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2012.01.31_TC_Minutes_Executive SessionPage: 1 140 I * 1-0 1 THE STATE OF FLORIDA, ) 2 COUNTY OF PALM BEACH. ) 3 4 5 6 IN RE:_rIGINAL. 7 8 TOWN OF HIGHLAND BEACH 9 ATTORNEY/CLIENT SHADE MEETING 10 11 12 13 14 15 Highland Beach, Florida 16 DATE: January 31, 2012 2:50 - 3:20 p.m. 17 18 19 20 21 22 23 24 25 Florida Court Reporting 561-689-0999 Page: 2 r� • 1 2 APPEARANCES: 3 MAYOR BERNARD FEATHERMAN 4 5 VICE -MAYOR MIRIAM S. ZWICK 6 COMMISSIONER DENNIS J. SHERIDAN 7 8 COMMISSIONER JOHN J. PAGLIAROI 9 TOWN MANAGER KATHLEEN D. WEISER 10 11 TOWN ATTORNEY GLEN J. TORCIVIA, ESQUIRE 12 LYMAN H. REYNOLDS, JR., ESQUIRE 13 14 TOWN CLERK BEVERLY BROWN 15 16 17 18 19 20 21 22 23 24 25 Florida Court Reporting 561-689-0999 Page: 3 • � 0 10 1 2 (The following proceedings were had): 3 - - - 4 MAYOR FEATHERMAN: Is there any miscellaneous 5 items left over? 6 Beverly, turn it on, and we'll get started. 7 (Thereupon, audio recorder was turned on.) 8 MAYOR FEATHERMAN: Good afternoon. It's 9 Tuesday, January 31, 2012 at 2:50 p.m. I now call 10 the order of the Town commission attorney/client 11 private meeting. 12 Can you take a role call, please? 13 THE TOWN CLERK: Commissioner Sheridan? 14 COMMISSIONER SHERIDAN: Here. 15 THE TOWN CLERK: Commissioner Pagliaroi? 16 COMMISSIONER PAGLIAROI: Here. 17 THE TOWN CLERK: Commissioner Trinley? 18 COMMISSIONER TRINLEY: Here. 19 THE TOWN CLERK: Vice-president? 20 MR. REYNOLDS: Here. 21 THE TOWN CLERK: President? 22 MAYOR FEATHERMAN: Here. 23 THE TOWN CLERK: Attorney Torcivia? 24 MR. TORCIVIA: Here. 25 THE TOWN COURT: Town Manager Weiser? Florida Court Reporting 561-689-0999 Page: 4 � is lie 10 1 TOWN MANAGER WEISER: Here. 2 THE TOWN CLERK: And the attorney for -- 3 MR. REYNOLDS: Lyman Reynolds, here. 4 MAYOR FEATHERMAN: We have to raise -- rise 5 for the pledge of allegiance again. 6 (Thereupon, the pledge of Allegiance was 7 cited by all present.) 8 MAYOR FEATHERMAN: Thank you. 9 Town Clerk, will you please recite the 10 Civility Pledge. 11 (Whereupon, the Town Clerk recites the 12 Civility Pledge.) 13 MAYOR FEATHERMAN: Thank you very much. 14 Are there any additions or deletions to the 15 agenda? Hearing none, the agenda is accepted as 16 submitted. 17 Public comments and requests at this time? 18 There are no public comments or requests. 19 Town Attorney Torcivia, will you please 20 review the procedures of this meeting? 21 And I would say that after he does that, 22 Beverly, could you please close the door and have 23 the sign put on appropriately? 24 The Town attorney? 25 MR. TORCIVIA: Thank you, Mr. Mayor. The Florida Court Reporting 561-689-0999 Page: 5 r U • • 11 purpose of this private section is for the town 2 commission and counsel to discuss settlement 3 negotiations or strategy regarding the litigation 4 in the case of Dale S. Sugarman versus the Town of 5 Highland Beach, 2011 CA 015192XXXXMP filed 6 October 3rd, 2011. 7 The entire session will be recorded by a 8 certified court reporter. The persons attending 9 the Attorney/Client Session are Mayor Featherman, 10 Vice -Mayor Zwick, Commissioner Trinley, 11 Commissioner Pagliaroi, Commissioner Sheridan, Town 12 Manager Weiser, myself and Attorney Lyman Reynolds. 13 And with that, I would turn it back over to 14 the mayor to close the session. 15 MAYOR FEATHERMAN: At this time, the Town 16 clerk and the public will leave the meeting. 17 Town Clerk, please mark the door in an 18 appropriate manner. 19 (Town Clerk complies with request.) 20 MAYOR FEATHERMAN: Thank you. I call the 21 attorney/client meeting back to order at 2:53 p.m. 22 Okay. Now, the public comments, you go 23 ahead, please, and -- and make your statement. 24 MR. REYNOLDS: Thank you, Mayor. Lyman 25 Reynolds, again. I met with you all before Florida Court Reporting 561-689-0999 Page: 6 0 10 1 mediation with regard to the status of settlement 2 negotiations, which we anticipated at the 3 mediation. Anything that transpires in mediation 4 is -- is confidential. 5 You -all are the clients, so you're entitled 6 to know what transpires at mediations. So this 7 isn't a disclosure of what transpired at the 8 mediation, but that having been said, the 9 negotiations did not result in settlement of the 10 case. The parties were just far -- far too far 11 apart. 12 Where we are presently is: The Plaintiff, 13 Dr. Sugarman, has filed what's called a Proposal 14 for Settlement. The Proposal for Settlement in 15 this case was $250,000. 16 If the Defendant, which is the Town, does not 17 quote, unquote, beat the settlement by 25 percent 18 or better, the Plaintiff, who's filed the Proposal 19 for Settlement, can obtain attorney's fees and 20 costs from the time of filing that Proposal for 21 Settlement up through whatever the point in time is 22 the judgment or the judgment is upheld on appeal. 23 What the reason for this Shade meeting is: 24 The insurance company, on behalf of the Town, would 25 like to file what's called a Counter Proposal for Florida Court Reporting 561-689-0999 Page: 7 L' I* 1 Settlement in the amount of $75,000. 2 Our thought is, is that if we're successful 3 and we win the suit or the judgment is in favor of 4 Dr. Sugarman 25 percent less than $75,000; in other 5 words, if he were to obtain a judgment of $50,000, 6 we would get our attorney's fees and costs. That's 7 sort of the -- the schtick that each side has to 8 the other. 9 The insurance company asked me to come before 10 the commission and request your consent as a 11 commission for settlement of authority, which is -- 12 of course is, as we discussed in our last meeting, 13 the insurance company's money, but your consent up 14 to a $100,000. 15 We'd file a Proposal for Settlement for 16 seventy-five. We think that their demand of 17 two -fifty is far too high, but if you give your 18 consent to the insurance company going up to a 19 $100,000 to settle, there would be some room to 20 negotiate between seventy-five and -- and a 21 hundred, and that's where we presently are. 22 The insurance company is not intending to 23 accept the -- the Plaintiff's Proposal for 24 Settlement of $250,000. They think that's just way 25 too high, so that's where we are. Florida Court Reporting 561-689-0999 Page: 8 • • 140 1 MAYOR FEATHERMAN: Well, I can say that I 2 would go along with the insurance company, and one 3 of the commissioners and the mayor; however, we 4 have other commissioners here. 5 I'd like to ask Commissioner Sheridan, how do 6 you stand on that? 7 COMMISSIONER SHERIDAN: Is it fair for me to 8 ask you what your personal feelings would be 9 regarding settlement of seventy-five? It's a long 10 way from two and a quarter or two and -a -half, I 11 know that. 12 I'd go with along with the mayor. If you 13 feel as though seventy-five with a buffer up to a 14 hundred is going to be within the ballpark, I guess 15 we've got to bite the bullet. 16 MR. REYNOLDS: And -- and it's not unfair, 17 because you're my client as a representative of the 18 Town. 19 Yes, I think it's fair. I'm a litigator, so 20 I have a tendency to want to put the blinders on 21 and just get me in front of a jury and I want to 22 win, obviously, every case that I can. 23 I tried ten jury trials last year. That's a 24 lot of jury trials, I can tell you. And in all of 25 them, I can promise you that I did everything for Florida Court Reporting 561-689-0999 Paee: 9 I• • i• 1 my clients that I could to get as close to what the 2 Plaintiff wanted to settle the case or cases, and 3 that's what I'm -- I'm advocating on behalf of the 4 Town here. 5 If the insurance company, as we went through 6 in our -- in our last shade meeting, is willing to 7 pay a $100,000 or a 125,000 or a $150,000 because 8 they see a danger value -- because no one can 9 predict, I certainly cannot, what a jury is going 10 to do. 11 Just like we talked about, other people's 12 money. We want it to be -- I want it to be on your 13 behalf, on behalf of the Town, the insurance 14 company's money. 15 As the mayor pointed out in our last meeting, 16 from a business standpoint, that's why you have 17 insurance. Because if you don't consent and tie 18 the insurance company's hands, they can then say 19 "all right, if you feel that strongly about it, you 20 defend it, you pay the judgment if it goes south." 21 Without going any -- into any of the details 22 from -- from mediation, I can tell you that when 23 mediation started, I felt like I was Alice looking 24 through the looking glass because I was going "you 25 think this case is worth what?" Florida Court Reporting 561-689-0999 Page: 10 � 0 10 10 1 So to put it mildly, the Motions to Dismiss 2 and everything that I brought to you -all and showed 3 you -all in our -- our in our last shade meeting, I 4 think have had -- have an affect in sort of in 5 terms of a wake-up call from Dr. Sugarman's 6 standpoint and from his attorney's standpoint. 7 They think they're being very reasonable at 8 two -fifty. I can assure you compared to what they 9 were demanding at mediation, and in that process, 10 yes, they come a long way, but I always call that 11 make-believe money. The real money is what the 12 insurance company or a Defendant is willing to 13 write someone an actual check for. 14 And I talked again with the insurance company 15 this morning before I -- before I came because we 16 had spoken with -- when we were setting up the -- 17 this follow-up shade meeting in terms of where she 18 was thinking, and that's -- that's where she's 19 comfortable is at a hundred thousand. 20 And that's why I made the suggestion to her 21 that well, if the -- if the commission authorizes a 22 hundred thousand, we can do this Proposal for 23 Settlement for seventy-five, which puts the schtick 24 back on -- on them. Because if they don't beat it, 25 if they're not successful and either give -- we get Florida Court Reporting 561-689-0999 Page: 11 • 0 1 a defense verdict or we get a verdict at $50,000 or 2 less, they pay our attorney's fees and costs, 3 they're out of pocket. 4 And so she -- she reconfirmed that, and 5 Plaintiff's counsel additionally -- that's -- 6 that's one additional point, contacted me at the 7 end of last week to say, "Well, we're not married 8 to this $250,000. Let's, you know, talk some 9 more." 10 And I said, "Okay. Let me talk to the 11 insurance company and do the due diligence that we 12 have to do here today, and I'll get back with you." 13 MAYOR FEATHERMAN: Yes? 14 COMMISSIONER PAGLIAROI: Question: When you 15 say "the woman," who you made mention of, that is 16 the attorney for Dr. Sugarman, correct? 17 MR. REYNOLDS: Yes. Yes, Maria Abate. 18 COMMISSIONER PAGLIAROI: Okay. Now, let's 19 say we go a hundred thousand dollars -- to a 20 $100,000. Originally the claim is two -fifty. 21 What's going to stop them from saying "well, that's 22 not the two -fifty we want." 23 We're going to have to go up. They're going 24 to have to come down. They're not going to 25 accept -- I mean, how realistic is it that they Florida Court Reporting 561-689-0999 Page: 12 �e 140 1 will accept the $100,000? 2 MR. REYNOLDS: I think it is a relative long 3 shot. Not a super long shot, but a relative one. 4 And that's why I suggested to her, because she -- 5 this is the insurance company representative, 6 Ms. Eggert. She had originally requested that I 7 come before you for authority for a Proposal for 8 Settlement of a $100,000. 9 And the reason I -- I spoke with her again 10 this morning was, I said: From my perspective, 11 from my experience doing this for a whole lot of 12 years, if you give a Proposal for Settlement of a 13 $100,000, the Plaintiff is going to think "well, we 14 want to settle somewhere between a hundred and 15 two -fifty," and so that's -- that's your new middle 16 ground. 17 And I said to her, I said, "Are you wanting 18 to do that? Because I want to be able to tell that 19 to the commission if that's what you're -- you're 20 thinking." 21 And she said, "No, No." She really would 22 want to try and settle it at or around a hundred 23 thousand. 24 So that's when I said to her, I go, "Well 25 then if -- if that's what you want to -- to settle Florida Court Reporting 561-689-0999 Page: 13 � 0 140 10 1 for, then we need to do a Proposal for Settlement 2 of seventy-five." 3 Because the highest we went at mediation was 4 seventy, and -- and they were still off in this 5 stratosphere. 6 And I said, "So -- so do a Proposal for 7 Settlement for 75,000, then you give yourself this 8 $25,000 window to negotiate, make sure" -- you 9 know, and I'll tell them right off the bat we're 10 not splitting the difference. That's not what 11 we're interested in. "But if you can get close to 12 our number, then maybe we can get it done." 13 And that's -- that's the -- that's the 14 strategy that -- that I employ like you would at 15 any good, you know, business negotiation. You have 16 to look at it purely objectively. 17 Will they take the hundred thousand? I think 18 they should, but that doesn't mean that they will. 19 Because again, not taking away from anyone's 20 perception with regard to Dr. Sugarman, but I have 21 the definite feeling that Dr. Sugarman wants, 22 quote, unquote, his day in court and he wants to 23 swing for the fences to see if he can get that 24 great big, you know, giant award. 25 And I think his attorney is trying to get him Florida Court Reporting 561-689-0999 Page: 14 • � 0 1 to look at it more realistically as a business 2 decision as what's your probabilities, and that -- 3 that's the impression that -- that I definitely had 4 from my conversations with her. 5 COMMISSIONER PAGLIAROI: But that -- 6 MR. REYNOLDS: Now maybe if she can talk him 7 down, as you pointed out, to that -- that realistic 8 figure, I don't know. 9 COMMISSIONER PAGLIAROI: That's my concern. 10 My concern was him going overboard. I know Dale 11 believes to this day that he is right, and he's 12 going to go with it and we're going to -- I don't 13 want us to get into a situation where we're going 14 to come up to a hundred thousand and they're going 15 to say two twenty-five, and it's going to get 16 higher and higher and higher, and I'm -- that 17 bothers me very, very, very much. 18 MR. REYNOLDS: And I just want to make it 19 clear now, because you don't -- you don't know me, 20 but I've been doing this a long, long time, and I 21 know exactly what you're thinking and what your 22 concern is. 23 And I can promise you from mediation, because 24 we were there for several hours, that that's when 25 we finally declared an impasse because we said Florida Court Reporting 561-689-0999 Page: 15 • � 0 10 1 "we're not going to fall into that trap of we're at 2 seventy-five, you're at two twenty-five, we're a 3 hundred, and now you're at two hundred." 4 That's -- that's not what I anticipate, but 5 that's why I talked to the insurance company this 6 morning. Because I wanted to know the exact same 7 answer, which is: Is the real number a hundred and 8 fifty? Because I'd be talking to you -all about a 9 hundred fifty if that's -- but that's not what the 10 insurance company has told me. 11 Will the insurance company maybe potentially 12 consider the risk value, cost of defense and -- and 13 those other factors to go up to a hundred and 14 fifty? Again, I'd have to come back before you 15 again before that can even happen because all -- 16 what I'm here for purposes of the today is the 17 consent for the insurance company up to the 18 $100,000. 19 MAYOR FEATHERMAN: How long will this take 20 you to make a deal on this settlement? 21 MR. REYNOLDS: Well -- and there may not be a 22 deal. 23 MAYOR FEATHERMAN: No, I understand that. 24 MR. REYNOLDS: Right. Right. Right. 25 MAYOR FEATHERMAN: I understand that. I'm Florida Court Reporting 561-689-0999 Page: 16 0 � 0 I* 1 just asking for a time period. 2 MR. REYNOLDS: Well, if I had the 3 commission's consent or permission today, I can do 4 a $75,000 Proposal for Settlement today. Then they 5 have 30 days to accept or reject that. 6 MAYOR FEATHERMAN: I see. 7 MR. REYNOLDS: And I can assure you that as 8 soon as they get that, I'll get a call from 9 Plaintiff's counsel, Ms. Abate. 10 And she's going to say, "Okay, you're 11 there" -- and just as the commissioner pointed out, 12 "You're there. If we come to two twenty-five, are 13 you going -- are we going to land in the middle?" 14 And that's when I'm going to have to give her 15 the bad news and say, "No. You're going to have to 16 get real, real, real close to our number in order 17 for the insurance company to want to -- to settle 18 this case." 19 Because at this point in time, the insurance 20 company does not have it evaluated above a hundred, 21 and so if we don't offer it, it's not there. 22 MAYOR FEATHERMAN: Right. 23 MR. REYNOLDS: Here's what the offer is. 24 It's -- at seventy-five, it's not quite 25 take -it -or -leave -it, but if we ever inch our way up Florida Court Reporting 561-689-0999 Page: 17 • • � 0 1 to the hundred, then it would at this point in time 2 be a take -it -or -leave -it number. 3 MAYOR FEATHERMAN: Another thing we have a 4 question on is: What is our portion of the 5 deductible on that? 6 MR. REYNOLDS: I think you -all are, like five 7 thousand. 8 MAYOR FEATHERMAN: Five thousand? 9 MR. REYNOLDS: And I'm quite sure that we've 10 gone through that by now. 11 TOWN MANAGER WEISER: Yeah. 12 MR. REYNOLDS: We're either at or near going 13 through it from my motions and what have you. 14 TOWN MANAGER WEISER: It's low. It's five 15 thousand. 16 MR. REYNOLDS: It is. It's a low deductible, 17 and -- and that is -- goes with cost of defense 18 and -- and what not, and I'm a hundred percent 19 positive that there's no further funds. 20 MAYOR FEATHERMAN: Is there any questions? 21 You have one vice -mayor? 22 VICE -MAYOR ZWICK: (Shakes head from side to 23 side.) 24 MAYOR FEATHERMAN: Commissioner Trinley? 25 COMMISSIONER TRINLEY: Yeah. If he doesn't Florida Court Reporting 561-689-0999 Page: 18 • � 0 10 1 accept, do you really think he'd go to trial? 2 MR. REYNOLDS: I always go on the assumption 3 that the other side is willing to go to trial 4 because I proceed that way. Because if you 5 don't -- if you don't anticipate that you're going 6 to go to trial, you're going to be caught 7 unawares -- 8 COMMISSIONER TRINLEY: Okay. 9 MR. REYNOLDS: -- unprepared, and so -- so 10 that will not be the case. I promise you that his 11 attorney does not want to go to trial. I mean, 12 I -- if you're asking me how I read this case, I 13 read his -- you know, his attorney, and you know 14 enough about the case and -- and the background 15 from the e-mails and the -- the stuff about we're 16 going to quote, unquote, embarrass the Town. 17 And you know, I don't need to belabor that 18 aspect of the case, but you know, we made it very 19 clear that no, this is -- this is not a -- a 20 situation which -- which the Town is simply going 21 to capitulate because it may be quote, unquote, 22 embarrassed. 23 COMMISSIONER TRINLEY: And it has been 24 brought out that he did not follow the personal 25 rules or regs, right, to get -- Florida Court Reporting 561-689-0999 Page: 19 10 I* 1 MR. REYNOLDS: That's my Motion to Dismiss. 2 COMMISSIONER TRINLEY: Okay. 3 MR. REYNOLDS: Absolutely, and that's when I 4 go straight down. Of course he takes the position, 5 and I think I made that clear in our last meeting, 6 that -- that he's the end-all/say-all on personnel 7 issues. 8 That's -- that's their complaint, and that 9 our position is: No. Whether you recognize it or 10 not, the Town manager works for the Town, and the 11 Town is run by the commission. 12 COMMISSIONER TRINLEY: Well, he has been 13 known to say that the commission works for him, 14 so... 15 MR. REYNOLDS: Oh, yeah. I -- yes, I -- I 16 have no doubt whatsoever. 17 COMMISSIONER TRINLEY: And I'm the only one 18 sitting here who's been involved with that. So 19 I -- I know him quite well, and I wouldn't be 20 surprised if he wanted to go to trial. 21 MR. REYNOLDS: Oh, I wouldn't either. I 22 wouldn't either. And -- and -- and candidly, and I 23 can tell you, because this has happened in cases 24 that I've had over the years, which is: If his 25 attorney doesn't want to go to trial and doesn't Florida Court Reporting 561-689-0999 Page: 20 r U I• 10 1 want to fight this and is trying to talk him into a 2 reasonable settlement in this range that I'm 3 talking about, seventy-five to a $100,000, he 4 doesn't like it, I wouldn't be at all surprised if 5 he fires her and hires another attorney. I mean, 6 I've had -- I've had plaintiffs do that. 7 MAYOR FEATHERMAN: Had it happen, right. 8 MR. REYNOLDS: As I've often explained to my 9 clients, my clients are like, "Why are we going to 10 trial? I made a reasonable offer." 11 I say, "I can't take that money, shove it in 12 their pocket and tell them to go away." That's not 13 how it works. 14 That's just -- that's -- that's -- and -- and 15 then so you're -- you're absolutely right. He -- 16 he may just say "absolutely, unequivocally not, I'm 17 not budging. And if you're not going to represent 18 me and you're not going to go in that courtroom 19 against Lyman Reynolds, I'll get somebody who 20 will." You -- you are a hundred percent correct. 21 COMMISSIONER PAGLIAROI: And I agree with you 22 guys a 110 percent. You're absolutely right. 23 MR. REYNOLDS: Right. And all we're trying 24 do is step back from the emotion of it and say from 25 a business standpoint if we could get a reasonable Florida Court Reporting 561-689-0999 PaoP• I • • 1 resolution in this range, my recommendation to you 2 and -- and Commissioner Sheridan, you -- you had 3 asked what my personal feelings are. 4 My personal feelings are on behalf of my 5 clients, take it. Get this behind us, get it 6 resolved and get it done; but again, those ten jury 7 trials that I had last year were all because I had 8 the same discussion with my clients. My clients 9 made very reasonable attempts at resolving the 10 case, and the other side, for whatever reason -- 11 some people think, you know, maybe I'm going to hit 12 a home run. Some people say it's the principle of 13 the thing. 14 COMMISSIONER TRINLEY: Can you share with us 15 your win and loss record? 16 MR. REYNOLDS: Nine and one. 17 COMMISSIONER TRINLEY: You won nine and lost 18 one? 19 MR. REYNOLDS: I won nine and lost one. 20 COMMISSIONER TRINLEY: That's terrific. 21 That's terrific. 22 MR. REYNOLDS: And I shouldn't have lost the 23 one. 24 COMMISSIONER TRINLEY: I'll go to trial with 25 you. Florida Court Reporting 561-689-0999 I* KI • 1 MR. REYNOLDS: And of course, the one is the 2 one that still eats me alive. I don't even think 3 about the nine wins. 4 COMMISSIONER TRINLEY: Yeah. 5 MR. REYNOLDS: It's the one that you're going 6 "okay, I just never should have lost that case." 7 MAYOR FEATHERMAN: You have something to say, 8 Town Manager? 9 TOWN MANAGER WEISER: I just have a -- a 10 procedure question. 11 Is that a normal course of action when you go 12 in, mediate at a table and walk away and then start 13 negotiating via paper? 14 MR. REYNOLDS: Yes. Yeah. Yeah. I mean, 15 anybody can negotiate anytime. I mean, I've 16 actually settled cases that -- that I've won on 17 appeal. 18 Mr. Roberts, who many of you know, my -- my 19 partner and I were up in Atlanta before the llth 20 Circuit Court of Appeals on a horrible brain damage 21 case that I won on a summary judgment, and you're 22 still rolling the dice. Is the Appellate Court 23 going to -- to uphold the summary judgment? 24 And Plaintiff's counsel approached and -- and 25 said, "Can we get that last reasonable offer that Florida Court Reporting 561-689-0999 Page: 23 � 0 • • 1 you made?" 2 And we said, "Well, considering the position 3 we're in, you can't get that, but you can get half 4 of that." And they took it. 5 And so yes, that -- that -- the -- the -- we 6 did an early, early mediation in this case because 7 normally you don't do mediation until you notice 8 the case for trial. But we did this one early 9 trying to save the attorney's fees, the costs, as 10 you -all know, and -- and we know this, and I'm sure 11 you -all would anticipate this, that if it doesn't 12 get resolved, it's like any of the other cases that 13 I presently have. You're going to see people going 14 to the press and into the newspapers. 15 And so we were saying -- thinking, "Hey, if 16 we can do it sooner rather than later, let's get it 17 done." But yeah, that's -- that's the usual 18 procedure. 19 COMMISSIONER TRINLEY: Excuse me. 20 MR. REYNOLDS: Yes, ma'am? 21 COMMISSIONER TRINLEY: Would the hundred 22 thousand include your attorney fees? 23 MR. REYNOLDS: No. No. No. The -- the -- 24 well, the insurance company pays my attorney's 25 fees. Florida Court Reporting 561-689-0999 Pave• ')d K I • �J 1 MAYOR FEATHERMAN: They pay him. 2 MR. REYNOLDS: That doesn't cost you -all 3 anything. That is $100,000 to him. 4 COMMISSIONER TRINLEY: To him, okay. 5 MR. REYNOLDS: And then he has to pay his 6 attorney and his costs out of that, and oftentimes 7 these are taken on either a -- 8 MAYOR FEATHERMAN: Percentage. 9 MR. REYNOLDS: -- contingency fee basis or a 10 semi -contingency fee basis. And well -- and for a 11 governmental entity case, my position is that they 12 should be contingency, and it's a 25 percent. It's 13 not the usual 40 percent. 14 MAYOR FEATHERMAN: Forty. 15 COMMISSIONER TRINLEY: Well, I think we can 16 sit here and talk for another 20 minutes or so, but 17 from what you've told me, I -- I, for one, would 18 say go for the hundred thousand and I wish you the 19 best. 20 COMMISSIONER SHERIDAN: One other question. 21 Would not the decision of this mediator that was 22 beneficial to the Town have some reflection on the 23 case regarding our benefit? 24 MR. REYNOLDS: No. 25 MAYOR FEATHERMAN: No. Florida Court Reporting 561-689-0999 Page- 25 10 • • 1 MR. REYNOLDS: The mediator doesn't decide. 2 COMMISSIONER SHERIDAN: No, I don't mean 3 decide, but his decision that was made. 4 MR. REYNOLDS: No, he doesn't make one. 5 That's an arbitrator. 6 COMMISSIONER SHERIDAN: I'm sorrv. I'm 7 sorry. 8 MR. REYNOLDS: Yeah, a mediator is -- 9 COMMISSIONER SHERIDAN: Yeah, I'm sorry. 10 MR. REYNOLDS: -- is just a settlor. He's 11 just -- he's just the broker in-between. 12 And candidly, I think he did help us. 13 Because as I said, they were off in the 14 stratosphere when we broke off the negotiations. 15 Still two -fifty is way, way too high, but 16 it's -- it's so significantly less because he had 17 the talk with them. I went over the Motion to 18 Dismiss with him, and so that's a second set of 19 eyes to help them try to look at it a little more 20 objectively. 21 COMMISSIONER SHERIDAN: Right. 22 MAYOR FEATHERMAN: I think we could just take 23 a vote on that then and give him permission and 24 authorization to do that. 25 I'll just say this off the cuff: I remember Florida Court Reporting 561-689-0999 Page: 26 • • 1 a woman falling off our curb at a plant that I 2 owned, a 200,000-foot plant, and she was claiming a 3 couple of million dollars. And then we were told 4 that she would settle for sixty-two hundred, and we 5 said "we're not stepping into the insurance 6 company's shoes, because if they're running it, 7 they know what to do." 8 And they settled, even though I was very 9 angry because no one was there at three in the 10 morning to see her slip. Those things can happen, 11 but I agree that we all vote to give him 12 authorization. I'll take a vote on this. 13 COMMISSIONER SHERIDAN: Yes. 14 MAYOR FEATHERMAN: Commissioner? 15 MR. TORCIVIA: You don't need an actual vote, 16 just a consensus of the body. 17 MAYOR FEATHERMAN: Then that's fine, you have 18 our consensus to go ahead and do that. 19 MR. REYNOLDS: Okay. 20 MAYOR FEATHERMAN: Yes. 21 COMMISSIONER TRINLEY: And I wish you all the 22 luck in the world. 23 MR. REYNOLDS: I -- I do too as well. Thank 24 ya'll very much. 25 MAYOR FEATHERMAN: Thank you for being here Florida Court Reporting 561-689-0999 Pan: 27 lie I 40 • 1 today with us. 2 COMMISSIONER TRINLEY: Yeah, thank you. 3 MR. REYNOLDS: I appreciate the 4 accommodation. 5 MAYOR FEATHERMAN: We are -- the time -- the 6 time is -- 7 COMMISSIONER PAGLIAROI: Can we have a time 8 frame of when you'll get back to us? 9 MR. REYNOLDS: Oh, I will keep -- 10 MAYOR FEATHERMAN: Notify us? 11 MR. REYNOLDS: -- the manager -- 12 MAYOR FEATHERMAN: Right. 13 MR. REYNOLDS: -- who sits as your risk 14 manager and the City attorney apprised -- 15 COMMISSIONER PAGLIAROI: A guesstimate? 16 MR. REYNOLDS: -- of those. I would say 17 within no more than 30 days he'll know where we 18 stand. 19 MAYOR FEATHERMAN: That's fine. 20 MR. REYNOLDS: We'll -- we'll -- as I said, 21 I'm going to get out this $7500 (sic) Proposal for 22 Settlement tomorrow. 23 MAYOR FEATHERMAN: Right. 24 MR. REYNOLDS: And they have 30 days, but 25 I'll get a call, I'm sure. Florida Court Reporting 561-689-0999 Pan: 28 lie � 0 lie 1 COMMISSIONER TRINLEY: Make sure you say 2 75,000, not 7500 as you just did. 3 MR. REYNOLDS: You're exactly right, I did. 4 You're right. 5 MAYOR FEATHERMAN: Don't put that in there. 6 MR. REYNOLDS: I'll put the $75,000 -- you 7 know what? That's a Freudian slip, because I was 8 thinking I'd really prefer to put 7500 on it, but 9 that's just -- that stays right in this room. 10 MAYOR FEATHERMAN: All righty. You're 11 excused on that. The time now is -- 12 MR. REYNOLDS: Thank you. 13 MAYOR FEATHERMAN: The time now is 3:19, and 14 there being no further business, I call for a 15 Motion to Adjourn. 16 TOWN MANAGER WEISER: Hold on. You have to 17 wait until Beverly comes back. 18 THE TOWN CLERK: I'm here. Go ahead. 19 MAYOR FEATHERMAN: The meeting is closed in 20 reference to our legal situation and opened again. 21 There's no public comments from anybody here, and 22 so I look for a Motion to Adjourn. 23 COMMISSIONER SHERIDAN: I make a Motion to 24 Adjourn. 25 COMMISSIONER PAGLIAROI: I second it. Florida Court Reporting 561-689-0999 I• r � 1 2 3 4 13 14 15 16 17 18 19 20 21 WK 23 24 25 MAYOR FEATHERMAN: All in favor saying aye. (Motion carried by unanimous voice vote.) MAYOR FEATHERMAN: Any nos? Hearing none, I call this Motion for Adjournment of the meeting at one -- at 3:20 p.m. (Proceedings were adjourned.) Florida Court Reporting 561-689-0999 Pace- 30 10 0 7 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 THE STATE OF FLORIDA, ) COUNTY OF PALM BEACH ) I, WANDA D. GOOD, a Professional Court Reporter and Notary Public in and for the State of Florida at Large: DO HEREBY CERTIFY that the above -entitled and numbered cause was heard as hereinabove set out; that I was authorized to and did report in shorthand the proceedings, and that the foregoing pages, numbered 1 through 29 inclusive, comprise a true and correct transcript of my stenographic notes taken during said proceeding. IN TESTIMONY WHEREOF, I have hereunto affixed my signature this 8th day of July, 2012. WANDA D. GOOD, Notary Public, Certified Court Reporter Florida Court Reporting 561-689-0999