Shillinger-Bob. Dear Mr. Morris,

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Bartholomew Walsh
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2 Shillinger-Bob From: Sent: To: Cc: Subject: Morris-Peter Tuesday, June 30, :09 PM Shillinger-Bob Bradley-Brian FW: For Settlement Purposes Only From: Michael Corey Sent: Friday, June 26, :27 AM To: Morris-Peter Dear Mr. Morris, My client, Marine Mammal Conservancy ( MMC ), has confirmed a global settlement offer. In exchange for a release of the code enforcement liens on the subject Property under Monroe County Code Enforcement Case No. CE and Monroe County Code Enforcement Case No. CE (collectively the Liens ) and, the two Final Judgments of Foreclosure in the County s possession which are the subject of the lawsuit styled Denenberg v. Marine Mammal Conservancy, Inc., et al., Monroe County Circuit Court Case No. 14-CA A 001PK (collectively the Final Judgments ), MMC will pay the County the following amounts to Monroe County within 180 days of the date a Settlement Agreement is signed: (1) $70,000 on the Liens; and (2) the full amount of the Final Judgments plus statutory interest calculated to the date the parties sign the written Settlement Agreement. I hope the County will seriously consider this offer. Please let me know if the item can still be added to the Monroe County Board of County Commissioner s (the Board ) July 15, 2015 meeting agenda for consideration of MMC s proposal. A representative of MMC will be present at the meeting to present our proposal to the Board and request that the Board accept the proposal in exchange for releasing the Liens. Again, I appreciate the County s consideration of our mitigation request. If you need any additional information from me or I need to do anything else to get the item on the Board s July 15 th agenda, please let me know. Sincerely, Michael Michael James Corey Partner Obront Corey, PLLC Southeast Financial Center 200 South Biscayne Boulevard, Suite 2940 Miami, Florida Telephone: Facsimile: Cellular: mcorey@obrontcorey.com NOTICE: This message is from the law offices of Obront Corey, PLLC. The information contained in this electronic mail transmission and any attachments may contain privileged or confidential information and may 1

3 be protected by legal privilege. This message is intended only for the individual or entity to which it is directed. If you are not the addressee, or if this message has been addressed to you in error, you are not authorized to use, read, copy or distribute this message and any attachments, and we ask that you please immediately delete this message and attachments (including all copies), and notify the sender by return or telephone at so that our records can be corrected. Delivery of this message and any attachments to any person other than the intended recipient(s) is not intended in any way to waive confidentiality or privilege. All personal messages express views only of the sender, which are not to be attributed to the law offices of Obront Corey, PLLC and may not be distributed or copied without this statement. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code, or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. From: Michael Corey Sent: Thursday, June 25, :35 PM To: 'Morris Peter' Understood. I am trying to work that out now. Michael Michael James Corey Partner Obront Corey, PLLC Southeast Financial Center 200 South Biscayne Boulevard, Suite 2940 Miami, Florida Telephone: Facsimile:

4 Cellular: NOTICE: This message is from the law offices of Obront Corey, PLLC. The information contained in this electronic mail transmission and any attachments may contain privileged or confidential information and may be protected by legal privilege. This message is intended only for the individual or entity to which it is directed. If you are not the addressee, or if this message has been addressed to you in error, you are not authorized to use, read, copy or distribute this message and any attachments, and we ask that you please immediately delete this message and attachments (including all copies), and notify the sender by return or telephone at so that our records can be corrected. Delivery of this message and any attachments to any person other than the intended recipient(s) is not intended in any way to waive confidentiality or privilege. All personal messages express views only of the sender, which are not to be attributed to the law offices of Obront Corey, PLLC and may not be distributed or copied without this statement. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code, or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. From: Morris Peter [mailto:morris FL.Gov] Sent: Thursday, June 25, :30 PM To: Michael Corey Mr. Corey, As a corollary, if your client has a global settlement offer to make, it should also be made now. Thank you, 3

5 Peter Morris Assistant County Attorney Monroe County Attorney's Office th Street, Suite 408 Key West, FL (305) (305) (fax) Please note that Florida has a broad public records law and that any communication with the County could be considered a public record. If you do not wish for your address to become a public record, use the telephone or some other method of conveying your message. From: Morris-Peter Sent: Thursday, June 25, :07 PM To: 'Michael Corey' Mr. Corey, In my opinion, it is not in our client s best interest to entertain a partial settlement offer that fails to secure payment of the mortgage judgments. I will bring this offer of settlement to the formal attention of our office and advise as to whether this may be heard at the July meeting of the BOCC. Thank you, Peter Morris Assistant County Attorney Monroe County Attorney's Office th Street, Suite 408 Key West, FL (305) (305) (fax) Please note that Florida has a broad public records law and that any communication with the County could be considered a public record. If you do not wish for your address to become a public record, use the telephone or some other method of conveying your message. From: Michael Corey [mailto:mcorey@obrontcorey.com] Sent: Thursday, June 25, :43 PM To: Morris-Peter Mr. Morris, This offer is to resolve the code enforcement liens only. We are still working on the mortgages. If you think that the Board would only consider a global settlement offer (including the mortgages) I can put that together but would probably need at least 3 months to pay so that the necessary funds can be procured. Michael Michael James Corey Partner Obront Corey, PLLC Southeast Financial Center 200 South Biscayne Boulevard, Suite 2940 Miami, Florida Telephone: Facsimile:

6 Cellular: NOTICE: This message is from the law offices of Obront Corey, PLLC. The information contained in this electronic mail transmission and any attachments may contain privileged or confidential information and may be protected by legal privilege. This message is intended only for the individual or entity to which it is directed. If you are not the addressee, or if this message has been addressed to you in error, you are not authorized to use, read, copy or distribute this message and any attachments, and we ask that you please immediately delete this message and attachments (including all copies), and notify the sender by return or telephone at so that our records can be corrected. Delivery of this message and any attachments to any person other than the intended recipient(s) is not intended in any way to waive confidentiality or privilege. All personal messages express views only of the sender, which are not to be attributed to the law offices of Obront Corey, PLLC and may not be distributed or copied without this statement. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code, or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. From: Morris Peter [mailto:morris FL.Gov] Sent: Thursday, June 25, :40 PM To: Michael Corey Mr. Corey, I confirm receipt of the below offer of settlement by this e mail. Is MMC s offer of $70,000 over and above the full amount of the two mortgage judgments Monroe County currently holds against your client? 5

7 In other words, is your client s settlement offer to pay the full amount of the two mortgage lien judgments in addition to/plus $70,000 to settle the outstanding Code Enforcement liens? Thank you, Peter Morris Assistant County Attorney Monroe County Attorney's Office th Street, Suite 408 Key West, FL (305) (305) (fax) Please note that Florida has a broad public records law and that any communication with the County could be considered a public record. If you do not wish for your address to become a public record, use the telephone or some other method of conveying your message. From: Michael Corey [mailto:mcorey@obrontcorey.com] Sent: Thursday, June 25, :04 AM To: Morris-Peter Subject: For Settlement Purposes Only For Settlement Purposes Only- Privileged Settlement Communication Pursuant to Section , Fla. Stat. (2014) Dear Mr. Morris, It was a pleasure speaking with you yesterday. My client, Marine Mammal Conservancy ( MMC ), has asked me to propose a settlement to Monroe County to resolve the current code enforcement liens on the property located at Overseas Highway, Key Largo, Florida (the Property ). To my understanding, the current code enforcement liens on the Property were filed under Monroe County Code Enforcement Case No. CE and Monroe County Code Enforcement Case No. CE (collectively the Liens ). In exchange for releasing the Liens, MMC offers to pay Monroe County $70,000. MMC respectfully requests that the Monroe County clerk add an item on the Monroe County Code Enforcement Board s (the Board ) July 15, 2015 meeting agenda for consideration of MMC s proposal. A representative of MMC will be present at the meeting to present our proposal to the Board and request that the Board accept the proposal in exchange for releasing the Liens. Again, I appreciate the County s consideration of our mitigation request. If you need any additional information from me or I need to do anything else to get the item on the Board s July 15 th agenda, please let me know. Sincerely, Michael Michael James Corey Partner Obront Corey, PLLC Southeast Financial Center 200 South Biscayne Boulevard, Suite

Miami, Florida 33131 Telephone: 305.373.1040 Facsimile: 305.373.2040 Cellular: 305.726.1786 Email: mcorey@obrontcorey.com NOTICE: This message is from the law offices of Obront Corey, PLLC.

8 Miami, Florida Telephone: Facsimile: Cellular: NOTICE: This message is from the law offices of Obront Corey, PLLC. The information contained in this electronic mail transmission and any attachments may contain privileged or confidential information and may be protected by legal privilege. This message is intended only for the individual or entity to which it is directed. If you are not the addressee, or if this message has been addressed to you in error, you are not authorized to use, read, copy or distribute this message and any attachments, and we ask that you please immediately delete this message and attachments (including all copies), and notify the sender by return or telephone at so that our records can be corrected. Delivery of this message and any attachments to any person other than the intended recipient(s) is not intended in any way to waive confidentiality or privilege. All personal messages express views only of the sender, which are not to be attributed to the law offices of Obront Corey, PLLC and may not be distributed or copied without this statement. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code, or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. 7

FILED: NEW YORK COUNTY CLERK 06/14/ :18 PM INDEX NO /2017 NYSCEF DOC. NO. 271 RECEIVED NYSCEF: 06/14/2018

FILED: NEW YORK COUNTY CLERK 06/14/ :18 PM INDEX NO /2017 NYSCEF DOC. NO. 271 RECEIVED NYSCEF: 06/14/2018 From: Fried, William Sent: Monday, June 11, 2018 10:43 AM To: Kevin A. Fritz ; Christopher Gorman Cc: Stephen B. Meister ; Poddar, Shivani ' ;