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LTC 140-2019 Deauville Beach Resort MIAMI BEACH OFFICE OF THE CITY ATTORNEY 140-2019 LTC No. LETTER TO COMMISSION TO: Mayor Dan Gelber Members of the City Commission Jimmy Morales, City Manager , f f FROM: Raul J. Aguila, City Attorney DATE: March 13, 2019 SUBJECT: Deauville Beach Resort The purpose of this Letter to Commission is to provide the Mayor and City Commission with the current status regarding the Deauville Beach Resort litigation, and the City's efforts to ensure that the Premises is secure from any further criminal activity or damage. In response to a series of criminal trespass violations and two (2) separate fires that occurred at the vacant Deauville Beach Resort on March 6, 2019, the City Attorney's Office immediately filed its Emergency Motion for Appointment of Receiver, Temporary Injunction and Memorandum of Law in Support (hereinafter identified as the "Emergency Motion") on March 7, 2019. The Emergency Motion requested that the Court enter an Order requiring the Deauville Beach Resort ownership entities to immediately and adequately secure the Property for the purpose of ensuring the safety of the general public, the City's first responders, and other City employees. On March 13, 2019, the Court entered an Order on the City's Emergency Motion, mandating that the Deauville Beach Resort ownership entities: (1) hire three (3) security guards to monitor the property during the hours of 7:00 pm to 7:00 am, one of whom must be certified for "fire watch" services; (2) install three (3) points of ingress and egress in order to allow MBPD and MBFD access to the property in case of an emergency; and (3) apply for a fencing permit on the beach side (east) of the Property in order to increase the height of the security fence to deter trespassers. A copy of the March 7, 2019 Emergency Motion and the March 13, 2019 Court Order is attached. The City shall continue to pursue its efforts to appoint a Receiver for the Property in order to ensure that, and to prevent any further deterioration of the Deauville Beach Resort. RJA/AB/sc Attachment F.\ATTO\AGUR\CITY ATTORNEY\LTC\2019\LTC=Deauville docx We are committed to providing excellent public service and safety to all who live, work, and play in our vibrant, tropical, historic community. Filing # 86073094 E-Filed 03/08/2019 09:13:17 AM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY,FLORIDA THE CITY OF MIAMI BEACH, FLORIDA, a CASE NO.: 19-03653 CA 32 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. THE CITY OF MIAMI BEACH,FLORIDA'S EMERGENCY MOTION FOR APPOINTMENT OF RECIEVER, TEMPORARY INJUNCTION AND MEMORANDUM OF LAW IN SUPPORT Plaintiff, the City of Miami Beach, Florida (the "Plaintiff' or "City"), by and through undersigned counsel and pursuant Fla. R. Civ. P. 1.620 and 1.610, moves this Court for the appointment of a receiver to take control of the Deauville Beach Resort Property, and for a temporary injunction requiring Deauville Associates, LLC, Deauville Hotel Property, LLC, and Deauville Hotel Holdings, LLC (collectively, the "Deauville") to immediately protect and secure the Deauville Beach Resort Property for the purpose of ensuring the safety of the public,City first responders and employees, the surrounding buildings, and the historic Deauville Beach Resort Property. In support of this Emergency Motion, the City incorporates its Complaint and Memorandum of Law herein and further submits the following: INTRODUCTION On February 5, 2019, the City filed its Complaint for Injunctive Relief, Damages and the Appointment of a Receiver related to the Deauville Beach Resort's protracted state of disrepair CASE NO.: 19-03653 CA 32 and fear that the owners of the Deauville Beach Resort are intentionally neglecting to maintain the property in accordance with the City Code and Florida law which will eventually lead to the deterioration beyond repair of the historic structure. The Deauville Beach Resort was closed on July 2017 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. The Property has not re-opened since its closing in July 2017. Coincidentally, on the very same day Deauville was required to respond to the City's Complaints, multiple fires broke out in the Deauville Beach Resort. A copy of the Miami Beach Police Department ("MBPD") Report is attached hereto as Exhibit "A". Two active fires were located by law enforcement, one in the main lobby and the other in the reservation office. The Miami Beach Fire Department ("MBFD") extinguished both fires. Additionally, MD PD responded and noticed several convincing signs of ongoing homeless activity within the structure. The main fire occurred in the main lobby of the building and the origin was located in a small portion of the wall just south of the front desk. The second fire occurred in the reservation office and the origin was located in the file room just in front of a file cabinet. Both fires were incendiary, as a pile of hotel paper was likely the source of the fire. Due to the building having no electricity, their CCTV is not functioning. It is strongly suggested that this fire was caused by a trespasser or trespassers at the closed Deauville Beach Resort—which trespassing Deauville has permitted due to its failure to adequately secure the property. See Exhibit A. Deauville is responsible for the on-going security of the Deauville Beach Resort which was made clear in the Miami-Dade County Unsafe Structures Board The three Deauville entities were served on February 12,2019. 2 CASE NO.: 19-03653 CA 32 Order requiring Deauville to "maintain secure" the property. See Exhibit F to Plaintiff's Complaint. Luckily, the damage caused by the fires were isolated to the main lobby and file room. However,the Deauville's perpetual disregard for securing the property invites the real possibility of a larger fire endangering the community at large, surrounding structures and Miami Beach first responders and employees. The Deauville's ongoing failure to repair and maintain the property in accordance with the City Code, and its failures to adequately secure the property are genuine matters of public concern requiring the immediate and urgent need for: (1)a temporary injunction requiring the Deauville to adequately secure the property; and (2) the appointment of a receiver due to Deauville's ongoing and intentional failures to comply with the Miami-Dade County Unsafe Structures Board Order, City Code and Florida law. FACTS 1. The Deauville Beach Resort is a 538-room ocean front hotel located at 6701 Collins Avenue,Miami Beach,Florida owned by Deauville Associates,LLC,and is operated by Deauville Associates, LLC, Deauville Hotel Property LLC, Deauville Hotel Holdings, LLC. 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. 2. 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. The Property has not re-opened since its closing in July 2017. 3 CASE NO.: 19-03653 CA 32 3. Following an inspection performed by the City on July 25,2017,the City issued Violation US2017-01686 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 US2017-01686 is attached as Exhibit "B" to Plaintiff's Complaint. Deauville failed to timely comply with the City's Violation US2017-0168. 4. 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. 4 CASE NO.: 19-03653 CA 32 5. In addition to Miami-Dade County and Florida state guidelines, the City requires that buildings located within local historic districts be properly maintained, and that 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. Section 118-532(g)of the City Code. 6. 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 of the 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. 7. 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 to inspect the interior and exterior of the Property. The 48 Hour Prior Notice of Intent is attached as Exhibit"C" to Plaintiffs Complaint. 8. 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. 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. 5 CASE NO.: 19-03653 CA 32 9. The Deauville has no intention of 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 to the Complaint as Exhibit"H". "So, the building is full of water, full of mold and mildew. We have no power. I mean, what do vve do?We have no money.Id at P. 33, 13-16. 10. 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 Deauville officials freely admitted under oath at the Unsafe Structures Case hearing before the Unsafe Structures Board. See Exhibit "H" to Plaintiff's Complaint, Pages4l-42; 19-25, 1-0; Pages 53-54; 20-25, 1-3. 11. To further demonstrate Deauville's neglect of the Deauville Beach Resort and blatant disregard for the City Code and the Miami Dade County Unsafe Structures Board Order, two (2) fires occurred at the property on March 6, 2019 which MBPD suspects was caused by trespassers to the Deauville Beach Resort, and this is all a direct result of Deauville's failure to adequately secure and protect the property. 12. In addition to the fires on March 6, 2019, MBPD and MBFD have identified numerous incidents involving trespassers and the public gaining access to the structure due to Deauville's failure to secure the property. See Exhibit"B" attached hereto. MEMORANDUM OF LAW A. The Appointment of a Receiver is Appropriate Equitable receiverships are a creation of common law,which the Supreme Court of Florida has declared should be reserved for cases involving fraud, self-dealing, or waste. Granada Lakes 6 CASE NO.: 19-03653 CA 32 Villas Condominium Ass'n, Inc. v. Metro-Dade Investments Co., 125 So. 3d 756 (Fla. 2013). The appointment of a receiver is appropriate to prevent fraud, self-dealing,or the destruction or loss of property. See McAllister Hotel v. Schatzberg, 40 So. 2d 201, 202-03 (Fla. 1949). The power to appoint a receiver has long been recognized as one that is inherent in a court of equity,which"lies in the sound discretion of the chancellor to be granted ... according to the facts and circumstances of the particular case." Ins. Mgmt. Inc. v. McLeod, 194 So. 2d 16, 17 (Fla. 3d DCA 1966). "To authorize the appointment of a receiver, the petitioner must show clear legal right to the property in controversy, or that he has some lien upon property or right in it, or that it constitutes a special fund out of which he is entitled to satisfaction of his demand. While the appointment of a receiver does not involve the determination of any right, or affect the title of either party in any manner whatever, an appointment of a receiver should be made only at the instance of those who have an acknowledged interest, or at least a probable right or interest, in or to the property, fund, or assets over which he seeks to have a receiver appointed, and where there is a strong reason to believe that the party asking for a receiver will recover."Appalachia Northern R. Co. v. Sommers, 79 Fla. 816 (Fla. 1920); see also Plaza v. Plaza, 78 So. 3d 4, 6 (Fla. 3d DCA 2011) (holding that to be entitled to the appointment of a receiver, a movant must show that the property is subject to a serious loss and that the movant has a clear legal right to the property). The allegations of Plaintiff's Complaint, including the documents and exhibits thereto, establish that Plaintiff has a clear legal right in the property because 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. Accordingly, the Deauville Beach Resort is required to meet the minimum maintenance and repair standards set forth in § 118-532(g)(1)(a) of the City Code and comply with Florida law. Additionally, the failure to comply with § 118-532(g)(1)(a) of the 7 CASE NO.: 19-03653 CA 32 City Code and the Miami Dade County Unsafe Structures Board is resulting in the ongoing deterioration of the structure which without a question is a clear waste of the historic structure. The City has a clear interest in maintaining its inventory of historic structures, including the Deauville Beach Resort. "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 of the [C]ity's future prosperity." § 118-501 of the City Code. The Deauville Beach Resort remains closed with no opening in sight as a result of the Deauville's mismanagement of the property and disregard for the historic structure.Moreover,the appointment of a receiver is needed to the self-dealing of the Deauville and breakdown of trust and communication between the City and Deauville. B. Plaintiff is entitled to have a temporary injunction issued against Deauville A trial court "is afforded broad discretion in granting, denying, dissolving or modifying injunctions..."Sacred Family Investments, Inc. v.Doral Supermarket,Inc.,20 So. 3d 412 (Fla. 3d DCA 2009); Carricarte v. Carricarte,961 so.2d 1019(Fla. 3d DCA 2007). The following factors support this Court's granting of the injunction: (i) the likelihood of irreparable harm; (ii) the unavailability of inadequate remedy at law;(iii)the substantial likelihood of success on the merits; (iv)the threatened injury to the petitioner outweighs any possible harm to the respondent; and(v) the granting of a preliminary injunction will not disserve the public interest.Mati-Dade County v. Fernandez, 905 So. 2d 213, 215 (Fla. 3d DCA 2005);see Naegele Outdoor Advertising Co., Inc. v. City of Jacksonville, 659 So.2d 1046, 1047(Fla. 1995);LaRose v.A.K., 37 So. 3d 265,266(Fla. 2d DCA 2009). Florida Courts have also held that a plaintiff must possess a "clear legal right to the relief sought." See Wilson v. Sandstrom, 317 So. 2d 732, 736 (Fla. 1975). Establishing this "right" equates to demonstrating Plaintiffs substantial likelihood of success on the merits. Hall v. 8 CASE NO.: 19-03653 CA 32 City of Orlando, 555 So. 2d 963,n.1 (Fla. 5th DCA 1990) (citing Langford v. Rotech Oxygen and Med. Equip., inc., 541 So. 2d 1267, 1268,n.2 (Fla. 5th DCA 1989)). Plaintiff's Complaint, and the instant Emergency Motion, including the documents and exhibits attached thereto, establishes that the City will suffer irreparable harm, that no adequate remedy at law exists, and the City's likelihood of success on the merits. The same also demonstrates that Plaintiff is entitled to injunctive relief in light of Deauville's self-dealing conduct and the extreme damage and harm to the community at large arid the City's first responders(MBPD and MBFD)that may result if Deauville's conduct is not required to be altered by Court order. As such, the Plaintiff requests that the Court enjoin Deauville, requiring Deauville to immediately provide adequate and necessary security for the property. I. It is Substantially Likely that the City Will Suffer Irreparable Harm Irreparable harm exists where the harm cannot be adequately compensated for by a monetary award.Supreme Service Station Corp. v. Telecredit Sery1 ce Center, Inc., 424 So. 2d 844 (Fla. 1982); City of Miami Springs v. Steffon, 423 So.2d 930(Fla. 1982). The showing that the agreement in question is being directly violated and that"from the nature of the act of the circumstances (the breach) cannot be readily,adequately,and completely compensated for with money,..." is sufficient to support the finding of irreparable injury. Puga v. Suave Shoe Corp., 374 So. 2d 552 (Fla. 3d DCA 1979). Injunctive relief is appropriate to prevent the dissipation of funds and removal of assets. See e.g., Blecher v. Dreyfus Brokerage Servs.,Inc., 770 So.2d 1276(Fla.3d DCA 2000); Gruder v. Gruder, 433 So.2d 2g (Fla.4th DCA 1983). The purpose of a temporary injunction is to maintain the status quo pending determination of the suit. North Dade Water Co. v.Adken Land Co., 114 So. 2d 347 (Fla. 3d DCA 1959). The City has no way to determine the amount of damages that have been inflicted upon the City by Deauville as the City's desire to demand a safe environment for its citizens and visitors and maintain historic properties within the City cannot be quantified. Additionally,the potential damage that could be 9 CASE NO.: 19-03653 CA 32 sustained to human life and the structures surrounding the Deauville Beach Resort due to Deauville's failure to simply secure the property cannot be quantified at this time. Further,there exists no adequate remedy at law because the City does not own the subject property and is not in possession or control of the structure. II. Plaintiff has Established a Substantial Likelihood of Success on the Merits and/or a Clear Legal Right to the Requested Relief The City, through its underlying Complaint, is seeking: (1) injunctive relief pursuant to § 118- 532(g)of the City Code;(2)breach of fiduciary duty against Deauville Associates,LLC for failure to remit resort taxes to the City of Miami Beach pursuant to§ 102-307 of the City Code;and(3)the appointment of a receiver. It is clear that Deauville has failed to maintain the Deauville Beach Resort consistent with the minimum maintenance standards set forth in§ 118-532(g)of the City Code as demonstrated by the fact that the Deauville Beach Resort remains closed and the inspection performed by the City evidenced a deterioration of the structure and property. Further,resort tax obligations remain unpaid by the Deauville. Due to all the forgoing, the City has demonstrated a substantial likelihood of success on the merits of its claims and that the City possesses a"clear legal right"to the requested relief. C. The Injury to the City will Outweigh Any Possible Harm to Deauville The City's demand is simple,to adequately secure the Deauville Beach Resort.Deauville is already required to secure the property according to the Miami-Dade County Unsafe Structures Board Order and has failed to do so.The property is in an absolute state of disrepair while there have been numerous incidents of trespasses and fires at the subject property.See Exhibits A,B.If the Deauville is allowed to disregard its obligation to secure the property then the harm to the City,its residents,tourists,and structures surrounding the Deauville Beach resort will be immeasurable. The potential loss of life and property clearly outweighs any possible harm to the Deauville. Frankly, we are lucky that the multiple fires and trespasses at the Deauville have not already caused the loss of life and property. 10 CASE NO.: 19-03653 CA 32 D. Entry of a Temporary Injunction Will Not Disserve the Public Interest It is in the public interest for the subject property to remain secured due to the potential loss of life and property that may result if Deauville is allowed to continually forgo its obligations to secure the structure and the Deauville Beach Resort. E. The City Will Post an Appropriate Bond The City will post a bond in an amount the Court deems proper, as required by Fla. R. Civ. P. 1.610(b);however,only a nominal bond,if any,should be required. WHEREFORE,Plaintiff,The City of Miami Beach,respectfully request that this Honorable Court appoint a receiver that 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;(3)oversee all remediation and repair work required for the Property to comply with§ 118-532 of the City Code;(4)take all required measures to rectify 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 or fines against the Property or Deauville pursuant to the applicable sections of the City Code; and that the Court issue a temporary injunction requiring the Deauville secure the Deauville Beach Resort,together with such further relief deemed necessary and appropriate under the circumstances. Respectfully submitted, RAUL J. AGUILA, CITY ATTORNEY CITY OF MIAMI BEACH 1700 Convention Center Drive, 4th Floor Miami Beach, Florida 33139 Tel: (305) 67/-7/ /Fax:(305)673-7002 By: -� Stev 'o•'stein,Esq, Dept' • Attorney Flo" ar No. 727547 J. fncobson,Esq, Assis • t City Attorney II Florida Bar No. 118276 11 CASE NO.: 19-03653 CA 32 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was electronically filed with the Clerk of the Court using the Florida Courts e-Filing Portal and served upon all interested parties via electronic service generated by the e-Portal system,this 8`h day of March, 2018. 12 EXHIBIT A MIAMIBEACH yr ,y SPECIAL INCIDENT NOTIFICATION OPERATIONS DIVISION INCIDENT: Building Fire (Area 3) DATE: March 6, 2019 TIME: 2100 Hrs. CASE: 2019-21254 LOCATION: 6701 Collins Avenue COMMANDER: Lt. Paul Ozaeta SUPERVISOR: Sgt. Janelle Delgado LEAD OFFICER: Ofc. Brian Rhodes LEAD DETECTIVE: Sgt. Javier Fernandez WHO WAS NOTIFIED: Captain Doce was notified by phone. The remaining Police Command Staff and PIO were notified via this document. DESCRIPTION OF INCIDENT: Fire Department responded to a report of a fire at the Deauville Hotel, which is currently under construction. Two separate trash fires were extinguished upon their arrival. Fire Department cleared building while police units shut down Collins Avenue for approximately one hour. The fire may have possibly been caused by four juveniles that had been arrested for trespassing inside the building approximately three hours earlier. No injuries reported. Case is currently under investigation. Subject(s): TBD Charge(s): TBD Media Inquiries: Freelance videographers observed at scene. CASE SEARCH Print Date/Time: 3/7/2019 2:07:15 PM tri • Lock Case Number Reported Date/Time Reporting Officer Occurred Incident Type Location Assigned Bureau Current Review Level Current==ReviewType Case Status Case Status�Date Disposition ��a= Disposition Date Jurisdiction z False 2019-00021254 03/06/2019 21:00:17 Rhodes, Brian FIRE INVESTIGATION 6701 COLLINS AVE, Miami Beach PROPERTY CRIMES 0 Merged Report OPEN 03/06/2019 0130700 M4 False 2019-00016529 02/21/2019 14:53:42 Llamoca, Ysidro FIELD INTERVIEW 6701 COLLINS AVE, Miami Beach y 0 Merged Report PENDING 02/22/2019 0130700 False 2019-00014103 02/13/2019 18:04:11 Gonzalez, Adrian TRESPASS 6701 COLLINS AVE, Miami Beach M 0 Merged Report PENDING 02/13/2019 0130700 False 2019-00014061 02/13/2019 15:17:03 Pagan, Erick BURGLARY OTHER 6701 COLLINS AVE, Miami Beach BURGLARY 0 Merged Report 1 - CLOSED N/A 02/18/2019 CBA-PATROL 02/18/2019 0130700 False 2019-00010099 02/01/2019 12:01:47 De Las Salas, Sergio THEFT/OTHER 6701 COLLINS AVE, Miami Beach PROPERTY CRIMES 3 ROR Report Reviewed by D/E 1 - CLOSED N/A 02/01/2019 1- NOT ASSIGNED 02/05/2019 0130700 False 2019-00007087 01/22/2019 16:38:39 Pagan, Erick INCIDENT 6701 COLLINS AVE, Miami Beach BURGLARY 3 ROR Report Reviewed by D/E 1 - CLOSED N/A 02/01/2019 1- NOT ASSIGNED 02/01/2019 0130700 False 2018-00114408 11/28/2018 09:25:17 Casas, Reinaldo BURGLARY OTHER 6701 COLLINS AVE, Miami Beach BURGLARY 3 ROR Report Reviewed by D/E 1 - CLOSED N/A 12/10/2018 1- NOT ASSIGNED 12/10/2018 0130700 False 2018-00111117 11/16/2018 05:37:46 Rivera, Brian SUSPICIOUS VEHICLE 6700 COLLINS AVE PARKING LOT, Miami Beach CAU 2 3 ROR Report Reviewed by D/E PENDING 11/16/2018 CBA-PATROL 11/16/2018 0130700 False 2018-00107887 11/05/2018 15:10:14 Taylor, Garfiled TRESPASS WARNING 6701 COLLINS AVE, Miami Beach 3 ROR Report Reviewed by D/E PENDING 11/12/2018 0130700 Total Rows: O IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY,FLORIDA CIRCUIT CIVIL DIVISION CASE NO: 1LCi Mw), Ba,0) Plaintiff(s), vs. r eJ ORDER // GR.A3N-� tvr__r G \-)31%„\iki kstr:fAv) Wl,J �1•�l P T'S Defendant(s), THIS CAUSE having come on to be heard on4L.C$� V�, (1 I1 onaintif '/Defendant's Motion ref ociici Nv a- (-AQn`4`14 4 Re(cti ketol of ails\ -\3(.\,�hJ fil\cma 4 4 ly 5,1P,k6'I 09() � ����6\ and the Court having heard arguments of counsel,and being otherwise advised in the premises,it is hereupon ORDERED AND ADJUDGED that said Motion be,and the same is hereby Plea) b QJN4S Cb Atit. E* 43wvilit cAf Lik Nile 4' 41ity Chiu t 4� 1 �bltJ�, LL 5411 ° 6 I)1\tilt twee c ).56 1'r 9 R'c.�r 71.'36piy1--71,34\01,4 l s� o c.i) 5611 he a1 `�. 1 .�A 5,deceusr)�v4 k ►2 (6) ,LvillCGii eJ 5111►wf,? li I� It � ea,` IC 111' I r ,n V .', I. • �I :41. I. ti 1.11 w, 1141f e GS) ',stIStfS cn of (z)•kiNort SO be akik\ kwic 5 c'155 c)425_) c tP441 C-At Pifmr)- CI\ b616-) S►(ic { 1c .'�/� Ca��j�' tin it le 4i4 me#cf� u# ilv'e. DONE�ND ORDERED m Chambers a' tai�ade . nty,Flonda this d++ bctWP )Ji day of CONFORMED COPY /lard-% , 7 (;1 . • MAR 1 3'1a Maria de Jesus San tovenia • CIRCliIT COURT JUDGE �i.1 . . CIRCUI COI'T_Tr 'E ''itaria ?pydo,43,e(liiit ;.'cr �,r"ej ';;:�3I4�a , Copies furnished to: Counsel of Record /2, 0)44. 7`� 117_01-554 9r11 Cr"- 77 ; Ds. Id(/' 4 I/9A, /11 D '- . SiT�t« a , cfAka-1