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Filing # 34681324 E-Filed 11/19/2015 04:27:50 PM

EXHIBIT A

Photo: Defendant Xavier Alban recording Plaintiffs public records request on


September 3, 2015.


Screenshot of Foursquare check in to Miami Riverside Center on September 14, 2015



Screenshot of Foursquare check in to Miami City Hall on September 14, 2015

EXHIBIT B

Walmart Request
PublicRecords <PublicRecords@miamigov.com>
Fri, Sep 18, 2015 at 5:18 PM
To: Grant Stern <grantstern@gmail.com>
Cc: "Alban, Xavier E." <XEAlban@miamigov.com>, PublicRecords <PublicRecords@miamigov.com>
Good afternoon,

Below is the criteria IT has developed based on your public records request. The cost of the search is $112.05. Please
review the search criteria below and advise if it is acceptable. If you would like to add additional search terms, please
let us know so that it can be updated and we can provide you with the updated cost. If the criteria is acceptable,
please follow the payment instructions below so that your request may be processed.

If you have any questions, please do not hesitate to contact us. Thank you.

!
!

===========================================================================

The total cost to run the queries to retrieve emails which fit suggested criteria below, to create Outlook PST files with
querys output and to save the output to a media (CD, DVD or hard disk depending on the volume) is $112.05. The
electronic media to save the data is included in the estimate.

The process to create the storage media will take approximately 4 business days after receiving the approval and
payment. The costs includes searches for Civilian mailboxes. Police mailboxes are not included.
If the request is related to a law matter case or may include any other exempted emails then a review of the results
may be required before being released and this may add more delivery time and cost.
If the suggested criteria and estimate are accepted, a payment for the quantity above needs to be made to City of
Miami and delivered to Ms. Latanya Johnson at 444 SW 2nd Avenue, cubicle 515, Miami, FL 33130. Payment can be
done in check or cash.
Results are based on suggested criteria and may contain emails not related to requestors desire. If the requestors are
not agreed with suggested criteria, they can change it before making the payment. Once the payment is received and
the query is executed, a change in criteria may require additional charges

Suggested Criteria:
Search 1:
Criteria Type

Search criteria

Start Date

10/15/14

End Date

12/4/14

To or From

FGarcia@miamigov.com

Key words / Phrases

Walmart
OR
"3155 N. Miami Ave" AND zoning
OR
"3155 N. Miami Avenue" AND zoning
OR
"3155 North Miami Ave" AND zoning
OR
"3155 North Miami Avenue" AND zoning
OR
"3155 N. Miami Ave" AND referral
OR
"3155 N. Miami Avenue" AND referral
OR
"3155 North Miami Ave" AND referral
OR
"3155 North Miami Avenue" AND referral

!
Search 2:
Criteria Type

Search criteria

Start Date

10/15/14

To or End Date

12/4/14

From

ISHegedus@miamigov.com

Key words / Phrases

Walmart
OR

"3155 N. Miami Ave" AND zoning


OR
"3155 N. Miami Avenue" AND zoning
OR
"3155 North Miami Ave" AND zoning
OR
"3155 North Miami Avenue" AND zoning
OR
"3155 N. Miami Ave" AND referral
OR
"3155 N. Miami Avenue" AND referral
OR
"3155 North Miami Ave" AND referral
OR
"3155 North Miami Avenue" AND referral

!
Requestor Criteria:
Good evening,

We received the following public records request in person today. Please process this as soon as possible. The
requestor has informed me that they need to file an appeal by Wednesday, September 23, 2015. Please provide an
estimate as soon as possible. The criteria are as follows:

Search 1:

All emails to or from: Francisco Garcia


Time Frame: Oct. 15, 2014 Dec. 4, 2014
Search Criteria:
Walmart
or
3155 N. Miami Ave and zoning
Or
3155 N. Miami Avenue and zoning

Or
3155 North Miami Ave and zoning
Or
3155 North Miami Avenue and zoning
or
3155 N. Miami Ave and referral
Or
3155 N. Miami Avenue and referral
Or
3155 North Miami Ave and referral
Or
3155 North Miami Avenue and referral

Search 2:

All emails to or from: Irene Hegedus


Time Frame: Oct. 15, 2014 Dec. 4, 2014
Search Criteria:
Walmart
or
3155 N. Miami Ave and zoning
Or
3155 N. Miami Avenue and zoning
Or
3155 North Miami Ave and zoning
Or
3155 North Miami Avenue and zoning
or
3155 N. Miami Ave and referral
Or
3155 N. Miami Avenue and referral
Or
3155 North Miami Ave and referral

Or
3155 North Miami Avenue and referral
==========================================================

Xavier E. Albn, Esq.


Public Records Coordinator
City of Miami Office of the City
Attorney
Telephone: 305-416-1830
Facsimile:

305-416-1801

xealban@miamigov.com
PublicRecords@miamigov.com
DISCLAIMER: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain
legally privileged and confidential information. If you properly received this e-mail as a client or retained expert, please hold it in
confidence to protect the attorney-client or work product privileges. Should the intended recipient forward or disclose this
message to another person or party, that action could constitute a waiver of the attorney-client privilege. If the reader of this
message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified
that any review, dissemination, distribution or copying of this communication is prohibited by the sender and to do so might
constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this communication was
received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing in
this e-mail message shall, in and of itself, create an attorney-client relationship with the sender. Under Florida Law, e-mail
addresses and the contents of the e-mail are public records. If you do not want your e-mail address, or the contents of
the e-mail, released in response to a public records request, do not send electronic mail to this entity. Instead, contact
this office by phone or in writing.

Please consider the environment before printing this e-mail.

!
From: Grant Stern [mailto:grantstern@gmail.com]
Sent: Friday, September 18, 2015 1:43 PM
To: Alban, Xavier E.
Subject: Walmart Request
[Quoted text hidden]

EXHIBIT C

Walmart Request
Grant Stern <grantstern@gmail.com>
To: PublicRecords <PublicRecords@miamigov.com>
Cc: "Alban, Xavier E." <XEAlban@miamigov.com>
Hey Xavier,
I believe that the project is actually 3055 N. Miami Avenue.
Also, can you please email me the portion which I viewed at your office earlier today now.
Thank you,
Grant

[Quoted text hidden]

Fri, Sep 18, 2015 at 5:58 PM

EXHIBIT D

Screenshot of digital file folder provided by the City of Miami in response to Plaintiffs
public records request

EXHIBIT E

Screenshot of public records request in City of Miamis online records request database

EXHIBIT F

Walmart Request
PublicRecords <PublicRecords@miamigov.com>
Mon, Sep 21, 2015 at 9:06 AM
To: Grant Stern <grantstern@gmail.com>
Cc: PublicRecords <PublicRecords@miamigov.com>, "Alban, Xavier E." <XEAlban@miamigov.com>

Good$morning,
$
The$les$you$reviewed$Friday$were$uploaded$later$that$same$day$and$you$should$have$received$a$link$to$access
the$les.$I$am$including$the$link$here$now.
$
https://miami.nextrequest.com/requests/15-165
$
I$will$have$the$address$corrected$to$3055$N.$Miami$Ave$in$the$IT$search.
$
Please$let$me$know$if$you$have$any$quesFons.$Thank$you.
$

Xavier E. Albn, Esq.


Public Records Coordinator
City of Miami Office of the City
Attorney
Telephone: 305-416-1830
Facsimile:

305-416-1801

xealban@miamigov.com
PublicRecords@miamigov.com
DISCLAIMER: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain
legally privileged and confidential information. If you properly received this e-mail as a client or retained expert, please hold it in
confidence to protect the attorney-client or work product privileges. Should the intended recipient forward or disclose this
message to another person or party, that action could constitute a waiver of the attorney-client privilege. If the reader of this
message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified
that any review, dissemination, distribution or copying of this communication is prohibited by the sender and to do so might
constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this communication was
received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing in
this e-mail message shall, in and of itself, create an attorney-client relationship with the sender. Under Florida Law, e-mail
addresses and the contents of the e-mail are public records. If you do not want your e-mail address, or the contents of
the e-mail, released in response to a public records request, do not send electronic mail to this entity. Instead, contact
this office by phone or in writing.

Please consider the environment before printing this e-mail.

$
From: Grant Stern [mailto:grantstern@gmail.com]
Sent: Friday, September 18, 2015 5:58 PM
To: PublicRecords
Cc: Alban, Xavier E.
Subject: Re: Walmart Request
[Quoted text hidden]

EXHIBIT G

Walmart Request
Grant Stern <grantstern@gmail.com>
To: PublicRecords <PublicRecords@miamigov.com>
Cc: "Alban, Xavier E." <XEAlban@miamigov.com>

Mon, Sep 21, 2015 at 9:26 AM

We did get it! I didn't see any of the City Commission (or PZAB) resolutions or court opinions in the file. Shouldn't
those be a part of the file since the matter went to commission?
Thanks
Grant
[Quoted text hidden]

EXHIBIT H

Walmart Request
PublicRecords <PublicRecords@miamigov.com>
Mon, Sep 21, 2015 at 10:01 AM
To: Grant Stern <grantstern@gmail.com>
Cc: PublicRecords <PublicRecords@miamigov.com>, "Alban, Xavier E." <XEAlban@miamigov.com>

I"will"follow"up"with"Hearing"Boards"who"would"have"the"le."They"were"contacted"last"week.
"

Xavier E. Albn, Esq.


Public Records Coordinator
City of Miami Office of the City
Attorney
Telephone: 305-416-1830
Facsimile:

305-416-1801

xealban@miamigov.com
PublicRecords@miamigov.com
DISCLAIMER: This e-mail is intended only for the individual(s) or entity(s) named within the message. This e-mail might contain
legally privileged and confidential information. If you properly received this e-mail as a client or retained expert, please hold it in
confidence to protect the attorney-client or work product privileges. Should the intended recipient forward or disclose this
message to another person or party, that action could constitute a waiver of the attorney-client privilege. If the reader of this
message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified
that any review, dissemination, distribution or copying of this communication is prohibited by the sender and to do so might
constitute a violation of the Electronic Communications Privacy Act, 18 U.S.C. section 2510-2521. If this communication was
received in error we apologize for the intrusion. Please notify us by reply e-mail and delete the original message. Nothing in
this e-mail message shall, in and of itself, create an attorney-client relationship with the sender. Under Florida Law, e-mail
addresses and the contents of the e-mail are public records. If you do not want your e-mail address, or the contents of
the e-mail, released in response to a public records request, do not send electronic mail to this entity. Instead, contact
this office by phone or in writing.

Please consider the environment before printing this e-mail.

"
From: Grant Stern [mailto:grantstern@gmail.com]
Sent: Monday, September 21, 2015 9:26 AM
[Quoted text hidden]
[Quoted text hidden]

EXHIBIT J

EXHIBIT K

Docket at the Third District Court of Appeal in Pfeffer v. Wal-mart, City of Miami, et al

EXHIBIT L

EXHIBIT M

EXHIBIT N