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• <br />Michael. P. Bist <br />Garvin B. Bowden** <br />Benjamin B. Bush <br />David S. Dee <br />Erin W. Duncan <br />Charles R Gardner <br />John T. LaVia, III <br />GB <br />Telephone <br />850-385-0070 <br />Gardner, Bist, Wiener, <br />Bowden, Bush, Dee, <br />LaVia & Wright, P.A. <br />ATTORNEYS AT LAW <br />1300 Thomaswood Drive <br />Tallahassee, Florida 32308 <br />www.gbwlegal.com <br />Bruce I. Wiener** <br />Wendy Russell Wiener <br />Bedford Wilder <br />Robert Scheffel `Schei Wright <br />Facsimile <br />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 />0 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. Convent, <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 />• <br />16 <br />