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09-08-2005 VC SP-MMINUTES OF THE SPECIAL SESSION ~• VILLAGE COUNCIL OF NORTH PALM BEACH, FLORIDA SEPTEMBER 8, 2005 Present: Dr. Edward M. Eissey, Mayor David B. Norris, Vice Mayor Robert F. Rennebaum, President Pro Tem Charles R. O'Meilia, Councilman Donald G. Noel, Councilman Mark Bates, Village Manager Melissa Teal, CMC, Village Clerk ROLL CALL Mayor Eissey called the meeting to order at 7:00 p.m. All members of Council were present. All members of staffwere present. REQUEST FOR ATTORNEY-CLIENT SESSION Village Attorney George Baldwin requested a private Attorney-Client session with the Village Council regarding litigation styled Sean Jackson and Sherrel Meriweather vs. Village of North Palm Beach, et al. ANNOUNCEMENT OF CLOSED ATTORNEY-CLIENT SESSION Mayor Eissey announced that the Village Council would recess at this time for the purpose of convening a private Attorney-Client Session with an estimated length of 30 minutes to discuss pending litigation styled Sean Jackson and Sherrel Meriweather vs. Village of North Palm Beach, et al. Mayor Eissey announced all persons who would be in attendance at the Session. RECESS The Special Session recessed at 7:01 p.m. RECONVENED SPECIAL SESSION Mayor Eissey reconvened the Special Session at 7:40 p.m. and announced the termination of the Attorney-Client Session. ADJOURNMENT With no further business to come before the Council, the Special Session adjourned at 7:40 p.m. • Melissa Teal, CMC Village Clerk 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 JACKSON and VILLAGE OF NORTH PALM BEACH APPEARANCES: Village of North Palm Beach, Florida September 9, 2005 7:00 o'clock p.m. KENNETH P. CARMAN, ESQ. RON VINOGRAD ED M. EISSEY, COUNCILMAN DAVID NORRIS, ESQ, COUNCILMAN CHARLIE R. O'MELIA, COUNCILMAN DONALD G. NOEL, COUNCILMAN GEORGE BALDWIN, ESQ, COUNCILMAN MARK BATES, COUNCILMAN ROBERT F. RENNEBAUM, COUNCILMAN SPECIAL COUNCIL MEETING FOR APPROVAL OF SETTLEMENT ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 1 2 K 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Thereupon: The following proceedings were had: MR. EISSEY: Mr. Baldwin, do we begin with Mr. Carman or do -- MR. BALDWIN: That would be fine. MR. EISSEY: Okay. Mr. Ca'.rman, you're on. MR. CARMAN: Thank you. We're here at a meeting to present to you the status of a lawsuit which has tentatively been resolved pending the approval of council and the approval of the SIRMA board; SIRMA, being the self-insured poll to which the city belongs. SIRMA handles all insurance claims on behalf of the city. This case arrives out of an incident that occurred back on October 20th of 2004. To very briefly summarize the facts leading up to this particular lawsuit, the Village Police Department was notified by the Dade County Public Safety Department that one of their prisoners that was on work release had fled. He was believed to be back on his way up to the Village to look for his wife, predicated upon information they have received that they ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 2 1 2 3 4 5 6 7 8 9 10 14 15 16 17 18 19 20 21 22 23 24 25 had obtained from his wife a, quote, Dear John tetter. They notified us that he may be coming back up to the Village because his last known address was believed to be here in the Village. Upon receiving that information we, in fact, verified, based on information available to us, that he was residing here or last had resided herein an apartment complex located here in the Village. Predicated upon that information the decision was made that because this gentleman had a violent past, including utilization of force against police officers, that it would be best to utilize -- best to utilize the SWAT team to apprehend this individual and bring him back into custody and return him to Dade County. So, we found out where he last resided and we set up surveillance using equipment belonging to the SWAT team unit. Unfortunately, there was inclement weather on the day of this occurrence and we were never able to identify who was coming in or out of this particular apartment. ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 We got information from one of our detectives that a gentleman was seen entering the apartment; however, due to weather conditions and darkness we were not able to identify the individual that went into the apartment as that matching the description given to us by Miami -Dade. For whatever reason the captain in charge of the SWAT team decided that he would effectuate entry. So, we set up outside of this individual's apartment and we attempted entry using avon rounds, which are a type of shotgun rounds, and flash grenades in an attempt to exercise the element of surprise and gain entry into the apartment. The intent was to prevent the occupants.of the apartment from being harmed and other individuals in the surrounding apartments being harmed. When we entered the apartment, instead -of finding a white male, which is who we were looking for, we found a black family hiding in the bedroom. Having realized that we had entered the wrong apartment and that nobody fitting the ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 v 1 2 3 4 5 6 7 8 9 10 14 15 16 17 18 19 20 21 22 23 24 25 description of the gentleman who was missing from Dade County was in fact residing in that apartment, we still placed the male inhabitant, that being the black male of the apartment, in handcuffs and marched him out of the apartment while in handcuffs in front of his neighbors. We caused considerable damage to the apartment. They had. a young child residing with them in the apartment. It was a husband, a fiancee, and their child. Our own records indicate that the child was somewhat shook up as a result of this to the extent where children and family services were called to the scene to render care to the young child. MR. EISSEY: How old was the child? MR. CARMAN: Nine years old, I believe, at the time the incident occurred. The bottom line is that we made a mistake. We went into the wrong apartment arguably with inadequate information and also arguably by using a SWAT team with the amount of force that was not necessary for that type of unit to be utilized. The captain in charge felt like it was necessary to use the SWAT team; however, it's ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 important to note that our policy and procedures did not contain any guidelines as to when the SWAT team would or would not be utilized. That's important because when you're -- and I'll get into what the nature of the claim that was filed against the Village -- MR. NOEL: May we ask questions while he does this? MR. EISSEY: What's your pleasure? MR. CARMAN: Whatever suits him. MR. EISSEY: Go ahead,'Mr. Noel. MR. NOEL: Well, you know, to start this thing I'm kind of going through this. It say it was a fugitive. What kind of fugitive was he? You said we used the SWAT team. MR. CARMAN: He was on work release. The argument MR. NOEL: For what kind of crime? MR. CARMAN: He did have a violent past, but the argument being that they felt that he was sufficiently rehabilitated to the extent that he was able to be released on a work release program, which requires minimal supervision. Now, the counter argument to that, to ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 at 21 22 23 24 25 answer your question, is that he was at the end of the sentence. So, somehow in this man's mind he felt it so necessary to walk away from the tail end of his sentence and risk additional jail time. One would suspect that he was capable of doing violence either to himself or to his wife so as to incur additional jail time by -- MR. NOEL: What time was this raid? MR. CARMAN: The raid was conducted at about 8:30 in the evening. MR. NOEL: So, it was dark? MR. CARMAN: Yes. MR. RENNEBAUM: When did they start the surveillance? MR. CARMAN: We started at around noon and there was a gap in the surveillance because we thought we spotted somebody similar to the description in a nearby park. One of the problems that we had, however, is that the Plaintiff's testified that they came home from work at different times that day; the husband, the wife, and the husband bringing the child home at different times. They entered -- The husband went out to get ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 w 19 20 21 22 23 24 25 groceries and it wasn't until he returned with the groceries when we first noticed for the first time someone entering the apartment. So, our surveillance missed the fact that the wife came home, that the husband came home, and that the husband left to pick up groceries. So, our surveillance was somewhat inefficient in that we failed to pick up the individuals that entered this apartment before an unidentified male was identified as entering the apartment, which is when the captain called for the raid to begin. MR. EISSEY: Anything else, Mr. Noel? MR. NOEL: Not at the moment. MR. EISSEY: Please proceed. MR. CARMAN: Okay. We entered the apartment again, brought this individual out in handcuffs, and later released him from the handcuffs. We had done considerable damage to the apartment. One of the difficulties that we had is that this occurred shortly after the last hurricane took place and we had an extremely difficult time finding a place for these individuals to stay since most of the hotel rooms were booked ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 I 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 up. We did, after some period of time, replace all of the contents of the apartment that had been damaged. MR. NOEL: What's that period of time? MR. CARMAN: There was a dispute about that. Our records reflect that they were immediately replaced after a matter of days. It was the Plaintiff's contention in mediation and they produced records to show that it was actually months before everything was replaced. So, we did replace their damaged materials; however, there were some difficulties that were brought to our attention at the mediation. The first difficulty is.the fact that neighbors of the Jacksons' were out there with video cameras filming everything that was going on. These videotapes were not made known to us until the mediation that we attended shortly after the lawsuit was filed. That became a particular importance due to the case law in the nature of the claim that were served against us. In the videotape that the neighbors took our officers were verbally and visibly rude to the neighbors that were videotaping. One of ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 f 1 2 3 M 5 I 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the things they made reference to when they told these people to stop filming is that this is a crime scene. You must leave. Actually, these individuals, that being the Jacksons, had committed no crime. One of the things that caused us to have some concern is the continued reference of referring to this situation as a crime scene even after we knew no criminal activity had been committed by the Jacksons. One of the claims that has been asserted against us is a civil rights claim, a 1983 claim, arising out of the Forth Amendment violation of illegal search and seizure. The defense available to the individual officers is qualifying immunity, which means that,the officers, in fact, in the importance of their official duties will not be responsible as a matter of law unless they're blatantly ignoring the law and acted in an incompetent matter or in a willful or wrongful matter to cause damage to the individuals that are involved. One of the case law and sections of qualified immunity that creates an issue of ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 10 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 fact that prevents an entry of motion for summary judgement in our favor is the continuation to refer to a crime scene or to criminal activity once it is known by us that there is no crime that has been committed. In mediation they continued to refer to this as a crime scene even though we knew that the Jacksons were innocent of any crime. One of the concerns we had to address was whether or not that would impact on our ability to get our officers out via filing the motion for summary judgment. The other concern was the utilization of the explosive.devices forcing entry -- MR. NOEL: Hang on a second. Before you get off of the 1983 claim, you mentioned in here something about -- Mayor, I'm sorry for interrupting. You have a problem with officers not being -- not having the immunity that they would normally have because they were referring to this as a crime scene. That's the incompetence you're referring to? MR. CARMAN: No. We're getting a little bit ahead of the presentation, but generally ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 there were two causes of action that were stated against the Village and against the officers. Against the Village it was a 1983 claim. That is a claim against the government entity, which means that they have to establish and plead that the Village had a custom of policy, whether it be in fact by the city's policies and procedures or that the city had established through its customs and policy a policy 'and procedure to violate individuals' civil rights by violating the Forth Amendment right by committing an illegal search and seizure. We know that did not exist. The second way to establish such a cause of action is to establish that the actions of our administration by way of supervision and training were deliberately indifferent to the rights of our citizens. That would have been the claim that they would have been traveling on to establish a 1983 claim against the city. I don't believe that the Plaintiff would have been able to have met that burden against the city. We felt very strongly that a 1983 claim against the city had not been sustained. ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 12 1 2 3 4 5 I 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. NOEL: Okay. MR. CARMAN: Where we felt we had a problem with the 1983 claim is with the individual officers, more particularly the captain, in his decision to use the SWAT team based upon the lack of sufficient information that would justify his calling of the SWAT team to effectuate the raid. Now, when a claim is filed against a governmental employee where a governmental employee is acting under the color of law and violating an unconstitutional right under color of law, one of the defenses that we assert is the defense of qu..alifying immunity. That means that the officer was just doing his or her official job in an official manner following the known law. We immediately filed for a summary judgment asserting a defense for qualified immunity. The theory behind that defense is that the federal courts did not want governments to come to a standstill while its officers spent all their time in depositions and in courts of law defending themselves, because then local governments would not be able to function ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 because they would be spending all of their time at a court of law. The problem that we had is that there are several cases out there that stand for the proposition that if you continue to call somebody a criminal after knowing they committed no crime, that kind of takes you out of that immunity because you are therefore violating a constitutional right in and of i tself . Those cases say that then becomes a question of fact for the jury to decide. It's no longer -the judge, but the jury must decide whether or not qualified immunity will apply. So, we were concerned about those cases. The reference to the continuation of referring to this as a crime scene might cause the judge to deny our motion for summary judgment thereby causing our officers to remain in the law as a party defendant. MR. NOEL: So, when they say "crime scene", that implies that the person inside the scene is a criminal? MR. CARMAN: Correct. The second prong of that had to do with the fact that there are ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 14 f- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 cases that deal with areas of this nature that find that the utilization of explosive devices to gain entry in and of itself is a constitutional violation. It creates sufficient questions of fact under the circumstances so as to avoid the judge, as a matter of law granting qualified immunity, leaving it up to the jury to decide. So, again instead of being able to win over the judge saying, Judge, it's a matter of law, you must grant summary judgment in favor of our officers, we may have been faced with the proposition of having to go to the jury and letting the jury decide. MR. NOEL: Thank you. MR. EISSEY: Please continue. MR. CARMAN: So, as it turns out we clearly made a mistake. Now, there are two causes of action that were pled, state court claims for negligence and false arrest, false imprisonment, and then we had the federal civil rights claims. Again, I did not believe that the plaintiff would be able to sustain his burden of establishing a federal claim against the ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Village for the officers, but when the lawsuit was filed, we prepared and filed a motion for summary judgment -- excuse me a motion to dismiss the 1983 claim. The case in federal court fell if front of Judge Middlebrooks. Judge Middlebrooks was very welt -known to us. He never grants motions to dismiss. I've had probably 50 or 60 cases in front of him and I never had him grant a motion to dismiss. He denied our motion to dismiss. The next step for us would have been to have a -- to proceed with discovery and then file a motion for summary judgment on the basis of qualified immunity. Once that motion was heard, we would then file the second motion to get the Village out on the basis that the Plaintiff did not establish necessary evidence to have sustained the 1983 claim against the Village. The problem we had with the 1983 claim is that there's no statutory cap on damages on a 1983 claim as there are on the State Tort Claims. As you are aware there was a $200,000 statutory cap on the State Tort Claims. In ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 this instance they were claiming that $200,000 was available on damage. On the 1938 claim no such statutory cap exists. If the Plaintiff substantially recovered on any of their civil.rights claims, not only do, we owe monetary damages, but we owe their attorney's fees as well. So, we had a mediation with the officers on two occasions. What we learned from our meeting with the officers is that there were three positions that were being taken by the various officers involved in the circumstance. There was then an entirely different position taken by the administration that was not involved in this situation because a change in administration didn't take place. One group of officers felt that the utilization of the SWAT team and the information that what relied upon was totally inappropriate .and the information that was relied upon was totally inadequate. MR. RENNEBAUM: Are these members of the SWAT team that were saying this? MR. CARMAN: Yes. Another group supported everything that was done and a third group sat ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 mute. What that caused was a problem in our being able to represent all of the officers that were involved because obviously there was a conflict of interest because one group of officers was in essence going to be pointing fingers at a second group of officers that was involved in this particular event. Just as a side, some of that is continuing on today in other cases that we have pending. MR. NOEL: With us? MR. CARMAN: Yes. So, we had a problem there and that caused me to have to go to the claims representative, who was handling this file and say, if this continues, I have a conflict of interest and you're going to have to bring in another law firm to represent these officers because there's a conflict of interest. They'll be pointing the finger at other officers and I can't represent them. Based upon those discussions, based upon an analysis of the cost involved to defend the lawsuit, based upon the possibility that a 1983 claim could go to a jury, based upon the fact that claims of this nature could have some ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 jury's sympathy because nobody tikes to have their house innocently broken into whether it's intentionally or whether it's by mistake, and based upon the position taken by our current chief we were instructed to undertake a settlement negotiations. One of the things of concern is what it would cost to defend this case if we were to continue to the point where we could file a necessary summary judgment. That would entail hiring several expert witnesses. It would entail having two law firms defend the city. My projection as to what it would cost to continue on with this defense at least to the point where we're ready to go to trial would probably be $100,00 because we're going to have two law firms at all of these depositions and we anticipated 30 or 40 depositions. We foresaw the need for two liability experts and the need for at least one if not two medical experts. So, we were given instructions to attempt to resolve these issues before incurring defense cost and more importantly for giving the Plaintiff the opportunity to take discovery ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 19 1 2 3 4 5 6 7 8 9 10 14 15 16 17 18 19 20 21 22 23 24 25 from our officers which would be detrimental to our case. So, we set this case for mediation. We mediated the case and the Plaintiff demanded $750,000 and insisted that that was his bottom line. We got into a very strong argument as to whether or not he would be able to sustain his 1983 claim against the city. I was addiment that he would not. That caused him to walk out of the mediation. We were instructed to formally continue the mediation process through the mediator and we were finally successful in doing that and we arrived at a tentative settlement of this case at the $200,000 statutory cap. That settlement would include all claims, all resolution, all attorney's fees, all costs. It's a little bit more than what we felt the value of the case was, but due to the publicity -- MR. EISSEY: Considering all of the other things you mentioned earlier. MR. CARMAN: And considering the fact that I earned very little in'defending this case. We have put defense costs towards the ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 settlement, that we're not going to incur future defense costs and expert witness fees, that this case did have value to it that would no longer expose the city to attorney's fees and to potential damages that could include the statutory cap. It was a recommendation from all parties involved that we attempt to resolve this case. MR. EISSEY: At $200,000? MR. CARMAN: Yes, sir. MR. EISSEY: And that's what you'll recommend to the council to consider? MR. CARMAN: Yes. MR. EISSEY: Mr. Rennebaum. MR. RENNEBAUM: When you said Mr. Jackson walked out, is he now agreed to this $200,000 offer? MR. CARMAN: Yes, sir. MR. RENNEBAUM: So, we say $200,00 and it's all done and everybody agrees? MR. CARMAN: Everybody agrees. It's confirmed at the SIR meeting set for September 16th, but with your approval I'm sure that -- MR. NOEL: What's SIR? MR. CARMAN: Self Insurance Retention. ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 21 2 3 4 5 6 7 I 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. NORRIS: The money all comes from SIRMA? MR. CARMAN: Correct. MR. BALDWIN: And anything over $25,000 they have to approve? MR. CARMAN: Yes, that's correct. MR. NORRIS: Can I ask one question? MR. EISSEY: Mr. Norris. MR. NORRIS: You mentioned position by a current chief. What was that? You said one of the reasons or -- MR. CARMAN: The chief reviewed all potential circumstances surrounding this particular situation and felt that it was improperly handled. He felt it did not support the utilization of a special response team and felt that it was in the Villages best interest to resolve the case. There were also some issues that may have come up in discovery. There were some other cities that our SWAT team participated in training activities with. They refused to allow our participation with concerns -- MR. RENNEBAUM: Say that again. MR. CARMAN: They refused'to allow us to ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 22 1 2 3 4 5 6 7 8 9 10. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 participate in their activities. MR. RENNEBAUM: For what reasons? MR. CARMAN: Once we established the team they didn't think -- From what I've been told by the chief they didn't think that we were at a sufficient level to be on -- be put with their units and would not allow us to participate in the. MR. RENNEBAUM: Prior to this incident? MR. CARMAN: Yes. MR. RENNEBAUM: Not based on this incident? MR. CARMAN: Prior to the incident. MR. RENNEBAUM: Strictly independent based on their perception of our qualifications? MR. CARMAN: Correct MR. BALDWIN: How many Plaintiffs are involved and are they all represented by one attorney? MR. CARMAN: Yes, every Plaintiff is represented. It was a father, a mother, and a child. MR. NOEL: I heard neighbors are jumping in on this. MR. CARMAN: No. MR. NOEL: No neighbors? ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. CARMAN: No neighbors. MR. O'MELIA: Is the lawsuit just against the Village or against the Village and the employees? MR. CARMAN: It was the Village and I think there were six officers named. MR. O'MELIA: So, this would release all of the officers? MR. CARMAN: This would be an entire release of the Village and all of its employees. MR. NORRIS: Will you be directed to defend all of the officers and the Village? MR. CARMAN: Yes, but after meeting with the officers, due to the inconsistencies as to how they saw the events surrounding the circumstances, it's apparent that I could not continue with that representation any further because they were taking positions adverse to one another. MR. EISSEY: Well, allow me to stipulate and I believe I can, in this case, speak for the council to thank you for the thorough information that you have provided us and it's very, very helpful. With that, unless there -- ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Do you have any questions? MR. NOEL: Do you want to talk about it in here? MR. EISSEY: Shall we -- MR. BALDWIN: I think I would talk and converse about it in here, but the actual decision I think would be made at the regular meeting. MR. EISSEY: With the amount? 'MR. BALDWIN: Correct. .There is a resolution prepared for the council with the amount to be inserted and to take -- MR. NOEL: So, we shouldn't be having a big discussion about this out there? MR. BALDWIN: Is that appropriate with you? MR. CARMAN: Yes. That's correct. I know there is probably going to be a lot of media attention surrounding this and I think we have to stick firm that this was a simple mistake. Nobody's constitutional rights were in any way, shape, or form violated. This was never looked upon by the Village as being a civil rights 1983 claim and that in large part what went into our settlement, ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 NO 19 20 21 22 23 24 25 Number 1; we wanted to do right by our citizens who did sustain some damages as a result of a mistake on our part and, Number 2, that economics and cost of events played a large factor. The attorney who was representing the Plaintiffs is very publicity happy and will try to put a negative spin against the Village -- MR. NOEL: Who is it? MR. CARMAN: Brian Porsaw (phonetic). I've never dealt with him before. MR. EISSEY: Will he be here tonight? MR. CARMAN: I don't think so. He knows about the meeting tonight. I know there will be another article in the paper, so if anybody if intending to speak to the press, we want to say -- MR. EISSEY: It will be my recommendation to all of the council that we stipulate that they must contact our attorney then our attorney can respond based upon -- MR. CARMAN: Well, I don't respond. My standing instructions is not to speak with the press. I just want to make clear that my position ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 26 i 2 3 4 5 6 E 10 14 15 16 17 18 19 20 21 22 23 24 25 is that there was no and never has been any constitutional violation, no 1983 violation. If fact,.it was a simple mistake that has been made. They have a remedy for the mistake that's under Florida Tort Law, not under the civil rights claim. MR. EISSEY: And your recommendation is that we just not have any comment and not refer this to anyone else? MR. BALDWIN: That's my bet. It's that you will refer to Mr. Carman, who won't comment. MR. EISSEY: Any problem with that, counsel? MR. CARMAN: I have no problem with that. MR. BALDWIN: Is that all right with you? MR. CARMAN: Well, that's strictly your decision as to whether or not you want to somehow, you know, present the city's version of this in the press so that the Village -- so that we don't -- They're going to make this look as bad as they possibly can. MR. BATES: At some point I think it will be incumbent upon the city to make a comment. It should be very concise, very brief, and entirely consistent. It should be one time ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 27 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 only. MR. NORRIS: We need to have a prepared statement. MR. EISSEY: All right. Will the council agree that Mr. Carman should do that. MR. BALDWIN: Well, Mr. Carman said he doesn't comment. MR. NOEL: Let's have Mr. Carman approve the comment. MR. EISSEY: Mr. Bates can comment and Mr. Carman will approve the comment. MR. BATES: Tonight or tomorrow morning I'll -draft up probably a two to three sentence comment. I can run it by Mr. Carman and Mr. Baldwin's office. When the question comes, if it comes, here it is. You'll know about it ahead of time and that's it. MR. EISSEY: Do you have any problems drafting a sentence or two for our village manager? MR. CARMAN: I think Mr. Bates is quite capable of doing that. MR. BATES: It will take me 5 minutes and it will take them 30 seconds to comment on that. It's not terribly complicated. ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 0 r I 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. CARMAN: I want to make sure that nobody leaves the room feeling that it wasn't anything but an honest mistake made here. We have economic considerations that we have to consider and that was -- MR. EISSEY: We announced a certain time to get back, so may I thank you on behalf of the council for your representation here this evening and for your representation in the past with us. MR. RENNEBAUM: Mayor, I have one last question. Mr. Bates, what's the form of the* motion for tonight? MR. EISSEY They have a resolution. MR. BALDWIN: Let's give all the letters back to Mr. Carman. (Thereupon, the meeting was concluded at 7:35 o'clock p.m.) ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 29 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CERTIFICATE WITH ACKNOWLEDGMENT I, Nancy Berrios, certify that I was authorized to and did stenographically report the foregoing proceedings and that the transcript is a true record. Dated this 14th day of September, 2005 Notary Publ�i4, State of Florida Nancy Benios Commission #DD319521 �;. `�'.01ZQ= Expires: May 16, 2008 Bonded Thru Atlantic Bonding Co., Inc. ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 30 $100,00 - 19:16 $200,00 - 21:19 $200,000 - 16:24, 17:1, 20:15, 21:9, 21:16 $25,000 - 22:4 $750,000 - 20:5 1 - 26:1 14th - 30:9 16th - 21:23 1938 - 17:2 1983 - 10:12, 11:16, 12:4, 12:21, 12:24, 13:3, 16:4, 16:19, 16:21, 16:23, 18:23, 20:8, 25:24, 27:2 2 2 - 26:3 2004 - 2:16 2005 - 1:8, 30:9 20th - 2:16 30 - 19:18, 28:24 4 40 - 19:18 5 5 - 28:23 50 - 16:8 6 60 - 16:8 7 7:00 - 1:9 7:35 - 29:18 8 8:30 - 7:11 9 9 - 1:8 A ability - 11:10 able - 3:24, 4:4, 6:22, 12:23, 13:25, 15:9, 15:24,18:3, 20:7 Acknowledgment - 30:1 acted - 10:20 acting - 13:11 action - 12:1, 12:16, 15:19 actions - 12:16 activities - 22:22, 23:1 activity - 10:9, 11:4 actual - 25:6 addiment - 20:8 address - 3:5, 11:9 administration - 12:17, 17:14, 17:16 adverse - 24:19 agree - 28:5 agreed - 21:16 agrees - 21:20, 21:21 ahead - 6:11, 11:25, 28:17 allow - 22:23, 22:25, 23:7, 24:21 Amendment - 10:13, 12:12 amount - 5:21, 25:9, 25:12 analysis - 18:22 announced - 29:6 answer - 7:1 anticipated - 19:18 apartment - 3:9, 3:25, 4:3, 4:6, 4:11, 4:15, 4:17, 4:20, 4:25, 5:3, 5:4, 5:5, 5:8, 5:9, 5:19, 8:3, 8:9, 8:11, 8:17, 8:20, 9:2 apartments - 4:18 apparent - 24:17 Appearances- 1:11 apply - 14:14 apprehend - 3:16 appropriate - 25:15 Approval - 1:23 approval - 2:10, 2:11, 21:23 approve - 22:5, 28:8, 28:11 areas - 15:1 arguably - 5:19, 5:20 argument - 6:17, 6:20, 6:25, 20:6 arising - 10:13 arrest - 15:20 arrived - 20:14 arrives - 2:15 article - 26:15 assert - 13:13 asserted - 10:11 asserting - 13:19 attempt - 4:14, 19:22, 21:8 attempted - 4:11 attended - 9:18 attention - 9:13, 25:19 attorney - 23:18, 26:6, 26:20, 26:21 attorney's - 17:7, 20:17, 21:4 authorized - 30:5 available - 3:7, 10:15, 17:2 avoid - 15:6 avon - 4:12 aware - 16:24 B bad - 27:21 Baldwin - 1:16, 2:3, 2:5, 22:4, 23:16, 25:5, 25:10, 25:15, 27:10, 27:15, 28:6, 29:15 Baldwin's - 28:15 Based - 18:21 based - 3:7, 13:5, 18:21, 18:23, 18:24, 19:4, 23:11, 23:13, basis - 16:14, 16:17 Bates - 1:16, 27:22, 28:10, 28:12, 28:21, 28:23, 29:12 Beach - 1:4, 1:7 became - 9:19 becomes - 14:11 bedroom - 4:23 begin - 2:3, 8:12 behalf - 2:13, 29:7 behind - 13:20 belonging - 3:21 belongs - 2:12 Berrios - 30:5, 30:12 best - 3:15, 22:17 bet - 27:10 big - 25:13 bit - 11:25, 20:18 black - 4:22, 5:4 blatantly - 10:20 board - 2:11 booked - 8:25 bottom - 5:18, 20:5 Brian - 26:10 brief - 27:24 briefly - 2:17 bring - 3:16, 18:17 bringing - 7:24 broken - 19:2 brought - 8:17, 9:13 burden - 12:23, 15:24 C cameras - 9:16 cap - 16:22, 16:25, 17:3, 20:15, 21:6 capable - 7:6, 28:22 captain - 4:8, 5:24, 8:11, 13:4 care - 5:14 Carman- 1:13,2:4, 2:6, 2:7, 5:16, 6:10, 6:16, 6:19, 7:10, 7:13, 7:16, 8:16, 9:5, 11:24, 13:2, 14:24, 15:17, 17:24, 18:12, 20:23, 21:10, 21:13, 21:18, 21:21, 21:25, 22:3, 22:6, 22:12, 22:25, 23:3, 23:10, 23:12, 23:15, 23:19, 23:24, 24:1, 24:5, 24:9; 24:14, 25:17, 26:10, 26:13, 26:22, 27:11, 27:14, 27:16, 28:5, 28:6, 28:8, 28:11, 28:14, 28:21, 29:1, 29:16 case - 2:15, 9:20, 10:24, 16:5,19:8, 20:2, 20:3, 20:4, 20:14, 20:19, 20:24, 21:3, 21:8, 22:18, 24:22 cases - 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3:17 custom - 12:7 customs - 12:10 D Dade - 2:19, 3:17, 5:2 dade - 4:7 damage - 5:7, 8:19, 10:22, 17:2 damaged - 9:3, 9:11 damages - 16:22, 17:6, 21:5, 26:2 dark - 7:12 darkness - 4:4 Dated - 30:9 David - 1:14 days - 9:7 deal - 15:1 dealt - 26:11 Dear- 3:1 decide - 14:12, 14:13, 15:8, 15:14 decided - 4:9 decision - 3:12, 13:5, 25:7, 27:17 defend - 18:22, 19:8, 19:12, 24:12 defendant - 14:20 defending - 13:24, 20:24 defense - 10:15, 13:14, 13:19, 13:20, 19:14, 19:24, 20:25, 21:2 defenses - 13:13 deliberately - 12:18 demanded - 20:4 ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 deny - 14:18 Department- 2:19, 2:20 depositions - 13:23, 19:17, 19:18 description - 4:6, 5:1, 7:19 detectives - 4:2 detrimental - 20:1 devices - 11:14, 15:2 different - 7:22, 7:24, 17:13 difficult - 8:23 difficulties - 8:21, 9:12 difficulty - 9:14 directed - 24:12 discovery - 16:13, 19:25, 22:20 discussion - 25:14 discussions - 18:21 dismiss - 16:4, 16:8, 16:10, 16:11 dispute - 9:5 Donald - 1:15 done - 8:19, 17:25, 21:20 draft - 28:13 drafting - 28:19 due - 4:3, 9:20, 20:19, 24:15 duties - 10:18 E earned - 20:24 economic - 29:4 economics - 26:4 Ed- 1:14 effectuate - 4:10, 13:8 Eissey - 1:14, 2:3, 2:6, 5:15, 6:9, 6:11, 8:13, 8:15, 15:16, 20:21, 21:9, 21:11, 21:14, 22:8, 24:21, 25:4, 25:9, 26:12, 26:18, 27:7, 27:12, 28:4, 28:10, 28:18, 29:6, 29:14 either - 7:6 element - 4:14 employee - 13:10, 13:11 employees - 24:4, 24:11 end - 7:1, 7:4 entail - 19:10, 19:12 entered - 4:20, 4:24, 7:25, 8:9, 8:16 entering - 4:2, 8:3, 8:10 entire - 24:9 entirely - 17:13, 27:25 entity - 12:5 entry - 4:10, 4:12, 4:15,11:1, 11:14, 15:3 equipment - 3:20 Esq - 1:13, 1:14, 1:16 essence - 18:6 establish - 12:6, 12:15, 12:16, 12:21, 16:18 established - 12:9, 23:3 15:25 evening - 7:11, 29:9 event - 18:8 events - 24:16, 26:4 evidence - 16:18 excuse - 16:3 exercise - 4:14 exist - 12:14 exists - 17:3 expert - 19:11, 21:2 experts - 19:20, 19:21 explosive - 11:14, 15:2 expose - 21:4 extent - 5:12, 6:21 extremely - 8:23 F faced - 15:12 fact - 3:7, 5:2, 8:4, 9:14, 10:17, 11:1, 12:8, 14:12, 14:25, 15:5, 18:24, 20:23, 27:3 factor - 26:5 facts - 2:17 failed - 8:8 false - 15:20 family - 4:22, 5:13 father - 23:20 favor - 11:2, 15:11 federal - 13:21, 15:21, 15:25, 16:5 fees - 17:7, 20:17, 21:2, 21:4 fell - 16:5 felt - 5:24, 6:20, 7:3, 12:24, 13:2, 17:17, 20:18, 22:14, 22:15, 22:17 fianc - 5:10 file - 16:14,16:16, 18:15, 19:9 filed - 6:6, 9:19, 13:9, 13:18, 16:2 filing - 11:11 filming - 9:16,10:2 finally - 20:13 fine - 2:5 finger - 18:19 fingers - 18:6 firm - 18:17, 25:20 firms - 19:12, 19:17 first - 8:2, 8:3, 9:14 fitting - 4:25 flash - 4:13 fled - 2:22 Florida- 1:7, 27:5, 30:13 following - 2:2, 13:16 force - 3:14, 5:21 forcing - 11:14 foregoing - 30:6 foresaw - 19:19 form - 25:22, 29:12 formally - 20:11 Forth- 10:13, 12:12 front - 5:6, 16:5, 16:9 fugitive - 6:14 function - 13:25 future- 21:2 G gain - 4:15, 15:3 generally - 11:25 gentleman - 3:12, 4:2, 5:1 George- 1:16 given - 4:7, 19:22 government - 12:5 governmental - 13:10 governments - 13:21, 13:25 grant - 15:11, 16:9 granting - 15:7 grants - 16:7 grenades - 4:13 groceries - 8:1, 8:2, 8:6 group - 17:17, 17:24, 17:25,18:5, 18:7 guidelines - 6:2 H handcuffs - 5:5, 5:6, 8:18, 8:19 handled - 22:15 handles - 2:13 handling - 18:14 Hang- 11:15 happy - 26:7 harmed - 4:17, 4:19 heard - 16:16, 23:22 helpful - 24:25 hiding - 4:22 himself - 7:7 hiring - 19:11 home - 7:22, 7:24, 8:5 honest - 29:3 hotel - 8:25 house - 19:2 hurricane - 8:22 husband - 5:9, 7:23, 7:25, 8:5, 8:6 identified - 8:10 identify - 3:24, 4:5 ignoring - 10:20 illegal - 10:14, 12:13 immediately - 9:7, 13:18 immunity - 10:16, 10:25, 11:20,13:14, 13:19, 14:8, 14:14, 15:7,16:15 impact - 11:10 implies - 14:22 importance - 9:20, 10:17 important - 6:1, 6:4 importantly - 19:24 imprisonment - 15:21 improperly - 22:15 inadequate - 5:20, 17:21 inappropriate - 17:20 incident - 2:15, 5:17, 23:9, 23:11, 23:12 inclement - 3:22 include - 20:16, 21:5 including - 3:13 incompetence - incompetent - 10:21 inconsistencies - 24:15 incumbent - 27:23 incur - 7:7, 21:1 incurring - 19:23 independent - 23:13 indicate - 5:11 indifferent - 12:18 individual - 3:16, 4:5, 8:17, 10:15,13:3 individual's - 4:11 individuals - 4:18, 8:8, 8:24, 10:4, 10:22 individuals'- 12:11 inefficient - 8:7 information - 2:25, 3:6,3:7,3:11,4:1, 5:20,13:6, 17:19, 17:20, 24:24 inhabitant - 5:3 innocent - 11:8 innocently - 19:2 inserted - 25:12 inside - 14:22 insisted - 20:5 instance - 17:1 instead - 4:20, 15:9 instructed - 19:5, 20:11 instructions - 19:22, 26:23 insurance - 2:13 Insurance - 21:25 insured - 2:12 intending - 26:16 intent - 4:16 intentionally - 19:3 interest - 18:5, 18:16, 18:19, 22:17 interrupting - 11:18 involved - 10:23, 17:12, 17:15, 18:4, 18:7,18:22, 21:8, 23:17 issue - 10:25 issues - 19:23, 22:19 itself - 14:10,15:3 J Jackson- 1:2, 21:15 Jacksons- 10:5, 10:10, 11:8 Jacksons'- 9:15 jail - 7:5, 7:8 job - 13:16 John- 3:1 Judge- 15:10, 16:6 judge - 14:13, 14:17, 15:6, 15:10 judgement - 11:2 judgment - 11:12, 13:18, 14:18, 15:11, 16:3, 16:14, 19:10 jumping - 23:22 jury - 14:12, 14:13, 15:8, 15:13, 15:14, 18:24 jury's - 19:1 justify - 13:7 K Kenneth- 1:13 kind - 6:13, 6:14, knowing - 14:6 known - 3:4, 9:17, 11:4, 13:17,16:7 knows - 26:13 L lack - 13:6 large - 25:25, 26:4 last - 3:4, 3:8, 3:19, 8:22, 29:11 law - 9:20,10:19, 10:20, 10:24, 13:11, 13:13, 13:17, 13:23, 14:2, 14:19,15:7, 15:10, 18:17, 19:12, 19:17 Law- 27:5 lawsuit - 2:9, 2:18, 9:19, 16:1, 18:23, 24:2 leading - 2:17 learned - 17:9 least - 19:14, 19:20 leave - 10:3 leaves - 29:2 leaving - 15:8 left - 8:6 letter - 3:2 letters - 29:15 letting - 15:14 level - 23:6 liability - 19:19 line - 5:18, 20:6 local - 13:24 located - 3:9 look - 2:24, 27:21 looked - 25:23 looking - 4:22 M male - 4:21, 5:3, 5:4, 8:10 man's - 7:2 manager - 28:20 manner - 13:16 marched - 5:5 Mark - 1:16 matching - 4:6 materials - 9:11 matter - 9:7, 10:19, 10:21, 10:22, 15:7, 15:10 Mayor - 11:17, 29:11 means - 10:16, 12:6, 13:14 media - 25:18 mediated - 20:4 mediation - 9:8, 9:13, 9:18, 11:6, 17:8, 20:3, 20:10, 20:12 mediator - 20:12 medical - 19:21 Meeting - 1:22 meeting - 2:8, 17:10, 21:22, 24:14, 25:8, 26:14, 29:17 members - 17:22 mentioned - 11:16, 20:22, 22:9 met - 12:23 Miami - 4:7 Miami-dade - 4:7 Middlebrooks - 16:6 might - 14:17 mind - 7:3 ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 minutes - 28:23 missed - 8:4 missing - 5:1 mistake - 5:18, 15:18,19:3, 25:20, 26:3, 27:3, 27:4, 29:3 moment - 8:14 monetary - 17:6 money - 22:1 months - 9:10 morning - 28:12 most - 8:25 mother - 23:20 motion - 11:1, 11:11, 14:18, 16:2, 16:3, 16:10,16:14, 16:15, 16:16, 29:13 motions - 16:7 must - 10:3, 14:13, 15:11, 26:20 mute - 18:1 N named - 24:6 Nancy - 30:5, 30:12 nature - 6:5, 9:21, 15:1, 18:25 nearby - 7:19 necessary - 5:22, 5:25, 7:3,16:18, 19:10 need - 19:19,19:20, 28:2 negative - 26:8 negligence - 15:20 negotiations - 19:6 neighbors - 5:6, 9:15, 9:23, 9:25, 23:22, 23:25, 24:1 never - 3:23, 16:7, 16:9, 25:23, 26:11, 27:1 next - 16:12 Nine- 5:16 nobody - 4:25, 19:1, 29:2 Nobody's - 25:21 Noel - 1:15, 6:7, 6:11, 6:12, 6:18, 7:9, 7:12, 8:13, 8:14, 9:4, 11:15, 13:1, 14:21, 15:15, 18:11, 21:24, 23:22, 23:25, 25:2, 25:13, 26:9, 28:8 noon - 7:16 normally - 11:21 Norris - 1:14, 22:1, 22:7, 22:8, 22:9, 24:12, 28:2 North - 1:4, 1:7 Notary - 30:13 note - 6:1 noticed - 8:2 notified - 2:19, 3:3 Number- 26:1, 26:3 0 o'clock - 1:9, 29:18 O'melia- 1:15, 24:2, 24:7 obtained - 3:1 obviously - 18:4 occasions - 17:9 occupants - 4:16 occurred - 2:16, 5:17, 8:22 occurrence - 3:23 offer - 21:17 office - 28:15 officer - 13:15 officers - 3:14, 9:24, 10:16, 10:17, 11:11, 11:19, 12:3, 13:4, 13:22, 14:19, 15:12, 16:1, 17:8, 17:10, 17:12, 17:17, 18:3, 18:5, 18:7, 18:18, 18:20, 20:1, 24:6, 24:8, 24:13, 24:15 official - 10:18, 13:16 old - 5:15, 5:16 once - 11:4 Once- 16:15, 23:3 one - 2:20, 4:1, 13:13, 18:5, 19:20, 22:7, 22:10, 23:17, 24:20, 27:25, 29:11 One- 7:5, 7:20, 8:21, 9:25, 10:5, 10:11, 10:24, 11:9, 17:17, 19:7 opportunity - 19:25 outside - 4:10 owe - 17:6 own - 5:10 P Palm - 1:4, 1:7 paper - 26:16 park - 7:19 part - 25:25, 26:3 participate - 23:1, 23:8 participated - 22:21 participation - 22:23 particular - 2:18, 3:25, 9:20, 18:8, 22:14 particularly - 13:4 parties - 21:7 party - 14:20 past - 3:13, 6:19, 29:9 pending - 2:10, 18:10 people - 10:2 perception - 23:14 period - 9:1, 9:4 person - 14:22 phonetic - 26:10 pick - 8:6, 8:8 place - 8:23, 8:24, 17:16 placed - 5:3 plaintiff - 15:23 Plaintiff - 12:22, 16:18, 17:4, 19:25, 20:4, 23:19 Plaintiff's - 7:21, 9:8 Plaintiffs - 23:16, 26:7 played - 26:4 plead - 12:7 pleasure - 6:9 pled - 15:19 Pm - 1:9, 29:18 point - 19:9, 19:15, 27:22 pointing - 18:6, 18:19 Police - 2:19 police - 3:14 policies - 12:8 12:10 poll - 2:12 Porsaw - 26:10 position - 17:14, 19:4, 22:9, 26:25 positions - 17:11, 24:19 possibility - 18:23 possibly - 27:21 potential - 21:5, 22:13 predicated - 2:24 Predicated - 3:11 prepared - 16:2, 25:11, 28:2 present - 2:8, 27:18 presentation - 11:25 press - 26:17, 26:24, 27:19 prevent - 4:16 prevents - 11:1 prisoners - 2:21 problem - 11:19, 13:2, 14:3, 16:21, 18:2, 18:12, 27:12, 27:14 problems - 7:20, 28:18 procedure - 12:11 procedures - 6:2, 12:9 proceed - 8:15, 16:13 proceedings - 2:2, 30:7 process - 20:12 produced - 9:9 program - 6:23 projection - 19:13 prong - 14:24 proposition - 14:5, 15:13 provided - 24:24 Public - 2:20, 30:13 publicity - 20:20, 26:7 put - 20:25, 23:6, 26:8 Q qualifications - 23:14 qualified - 10:25, 13:19, 14:14,15:7, 16:15 qualifying - 10:16, 13:14 questions - 6:7, 15:5, 25:1 quite - 28:21 quote - 3:1 R raid - 7:9, 7:10, 8:12, 13:8 ready - 19:15, realized - 4:24 reason - 4:8 reasons - 22:11, 23:2 received - 2:25 receiving - 3:6 recommend - 21:12 recommendation - 21:7, 26:18, 27:7 record - 30:7 9:9 recovered - 17:4 refer - 11:3, 11:6, 27:8, 27:11 reference - 10:1, 10:7,14:16 referring - 10:7, 11:21, 11:23, 14:16 reflect - 9:6 refused - 22:22, 22:25 regular - 25:7 rehabilitated - 6:21 release - 2:21, 6:16, 6:23, 24:7, 24:10 released - 6:22, 8:18 relied - 17:19,17:21 remain - 14:19 remedy - 27:4 render - 5:14 Rennebaum- 1:17, 7:14,17:22, 21:14, 21:15, 21:19, 22:24, 23:2, 23:9, 23:11, 23:13, 29:11 replace - 9:1, 9:11 replaced - 9:7, 9:10 report - 30:6 represent - 18:3, 18:17, 18:20 representation - 24:18, 29:8, 29:9 representative - 18:14 represented - 23:17, 23:20 representing - 26:6 requires - 6:23 resided - 3:9, 3:19 residing - 3:8, 5:2, 5:8 resolution - 20:16, 25:11, 29:14 resolve - 19:23, 21:8, 22:18 resolved - 2:9 respond - 26:21, 26:22 response - 22:16 responsible - 10:19 result - 5:12, 26:2 Retention- 21:25 return - 3:17 returned - 8:1 reviewed - 22:12 rights - 10:12, 12:11, 12:19, 15:22, 17:5, 25:21, 25:24, 27:6 risk - 7:4 Robert 1:17 Ron- 1:13 room - 29:2 rooms - 8:25 rounds - 4:12, 4:13 rude - 9:24 run - 28:14 S Safety - 2:20 sat - 17:25 saw - 24:16 scene - 5:14, 10:3, 10:8,11:3, 11:7, 11:22,14:17, 14:21, 14:22 search - 10:14, second - 11:15, 12:15, 14:24, 16:16, 18:7 seconds - 28:24 sections - 10:24 seizure - 10:14, 12:13 self - 2:12 Self- 21:25 self-insured - 2:12 sentence - 7:2, 7:4, 28:13, 28:19 September- 1:8, 21:22, 30:9 served - 9:21 services - 5:13 set - 3:20, 4:10, 20:3, 21:22 settlement - 19:6, 20:14, 20:15, 21:1, 25:25 Settlement- 1:23 several - 14:4, 19:11 Shall - 25:4 shape - 25:22 shook - 5:11 shortly - 8:22, 9:18 shotgun - 4:13 show - 9:9 side - 18:8 similar - 7:18 simple - 25:20, 27:3 Sirma - 2:11, 2:13, 22:2 situation - 10:8, 17:15, 22:14 six - 24:6 someone - 8:3 somewhat - 5:11, 8:7 sorry, - 11:17 Special - 1:22 special - 22:16 spending - 14:1 spent - 13:22 spin - 26:8 spotted - 7:18 stand - 14:4 standing - 26:23 standstill - 13:22 start - 6:12, 7:14 started - 7:16 state - 15:19 State- 16:23, 16:25, 30:13 statement - 28:3 status - 2:8 statutory - 16:22, 16:25, 17:3, 20:15, 21:6 stay - 8:25 stenographically - 30:6 step - 16:12 stick - 25:20 still - 5:3 stipulate - 24:21, 26:19 stop - 10:2 Strictly - 23:13 strictly - 27:16 strong - 20:6 strongly - 12:24 substantially - 17:4 successful - 20:13 sufficient - 13:6, 15:5, 23:6 sufficiently - 6:21 ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338 summarize - 2:17 unit - 3:21, 5:22 summary - 11:2, units - 23:7 11:12, 13:18, 14:18, unless - 10:19, 15:11, 16:3, 16:14, 24:25 19:10 up - 2:18, 2:23, 3:4, supervision - 6:24, 3:20, 4:10, 5:11, 8:6, 12:17 8:8, 9:1, 15:8, 22:20, support - 22:15 28:13 supported - 17:24 utilization - 3:13, surprise - 4:14 11:13, 15:2, 17:18, surrounding - 4:18, 22:16 22:13, 24:16, 25:19 utilize - 3:15 surveillance - 3:20, utilized - 5:23, 6:4 7:15,7:17,8:4,8:7 V suspect - 7:5 sustain - 15:24, value - 20:19, 21:3 20:7, 26:2 sustained - 12:25, various - 17:12 16:19 verbally - 9:24 Swat- 3:15, 3:21, verified - 3:7 4:9, 5:21, 5:25, 6:3, version - 27:18 6:15, 13:5, 13:7, via - 11:11 17:18, 17:23, 22:21 video - 9:16 sympathy - 19:1 videotape - 9:23 videotapes - 9:17 videotaping - 9:25 T Village- 1:4,1:7, 2:18, 2:24, 3:4, 3:5, tail - 7:4 team - 3:16, 3:21, 3:10, 6:6, 12:2, 12:4, 4:9, 5:21, 5:25, 6:3, 12:7, 16:1, 16:17, 6:15, 13:5, 13:7, 16:20, 24:3, 24:5, 17:18, 17:23, 22:16, 24:10, 24:13, 25:23, 22:21, 23:3 26:8, 27:19 tentative - 20:14 village - 28:19 tentatively - 2:9 Villages- 22:17 terribly - 28:25 Vinograd- 1:13 testified - 7:21 violate - 12:11 themselves - 13:24 violated - 25:22 theory - 13:20 violating - 12:12, thereby - 14:18 13:12, 14:9 therefore - 14:8 violation - 10:14, Thereupon- 2:1, 15:4, 27:2 29:17 violence - 7:6 third - 17:25 violent - 3:13, 6:19 thorough - 24:23 visibly - 9:24 three - 17:11, 28:13 W today - 18:9 tomorrow - 28:12 walk - 7:3, 20:9 tonight - 26:12, 26:14, 29:13 walked - 21:16 Tonight- 28:12 weather - 3:22, 4:3 took - 8:23, 9:23 well-known - 16:7 Tort- 16:23, 16:25, white - 4:21 27:5 wife - 2:24, 3:1, 7:7, totally - 17:19, 7:23, 8:5 17:21 willful - 10:21 towards - 20:25 win - 15:9 training - 12:18, witness - 21:2 22:22 witnesses - 19:11 transcript - 30:7 wrongful - 10:21 traveling - 12:20 Y trial - 19:15 true - 30:7 years - 5:16 try - 26:7 turns - 15:17 young - 5:8, 5:14 two - 12:1, 15:18, 17:9,19:12, 19:17, 19:19, 19:21, 28:13, 28:19 type - 4:12, 5:22 U unconstitutional - 13:12 under - 13:11, 13:12, 15:5, 27:5 undertake - 19:5 Unfortunately - 3:22 unidentified - 8:10 ELITE REPORTING OF SOUTH FLORIDA, INC., (954) 761-8338