LTC 064-2019 Deauville Beach ResortOFFICE OF THE CITY ATTORNEY LETTER TO COMMISSION
064-2019
LTC No.
TO: Mayor Dan Gelber
Members of the City Commission
FROM:
City Manager Jimmy L. Morales /). •• :, / __.-/
City Attorney Raul J. Aguila ~,J.Lt1J·
DATE: February 5, 2019
SUBJECT: Deauville Beach Resort
The purpose of this Letter to Commission is to provide the Mayor and City Commission with an
update regarding the Deauville Beach Resort.
At the direction of the Mayor and City Commission, the City Attorney's Office filed a lawsuit against
the De~uville Beach Resort entities on February 5, 2019 for an injunction to avoid demolition by
neglect (in accordance with Section 118-532(g) of the Code of the City of Miami Beach), the
appointment of a receiver, and breach of fiduciary duty for the failure to remit resort taxes due
and owing to the City. The Complaint is attached to this Letter to Commission as Exhibit "A".
Should you have any questions or concerns about any of the foregoing, please don't hesitate to
contact me.
Filing# 84407310 E-Filed 02/05/2019 09:32:03 AM
EXHIBIT "A"
THE CITY OF MIAMI BEACH, FLORIDA, a
Florida municipal corporation,
Plaintiff,
v.
DEAUVILLE ASSOCIATES, LLC, a Florida limited
liability company, DEAUVILLE HOTEL
PROPERTY, LLC, a Florida limited liability
company, DEAUVILLE HOTEL HOLDINGS, LLC,
a Florida limited liability company, and OCEAN
BANK, a Florida banking corporation,
Defendants.
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IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT, IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO.:
THE CITY OF MIAMI BEACH, FLORIDA'S COMPLAINT
FOR INJUNCTIVE RELIEF, DAMAGES, AND APPOINTMENT OF RECIEVER
Plaintiff, the City of Miami Beach, Florida (the "City"), sues Deauville Associates, LLC,
Deauville Hotel Property LLC, Deauville Hotel Holdings, LLC, and Ocean Bank, and alleges as
follows:
JURISDICTION, VENUE AND IDENTIFICATION OF PARTIES
1. This is an action for an injunction to avoid demolition by neglect, in accordance
with the Section 118-532(g) of the Code of the City of Miami Beach, Florid, ("City Code"), for
damages in excess of $15,000.00, and for the appointment of a receiver, and is within the
jurisdiction ofthis Court.
2. The City is a political sub-division of the State of Florida.
3. At all times material hereto, Deauville Associates, LLC is a Florida limited liability
company with its principal office located in Miami-Dade County, Florida, and is doing business
in Miami-Dade County, Florida.
CASE NO.:
4. At all times material hereto, Deauville Hotel Property, LLC is a Florida limited
liability company with its principal place of business in Miami-Dade County, Florida and is doing
business in Miami-Dade County, Florida.
5. At all times material hereto, Deauville Hotel Holdings, LLC is a Florida limited
liability company with its principal place of business in Miami-Dade County, Florida and is doing
business in Miami-Dade County, Florida.
6. Ocean Bank is a Florida banking corporation with its principal place of business
located in Miami-Dade County, Florida. At all times material hereto, it was doing business in
Miami-Dade County, Florida.
7. Ocean Bank ("Lender") has an interest in this action as the holder of a Promissory
Note and holder of the Amended and Restated Mortgage and Security Agreement executed as of
July 8, 2005, by Deauville Associates, LLC, Deauville Hotel Property, LLC, and Deauville Hotel
Holdings, LLC, in favor of Lender and recorded in Official Records Book 23592, Page 1827, of
the public records of Miami-Dade County, Florida, as modified by that certain Extension and
Modification of Note and Mortgage Agreement executed as of September 23, 2008, by Deauville
Associates, LLC, Deauville Hotel Property, LLC, and Deauville Hotel Holdings, LLC, in favor of
Lender, and as is further modified by that Certain Modification of Mortgage and Other Loan
Documents, executed May 17, 2011, by Deauville Associates, LLC, Deauville Hotel Property,
LLC, and Deauville Hotel Holdings, LLC, in favor of Lender and recorded in Official Records
Book 27713, Page 4188, ofthe public records ofMiami-Dade County, Florida, and encumbers the
real property located at 6701 Collins Avenue, Miami Beach, Florida (the "Property").
8. Venue is proper in this Court because the Property which is the subject matter of
this action and the causes of action alleged herein accrued in Miami-Dade County.
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9. All conditions precedent to bringing this action have occurred, been performed or
excused.
GENERAL FACTUAL ALLEGATIONS
THE HISTORIC DEAUVILLE BEACH RESORT
10. The Deauville Beach Resort is a 538-room ocean front hotel located at 6701 Collins
A venue, Miami Beach, Florida owned by Deauville Associates, LLC, and is operated by Deauville
Associates, LLC, Deauville Hotel Property LLC, Deanville Hotel Holdings, LLC. (collectively
referred to as "Deauville").
11. The Deanville Beach Resort was designed by the noted architect Melvin Grossman
and constructed in 1957, and upon opening, the Deauville was named "Hotel of the Year."
Deauville History, https://deanvillebeachresortmiami.com/home/deauville-history/, attached
hereto as Exhibit "A".
12. The Deauville Beach Resort's iconic design is described as "Post War Modern"
and, more recently, "Miami Modern" (MiMo), a style that picked up where Art Deco left off with
the added influences of a booming post World War 2 economy, new technologies, the prevalence
of the redesigned automobile, and a feeling of national optimism. Id; North Beach Resort Historic
District Designation Report, City of Miami Beach Planning Department (March 17, 2004).
13. The Deauville Beach Resort was a favored venue for many notable entertainers of
the 1950s and 1960s, including Frank Sinatra, Sammy Davis, Jr., Dean Martin, Joey Bishop, Tony
Bennett, Bing Crosby, Judy Garland, Sophie Tucker, Henny Youngman, Milton Berle and Jerry
Lewis. See Exhibit "A".
14. Notably, the Deauville Beach Resort is iconic for hosting one of the most
significant events in the history of popular music: The Beatles' performance on The Ed Sullivan
Show on February 16, 1964. Id.
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Historic Preservation in Miami Beach
15. The City Commission has declared that "the preservation and conservation of
properties of historical, architectural and archaeological merit in the [C]ity is a public policy of the
[C]ity and is in the interest ofthe [C]ity's future prosperity." Section§ 118~501 ofthe City Code.
As adopted by the Mayor and City Commission, the goals of the City's historic preservation
regulations include:
[t]he protection of historic sites and districts to combat urban blight,
promote tourism, foster civic pride, and maintain physical evidence of
the [C]ity's heritage; ...
[t]he encouragement and promotion of restoration, preservation,
rehabilitation and reuse of historic sites and districts by providing technical
assistance, investment incentives, and facilitating the development review
process; ...
[t]he promotion of excellence in urban design by assuring the compatibility
of restored, rehabilitated or replaced structures within designated historic
districts; and ...
[t]he protection of all existing buildings and structures in the [CJity's
designated historic districts or on designated historic sites from
unlawful demolition, demolition by neglect and the failure of property
owners to maintain and preserve the structures.
Section§ 118-502 ofthe City Code (emphasis added).
16. The City Code requires Historic Preservation Board review of "all applications
involving demolition, new construction, alteration, rehabilitation, renovation, restoration or any
other physical modification of any building, structure, improvement, significant landscape feature,
public interior or site individually designated in accordance with sections 118-591, 118-592 and
118-593, or located within an historic district." Section § 118-563 of the City Code.
17. The Deauville Beach Resort is a "Contributing" structure located within the North
Beach Resort Local Historic District, and the Property falls under the jurisdiction of the City's
Historic Preservation Board. City of Miami Beach Code of Ordinances No. 2004-3438.
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DEMOLITION BY NEGLECT-THE DEAUVILLE BEACH RESORT
18. In or around July 2017, the Property was rendered uninhabitable due to extensive
damages caused by an electrical fire at the Property, forcing Deauville to close the Deauville Beach
Resort. Approximately two months after the electrical fire, the Property sustained wind and water
damage caused by Hurricane Irma, which damages were later amplified by certain illegal work
performed on the Property without a permit.
19. The Property has not re-opened since its closing in July 20 17.
20. Since the Property's closing in July 2017, the Deauville has not undertaken any
substantial remedial measures at the Property, causing the Property to deteriorate which is
jeopardizing the structural integrity of the historic "Contributing" structure.
21. Following an inspection performed by the City on July 25, 2017, the City issued
Violation US20 17-01686 against Deauville Hotel Property LLC, deeming the structure an "Unsafe
Structure", and providing Deauville Hotel Property LLC fifteen (15) days to: (1) submit an
engineering report signed and sealed by electrical engineer to evaluate the cause of the fire, the
extent of the damages and methods of repair; (2) obtain approved final inspection to reconnect
power to the building; and (3) obtain approved permits for the required repairs. A copy of Violation
US20 17-0 1686 is attached hereto as Exhibit "B".
22. Deauville failed to timely comply with the City's Violation US20 17-0168.
23. In accordance with Section 118-532(g) of the City Code, pertaining to the
"Maintenance ofDesignated Properties and demolition by neglect", the City requires that buildings
located within local historic districts be properly maintained, and contributing structures within
the local district are required to properly maintain and preserve the structure in accordance with
standards set forth in the applicable City Code, Florida Building Code, and the City's Certificate
of Appropriateness criteria.
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24. The City has defined "demolition by neglect" as any failure to comply with the
minimum required maintenance standards of City Code Section 118~532, whether deliberately or
inadvertently and Section 118~ 532(g)(l)(a) of the City Code outlines required minimum
maintenance standards in order to preserve from deliberate or inadvertent neglect, the interior,
exterior, structural stability and historic and architectural integrity of any building located within
a local historic district. Such defects shall include, but are not limited to the following:
a) Deteriorated or decayed facades or facade elements, including, but not limited to,
facades which may structurally fail and collapse entirely or partially;
b) Deteriorated or inadequate foundations;
c) Defective or deteriorated flooring or floor supports or any structural members of
insufficient size or strength to carry imposed loads with safety;
d) Deteriorated walls or other vertical structural supports, or members of walls,
partitions or other vertical supports that split, lean, list or buckle due to defective
material or deterioration;
e) Structural members of ceilings, roofs, ceiling and roof supports or other horizontal
members which sag, split or buckle due to defective material or deterioration;
f) Deteriorated or ineffective waterproofing of exterior walls, roofs, foundations or
g) floors, including broken or missing windows or doors;
h) Defective or insufficient weather protection which jeopardizes the integrity of
exterior or interior walls, roofs or foundation, including lack of paint or weathering
due to lack of paint or other protective covering; any structure which is not properly
secured and is accessible to the general public; or any fault or defect in the property
that renders it structurally unsafe or not properly watertight;
i) The spalling of the concrete of any portion of the interior or exterior of the building.
25. Pursuant to Section 118~532(g)(l)(b) of the City Code, pertaining to "Notice
administrative enforcement and remedial action", if any building located within a local historic
district, in the opinion of the historic preservation board, Planning Director or designee, or the
City's Building Official or designee, falls into a state of disrepair so as to potentially jeopardize its
structural stability and/or architectural integrity, and/or the safety of the public and surrounding
structures, or fails to satisfy any of the required minimum maintenance standards above, the
Planning Director or designee, or the City's Building Official or designee shall have right of entry
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onto the subject property and may inspect the subject property after 48 hours' notice to the owner
of intent to inspect.
26. On September 19, 2018, the City of Miami Beach Planning Director and the City's
Building Official determined that the Property had fallen into a state of disrepair that jeopardizes
the structural and architectural integrity of the Property, which decision was based upon several
visual inspections ofthe exterior of the premises, the numerous building permits that have not been
issued or finalized, the inability to occupy the structure, the fact that the Deauville's contractor had
placed the City on notice of his intent to withdraw as the Contractor of Record, and the fact that
the City issued an Unsafe Structure Board filing with Miami-Dade County with regard to the
Property.
27. More specifically, the Planning Director and Building Official determined that the
Property did not meet the required minimum maintenance standards established in 118-
532(g)(l)(a) which include, inter alia, deteriorated or decayed facades or facade elements,
including, but not limited to, facades which may structurally fail and collapse entirely or partially;
deteriorated or inadequate foundations; deteriorated or ineffective waterproofing of exterior walls,
roofs, foundations or floors, including broken or missing windows or doors; defective or
insufficient weather protection which jeopardizes the integrity of exterior or interior walls, roofs
or foundation, including lack of paint or weathering due to lack of paint or other protective
covering; any structure which is not properly secured and is accessible to the general public; any
fault or defect in the property that renders it structurally unsafe or not properly watertight; the
spalling of the concrete of any portion of the interior or exterior of the building.
28. Based upon the Planning Director's and the Building Director's findings, in
accordance with Section 118-532(g)( 1 )(b) of the City Code, the City issued its "48 Hour Prior
Notice Of Intent To Inspect Pursuant To The City's Demolition By Neglect Procedures", intending
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to inspect the interior and exterior of the Property. The 48 Hour Prior Notice of Intent is attached
hereto as Exhibit "C".
29. On or about October 8, 2018, the City and Deauville held an inspection at the
Property pursuant to the 48 Hour Prior Notice Of Intent to Inspect Pursuant to the City's
Demolition by Neglect Procedures.
30. At the October 8, 2018 inspection, the City confirmed that the Property did not
ineet the required maintenance standard performed set forth in City Code Section 118-532(g). The
inspection photos are attached hereto as Composite Exhibit "D".
31. The City notified the Deanville on October 11, 2018 that the inspection confirmed
that the Property did meet the minimum required maintenance standard set forth in City Code
Section 118-532(g), and that the City would institute an action to avoid demolition by neglect
claim unless the Deauville undertook meaningful action to place the Property in compliance with
the established maintenance standard, attached hereto as Exhibit "E".
32. To date, Deauville has failed to perform any substantial work at the Property which
would be required in order to place the Property in compliance with Section 118-532(g) of the City
Code.
3 3. Deauville' s continuing failures to perform the required repair and remediation work
to the Property is resulting in the ongoing deterioration of the structure, which unless resolved,
will deteriorate beyond repair requiring the demolition of the historic Property, a "Contributing"
structure located in the North Beach Resort Local Historic District.
34. A case is currently pending before Miami-Dade County Unsafe Structures Board,
Case No. US2017-0 168 ("Unsafe Structures Case") related to Violation US20 17-0168 issued by
the City. Supra at 21-22.
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35. At its meeting on December 12, 2018 regarding the Unsafe Structures Case, the
Miami-Dade County Unsafe Structures Board upheld the recommendation of the City's Building
Official and entered the following ruling:
a) The structure(s) are to be maintained secure, clean and sanitary, free of debris,
overgrown grass or weeds and free of discoloration or graffiti.
b) A temporary electrical power permit must be applied for within thirty (30) days of
the date of the ruling. The temporary electrical permit shall be obtained within sixty
(60) days from the date of the ruling. The building permit(s) to repair windows and
for concrete spalding must be applied for within sixty (60) days after obtaining the
temporary electrical permit, with the understanding that no work can be performed
until the temporary power permit is issued.
c) A 40-Year Recertification Report shall be submitted within one hundred twenty
(12) days from obtaining the temporary electrical permit to the City of Miami Beach
Building Official as required in standard form signed and sealed by a structural and
electrical engineer and to obtain all necessary permits to repair and restore said
structure.
Unsafe Structures Board Order, attached hereto as Exhibit "F".
36. The Deauville has not applied for temporary power within thirty (30) clays of the
Unsafe Structures Case ruling, and the Deauville has not undertaken any meaningful steps
necessary to comply with any other. ruling from the Unsafe Structures Board Order.
37. On January 24, 2018, the City issued Violation ZV2019-02352 to Deauville
Associates LLC based on the failure to comply with the minimum required maintenance standards
established in Section 118-532(g) of the City Code. A copy of Violation ZV20 19-02352 is attached
hereto as Exhibit "G".
38. In fact, it is clear that the Deauville has no intention on voluntarily undertaking the
repairs necessary to bring the Property into compliance with the City Code and the City's Historic
Preservation Board, and Deauville is hedging its bets that the City will eventually allow the
demolition of the structure: "It would be a favor that they demolish the [Property] and I get rid of
this nightmare that I have. That's the truth." Unsafe Structures Case Hearing Transcript, P. 38, 7-
10, December 12, 2018, attached hereto as Exhibit "H". "So, the building is full of water, full of
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mold and mildew. We have no power. I mean, what do we do? We have no money. Id at P. 33, 13-
16.
39. Incredibly, the only work that the Deauville has performed on the Property since
the Deauville Beach Resort closed its doors to the public was the illegal work Deauville performed
on the roof without any construction permit, which Deanville officials freely admitted under oath
at the Unsafe Structures Case hearing. See Exhibit "H", Pages 41-42; 19-25, 1-0; Pages 53-54; 20-
25, 1-3.
herein.
Code.
COUNT I
INJUNCTION PURSUANT TO SECTION 118-532(g) OF THE CITY CODE
TO A VOID DEMOLITION BY NEGLECT
40. The City re-alleges and reincorporates Paragraphs 1 through 39 as if fully set forth
41. This is an action for injunctive relief pursuant to Section 118-532(g) of the City
42. The Property is located within the City's North Beach Resort Local Historic District
and is classified as a "Contributing" structure.
43. Section 118-532(g) of the City Code requires that the owner of any building,
structure, improvement, landscape feature, public interior located within a historic district to
properly maintain and preserve such building or structure in accordance with the Florida Building
Code and Section 118-532(g) ofthe City Code.
44. The City sent Deanville a 48 Hour Prior Notice Of Intent To Inspect Pursuant To
The City's Demolition By Neglect Procedures. See Exhibit "C".
45. On or about October 8, 2018, the City met with the Deanville at the Property
pursuant to the 48 Hour Prior Notice Of Intent to Inspect Pursuant to the City's Demolition by
Neglect Procedures.
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46. The inspection performed on October 8, 2018 confirmed that the Property did not
meet the required minimum maintenance standards as set forth in Section l18-532(g) of the City
Code. See Composite Exhibit "D"; see also Exhibit "E".
47. To date, Deauville has failed to perform work required to put the Property within
the required minimum maintenance standards set forth in by Section 118-532(g) ofthe City Code.
48. The City is entitled to an injunction requiring the Deauville to take the remedial
and corrective action necessary to restore the Property's compliance with the required 'minimum
maintenance standards set forth in by Section 118-532(g) of the City Code. Section 118-
532(g)(l)(c) ofthe City Code.
49. The Property is a "Contributing" structure located in the North Beach Resort Local
Historic District, subject to the City's zoning regulations pertaining to historic properties, and the
City will suffer irreparable harm unless the Property is brought into compliance with City Code
Section l18-532(g) because Deauville's continuing failures to perform the required repair and
remediation work to the Property will result in the ongoing structural and architectural
deterioration of an iconic Miami Beach property, and, unless resolved, will ultimately result in the
Property's deterioration beyond repair requiring the demolition of the Property.
50. There is no other adequate remedy at law to the City.
51. The public interest supports the entry of an injunction pursuant City Code Section
118-532(g) because the public has an interest in the maintaining of historical properties and
structures located within the City.
WHEREFORE, the Plaintiff, the City of Miami Beach, respectfully requests that that this
Court enter an injunction in its favor against Deauville, requiring Deauville to take the remedial
and corrective action necessary to restore the Property's compliance with the required minimum
maintenance standards set forth City Code Section 118-532(g), together with the City of Miami
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Beach's reasonable attorney's fees and costs pursuant to City Code Section 118-532(g)(5),
together with such further relief that this Court deem just and proper.
herein.
COUNT II
BREACH OF FIDUCIARY DUTY TO REMIT RESORT TAXES
AGAINST DEAUVILLE ASSOCIATES LLC
52. The City re-alleges and incorporates paragraphs 1 through 39 as if fully set forth
53. This is an action for breach of fiduciary duty against Deauville Associates, LLC for
failure to remit resort taxes to the City of Miami Beach pursuant to Section 102-307 of the City
Code.
54. The City levies a tax of four percent ( 4%) on the rent of every occupancy of a room
or rooms in any hotel, motel, rooming house, or apartment house in the city, and two percent upon
the total sales price of all items of food, beverages, alcoholic beverages or wine sold at retail of
any restaurant. Section 102-307(a) ofthe City Code.
55. Such tax constitutes a debt owed by the occupant or guest to the City. Section 102-
307(b) ofthe City Code.
56. The Deauville Associates, LLC owes a duty to the City to remit all resort taxes
collected from the Deauville Beach Resort's occupants or guests to the City.
57. The City performed an audit of the Property and Deauville Associates, LLC
regarding the Deauville Associates, LLC's resort tax obligation to the City, identifying that the
Deauville Associates, LLC owes in excess of$91,2120.48 to the City for its resort tax obligations.
A copy of the Audit is attached hereto as Exhibit "I".
58. On September 19, 2018, the City recorded a claim of lien for unpaid resort taxes in
official records Book 31146, Page 3912 of the Public Records in and for Miami-Dade County,
Florida. A copy of the claim of lien is attached hereto as Exhibit "J".
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59. Deauville Associates, LLC has knowingly, willfully, and recklessly breached the
fiduciary duties of good faith, loyalty and due care owed to the City to remit resort taxes.
60. The City has been damaged in excess of $91,2120.48 for Deauville Associates,
LLC's breach of fiduciary duty remit resort taxes to the City.
WHEREFORE, the Plaintiff, the City of Miami Beach, respectfully requests that that this
Court enter judgment in its favor against Deauville Associates, LLC, awarding the City damages
in excess of $15,000.00 plus interest, fees, reasonable attorney's fee's, costs, and any other relief
that this Court deem just and proper.
COUNT III
APPOINTMENT OF RECIEVER
61. The City re-alleges and incorporates paragraphs 1 through 39, 42 through 51, and
54 through 60 as if fully set forth herein.
62. The City seeks the appointment of a receiver to: (1) ensure the collection of all
resort taxes owed to the City by Deauville Associates, LLC; (2) manage the Property; (3) oversee
all repair and remediation work required for the Property to comply with Section 118-532 of the
City Code; (4) take all required measures to rectify all outstanding City violations related to the
Property; (5) collect and remit all outstanding taxes related to the Property; and (6) collect
and remit to the City all civil penalties or fines against the Property or Deauville pursuant to the
applicable sections of the City Code.
63. The City has a clear right and entitlement to: (1) collect Deauville Associates,
LLC's resort tax obligations to the City; (2) to require Deauville to manage and maintain the
Property subject to the minimum maintenance standards set forth in City Code Section 118-
532(g)(5); (3) cause Deauville to undertake repair and remediation work required for the Property
to comply with Section 118-532 of the City Code; ( 4) require that Deauville rectify all outstanding
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City violations related to the Property; and (5) collect civil penalties and fines against the Property
or Deauville pursuant to the applicable sections of the City Code.
64. As such, the City has a strong likelihood of success on the merits.
65. The Property has remained closed since July 20 17, and Deauville has failed to
perform any significant remedial or repair efforts that would place the Property in compliance with
City Code Section 118-532(g)(5).
66. The Deauville has indicated that it has no intention of performing the work required
to place the Property within compliance with the City's Land Development Regulations and City
Code Section 118-532(g)(5). Supra at 38.
67. Deauville Associates LLC has failed to remit resort taxes due and owing to the City
in excess of$15,000.00.
68. The Property is in a state of disrepair and is being wasted all while Deanville is not
taking any significant steps towards performing any work necessary to restore the historic Property
and re-open the Deauville Beach Resort.
69. There is good cause to believe that immediate and irreparable harm to the City's
interests in maintaining the historical status of the Property will occur from Deauville's and the
Property's ongoing violations, tax obligations and failure to maintain and repair the Property
without the appointment of a receiver.
70. There is no other adequate remedy at law to protect the Property from the ongoing
waste, deterioration, accruing fines, liens, and violations, and as such the immediate appointment
of a receiver over the Property is necessary to protect the City's interest in the Property.
WHEREFORE, the Plaintiff, the City of Miami Beach, respectfully requests that that this
Court appoint a receiver and order that the receiver takes any and all necessary action required to:
( 1) ensure the collection of all resort taxes owed to the City by Deauville Associates, LLC;
(2) manage the Property;
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(3) oversee all remediation and repair work required for the Property to comply with
Section 118-532 of the City Code;
( 4) take all required measures to re.ctify all outstanding violations related to the Property;
(5) collect and remit all outstanding taxes related to the property; and
(6) collect and remit to the City all civil penalties ot· fines against the Pmpetty or Deauville
pursuant to the applicable sections of the City Code.
DATED this 4th day of February, 2019.
Respectfully submitted,
RAUL J. AGUILA, CITY ATTORNEY
CITY OF MIAMI BEACH
1700 Convention Center Drive, 4111 Floor
Miami Beach, Florida 33139
Tel: (305) 673-7 4 70 I Fax:(305) 673-7002
By.r--· -~'----~-itA b_-_
St ven Rothstein, Esq,
Deputy City Attorney
Florida Bar No. 727547
Jason Jacobson, Esq,
Assistant City Attorney II
Florida Bar No. 118276
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