Stern vs. Miami - Exhibit List

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    EXHIBIT A

    Filing # 34681324 E-Filed 11/19/2015 04:27:50 PM

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    Photo:DefendantXavierAlb

    anrecordingPlaintiffspublicrecords

    requeston

    September3,

    2015.

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    Screenshot of Foursquare check in to Miami Riverside Center on September 14, 2015

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    Screenshot of Foursquare check in to Miami City Hall on September 14, 2015

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    EXHIBIT B

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    Walmart Request

    PublicRecords Fri, Sep 18, 2015 at 5:18 PTo: Grant Stern Cc: "Alban, Xavier E." , PublicRecords

    Good afternoon,

    Below is the criteria IT has developed based on your public records request. The cost of the search is $112.05. Pleasereview the search criteria below and advise if it is acceptable. If you would like to add additional search terms, pleaselet us know so that it can be updated and we can provide you with the updated cost. If the criteria is acceptable,please follow the payment instructions below so that your request may be processed.

    If you have any questions, please do not hesitate to contact us. Thank you.

    ===========================================================================

    The total cost to run the queries to retrieve emails which fit suggested criteria below, to create Outlook PST files withquerys output and to save the output to a media (CD, DVD or hard disk depending on the volume) is $112.05. Theelectronic media to save the data is included in the estimate.

    The process to create the storage media will take approximately 4 business days after receiving the approval andpayment. The costs includes searches for Civilian mailboxes. Police mailboxes are not included.

    If the request is related to a law matter case or may include any other exempted emails then a review of the resultsmay be required before being released and this may add more delivery time and cost.

    If the suggested criteria and estimate are accepted, a payment for the quantity above needs to be made to City of

    Miami and delivered to Ms. Latanya Johnson at 444 SW 2ndAvenue, cubicle 515, Miami, FL 33130. Payment can bedone in check or cash.

    Results are based on suggested criteria and may contain emails not related to requestors desire. If the requestors arenot agreed with suggested criteria, they can change it before making the payment. Once the payment is received andthe query is executed, a change in criteria may require additional charges

    Suggested Criteria:

    Search 1:

    Criteria Type Search criteria

    Start Date 10/15/14

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    End Date 12/4/14

    To or From [email protected]

    Key words / Phrases Walmart

    OR

    "3155 N. Miami Ave" AND zoning

    OR

    "3155 N. Miami Avenue" AND zoning

    OR

    "3155 North Miami Ave" AND zoning

    OR

    "3155 North Miami Avenue" AND zoning

    OR

    "3155 N. Miami Ave" AND referral

    OR

    "3155 N. Miami Avenue" AND referral

    OR

    "3155 North Miami Ave" AND referral

    OR

    "3155 North Miami Avenue" AND referral

    Search 2:

    Criteria Type Search criteria

    Start Date 10/15/14

    To or End Date 12/4/14

    From [email protected]

    Key words / Phrases Walmart

    OR

    mailto:[email protected]:[email protected]
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    "3155 N. Miami Ave" AND zoning

    OR

    "3155 N. Miami Avenue" AND zoning

    OR

    "3155 North Miami Ave" AND zoning

    OR

    "3155 North Miami Avenue" AND zoning

    OR

    "3155 N. Miami Ave" AND referral

    OR

    "3155 N. Miami Avenue" AND referral

    OR

    "3155 North Miami Ave" AND referral

    OR

    "3155 North Miami Avenue" AND referral

    Requestor Criteria:

    Good evening,

    We received the following public records request in person today. Please process this as soon as possible. Therequestor has informed me that they need to file an appeal by Wednesday, September 23, 2015. Please provide anestimate as soon as possible. The criteria are as follows:

    Search 1:

    All emails to or from: Francisco Garcia

    Time Frame: Oct. 15, 2014 Dec. 4, 2014

    Search Criteria:

    Walmart

    or

    3155 N. Miami Ave and zoning

    Or

    3155 N. Miami Avenue and zoning

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    Or

    3155 North Miami Ave and zoning

    Or

    3155 North Miami Avenue and zoning

    or

    3155 N. Miami Ave and referral

    Or

    3155 N. Miami Avenue and referral

    Or

    3155 North Miami Ave and referral

    Or

    3155 North Miami Avenue and referral

    Search 2:

    All emails to or from: Irene Hegedus

    Time Frame: Oct. 15, 2014 Dec. 4, 2014

    Search Criteria:

    Walmart

    or

    3155 N. Miami Ave and zoning

    Or

    3155 N. Miami Avenue and zoning

    Or

    3155 North Miami Ave and zoning

    Or

    3155 North Miami Avenue and zoningor

    3155 N. Miami Ave and referral

    Or

    3155 N. Miami Avenue and referral

    Or

    3155 North Miami Ave and referral

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    Or

    3155 North Miami Avenue and referral

    ==========================================================

    Xavier E. Albn, Esq.

    Public Records Coordinator

    City of Miami Office of the CityAttorney

    Telephone: 305-416-1830

    Facsimile: 305-416-1801

    [email protected]

    [email protected]

    DISCLAIMER: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contai

    legally privileged and confidential information. If you properly received this e-mail as a client or retained expert, please hold it i

    confidence to protect the attorney-client or work product privileges. Should the intended recipient forward or disclose thi

    message to another person or party, that action could constitute a waiver of the attorney-client privilege. If the reader of thi

    message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified

    that any review, dissemination, distribution or copying of this communication is prohibited by the sender and to do so migh

    constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this communication wa

    received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing i

    this e-mail message shall, in and of itself, create an attorney-client relationship with the sender. Under Florida Law, e-ma

    addresses and the contents of the e-mail are public records. If you do not want your e-mail address, or the contents o

    the e-mail, released in response to a public records request, do not send electronic mail to this entity. Instead, contac

    this office by phone or in writing.

    Please consider the environment before printing this e-mail.

    From:Grant Stern [mailto:[email protected]]Sent:Friday, September 18, 2015 1:43 PM

    To:Alban, Xavier E.

    Subject:Walmart Request

    [Quoted text hidden]

    mailto:[email protected]:[email protected]:[email protected]
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    EXHIBIT C

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    Walmart Request

    Grant Stern Fri, Sep 18, 2015 at 5:58To: PublicRecords Cc: "Alban, Xavier E."

    Hey Xavier,

    I believe that the project is actually 3055 N. Miami Avenue.

    Also, can you please email me the portion which I viewed at your office earlier today now.

    Thank you,

    Grant

    [Quoted text hidden]

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    EXHIBIT D

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    Screenshotofdigitalfilefold

    erprovidedbytheCityofMiamiinre

    sponsetoPlaintiffs

    publicrecordsrequest

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    EXHIBIT E

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    Screenshot of public records request in City of Miamis online records request database

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    EXHIBIT F

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    Walmart Request

    PublicRecords Mon, Sep 21, 2015 at 9:06 ATo: Grant Stern Cc: PublicRecords , "Alban, Xavier E."

    !""# %"&'(')*

    +,- ./-0 1"2 &-3(-4-# 5&(#61 4-&- 27/"6#-# /68-& 8,68 06%- #61 6'# 1"2 0,"2/# ,63- &-9-(3-# 6 /(': 8" 699-00

    8,- ./-0; < 6% ('9/2#(') 8,- /(': ,-&- '"4;

    https://miami.nextrequest.com/requests/15-165

    < 4(// ,63- 8,- 6##&-00 9"&&-98-# 8" =>?? @; A(6%( B3- (' 8,-

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    Please consider the environment before printing this e-mail.

    From:Grant Stern [mailto:[email protected]]

    Sent:Friday, September 18, 2015 5:58 PM

    To:PublicRecords

    Cc:Alban, Xavier E.

    Subject:Re: Walmart Request

    [Quoted text hidden]

    mailto:[email protected]
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    EXHIBIT G

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    Walmart Request

    Grant Stern Mon, Sep 21, 2015 at 9:26 ATo: PublicRecords Cc: "Alban, Xavier E."

    We did get it! I didn't see any of the City Commission (or PZAB) resolutions or court opinions in the file. Shouldn'tthose be a part of the file since the matter went to commission?

    Thanks

    Grant[Quoted text hidden]

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    EXHIBIT H

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    Walmart Request

    PublicRecords Mon, Sep 21, 2015 at 10:01 ATo: Grant Stern Cc: PublicRecords , "Alban, Xavier E."

    ! #$%% &'%%'# () #$*+ ,-./$01 2'./34 #+' #'(%3 +.5- *+- 6%-7 8+-9 #-/- :'0*.:*-3 %.4* #--;7

    Xavier E. Albn, Esq.

    Public Records Coordinator

    City of Miami Office of the CityAttorney

    Telephone: 305-416-1830

    Facsimile: 305-416-1801

    [email protected]

    [email protected]

    DISCLAIMER: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain

    legally privileged and confidential information. If you properly received this e-mail as a client or retained expert, please hold it i

    confidence to protect the attorney-client or work product privileges. Should the intended recipient forward or disclose thi

    message to another person or party, that action could constitute a waiver of the attorney-client privilege. If the reader of thi

    message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified

    that any review, dissemination, distribution or copying of this communication is prohibited by the sender and to do so migh

    constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this communication wa

    received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing ithis e-mail message shall, in and of itself, create an attorney-client relationship with the sender. Under Florida Law, e-ma

    addresses and the contents of the e-mail are public records. If you do not want your e-mail address, or the contents o

    the e-mail, released in response to a public records request, do not send electronic mail to this entity. Instead, contac

    this office by phone or in writing.

    Please consider the environment before printing this e-mail.

    From:Grant Stern [mailto:[email protected]]

    Sent:Monday, September 21, 2015 9:26 AM

    [Quoted text hidden]

    [Quoted text hidden]

    mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]
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    EXHIBIT J

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    EXHIBIT K

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    Docket at the Third District Court of Appeal in Pfeffer v. Wal-mart, City of Miami, et al

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    EXHIBIT L

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    EXHIBIT M

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    EXHIBIT N

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