3/30/77 File No. 19721
RE: St. Pete Appeal of SWF Orders on Cosme-Odessa
and Section 21 Wellfields
Oral arguments are scheduled before the Second District
Court in Lakeland at 9:30 A.M., Monday, April 11, 1977.
This case is first on the calendar.
Under applicable rules of appellate procedure not more
than 30 minutes to the side will be permitted. The Clerk's
office advises that no specific time has been reserved for
Except by special permission (which has not been requested)
not more than two attorneys to the side will be allowed to
argue. Do you wish to talk to Clint Brown about his role,
St. Pete will argue first, since it is the "appellant". It
will be the City's responsibility to state the following matters
for the Court. If it doesn't, we should do it to prevent
(1) position of appellant in the proceedings
below .i.e. permit applicant, etc.;
(2) the nature of the order appealed from .
order granting consumptive use permits; etc.;
(3) short statement of facts which support
(4) points relied upon for reversal.
Attached are the Briefs in the case. They are:
1. Brief of Petitioner Supporting Certiorari
2. Brief of Respondent in Support of Motion
to Strike Point One of Petitioner's Brief
3. Brief of Petitioner in Opposition to
Respondent's Motion .
4. Brief of Respondent Opposing Certiorari
on the Merits
5. Reply Brief of Petitioner
6. Brief of Amicus Curiae Hillsborough County
7. Brief of Amicus Curiae Pinellas County
8. Brief of Amicus Curiae Pasco County
Memo to LMB
I will prepare a synopsis relating the chronology of the case,
the positions of the parties and the arguments presented to
the Court. I will mail this to you in Tallahassee.
I will keep Sunday evening (4/10/77) free for a conference
with you if you wish.