Lobby For Justice South Florida

MIAMI MIRROR TRUE REFLECTIONS
CRITICAL PRONOUNCEMENT ON MIAMI DADE COUNTY COMMISSION ON ETHICS AND PUBLIC TRUST
TheMiamiDadeCountyBoardofCommissionersknewverywellthatcitizenshadgoodreason
tohavecontemptforpublicofficialswhoseunethicalbehaviorgavecountygovernmentabad
name.Indeed,thatcontemptismemorializedintheCitizensBillofRightsofthecountysHome
RuleCharterwhenitcallsforindividualcitizenstograntrespectforthedignityofpublicoffice
asaquidproquoforallowingthemtoparticipate.Imaginethat.
TheperversionwassopervasivethattheBoardofCommissionersfounditnecessarytocreate
theMiamiDadeCountyEthicsCommissiononEthicsandPublicTrustasatrusteeandguardian
charged with restoring public confidence by educating the public on ethical principles and
enforcing certain standards designed to ensure the integrity that is essential to the decision
makingprocessinanopen,ordemocraticgovernment.Imaginethat.
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NowtheEthicsCommissionhassomegoodbehaviortoitscredit,butitsdemeritsaresuchthat
severalpeoplewhohaveingoodfaithtriedtoparticipaterespectfully,withoutfoullanguage
towardsitsofficers,havedubbedittheUnethicalCommissionofPublicDistrust.Theconductof
itsinvestigativestaffanddirectorhasbeenespeciallytakentotask,andwithgoodreason,and
theyhaveaccordinglyperceivedcriticismaspersonallyinsulting.
No,theparticipationofcriticsisnotwelcome.Informationisdismissedwithprejudiceagainst
the informer instead of on the merits. Enthusiasm for ethical behavior is greeted with a cold
shoulder,thestonewall,thesilenttreatment.
Investigatorsrequireinformantsandcomplainantstoconductthoroughinvestigationsinstead
ofdoingsothemselves,althoughinformantsandcomplainantsdonothavethelegalpowerto
doso.
Investigatorstakethewordofpublicofficialswhentheyanswerandfindnoprobablecausefor
complaintsafterfailingtoprovidecomplainantswithanopportunitytorespondtotheofficials
answers.Andthenmostoftheinvestigativefindingsarehiddenfromview,i.e.,notpublished
ontheCOEwebsitebecauseconsideredunworthyofpublicattention.
AgreatdealofinformationbroughttotheattentionoftheCOEdirectoranditsstaffisignored,
and when inquiry is made as to whether the information will be investigated or if it is under
investigation, staff responds that investigations if any are secret until reported if ever, thus
keepingthepublicinthedarkandrenderingtheCOEunaccountabletothepublic.
All this is sad to say since the rise civilization is based on criticism: civilization is an ongoing
complaint.Civilizationisdeclininginthisinstitutiondespiteitsmeritsandthegoodworksofits
staff.Hereagainwhatisneededisgoodgovernment,goodleadership,andthewilltodothe
rightthingatalltimesforthepeoplenomatterwhotheyare.
David Arthur Walters

September29,2014
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LOOKINGINTOTHECORRUPTIONOFTHE
THEMIAMIDADECOMMISSIONONETHICSANDPUBLICTRUST
BY
DAVIDARTHURWALTERS
Exploitationofofficialpositionprohibited.Nopersonshalluseorattempttouse
his official position to secure special privileges or exemptions for himself or
others.....(MiamiDadeCountyConflictofInterestandCodeofEthicsOrdinance)
Rhonda Victor Sibilia, Communications Director for the MiamiDade Commission on Ethics &
PublicTrustconfirmedon22July2015thattheCOEislookingintobutnotinvestigatingthe
current preelection uproar over contributions allegedly solicited from city vendors by
Commission Jonah Legal Weasel Wolfson and/or Mayor Philip King Levine for a political
actioncommitteecalledRelentlessforProgress.AtissueistheproverbialQuidProQuo.
ThefoodfightonthedaiswasstartedbyoppositionCommissionDeedeWeithorn,aprominent
member of the old regime upset by the mayors purchase of his seat and a majority on the
commission, rendering him a virtually strong mayor in a city with a weak mayor, strong city
managercharter.CityManagerJimmyNiceGuyMoralesisthusdependentonhiswillyethas
considerablelatitudeasadictatorasthelowpaid,parttimemayorandcommissionersdevote
themselves to politics as usual, politics being mainly the distribution of the absolute power
fearedbyhumankind.
Mr.WolfsonsaidthePAChadstatewidecausestopursue.Theonlycauseadvancedthusfaris
KingLevine,albeittheRoyalMediaexecutiveandrealestatedeveloperisloadedandhasthe
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backingoftheClintons,hisintimates.Helaidoutoveramilliondollarsfromhisownpocketto
savethecityfromtheoldregime.Hewasaamateurishatfirst,buthesoongrewcomfortablein
his new saddle, resorting to his media principles, basking in praise during the honeymoon
period, ignoring naysayers, and stroking his henchmen and lackeys along the way. The slick
commercials bring out his star quality. He is the valiant Southern Knight fighting Neptune
himself. You see, global warming is a scientific fact. Sea levels are rising. Sinful Miami Beach
mustbesavedfromtheGreatFlood.Tomorrowtheworld:Mr.Levinemaybeanambassador
forHilaryifsheisnottrumpedbyTheDonaldorchargedwithtreason.
Well, now, the mayor was unflappable as the pots called kettles black and vice versa for the
public goods at the raucous commission meeting. He refused, as chair of the commission, to
recognizeamotiontoaskthecountyethicscommissiontoopineforthethousandthtimeon
QuidProQuo.
Its director, Sleeping Joe Centorino, is not the only lawyer who would fall asleep with wits
exhaustedonthequestionunlesspaid$500hourforresearch.TraditionalMiamiBeachwould
perishifallformsofQuidProQuo,theveryessenceofpoliticalcorruption,werenegatedwitha
flood of prosecutions. Indeed, civilization itself would come to an end if there were no
corruption in the world; therefore the arguments over the true nature of the quiddity are
endless.Ideally,corruptionshouldbenomorethan4onascaleof10.
Thecityattorneyreportedlyadvisedthecommissionersthatitcouldnotaskthecountyethics
commission to investigate them after the mayor refused to recognize the motion.Yet the
clamor over the whole thing did slightly raise an ethical eyebrow at the county ethics
commission.
The ethics commission may proceed on any information alleging or implying unethical
conductofofficials,asdidtheStarChamberofyoreforsovereignswhowouldfaindisposeof
unrulynobles.Aformalcomplaintdoesnothavetobemade.
The rules provide for the handling of formal complaints by the ethics commission within a
definiteperiodoftime.Otherinformationsuchasnewspaperreports,statementsofcommon
informersandwatchdogsishandledatitsowndiscretion.
Oneofthebestinvestigativejournalistsinthecountryadvisedmethatitisbestforreporters
nottofileformalcomplaints.Rather,bringinformationtotheattentionofpublicofficials,come
backlaterandaskthemwhatactiontheyhavetaken.
Thetroublewiththatistheydonothavetoanswer.Oh,theymightanswerifyouareverynice
tothem,orifaclamorcanberaisedovertheirnegligence.Look,everybodylovestohavetheir
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professional decisions praised and they loath being blamed for themAdam Smith excepted
mathematicians,and,tosomeextent,naturalscientists.
Mr. Centorino was well aware of the brouhaha in a teacup over the Relentless PAC. He
congratulated an inquirer for his civic interest in the matter, and stated on the public record
that:
Our agency is called the Commission on Ethics and Public Trust, and we take seriously the
public trust issue which is raised in circumstances where an otherwise legal activity
diminishestrustinthehonestyoflocalgovernment.Wehaveoccasionallycommentedonsuch
appearancesinpublicreportsoropinionsthatwehaveissued,althoughIamawarethatsome
locallawyersdonotapproveofourdoingso.Unfortunately,Iamnotinapositiontogiveyou
any definitive information on the Miami Beach situation at the present time since it is
something that we are currently looking into. When we have completed our inquiry, any
findingsthatwereachwillbemadepublic.(Emphasisadded)
I opine that Miami Beach will freeze over before Mr. Centorino will ask his staff to open an
Investigation into the situation after looking into it. I take that back: he might order an
investigationtohelpfulfilltheeducationalobjectiveofhiscommission;afterall,theinevitable
railsittingandissuanceofanInstructionwouldmakegoodpress.
According to my intercourse with his communications director, looking into and investigation
aredifferentcategories.Ihavebeenlookingintothecommissionsbehaviorforthreeyears.I
feedtheethicscommissioninformation,andthencomebacklaterandaskwhathasbeendone
withit.
InOctoberandNovemberof2014,sincethecityclerkhadnotvoluntarilydonesoasrequired
by local ordinance, I provided Mr. Centorino with hard evidence of multiple violations of
lobbyinglawsbyprominentdevelopersandtheirlobbyinglawyersandarchitectsfriendlywith
membersofMiamiBeachsfauxreformregime.
Thepersonsofinterestincluded,amongothers,PhilipLevineandScottRobins,whopartnered
with the city in a big Sunset Harbour shopping center and garage; Jorge Perez, king of the
developmentmountainwithhisimmenseluxurycondominiumprojectsinSouthBeachsSouth
of Fifth neighborhood; New York carpetbagger developers and Enrique Norten, their suave
starchitect,unlicensedinFlorida,forthespotzoninganddevelopmentofthelastbeachfront
property in South Beach at 321 Ocean Drive; the influential local architect and lobbyist Luis
RevueltaslicensewasusedforthebuildingpermitsontheEnriqueNortenproject,andhewas
thearchitectofrecordforYairWolffsSeaSprayDevelopmentofthehighendprojectat304
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OceanDriveacrossthestreet.LawyersforBercow,Radell&Fernandez,P.A.wereretainedas
lobbyistsfortheSeaSprayandforthemayorsdevelopments.Andsoon.
IcircledbackinNovemberandaskedwhathadbeendonewiththeinformation.
Mr.Walters,Ms.Sibiliarespondedfortheethicscommission,Wheninformationisreceived
bythisofficeregardingapossibleviolationofanyordinanceunderthisagencysjurisdiction,it
isconfidential.Onceprobablecauseisfound,thecaseisclosedorthecomplaintisdismissed,
wecanacknowledgeitpublicly.Untileitherofthosethingsoccurs,wecanneitherconfirmnor
deny our participation. I hope you understand that these are parameters we must operate
underaccordingtotheenablingordinancethatestablishedtheEthicsCommission.
Nothing in Sec. 21074(e) MiamiDade Code of Ordinances governing confidentiality explicitly
prohibits the Commission on Ethics from affirming or denying that an investigation has been
opened or will be conducted into information brought before its staff. Even if a formal
complaintwerefiled,nothingwouldprohibitthecommissionfromacknowledgingthatonehas
beenreceivedorthataninvestigationhasbeenorwouldbeinitiated,while,atthesametime,
refusing to provide any specific record such as the complaint itself or investigative
documents.Sec. 21074(e) states that All proceedings, the complaint, and other records
relating to the preliminary investigation as provided herein shall be confidential and exempt
fromtheprovisionsofSection119,FloridaStatutes,eitheruntiltheallegedviolatorrequestsin
writing that such investigation and records be made public records or the preliminary
investigation is completed.(Emphasis added) The acknowledgement of a record is not the
recorditself.
AsfarasIwasconcerned,theinformationwasbeingwithheldfrommebecauseIhadcriticized
a few decisions of the ethics commission instead of just reporting them. Even worse, I had
criticized the judgement of its director more than once, and suggested that, on at least one
occasion,hehadabusedthepowerofhisofficetofavorCityofMiamiBeachofficials,thevery
sortofunethicalbehaviortheethicslawsaresupposedtoprohibit.
Thatwouldbenothingnewinthehistoryoftheworld,thatministerswhoabjuresinsareprone
to committing them in darkened theatres. The power of suggestion is augmented when the
suggestionisoftrepeatedevenasaThoushaltnot.Forinstance,amostamusingvideotape
wasmadeofethicscommissionersviolatingtheSunshineActtheyaresupposedtouphold,and
they did nothing to discipline themselves. When wrong is done long enough, wrong seems
right. Holierthanthou ministers become institutionally blind to their own sins, and become
evenbiggerbulliesthanJohnMcCainwhentheirloyaltytohighprinciplesischallenged.
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Furthermore,IconsideredthewithholdingofaresponsetomyinquiryasunethicalbecauseI
knew that commission staff had acknowledged the existence of investigations to socalled
legitimate i.e. uncritical reporters of the mainstream press. Information from authoritative
sourcesisgold.TheQuidProQuois,Benicetousandyougetthegold.
I persisted in pressing for the disposition of the lobbying violations. All were eventually
dismissed.Thetrafficticketswerenotignored.Thelobbyistsandtheirprincipleshadrunred
lights,sotheywereallowedtogoaroundtheblockandpassthroughtheintersectionwhenthe
lightsweregreen.Thelightwasactuallyyellowforsomeofthemastheyhadnotyetcomplied
with correcting the sworn registrations that were fatally defective because incomplete in
essentialdetails.
Sotherewasfavorablelaxityinsteadofstrictliability,whichwouldhaveresultedinverysmall
finesonwealthydevelopersandtheirmouthpieces.Herewasanotherinstanceoffavoritismon
thepartoftheethicscommissionitself,theveryreasonthatenlightenedpeopleonthebeach
call it The MiamiDade County Unethical Commission. Of course that by no means detracts
from its good deeds when the unethical conduct is turned into a scandal by the socalled
legitimatepress.
NowthatIhadacopyofJoeCentorinoswrittenstatementthatthecommissionwaslooking
intothepoliticalcontributiontempestintheteapot,butcouldnotmakeitsfindingspublicuntil
completingitsinquiry,Idecidedtoaskforthesameacknowledgmentmyself,knowingwellthat
the gold would probably be withheld from me again because I had faulted the director,
investigators,andethicscommissioners.
Dear Ms. Sibilia, I wrote on July 22, we have quite an uproar on the beach regarding
contributions allegedly solicited by Jonah Wolfson and/or Philip Levine for a PAC called
RelentlessForProgress,asIreportedinthisarticle:
http://miamimirror.blogspot.com/2015/07/relentlesslegalweaselstrikesmiami.html
PleaseadviseiftheCOEhasanopeninvestigationofthematter.
Mr. Walters, under the enabling ordinance that established the Ethics Commission, we can
neitherconfirmnordenyanyongoinginvestigation.
Thankyou,Madame.ThenakeymemberofCOEstaffhasviolatedthatruleinrespecttothis
issue.WhomshouldIinformabouttheviolationoftherule?
If, as part of an investigation, one of our staff members discusses a complaint with the
respondentorwithapotentialwitness,thatwouldbeconsideredpartofhisorherjob.Ifone
ofthoseindividualssharestheinformation,thatisbeyondourcontrol.
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No, Madame, that is not the case here. This is a case of direvctly confirming that an
investigation or inquiry is underway yet not revealing any other details, which is what I am
seeking here. I see nothing wrong with that unless a particular person is favored to the
disadvantage a reporter who is disliked, and that may be unethical. Please reconsider and
advise whom should be notified if absent favoritism the simple revelation as described is a
violationoflawasyousay.
Ifoneofourstaffacknowledgesthatthisagencyisawareofthesituationandislookinginto
the matter, that does not reveal that a formal investigation is underway. If you believe
someone has truly committed a violation, you should let the Ethics Commission advocate
know.
Aha, there is the phrase used by Mr. Centorino: looking into. So we have Looking Into,
Investigation,andInquirytodistinguish.
Isee.Thatmakessense.Pleaseadviseifthestaffis<LookingIntothematterIaskedabout.
Thisagencyisawareofthesituationandislookingintoit.
Asforme,IamlookingintothecorruptionoftheMiamiDadeCommissiononEthicsandPublic
Trust. I have made several inquiries, and I am disclosing the details of my investigation as I
proceed.
By the way, I am raising funds for my trip to Washington, where I intend to lobby federal
investigators for justice. This matter will be included in the ball of wax presented for their
consideration.
##
Political Cartoon by Marian Del Vecchio
Page6of9
MIAMIDADEETHICSCOMMISSIONSTONEWALLSTHEPUBLIC
SecrecymaybemaintaineduntilDoomsday
22November2014
ByDavidArthurWalters
MIAMIMIRROR
MiamiBeachNelsonBellido,Esq.ChairmanoftheMiamiDadeCommissiononEthicsandPublicTrust
(COE)didnotresponddirectlytotheMiamiMirrorsinquiryyesterdayastowhetherornotithadtaken
orwouldtakeanyactiononanInformationfiledon15OctoberwithJoeCentorino,Esq.,thedirectorof
itsstaff,inregardsofthefailureofseverallobbyistsforMiamiBeachrealestatedevelopmentstoeither
registeraslobbyistsortodisclosethenamesofthepersonsheadingthelimitedliabilitycompaniesthey
represented,andtheidentitiesofanyoneholdinga5%ormoreinterestinthoseentities,asrequiredby
thecityslobbyistordinance922777.
Certainkindsofartificialpersonsarecommonlyorganizednotonlytoshieldtheirofficers,investorsand
beneficiariesfrompersonalliability,buttoconcealtheidentitiesofsuchnaturalpersons.Therefore,the
commission of the City of Miami Beach, observing that all citizens have a right to know what their
officials are doing, a right that includes knowing the names of parties influencing legislation and
administrativedecisions,mandatedthat:
"Ifthelobbyistrepresentsacorporationpartnershiportrustthechiefofficerpartnerorbeneficiaryshall
also be identified. Without limiting the foregoing, the lobbyist shall also identify all persons holding
directly or indirectly a five percent 5 or more ownership interest in such corporation partnership or
trust."(Ordinance922777,asadopted4March1992)
Insteadofrespondingdirectlytoamemberofthelegitimatepresswhoservesthepublicasadelator*
i.e.acommoninformer,Mr.Bellidowaspurportedlyboundtotakecoverbehindtheskirtsofthecounty
codeassummarizedbyCOECommunicationsDirectorRhondaSibilia.
Wheninformationisreceivedbythisofficeregardingapossibleviolationofanyordinanceunderthis
agencysjurisdiction,itisconfidential,Ms.Sibiliaadvised.Onceprobablecauseisfound,thecaseis
closedorthecomplaintisdismissed,wecanacknowledgeitpublicly.Untileitherofthosethingsoccurs,
wecanneitherconfirmnordenyourparticipation.Ihopeyouunderstandthattheseareparameterswe
mustoperateunderaccordingtotheenablingordinancethatestablishedtheEthicsCommission.
Page7of9
Indeed, Sec. 21074(e) of the MiamiDade Code of Ordinances states that, All proceedings, the
complaint, and other records relating to the preliminary investigation as provided herein shall be
confidential and exempt from the provisions of Section 119, Florida Statutes, either until the alleged
violator requests in writing that such investigation and records be made public records or the
preliminaryinvestigationiscompleted notwithstandinganyprovisionofChapter120,FloridaStatutes,
and Chapter 286, Florida Statutes. As provided in Section 21074(b), the preliminary investigation is
completedwhentheprobablecausedeterminationismade.Allotherproceedingsconductedpursuant
tothissubsectionshallbepublicmeetingswithinthemeaningofChapter286,FloridaStatutes,andall
other documents made or received by the Ethics Commission shall be public records within the of
Chapter119,FloridaStatutes.
A complaint was not filed with the COE. Public informationlobbyist registration forms with
inadequacies acknowledged by the city clerkwas simply brought before the director with this
underlying statement: The City of Miami Beach has evidently been remiss in diligently enforcing its
lobbyistordinanceincrucialprovisions,atleastinrespecttotheselobbyistsandtheirprincipals.Itmay
also be negligent in providing for effective penalties and adequate remedies so that the goal of
compliance will more likely be obtained in the future. This communication comprises an Information,
andnotaComplaint,thereforeyouarelefttoactonyourowninitiativeaccordingtoyourconscience
whilethelobbyingindustryandthepublicwatches.
Nothing in Sec. 21074(e) prohibits the COE from affirming or denying that an investigation has been
openedorwillbeconductedintoinformationbroughtbeforeitsstaff.Evenifaformalcomplaintwere
filed,nothingwouldprohibitthecommissionfromacknowledgingthatonehasbeenreceivedorthatan
investigation has been or will be initiated, while, at the same time, refusing to provide any specific
recordsuchasthecomplaintitselforinvestigativedocuments.
TheFloridaBarhasarulesimilartothecountyordinance,yetitwillacknowledgetothepressthatan
investigation of an attorney is underway providing that the request provides specific identifying
information.IntheUnitedKingdom,theagencythathandlescomplaintspublishesonlinethenamesof
lawyersagainstwhomcurrentinvestigationsarepending.Thefailuretopublishthiskindofinformation
may prevent members of the public from coming forward to testify against miscreants before their
casesaredecided.
Hopefullyeverycivilizedcitizenknowsthatpeopleareinnocentuntilprovenguilty.Thetypeofsecrecy
employed here is designed not only to protect the innocent, but officials who wish to protect their
colleaguesand/orcloaktheirnegligenceandotherformsofmalfeasance.
WemayreasonablyinferfromMs.Sibiliasstatementinthisinstancethatdamninginformationcouldbe
receivedbytheCOE,neverinquiredinto,or,ifinquiredinto,neveractedupon,andanyonefollowingup
toseeifthebehaviorofofficialswereappropriatewouldbeconfrontedbyaboilerplatedstonewall.
Nowletusimagine,arguendo,thatMr.Centorino,aformerpubliccorruptionprosecutor,lookedatthe
Informationfiledwithhim,anddecidedthatnoactionshouldbetakensinceitwasnotacomplaintfiled
bythecityclerk,theprocessprovidedforbythelocalordinance,whichthecityclerk,RafaelGranado,
Page8of9
Esq., decided not to follow, instead electing to ask the lobbyists to file corrected forms long after the
issueslobbiedonweredecidedoninformationhiddenfromthepublicview.
Ifthatwerethecase,thenMr.Centorino,andMr.Bellidoaswell,sinceacopyoftheInformationwas
filedwithhim,couldbeinviolationofFloridaspublicrecordslawaswellasthecountysCitizensBillof
RightsandtheveryrulereferredtobyMs.Sibilia,sincethedecisiontotakenoactionwouldineffectbe
adismissalorfindingofnoprobablecause.
Indeed, a common complaint against investigative bodies, especially bar regulators, is that officials
dismiss most complaints they receive without investigating them and entering them onto a public
recordforeveryonetoview.TheFloridaBarkeepsarecordofcomplaintsitdoesinvestigateanddismiss
for a year before destroying them. Police departments make records of dismissed complaints against
policeofficerspublic,butsomedepartmentshavebeguntodestroytherecordswhenashortperiodof
timeexpires,soprivatewatchdogsattempttocollectthembeforehandbecausetheymightindicatea
patternofmisconductbycertainofficerseventhoughthecomplaintsweredismissed.
Ontheotherhand,letusassumethatMssrs.CentorinoandBellidocomplywiththelaw.Thenwemay
interpretthesilencehereasanaffirmation(quitacetconsentirevidetur)thataninvestigationhasbeen
initiated. Still, if the investigation is never concluded, the public shall be kept in the dark forever and
everoruntilDoomsdaywhenofficialsarejudged.
##
*TheCommonInformer,withhiseyesconstantlyfixedontheflawsandcrookednessesofthestatutes,
and feeding upon them, contracts in his features an habitual sharpness and wary meanness of
expression.TheCommonInformermaybeaninjuredgoodness,arealbenevolenceunderacloudof
odium; inasmuch as his labours, suspected and despised as they always are, may, in many instances,
enforcetheworkingoutoflegislativewisdom.AcelebratedInformerlaidaninformationagainstthe
servantsofourmaidenqueenforhavingfailedtoemblazonherinitialsonthevehicle.Andwhyhave
wethusdweltuponthisancientfolly,thisgrimabsurdityofourlawmakers?Simply,thatitistotheir
loveoftheobscuretotheiradmirationofthedimtwilightofsense,inpreferencetothebroaddaylight
of truththat we owe nearly all the labours of the Common Informer. Bentham has declared the
functionsoftheCommonInformertobemosthonourable:intruth,Cato,withhissourfaceandbare
feet, might have plied the trade, gaining a civic wreath for the energy and utility of his practice....
(Jerrold, Douglas, The Common Informer, in HEADS OF THE PEOPLE, PORTRAITS OF THE ENGLISH,
Vizetelly&Co.,London:1840
<hr>
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25 July 2015
Michael Murawski, Advocate
MIAMI DADE COUNTY COMMISSION ON ETHICS AND PUBLIC TRUST
Re: City of Miami Beach Lobbying Irregularities
Dear Mr. Murawski:
Greetings! Thank you for your public service. I always enjoy reading your probable cause
memorandums and complaint summaries. And I always recall your Motion In Limine in the
Corolla Affair C 12-32 (that the reputation or character of a complainant, in that case a bank
robber, is totally irrelevant to the facts) when I consider what your director thinks of me for
criticizing his behavior although I am not a bank robber.
I have not received a response from you to my letters appertaining to Complaint 15-08 that
Michael J. Marrero of Bercow, Radell & Fernandez, P. A. failed to register prior to testifying
before the City of Miami Beach Preservation Board on 8 April 2014. I understand that the
Commission on Ethics and Public Trust found that he had made an inadvertent error wherefore
the case was dismissed:
Pursuant to Section 2-1074(s) of the Code of Miami-Dade County, the Ethics Commission
determined that the violation was inadvertent and unintentional and that the public interest would
not be served by proceeding further in this matter. They ordered the complaint to be dismissed
with and a Letter of Instruction be issued. (C 15-08 Pubic Report and Final Order)
I asked you to reexamine the matter because the timeline of circumstances which I discovered,
indicating that he may have lied when he stated that he had just been retained on an emergency
basis to represent the client Sea Spray Development. It turns out that he was representing that
client at least as early as 29 January 2014, two months prior. If he did lie to public officials
and/or agencies in the matter, and that is a criminal offense, I expect you will refer the matter to
the prosecutor, and reopen the case for imposition of a fine as well. Please see my comments on
that matter below.
I have reviewed the status report recently supplied to me by your office, and you shall also see
my notes on the issues below.
Some of the complete information provided by the city clerk to your office on other lobbyist
violations, of which only the 16 July 2015 was attached to the Public Report and Order in the
Marrero matter, appears to be at variance with the full status report provided by the city clerk.
Page 1 of 6
Apparently some of the inquiries on the other matters were summarily closed, without careful
examination by the COE, based on the report by city clerks office, despite the fact that the
diligence of that office was in question. Please correct me if I err, but it does appear from an
examination of the clerks records that several of the parties remain noncompliant as noted
below.
If that is true, we have all ready been extraordinarily lenient at extraordinary cost to your staff
and that of the city, which demonstrates that in this type of instance strict liability for violations
should be the rule. That is, no excuses such as inadvertent error should be allowed, nor should
anyone be allowed to simply correct sworn lobbyist statements if caught.
As I have said, the failure of the lobbyist to disclose critical information on the registration forms
rendered the filings fatally defective whether accept by negligent clerks or not. The fines are
relatively small, and the parties and their lobbyists are wealthy and influential, used to getting
their way with city boards and commissions.
What we are doing here is allowing people who ran red lights to go around the block and pass
through the intersections when the lights turn green. A prominent lawyer says, Your honor, I
made an inadvertent error, so the judge forgives the violator.
It should go without saying that the public is rightfully suspicious of the legal profession that
holds sway over all branches of government. Yet it must be said that for all we know, the ethics
commission lawyers tend to forgive lawyers as a professional courtesy, yet another reason that
there should be strict liability of offenders in these cases. You may recall how amused I was by
the ethics commission opinion that it is all right for city commissioners, most of whom were
attorneys, to engage in allegedly extortionate behavior during the Madonna Club Affair because
they were under advice of the city attorneys to do so.
In my opinion, the continued noncompliance indicated by the records at this time should
motivate a diligent investigation. Of course to err is human, and I may not have all the facts or
may have misinterpreted the status reports. Still, if warranted, ethical ethics staff should initiate
Complaints based on Information available and assert Probable Cause to the Commission to fine
the parties instead of favoring them.
In fine, I believe there should be some consequences to restore the waning public trust in the
Miami Dade County Commission on Ethics and Public Trust.
Sincerely,
Cc. Rafael Granado, Esq. City Clerk
Page 2 of 6
2012-2-17
Michael W. Larkin, Bercow, Radell & Fernandez, P.A.
Bay Road Partners LLC c/o Scott Robins Group
Failure to identify Chief Person and 5% or More Ownership Interest(s)
COMPLIANT:
Philip Levine, Manager
Scott Robins, Manager
50%
50%
2010-09-13
Les Belinson
for Espanola Way Associates LTD
re 405 & 419 Espanola Way
NONCOMPLIANT: Espanola Way Associates Ltd. was provided as 100% owner of the client,
but beneficial ownership of natural persons in Espanola Way Associates is required by the
ordinance.
20120501
Bill Eager for
for TRG Alaska III LLC
NONCOMPLIANT: TRG Alaska III LLC (see below)
20120501
Charles Sieger
for TRG Alaska III LLC
NONCOMPLIANT: TRG Alaska III LLC
The architectural firm revealed its owners, but what is wanted ownership information for its
client, Jorge Perez TRG Alaska III LLC. The Commission on Ethics should fine the lobbyists
and the principal.
2015-05-01 Bill Eager for TRG Alaska III LLC, Failure to Identify Chief Person and 5% or
Page 3 of 6

More Ownership Interest, To achieve compliance, on September 29, 2014, we mailed a Certified
Letter address to TRG Alaska III with a copy to Mr. Bill Eager, requesting the above
information. We received the signed Return Receipt #7012 3460 003 5613 9327 but no response
to our request has yet been obtained. ///On December 11, 2014, a second letter was sent to Mr.
Bill Eager, with Return Receipt #7014 1200 0000 2403 3579 copying TRG Alaska III LLC once
again requesting the information. Mr. Eager has been asked to respond within five days of
receipt of the second notice. Update on 2014- 12- 15: A partial response to the first letter has
been received, whereby the City was provided with a listing of the corporate officers. A follow
up email was sent on December 15, 2015 to Suzie Perez of The Related Group, after a telephone
conversation, explaining they still need to identify all persons holding, directly or indirectly, a
5% or more ownership interest in such corporation, partnership or trust. (City Clerk)
20140408
Michael J. Marrero, Bercow, Radell & Fernandez, P.A.
for Sea Spray Development LLC
Failure to register as lobbyist yet permitted to lobby before the Historic Preservation Board
DISMISSED, (according to a press release) in the interest of justice because of an inadvertent
error. Mr. Marrero stated [presumably under oath to the citys preservation board] that he had
had just been retained by the client. Wherefore it was opined that he inadvertently failed to
register. A further investigation found that the client had retained him long before he appeared
before the preservation board: Cynthia Neves of the City of Miami Beach disclosed on 25 July
2015 that Mr. Marrero appeared by way of a letter dated 29 January 2014 before the special
master asking for a reduction of the $101,219.93 fine on the property (docketed 16 February
2014, JB07000392 BV07000621). The fine was reduced to $2,000. It is not known whether the
ethics investigator asked when the law firm was initially retained; it may have handled the
purchase of the property on 30 August 2013. In any event, Mr. Marrero was on the case more
than two months prior to his unregistered appearance before the citys preservation board.
Residents have complained that lobbyists prevaricate before city officials. There should be
consequences for that from the county ethics commission in order for it to regain the public trust.
Advocate Michael Murawski was asked on 14 April 2015 to reexamine the matter in that vein;
he did not respond.
The case should be reviewed, and if it is found that Mr. Marrero lied to a public official or public
agency, and if that is a criminal offense, the matter should be referred to a prosecutor, and he
should be fined as lobbyist.
A COE investigator contacted the Respondent. He does not deny appearing before the HPB on
April 4, 2014. Respondent explained that he and his firm were retained on an emergency issue by
principal Yair Wolff of Sea Spray. Sea Spray had just purchased the building located at 304
Ocean Drive when they were notified by the City of Miami Beach Building Department that the
building was going to be demolished. Sea Spray did not want the department to demolish the
building. (Michael J. Marrero C15- 08) The former statement is proven false. It is my belief that
the later statement is false as well (Please do not throw us into the briar patch.) as
Page 4 of 6

demonstrated my published investigation of the circumstances leading to the demolition of the
building so that a new structure could be erected at enormous profit to the developer. SEE:
Demolishing South Beach History
http://miamimirror.blogspot.com/2015/05/demolishingsouthbeachhistorywhat.html
20140708
Michael J. Marrero (Bercow, Radell & Fernandez, P.A)
for Sea Spray Development LLC
(Example provided of his compliance elsewhere)
COMPLIANT: Coincidentally, the clerks office found a list somewhere in file after it responded
to a public record request without that list and with a registration form that made no reference to
exhibits.
Yair Wolff
Dirk G. Goldwasser
Maurice Ferre
Christopher C. Dewey
Danny Rimoni
Nir Moshe Kunik
Avinuan Hazan Noy
BRONSHTEYN MR
Jacob Verthaizer
Alony Iftach
Alex Friedman
Chen Shein
Doran Sharabany
Alabi Gbade
ZOHAR ZEEV ZOHAR IFAT
YORAM TIETZ
DANA UNGER BAR DAYAN
RUBINSTIEN ZALMA
MICHAEL HAR- ZVI
YARON HAR ZVI
Arie Gold
Ronen Barel
10.95%
8.76%
7.30%
7.30%
4.38%
6.57%
6.57%
2.91%
1.46%
4.38%
4.38%
4.38%
2.92%
4.38%
1.46%
4.38%
4.38%
4.38%
2.19%
2.19%
1.46%
2.92%
20110517
Joshua M. Benaim
Page 5 of 6

for 321 Ocean Holding LLC
AMENDMENT:
E' s Legacy Fund LLC 24.49%
Westbury Investments Ltd. 16.33%
SOFI Ocean Drive LLC 16.33%
NONCOMPLIANT: The ordinance requires the revelation of any natural person within those
shields limiting liability that indirectly owns a 5% or more interest in 321 Ocean Holding LLC
20120709
James W. Carse
for 321 Ocean Holding LLC
NONCOMPLIANT: see above
Page 6 of 6
From: The Herald southbeachherald@gmail.com

Date: Friday, July 24, 2015
Subject: High Priority - Investigation Ongoing
To: "Cardeno, Hernan" <HernanCardeno@miamibeachfl.gov>
Thanks. In my opinion, the administration on its own and on behalf of commissioners
deliberately obscures the records of this faux court. Real courts of justice display dockets
identifying judges and lawyers appearing. Your mention of audio recordings reminds me of the
guidance I supplied IA with back when we were dreaming that IA, with Officer Buhrmaster and
Officer De La Espriella, before Gary Shimminger died, would investigate allegations of official
misconduct beyond MPBD. The county IG refused to assist us, and the COE is negligent and
incompetent and institutionally blind as is the state attorney. IA like others was given a bad
program to listen to an audio, and I had to explain how to obtain the right one on the Internet
from the contractor. Audios are often poor in quality and it is tedious to find particular "cases"
many decisions are travesties on justice, and special masters who refuse to be lackeys for the
adminstration are gotten rid of, as Mr. Morales said, to take that arm "in a new direction." That
is, in a compliant direction. The FBI says that it is slow but has a very long arm. I trust that you
are independent of our little banana republic dictatorship, that you will do whatever you can to
speed up that arm by digging deeply into this subject.
There was an investigation of multiple cut-and-dried lobbying violations, most of which were
referred to Rafael Granado to have corrected by the lobbyists, and one violation by a particular
lawyer was ignored while his other violation was dismissed as falling within the "Inadvertent
Error" class of violations. That is, the COE abused its power of discretion, or sincerely believed
that there is no strict liability for lobbyists for big developers in the South of Fifth
Neighborhood--where the local unincorporated NA, which has ignored my request (for)
information identifying its officers so I can check that against lobbyists and campaign records-has virtually taken governmental authority. I want to know the names of attorneys who appeared
for this particular project and on what date, especially the January date, is to see if an attorney
lied to the COE about his involvement.
Sometimes traffic violators do not have strict liability for running red lights - - a gentleman told
me that he was stopped for running a light, and told the officer who knew him that he was on the
way to Las Olas for coffee, and did not notice the light. That is, his violation was an Inadvertent
Error. Of course that is improper enforcement.
Persons favored by the COE are protected by Inadvertent Error policy when a formal decision
must be made on an obvious violation. When that is deemed unnecessary, they are given an
opportunity to redo their fatally defective deeds (fill out new forms), which by analogy means
someone who runs a light can go back and pass through the intersection when it is green.
Best, David
Cardeno, Hernan HernanCardeno@miamibeachfl.gov

Thu, Jul 23, 2015 at 3:04 PM
To: The Herald <southbeachherald@gmail.com>
This is all I have under comments for the Special Master case number.
(SCREEN SHOWING NO ATTORNEYS, SPECIAL MASTERS, ET CETERA)
Hernan D. Cardeno, Esq. Director
CODE COMPLIANCE DEPARTMENT
Cardeno, HernanHernanCardeno@miamibeachfl.gov
Thu, Jul 23, 2015 at 11:15 AM
To: The Herald <southbeachherald@gmail.com>
David,
Let me take a look to see if the attorney is identified in the narrative somewhere; in the
alternative, it should have been audio recorded when he appeared on behalf of the property
owner. Let me take a look.
Hernan D. Cardeno, Esq. Director
CODE COMPLIANCE DEPARTMENT
23July2015
HernanCardeno,Esq.
Director
CodeComplianceDepartment
CITYOFMIAMIBEACH
Re:LobbyingForJustice
Hernan,
Greetings!
While following up on unsatisfactory county ethics commission behavior in regards to local

lobbying irregularities, I again encountered the unsatisfactory special master process. I have
alreadypublishedanarticleonthepropertythatyoumayfindhere:
DemolishingSouthBeachHistory
http://miamimirror.blogspot.com/2015/05/demolishingsouthbeachhistorywhat.html
There is one piece of information that I recently sought tohave retrievedfrom the special
master for my Lobbying for Justicetrip to Washington; to wit: the name of the lawyer who
submittedalettertotheSpecialMasterdatedJan.29,2014tostopfinesregardingViolation
BV07000621, Case JB07000392, Address 304 Ocean Drive. I am informed that the fine was
reducedfrom$101,219.93to$2,000.
The notation about that letter appears on the SM Synopsis Feb. 6, 2014, as ATTORNEY FOR
PROPERTY OWNER. Activity Field: SUBMITTED LETTER ON1/29/14 REQUESTING TO STOP
FINES.
Theclerkinformsmethatthefileissooldthatitisstoredaway,andthatthespecialmaster
arm of the administration acting for the commission does not record the names of
representatives including lawyers that appear for owners.Neither do I see the names of the
particularspecialmastersmakingjudgmentsonsynopsesprovidedtome.
Soitappearsfromtheclerkscommentsonthesubjectthat,unlikerealcourtsofrecord,there
isnoformalattorneyonrecordplacedonthesynopsesofspecialmastercases.Ihavemyself
Page1of4
witnessed a person completely unrelated to an owner appearing for an owner without the
knowledgeofsamein acasewhereafinewaspracticallydismissedontheadviceofthecity
attorneyaftercollaboratingwithaprofessionaloutsidefixerwhoprovidedanoticeofappeal
neverfiledinthecircuitcourtasapretextfornegotiation.
Asyouknow,importantspecialmasterdocumentsarenotscannedforonlineviewingsothat
thepublicmayfollowtheprocessandofferevidenceandcriticismappertainingtothespecial
masterprocess,noraretheproceedingsvideorecordedandputonlineforimmediateaccess.It
is tedious and costly for independent reporters, who by virtue of independence from the
institutionally blind Establishment are underfunded, to discover and report on events.This
naturally arouses the suspicion that this importantregulatory process has been intentionally
keptrelativelyopaqueformanyyearsbecauseitconstitutesastickyhoneypotformorallyor
criminally corrupt actors. Both sides of a quid pro quo are unlikely toreport on it. Influential
playersgettheircasesdismissedordrasticallymitigatedwithvainexcuses,whilepoorplayers
without access to legal counsel generally lose. An house attorney billing $600 an hour might
evenappeartogetasmallfineeliminatedforanorganization,whileasensiblebusinessmanis
betteroffpayingthefine.
ThatisonlyonesubjectIplanonspeakingtofederalofficialsinWashingtonabout.Ihopethat
you will take it up with any of your local federal associates whom you trust and who are
seriouslyinterestedinmunicipalreform.
Thatbeingsaid,thereissomethingelseyoumaybeabletoassistmewith.GeorgeCastellhas
on some occasions provided me with the names of persons who appeared in special master
court;forexample:
OnMay18,20151:11PM,"Castell,George"<GeorgeCastell@miamibeachfl.gov>wrote:
The case was dismissed by a Special Master at a hearing when the violator appealed the
violation.Seeinspectornotebelow.
Special Master Hearing SM Cannon Ralph Andrade (attorney) SM Cannon dismissed the
case.GD
DoyouhaveaccesstoaCodeCompliancenarrativeofinformationinregardstothisparticular
casethatwouldincludetheattorney(s)appearinginthecaseIfso,wouldyoukindlypasteit
tome?
Thankyou,
Page2of4

Neves,CynthiaCynthiaNeves@miamibeachfl.gov
Fri,Jul24,2015at3:59PM
To:DavidArthurWalters<miamimirror@gmail.com>
Youarewelcome!
ChiefSpecialMaster,EnriqueZamoraonNovember20,2014intheamountof$2,000.00.If
thereisntanythingelseyouwouldliketoknowwithinthisfile,mayInowsenditbacktoour
storagefacility?Pleaseadvise.
Thanksmuch,
Cindy
DavidArthurWalters<miamimirror@gmail.com> Fri,Jul24,2015at3:55PM
To:CynthiaNeves<CynthiaNeves@miamibeachfl.gov>
Thankyouverymuch.Whomitigatedthefine?
Neves,Cynthia<CynthiaNeves@miamibeachfl.gov>
Fri,Jul24,2015at3:51PM
To:DavidArthurWalters<miamimirror@gmail.com>
David,
TheattorneywhomadearequesttostopfinesinanemaildatedJanuary29,2014,wasatthat
timeMickeyMarrero,Esq.whoiswithBercowRadell&Fernandez,PA.
Hopethishelps.
CynthiaL.Neves,ClerkoftheSpecialMaster
DavidArthurWalters
TheHerald<southbeachherald@gmail.com>10:06AM(0minutesago)
toCynthia
ThankyouforyourusualexcellentserviceIunderstandthereisonlysomuchyoucando,andthatwhat
isiswhatitis.Ihavefrequentlyadvocatedreform ofthesheepskininacavesystemusedbythecity
during the rapidly advancing Information Age, all to no avail. I plan on discussing it with officials in
Washingtonduringmy'LobbyForJustice'campaign.Bestregards,David
Note: Perhaps you noticed that what is thought to be a portion of the Quran written on goat skin by
someonewhomayhaveknowntheProphetwasfoundbyastudentwhereithadbeenfiledunnoticed
foracentury.
Neves,Cynthia4:41PM(17hoursago)tome
Imsorrythatsnothowitgoes,thiscasewillneedtobecalledupfromstoragewhichislocatednotat
cityhall.Iwillhavethecasebroughtupandgetintouchwithyou.
Cindy
From:TheHerald[mailto:southbeachherald@gmail.com]
Sent:Wednesday,July22,20154:37PM
To:Neves,Cynthia
Subject:Re:CYNTHIAQUESTIONJB07000392BV07000621$101,219.93
Cynthia,
Theitemdated2/16onmyoldcopyofthesynopsisclearlystatesthattheattorneyforownersubmitted
letterdated1/29/14requestingtostopfines.Ineedtoknowwhothatletterwasfrom.IfitisinaboxI
shallbegladtocomeoverFridayafternoonanddigitout.
David
OnWednesday,July22,2015,Neves,Cynthia<CynthiaNeves@miamibeachfl.gov>wrote:
HiDavid,
Page3of4
Referencingtheabovecase,itsbeendismissedforsometimeandthefileisinstorage,asthiscasewas
mitigated back in November, 2014. There was no hearing on January 29, 2014, nor did anyone
representingthispropertymakeanyrequestonJanuary29,2014,asyoucanseebymyeventlogbelow
(screen shot). Also, this office does not keep a record of any party that showed at any hearing to
representthecaseinquestionwhetheritbeanattorneyorotherwise.Whenthefolkssigninfortheir
caseitsbytheircasenumberandpropertyaddresstocoincidewithtimethecaseisbeingheard.Im
sorryIcantbeofbetterhelptoyou.
Cindy
From:TheHerald[mailto:southbeachherald@gmail.com]
Sent:Monday,July20,201511:50AM
To:Neves,Cynthia
Subject:CYNTHIAQUESTIONJB07000392BV07000621$101,219.93
Cynthia,
Whatisthenameoftheattorneyand/orlawfirmthatappearedforthedefendantbywayofletter
dated29January2014?
Thanks,
DavidArthurWalters
Page4of4
18July2015
MayorandCommissioners,CityofMiamiBeach
1700ConventionCenterDrive
MiamiBeach,Florida33139
Re:LobbyingforJustice
DearMayorandCommissioners:
Icongratulatethoseofyouwhofinallyhadthecouragetoraisequestionsaboutcontributionssolicited
by the faux reform majority and related political action committees from persons that might benefit
fromyourcollectivedecisions.
CommissionerEdTobindescribedwhatmightbeaformofarmtwistingorextortion,althoughIdont
thinkheusedthetermextortion.Ofcoursealreadyconnectedrentseekerswouldgladlycontribute.
CommissionerDeedeWeithornreportedtotheTuesdayBreakfastClubthattheCityCommission,onthe
adviceoftheCityAttorney,decidednottoaskthecountyethicscommissiontoinvestigate.Iunderstand
thatthemayorrefusedtorecognizeamotiontodojustthat,andthattheoppositionfearsretaliation
formakingcomplaintsasprivatecitizens.
Although the lay definition of corruption would suit the behavior suspected, that of doing favors in
exchangeforcontributions,itishighlyunlikelyinthisjurisdictionthattheethicscommissionorthestate
attorneywouldeverfindprobablecauseofunethicalorillegalconduct.
Asyouallknow,successfulrentseekersnotonlycontributereligiouslytopoliticalcampaigns,theyalso
paylobbyistsagreatdealofmoneytoobtainfavorablepoliticaloutcomes.Thepeoplewiselywantto
know who lobbyists and their principals are, what they want, and how much they are paid, so their
representativescreatedlobbyingordinancestosatisfytheircuriosity.Ihavediscovered,however,that
ourlocalandcountylobbyingordinancesarenotalwayscompliedwith.Ibelievetheofficialswhoare
lobbied,andthepersonschargedwithprosecutingviolations,knowthatorarenegligent,andineither
casecouldcareless.
Attachedyouwillfindmy fileonseveralviolationsIdiscoveredandreported whileinvestigatingposh
realestatedevelopmentintheSouthofFifthNeighborhood.Ireportedittothecityclerkandaskedhim
toreportittothecountyethicscommission.Imyselfbroughtthematerialbeforetheethicscommission
Page1of2
staffasanInformation,andnotasaComplaint,soIcouldobserveandreportitsproactiveresponsesif
any.
IhavebeenexaminingthebehavioroftheethicscommissionforsometimeinrespecttoseveralCityof
MiamiBeachissues,andIhavefounditaslackingasthatofseveralhighcityofficials.Iamcompilingmy
files on those issues as well as this one in order to compose persuasive synopses, and am currently
seeking$3,500incontributionstofundmerelythecostsofmyventuretoWashington,D.C.tolobbythe
Justice Department to conduct a careful investigation into the subject matter and the backgrounds of
the key persons involved; speak to members of the congressional judiciary committees about the
decisionsofalocalfederaljudge;askWhiteHousestaffandkeyDemocratsaboutthecloserelationship
between our honorable mayor and the Clintons; and approach public interest law firms to assist in
reformingyourcitygovernment.
IinviteyoutocommentontheissuesraisedintheattachedfilesoImayincludeyourviewsinfuture
reports.
Sincerely,
Page2of2
10July2015
MichaelMurawski,Advocate
MIAMIDADECOUNTYCOMMISSIONONETHICSANDPUBLICTRUST
FollowingUpViolationsCityofMiamiBeachLobbyingCode
Mr.Murawski:
It has been nearly a year since several violations of the City of Miami Beach lobbyist ordinance were
broughttotheattentionoftheCOEaspertheattachedPDFfile.
IhaveyourreportC1508ontheviolationofMichaelJ.MarreroforSeaSprayDevelopment,Inc.MayI
haveacopyofthecommissionsdispositionofthecase?
C1508, although referring to lobbying provisions of the City of Miami Beach Code, does not address
Mr.MarrerosFailuretoidentifyChiefPersonand5%orMoreOwnershipInterest(s)asrequiredbythe
Code,arequirementthathewasawareofandfulfilledforotherclients.Pleaseadvisewhyyoudidnot
findprobablecauseofthatviolation.
Yourexplanationonthatissuemayormaynotresolvethefollowing:
Please advise if investigations have been made or are underway for the failures of Bill Eager for TRW
Alaska,CharlesSiegerforTRWAlaska,JoshuaM.Benaimof321OceanHoldingLLC,andJamesW.Carse
of321OceanHoldingLLCtoidentifychiefpersonsand5%ormoreownershipinterest(s)asrequiredby
ourlobbyingcode.Ifthefileshavebeendisposedof,pleaseadvisemeofthedispositions.
Thankyou,
DavidArthurWalters
PRESSINDEPENDENT
April14,2015
MichaelMurawski,Advocate
MiamiDadeCountyCommissiononEthicsandPublicTrust
Miami,Florida
Subject:C1508MichaelJ.Marrero
DearMr.Murawski:
IunderstandfromaCOEpressreleasethatthecutanddriedchargeyoupreferredagainstMr.Marrero
for failing to register as a lobbyist has been dismissed in the interest of justice because he had
allegedly just been hired by his client to make an emergency appearance to prevent the county from
havinghisclientspropertydemolishedagainsttheclientswill.
IdonothaveatranscriptofhistestimonybeforetheCommission,nordoIknowifhistestimonywas
sworn, but I have reason to suspect from the COE press release that he may have perjured himself
beforetheCommission,andthatafurtherinvestigationbyyouiswarrantedintothemattertoascertain
ifthereisprobablecausetobelievethatheperjuredhimself,and,ifso,toreferthemattertotheState
Attorney,andtohavetheCommissionreopenthecase.
AttachedyouwillfindabookmarkedPDFfilefromwhichitisnaturaltoinferbyinductivelogicthatthe
concern with the demolition was feigned because the entire destruction of the structure was the
optimumoutcome,andthepropertyowneranditsarchitectswereonhandwithelaboratedesignsto
urge the commission to approve full demolition just three months after Mr. Marreros emergency
appearance.
Iffactswerediscoveredtocastdoubtonthattheoryofthecase,thefactsasnowknownshowthatit
shouldhavebeennosurprisetotheowner,atleast,ifdulydiligent,thatthestructurewassubjectto
substantial lien and was at risk of demolition by normal process, and that, unless Mr. Marrero was
deliberatelydeceived,orperhapsisanincompetentormomentarilynegligentattorney,heshouldnot
havebeensurprisedatallbytherevelation.
Inanyevent,ascanbeshownbythelobbyistregistrationthathedidfilethreemonthsafterthehearing
hefailedtoregisterfor,hecouldhaveregisteredevenonthesamedayasthehearing.Whatinterest
ofjusticecouldpossiblybeservedbynotimposingafine,whichisofsmallmomenttohispracticeasa
professionallobbyist,remainstobeseenfromtheCOErecords.
Additionally,theCommissionseemstohaveignoredthefactthattheregistrationthatheeventuallydid
fileinthematterwasfatallydefectiveduetothefailuretoidentifythechiefpersonoftheownership
entityandany5%ofmoreinterestinthatentity,asrequiredbythecityslobbyingordinance.Hehasin
factcompliedwiththatessentialrequirementinthepast,astheCRESPIregistrationshows;therefore,
hewouldnothavetheexcuseofignorance.
Page1of2
Furthermore,nochargeshavebeenbroughtagainsttheresponsibleofficialsattendingthepreservation
boardhearingfornotcheckinghiscredentialsbeforeallowinghimtotestify,asperSection2242(i)of
the city ordinance: (i) All members of the city commission and all city personnel shall be diligent to
ascertainwhetherpersonsrequiredtoregisterpursuanttothissectionhavecomplied.Commissionersor
city personnel may not knowingly permit themselves to be lobbied by a person who is not registered
pursuanttothissectiontolobbythecommissionerortherelevantcommittee,boardorcitypersonnel.
Hereisapartialtimeline:
20070315BV07000621FailuretoRecertifytoCourt
20070518JB07000392LIENfinesimposed$101,223.63
20130726BV13000973ViolationUnsafewithout40year
20130830Deedfrom304SouthBeachLLCtoSeaSprayDevelopmentLLC
20140208AttorneyAppearsinSpecialMasterCase
20140408HPBdiscussesunsafestatusMarreroappearsunregistered,credentialsunchecked
20140516SpecialMasterhaltsfineaccruals
20140708Marreroregistersbeforemeeting
20140708HPBAgendaforcompletedemolition
20140708HBPhearingcompletedemolitionapproved
Exculpatory information may be discovered if this matter is fully investigated, as it should be, in the
interest of justice, assuming that justice is what the Commission actually serves. I am merely offering
thisinformationinthathighinterest.
Sincerely,
DavidArthurWalters
Page2of2
L.
"
City of Miami Beach, 1700 Convention Center Drive, Miami Beach, Florida 33139, www.miamibeachfl.gov
OFFiCE OF THE SPECIAL MASTER
(~05)
Phone: (305) 673-7181 Fax:
673-7254
Special Master Case Synopsis

Case #:
Violation # BV07000621
JB07000392
Current Status: LIEN

Property Address: 304
Balance Due: $101,219.93
(Approximate)
OOEAN DR
Business Name: SIMONE ~EACH CLUB WEST LLC

Owner/Agent: SIMONE BEACH CLUB WEST LLC
Schedule Date Description
Comments
9/20/2007 ALLEGED VIOLATOR
SUBMITTED REQUEST ON 9/20/07 FOR AN EXENTION OF TIME.
9/20/2007 Special Master Hearing
REQUESTING AN EXTENSION OF TIME TO COMPLY---------------A

progress report shall be given on November 16,2007.
2: Today's $76.00 adminstrative courtcost is assessed.
11/14/2007 ALLEGED VIOLATOR

SUBMITTED
LETTER ON 11/14/07 REQUESTING AN EXTENSION OF TIME TO

COMPLY
11/16/2007 Special Master Hearjng
PROGRESS REPORT (REQUESTED ON 11/14/07 AN EXTENSION OF

TIME TO COMPLY)--------------The case was scheduled for 2:00 p.m. The
violator was not present by 8:66 p.m.
,'.
2: The request for an extension of time is DENIED.
..
..
. 3: Today's $76.00 admlnstratlve courtcost is assessed.
12/11/2012 AT THE REQUEST OF . DEPARTMENT, THIS CASE TO BE SCHEDULED BEFORE SM

;
THE BUILDING
1/24/2013 Special Master Hearing
':
~
'.,
"
CASE SCHEDULED AT THE REQUEST OF BUILDING DEPT.------------The casewas scheduled for 2:00 p.rn, The violatorwas not present by 7:00
p.m,
2: There shall be full compliance to correct this violation by February 26,
2013, or a fine of $200.00 a day for each day of noncompliance shall begin
February 26, 2013.
3: Today's $76.00 adminstrative courtcost is assessed.
3/12/2013 AFFIDAVIT OF
NONCOMPLIANCE.
FROM INSPECTOR ARNAU - A fine of $200.00 a day for each day of

noncompliance shall begin February 26, 2013, pursuant to a prior Special
Master Order.
4/29/2013 SENT20 DAY NOTICE

4/29/13
6/20/2013 20 DAYNOTICE
File Lien
j
2/6/2014 ATTORNEY FOR

PROPERTY OWNER
SUBMITTED LETTER ON 1/29/14 REQUESTING TO STOP FINES.
Weare committed to providing excellent publicservice

andsafetyto all wholive, work, andplayIn our vibrant, tropical, historiccommunity.
.,
9/22/201412:27:00 PM
Page 1 of 2
21November2014
NelsonBellido,Esq.,Chairman
MIAMIDADECOMMISSIONONETHICSANDPUBLICTRUST
viaemail
FollowUp:InformationFiledreLobbyistLawViolationsinCityofMiamiBeach
DearMr.Bellido:
Greetings!
AttachedyouwillfindaselfexplanatorycopyofanunacknowledgedInformationfiled
on15OctoberwithCommissiononEthics(COE)directorJoeCentorino,Esq.regardingcauseto
believethatfivelobbyistsviolatedthelobbyistordinanceoftheCityofMiamiBeach.
I understand that the COE has jurisdiction over lobbyist issues, and, upon information
foundorprovided,theCOEmay,withoutacomplaintbeingfiledbyanymemberofthepublic
or public official, proceed with an investigation if the information includes reason to suspect
thatlobbyistshaveviolatedrelevantcodes.
Please advise in writing whether the COE has taken or will take any action on the
Informationfiled,and,ifso,thenatureofthataction.
IfIreceivenoresponsebydeadlineon1December,Ishallassumethatsilenceconfirms
thatithasnotandwillnotactontheInformation(Quitacetconsentirevidetur).
Verytrulyyours,
DavidArthurWalters
Cc:
JoeCentorino,Esq.Director
MiamiDadeCommissiononEthicsandPublicTrust
RaulAguila,Esq.,CityAttorney
CityofMiamiBeach
RafaelGranado,Esq.,Clerk
CityofMiamiBeach
MIAMIMIRRORTRUEREFLECTIONS
26 November 2014
Rafael Granado, Esq.
CITY CLERK
City of Miami Beach
via email
Re: Scott Robins & Lobbyist Registration Irregularities
Dear Sir:
I have discovered three lobbyist registration irregularities during my cursory research into the
affairs of prominent public figure Scott Robins:
Date:
Lobbyist:
Principal:
Issue:
Lobbied:
Violation:
13 September 2010
Scott Robins, Developer
Scott Robins Companies (SRC Properties LLC)
Sunset Harbour Parking Garage
City Commission
Failure to identify person(s) who hold 5% of more interest in principal
Date:
12 February 2012
Lobbyist:
Michael W. Larkin, Attorney
Principal:
Bay Road Partners, LLC
Issue:
Parking District for Sunset Harbour Neighborhood
Lobbied:
Undisclosed
Violation:
Failure to identify person(s) who hold 5% of more interest in principal. Failure to
disclose officials lobbied.
Date:
Lobbyist:
Principal:
Issue:
Lobbied:
Violation:
1 March 2013
Les P. Bellison, Architect
Espanola Way Associates Ltd.
Downsize hotel rooms at 405-419(b) Espanola Way
Board of Adjustment
Failure to identify person(s) who hold 5% of more interest in principal.
As you know, the failure to identify persons who hold a 5% or more interest in principals lobbied
for is a fundamental therefore most serious violation of Sec.2-482 (c) of the Miami Beach Code
of Ordinances. The Preamble of Enabling Ordinance 92-2777 clearly states the intention of the
legislation:
Page1of3
WHEREAS, all citizens of the City of Miami Beach have the right to know how their elected
and appointed officials make decisions and carry out their functions in a manner that guarantees
all actions are taken in the best interests of the City; and WHEREAS, this right of the people to
know includes ascertaining the names of all parties having an interest in the outcome of a
legislative or administrative decision, and who meet with the elected or appointed officials
outside of the public's view; and WHEREAS, in order to continue to restore confidence in the
citizens of Miami Beach that the current Mayor and city Commission will undertake reforms of
past practices that sometimes left in doubt the fairness, openness and honesty of Government, the
Mayor and City Commission wish to pass into law measures to assure that special interests do
not obtain a greater voice in the decisions of the City than the voice an opinion held by any
individual. NOW THEREFORE BE IT ORDAINED.
Twenty-two years later we still have good reason, rooted in long experience with human nature,
to doubt the integrity of our government: it is likely to be unfair, closed, and dishonest if we fail
to question it and get the answers we need.
The following comes to mind in respect to the irregularities I noted above.
The downsizing of the rooms upstairs at 405 thru 419B Espanola Way, to increase the number of
rooms stated from 36 to 44, in order to gain revenue from an additional 8 rooms, was approved
by the Board of Adjustment, File No. 3622. The deed is done: it is too late to have the lobbyist
registration corrected so the public would know everyone who was involved. Curiously, the
county appraiser publishes the total number of rooms for the entire parcel, including the
Espanola Way Suites at 433 Espanola Way, which has another 12 units not counted for the
adjustment, as numbering only 24 units (Folio 02-3234-015-0010). Public access to Permit
Manager has been denied for nearly two weeks now, with no regrets expressed by IT, so I am
unable to ascertain whether the remodeling of the ancient suites, as evident in advertised
photographs, was permitted by the city.
Espanola Way Suites had its application for a certificate of use denied, yet it has been allowed to
operate continuously for nearly three years without a certificate of use or business tax receipt
license, yet the operator of the Sadigo hotel was arrested and had his tenants thrown onto the
street for not having the right kind of license for his hotel, allegedly in retaliation for previously
exposing the corruption of city officials. Mr. Robins was reportedly asked for some missing
engineering information on a change of use, and failed to provide it. Perhaps his secretary missed
the request, and, city officials, having the computer software to blame, forgot to follow up for
three years.
The same goes with the done deal with the city at Sunset HarbourI recall that the agreement
between Mr. Robins interests and the city prohibits the public/private relationship from being
called a partnership. The deed is done; the public is deprived of its right to know: it would be
inutile to cure the defective registration by filling in the blanks now. As you may know,
Page2of3
Commissioner Ed Tobin did reveal that he had a conflict of interest in the Tremont Towing
property on Bay Road because his firm represented Scott Robins Companies, also his campaign
fund contributor. The county ethics commission, after the investigator reduced the charges to
violating the cone of silence in respect to bidding, dismissed case C08-32 with a patronizing
letter instructing officials to seek its advice before doing things that might generate complaints.
It should not just be assumed that Scott Robins owns 100% of every entity lobbied for. It should
be sworn to under penalties of perjury. For all we know, Mr. Tobin or some other deciding
official may have owned either directly or indirectly an interest in the Robins firms that were
involved in the development of the Sunset Harbour neighborhood.
All this is intended to illustrate the gravity of the disclosure requirement, and not suggest any
lack of integrity on the part of Mr. Tobin, for whom the commission waived an ethics
requirement so he could realize his lifelong dream of being a police officer.
I certainly do not question the personal integrity of contractor/developer Scott Robins, who is
publicly heralded as a foremost savior of South Beachs dilapidated historic structures, and
lauded as a most generous philanthropist, a virtuous and diplomatic gentleman of exceeding
integrity.
Nor do I question the integrity of the lawyer and the architect who lobbied for the sake of Mr.
Robins interests in business entities that shield him from personal liability.
No, the issue here is not Scott Robins et al, but due process of law, that the citys officials,
including city clerks, should be most diligent in seeing that everyone, even Scott Robins and his
architects and lawyers, comply with the ordinance, which provides, in part, that the city clerk
may report violations to the county ethics commission for investigation and prosecution.
I do question the integrity of the city government in hopes that my questions will help integrate
the words of its legislation with its deeds. To that end I thank you for your excellent service, and
wish you a Happy Thanksgiving,
Very truly yours,
Cc
Raul Aguila, City Attorney
City of Miami Beach
Nelson Bellido, Chairman
Joe Centorino, Director
Miami-Dade Commission on Ethics and Public Trust
Page3of3
MIAMI BEACH
City of Miami Beach Office of the City Clerk
1700 Convention Center Drive Miami Beach
FL 33139
LOBBYIST REGISTRATION FORM
Lobbyist means all persons employed or retained whether paid or not by a principal who seeks to encourage the passage defeat
or modification of any ordinance resolution action or decision of any commissioner any action decision recommendation of the
City Manager or any city board or committee or any action decision or recommendation of any city personnel during the time
period of the entire decision making process on such action decision or recommendation that foreseeably will be heard or reviewed
by the city commission or a city board or committee The term specifically includes the principal as well as any employee engaged
in lobbying activities The term Lobbyists has specific exclusions Please refer to Ordinance 2004 3435
Larkin
Bercow
Radell
Fernandez
Biscayne Blvd
Number
377 6231
305
W
M 1
First
200 S
P A
BUSINESS NAME AND ADDRESS
305
Michael
Last
NAME OF LOBBYIST
and
Suite 850
Street
Miami
Florida
City
State
377 6222
Zip Code
mlarkin abbrzoninglaw com
FAX NUMBER
TELEPHONE NUMBER
33131
EMAIL
LOBBYIST RETAINED BY
Scott Robins
NAME OF PRINCIPAL CLIENT

Bay Road Partners
230 Fifth Street
LLC

305
Number
674 0600 X309
and
305
TELEPHONE NUMBER
Miami Beach
Street
Florida
674 0619
Zip Code
scott@robinscompanies com
Optional
FAX NUMBER
33139
State
City
EMAIL
Optional
Fill out this section if principal is a Corporation Partnership or Trust Section 2 482 c
NAME OF CHIEF OFFICER PARTNER OR BENEFICIARY
IDENTIFY ALL PERSONS HOLDING
CORPORATION
DIRECTLY OR INDIRECTLY
A 5
OR MORE OWNERSHIP INTEREST IN SUCH
PARTNERSHIP OR TRUST
SPECIFIC LOBBY ISSUE
II
C7
N
0
Proposed Parking District for Sunset Harbor Neighborhood

Issue to be lobbied
Describe in detail
r
Full Name
Planning
Mayor
Individual
Department Staff
and
an
Title
City
Administration
Financial
Familial
or
Professional Rela
nshg9
None
None
members
issue is legislative in
Any
None
City Commission
Planning Board
Unless
of
nature
HPB BOA
Planning Board
and
n
1
CITY AGENCIES INDIVIDUALS TO BE LOBBIED
III
r 7
W
City
Commission
members are not
lobbied
outside of a public
hearing setting
DISCLOSURE OF TERMS AND AMOUNTS OF LOBBYIST COMPENSATION
IV
DISCLOSE WHETHER HOURLY
FLAT RATE OR OTHER

A
LOBBYIST DISCLOSURE
PRINCIPAL S DISCLOSURE
445 00
Required
445 00
Required
OF LOBBYIST COMPENSATION
The following information must be answered
Pursuant to Miami Beach City Code Section 2 488 Entitled Prohibited Campaign Contributions By Lobbyists
On Procurement Issues
Yes X No
Are you lobbying on a present or pending bid for goods equipment or services or on a
present or pending award for goods equipment or service
Pursuant to Miami Beach City Code 2 490 Entitled Prohibited Campaign Contributions By Lobbyists On Real
Estate Development Issues
Are you lobbying on a pending application for a Development Agreement with the City or
Yes X No
application for change of zoning map designation or change to the City s Future Land Use
Man
3
Pursuant to Miami Beach City Code 2 484 h Any person except those exempt from the definition of
lobbyist as set forth in Section 2 481 above who only appears as a representative of a not for profit
corporation or entity without special compensation or reimbursement for the appearance whether direct or
indirect to express support of or opposition to any item shall register with the clerk as required by this
section but shall not be required to pay any registration fees
Yes X No
Are you representing a not for profit corporation or entity without special compensation
or reimbursement
SIGNATURE UNDER OATH
ON OCTOBER 1ST OF EACH YEAR

STATEMENT
RECEIVED
UNDER
OATH
EACH LOBBYIST SHALL SUBMIT TO THE CITY CLERK A SIGNED
LISTING
LOBBYING
IN THE CITY OF MIAMI BEACH
EXPENDITURES
AS
WELL
AS
COMPENSATION
FOR THE PRECEDING CALENDAR YEAR
A STATEMENT
SHALL BE FILED EVEN IF THERE HAVE BEEN NO EXPENDITURES OR COMPENSATION DURING THE
REPORTING PERIOD
Sig
tutt of Lobbyist
I do solemnly swear that all of the foregoing facts are true and correct and that I have read or am
familiar with the provisions contained in Section 2 482 of the Miami Beach City Code and all reporting
requirements
Signature of Lobbyist
Signature of Principal Client
l
LOBBYIST IDENTIFICATION
VI
4
A
r
PRINCIPAL IDENTIFICATION
Form
of
uS
Produced ID
Produced ID
Identification
Form of Identification
ari
XPersonally
State
of
Sworn
This
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I Personally known Principal
Lobbyist
Florida
County
of
o and subscribed
re of
PL6k
2012
Notary
State
of
Lobbyist Registration Form

CLER
Yes
No
received and verified
ALL MARIA M Lobbyist LOBBYIST fORM 05 doc
Florida
County
Signa ture6fPublic
Florida
of
Miami Dade
tary
State of Florida
Notarization of Principal s signature
signature
FOR CLERR
Annual Registration fee
of
Sworn aad subscribed before me

This Ada of E
2012
U
me
clay of
State
Miami Dade
before
Notarization of Lobbyist s
N
STAMP O F NOTARY
SIGNATURE AND
O
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known
Amount Paid
by
SNLY
MCR
Date Paid
Entered By
Revised 12 08 04
t A
City of Miami Beach 1700 Convention Center Drive Miomi beach Florida 33 i 39 www miamibeachtLgov
CITY CLERK Office
Tel 305 b 3 7411
CityC1er1c@miami6eachf1 gov
Fax 305 673 7254
LOBBYIST NAME
MICHAEL
LARKIN
I understand that no later than February 28th of each year I must file the following form pursuant
to Section 2 485 of the Miami Beach City Code with the City Clerk s Office for all active lobbying
issues
Lobbyist Expenditure and Compensation Form
Failure to file these forms on a timely basis will result in my name being transmitted to the Miami Dade
County Commission on Ethics and for code violation evaluation
In
have
lobby on has been

immediately notify the City Clerk s Office of lobbyist withdrawal in writing
addition
once
an
issue
registered
to
Im
r
Signature
Date
resolved
I am required to
N 1 A M I B EAC H
l

1700 Convention Center Drive Miami Beach FL 33139
Lobbyist means all persons employed or retained whether paid or not by a principal who seeks to encourage the passage defeat or
modification of any ordinance resolution action or decision of any commissioner any action decision recommendation of the City
Manager or any city board or committee or any action decision or recommendation of any city personnel during the time period of the
entire decision making process on such action decision or recommendation that foreseeably will be heard or reviewed by the city
commission
or a city board or committee
The term specifically includes the principal as well as any employee engaged in lobbying
h
ctivities
LobbyWt
term
ha
specific exclusions
Please refer to Ordinance 2004
Z
NAME OF LOBBYIST
Last
0 10 1 F
First
Number
and
M 1
I it
y
Street
State
Zip Code
TELEPHONE NUMBER
FAX NUMBER
EMAIL
aim
Please notify this office if your contact information changes address phone or e mail address
I
LOBBYIST FZETAINED BY
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NAM
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ANP
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ADDRESS
Number
and
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TELEPHONE NUMBER
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Optional
IDENTIFY ALL PERSONS HOLDING DIRECTLY OR INDIRECTLY A 5
K0
tin
13 I
OR MORE OWNERSHIP INTEREST IN SUCH CORPORATION
CrIno L
B Y ISSU
IN
ao
Issue to be lobbied Describe in detail
Ill CITY AGE NCIESIINDIVIDUALS TO BE LOBBIED

Pursuant to City Code Section 2 482 a 4 include the commissioner or personnel sought to be lobbied and whether the lobbyist has entered
into any contractual relationship paid or unpaid with said city commissioner or personnel from 12 months preceding such person s
commencement of service with the city to the present date stating the general nature of the subject contractual relationship
Sec 2 482 a 4 Full Name of Individual and
Contractual Relationship Explain
YES
NO
title of p rson to be I bbied
1
Pursuant to City Code Section 2 482 g Every registrant shall be required to state the extent of any business financial familial or professional
relationship or other relationship giving rise to an appearance of an impropriety with any current city commissioner or city personnel who is
sought to be lobbied as identified on the lobbyist registration form filed
Sec 2 482 g Any Financial Familial or Professional Relationship

r
IN
C Users clerhatMppData Local Microsoft Windows Temporary Internet Files Content Outlook 83LGQDDH Lobbyist Registration
Formrevised 5 30 2012 doc
IV
DISCLOSURE OF TERMS AND AMOUNTS OF LOBBYIST COMPENSATION DISCLOSE WHETHER HOURLY FLAT RATE OR OTHER
LOBBYIST DISCLOSURE
PRINCIPAL S DISCLOSURE OF LOBBYIST COMPENSATION
Required
0J
t
REQUIRED

1
Pursuant to Miami Beach City Code Section 2 488 Entitled Prohibited Campaign Contributions By Lobbyists On Procurement
Issues
No
Yes
Are you lobbying on a present or pending bid for goods equipment or services or on a present or pending
award for goods equipment or service
Pursuant to Miami Beach City Code Section 2 490 Entitled Prohibited Campaign Contributions By Lobbyists On Real Estate
Development Issues
Yes
No
Are you lobbying on a pending application for a Development Agreement with the City or application for
change of zoning map designation or change to the City s Future Land Use Map
Pursuant to Miami Beach City Code Section 2 482 h Any person except those exempt from the definition of lobbyist as set
forth in Section 2 481 above who only appears as a representative of a not for profit corporation or entity without special
compensation or reimbursement for the appearance whether direct or indirect to express support of or opposition to any
tem shall register with the clerk as required by this section but shall not be required to pay any registration fees
Yes
No
Are you representing a not for profit corporation or entity without special compensation or reimbursement
ON FEBRUARY 28 OF EACH YEAR EACH LOBBYIST SHALL SUBMIT TO THE CITY CLERK A SIGNED STATEMENT UNDER
OATH LISTING LOBBYING EXPENDITURES AS WELL AS COMPENSATION RECEIVED IN THE CITY OF MIAMI BEACH FOR
THE PRECEDING CALENDAR YEAR
A STATEMENT SHALL BE FI ED EVEN IF THERE HAVE BEEN NO EXPENDITURES OR
COMPENSATION DURING THE REPORTING PERIOD
I do solemnly
that
swear
in Section 2 482
of
e foreg ing facts are true and correct and that I have read or am familiar with the provisions containe
all of
the Mi
each
ode and all
requirements
reporting
SATC ELL
Signature
of Lobbyist
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SIGNATURE AND STAMP OF NOTARY

J
State
of
Florida
Sworn to
County
of
aaqsubscribed
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Signature
Notarization
Miami Dade
before
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State
Notary
Lobbyist
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s signature
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No
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Personally
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State of Florida County of Miami Dade

Sworn atA subscribed befo e me
2012
day of 1 k 1
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State of Florida
Notarizatio of Principal s signature
TO BE COMPLETED BY CITY CLERK S STAFF ONLY

M CR
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Amount Paid
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Revised 04 2712012
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LB
City of Miami Beach 1700 Convention Center Drive Miami Beach Florida 33139 www miamibeachfl gov
CITY CLERK Office
Rafael E
Granado
Tel 305 673 7411
City
Clerk
CityClerk@miamibeachfl gov
Fax 305 673 7254

P
LOBBYIST NAME
I understand that no later than February 28 of each year I must file the following form
pursuant to Section 2 485 of the Miami Beach City Code with the City Clerk s Office for
all active lobbying issues
LOBBYIST EXPENDITURE AND COMPENSATION FORM
Failure to file these forms on a timely basis will result in my name being transmitted to
the Miami Dade County Commission on Ethics and for code violation evaluation
In
issue I have
registered to lobby on has been resolved or I am no

lobbying on that issue or for that principal I am required to immediately notify
the City Clerks Office of lobbyist withdrawal in writing
addition
once an
longer
Pursuant to Section 2 485 d
City Clerk shall notify any lobbyist or principal who

fails to timely file a Statement and in addition to any other penalties which may be
imposed as provided in Section 2 485 1 a fine of 50 00 a day shall be assessed for all
Statement s filed after the due date
The City Clerk shall notify the Miami Dade
County Commission on Ethics and Public Trust of the failure of a lobbyist or principal
to file the Statement or pay the assessed fines after notification
Any
lobbyist
automatically
to
appealed
who
fails to file the
suspended
a
the
required
Statement
by
April 30th
shall be
from
Miami Dad
lobbying until all fines are paid unless the fine has been
County Commission on Ethics and Public Trust
A
Signature
2012
201
Date
C Users clerhatl AppData Local Microsoft Windows Temporary Internet Files Content Outlook 83LGQDDH Lobbyist Registration
NIN
Q4
p
LL
CO
m
o
pc
kk
15October2014
JoeCentorino,Director
MIAMIDADECOUNTYCOMMISSIONONETHICSANDPUBLICTRUST
19WestFlagler,Suite820
Miami,Florida33130
INFORMATION:ProbableLobbyistLawViolationsinCityofMiamiBeach
Mr.Centorino:
PleasefindattachedinformationregardingprobablelobbyistlawviolationsoftheCityofMiami
BeachsLobbyistCodebythefollowingpersons:
20120501
BillEagerfor
forTRGAlaskaIIILLC
FailuretoidentifyChiefPersonand5%orMoreOwnershipInterest(s)
20120501
CharlesSieger
forTRGAlaskaIIILLC
20140408
MichaelJ.Marrero
forSeaSprayDevelopmentLLC
FailuretoregisteraslobbyistyetpermittedtolobbybeforetheHistoricPreservationBoard
20140708
MichaelJ.Marrero
forSeaSprayDevelopmentLLC
(Exampleprovidedofhiscomplianceelsewhere)
Page1of2
20110517
JoshuaM.Benaim
for321OceanHoldingLLC
20120709
JamesW.Carse
for321OceanHoldingLLC
TheCityofMiamiBeachhasevidentlybeenremissindiligentlyenforcingitslobbyistordinance
in crucial provisions, at least in respect to these lobbyists and their principals. It may also be
negligent in providing for effective penalties and adequate remedies so that the goal of
compliancewillmorelikelybeobtainedinthefuture.
ThiscommunicationcomprisesanInformation,andnotaComplaint,thereforeyouareleftto
act on your own initiative according to your conscience while the lobbying industry and the
publicwatches.
Respectfullysubmitted,
DavidArthurWalters
Cc
NelsonBellido,Chairman
MIAMIDADECOMMISSIONONETHICSANDPUBLICTRUST
Page2of2
26 November 2014
Rafael Granado, Esq.
CITY CLERK
City of Miami Beach
via email
Re: Scott Robins & Lobbyist Registration Irregularities
Dear Sir:
I have discovered three lobbyist registration irregularities during my cursory research into the
affairs of prominent public figure Scott Robins:
Date:
Lobbyist:
Principal:
Issue:
Lobbied:
Violation:
13 September 2010
Scott Robins, Developer
Scott Robins Companies (SRC Properties LLC)
Sunset Harbour Parking Garage
City Commission
Failure to identify person(s) who hold 5% of more interest in principal
Date:
12 February 2012
Lobbyist:
Michael W. Larkin, Attorney
Principal:
Bay Road Partners, LLC
Issue:
Parking District for Sunset Harbour Neighborhood
Lobbied:
Undisclosed
Violation:
Failure to identify person(s) who hold 5% of more interest in principal. Failure to
disclose officials lobbied.
Date:
Lobbyist:
Principal:
Issue:
Lobbied:
Violation:
1 March 2013
Les P. Bellison, Architect
Espanola Way Associates Ltd.
Downsize hotel rooms at 405-419(b) Espanola Way
Board of Adjustment
Failure to identify person(s) who hold 5% of more interest in principal.
Page1of4
As you know, the failure to identify persons who hold a 5% or more interest in principals lobbied
for is a fundamental therefore most serious violation of Sec.2-482 (c) of the Miami Beach Code
of Ordinances. The Preamble of Enabling Ordinance 92-2777 clearly states the intention of the
legislation:
WHEREAS, all citizens of the City of Miami Beach have the right to know how their elected
and appointed officials make decisions and carry out their functions in a manner that guarantees
all actions are taken in the best interests of the City; and WHEREAS, this right of the people to
know includes ascertaining the names of all parties having an interest in the outcome of a
legislative or administrative decision, and who meet with the elected or appointed officials
outside of the public's view; and WHEREAS, in order to continue to restore confidence in the
citizens of Miami Beach that the current Mayor and city Commission will undertake reforms of
past practices that sometimes left in doubt the fairness, openness and honesty of Government, the
Mayor and City Commission wish to pass into law measures to assure that special interests do
not obtain a greater voice in the decisions of the City than the voice an opinion held by any
individual. NOW THEREFORE BE IT ORDAINED.
Twenty-two years later we still have good reason, rooted in long experience with human nature,
to doubt the integrity of our government: it is likely to be unfair, closed, and dishonest if we fail
to question it and get the answers we need.
The following comes to mind in respect to the irregularities I noted above.
The downsizing of the rooms upstairs at 405 thru 419B Espanola Way, to increase the number of
rooms stated from 36 to 44, in order to gain revenue from an additional 8 rooms, was approved
by the Board of Adjustment, File No. 3622. The deed is done: it is too late to have the lobbyist
registration corrected so the public would know everyone who was involved. Curiously, the
county appraiser publishes the total number of rooms for the entire parcel, including the
Espanola Way Suites at 443 Espanola Way, which has another 12 units not counted for the
adjustment, as numbering only 24 units (Folio 02-3234-015-0010). Public access to Permit
Manager has been denied for nearly two weeks now, with no regrets expressed by IT, so I am
unable to ascertain whether the remodeling of the ancient suites, as evident in advertised
photographs, was permitted by the city.
Espanola Way Suites had its application for a certificate of use denied, yet it has been allowed to
operate continuously for nearly three years without a certificate of use or business tax receipt
license, yet the operator of the Sadigo hotel was arrested and had his tenants thrown onto the
street for not having the right kind of license for his hotel, allegedly in retaliation for previously
exposing the corruption of city officials. Mr. Robins was reportedly asked for some missing
engineering information on a change of use, and failed to provide it. Perhaps his secretary missed
the request, and, city officials, having the computer software to blame, forgot to follow up for
three years.
Page2of4
The same goes with the done deal with the city at Sunset HarbourI recall that the agreement
between Mr. Robins interests and the city prohibits the public/private relationship from being
called a partnership. The deed is done; the public is deprived of its right to know: it would be
inutile to cure the defective registration by filling in the blanks now. As you may know,
Commissioner Ed Tobin did reveal that he had a conflict of interest in the Tremont Towing
property on Bay Road because his firm represented Scott Robins Companies, also his campaign
fund contributor. The county ethics commission, after the investigator reduced the charges to
violating the cone of silence in respect to bidding, dismissed case C08-32 with a patronizing
letter instructing officials to seek its advice before doing things that might generate complaints.
It should not just be assumed that Scott Robins owns 100% of every entity lobbied for. It should
be sworn to under penalties of perjury. For all we know, Mr. Tobin or some other deciding
official may have owned either directly or indirectly an interest in the Robins firms that were
involved in the development of the Sunset Harbour neighborhood. As a matter of fact, Mr.
Robins, in a press report on the Sunset Harbour deal with the city, said that Philip Levine is my
partner in everything. (Miami Magazine, Astute Awakening, October 24, 2012)
All this is intended to illustrate the gravity of the disclosure requirement, and not suggest any
lack of integrity on the part of Mr. Tobin, for whom the commission waived an ethics
requirement so he could realize his lifelong dream of being a police officer.
I certainly do not question the personal integrity of contractor/developer Scott Robins, who is
publicly heralded as a foremost savior of South Beachs dilapidated historic structures, and
lauded as a most generous philanthropist, a virtuous and diplomatic gentleman of exceeding
integrity.
Nor do I question the integrity of the lawyer and the architect who lobbied for the sake of Mr.
Robins interests in business entities that shield him from personal liability.
No, the issue here is not Scott Robins et al, but due process of law, that the citys officials,
including city clerks, should be most diligent in seeing that everyone, even Scott Robins and his
architects and lawyers, comply with the ordinance, which provides, in part, that the city clerk
may report violations to the county ethics commission for investigation and prosecution.
I do question the integrity of the city government in hopes that my questions will help integrate
the words of its legislation with its deeds. To that end I thank you for your excellent service, and
wish you a Happy Thanksgiving,
Very truly yours,
Cc
Page3of4
Raul Aguila, City Attorney, City of Miami Beach

Nelson Bellido, Chairman, Joe Centorino, Director
Miami-Dade Commission on Ethics and Public Trust
Page4of4
30September2014
RafaelGranado
CityClerk
CITYOFMIAMIBEACH
Subject:LobbyistRegistrationandOurGoal
DearMr.Granado:
Thank you for allowing an ordinary person to participate in your government. It is for that
reasonthatIhaveagreatdealofrespectforyourofficeunderyoursupervisionaswellasthat
of your predecessor, the good Mr. Parcher, whom was known for his dogged independence
despitethecitysbranchlessormonolithicconstitution.
2014-09-29 Email: Rafael Granado to David Arthur Walters. Mr. Walters. Thank you for
bringing this matter to our attention. Our goal is to have the form(s) completed accurately
by the applicant, lobbyist and/or principal, As soon as that is done, they will be scanned
and posted. Rafael Granado
ItiswithindependenceinmindthatImustsaywithallduerespectthatIdonotknowwhom
ourmeanswhenyoustatethatourgoalistohavethefatallydefectivelobbyistregistration
formscompletedbysomeoneatsomeunspecifieddate.Isuspectthatourexcludesmostof
thecommunity.IhadaskedwhenyouwillreferthemattertotheEthicsCommission,asour
lobbyingordinanceprovidesyouwiththediscretiontodothat.
Icertainlyamlookingforwardtobeingalertedonthearrivaloftheinformationastowhoowns
10%ofmoreofthisAlaskanmemberoftheRelatedGroupcontrolledbybillionaireJorgeM.
Perez,thedeveloperbehindthehugeSouthPointedevelopmentsgobblingupthelastacresof
scarceopenspaceforthebenefitofwealthyinternationalclientele.
I hope that I and anyone else interested do not have to search the records everyday of the
workweektodiscoverthatinformationsomeday.
IfIwereclerk,Iwouldsetafivedaycompliancedeadline.Complianceisminimalornilwithout
punishment. The natural persons involved here know better. They know why the community
Page1of2
wantstoknowwhoisbehindrealestatedevelopersfaades,andyettheyhavescoffedatthe
lawexpressedclearlyonthelobbyistregistrationformitself.Theyknewbetter,andnowisthe
timeforthecitytoshowthatittakesthepeopleswillexpressedinlawsseriouslyenoughto
enforcethem.
Weareplaguedbynoncomplianceinthiscity.Thefaultliesnotonlywithcityofficialsbutwith
the ethics commission and the county board of commissioners, not to mention the state
attorneyandattorneygeneralandgovernor.Ipraythatyoumayincludeeveryonewithinyour
our,andactindependentlyofthewillofJimmyMorales,PhilipLevine,JorgeM.Perez,and
theClintons.
Sincerely,
Page2of2
Defective Filing on TRG ALASKA Defective Lobbyist Registration
SEPTEMBER 27, 2014
10:58 AM
David Arthur Walters <miamimirror@gmail.com>

to Rafael Granado, Joseph Centorino, Raul Aguila,
Mr. Granado:
Please advise approximately when your staff will have completed its research, and
when the matter will probably be referred to the Ethics Commission.
As explained before, the 5% or more stake information and name of the person
controlling is very important information that should not be left off the registration form.
The perhaps coincidental word "Alaska" in TRG Alaska piques my interest because
I am personally familiar with the nature of Alaska, and because a prominent Miami
Beach official had his company investigated for fraud there.
As you can see from a sample below, other persons have rightfully expressed an
interest in who is involved in Mr. Perez' companies with 'Alaska' in the rubric.
The failure to fill out the forms as required should subject the party to the maximum
penalty. Perhaps a daily fine should be imposed on the lobbyists whose forms have
already been inadvertently accepted by the clerk, calculated from the time of
acceptance until the time the information is revealed.
Thank you,
Defective Filing on TRG ALASKA Defective Lobbyist Registration
Granado, Rafael <RafaelGranado@miamibeachfl.gov>
Tue, Sep 23, 2014 at

11:45 AM
To: David Arthur Walters <miamimirror@gmail.com>

Cc: "Centorino, Joseph (COE)" <CENTORI@miamidade.gov>, "Aguila, Raul"
<RaulAguila@miamibeachfl.gov>, "Granado, Rafael"
<RafaelGranado@miamibeachfl.gov>
Thankyou.Iwillaskmystafftoreviewandfollowup
Regards,
MIAMIBEACH
Rafael E. Granado, Esq., CityClerk.
From: David Arthur Walters [mailto:miamimirror@gmail.com]
Sent: Tuesday, September 23, 2014 11:27 AM
To:Granado, Rafael
Cc:Centorino, Joseph (COE); Aguila, Raul
Subject: TRG ALASKA Defective Lobbyist Registration
Granado, Rafael <RafaelGranado@miamibeachfl.gov>
To: David Arthur Walters <miamimirror@gmail.com>
<RaulAguila@miamibeachfl.gov>
Thankyou.Iwillaskmystafftoreview.
Regards,
MIAMIBEACH
Rafael E. Granado, Esq., CityClerk
Additional Defective Filing on TRG ALASKA Defective Lobbyist Registration

2 messages
Tue, Sep 23, 2014 at 11:34

AM
To: "Granado, Rafael" <RafaelGranado@miamibeachfl.gov>

Dear Mr. Granado:
Attached please find another defective filing (attached), Charles Sieger's 2012-05-01
Lobbyist Registration Form giving TRG ALASKA III as principal in the 801
South Pointe (MAREA) project but without identifying those with a greater than 5%
ownership interest and who is in charge of the company as required by law.
If there is no correction on file for this fatally defective registration, please follow the
provision set forth in our lobbying ordinance and forward it to the Miami Dade
County Commission on Ethics and Public Trust for disposition.
This will make a half-dozen I have referred to you. There are probably many more,
and from lobbyists who know better.
Thank you for your usual excellent service.
On Tue, Sep 23, 2014 at 11:26 AM, David Arthur Walters
<miamimirror@gmail.com> wrote:
Dear Mr. Granado:
Attached please find Bill Eager's 2012-05-01 Lobbyist Registration Form giving TRG
ALASKA III as principal in the 801 South Pointe (MAREA) project but without
identifying those with a greater than 5% ownership interest and who is in charge of
the company as required by law.
I have already remarked, in previous submissions of defective registrations, on the
importance of providing the information.
If there is no correction on file for this fatally defective registration, please follow the
provision set forth in our lobbying ordinance and forward it to the Miami Dade
County Commission on Ethics and Public Trust for disposition.
Thank you for your usual excellent service.
MIAMI
commission or a city board or committee

activities
The term
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LOBBYIST NAME
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the City Clerk shall notify any lobbyist or principal who

fails to timely file a Statement and In addition to any other penalties which may be
Imposed as provided in Section 2 485 1 a fine of 50 00 a day shall be assessed for all
Any lobbyist who fails to file the required Statement by April 30th 2012 shall be
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lobby on has been resolved I am
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Lobbyist Michael J. Marrero

Thu, Sep 4, 2014 at 11:08

AM
To: "Granado, Rafael" <RafaelGranado@miamibeachfl.gov>

Cc: "Held, Gary" <garyheld@miamibeachfl.gov>, "Aguila, Raul"
4 September 2014 to Clerk of City of Miami Beach
Dear Mr. Granado:
Attached please find Michael J. Marrero's July 8 registration as lobbyist for 304
Ocean Drive property owner Sea Spray Development LLC. His registration appears
to be three months late, in violation of lobbying ordinance: he appears on the April 8
video of the April 8 Historic "Preservation" Board.
Perhaps there has been a clerical error in not recording a registration for April 8. If
not, then it is astonishing to me that he was allowed to testify under oath before the
Board, since officials there are required by the ordinance to exercise due diligence at least I recall the word "diligent" in the code - which would require checking
credentials in advance when a lobbyist signs a log before the hearing.
Furthermore, Mr. Marrero does not make the necessary disclosures of persons
holding directly or indirectly an interest in the LLC, a fact that arouses my suspicion
because he is an experienced lobbyist, doing a tremendous amount of business on
the beach, and is licensed by the Florida Bar; the ordinance and the registration form
itself clearly require the information; other registration forms filed by him, including
the example I attach hereto, his filing for 8421 Crespi LLC, include the required
information.
Furthermore, one inducement offered by developer David Arditi to city officials for
the spot zoning of 321 Ocean Drive across the street was his promise to cause 304
Ocean Drive to be developed with foreign funds obtained. As you will recall, two
lobbyists for 321 Ocean Drive, developer Joshua Benaim and architect James
Carse, also failed to provide information on the substantial interests persons held in
that property's owner, the managing member being a Delaware entity unregistered
at the time in Florida.
So now the failures to supply the required information appear to be a pattern rather
than coincidence; a pattern apparently contributed to by official negligence.
I do not understand why the clerks would have accepted the forms absent the
required information. Disclosure and its publicity are intended to help the public and
its investigators ascertain the identity of the natural persons involved in public
Page1of2
business and their sources of funds.

Indeed, this information, especially where foreign entities, foreign cash, and foreign
architects are involved, should be just as important to Board members as to whether
or not a design is "foreign" to some current historical context.
That is not to say that I believe that the developers are not "nice boys," as Frank Del
Vecchio has informed me. Given the fact that even nice boys next door are
occasionally arrested for serious crimes, I believe it is better to obtain as much
information as can be had about them.
Please let me know what steps will be taken to remedy these issues so that I may
inform my dozen or so constituents in Miami Beach.
Sincerely,
cc.
Raul Aguila, City Attorney
Gary Held, First Assistant City Attorney
Page2of2
Lr
MIAMI BEACH
entire
city
decision making
cmmission
lobbying
process
on
such
action
decision or recommendation that foreseeably will be heard or reviewed by the

employee engaged in
city board or committee

The term specifically includes the principal as well as any
The term Lobbyists has specific exclusions Please refer to Ordinance 2004 3435
or
activities
Marrero
NAME OF LOBBYIST
Bercow Radell
Michael
Last
Fernandez PA
200 South Biscayne Blvd
First
Number
305 374 5300
and
Street
M I
Suite 850 Miami FL
City
305 377 6222
TELEPHONE NUMBER
33131
State
Zip Code
brzoninolaw com
mmarrero
FAX NUMBER
EMAIL
I
Yair Wolff
NAME OF PRINCIPAUCLIENT
Sea
Spray Development LLC
3180
Number
TELEPHONE NUMBER
Stirling
and
Road
Hollywood
Street
FAX NUMBER
Florida
City
33021
State
Optional
EMAIL
Zip Code
Optional

Development Board Approvals for 304 Ocean Drive Miami Beach Florida

into
any
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paid
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unpaid
with
said
city
commissioner
or
from
personnel
12 months preceding such
person s commencement of service with the city to the present date stating the general nature of the subject contractual relationship
Sec 2 482
a 4 Full Name of Individual

title of person to be lobbied
Tanning
Department
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Yes
No
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in Section 2 481 above who only appears as a representative of a not for profit corporation or entity without
forth
special
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whether
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to
express
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or
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fees
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OATH
LISTING LOBBYING EXPENDITURES
ME THE
AS WELL AS COMPENSATION RECEIVED
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AAIAMIBEACH
City
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Miami Beach
1700 Convention Center Drive Miami Beach Florida 33139 www miamibeachfl gov
CITY CLERK Office

Rafael E
Tel
Granado
305 673 7411
City
Fax
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LOBBYIST NAME
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that
understand
305 673 7254
Michael J
no
Marrero
later than February 28 of each year

I
of the Miami Beach
City Code with
to Section 2 485
pursuant
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the City Clerk s Office for all
active lobbying issues

1
Failure to file these forms on a timely basis will result in my name being transmitted to the
Miami Dade County Commission on Ethics and for code violation evaluation
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modification of
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FAX NUMBER
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Florida
State
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EMAIL
Pierre Elmaleh
NAME OF PRINCIPAL CLIENT
8421 Crespi LLC
407 Lincoln Rd Ste 9D Miami Beach
Number and Street
TELEPHONE NUMBER
FAX NUMBER
City
FL
33139
State
Zip Code
Optional
EMAIL
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See Attached
DIRECTLY OR INDIRECTLY A 5
See Attached
II SPECIFIC LOBBY ISSUE

Development Board Approvals for 8421 Crespi Boulevard Miami Beach
Issue to be lobbied
Describe in detail
Ill CITY AGENCIES INDIVIDUALS TO BE LOBBIED

into
contractual
any
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YES
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Pierre Elmaleh
100
Rebond LLC
Michel Besnier
100
Miscellaneous Cash Receipt

CITY OF MIAMI BEACH
Cash
0 Credit Card
check
20
Received
A1
of
kC
Alf
Address
For
Ilya
pt
liq
ra
4f
Office of Finance Director
THIS INFORMATION MUST BE COMPLETED
By
Account Number
Pr P arer
Dept
EXT
40
MIAMI MIRROR TRUE LOBBYING REFLECTIONS
FILE:321OCEANENRIQUENORTEN
August19,2014
To:DavidArthurWalters
Cc:"Aguila,Raul""Prieto,Silvia""Hatfield,Liliam"
Thankyou.WewillreviewandcontactLobbyisttoupdate.
Regards,
MIAMIBEACH
RafaelE.Granado,Esq.,CityClerk
CITYCLERK'SOFFICE
1700ConventionCenterDrive,
MiamiBeach,FL33139
19August2014
RafaelGranado,Clerk
CITYOFMIAMIBEACH
Subject:2011JoshuaBenaimDefectiveLobbyistRegistration
Mr.Granado:
AttachedpleasefindPDFoflobbyistregistrationformnamingJoshuaBenaimaslobbyist.
Bysomestrangecoincidence,hisprincipalhappenstobethesameasMr.Carse's,namely,the
Delawareentity321OceanHoldingLLC.AlthoughithasanaddressonBrickell,itapparentlyhas
nolegalstandinginFloridasinceitisnotlistedonourSecretaryofState'swebsiteasoftoday.
Would you please ask this lobbyist to amend his application to name the persons with
controllingandownershipinterests?Irealizethesameentityisprincipalforbothlobbyists,but
I wish to compare their separate answers with the information I have for consistency before
publication.
Thankyou!
DavidArthurWalters
August15,2014
GoodmorningMr.Walters,
Thankyouforbringingthismattertoourattention.
Wewillrequestthelobbyisttoamendhisapplicationtoanswerallquestions.
Regards,
MIAMIBEACH
15August2014
RafaelGranado
CLERK
CityofMiamiBeach
Subject:PRRre9July2012JamesW.CarseLobbyistRegistration
DearMr.Granado:
GoodDay,Sir.
Attached please find the sworn Lobbyist Registration Form executed by lobbyist James W.
Carse,an architect employed by Enrique Nortens New York firm, TenArquitectos, and by an
officeroftheprincipal,321OceanHoldingLLC,aDelawareentitythenunregisteredinFlorida,
beingthemanagingmemberoftheownerofthepropertyat321OceanDrive,knownbythe
projectnameof321OceanEnriqueNorten.Theidentitiesofbothpersonswereverifiedbythe
notarybytheirNewYorkdriverslicenses.
Asyouknow,theMiamiBeachCodeofOrdinances,Sec.2482(c),Registration,mandatesthat,
If the lobbyist represents a corporation, partnership or trust, the chief officer, partner or
beneficiary shall also be identified. Without limiting the foregoing, the lobbyist shall also
identifyallpersonsholding,directlyorindirectly,afivepercentormoreownershipinterestin
suchcorporation,partnership,ortrust.
For all intents of purposes of this clause, a limited liability company is considered as a
corporationorpartnershipsinceitisasortofhybridofthetwotypesofbusinessentity,and
DelawarelistsLLCsasatypeofcorporation.
TheLobbyistRegistrationFormitselfdoesnotidentifythechiefofficer,partnerorbeneficiary
andallpersonsholding,directlyorindirectly,afivepercentormoreownershipinterestinsuch
corporation,partnership,ortrust,eventhoughtheformitselfclearlydemandstheinformation,
andtheoathunderpenaltiesofperjuryassertsfamiliarityofthesignatorieswiththelobbying
code:IdosolemnlyswearthatalloftheforegoingfactsaretrueandcorrectandthatIhave
readoramfamiliarwiththeprovisionscontainedinSection2482oftheMiamiBeachCityCode
and611reportingrequirements.
It appears to me that an incomplete form absent that information of great public interest is
tantamounttoafailuretoregistereventhoughitwasacceptedandinitialedbyacityclerk.
WhereforethisismyChapter119requestforanyswornLobbyistRegistrationFormthathasall
theinformation,trueatthattime,asrequiredbytheordinanceandtheformitself.
Intheeventthatyouhavenosuchform,andifIamnotmistakenastothelaw,Iwillappreciate
youradviceaswhatactionyouwilltaketoobtainaproperlyfilledoutformposthaste,orto
refer the matter to the Miami Dade Commission on Ethics and Public Trust as per Sec. 2485
Listofexpenditures;feedisclosure;reportingrequirements,(e)Thecityclerkshallnotifythe
MiamiDade County Commission on Ethics and Public Trust of the failure of a lobbyist (or
principal)tofileeitherofthereportsreferenced above[registrationandexpenditure]and/or
paytheassessedfinesafternotification.
Although I am not required to disclose my identity or intent for making this request, please
knowthatmyinterestissimplythepublicityoftheinformation.Ihadadvocatedthepublication
ofthatkindofinformation,notknowingthatlegislationalreadymandatedit.
BestRegards,
DavidArthurWalters
IAMIBEACH
M
activities The term Lobbyists has specific exclusions Please refer to Ordinance 2004 3435
NAME OF LOBBYIST
Last
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81
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umber and
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TELEPHONE NUMBER
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FAX NUMBER
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EMAIL
Please notify this office if your contact information changes address phone or e
mail address
I
C 02
cl
Number and Street
TELEPHONE NUMBER
City
FAX NUMBER
State
Optional
Zip Code
EMAIL Optional
Fill out this section if principal is a Corporation Partnership or Trust Section 2

482 c
c
IDENTIFY ALL PERSONS HOLDING DIRECTLY OR
INDIRECTLY
A 5 OR MORE OWNERSHIP INTEREST IN SUC
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a
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s
Sec 2482
4 Full Name of Individual and
a
Contractual
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YES
NO
OA
by
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Pursuant to C
ty
relationship
r other relationship giving rise to an a pearance of an impropriety with any current city commissioner or city personnel who is
Code Section 2 482

g
Every regist
t shall be required to state the extent of any business financial familial or professional
Sec 2482
g Any Financial Familial or Professional Relationship
IV
DISCLOSURE OF TERMS AND AMOUNTS OF LOBBYIST COMPENSATION DISCLOSE WHETHER HOURLY FLAT RATE OR
OTHER
LOBBYIST DISCLOSURE
Required
B PRINCIPAL
S DISCLOSURE OF LOBBYIST COMPENSATION
Rquired
The
estn
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C utit dam
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UV
following information must be answered

Pursuant to Miami Beach City Code Section 2
488 Entitled Prohibited Campaign Contributions By Lobbyists On Procurement
Issues
Yes
l No
Pursuant to Miami Beach City Code 2 490 Entitled Prohibited Campaign Contributions By Lobbyists On Real Estate
Dev opment Issues
Yes
No
change of zoning map designation or change to the City
s Future Land Use Map
Pursuant to Miami Beach City Code 2484 h Any person except those exempt from the definition of lobbyist as set forth in
Section 2
481 above who only appears as a representative of a not for profit corporation or entity without special
comp
sation or reimbursement for the appearance whether direct or indirect to express support of or opposition to any
Yes
V
No Are you representing a notforprofit corporation or entity without special compensation or reimbursement
ON FEBRUARY 28th OF EACH YEAR EACH LOBBYIST SHALL SUBMIT TO THE CITY CLERK A SIGNED STATEMENT UNDER
A STATEMENT
LL BE
ILED
N IF THERE HAVE BEEN NO EXPENDITURES OR

oe
I do solemnly swear that

in Section 2 482 of the M
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TO BE COMPLET D BY CITY CLERK

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Annual
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1VICR
CLER ALL a FORMS LOBBYIST FORMS Lobbyist Annual Registration Form

doc
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Date Paid
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Revise
11
11
CA
MIAMJBEACH
BEACH
City of Miami Beach 1700 Convention Center Drive Miami Beach Florida 33139 www
gov
miamibeachfl
CITY CLERK Office
Tel 673
305
7411
CityClerk@miamibeachfl
gov
Fax 673
305
7254
LOBBYIST NAME
understand that no later than February 28th of each year I must file the following
form pursuant to Section 2485 of the Miami Beach City Code with the City Clerk
s
Office for all active lobbying issues
1
Failure
file these forms
on a timely basis will result in my name being transmitted to the

MiamiDade County Commission on Ethics and for code violation evaluation
In
to
addition
issue I have
registered
lobby on has been resolved I am required

to immediately notify the City Clerk
s Office of lobbyist withdrawal in writing
gna
once an
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to
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MIA
IBEACH

activities
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Fill out this section If principal is a Corporation Partnership or Trust Section 2 482 c

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Describe in detail
ui CITY AGENCIEVINDIVIDUALS TO BE LOBBIED

commencement of service with the city to the present date stating the
Sec 2 482
4 Full Name
of
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eneral nature of the subject contractual relationship

Contractual Relationship
and
Explain
YES
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0
1
Sec 2 482
Any
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ALL a FORM S LOBBYIST FORMS Lobbyist Registration Form doc

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D19CLOSUVE OF TERMS AND AMOUNTS OF LOBBYIST COMPENSATION
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LOBBYIST DISCLOSURE
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DISCLOSE WHETHER HOURLY FLAT RATE OR OTHER
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PRINCIPAL S DISCLOSURE OF LOBBYIST COMPENSAT ON

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in Section 2 482 of the Miami Beach City Code and 611 reporting requirements
VI
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Amount Paid
day
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nature
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TO BE COMPLETED BY CITY CLERK S STA F O

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This
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Miami Dade
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and subscribed
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Date Paid

F
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ALL
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S LOB BYI ST FORMS Lobbyist Registration Form doc
ReviS d 04 27 2012
MIANAIBEACH
City of Miami Beach 1700 Convention Center Drive Miami Beach Florida 33139 www miamibeochfl gov
CITY CLERK Office
Rafael E Granado
City
Tel 305 673 741 1
Fax 305 673 7254
Clerk
CityClerkCmiamibeachfl gov
LOBBYIST NAME
1
In addition once an issue I have registered to lobby on has been resolved or I am no

longer lobbying on that issue or for that principal I am required to immediately notify
the City Clerk s Office of lobbyist withdrawal in writing

Any
lobbyist
who
fails to file the
required
Statement
by
April 30th
2012
shall be
20l2
Date
Signature
CADocuments
and
Settings
clermarm
Local Settings
Temporary
Internet Files OLK11 Lobbyist Registration Formrevised 5 30 2012 doc
MIAMI-DADE CoMM1SSION ON ETHICS & PUBLIC TRUST
PROBABLE CAUSEMEMORANDUM
To:
Miami-Dade CountyCommission on Ethics andPublic Trust
From:
MichaelP. Murawski, Advocate
Re:
. Michael J. Marrero C15- 08
Date:
Recommendation:
Probable Cause exits to believe that Respondent, Michael J. Marrero, violated Section2-482ofthe
City of Miami Beach Coderegarding lobbyistregistration.'
Background and Investigation;
The COEreceived information that Respondent failed to register to lobbyon behalf of Sea Spray
Development, LLC (Sea Spray) at the Historic PreservationBoard (HPB) meeting held on April 8, 2014, in
the City of Miami Beach.
A COEinvestigator contacted the Respondent. He does not deny appearing before-the HPB on April
4, 2014. Respondent explainedthat he and his fum were retained on {ill emergency issue by principal Yair
Wolff of Sea Spray.
Sea Spray had just purchasedthe building located at 304 Ocean Drive when they were notified by the City of
Miami BeachBuilding Departmentthatthe building was goingto be demolished. Sea Spray did not want the
Probable Cause exists where there are reasonablytrustworthy facts and circumstances for the
Commission onEthics and Public Trust(COE) to conclude that Respondentshould be chargedwith
violating Section2-482 of the Cityof Miami Beach Codeconcerning lobbyistregistration.
1
COMMISSION ON ETHICS & PUBLIC TRUST

MIAMI-DADE COUNTY
IN
ETHICS COMPLAINT
RE:
C 15-08
MICHAEL MARRERO
RESPONDENT
-----~----~/
Petitioner,the Advocatefor the Miami-Dade County Commission on Ethics and Public Trust,
files this Complaint against Michael Marrero for violating Miami. Beach City Code, Chapter 2,
Article VII, Division 3 entitled "Lobbyists," Sec. 2-482 Registration.
STATEMENT OF JURISDICTION
1.
The MtamicDade County Commission on Ethics and Public Trust (COE) has
jurisdiction pursuant to Sections 2-1068 and 2-1072(a)(3) of Code of Miami-Dade County.

2.
Investigation determined that on or about April 8, 2014, Respondentappeared
beforethe City of Miami BeachHistoric PreservationBoard (HPB)on behalf of \principal Yair

Wolff of Sea Spray Development, LLC (Sea Spray).
3.
Respondentdoes not deny appearingbefore the HPB on April 8,2014.
4.
A reviewof the April 8, 2014 HPB meeting shows that Respondentappeared
before-the HPB, announced his appearance, and advisedthat his firm had just been retained by
the owner of the property in question(304 Ocean Drive). Further, Respondentmade it clear that
he was seeking the support of the HPB and was requesting that they recommend, to the Unsafe
Structure Board, not to proceed with a demolition of the property.
5.
Thus, it is clearthat Respondent was attempting to encourage the "action,
decision, recommendation of ... any city board.
Liborio Prosperi, House of Commons Lobby (1886)

August 30, 2014
Gary Held
First Assistant City Attorney
CITY OF MIAMI BEACH
Subject: Revision of Lobbying Code Sorely Needed
Dear Mr. Held:
Thank you for revising the instructions for lobbyists and others, read out at the outset of
meetings, now to include the requirement that persons representing nonprofit associations
such as condominium boards without compensation file letters with the city clerk, as per this
section of the city code:
2-481 Definitions. Lobbyist means all persons employed or retained, whether
paid or not. "lobbyist" specifically excludes the following persons: any person
who only appears as a representative of a any person who only appears as a
representative of a neighborhood association without compensation or
reimbursement; and any person who only appears as a representative of notfor-profit community based organization for the purpose of requesting a grant
1 | Suggested Lobbying Ordinance Revisions / David Arthur Walters
without special compensation or reimbursement for the appearance. The

persons specifically excluded above from the definition of "lobbyist" shall, prior
to communicating with subject city personnel, disclose in writing to the city
clerk, their name, address, and principal on whose behalf they are
communicating.
Now pardon me for being so bold as to suggest that the code itself be revamped from top to
bottom, as was regularly done with the Roman civil code by the ancient Roman clerks to correct
anomalies, insert new legislation, codify the legal fictions, which dissatisfaction with strict
construction had made necessary, and to render the whole more cogent.
1. The requirement that unpaid representatives for nonprofits file letters with the clerk
should be eliminated unless an efficient means for determining who they are is codified.
For example, take the case of my local activist hero, Frank Del Vecchio Esq. Ret., who has
served as a sort of shadow city attorney for some years now. I inquired into the nature of his
role, in the matter of the ad hoc legislation that spot zoned the property at 321 Ocean Drive for
the exclusive benefit of the developers and owners. He wrote the first draft of the zoning
amendment and lobbied vigorously for its passage. The city planners and lawyers greatly relied
upon his opinion as well as the opinion of the clients lawyers at Greenberg Traurig led by High
Rise Power Lawyer Lucia Dougherty, who disclosed $700 per hour as her compensation.
First of all, I considered whether he was practicing law without a license when lobbying for the
cause. I decided in the negative, for any official who takes a lobbyists words for granted is a
fool deserved by his or her constituents, and, the city is presumably protected from bad legal
advice not only by its own attorneys but by the fact that most legislators are lawyers
themselves.
Secondly, I considered whether or not he should have registered as a lobbyist since he seemed
to walk and talk like a lobbyist. A confidential source close to the matter said that the venerable
city clerk now retired thought he was in fact violating the lobbying ordinance, but a
discretionary decision was made not to prosecute him for not registering.
Thirdly, I considered whether he should have filed a letter with the clerk identifying him as the
president and representative of the condominium association of the property next door to 321
Ocean Enrique Norten. After all, in his July 10, 2011, letter to the mayor and commissioners, he
represented the board of the 301 Ocean Drive Condominium Association, Inc., as its president.
I questioned Mr. Del Vecchio about his representation in general, and he identified himself as
an advocate for the community at large.
Now you and I know that lawyers dominate society dominantly for the power elite mostly
concerned with its own perspective on law and order, and that their dialectical practice renders
them, whether they are retired or active, experts cavilers; therefore, the profession has a way
of exempting clients and especially itself from the assiduous application of ethical standards
except to curb competition of upstarts among themselves. However that may be, I doubt
whether anyone with jurisdiction would care to assiduously investigate this exemplary esquire
to determine if there is probable cause that he violated the lobbying ordinance, and to
prosecute him if such determination were had.
Lacking some efficient way of resolving anyones claim that s/he is just an individual
representing her own interest or that of the community, perhaps the requirement for
registration with the clerk be dropped, since that has been the informal practice. I see there is
no such requirement under Floridas lobbying code:
Fla. Stat. 11.045 (8) Lobbying before the Legislature; registration and reporting;
exemptions; penalties.
(1) (f) Lobbying firm means any business entity, including an individual contract
lobbyist, which receives or becomes entitled to receive any compensation for
the purpose of lobbying, where any partner, owner, officer, or employee of the
business entity is a lobbyist.
(g) Lobbyist means a person who is employed and receives payment, or who
contracts for economic consideration, for the purpose of lobbying, or a person
who is principally employed for governmental affairs by another person or
governmental entity to lobby on behalf of that other person or governmental
entity.
2. Any lobbyist who fails to register before lobbying should be subject to the same daily fines
imposed on lobbyists who fail to file their annual fee and expense reports.
Take for example, the April 8, 2014, appearance of Michael T. Marrero before the Historic
Preservation Board in the matter of the utter demolition of the structure at 401 Ocean Drive
he swore there was no intention to completely destroy the building; complete demolition was
apparently the objective to begin with (accomplished by approval of the Board on July 8) as can
be seen by Luis Revueltas grand renderings; the demolition proceeded August 28.
Curiously, the Lobbyist Logs of Jul 23 and August 27 do not show Mr. Marrero registered for his
304 Ocean Drive advocacy until July 8, three months after his April 8 appearance before the
board. Now the clerk may find some error in my reading of the log or perhaps a clerical error in
recording registrations on the logs, but please assume for the sake of argument that his
registration was made three months late.
Would he be assessed approximately $4,500 in fines at $50 per day for late filing, as is specified
under the city code for already registered lobbyists who fail to file their fee and expense
reports? Apparently not, if my reading of the ordinance is correct. He would be subject to the
penalties imposed by the county ethics commission, an entity that is notorious for its
prosecutorial indiscretions, erroneous opinions, violations of Sunshine Law while sitting, and
inequitable and prejudicial imposition of penalties. That is not to say that the ethics staff and
the commission member do not have good intentions, which is all that Immanuel Kant required
of anyone to do their duty.
Am I correct in saying that the law now provides only a possible wrist slap, or maybe a little
more from the county ethics commission depending on who is involved, of someone does not
register at all, yet the city imposes $50 a day find for failure to file annual reports after
someone does register? If that is true, is this absurdity intentional legislative legerdemain? If
not, let those who fail to register in time be subject to the same $50 per day fine, and make the
fines mandatory or not to be waived without defined good causes.
3. Subject anyone who fails to provide material information or provides misinformation on
their registration forms to a stiff mandatory fine.
The state provides such a penalty for lobbyists within its jurisdiction:
Fla. Stat. 11.045 (8) Lobbying before the Legislature; registration and reporting;
exemptions; penalties.
(8) Any person required to be registered or to provide information pursuant to
this section or pursuant to rules established in conformity with this section who
knowingly fails to disclose any material fact required by this section or by rules
established in conformity with this section, or who knowingly provides false
information on any report required by this section or by rules established in
conformity with this section, commits a noncriminal infraction, punishable by a
fine not to exceed $5,000. Such penalty shall be in addition to any other penalty
assessed by a house of the Legislature pursuant to subsection (7).
I notice that Mr. Marrero did not reveal the identities of those who control and/or have a
greater than 10% stake in his principal, Sea Spray Development LLC, as required on the
registration form and by law. He has made such disclosures for other principals. I suppose he
might claim that he represents Yair Wolf, who apparently presides over Sea Spray, and not the
LLC. That might not wash with an unsympathetic lawyer.
I have pointed out to the clerk two other failures to reveal such substantial information, on the
part of a developer and an architect both lobbying for 321 Ocean Enrique NortenMr.
Norten is the unlicensed master designer on the 321 Ocean Drive Project, with Luis Revuelta
covering with his license.
The lobbyists for 321 promised to bring in foreign funds to develop blighted 304 across the
street, which they apparently did, but flipped it at an ostensibly handsome profit to the current
vested interests, whosoever they might be. The managing member of 321, the principal the
lobbyists represented, is a Delaware holding company unregistered in Florida. I imply nothing
illegal here such as secrecy for money laundering activities although that is something publicity
of the required information is intended to curb. Perhaps the reason for the Delaware holding
company involves Delaware law, say, that allows principals to expressly preclude fiduciary
responsibility, or some other legally evasive maneuver.
The importance of knowing who owns and controls developments in our community is
obviously material to its interests, although that knowledge may not be sufficient to curb
nefarious activities. Wherefore stiff fines should be imposed on any failure to do so.
As it is, the clerk has asked the 321 Ocean Enrique Norten developer and the architect to
amend their lobbying registration forms instead of referring the matter to the county ethics
commission as the ordinance seems to require.
4. The city lobbying ordinance should make a correct reference to penalties under the county
ethics code.
I have already taken this matter up with City of Miami Beach Attorney Raul Aguila. And I have
pointed out that a particular section of our code does not seem to require the clerks reference,
of failure of nonprofit lobbyists to file letters with the clerk, to the ethics commission, hence
there is no penalty where there should be one if obedience is wanted.
2-481(d) The city clerk shall notify any lobbyist (or principal) who fails to timely
file the expenditure or fee disclosure reports referenced in sections (a) and (b)
above [fee and expenditure reports]. In addition to any other penalties which
may be imposed as provided in section 2-485.1 [those penalties set forth within
subsections 2-11.1(s) and (z) of the Metropolitan Dade County Code but (z)
does not apply see instead (cc)], a fine of $50.00 per day shall be assessed for
reports filed after the due date. Any lobbyist who fails to file the required
expenditure report by April 30 shall be automatically suspended from lobbying
until all fines are paid, unless the fine has been appealed to the Miami Dade
County Ethics Commission.
Again, the city code provides for penalties, other than the fines for late filings, by reference to
an apparently inapplicable clause (z) section of the county code, when it should refer to clause
(cc).
2-11.1(s) (cc) Penalty. (1) Proceeding before Ethics Commission. A finding by the
Ethics Commission that a person has violated this section shall subject said
person to an admonition or public reprimand and/or a fine of five hundred
dollars ($500.00) for the first such violation and one thousand dollars ($1,000.00)
for each subsequent violation. Where the Ethics Commission finds that a person
has intentionally violated this section and determines that a fine is appropriate,
said person shall be subject to a fine of one thousand dollars ($1,000.00) for the
first such violation and two thousand dollars ($2,000.00) for each subsequent
violation. Actual costs incurred by the Ethics Commission, in an amount not to
exceed five hundred dollars ($500.00) per violation, may be assessed where the
Ethics Commission has found an intentional violation of this section. The Ethics
Commission may also order the person to pay restitution when the person or a
third party has received a pecuniary benefit as a result of the person's governed
by an administrative order adopted by the County Commission and rules of
procedure promulgated by the Ethics Commission.
5. Lobbyists should be required to file withdrawals when they become inactive in any matter.
I understand from the clerk that lobbyists who do not file the annual fee and expense reports
required by the ordinance, and who have not already voluntarily filed withdrawals, are simply
dropped from the active list.
If officials are not diligent to ascertain whether or not someone before them is actually active,
that person may continue with representation here and there and get away with it absent
watchdogs at every turn such as the taxmen depicted in the musical, Popeye (1980). No doubt
there have been many instances of an absence of the exercise of diligence due. The
requirement to sign logs before seeing someone may be overlooked. Those logs could be made
electronic, and should be published online the next day. The lobbyists at hears should definitely
log in prior to the hearing, and their credentials should be checked.
In any event, lobbyists should be required to notify the city when they become inactive, and
their failure to do so should result in a fine of $500.
6. Code should clearly specify that a separate fee must be paid for each registration.
That may already be the procedure. Perhaps you may point out where that is clearly specified
in the code. An anonymous inside source has told me that is often not being done, so that
favored attorneys with many cases are not overburdened by fee expenditures.
Now, then, I am sure that your law revision council would propose even more improvements in
the lobbyist ordinance. And perhaps the council would take up revising the Byzantine sidewalk
caf ordinance that results in appearances of impropriety, seemingly discriminatory
enforcement that might have to be defended in federal court. Also the signage code needs to
be overhauled, something I have already commented on to high official in vain.
I apologize in advance for any misstatements I may have inadvertently made, and pray you will
correct them.
Sincerely,
Cc. Raul Aguila, Esq.

Cc. Frank Del Vecchio, Esq.
301 Ocean Drive Condominium Association, Inc.

301 Ocean Drive, Miami Beach, FL 33139
July 10, 2011

Mayor and Commissioners, City of Miami Beach
1700 Convention Center Drive
Miami Beach, FL 33139
SUBJ: Agenda Item R7G, July 13,2011 City Commission Agenda: Charter Height
Referendum for Nov. 1, 2011 Election
Dear Mayor and Commissioners:
In the event you enact the ordinance placing a Charter height referendum requirement on
the November 1, 2011 ballot, we request that May 1, 2012 be the effective date.
A May 1, 2012 date will enable the zoning amendment now in process for our district to
satisfy the city's lengthy notice and public hearing requirements.
The enactment of this zoning is essential for a condominium on the 321 Ocean Drive
vacant lot to be feasible - a great asset for our neighborhood and our community.
For the immediate neighbors in particular, a condo is a much sought after alternative to a
hotel on the site, less than fifteen feet from the 325 Ocean Drive condo, and twenty feet
from our building. A condo would be wholly compatible with our historic residential
district. A hotel would not. A hotel's accessory use restaurants and facilities would have
to be serviced solely from Ocean Drive, since there is no rear alley service access. The
traffic and servicing impacts would be severe for the adjacent properties and adverse to
the entire neighborhood.
Our condo association joins with our neighbors, East Atlantic Gardens Condo at 325
Ocean Drive, and Sholom House Condominium at 260 Ocean Drive, in a request that the
city commission take the actions necessary for the pending zoning of our district to
proceed without the fatal burden of a citywide voter referendum.
VOTED: 301 Ocean Drive Condominium Association Board ofDirectors, July 10,2011
Frank Del Vecchio, President

For the Board
LUDC#19
Lr
MIAMI BEACH
entire
city
decision making
cmmission
lobbying
process
on
such
action

employee engaged in
city board or committee

The term specifically includes the principal as well as any
The term Lobbyists has specific exclusions Please refer to Ordinance 2004 3435
or
activities
Marrero
NAME OF LOBBYIST
Bercow Radell
Michael
Last
Fernandez PA
200 South Biscayne Blvd
First
Number
305 374 5300
and
Street
M I
Suite 850 Miami FL
City
305 377 6222
TELEPHONE NUMBER
33131
State
Zip Code
brzoninolaw com
mmarrero
FAX NUMBER
EMAIL
I
Yair Wolff
Sea
Spray Development LLC
3180
Number
TELEPHONE NUMBER
Stirling
and
Road
Hollywood
Street
FAX NUMBER
Florida
City
33021
State
Optional
EMAIL
Zip Code
Optional

Development Board Approvals for 304 Ocean Drive Miami Beach Florida

into
any
contractual
relationship
paid
or
unpaid
with
said
city
commissioner
or
from
personnel
12 months preceding such
Sec 2 482
a 4 Full Name of Individual

Tanning
Department
B HPB BOA
City
and
Building
Commission
Contractual
and
Department Staff
None
as
None
necessary
Relationship
Explain
YES
NO
X
X

G
I t
Nil 101
cl IP
C Users clerhatl AppData Local Microsoft Windows Temporary Internet Files Content 0utlook 83LGQDDH Lobbyist Registration
IV
A
LOBBYIST DISCLOSURE
Required
445 00
REQUIRED
445 00

1
Issues
Yes
No
Are you lobbying on a present or pending bid for goods equipment or services or on a present or
award for aoods eauinment or service
pe
Development Issues
Yes
No
Are you lobbvina on a pending application for a Development Agreement with the City or application
in Section 2 481 above who only appears as a representative of a not for profit corporation or entity without
forth
special
compensation
or
reimbursement
for
the
appearance
direct
whether
or
indirect
to
express
support
of
or
opposition to any item shall register with the clerk as required by this section but shall not be required to pay any registration
fees
Yes
X No
OATH
LISTING LOBBYING EXPENDITURES
ME THE
AS WELL AS COMPENSATION RECEIVED
PRECEDING
EXPENDITURES OR
Sign
I do solemnly swear that all of the

in Section 2 482 of the Miami B
foregoing fa
C
re
ure efLobbyist
a and correct and that I have read or am familiar with the provisions contained
all rep rting requirements
VI
Produced ID
odn
Form
P ersonall
known
Form
Lobbyist

i
State
of
Florida
Sworn to
nd
This
Sign
County
of
of
re of
Notarization
blic
of
Notary
Lobbyist
jj
State
2014
of
o
co

Sworn
d subscribed
is
Signature f
Notarizati n
Amount Paid
ay
ubli
MCR
Notary
of
fore
me
2014
of
State of Florida
signature
iy
Datq Paid

C Users clerhatl AppData Local Microsoft Windows
cto
Florida
No
coz
g
0
s signature
Yes
TO BE COMPLET D BY CITY CLERK S STAFFiON

Identification
3
3 X
eore me
L
subscrijjj
y
o a
Miami Dade
of
ZPersonally
K o
o
VII
Produced ID
Identification
of
Temporary Internet
Files Content Outlook 83LGQD
H Lobbyist Registration
CLE
istration Form doc
Revised 04 27 2012
AAIAMIBEACH
City
of
Miami Beach
1700 Convention Center Drive Miami Beach Florida 33139 www miamibeachfl gov
CITY CLERK Office

Rafael E
Tel
Granado
305 673 7411
City
Fax
Clerk
LOBBYIST NAME
I
that
understand
305 673 7254
Michael J
no
Marrero
later than February 28 of each year

I
of the Miami Beach
City Code with
to Section 2 485
pursuant

the City Clerk s Office for all

1
In
addition
lobbying
once an
on
issue I have
or for that
that issue
registered
principal

fails to timely file
imposed
the
City
to
lobby
on
has been
or I am no longer
resolved

Clerk
shall
notify any lobbyist
or principal
who
a Statement and in addition to any other penalties which may be
in Section 2 485 1 a fine of

50 00 a day shall be assessed for all
CountY Commission on Ethics and Public
b c Trust of the failure of a lobb
lobbyist or principal
as provided

Any lobbyist
automatically
appeal
Signature
who
fails to file the required Statement

from lobbying until all fines are
suspended
he Mia
ade
County Commission
on
by April 30th 2012

paid
Ethics
and
shall
be
unless the fine has been

Public Trust
lc dl v
ate
CFormrevised
Users clerhatl
AppData Local Microsoft Windows Temporary Internet Files Content Outlook 83LGQDDH Lobbyist Registration
5 30 2012 doc
CV
kAs
till
LU
Nom
cc
lion
O
LL
FILE:321OCEANENRIQUENORTEN
August19,2014
Thankyou.WewillreviewandcontactLobbyisttoupdate.
Regards,
MIAMIBEACH
CITYCLERK'SOFFICE
1700ConventionCenterDrive,
MiamiBeach,FL33139
19August2014
RafaelGranado,Clerk
CITYOFMIAMIBEACH
Subject:2011JoshuaBenaimDefectiveLobbyistRegistration
Mr.Granado:
AttachedpleasefindPDFoflobbyistregistrationformnamingJoshuaBenaimaslobbyist.
Bysomestrangecoincidence,hisprincipalhappenstobethesameasMr.Carse's,namely,the
Delawareentity321OceanHoldingLLC.AlthoughithasanaddressonBrickell,itapparentlyhas
nolegalstandinginFloridasinceitisnotlistedonourSecretaryofState'swebsiteasoftoday.
Would you please ask this lobbyist to amend his application to name the persons with
controllingandownershipinterests?Irealizethesameentityisprincipalforbothlobbyists,but
I wish to compare their separate answers with the information I have for consistency before
publication.
Thankyou!
DavidArthurWalters
August15,2014
GoodmorningMr.Walters,
Thankyouforbringingthismattertoourattention.
Wewillrequestthelobbyisttoamendhisapplicationtoanswerallquestions.
Regards,
MIAMIBEACH
15August2014
RafaelGranado
CLERK
CityofMiamiBeach
Subject:PRRre9July2012JamesW.CarseLobbyistRegistration
DearMr.Granado:
GoodDay,Sir.
Attached please find the sworn Lobbyist Registration Form executed by lobbyist James W.
Carse,an architect employed by Enrique Nortens New York firm, TenArquitectos, and by an
officeroftheprincipal,321OceanHoldingLLC,aDelawareentitythenunregisteredinFlorida,
beingthemanagingmemberoftheownerofthepropertyat321OceanDrive,knownbythe
projectnameof321OceanEnriqueNorten.Theidentitiesofbothpersonswereverifiedbythe
notarybytheirNewYorkdriverslicenses.
Asyouknow,theMiamiBeachCodeofOrdinances,Sec.2482(c),Registration,mandatesthat,
If the lobbyist represents a corporation, partnership or trust, the chief officer, partner or
beneficiary shall also be identified. Without limiting the foregoing, the lobbyist shall also
identifyallpersonsholding,directlyorindirectly,afivepercentormoreownershipinterestin
suchcorporation,partnership,ortrust.
For all intents of purposes of this clause, a limited liability company is considered as a
corporationorpartnershipsinceitisasortofhybridofthetwotypesofbusinessentity,and
DelawarelistsLLCsasatypeofcorporation.
TheLobbyistRegistrationFormitselfdoesnotidentifythechiefofficer,partnerorbeneficiary
andallpersonsholding,directlyorindirectly,afivepercentormoreownershipinterestinsuch
corporation,partnership,ortrust,eventhoughtheformitselfclearlydemandstheinformation,
andtheoathunderpenaltiesofperjuryassertsfamiliarityofthesignatorieswiththelobbying
code:IdosolemnlyswearthatalloftheforegoingfactsaretrueandcorrectandthatIhave
readoramfamiliarwiththeprovisionscontainedinSection2482oftheMiamiBeachCityCode
and611reportingrequirements.
It appears to me that an incomplete form absent that information of great public interest is
tantamounttoafailuretoregistereventhoughitwasacceptedandinitialedbyacityclerk.
WhereforethisismyChapter119requestforanyswornLobbyistRegistrationFormthathasall
theinformation,trueatthattime,asrequiredbytheordinanceandtheformitself.
Intheeventthatyouhavenosuchform,andifIamnotmistakenastothelaw,Iwillappreciate
youradviceaswhatactionyouwilltaketoobtainaproperlyfilledoutformposthaste,orto
refer the matter to the Miami Dade Commission on Ethics and Public Trust as per Sec. 2485
Listofexpenditures;feedisclosure;reportingrequirements,(e)Thecityclerkshallnotifythe
MiamiDade County Commission on Ethics and Public Trust of the failure of a lobbyist (or
principal)tofileeitherofthereportsreferenced above[registrationandexpenditure]and/or
paytheassessedfinesafternotification.
Although I am not required to disclose my identity or intent for making this request, please
knowthatmyinterestissimplythepublicityoftheinformation.Ihadadvocatedthepublication
ofthatkindofinformation,notknowingthatlegislationalreadymandatedit.
BestRegards,
DavidArthurWalters
IAMIBEACH
M
activities The term Lobbyists has specific exclusions Please refer to Ordinance 2004 3435
NAME OF LOBBYIST
Last
First
f1 8 kiLae
81
Oc
@C5
umber and
Street
6
C3
TELEPHONE NUMBER
I
M
City
Ma
State
NefV
ch
FAX NUMBER
33 3
Zip Code
Oaidl o
EMAIL
Please notify this office if your contact information changes address phone or e
mail address
I
C 02
cl
Number and Street
TELEPHONE NUMBER
City
FAX NUMBER
State
Optional
Zip Code
EMAIL Optional
Fill out this section if principal is a Corporation Partnership or Trust Section 2

482 c
c
IDENTIFY ALL PERSONS HOLDING DIRECTLY OR
INDIRECTLY
A 5 OR MORE OWNERSHIP INTEREST IN SUC
CORPORA9N
rri

n
d t t
Issue to be lobbied
Describe
ry
32
JC
A
ov
in de
T
nl
Pursuant to City Code Section 2482

4 include the commissioner or personnel sought to be lobbied and whether the
a
1bbb91t has entered
into any contractual relationship paid or unpaid with said city commissioner or personnel from 12 months preceding such person
s
Sec 2482
4 Full Name of Individual and
a
Contractual
Relationship Explain
YES
NO
OA
by
I en
Pursuant to C
ty
relationship
r other relationship giving rise to an a pearance of an impropriety with any current city commissioner or city personnel who is
Code Section 2 482

g
Every regist
t shall be required to state the extent of any business financial familial or professional
Sec 2482
g Any Financial Familial or Professional Relationship
IV
DISCLOSURE OF TERMS AND AMOUNTS OF LOBBYIST COMPENSATION DISCLOSE WHETHER HOURLY FLAT RATE OR
OTHER
LOBBYIST DISCLOSURE
Required
B PRINCIPAL
S DISCLOSURE OF LOBBYIST COMPENSATION
Rquired
The
estn
tI
C utit dam
1C
UV
following information must be answered

Pursuant to Miami Beach City Code Section 2
488 Entitled Prohibited Campaign Contributions By Lobbyists On Procurement
Issues
Yes
l No
Pursuant to Miami Beach City Code 2 490 Entitled Prohibited Campaign Contributions By Lobbyists On Real Estate
Dev opment Issues
Yes
No
change of zoning map designation or change to the City
s Future Land Use Map
Pursuant to Miami Beach City Code 2484 h Any person except those exempt from the definition of lobbyist as set forth in
Section 2
481 above who only appears as a representative of a not for profit corporation or entity without special
comp
sation or reimbursement for the appearance whether direct or indirect to express support of or opposition to any
Yes
V
No Are you representing a notforprofit corporation or entity without special compensation or reimbursement
ON FEBRUARY 28th OF EACH YEAR EACH LOBBYIST SHALL SUBMIT TO THE CITY CLERK A SIGNED STATEMENT UNDER
A STATEMENT
LL BE
ILED
N IF THERE HAVE BEEN NO EXPENDITURES OR

oe
I do solemnly swear that

in Section 2 482 of the M
of the
foregoing
m Beach Cit
facts
are
Sign
ure
true
Id c rect and that I have read or am familiar with the provisions contained
obbyist
e and all reporting requirements
io
Signature of PrincipalClien
VI
LOBBYIST IDENTIFICA
El
ID
Y 61
ON
CA
IQ
aProduced IDS DI
Personally
VII
known
Lobbyist
Personally
ptttiltttiiiiel
SSio
NOT
c

Sworn to and subscribed before me
This
201
day of
DD 832367
GOMMiSSIpN
Principal
a 1I d
D8
State of Florida Count of Miami ga
236
3
Sworn and subscribed before me
mro
9o
I
This
j day of
r
z
known
tllltiiiii
e
i
2011O
Ga
ti
e
ll
9iit
ub
Si nature of Public Notary

St a
Florida
Notarization of Lobbyists signature
i
U
A
QC STATE
41
gi91ti110
16
Signatur
of
ub
ublic
Notary
State of
lorida
Notarization of Principal
s signature
TO BE COMPLET D BY CITY CLERK

S STAFF ON
Y
Annual
Registration
fee
Lobbyist Registration
F
No
Amount Paid
Form received and verified by
Yes
5
t
1VICR
CLER ALL a FORMS LOBBYIST FORMS Lobbyist Annual Registration Form

doc
ir
Date Paid
1
Revise
11
11
CA
MIAMJBEACH
BEACH
City of Miami Beach 1700 Convention Center Drive Miami Beach Florida 33139 www
gov
miamibeachfl
CITY CLERK Office
Tel 673
305
7411
CityClerk@miamibeachfl
gov
Fax 673
305
7254
LOBBYIST NAME
understand that no later than February 28th of each year I must file the following
form pursuant to Section 2485 of the Miami Beach City Code with the City Clerk
s
Office for all active lobbying issues
1
Failure
file these forms
on a timely basis will result in my name being transmitted to the

MiamiDade County Commission on Ethics and for code violation evaluation
In
to
addition
issue I have
registered
lobby on has been resolved I am required

to immediately notify the City Clerk
s Office of lobbyist withdrawal in writing
gna
once an
i
ers
ure
to
D te
MIA
IBEACH

activities
The term
Lobbyists
First
T0 V AVZ Jx05
54
ll5
6ZO
Last
NAME OF LOBBYIST
Zliz
Number
and
ti1EW Ok
A4e
Street
M 1
NV
10610 3
State
City
Zip Code
S
oix4 y
FAX NUMBER
TELEPHONE NUMBER
ca
EMAIL
I
32 1
CtAIU
7O0
Q
y3
Number
305
534
1a I
A t
and
Street
State
City
Zip Code
6
FAX NUMBER
TELEPHONE NUMBER
Optional
EMAIL
Optional
Fill out this section If principal is a Corporation Partnership or Trust Section 2 482 c

3Z 1
yel V E
Issue to be lobbied
np JF rf
Describe in detail
ui CITY AGENCIEVINDIVIDUALS TO BE LOBBIED

commencement of service with the city to the present date stating the
Sec 2 482
4 Full Name
of
Individual
eneral nature of the subject contractual relationship

Contractual Relationship
and
Explain
YES
NO
M0
0
1
Sec 2 482
Any
Financial Familial
or
Professional
J A 111
Relationship
I
loll
0 9
F CLER
ALL a FORM S LOBBYIST FORMS Lobbyist Registration Form doc

J
D19CLOSUVE OF TERMS AND AMOUNTS OF LOBBYIST COMPENSATION
IV
Required
LOBBYIST DISCLOSURE
i4r
DISCLOSE WHETHER HOURLY FLAT RATE OR OTHER
12L
PRINCIPAL S DISCLOSURE OF LOBBYIST COMPENSAT ON

UO
REQUIRED
P t l tt1 JT
M V r L

1
Issues
YesiNo
Development Issues
Yes
tNo
Ye4No
in Section 2 482 of the Miami Beach City Code and 611 reporting requirements
VI
4 Lic
l
AeuJ
YP
Produced ID
roduced
ID
Personally
known
2K
Lobbyist
Personally
Principal
known
State
of
Florida
Sworn to
County
befgre
me
Signature
f Public
on of
St
Lobbyist
s s
a of
State
Sworn and subscribed bQfore me

Thi
Florida
of
No
Amount Paid
day
of
Wiz
2012
Signature
Public Nota
State of Floridan
nature
yes
County
Florida
TO BE COMPLETED BY CITY CLERK S STA F O

Miami Dade
wD
2012
This
Notariza
Miami Dade
of
and subscribed
g
U O M J
QR4
VII
Lic
Form o Identification
MCR
Date Paid

F
CLER
F CLE R
ALL
aFORMS
ALL
LOBBYIST FORMS
a FORM
S LOB BYI ST FORMS Lobbyist Registration Form doc
ReviS d 04 27 2012
MIANAIBEACH
City of Miami Beach 1700 Convention Center Drive Miami Beach Florida 33139 www miamibeochfl gov
CITY CLERK Office
Rafael E Granado
City
Tel 305 673 741 1
Fax 305 673 7254
Clerk
CityClerkCmiamibeachfl gov
LOBBYIST NAME
1
In addition once an issue I have registered to lobby on has been resolved or I am no

longer lobbying on that issue or for that principal I am required to immediately notify
the City Clerk s Office of lobbyist withdrawal in writing

Any
lobbyist
who
fails to file the
required
Statement
by
April 30th
2012
shall be
20l2
Date
Signature
CADocuments
and
Settings
clermarm
Local Settings
Temporary
Internet Files OLK11 Lobbyist Registration Formrevised 5 30 2012 doc
11August2014
RaulAguila,CityAttorney
CITYOFMIAMIBEACH
RE:MiamiBeachLobbyingOrdinanceandMiamiDadeCountypenaltiesforviolationsthereof
DearMr.Aguila:
Preliminarytospotcheckingtherecordsofthecityclerkforviolationsofourcityslobbyingordinancein
respect to failures to register, failures to withdraw, and failures to submit annual statements, I
encounteredwhatmaybeananomalyormistakeinourcitycode.Imustbemistaken,soIhopeyouwill
correctme.
Accordingtomyreading,theMiamiBeachCodeofOrdinances,besidesspecifyingfinesforfailuretofile
disclosureandexpenditurestatements,providesforpenaltiesasfollows:
Sec.2485.1.Penalties.(a)AfindingbytheMiamiDadeCountyCommissiononEthicsandPublicTrust
that a person has violated this division shall subject said person to those penalties set forth within
subsections 211.1(s) and (z) of the Metropolitan Dade County Code, said penalties including
admonition,publicreprimand,fines,aswellasprohibitionsfromregisteringasalobbyistorengagingin
lobbyingactivitiesbeforethecity.
Subsection 211.1(s) (Lobbying) of Section 211.1. (Conflict of Interest and Code of Ethics Ordinance),
providesforthefollowingunder211.1(s)(9):
(9) The Ethics Commission shall investigate any person engaged in lobbying activities who may be in
violationofthissubsection(s).IntheeventthataviolationisfoundtohavebeencommittedtheEthics
Commission may, in addition to the penalties set forth in subsection (z), prohibit such person from
lobbying before the County Commission or any committee, board or personnel of the County as
providedherein.
However,Subsection211.1(z)isnotrelevanttopenalties,readingasfollows:
(z)Prohibitiononparticipationinsettlementnegotiations.NeithertheMayor,aCountyCommissioner
noranymemberoftheirstaffshallparticipateinsettlementnegotiationsofclaimsorlawsuits,including
but not limited to contract scope or compensation adjustments involving the County without prior
approvaloftheBoardofCountyCommissioners.
Doesthismeanthat,since(z)asreferredtoinourordinanceisnotrelevanttopenaltiesinthecounty
ordinance,thereisinfactnoconsequenceforviolations,otherthanthefinesspecifiedinthemunicipal
ordinance?
Inoticethatthecounty,under211.1(cc)(1)reads:
(cc) Penalty. (1) Proceeding before Ethics Commission. A finding by the Ethics Commission that a
personhasviolatedthissectionshallsubjectsaidpersontoanadmonitionorpublicreprimandand/ora
fineoffivehundreddollars($500.00)forthefirstsuchviolationandonethousanddollars($1,000.00)
for each subsequent violation. Where the Ethics Commission finds that a person has intentionally
violatedthissectionanddeterminesthatafineisappropriate,saidpersonshallbesubjecttoafineof
one thousand dollars ($1,000.00) for the first such violation and two thousand dollars ($2,000.00) for
eachsubsequentviolation.
Ifthereissomeerrorinamendingthecitycodetogibewiththecountycode,shouldthecodesberead
strictly, so that, again, there is no county penalty under our code since our code refers to a county
sectionthatdoesnotsoprovide?
Onemorequestion(thankyouinadvanceforyourpatience).
The ordinance excludes from the definition of lobbyist unpaid representatives of neighborhood
associations,but they must, prior to communicating with subject city personnel, disclose in writing to
thecityclerk,theirname,address,andprincipalonwhosebehalftheyarecommunicating.
Whatisthepenaltyforthewillfulfailureofarepresentativeofaneighborhoodassociationtomakesuch
adisclosure?Isthatanissuefortheethicscommission?
Verytrulyyours,
DavidArthurWalters

Lobby For Justice South Florida

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MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

David Arthur Walters

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

Political Cartoon by Marian Del Vecchio

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

From: The Herald southbeachherald@gmail.com

Cardeno, Hernan HernanCardeno@miamibeachfl.gov

MIAMI MIRROR TRUE REFLECTIONS

While following up on unsatisfactory county ethics commission behavior in regards to local

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

MIAMI MIRROR TRUE REFLECTIONS

Phone: (305) 673-7181 Fax:

Special Master Case Synopsis

Current Status: LIEN

Balance Due: $101,219.93

Business Name: SIMONE ~EACH CLUB WEST LLC

9/20/2007 ALLEGED VIOLATOR

SUBMITTED REQUEST ON 9/20/07 FOR AN EXENTION OF TIME.

9/20/2007 Special Master Hearing

REQUESTING AN EXTENSION OF TIME TO COMPLY---------------A

11/14/2007 ALLEGED VIOLATOR

LETTER ON 11/14/07 REQUESTING AN EXTENSION OF TIME TO

11/16/2007 Special Master Hearjng

PROGRESS REPORT (REQUESTED ON 11/14/07 AN EXTENSION OF

2: The request for an extension of time is DENIED.

. 3: Today's $76.00 admlnstratlve courtcost is assessed.

12/11/2012 AT THE REQUEST OF . DEPARTMENT, THIS CASE TO BE SCHEDULED BEFORE SM

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