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IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT

IN AND FOR BROWARD COUNTY


TIMOTHY "CHAZ"' STEVENS
an individual,
Case No: CACE 13-024010
Plaintiff
Div. 18
vs.
THE CITY OF DEERFIELD BEACH,
a municipal corporation, and
JEAN M. ROBB, in her capacity as Mayor
of Deerfield Beach, and individually,
Defendants.
____________________________ /
Answers to Defendants' Propounded Interrogatories
Plaintiff TIMOTHY "CHAZ" STEVENS hereby serves upon
Defendants his answers to interrogatories:
1. Plaintiff has knowledge of emails sent by Defendant Jean Robb,
during the time period set forth in the complaint, to Mr. Jim Lusk,
Mr. David Eller, or some other person, that discuss either her
support, or lack thereof, for Defendant City's a pproval of a vote
that would effect the land use of property owned by Mr. Eller.
Plaintiff has not been able to gain access to these emails because
they have not been produced pursuant to his public records
request by defendants. However, the persons who have knowledge
of the existence and content of these emails are Mr. Lusk, Mr.
Eller, the Defendant Jean Robb, and possibly other persons known
to Jean Robb.
2. Plaintiff is also aware of emails received by Defendant Jean Robb
during
the time frame as set forth in the complaint which have not been
produced pursuant to that same request. On several occasions
Defendant Jean Robb received emails and lhereaiLer forwarded text
from those emails to other persons after deleting the information
and identity of the person/ source of the text.
Plaintiff is unaware of the original source of the emails, as the
emailsjpublic records have been altered by Defendant Jean Robb.
Additionally, it is also unlmown whether the forwarded text of
those emails reflect the entire email received by Robb.
A random sample of emails where the email sent by Jean Robb
fails to indicate from who it was received is as follows:
From: Mamamayor@comcast. net
To: Jrobb@deeerfield-beach. com
Date: 8/16/2013 4:18:45
Subject: Fwd: THE COST OF DYING????
From: fastfreddy1752@aol.com
To: BPreston@deerfield-beach.com
Sent: Tuesday, August 6, 2013 10:36:56
Subject: RE: THE COST OF DYING????
I, TIMOTHY "CHAZ" STEVENS, hereby swear that the foregoing is
......... '-L-et to the be of my lmowledge.
STATE OF FLORIDA
COUNTY OF BRO\VARD
?c:o..\M
PERSONALLY APPEARED before me on the date signed above, the
undersigned authority, TIMOTHY "CHAZ" STEVENS, who is personally
lmown to me, or who has produced a driver's license as identification
and who being first duly sworn, on oath, deposes and says that the
foregoing is true and correct.

WITNESS my hand and seal at fuaJ2ru-m , Browa:rd County, Florida,
this of December, 2013.
~ : ~
Notary Public
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing
was furnished by electronic mail to counsel for the counsel for the
Defendants, Mr. Stuart Michelson m.a email
smichelson@smichelsonlaw.com this ___ day of December, 2013
Is David A. Frankel
David A. Frankel, Esq.
Fla. Bar Number 7 41779
20 South East 20th Street
Fort Lauderdale, Florida
33316
Phone: 954-557-2244
davidfrankel7@gmail.com
a t
This message sent from a mobile device. Apologies for any typographical , grammatical, or Siri
translation errors.
Begin forwarded message:
From: David Frankel <dayjdfrankeiZ@gmail.com>
Date: December20, .2013 at 11:14:55 EST
To: Chaz Stevens <chaz@zproductions.com>
Subject: Answers to interrogatories
sign and scan back to me. Send back originals j.Jst so I have
David A Frankel, Esq.
Law Offices of David A Frankel, PA
.20 SE 20 Street
Fort Lauderdale, R... 33316
954.557.2244 Cell