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LongvooJ Ciry Commission Chxmhers
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SPECIAL MEETING
MINUTES
Soprnnber l4, 1999
Mayor 1?,ul I.ovesmnd
Oepury Mayor Sreve Millar
Commissioner llhn Aodenon
Commissionu Aanamarie Vac,a
John J. IJrago, City Adminisrcaror
Richard S ]'aylor, Jr, City Arcomey
Uonoran ltoprl, l;srl., Ca-Counsel
R~dn n. naar~rd,, nepnry city cl¢k
AI3SEN]': Commissioner l2useg Alilas
1. CALL TO ORDGR.
'1'he,myorealled aspecial messing ro ordn az ]:02 p.m.
2. ANNOUNCEMENT RY MAYOR. the mayor read the tollorving-.,nnoun<cmenr
1'Ar nremhers af<be La,rgrvood G[y Coarmimon,MynrFard Lo,emm~d DrpnrynlynrSUu
nL]Lr, Comneimioner D~eAndmon, and Commirrionu'Anrtmrrmte V/ttu, ailb (ammexianer'
1{rury AU'ler ubrw~t, nv'!linert in dnredrwian ,nv(b lbe G'iry flnamg~, Iliab/rdS. Trybr, Jr,
Dono,an Itap<r; Lrg., romri„n( C.iry Admini+nvlor Jabn). Drvga, m,du Conrz IGpoar,//rrbe
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viii be mnd,rrrJ in wrurd/„m uirb fGrida Srarr,rrr. Cfxynr 286.OIr[8J.
3. RECESS TO CIASED SESSION.
'lhe tity commission recessed az"1:OJ p.m. ro a closed session.
J. RECONVENE SPECIAL MEETING TO ANNOUNCE THE TIME OP
ADJOURNMENT OF CLOSEll SESSION.
the <iry <o mened ar]:llp.m. and the nayor announced the closed.ess:on
adloumed am"lioion reco
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F0.2Tk.~ BY. J Ler
xICHARD T EsgIIIxE
531 nog T ackxROad
Longwood, rFL 32'150
DGNOVAN x PER, ESQUIRE
919 W. SCate Road 436
Altamonte Syringe, FL 32']14
APPEARING ON BEHALF OF THE DEPENDANT
ALSO PRESENT: Paul Lovestrand, Mayor
Seeve Hiller, Depuey Mayor
Dan Anderson, c
John nrago, CitymAdministra[or
AnnaMarie Vacca, Commissioner
P R O C E E D I N G S
MR. LOVESTRAND: We'll call the September 13th
special meeting to order. I have an announcement,
Members of [he Longwood City Commission. Mayor Paul
Lovese rand, Deputy Mayor Steve Miller, commissioner Dan
Anderson, and Commissioner AnnaMarie Vacca with
Commissioner Rusty Miles absent will meet in closed
session with the city attorney Richard s. Taylor,
Donovan Ropes, Esquire co-counsel, city administrator
Sohn Drago, and Che cou.rC reporter for the purpose of
discussing pending litigation for Morr s, ee. al.
versus City of Longwood. The meeting will be conducted
in accordance with Florida Statutes Chapter 286.011,
Paragraph 8, and we'll now recess rt and close the
MR. LOVESTRAND: I will entertain a motion [o
suspend she rssle, so we can have free discussion.
Is there a second?
MR. MILLER: Second the motion.
MR. LOVESTRAND: All in favor, say aye.
THE BOARD: Aye.
MR. LOVESTRAND: The motion carries, Mr. Taylor.
MR. TAYLOR: I m [he city attorney, Mr. Taylor. 2
wanted [o meet tonight to discuss this Morris versus
City of Longwood case. The city admivist razor and I met
with Attorney Sones and his clients here about two weeks
ago to discuss settlement. I ve also met with the
Brstorrc Society to get their input and feelings on the
matter. easrcally, Mike Soves and his clients are
saying no[ only do they want Che street closed from
Wilma, the street out here on the side, down on
MR. ORACO. you mean open?
MR. TAYLOR: Well, left open, E keep saying it
they actually put an entire street all [he way up Co 927
to remain open. The o e person [ha[ lives at [he other
end of the street that got out of the litigation, aow
they're stating that they will allow that to be open.
The ho[ dog vendor guy over here (indicating) was
protesting saying ie would have required him Co back his
ho[ dog trailers out, and he wanted even Char to remain
open. Au[ the overall consensus Erom that group is that
they would allow that portion [o be closed, but they
also want Co remarn open Wilma from Warren all [he way
down to Highway 434, and there's a lot of booths from
City Hall down to Bay scree[, nevermind the ones all ehe
way down. They azen t willing to go and just close half
of Warren from here to Wi 1ma. They want the whole
thing -- 2 say closed -- to remain open.
So basically, that, in essence, rs probably half
or close to half of [he booth areas Chat [hey want to
eliminate from this festival. The Historic Preservation
Society agrees, basically, with the advice I gave them,
which is at ehis point not to concede leaving any of the
proposed streets open. The reason for chat is, as 2
explained a[ our last executive session, T feel that the
law is entirely on our side in this matter. I have
concerns that if we even agree to close par[ of it, ChaC
homeowner or busrness owner is going to be the next one
to say, well, you closed this for them, now you close
our portion, so at sees a precedent that we ve done
that.
As far as the status of Che litigation, Sudge
Freeman denied my motion to disqualify him as the judge.
Ne then also denied my motion for reconsideration on it.
He cited a couple of cases and his reasonings, Ywo
cases, one of which had a little biY of merit but was
distinguishable from the situatron rn this case, and the
other one had, I thought, no merit wha[soeve r, and I
pointed that out [o him. Artd he summarily, without
hearing, denied the motion foz reconsideration.
Then Hike Sones set a hearing to get injunctive
relief. That was held last Thursday. He has now set a
hearing for the injunctive relief for Wednesday, October
6th at 9:00 a.m. S don't feel this case is going to
settle unless we are to fold and close these two
streets, and I think we might as well just give up on
the festival if we are going to do that. I think we'll
destroy the festival, and I think the Historic Socieey
backs me on [hat.
As I talked last time about bringing Donovan Roper
tn, he's worked with us on Che billboard suit [hat we
had against us with Hardin and the litigation againse
[he City and done an excellent job. I though[ it would
be very effective -- particularly for some long shot
that Judge Freeman actually hears ehis -- it's even more
important to have him involved. 2 don't think that will
ever happen, but S just think as far as to handle [his
case effectively to have nr. Roper on board would be
beneficial to the City and to me.
I've discussed with him -- 2'11 let him talk more
about this. we have two different approaches [o Cake
now. One rs to 9o to the Rif th Dr et rict Court of
Appeals in -ayeona Beach. There is a three-judge panel
over [here that hears appeals from the crrcurt court,
and one would be Co appeal the decision of nudge Freeman
eo not remove himself from the case.
Mike Jones sent one of his associates to this
hearing and asked him for [rme Eor the injunctive
relief, and he even mentioned -- he said, have you
looked at all the cases in the last two years against
Sudge Freeman Eor wzrts of prohibition in the Fifth DCA
that have been granted where he wouldn't get off the
case, and the Fifth DcA made him get oft cases.
This is not an unusual situation with him, but we
can go there and chat possibly would delay -- my ovly
concern 1s that if we do Chat, and if the court trr es to
re-assign us to a different judge, that wouldn'e serve
our purpose. Another effective ehing to do that was
really Mr. Ropers idea would be Co -- since they are
asking £or federal remedies in here, is eo remove this
to the federal district court, and that would be more
eff ece ive for many avenues including: judges who have
knowledge concerning [he type of relief that they are
asking £or in here, having a more neutral playing field,
time factors that will benefit us, and so forth.
we have not finalized, actually, what we re going
to do, and we may end uo doing a combination of both for
various strategy reasons that we ve discussed. We need
to discuss those mare, but that's my plan. I wan[ to
move forward on defending this suit. I wanted Co let
you know what the status was, getting input from you,
and some marching orders.
MR. LOVEETRAND: Does Mr. Roper want to speak?
Mx. RopER: Yee, sar. 2'm very recently on the
case, not fully on board, but i ve been talking with
Richard about it £or a couple of weeks. 2 know what has
been going on, and I read [he complaint quite a while
I suggested to Richard [haC you all consider
removing rt £rom federal dis[ri c[ court, if it's not too
late. 2 had urged Richard to be very careful, very
guarded, in the way he ohrased pleadings in the state
crrcuit court case to _ cifically withhold and reserve
any right to object [o the jurisdiction of [he cr rcurC
court over the case.
You ve go[ two federal amendments and federal
crvil rights statutes ehae ehey're going at you from;
Fifth Amendment, Fourteenth Amendment, and Section 1983,
which is [he crvil rights statute. This is what they
call a [emporaiy-takings case. Usual takings cases,
like the one we have in ERM with Ali Molamed (ph), but
tnia is aifferane in chac rt ra a trans~enc e~enc. xt a
going [o be over after a couple of days and no one as
really - they're not even really alleging this is a,
quote, unquote, true-Cakings case.
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the problem that we run into historically, and
.t s noe ao ranch snage ereeman, ~c e fuse seaee c~rcn~c
juages aen'c unaerseaaa feaeral e~~il rignra laws. Ana
what you get is -- sometimes you get -- and ie snot
necessarily an unknowledgeable or an ignorant judge.
You just get someone that doesn't deal with this day in
and day out. We prefer to have these kinds of cases
question decided by a federal judge, because the
Eleventh Circuit Coure of Appeals is a lot beteer than
the Fifth District Court of Appeals in the state system.
Another good reason why it would be behoove you [o
think about doing Chat. is because it will buy you more
time. And in [he effort to buy more tame, I think Chat
suite your purpose, and that rt keeps a decision from
being made, meaning that Che festival goes on unless a
court rules on vt.
Now, historically, federal courts are a lo[ more
slow moving Chan circuit courts, especially on questions
Iike Chis. Not only Cha[, yon don'[ have hearing wars.
You don't have hearings as much in federal court as you
do in slate circuit Coure. For some reason, [ate
judges love Co have hearings over even minuscule, minor
issues- Federal judges are [he opposite. You done see
[hem until pretrial conference and then trial.
Everything is argued through pleadings and paperwork.
if you done -- r_ we remove t, then Mike Jones
could, theoretically, come back and try to unremove it,
that rs, ove rC. back down to state crrcuit court on an
argument that, look, yo'a've already appeared in the
state crrcur[ coure. You ve been to several hearings.
You've argued motions to disqualify Judge Freeman.
You've lost. You've given up. You ve warved your right
Mike Jones does quite a bic of federal civil
rights Iaw, and he may be aware of some of the case law
that's out there that does stand for Chat. That's why 1
told Richard to be very guarded in phrasing everything
that we re not agreeing -- that we re properly in front
of the state crrcuit court here by simply appearing at a
hearing by simply f'il ing a motron on behalf of ehe CiCy.
The other option that Richard hit on rs staying in
state crrcuit court and trying [o Cie everything up, and
again, buy yourself some more irme here with the wrrc or
prohibition. A11 that is rs an appeal of Che judge's
order denying the motron [o disqualify hi.m. I m a
little less optimistic about that being as successful.
Even though ehere are lots of cases rn which the
Fifth ECA has granted wrrts of prohibition against Judge
Freeman, I think that Richard has -- by one me rrtorrous,
maybe two out of four grounds -- that he listed in his
mot von as he ran against the guy in a judicial election,
the Board of Governors. That is a pretty good reason.
I mean, the standard Chat says you should or should no[
d isgr~a l.i Ey yourself is whether or not it states a
reasonable fear chat you, as a lawyer, and your client
are not going to gee a fair and impartial trial. And i£
vt states a legally suffici ene reason, then Judge
Freeman has got to do it. To me, Chat, rn and of
v[se1f, >s enough. The fwo guys ran against each other.
They have a track record. I think that's a me rrtoxvous
argument. tut I'm not going [o tell you -- I don't have
a glass ball, a crystal ball, and the Fi.F[h DCA is
not orv ous for noe wanting to make decisions.
MR. LOVE'STRAND: Wouldn't you think -- we ve had
one drop out. If we go to federal coure, and they see
the delays, v[ s probably more expense Co them. There
will be others that will drop out.
MR. ROPER: I think so; hence, that sL rategy. I
chink -- you're making it clear to them that number one,
you're noL messing around. Number two, at s goiny eo
stretch vt all out. 2 think you will sta_t seeing a loe
MR. MILLER: Not ovly [ha[, I really believe that
[here's only one person Chat's paying this bill. I
don't Chink iC s the people [hat are rnvolved in st.
It s an outside person that's stirring this up. How
much more expense is it [o Chat person to go and
take -- for Mr. Roper to 9o up onto a different court
level? Will they have to expend more money now.
MR. RoeeR. well, there's more paperwork from our
side, but it s very easy role paperwork to go crank out.
it will make Mike work a little bit more.
MR. TAYIAR: Bu[ the only thing I'll say about
Chat is Mike Sones rs infamous for taking on cases. I
don't think he's been paid very much money to this day.
He s the type, and he's done it rn other cases, where
he'll go to the end ort a case based upon what he sees as
a principle that he believes in and without being paid a
dime. I've seen him do it before, so rt s noe your
cyp ical case where, you know, you got the lawyers
saying, all right, now we are in federal court, and I
need an additional $10,000 or $5,000 retarner. Ne's
liable to say, don't worry about it. I~11 handle it.
MR. ROPER: He s definitely a governmental
rconocl ast There's no doubt about it.
case law on this matter already?
MR. ROPER: Yeah. Temporary takings, as I said,
that's what Z mean. You ve go[ a So[ of good case law
rn federal crrcucts on temporary takings.
Mx. TAYLOR. The only other thing I would suggest,
by the way, that I think we should do, and I ve not
really discussed Chis with Mr. Roper a whole lot, so
ct ~ subject to his input also. fie has no[ really
looked at our codes that we passed concerning the
regulations on this festival, but I think -- I thought
before the suit ever came up that that code that we
wrote could be revamped and made better. And I think in
term of what we re looking at with this litigation they
could be rewritten eo make it better even rn terms of
the concern.
The only concern Z have with [he suit he filed,
and it s not a nig concern, cs they're alleging that
we re giving authority to a non-profit, private
corporation [hat we don't have any authority to give to.
Z don't YhiNC that argument is valid. I think a lot of
other towns; Winter Park, Mount Dora do the same Chirt9,
and I read Winter Park's when I prepared the one we
already did. Bu[ I would possibly wan[ eo go back and
see if there s a way that we can pass an amended code
that even makes it stronger, which even then makes our
beginning on Chis thing Cha[, at bes C, that Mike Sones
could win the battle, a battle, but could neve_ win [he
r 1
Because if a court says, well, you haven't done
street, meaning it's not your official event, [hen we
just go back and do what the judge says you have to do
in order to make it right, and we wan anyway.
So iE the judge says that what you've done wrong
as Chis, you weed to put your seal more as [he City's
art festival and not some private, non-profit
corporation, Chen that's what we do. And I ve talked to
Che Hiseoric Society about doing that, and they don't
seem to have Coo much of a concern.
MR. MILLER. In other words, you want to make it a
city-sponsored evene.
MR. LOVESTRAN~: More than that. A city event
where we <ont roc[ [hem to run it.
MR. MILLER. Right.
MR. TAYLOR: So Chat •s [he ocher thought I've
gotten, to even begin laying the ground work for chat
while this sort is going on. We'll already have an
ordinance in effect that, in essence, defeats Chem
before the. judge ever makes the decision or comes closer
[o at. 2 just think there could be improvemenes eo thae
ordinance that we could make from several standpoints,
and I ehixilc Mr. Rrago agrees with that that we could
bring an amended ordinance.
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MR. LOVE$TRAND: The Historic Society is no[
aa~erse to run,iag is nnaer a eoatraot.
MR. TAYLOR. No.
MR. MZI.LER: In that case, I'd like to move that
we go ahead and take it to the next higher court level
and fight it.
MR. LovesTRAND. well, we still may have more
discussion, but rs these a second?
MR. LovesTRAND: we name a motioa eo secona
Chat we had compromises with these people, artd
everything we heard from [he administrator and the
police chief was we had a solution that seemed amenable
to both parties. And as time has gone on, they have
gotten mote intransigent on their demands, and we have
discovered mo_e chat ehe Iaw is on our side. And seeing
how the law is on our side, and we ve gone to them and
said, we will do the following things Co work with you,
I just don't know whe ze they're coming from. What
exactly do ehey want.
MR. TAYLOR. I think --
MR. LOVEETRAND: They reneged on their deal.
MR. TAYLOR: I think ehey talked about this -- we
TERI GRANT, CODRT REPORTERS (4d?1 943-696
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broughe ehis very factor up at their settlement
discussion with them, and evidently, they were led to
believe that the closing of half of warren Avenue would
take place Chis year, and then it was brought back
lacer. There was a note ov one of the letters saying
this can [ be done this year because the booth space is
already rencea, but we'll ao it for next wear, ana ie
all blew up at that point.
That was true that the space has already been
rented for [his year. I, personally, didn't have any
involvement or didn•t even know those negotiations were
going on. I, personally, feel, not from a Segal
standpoint, well, maybe from a legal standpoint, in that
you could set a precedent, but I Chink the deal to close
half of Warren se arting next year was a bad deal for the
MA. ANDERSON: What I see then is that they're
basing their case on federal pzincipl es. That's where
at should be dealt with then.
MR. TAYLOR: They're basing [he decision on some
theory of Mike Jones that -- I'll have [o give Mike
Jones credit. ife s tenacious. He s a hard fighter. He
doesn't like the government, and he's often -- he just
recenely won a sort against the state on a taking of
this doctor's private land in Che Landings up here, and
he had a statute behind him [here to yo on. He had
He did a good job.
But he gets out an these things ~~- I've known h.i.m
s ance the late 70 s. I was employed by him for four and
a half months. I mean, he's challenged a lot of laws.
He was challenging them back then, and he still
challenges them. £Ie went to court -~~ you we rep t a
commrssroner then -- bue a few years ago a week-long
jury iri al against the City of Longwood and the Code
Enforcement. Board, and he walked out with a big goose
egg.
He does [hat a lot. He takes on some of these
cases and he yets -- you know, maybe S'll learn
something in this, and there's no guarantee who will wart
ehis sort. eue I'll juse cell you this, I ve done some
research on [he law, and it s an our favor. Md if we
lose this sort, Chen you can say goodbye [o the wanter
Park Ax[ Pestrval, the Coconut Groove Ar[ Festival,
which is one of the biggest an the southeast, and the
Moyne nora Art kestival. I don't see it happening.
MA. MILLER. Can we recover our legal expenses
from the parties?
MR. TAYLOR: No.
MA. LovesTRAxn. That's eoo bad.
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MR. ROPER. Long shot.
MR. DRAGO: We can ask Eor it
really believe that when it comes right down to it -- I
really believe that the agitator behind [his whole mess
is not even one of the parties. I believe that. Md
the ehing about it is, I think hex behind needs to be
dragged right rnto ehe coureroom wieh the rese OF them
if we try [o get damages. I really believe [hat's the
I think the fact that she's not one of the parties
does not stop her from being a part of this mess. And
quite honestly, I really believe, and like Dan said just
a few minutes ago, they didn't agree after they agreed.
I don t think the agreement was made with her present.
Okay. 'Lhe agreement was made with Che police chief and
some individuals that were parties. Then all of a
sudden after the agreement is made, it goes up in smoke.
Yes, he was probably right. One of the reasons was
probably because next year, this year, and bia h, blab,
blab. Eut I think [he reality is somebody from outside
go[ back in [here and strrred that pot up again. That
as what happened. That's what I think, so I think we
need to drag her into it.
MR. LOVESTRAND: That's not possible. I don't
think we have a case of proof, but Mike Jones sure
forgo[ to Cake her name o£f the carbon copy that he
mailed.
MR. MILLER. He sure did. That's right. She's
get [.ing copies of stuff, and he c.c.'d it right to her
MR. DRAGO: When we sat down with Chem, we kind of
drew a map out of Warren and everything else for the
pare Ces that are effected; got relief automatrcally wieh
the partial closure of Warren. At some point up Che
stumbling block, was this one over here, the hot dog
man, and when I asked him -- well, firs[ he wanted both
entrances to his driveway [o Tema rn open, so that's
Warren and part of Wilma. And then when he was pushed a
little bit even by [he parties, he agreed, well, I cart
live with Wilma closed, but waxrev has got to be open.
We dealt with [his one particular attorney down in
being able to hire and Eire attorneys, of course, they
wan that all the way through. I believe we probably
could have settled wit}i Chem, but I Chink part of the
problem also lres wr[h the attorney. He s rn there
Yelling Chem I have the Saw on my side. We re going to
win, you know, like the una on activist, you know, we re
going Co win. He did hit upon the second issue, which
was the ordinance. He says Chere are two issues
involved. One is Che open of the street, and [he second
one rs the ordinance. If we can address the ordinance
situation, that wr11 Cake care of that, and then the
other one lies with itself.
also, the group did indicate a dissatisfaceion
with the city government for a number of years holding
[he festival and not being sensrtave to their needs. I
haven't been a party to the city in the past, so I
really couldn'C address that, but [hose seemed like the
two bones of the con[entr on with t}ie resident a.
MR. LOVESTRAN-: I have some remarks on that.
They have had some legitimate gripes, I Chink, but they
have always complained eo the wrong people. They have
noe compl.a fined to the society of people who were running
tt. Now, I have one other questton. It would seem to
me - I ve heard this spoken by one of them in the
Society. we can always get them rn and out by getting a
police motorcycle to escort them in and out. Can Chey
maantaan chat we re closing the road if we say you have
access. We'll get you in, iE you need Co get. in, and
we'll get you ouC, and they still marntarn thae we ve
closed [he streeC. We can just take the blocks off the
end and not close the street but have so much actavity
Chat nobody would come up the street, you know. In the
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past, we ve put ehe horses there, and, rn fact, 2 stood
guard there one year on 92].
MR. ROPER. That's still a constructive closure, I
guess. I don't know. That deftest weakens their
argument.
MR. LOVESTRAND. I mean, we cart call a motorcycle
and have [hem taken in or taken out.
MR. TAYLOR: IC gets down [o -- I think Deputy
Mayor Miller said this about ehe outside parties, and
Che politics that I mentioned at the last meeting Chat's
involved in this case. The flavor I got aC Chat meeting
was, we done want eo settle [his case with you. We
want to fight i[. Thexe was nothing we can do short of
closing these two streets that was going to make them
happy enough. One lady that lives down here, she's
pregnant. She says at the time of this festival I'll
have my baby. What i£ [here's an emergency with [he
baby? I was, like, well, you can almost yell to the
Eire and rescue out your window from there.
I offered -- I said, that the society will get a
gas-powered golf cart, and we'll designate parking
spaces. As [he one guy said, yeah, you let us park at
the hospital, but when we go shopping and come back, no
spaces were left. i Ccld him we would designate, rune
off, and make sure you had reserved spots at our police
TERI GRANT, COURT AEPOATERS (907) 943-7696
building down here. No, no, no, that wont do.
take you there in a golf cart. The garbage
problem -- we offered Co say that we'SI take your
collected. we'll take them and have them dumped and
bring them back to your doorstep. All these other
supposed problems we have, we offered -- every single
one of [hose things we said we would resolve. No, they
MR. DRACO. A11 or nothing
MR. ROPER: If i[ s that kind o£ situation where,
obviously, they're not go in9 to negotiate or prior
negotiations have fallen apart because of their
intransigence, I chink then you~d have to make a
decision, do you want to take it to [he ma[ or not. In
my view, at s pretty much a no-braiver decision. we'll
go to federal coax[. There's a reason [hey filed that
in state circuit court. There's a reason.
MR. ANDERSON: 2 would say Char. i[ sounds like you
got to fighe ie, force the issue, and make them lose.
the trashy thi nge like the perking just the easy
simple, simple things. But i[ does sound -- [he thing
with the street closure you said we have to maintain [he
T6RI GRANT, COlJRT RE POATCRS (907) 843-7696
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precedent, and that's fine. But after it s done, and
you seem to chink thae we'll win xt, ehen we can address
any of the issues just Co be good neighbors.
them in wrr[ing that would help our case along as Ear
as, you know, we have offered to do this? you ve said,
no. We ve offered to do this. You ve said, no. Would
someC hing to [ha[ na[u_e heln us an our case as fax as
taking it to the next court level?
MR. LOVEETRAN~. The police bargain, was in
writing.
MR. TAYLOR: That was rn writing and that was
prelit igation. Things that happen now would be
considered discussions of settlement and typically are
inadmissible in the <o~re once you get to the trial
level.
Ma. RoeeR: There~s a lecter aacea only zsen,
two-page letter.
MS. VACCA: We11, my concern rs that they'll get
rneo court and say, well, the city was never willing to
work wieh us. They've come before the commrssron and
nobody wants to budge. 2've Cried to talk to them prior
to [hem filing the Lawsuit, you know, well, the City is
not willing [o listen to us. The Ci[y is not willing to
TERI GRAM', COURT REPORTERS (40?) 843-?696
work with us, but we were. we did make efforts to try
Co resolve this before it got [o this point. I don't
know who is vnvolved ;n >t.
MR. ROPER: They want to attach Tom Jackson's
letter to the c mp hint that they filed in Che court.
MS. VACCA: I think we have tried Co stay away
from the particular people that axe vnvolved in vL.
Philosophically, I think Chat it s wrong. They should
have beer. Crying to work with the administrator all
along and Crying Co negoC iate comet hi.ng with him as
opposed [o going and speaking to an attorney. I chink
things are always settled much better if [hey Cxy to
work through them then to take things to this level.
MR. ROPER: To answer your question, yeah, that's
already in the court file. That's already considered
part of ehe complaint, so the judge will be aware of it
just from [he fact at s attached.
MR. LOVESTRAND: Le[ me ask if this will hurt our
case. The man that's the holdout on Che corner here is
currently making money off the City. He has a Saturday
rt;yhC, once-a-month colt tact where Terxy Baker asked him
this guy business when he's giving us trouble?
M5. VACCA. That's a separate issue.
TEAI GRANT, CO[IAT REPORTEAu (40]) 893-7696
r
MR. LOVEBTRAND: I'd be of the mina that if you`re
going to sue the city, you can't do business with the
city.
MR. ROPF,R: You yot to be careful of that one.
MS, vACCA: That's a separate issue. we probably
shouldn•t even discuss that here.
MR. LOVEBTRAND: No. It's part of this issue
because it involves the same man.
MR. xOPER: I'm more worried about what county
court says be.i ng accused of that. I see what you're
saying though.
MR. LOVESTRAND: I don •t wan[ to do business with
him.
MS. VACCA: In their lawsuit do they also include
the spring festival?
MR. MILLER: Is the Pickin -- you said something
fo the effect chat Terry Baker is allowing somethiny.
MR. LOVBBTRAND: Terry Baker got Mr. Hopkins to
supply the concess.ton Eor the Pi ck in on the third
Saturday of the month.
MR. MILLER: On whose authori [y?
MR. DRAGO: Terry d.id not do that. That was done
by the parks and zees _oordinat or, because the Merchanes
Association turned it back over to the commission, and
Che commrssion agreed Co do i[ by resolution. That's a
sponsored event. They divorced themselves from the
re~reshment s, so as a stop-get measure, just Co have
some refreshments Here and there, he used Mr. Ropkins
just to 9o in there once a month and serve his coffee
and everything else. He s under no contract with the
City. I mean, we can sever the relationship tomorrow.
1 agree with you. There'e some ieeues on ret all atloxi.
MR. ROPER: You goe a _ Cey good case just based
on the facts right now under federal law. llnder 1983
ehis is no more than a temporary taking. You're not
depriving these people of their land permanently.
You're not depriving them of any and all economic use.
MR. LOVRSTRAN-: we re not depriving them of
MR. ORAGO. Well, plus, the big issue is Hoe only
this festival but any other festival that this diet ri ct
has. It impacts that also.
MR. MILLER: Any city that has a parade does the
same thing. I mean, obviously, there's plenty of --
MR. LOVF,STRAND: When a city paves a sereee, they
quite often have to cell homeowners you're going to be
denied access for a day.
MR. -AYLOA: I Cold you last time there's a street
in downtown Orlando next to the old hotel, which was Che
court house for many years down ehere, called court
r
Etree[. And [here's an attorney [hoe has his office on,
what used to be, Court Street. The City of Orlando juse
decided they were going to close that entire st reeC to
vehicular Czaffic, artd you can only walk on Ct now. Ee
sued [he City of Orlando saying you can C do [ha[. The
Fifth Oistri<t Court of Appeals says, oh, yes we can.
Yes, Chey can. So, I neon, no[ only can you close it
Eor a few days, you can close a street for a lifeeime.
I[ s your right-of-way.
MR. ROPER: It's not an eminent domain question.
IC's a right-oE-way.
MS. VACCA: But I still don't understand why Chey
have only filed a suit for the £all festival and no[ fox
the spring. That makes no sense [o me whatsoever.
MR. oxpco. My observation is because ie s the one
that's Ei rst.
MR. LOVESTRAN~: My observation is that a certain
agit actor is one of eke workers on the spring festival.
MR. ROPER: That could be next. We could be
setting a big precedent. for the spring festival. Where
does iL end, you know?
MR. MILLER: I[ ends right here as far as my
mot>on is concerned.
MS. vACCA: The tree lighting ceremony, then the
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dog show, and [he Christmas tree lighting.
MR. TAYLOR: TRe only thing I would say as far as
trte motion, and I appreciate your support, and you tell
me if I m wrong, would be [o allow us -- and
par[i cularly Donovan Roper's discretion, and fox some
reason between now -- we have to do something by a week
from Thursday. If we decide to go for [he writ of
prohibition first and Chen shift gears to the federal
court, that you'31 allow us that discretion oz a motion
just to go to federal court. That would kind of hem us
in. And we ve not -- I don't think Finally solidified
which direction we re going to go. I think we re
leaning towards federal court, but maybe, have noe
totally ruled out [he possibility of First filing a writ
of pzohibi[ion.
MR. MILLER: I'll amend tRe motion to state.
M5. VACCA: I'll amend the second.
MR. LOVE£TRAND. 2 think we Ve had enough
discussion. Are we ready to call it?
MR. -RAGO: One question. Do we need to send any
letters to Sone~ relative to denying his settlement
of i'er when we had that meeting? Do we need to say we'd
Ii ke eo entert avn it, but I think we need to do it this
way?
MR. ROPER: We don't have to. We can.
L^
MR. TAYLOR: He wrote a letter to me confirming
his offer and wanting to hear back from me. I don't
mind him the courtesy of [he letter back saying your
offer is not reasonable, and I ve been inse ruct ed eo
pursue --
MR. LOVESTRAND. We are pretty much satisfied that
[his will take us pas[ the November -- what is i[. The
26th or whatever that is.
MR. ROPER. Well, I hope. You have a lot better
chance of hav Sng that happen in federal court than you
ao in seace nrrcarc cOUrc.
MR. LOVEETRAND: And Chen Sohn can go to the city
comm.i s.sr on w.i th his permission and grant them the.i.r
permissron, because people out t}~ere can e plan because
they don'[ have [he official okay by the City. We
should, at the same time, give ehe okay from the Ci[y,
MR. LovesTRAND. Are we ready for the vote? A11
an Eavor of Mr. Miller's motion to allow the attorneys
Co go to federal eoure, or if they come Co some other
conclusion to give them. discretion of going some place
else firs[, say aye.
THE BOARD. Aye.
MR. LOVEETRAN-: The chair notes that it s
TERl GRANT, COURT REPORTERS 1900 843-]696
unan_mous. ?here's no further business. we'll now
adjourn [o the outside room.
(whereupon, the meeting was adjourned and returned [o open
forum.)
MR. LOVesTRANO: This meeting reconvenes. T_he
time of adjournment of the closed sessacn was 6.90.
MR. MILLER: No, :40.
MR. LovESTRaNO: x m so y, x.40. and that being
all the nusrness, we new adjourn the meeting.
(Whereupcn, the hearing concluded a[ ]:90 p.m.)
TERI GRANT, COURT REPORTERS (90~) 843-696
I, LORI .f[lN Court Reporter, c [ify [hat I w
uthorized t andRd id s rtographi<allyerepor[ [he foregoing
proc eedivgs and ChaC theeeransc rip[ is a true and complete
6 cord.
DATED this 2]th day of September 1999.
8
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Enclusu~e.