lpr motion to compel - martin county emails 11-25-13

8/13/2019 LPR Motion to Compel - Martin County Emails 11-25-13

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IN THE NINETEENTH JUDICIAL CIRCUIT COURT IN ANDFOR MARTIN COUNTY, FLORIDA

LAKE POINT PHASE I, LLC, andLAKE POINT PHASE II, LLC,Florida limited liability companies,

Plaintiffs,

Case No.: 2013-001321-CAv.

SOUTH FLORIDA WATERMANAGEMENT DISTRICT, apublic corporation of the State ofFlorida, MARTIN COUNTY, apolitical subdivision of the State ofFlorida, and MAGGYHURCHALLA,

Defendants. ____________________________/

PLAINTIFFS' MOTION TO COMPEL PRODUCTION OF

E-MAILS FROM DEFENDANT MARTIN COUNTY

Plaintiffs, Lake Point Phase I, LLC and Lake Point Phase II, LLC (collectively

Point), through their undersigned counsel, move to compel the production of certain e

from Martin County (the County) and to require that the County make a full and com

disclosure of its efforts to obtain such e-mails from each County Commissioner, and st

follows:

Introduction


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be transported to various points throughout South Florida. Among other claims, Lake Poi

sued the County for breach of contract and Defendant Maggy Hurchalla (Ms. Hurchalla

tortious interference.

2. Ms. Hurchalla, a former five-time Martin County commissioner, ha

working aggressively behind the scenes to improperly induce the County to breach the Con

with Lake Point. To date, discovery has revealed that Ms. Hurchalla has surrepti

communicated with various County Commissioners (the Commissioners) by sending mes

to their private e-mail accounts under Ms. Hurchallas code name DEEP Rockpit dir

certain County Commissioners to terminate the Lake Point Contracts. Discussion about th

in which the County should terminate the Contracts with Lake Point is public business b

reasonable test. These communications constitute public records and are discoverablejus

they were made to the Commissioners public e-mail addresses. 1 This Motion is to

the County produce all public records and responsive documents related to Lake Point

require that the County account for its efforts to obtain such e-mails.

The Commissioners Have Used Private E-Mail Addresses to Evade Discovery and Access toPublic Records.

3. Over nine months ago, on February 7, 2013, Lake Point made a public

request to the County for e-mails from several commissioners concerning Lake Poin

Public Records Request). ( Exhibit A ). The Public Records Request sought, in p

communications between you and Maggy Hurchalla. Id. On February 11, 2013,


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- Any and all documents from or to Maggy Hurchalla sent or received sinceDecember 1, 2012. (Request No. 5.)

- Any and all documents from or to Maggy Hurchalla related to the Lake PointRestoration Project. (Request No. 6.)

The County did not object to these requests, and produced documents revealing Ms. Hurch

communications with the Commissioners via their publ ic e-mai l addresses for Mart

4. For example, the County produced an e-mail sent by Ms. Hurchalla on

13, 2013, titled Tues Lake Pt. Agenda item, to the publ ic e-mail addresses

County Commissioners regarding the upcoming January 15, 2013 County board meeting a

(the January 13th Public E-mail) ( Exhibit C ). In the January 13th Public E

Hurchalla chose her words carefully, stating: I know that it is very hard to look a gift ho

the mouth, but I would strongly advise that you take [the Lake Point Restoration Project] o

agenda until you know what you are getting into. Exhibit C . 2

5. Unbeknownst to Lake Point, Ms. Hurchalla had sent an e-mail the day bef

January 12, 2013, to Commissioner Ed Fieldings pri vate e-mail account , discuss

January 15th meeting (the January 12th Private E-mail) ( Exhibit E ). In co

January 13th Public E-mail, Ms. Hurchalla holds nothing back about Lake Point

communication to Commissioner Fielding using his pri vate e-mail .

6. In the January 12th Private E-mail, Ms. Hurchalla directs Commissioner F

to ask staff to bring back an agenda item terminating the Interlocal [A]greement,

up a meeting to legally void that contract , and to Get the contr act cancell ed and


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to come back. Id. (emphasis added). Ms. Hurchalla even gives a roadmap to Comm

Fielding on how to pit one Commissioner against another during a public hearing regarding

Point:

Avoid discussion of other issues. Dont complicate things. Just set up a meeting tolegally void that contract.

***Dont issue any cease and desist order on the mining. Get the contract cancelledand wait for staff to come back. Doug [Commissioner Smith] will scream that youare missing an opportunity to save the river and giving up money due the county.Engineering will back him up. Donaldson is Dougs man.

(Exhibit E). At the January 15, 2013 public hearing, Commissioner Fielding follow

Hurchallas direction by: (1) moving to postpone the hearing; (2) directing the County st

prepare a termination document; and (3) asking that the staff not take any actions other t

come back at the next meeting to get the contracts canceled. Commissioner Fielding d

disclose Ms. Hurchallas e-mail on the record at that time.

7. The County did not produce the January 12th Private E-mail until N

2013, and only then after repeated requests by Lake Point that the County investigate the

personal e-mail accounts for the use of public business related to Lake Point. In sum, this e

was (1) not disclosed in a public meeting; (2) not available on the Countys public r

website; 3 (3) not produced in response to the Public Records Request Lake Point made ov

months ago; (4) not produced in response to Lake Points request for production; and (

produced by Ms. Hurchalla. In all respects, Lake Points efforts to uncover all efforts b

County and Ms. Hurchalla to cancel and interfere with the Contracts have been thwarted.


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The County Should Be Required Under Oath to Account for All of the Requested E-Mails

8. It appears from the limited production to date that Ms. Hurchalla h

communicating with individual Commissioners about Lake Point using private e-mail add

over an extended period of time. It is certainly a reasonable inference based upon the lim

mails produced to date that Ms. Hurchalla had similar communications with

Commissioners on their private e-mail addresses like the January 12th Private E-mail; in

Ms. Hurchalla has produced some e-mails related to Lake Point that she had s

Commissioner Sarah Heards private e-mail account. No e-mails to or from any

commissioners private e-mail accounts, however, have been produced. 4 The Coun

required to account for all e-mails sent to/from the private e-mail addresses of its Commi

with Ms. Hurchalla relating to Lake Point, and to produce all such e-mails. Further, giv

obvious attempted evasion by the Commissioners of public records requirements, the C

should be required to explain under oath what methodology it has used to search the vari

mail accounts of Martin County Commissioners for e-mails pertaining to Lake Point.

9. Because the County acts through its Commissioners, the County has th

right to the requested documents from the individual Commissioners, as they pertain to C

business, rather than the Commissioners personal lives. See Rosie D. v. Romney ,

2d 115 (D. Mass. 2003) (concept of control exists, among other circumstances, where

has a legal right to obtain documents). Consequently, the County certainly has the re


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Florida courts have specifically required county commissioners to participate in the disc

process in which their counties are involved. See e.g., Hillsborough Co. v. Pinellas Co

2d 1196, 1197 (Fla. 2d DCA 1983) (denying a countys motion for protective order to pre

the depositions of each of the countys board of county commissioners).

WHEREFORE , Lake Point respectfully requests that this Court enter an O

accordance with this Motion, and provide Lake Point such other and further relief as approp

CERTIFICATE OF GOOD FAITH

Pursuant to Local Rule 5(c), the undersigned has attempted to resolve this dispute wCourt intervention through several written communications and telephone calls, but hasunsuccessful.

s/ Ethan J. LoebETHAN J. LOEBFlorida Bar Number [email protected] [email protected] JON P. TASSOFlorida Bar Number 0120510

[email protected]

[email protected] SMOLKER, BARTLETT, SCHLOSSER,LOEB & HINDS, P.A.500 East Kennedy Blvd, Suite 200Tampa, Florida 33602(813) 223-3888; Fax: (813) 228-6422

andDAN BISHOP

Texas Bar 02348500; Florida Pro Hac [email protected] [email protected] CHRISTINA CARLSON DODDSTexas Bar 03813520; Florida Pro Hac [email protected]


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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and foregoing copy has been served via electronito David A. Acton, Senior Assistant County Attorney, Martin County, DActon@[email protected] , 2401 SE Monterey Road, Stuart, Florida; and Jeff Collier,

[email protected] and Edward Arteau, Esquire, [email protected] , South FManagement District, [email protected] , [email protected] , 3301 Gun Club Palm Beach, Florida 33406-3007; Virginia P. Sherlock, Littman, Sherlock & Heims,[email protected] , Post Office Box 1197, Stuart, Florida 34995; Andrew Esquire, [email protected] ; [email protected] and Cristina P. [email protected] , Trey White, Esquire, [email protected] , The Rock1760 Fennell Street, Maitland, Florida 32751; John J. Fumero, Esquire, jfumero@[email protected] , Thomas F. Mullin, Esquire, [email protected] and Fumero, LLP, 7700 Congress Avenue, Suite 2201, Boca Raton, Florida 3and John L. Wharton, Esquire, [email protected] , [email protected] , Sundstr& Fumero, LLP, 2548 Blairstone Pines Drive, Tallahassee, Florida 32301 this 25th d

November, 2013.

/s/ Ethan J. LoebETHAN J. LOEBFlorida Bar Number 0668338


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BEFORE THE BOARD OF COUNTY CO:MMISSIONERSMARTIN COUNTY, FLORIDA

RESOLUTION NO. 08-8.11

A RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS


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A RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERSMARTIN COUNTY, FLORIDA APPROVING THE SOUTH FLORIDA WAT

MANAGEMENT DISTRICT S ACQUlSmON AND DEVELOPMENTACRE:t: PUBLIC STORMWATER MANAGEMENT PROJECT IN M

COUNTY

WHEREAS, under the Northern Everglades and Estuaries Protection Prothe South Florida Water Management District (the District ) has identified the needstonnwater management and water quality treatment areas; and

WHEREAS, the proposed St. Lucie River Watershed Protection Plancomponent of the Northern Everglades and Estuaries Protection Program: and

WHEREAS, the 2266 / acres Lake Point Project (the Property ) iproposed St. Lucie River Watershed Protection Plan conceptual boundary and is loc

s depicted on attached Exhibit A ; and

WHEREAS, the District has detennined that the Property's location. conto the C-44/St. Lucie canal with a pennitted discharge easement to Lake Okeechoand the ability to discharge south through the L-8 right-of-way extension. lends itsephosphorous reduction and water treatment and transfer possibilities; and

WHEREAS, the District has entered into a Letter of Intent with thowner to acquire and develop the Property into a stonnwater management unfacility, including approximately 1,600 acres of water quality and treatment ar

. Public Works Facility ); and

WHEREAS, the Public Works Facility will provide a mechanism to hannful freshwater discharges away from the St. Lucie Estuary; and

WHEREAS, fee title to the Property. subject to a twenty (20) year reser

by the owner of mineral rights beneath the 1.000 acres intended [ be mined,Exhibit B , will be conveyed to the District pursuant to a proposed agreement betwthe property owner and the District; and

WHEREAS, approximately 150 acres ~ of land adjacent to State Roadepicted on Exhibit B ) will be donated to Martin County as a public recreati(lbe Recreation Area ), together with an interest n the Property which may fonn of an undivided interest or a conservation easement; and

WHEREAS, additionally, the Property owner has agreed with the District


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, y, p y gan environmental enhancement contribution to Martin County for use inconservation and environmental enhancement programs as Martin County detennine from time to time, equal to five cents ($0.05) per yard of material hathe Property. This environmental contribution will be in addition any other fee reunder Martin County's Land Development Regulations; and

WHEREAS, until the issuance of all necessary pennits for constructPublic Works Facility, the owner of the Property will continue to operate u

~ i s t i n gMajor Development Approval (County Resolution Nos. 07-5.14 dated M2007 and 0712.22 dated December 18,2007) for the Lake Point Ranches Project

WHEREAS, the District has assured the County that construction and opof the Public Works Facility will comply with the County's Excavation andMining Land Development Regulations. but in no event will the lakes be excavutedepth in excess of twenty (20) feet from the control water level. (which level wexceed five (5) foot below natural grade); and

W H E R E S ~the Public Works Facility, as described above, qualifiesexempt public stormwater management project pursuant to Section 1O.1.E.2.eLand Development Regulations.

W H E R E S ~Martin County shall not be required to contribute any fund

District's Public Works Facility; and

WHEREAS, Manin Coumy supports the proposed Public Works Facdescribed above.

NOW, THEREFORE, be it l esolved by the Board of County Commof Martin County, Florida, that:

1. The foregoing recitals are true and correct and incorporated inResolution.

2. Simultaneous with the execution of the agreement between the owner and the District the District and the County shall enter into an agr

cemetery sites located on the south side of SR76 adjacent to the northeast comeproperty. The location and size of said easement shall be acceptable to the Pahokee; and

3. The agreement between the District and County shall also provide fofee title to reven to the entity that conveys the Property to the District in the ev


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y y p ysuch entity is not able to timely obtain or able to maintain the penn ts andnecessary to mine and to construct the Public Works Facility s may be contethe agreement between the Property owner and the District.

4. This resolution is neither a development order nor an agreemenDistrict or the Property owner nor does it create any vested rights for the benefitDistrict or the Property owner.

DUL Y PASSED AND ADOPTED TIDS 2 t h DAY OF AUGUST 20

ATTEST: BOARD OF COUNTY COMMISSIMARTIN COUNTY FLORIDA

~ ~ n

IIF

Lake Okeechobee and stuary Recovery Project


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'

or.

. ~ ii ~ I 1 _

EXHI IT "'S"

LAND ACQUISITION EXECUTIVE SUMMARY

PROJECT: t Lucie River Watershed Protection Program


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COUNTY:

SIZE:

ACQUISITION PRICE:,

APPRAaSED VALUE:OWNI R:

REQUEST:

HIGHLIGHTS:

Martin

2266 +/. acres

Donation

53,500,000 (1212006)l ake Pointe Phase 1 LLC.Rusbridge Family Trust, Harold D. Rusbridge. TrusteeGeorge Undemann, Sr.Frayda UndemannAdam LindemannGeorge Undernann, Jr.Francis Judson Lalrd,IV

Authorize enby Into an agreement for donationconstructIOn services to the South Florida WaterDistrict

Creation of stormwater treabnent area and management lake fronting o C-44 Canal with permeasement to Lake Okeechobee and l 8 right of wallowing for connection to Loxahatchee River and Reservoir

CONSIDEM TIONa: The 2266 sere subject tract Is located in Martin County witbOundary fronting on the C-44/St. Lucie Canal while its eastern boundary Is adjacSFWMO owned 21,875 acre DUPUiS Management Area. see Exhibit A)

The property's location, adjacent to C-44 with a permitted discharge easemenOkeechobee and the L-8 right of way extension on its southwestern boundaryIntegral part in phosphorous reduction and water storage possibilities for the stWatershed Protection Program.

Approximately 1,000 acres of the property is currently fully permitted by all agprivete polo development with 44 ranchette sites, a polo field already constructedmining operation en.;ompessing approximately 160 acres. The owner has an optiothe project to approximately 100 homes by exercising an option to buy tJie add

Donation of approximately 2,200 acres to the District with the retention byrock mining rights under approximately 1.000 acres for approximately 2 ye

1.000 acres mined und er Martin County permit and, in accordance with Distri cstormwater manegement 8 ~ erequirements, to maximum depth of 20 feeexpense


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expense

Approximately 600 acres to b e utilized as stormwater treatment areas construOwner's expense In conformance with District specifications

Approximately 15 acres in the northeastem uplands comer of the propertythe M to be donated to Martin County for use s a recreational site

Previously, In April 2008, the Gov8ming Board approved entering Into a non-bindInintent regarding this donation transaction. At that time, the Board requested thfeasibility analysis be perform8d to ensure the viability of the intended projectdonated property as a 1000 acre stonnwater management lake and 6 acrtreatment area .

The feasibility team has run various modeling scenarios balancing treatment withavanability to provide a range of environmental benefits through phosphorus load

delivery of water to the Loxahatchee River. Thes8 benefits are being quantified with the cconstruction and operating the facility to determine the costlbenefit of the project

The initial results appear to indicate that the facility has the potential to captureadditi onal -excess' basin wate r and make it available for other water related needssame Ume providing flexibility to function as a kidney for the treatment of Lakewater. Pr1Illmlna,y analysis shows a measured e n ~ tin three different directOkeechobee, t h e l - 8 and st. Lucie Estuary. The final analysIs will be presentedBoard at the August meeting.

The benefits of this donation and construction proposal include:

Ability to cleanse, store and convey water between Lake Okeechobee, C-44/SCanal and the L-8 via 3 existing permitted pumps

Creation o 1 600 acres of storage and w ater quality sites

O land acquisition cost for the land with substantial amount of the project completed upon delivery of excavated portions of the property

Opportunity to reduoe the Total Maximum Daily Load (TMDL) to Lake Okeechobee

50 acres of recreational upland acres to Martfn County

TIming is critical. The Owner must exercise its option to acquire the remaining 1ugust 14 2008.

FISCAL IMPACT: No monetary cost for land acquisition with substantial amouearthwol1c for the stormwater management lake and stormwater treatment area being by the Owner


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by the Owner.

RECOMMI NDAnON: That the Governing Board of the South Florida WaterDistrict aU1hortz8 eritry into an acquisition agreement for donation to the South FManagement District of 2266 - -/. acres in Martin County and construction of substcomponents at no cost to the Dis trict for the t Lucie River Watershed Protection Pro

P ~ p e ~ b y______ ________ ______ ___Ruth P Clements, DirectorLand Acquisition Department

Approvedby: ____Kenneth G. Ammon, P.E.Deputy Exeeutlve DirectorEverglades Restoration Resource Area

D

D


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From: Maggy HurchallaTo: Sarah Heard

; Doug Smith ; John Haddox

; Anne Scott ; Taryn Kryzda

; Ed FieldingSubject: Tues Lake Pt. Agenda itemDate: Sunday, January 13, 2013 10:48:27 PM

Dear Commissioners,

You have another agenda item on the Lake Point rockpits on Tuesday.The handling of the project continues to be very strange.Did the staff just read the contract for the first time?

I know that it is very hard to look a gift horse in the mouth, but I would strongly advise that you taitem off the agenda until you know what you are getting into.Lake Point is asking you to acknowledge that the violations that happened in 2012 weren't really vibecause they were acting under the mining permit rather than the County approval.

If you accept the payment that is being offerred you may be causing the County some serious probarising from the fact that the Interlocal agreement with the SFWMD appears to be based on a clearviolation of the Martin County Comp Plan. You may be absolving the owner of all of the violationshave occurred under the County permit by accepting the assertion that last year he was NOT actingthe county permit.
mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]


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The owner's attorney appears to believe that rescinding the County approvals and transferring the pto management by the SFWEMD will exempt the project from the requirements of the Martin CouComprehensive Plan.I don't think you can or should let that happen.

The project's attorney asks that you accept the payment and recognize that in 2012 they were operunder the mining permit. The mining permit allows 60 acres of wetlands to be destroyed.

The Interlocal agreement states that the project is exempt for the process required for developmentas per 10.1.E.2.e of the LDRs. That section of the code specifically states that it MUST FOLLOW COMPREHENSIVE PLAN POLICIES.

"The provisions of section 10.1 .E.2. shall not waive any requirement of the ComprehensivePlan, the Land Development Regulations, or the Code other than the procedures for development review set forth in sections 10.2 through 10.7 ,10.9 , and 10.11 through

It does NOT qualify for exemption from comp plan polices under 9.1.G.1.(7)(g)

"Policy 9.1 G.1. Protection of wetlands. All wetlands in Martin County shall be protected.

Negative impacts shall not be allowed in wetlands or within the buffer surrounding the wetland. All development shall be consistent with the wetland protection requirements of the CGMP and

Everglades Restoration Plan in any part of Martin County"

THIS IS NOT A CERP PROJECT. IF THE COUNTY WAS TOLD IT WAS, THEN THE AGREEMENT WAS BASED ON FALSE INFORMATION.

It does not qualify for exemption under Obj. 14.1.E.

You have a mess on your hands and for reasons I don't understand your staff seems unwilling to deal

with the problem.Before taking any other action, the faulty Interlocal agreement needs to be corrected or voided.

Sincerely,

Maggy Hurchalla
http://library.municode.com/HTML/13592/level2/LADERE_ART10DEREPR.html#LADERE_ART10DEREPR_S10.1GEhttp://library.municode.com/HTML/13592/level2/LADERE_ART10DEREPR.html#LADERE_ART10DEREPR_S10.1GEhttp://library.municode.com/HTML/13592/level2/LADERE_ART10DEREPR.html#LADERE_ART10DEREPR_S10.2APPRhttp://library.municode.com/HTML/13592/level2/LADERE_ART10DEREPR.html#LADERE_ART10DEREPR_S10.7PRPUMEHEhttp://library.municode.com/HTML/13592/level2/LADERE_ART10DEREPR.html#LADERE_ART10DEREPR_S10.9POPRPRhttp://library.municode.com/HTML/13592/level2/LADERE_ART10DEREPR.html#LADERE_ART10DEREPR_S10.11REDEPLhttp://library.municode.com/HTML/13591/level2/COGRMAPL_CH9COOPSPEL.html#COGRMAPL_CH9COOPSPEL_S9.1BAhttp://library.municode.com/HTML/13591/level2/COGRMAPL_CH9COOPSPEL.html#COGRMAPL_CH9COOPSPEL_S9.1BAhttp://library.municode.com/HTML/13592/level2/LADERE_ART10DEREPR.html#LADERE_ART10DEREPR_S10.11REDEPLhttp://library.municode.com/HTML/13592/level2/LADERE_ART10DEREPR.html#LADERE_ART10DEREPR_S10.11REDEPLhttp://library.municode.com/HTML/13592/level2/LADERE_ART10DEREPR.html#LADERE_ART10DEREPR_S10.9POPRPRhttp://library.municode.com/HTML/13592/level2/LADERE_ART10DEREPR.html#LADERE_ART10DEREPR_S10.7PRPUMEHEhttp://library.municode.com/HTML/13592/level2/LADERE_ART10DEREPR.html#LADERE_ART10DEREPR_S10.7PRPUMEHEhttp://library.municode.com/HTML/13592/level2/LADERE_ART10DEREPR.html#LADERE_ART10DEREPR_S10.2APPRhttp://library.municode.com/HTML/13592/level2/LADERE_ART10DEREPR.html#LADERE_ART10DEREPR_S10.2APPRhttp://library.municode.com/HTML/13592/level2/LADERE_ART10DEREPR.html#LADERE_ART10DEREPR_S10.1GEhttp://library.municode.com/HTML/13592/level2/LADERE_ART10DEREPR.html#LADERE_ART10DEREPR_S10.1GE


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1 I N THE NI NETEENTH J UDI CI AL CI RCUI T COURT I N AND FOR MARTI N COUNTY, FLORI DA 2 CASE NO: 2013- 001321- CA 3

4 LAKE POI NT PHASE I , LLC, and LAKE POI NT 5 PHASE I I , LLC, Fl or i da l i mi t ed l i abi l i t y compani es, 6 Pl ai nt i f f s, 7 vs.

8 SOUTH FLORI DA WATER MANAGEMENT DI STRI CT, a publ i c cor por at i on of t he St at e of 9 Fl or i da; MARTI N COUNTY, a pol i t i cal subdi vi si on of t he St at e of Fl or i da;10 and MAGGY HURCHALLA,

MAGGY HURCHALLA Volume I

LAKE POINT vs. SOUTH FLORIDA

OctoMAGGY HURCHALLA Volume I


Octo


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11 Def endant s.12 ________________________________________/

13

14

15 VI DEOTAPED DEPOSI TI ON OF

16 MAGGY HURCHALLA

17 TAKEN ON BEHALF OF THE PLAI NTI FFS

18 VOLUME I - PAGES 1 - 104

19

20 Wednesday, Oct ober 30, 2013

21 10: 24 a. m. - 4: 45 p. m.

1 A. That ' s cor r ect .

2 Q. Al l r i ght . And i t l ooks l i ke a ser i es of

3 e- mai l s and ar t i cl es t hat wer e compi l ed?

4 A. Compi l ed? 5 Q. Yeah, because t hey appear t o al l - - i t l ooks

6 l i ke someone t ook and cut and past ed some ar t i cl es and

7 some e- mai l s i nt o t hi s.

8 A. I went t hr ough my e- mai l s - -

9 MR. WHI TE: Obj ect t o f or m.

10 THE WI TNESS: - - and I sear ched f or Lake

MAGGY HURCHALLA Volume I


OctoMAGGY HURCHALLA Volume I


Octo


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11 Poi nt .

12 BY MR. BI SHOP:

13 Q. Okay. And t hi s i s what came up?

14 A. Yes.

15 Q. And so, how exact l y was t hi s put t oget her and

16 pr i nt ed out ; I mean, j ust t he way t hat you t al ked about ?

17 A. Yeah.

18 Q. Okay. You di d a sear ch f or Lake Poi nt ?

19 A. Fi r s t , I s tar t ed t r yi ng pas t i ng t hem

20 t oget her .

21 Q. Okay.


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EXHIBIT "E"

lpr motion to compel - martin county emails 11-25-13

Documents