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<br />'-'~ <br /> <br />. . .-- __a__ <br /> <br />. t <br /> <br />) <br /> <br />LAW O"",CCS 0'- <br />NOJlKAN ~LINSJ[l; P.A. <br />2815 NOItTHE-'ST 1911T 5T~&ET <br />SUITf.: 508 <br />A".2NTUIlA. F:r.o:alDA 3(.'''80 <br /> <br />"ClEP~ON~t30'1937.242 <br />TElECO~IER 13051937.4261 <br />e-mail: IImpaGatt.net <br /> <br />June 30, 2004 <br /> <br />YlA FACSIMILE ((305) '4'.3113 <br /> <br />Lynn Dannheisser, City Attorney <br />City of Sunny Isles Beach <br />17070 Collins Avcnue, Suite 250 <br />Sunny Isles, Florida 33160 <br /> <br />Rc: City of Sunny Isles Beach v. 18100 Collins Avenue Shopping Center, Ltd., et aI. <br />Miami-Dade County Circuit Court Case No. 03-21419 CA 10 <br /> <br />Dear Lynn: <br /> <br />I am working through resolving the attorney's fees and coSts payable to the property <br />owncr. In order to expedite matters, I have agreed with Brad Gould that the following bills are <br />reasonable and should be paid immediately: <br /> <br />A. Rahenkamp Design Group, Inc. - $1,736.74 <br />B. JMD Engineering, inc. - $1,531.25 <br />C. Everman &. EvemtBIl, Inc. . 5527.90 <br />D. Civil Process Plus, Inc. - $170.00 <br /> <br />Please have the City issue a check, payable to Akerman, Senterfitt, Trust Account with respect to <br />the total of these bills, that is, the amount of$3,965.89. <br /> <br />Ba..c;ed on my discussions with our expert and my evaluation ofthe bills, I have offered to <br />pay a maximum ofSl0,000.OO t~ the property owner's appraiser and $50,000.00 in attorney's <br />fees, subject to an immediate agreement to accept these offers and withdraw of the Motion to <br />Stay Proceedings. Since we must address both the transfer and the stay motions next week, I <br />have advised the property owner's lawyer that these offers must be accepted no later than the <br />close of business on July 1, 2004. <br /> <br />I would like to discuss where we are on these matters by conference call on Friday <br /> <br />~ rj , <br />1. (.. .... <br />