At times … Sometimes
At times … Sometimes
I love my life
and embrace each moment.
At times … Sometimes
I love everybody
and one hundred songs
fill the silence inside me.
At times … Sometimes
My loneliness overwhelms me!
The words in my mouth are stale.
The stars are too far away.
And each tick of the clock booms heavy!
At times … Sometimes
I laugh
and play
like a spring bird.
Like the breeze
the sadness that comes
is lost and
I feel very happy
and laugh very loud.
I love my life
and adore what all that comes of it.
At times … Sometimes
At times … Sometimes
Lanosa’s strategy may be revealed best by her objections at deposition – they appear to be calculated to avoid disclosing key elements of our case.
One concern she expressed during the Hossfield deposition was the Fifth District’s affirmance of the BCC decision. Her assumption appeared to be that we were asking Hossfield questions that challenged the Fifth District’s decision. Oddly, at the end of the deposition she gets to the answers that we were really after – Hossfield would considered an "intended" use in reaching a decision on a permit.
Steven G. Mason, of Law Office of Steven G. Mason, P.A., Altamonte Springs.
This is the attorney for Rachel’s in OC Food & Beverage, LLC v. Orange County. He will understand our argument regarding Article VIII, Section 1 (j), Florida Constitutioin.
Jesse Clark and I spoke at length. It is still unclear to me whether or not he ever had a hearing before the Code Enforcement Board. But it is quite clear that he believes he was denied a permit by the Board of County Commissioners because Comm. Edwards wanted to punish him for finishing the garage after being notified by Code Enforcement that he was in violation of the code for starting the garage without a permit. I did not ask if Code Enforcement had issued a violation notice or a stop work order. And I don’t know if they even issue, or have the authority to issue, stop work orders.
Admissions should be drafted as soon as possible. The first drafts should be directed to the individual defendants and based upon the allegations of the complaint.
Subpoenas
The federal rules say that I can subpoena anyone. Jerry Jennings? Pet stores (i.e., Bird Crazy)? Florida Association of Counties? FWC licensees. I need to start on that as soon as possible. Next week. Review the rule. Check the case law.
It did occur to me (after sending out an email request) that the information I’ve asked FWC licensees to volunteer (and might demand by subpoena) is precisely the information the FWC requires them to keep on record. So, I could ask the returning chair of the FWC Rodney Barreto to help me: we want the same information; and, that information (by increasing the damages award) will give the ultimate judicial decision more weight.
In 2007 the defendants knew or should have known that what they were doing to us violated Article IV, Section 9, and Article VIII, Section 1(j), of Florida’s Constitution. We say "they knew or should have known" because the language of those two provisions of the state constitution is perfectly clear.
Article IV, Section 9, says County government has no authority to regulate wild animal life.
And Article VIII, Section 1(j), says County government has no authority to decide how it will prosecute code violations.
We say that in 2007 "they knew of should have known" what they were doing to us violated Article IV, Section 9, because Florida’s Attorney General told them so five years earlier in Attorney General Opinion 2002-23. And the Florida Fish and Wildlife Conservation Commission told them the same thing in its 2007 Memorandum of Law.
We say that in 2007 "they knew of should have known" what they were doing to us violated Article VIII, Section 1(j), because that provision very clearly and simply states: "Persons violating county ordinances shall be prosecuted and punished as provided by law."