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SIEGEL SIEGEL & WRIGHT

Civil & Criminal Trial Attorneys Commercial & Residential Real Estate Title Insurance
Spencer Bryant Siegel, Esq. Dara S. Siegel, Esq.* Thomas Hill Wright, III, Esq.
* Also Admitted In CA & HI

Telephone: 561.620.8200 Facsimile: 561.620.8225 Toll Free: 888.666.5338

February 3, 2012 VIA ELECTRONIC (hazelc@lauderdalelakes.org) AND U.S. MAIL CERTIFIED/RETURN RECEIPT Mayor Barrington Russell Vice Mayor Edwina Coleman Deputy Vice Mayor Eric L. Haynes Commissioner Benjamin Williams, Sr. Commissioner Gloria Lewis Commissioner Levoyd Williams Commissioner Patricia Hawkins-Williams c/o Hazeline Carson, City Clerk City of Lauderdale Lakes 4300 NW 36th Street | Lauderdale Lakes, FL 33319 Re: Notice of Intent to Sue Regarding Failure to Comply with Florida Public Records Law Dear Commissioners: On behalf of our client, MAOS Media Partners LLC (hereinafter referred to as "The Broward Post"), the purpose of this letter is to notify the Lauderdale Lakes City Commission that it is our opinion that that the Citys excessive fees and delay in producing public records previously requested by our client violates Florida Law. The Broward Post requests that these violations be addressed within 20 calendar days from receipt of this letter. If these violations are not addressed, it is the intent of The Broward Post through this firm to initiate litigation pursuant to Florida Statute 119 and to seek all other remedies available at law, including but not limited to complaints with appropriate agencies. The following requests were met with improper and excessive fee responses which do not comport with the actual time needed to satisfy these request and/or allowable expenses under Florida law:
Royal Palm Tower III 1600 South Dixie Highway, Suite 300 Boca Raton, Florida 33432-7409

1. The charge of $54.07 to acquire electronic copies of all emails from the City Manager, City Attorney, Gary Rogers, and/or elected officials pertaining to the following keywords and sent during the period of Sep/2011 present. Kessler International Michael Kessler Brad Hudson Kessler Report Kessler Audit 2. The charge of $54.07 to acquire electronic copies of all emails from City Manager Jonathan Allen to any outside agency pertaining to the following keywords and sent within the last 60 days. Searching for City Manager jobs Headhunters The City of Savannah, Georgia The EEOC 3. The charge of $173.04 to acquire electronic copies of all emails from any elected official and city staff pertaining to the following keywords and sent within the last 60 days. Black Elected Official BrowardPost.com Broward Post Chaz Stevens Great Caribbean American FBI Gwyn Clarke-Reed Hazel Rogers MAOS MyActsOfSedition.com My Acts Of Sedition Timothy Donnelly 4. The charge of $32.45 to acquire electronic copies of all emails between Jonathan Allen, your office, and the City Attorney regarding the handling of public records requests and sent within the last 60 days. 5. The charge of $358.20 to acquire electronic copies of the following: Since 2007, copies of any/all American Express charge card statements. Since 2007, copies of any/all Walmart charge card statements. Since 2007, copies of any/all Sears charge card statements. Since 2007, copies of any/all Bank Of America debit/charge card statements. Since 2007, copies of any/all Home Depot charge card statements. Since 2007, copies of any/all Sams Club charge card statements. Since 2007, copies of any/all BJs Club charge card statements.

6. The charge of $70.24 to acquire electronic copies of all checks paid from CRA funds greater than $5,000 during the period of 01 JAN 2007 01 JAN 2009. 7. The charge of $99.70 to perform an in-person review of City Manager Jonathan Allen's employment file. 8. The charge of $84.60 to obtain an electronic copy of Finance Director Marie Elianors resume and application. 9. The charge of $776.65 to do an in-person review of the following: All employment files of female subordinates of City Manager Jonathan Allen (including department heads) For the last three years, all travel records of those female subordinates and City Manager Jonathan Allen For the last three years, all salary increases granted to those female subordinates 10. The charge of $180.00 to obtain electronic copies of any HR disciplinary action(s) related to the following: Resulting from any complaint(s) filed by former employee Sue Campbell with regards to possible inappropriate contact between Jonathan Allen and female staffers Filed against former employee Sue Campbell Resulting from any complaint(s) filed by former employee Geri Peterkin with regards to possible inappropriate contact 11. The charge of $86.52 to obtain electronic copies electronic copies of any emails sent from Brady to the City of Lauderdale Lakes which contain any/some/all of the following phrases:

What up blood Jubblies He waxed that Tony Danza Fo' shizzle my nizzle

The Broward Post would welcome the opportunity to work with the Lauderdale Lake City Commission to resolve the issues addressed in this demand. However, should the City fail to resolve these issues in a matter conforming with Florida, and does not respond to this Notice of Intent within 20 days, The Broward Posts has retained this law firm to initiate a lawsuit without further warning against the City for the violations we have indicated. Should you wish to discuss this matter further, please do not hesitate to contact me.

GOVERN YOURSELF ACCORDINGLY.

Siegel Siegel & Wright

_______________________________________ Thomas H. Wright III, Esq.


Cc: client

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