HomeMy WebLinkAbout2021-141Mr. Matt Jordan
September 13, 2021
Page 9
CONFLICT OF INTEREST WAIVER
As we have discussed, Gunster currently represents several private companies and
individuals in connection with various regulatory and transactional matters before Indian River
County — Department of Utility Services (the "County'). Gunster also anticipates
representing additional clients in similar matters in the future, including possible litigation
that may arise from or is related to such matters as well as in eminent domain matters in
which the Indian River County is a party (the "Gunster Clients") These matters are (or will
be) wholly unrelated to the proposed representation in this Matter for the County.
We have consulted with you regarding the conflict of interest that would arise through
our representation of the County in this Matter and have explained the implications and material
risks of our simultaneous representation of the Gunster Clients with respect to other unrelated
matters. As we have discussed, the primary risks arising from this type of conflict circumstance
are that: (1) the representation of one client may be materially limited or less than zealous or
eager due to the representation of the other client, and (2) the potential that one client's
confidences or secrets may be disclosed to the other and used adversely against the first.
We believe that Gunster will be able to provide competent and diligent representation to
the County and to the Gunster Clients without resulting in any adverse impacts on our
relationships with either the County or the Gunster Clients. The law does not prohibit these
representations and Gunster' representation of the County and the Gunster Clients will not
involve the representation of both sides in the same proceeding. Under these circumstances, we
believe that a waiver of the conflict of interest and the County's consent to our representation of
current and future Gunster Clients in matters before the County or litigation arising out of or
related to such matters would be ethically permissible.
It is our understanding that, after considering the advantages, disadvantages and material
risks of the proposed conflict waiver as well as the reasonably available alternatives to providing
the consent that we have requested, the County has agreed (1) to provide its Informed Consent to
Gunster' representation of the Gunster Clients, (2) to waive the resulting conflict of interest, and
(3) that Gunster may represent current and future Gunster Clients in matters before the County,
provided, that (i) this conflict waiver shall not extend to'or cover any representation by Gunster
that is adverse to the Indian River County Department of Utility Services (IRCDUS) or the Solid
Waste and Disposal District (SWDD) in any subsequent litigation, proceeding, or transaction
arising out of or related to this Matter, and (ii) further, that in the event the County revokes its
consent or declines to consent in future matters to Gunster' representation of a Gunster Client,
the County agrees that Gunster will have the right to immediately terminate its representation of
the County in this Matter and that Gunster may continue to represent the Gunster Clients in
matters before the County. Subject to this limitation, you agree that Gunster may actively and
zealously represent the Gunster Clients' interests in other matters consistent with our obligations
to all of our clients.
We request that you sign this waiver acknowledging that you have received it, agree with
the understandings contained herein and consent to our representation as described herein and
discussed with you. As we have discussed, this is an important issue that deserves your careful
Mr. Matt Jordan
September 13, 2021
Page 10
consideration. You should consult with counsel other than Gunster before making the decision
to sign this letter. If you desire to consult with independent counsel concerning these matters, we
would be happy to work with any counsel that you designate for this purpose.
Finally, this will also confirm that before undertaking the representation of the County in
this Matter, we will obtain a similar acknowledgement and consent from all Gunster Clients.
Agreed to this 21 day of Sept , 2021:
l
Joseph E. Flescher
Printed Name
Attest: Jeffrey R. Smith, Clerk of
Cir i Court and Comptroller
Deputy Clerk
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