS draft SDT and request to produce 0.20 ""'
7/23/2014 JP instructions from Mr. Stewart regarding depositions duces tecum and the items they
are to bring with them; re-draft Notices of depositions for Commissioner Hiller,
Nance and Henning; draft Request for Production. 1.00 125.00
JP Receipt and review email from County Attorney's office regarding location of Hiller's
deposition and return email regarding same. 0.10 7.50
JP e-mail to County Attorney's office re available dates for our msj hearing. 0.10 7.50
7/24/2014 JP e-mail to County Attorney's office re deposition dates for Commissioners; 0.10 7.50
JDS Receipt and review email; Draft email. 0.10 45.00
JDS Receipt and review email; Draft email. 0.10 45.00
JP Receipt and review email from County re Penny's deposition; e-mail to client
regarding same. 0.10 7.50
JDS Receipt and review email from client regarding deposition date; e-mail to County
Attorney's office confirming Oct 2nd as depo date for Penny; e-mail to client
confirming same and enclosing deposition Article. 0.20 90.00
7/30/2014 JP Receipt and review email from County regarding dates for msj hearing; reply email
as to our availability; e-mail from County none of those dates will work, they will get
new dates. 0.20 15.00
7/31/2014 JDS Receipt and review email; Draft email. 0.10 45.00
JDS Receipt and review email; Draft email. 0.10 45.00
3/04/2014 JP draft and file Notice of Hearing re out msj; 0.20 15.00
3/05/2014 JP draft notice of hearing for msj; 0.20
JP e-mail from client; e-mail to client regarding various deposition dates and hearing on
msj; 0.20 15.00
3/21/2014 JDS Receipt and review email; Draft em;Packet Page-2304- and depo 0.20 90.00
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Statement No: 1
Phillipi v. Collier County
HOURS
8/25/2014 JDS Receipt and review email; Draft email. 0.10 45.00
8/26/2014 JDS Receipt and review response to request to produce 0.20 90.00
9/06/2014 JDS receipt and review docs filed with judicial notice 0.30 135.00
JDS initial review of response to motion for summary judgment and all attachments 0.40 180.00
9/07/2014 JDS inst to pk mre: msj docs 0.10 45.00
9/09/2014 JDS Receipt and review email; re: depo 0.10 45.00
JDS Receipt and review email; Draft email. 0.10 45.00
JDS Receipt and review email; Draft email. 0.10 45.00
JDS begin preps for 3 depos and review of opposition to msj by county; 0.60 270.00
9/10/2014 JDS begin to review the ocean of doc in response to our msj, start to index evidence, 1.20 540.00
9/12/2014 JP prepare production notebook for JDS to review in preparation for depositions; 1.00 75.00
JDS review county production in preps for depo 1.20 540.00
JDS legal research regarding issue one on the motion for sj, incorporation of law into a
contract. 1.20 540.00
JDS review docs provided by client in prep for depo, depo preps 0.70 315.00
JDS Draft email. depos 0.10 45.00
9/13/2014 JDS legal research on the remaining issues, draft response to motion for summary
judgment, review exhibits and transcripts 5.70 2,565.00
9/14/2014 JDS additional research on Brandt, amend memo of law, review transcript of previous
hearing. 2.10 945.00
9/18/2014 JDS telephone conference with penny in prep for depo 0.20 90.00
3/19/2014 JDS initial on line review of response, instructions to jp re changes 0.30 135.00
JP revisions to reply and correspondence to Judge Shenko; preparation of hearing
booklet for Judge;telephone call to courier for hand-delivery; e-mail to attorney
woods regarding same. 0.30 22.50
3/20/2014 JDS amend response, instructions to jp, work on hearing 0.60 270.00
JDS initial review of ovals, prepare for depo of Hiller, 0.70 315.00
JDS Receipt and review email; Draft email. 0.70 315.00
3/23/2014 JDS Receipt and review email; Draft email. response to motion for sj 0.10 45.00
JDS Receipt and review email; Draft email. 0.10 45.00
JDS prepare for depos, review board minutes and contracts 0.90 405.00
JDS review cases on employee resignation 0.40 180.00
3/24/2014 JDS prepare for and attend depo of Nance, post depo conference 1.70 765.00
JDS prepare for and attend depo of client 1.50 675.00
JDS prepare for and attend depo of client 1.80 810.00
3/25/2014 JDS prepare for and attend depo of Henning 1.20 540.00
JP e-mail to client regarding hearing; conference with Mr. Stewart regarding upcoming
depositions; 0.10 7.50
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Statement No: 1
Phillipi v. Collier County
HOURS
9/29/2014 JDS prepare for and attend depo of Hiller 0.60 270.00
JP prepare hearing notebook for JDS;telephone call with court reporter re attendance
at hearing; draft two orders for hearing. 0.30 22.50
9/30/2014 JDS draft order, legal research regarding: cases cited by Collier,prepare for and attend
hearing on motion for summary judgment 2.50 1,125.00
0/02/2014 JDS Receipt and review email fees 0.10 45.00
0/06/2014 JDS Receipt and review transcript and draft email 0.20 90.00
0/07/2014 JDS review transcript, draft order granting motion for summary judgment, draft final
summary judgment, draft email, office conference with jp re: status 0.40 180.00
0/09/2014 JDS amend order granting summary judgment,final summary judgment 0.20 90.00
0/10/2014 JP revise proposed Order and Final Judgment; e-mail to Wood regarding same. 0.20 30.00
0/16/2014 JDS draft email re:judgment and order 0.10 45.00
JDS Receipt and review email; Draft email.final judgment 0.10 45.00
0/20/2014 JDS Receipt and review email with changes to order and Draft email. 0.20 90.00
JDS Receipt and review email; Draft email.final judgment 0.10
JDS amend judgment
0/21/2014 JDS Receipt and review email; Draft email the order 0.10 45.00
0/23/2014 JDS Receipt and review It to judge 0.10 45.00
0/27/2014 JDS office conference with jp re: attny fees,. 0.10 45.00
JP conference with Mr. Stewart regarding attorney fee hearing; 0.10 7.50
0/28/2014 JDS Receipt and review email; Draft email. 0.10 45.00
0/29/2014 JDS Receipt and review order, emaill; Draft email.;office conference with jp re status 0.20 90.00
1/01/2014 JDS legal research regarding multiplier 2.00 900.00
1/10/2014 JP telephone call with Penny Phillippi; e-mail to Ms. Phillippi regarding Appeal notice;
instructions from Mr. Stewart; draft correspondence to Judge Shenko re Final
Judgment; 0.30 22.50
1/11/2014 JDS Receipt and review email; re: final judgment 0.10 45.00
1/15/2014 JDS Draft email. draft email 0.30 135.00
1/16/2014 JDS Receipt and review email; Draft email.re: appeal and reconsideration ordinance 0.20 90.00
JDS work on expected appeal argument--robert's rules of order, analyze collier county
ordinances, outline argument 1.80 81'' "O
JDS Receipt and review email; Draft email. re: appeal issues 0.20
1/17/2014 JDS telephone conference with municode, legal research regarding municode annotated 0.40 180.00
1/18/2014 JDS Receipt and review judgment, Draft Packet Page-2306- 0.20 90.00
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Statement No: 1
Phillipi v. Collier County
HOURS
JDS research robert's rules of order on a contract, outline issue 0.30 135.00
1/21/2014 JDS Receipt and review email; 0.10 45.00
1/23/2014 JDS work on appeal argument 0.20 90.00
2/05/2014 JDS work on demonstrative exhibit for appeal 0.30 135.00
2/15/2014 JDS Receipt and review notice of appeal. draft ermail 0.20 90.00
2/22/2014 JDS Receipt and review email 0.10 45.00
JDS Receipt and review directions to clerk and designation of record. 0.20 90.00
1/29/2015 JDS Receipt and review index on appeal, draft email 0.20 90.00
2/13/2015 JDS Receipt and review email; Draft email.appeal 0.10 45.00
JDS Receipt and review email; Draft email appeal 0.10 45.00
3/29/2015 JDS Receipt and review initial brief, draft email 0.40 180.00
3/30/2015 JDS Receipt and review email; Draft email. 0.20 90.00
JDS begin review and analysis of brief 0.60 270.00
31.. _J15 JDS draft motion for fees 0.20 90.00
4/01/2015 JDS review brief and compare attorney fee section to Curry, amend curry response 0.30 135.00
JDS review previous attorney fee cases and check for new law, compare administrative
remedy argument to Curry and review county court case, revise administrative law
section of appeal, instructions to staff 0.60 270.00
4/02/2015 JDS Review record on appeal, office conference with pk, legal research regarding
complete hearing transcript 0.30 135.00
JDS read transcript on appeal 1.20 540.00
4/05/2015 JDS work on brief. amend statement of facts, review record on appeal, work on estoppel
section, review case law 2.70 1,215.00
JDS amend brief with robert's rules of order. i/s, draft email 0.30 135.00
JDS amend appeal brief 0.20 90.00
4/06/2015 JDS Receipt and review email; Draft email.re: record references 0.20 90.00
JDS Receipt and review email; Draft email., amend brief 0.30 135.00
JDS Receipt and review email; Draft email. 0.10 45.00
JDS work on brief 1.30 585.00
4/10/2015 JDS amend appeal brief 0.80 360.00
4/21/2015 JDS review and revise brief 0.40 180.00
4/2""'015 JDS Proofread brief and appendix. 0.60 270.00
4/21/2015 JDS Receipt and review email; Draft email. 0.10 45.00
4/28/2015 JDS Receipt and review email re: appeal 0.10 45.00
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Statement No: 1
Phillipi v. Collier County
HOURS
5/01/2015 JDS Legal research regarding ATTNY FEE AWARD 0.30 135.00
5/18/2015 JDS Receipt and reply brief, Draft email. 0.30 135.00
7/01/2015 JDS telephone conference with woods, draft email 0.20 90.00
7/12/2015 JDS Draft email status of suit 0.10 45.00
7/13/2015 JDS Receipt and review email; Draft email status of appeal 0.20 90.00
7/28/2015 JDS Receipt and review email; Draft email status 0.20 90.00
JDS Receipt and review email; Draft email.supplemental authority 0.10 45.00
7/29/2015 JDS Receipt and review email; Draft email. supplemental authority 0.20 90.00
7/30/2015 JDS Receipt and review email; Draft email.supplemental authority 0.20 90.00
JDS Receipt and review email; Draft email.service on penny 0.10 45.00
3/21/2015 JDS Receipt and review email; Draft email. status 0.10 45.00
JDS Receipt and review email; Draft email.re: status 0.10 45.00
3/22/2015 JDS Receipt and review email; appeal assignment 0.10 45.00
2/09/2015 JDS Receipt and review order, telephone conference with jp re: client notification 0.10 4. J
2/10/2015 JDS Receipt and review email; Draft email. 0.20 90.00
2/11/2015 JDS Receipt and review order, office conference with JP, draft email 0.20 90.00
JDS Draft email settlement 0.10 45.00
2/12/2015 JDS Receipt and review email; Draft email.computation of amount 0.10 45.00
For Current Services Rendered 72.30 29,820.00
RECAPITULATION
Timekeeper Hours Rate Total
Joseph D. Stewart 64.70 $450.00 $29,115.00
Patricia A. Kullen 0.60 175.00 105.00
JoAnn Price 5.60 75.00 420.00
JoAnn Price 1.20 125.00 150.00
JoAnn Price 0.20 150.00 30.00
2/20/2014 Clerk of Court- Filing Fee for Complaint. 403.00
3/22/2014 Mail Station Courier- Hand delivery of documents to Judge Shenko. 10.00
3/25/2014 Gregory Court Reporting Service, Inc. - Fee for reporting the deposition of Tom Henning. 60.00
3/25/2014 Gregory Court Reporting Service, Inc. - Fee for reporting the deposition of Tim Nance. 60.00
3/30/2014 Westlaw online reserach charges. 1
3/30/2014 Gregory Court Reporting Service, Inc. - Fee for deposition of Georiga Hiller. t.„
3/30/2014 Gregory Court Reporting Service, Inc. - Fee for Deposition of Penny Phillipi. 146.20
3/30/2014 Gregory Court Reporting Service, Inc.- Fee for Deposition of Georgia Hiller. 60.00
)/06/2014 Gregory Court Reporting Service, Inc. - Fee for reporting hearing before Judge Shenko. 99.55
)/23/2014 Mail Station Courier- Fee for hand Packet Page-2308-iko. 10.00
Page: 8
Penny Phillipi 1/12/2016 16.K 5.°15
Statement No: 1
Phillipi v. Collier County
1/30/2014 Westlaw-online research charges. 8.49
4/30/2015 Westlaw-online reserach charges. 37.57
5/31/2015 Westlaw-online research charges. 76.12
Total Advances 1,197.61
Total Current Work 31,017.61
BALANCE DUE $31,017.61
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Draft Statement Run Totals 12/14/2015
Statements Printed: 1 1/12/2016 16.K.5.
Hours: 72.30
Fees: 29,820.00
Advances: 1,197.61
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1/12/2016 16.K.5.
PENNY PHILLIPPI
VS
COLLIER COUNTY
Judgment Amount $ 42,394.20
Costs $ 1,197.61
Total Attorney Fees $ 28,875.00
Plus fees from 07/28/15 - 12/12/15 $ 810.00
TOTAL $ 73,276.81
Post Judgment Interest at 4.75% $ 3,724.85
(11/14/14 through 12/14/15 [395 days] at per diem of$9.43)
($42,394.20 x 4.75%= $2,013.72-365=5.52)
Prejudgment Interest(awarded by Court) $ 3,526.28
TOTAL WITH INTEREST $ 80,527.94
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