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
United States v. Adrian Arnett Williams, Also Known As A-Bone, Also Known As A.K., United States of America v. Katrina Hayes, 45 F.3d 1481, 10th Cir. (1995)