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Gardner, Bist, Wiener, <br /> GBW Bowden, Bush, Dee, <br /> LaVia & Wright, P.A. <br /> ATTORNEYS AT LAW <br /> Michael P. Bist 1300 Thomaswood Drive Bruce I.Wiener** <br /> Garvin B. Bowden** Tallahassee, Florida 32308 Wendy Russell Wiener <br /> Benjamin B. Bush Bedford Wilder <br /> David S. Dee www.gbwlegal.com Robert Scheffel'Schef'Wright <br /> Erin W. Duncan <br /> Charles R. Gardner Telephone Facsimile <br /> John T. LaVia, III 850-385-0070 850-385-5416 **Board Certified Real Estate Lawyer <br /> December 12 , 2014 <br /> BY ELECTRONIC MAIL ONLY <br /> Carlos Alvarez, Esquire <br /> 847 East Park Avenue <br /> Tallahassee, Florida 32301 <br /> Re: The City of Vero Beach's Non-Confidential Mediation Statement <br /> Dear Carlos, <br /> The pending disputes between the Town of Indian River Shores and <br /> Indian River County, on the one hand, and the City of Vero Beach, on <br /> the other, are scheduled to be mediated by you at the City of Vero <br /> Beach Community Center at 9 :30 A.M. on Wednesday, December 17, 2014. <br /> The City will be represented at the mediation by The Honorable Richard <br /> G. Winger, Mayor, James R. O'Connor, City Manager, Wayne R. Coment, <br /> Esquire, City Attorney, and me. <br /> Consistent with your Mediation Retention and Scheduling Letter of <br /> December 2, 2014, the City provides the following information <br /> regarding the facts and law applicable to the pending disputes, the <br /> City's interests in these disputes, and the City's past proposals and <br /> its ongoing efforts to resolve the issues in dispute. <br /> Procedural Background of the Disputes <br /> The mandatory procedures of the Florida Governmental Conflict <br /> Resolution Act, Chapter 164, Florida Statutes ("Act") , were invoked by <br /> the complaint filed by the Town of Indian River Shores ("Town") in the <br /> Circuit Court in and for Indian River County on July 18, 2014. As <br /> provided for by the Act, Indian River County ("County" ) has joined <br /> these dispute resolution proceedings as an additional "conflicting <br /> governmental entity. " As discussed briefly below, the County has also <br /> 1 <br /> f(D <br />