Agenda 12/01/2009 Item #16K 7
Agenda Item No. 16K7
December 1, 2009
Page 1 of 8
EXECUTIVE SUMMARY
.-'""
Recommendation to authorize a Stipulated Final ,Judgment in the amount of $9,750 for Parcel
152RDUE in the lawsuit styled Collier County, Florida v, Patricia K. Carlyle, et ai, Case No. 07-
2829-CA (Oil Well Road Project 60044). (Fiscal Impact $14,468)
OBJECTIVE: That the Board of County Commissioners authorize the attached Stipulated Final
Judgment for payment of full compensation, for the taking of Parcel 152RDUE in the lawsuit styled
Collier County, Florida v. Patricia K. Carlyle, et ai, Case No. 07-2829-CA (Oil Well Road Project
60044).
CONSIDERATIONS: Collier County has condemned a .052 acre parcel for a non-exclusive road
right-of-way drainage and utility easement (Parcel 152RDUE) from property owner Patricia K.
Carlyle. The County's initial appraisal dated February 9, 2007, valued the taking at $3,900. The
County offered the owner $5,150 as the County's statutory offer on July 2, 2007 based on the initial
appraisal of $3,900 plus a settlement incentive of $1 ,250. An updated appraisal, dated November 2,
2007, shows a declining market value of $1,800 for the taking. An Order of Taking hearing was
held on January 4, 2008, and the County deposited the sum of $1,800 in the Court Registry. The
owners' original appraisal was for $30,700, exclusive of attorney's fees and costs.
.,-
On October 30, 2009, the parties mediated the case and agreed to a settlement of $9,750 for Parcel
I 52RDUE. This settlement agreement considers the owner's higher land value calculation and
severance damage claim due to a change in the location from a rural two-lane road to an urbanized
four/six lane thoroughfare, as well as avoidance of additional costs for trial. If approved, the
County will be responsible for the following costs:
Additional Amount Owed:
· Attorneys fees and costs:
Expert fees and costs:
TOTAL
$ 7,950
$ 1,518
$ 5.000
$14,468
* Attorney's Fees are mandated by S73.092, F.S., and are based on 33% of the total benefit .'
achieved, i.e., 0.33 x ($9,750 - $5,150).
FISCAL IMPACT: Funds in the amount of $14,468 will come from Gas Taxes and Impact Fees.
GROWTH MANAGEMENT IMP ACT: None.
LEGAL CONSIDERATIONS: This item is legally sufficient for Board action. RNl
RECOMMENDATION: That the Board of County Commissioners authorize the Stipulated
Final Judgment as to Parcel I 52RDUE and authorize payment ofthe funds as stated.
.
,
PREPARED BY: Robert N. Zachary, Assistant County Attorney
#-
CP:07-2829;203
, -"
. .~',..
, ", ~ ~
1'-
<-'.
Agenda Item No. 16K7
December 1. 2009
Page 2 of 8
.~..-
COLLIER COUNTY
BOARD OF COUNTY COMMISSIONERS
Item Number:
Item Summary:
16K7
Recommendation to authorize a Stipuiated Finai Judgment in the amount of $9,750 for
Parcel 152RDUE in the lawsuit styled Collier County, Florida v. Patricia K. Carlyle, et al.
Case No. 07-2829-CA (Oil Well Road Project 60044). (Fiscallmpac! $14,468)
12/1/2009 9:00:00 AM
Meeting Date:
Prepared By
Robert N. Zachary Assistant County Attorney Date
County Attorney County Attorney 11/17/200911:02:11 AM
Approved By
Robert N. Zachary Assistant County Attorney Date
County Attorney County Attorney 11/17/200912:37 PM
Approved By
Lisa Taylor ManagemenUBudget Analyst Date
Transportation Division Transportation Administration 11/17/20094:15 PM
Approved By
Najeh Ahmad Director ~ Transportation Engineering Date
Transportation Engineering &
Transportation Division Construction Management 11/17/20094:30 PM
Approved By
Kevin Hendricks Manager ~ Right of Way Date
Transportation Engineering &
Transportation Division Construction Management 11/17/20094:39 PM
Approved By
Therese Stanley Manager. Operations Support. Trans Date
Transportation Division Transportation Administration 11/17120094:44 PM
Approved By
Norm E. Feder, AICP Administrator. Transportation Date
Transportation Division Transportation Administration 11/17/20094:46 PM
Approved By
Heidi F. Ashton Section Chief/Land Use.Transportation Date
County Attorney County Attorney 11/17/20094:52 PM
Approved By
--
OMS Coordinator Date
County Attorney County Attorney 11/18/20099:47 AM
---"".-.,
'-'--.. ...,.'''"'''-....-
-'.-'
.
-._....w.-T..~..
Agenda Item No. 16K7
December 1, 2009
Page 3 of 8
Approved By
Jeff Klatzkow
County Attorney
Date
11/19/20099:42 AM
Approved By
John A. Yonkosky
Director. Management and Budget
Date
Office of Management &
Budget
Office of Management & Budget
11/19/2009 1 :42 PM
Agenda Item No. 16K7
December 1, 2009
Page 4 of 8
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL ACTION
COLLIER COUNTY, FLORIDA, a
political subdivision of the State of Florida,
Petitioner,
Case No. 07-2829-CA
v.
PATRICIA K. CARLYLE, et aI.,
Parcel: 152RDUE
Respondents.
/
STIPULATED FINAL JUDGMENT
THIS CAUSE having come before the Court upon Joint Motion made by Petitioner,
COLLIER COUNTY, FLORIDA, by and through its undersigned counsel, and Respondent,
PATRICIA K. CARLYLE, by and through her undersigned counsel, for entry of a Stipulated Final
Judgment as to Parcel 152RDUE for Project No. 60044, and it appearing to the Court that the
parties are authorized to make such Motion, the Court finding that the compensation to be paid by
Petitioner is the full compensation due the Respondent, PATRICIA K. CARLYLE, and the Court
being otherwise fully advised in the premises thereof, it is thereupon
ORDERED AND ADJUDGED that Respondent, PATRICIA K. CARLYLE, have and
recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Nine Thousand Seven
Hundred Fifty and No/IOO Dollars ($9,750.00) for Parcel I 52RDUE, as full payment for the
property interest taken and for damages resulting to the remainder, if less than the entire property
was taken, and for all other damages in connection with said parcel; it is further
~'-'-
. ___~'__._._.__w__
~."~~,~- -,..-.,. '--
----._--
r"
Agenda Item No. 16K7
December 1, 2009
Page 5 of 8
ORDERED AND ADJUDGED that Petitioner, COLLIER COUNTY, FLORIDA, is
entitled to a credit for the good faith estimate of value previously deposited in the amount of
$1,800.00; it is further
ORDERED AND ADJUDGED that Petitioner, COLLIER COUNTY, FLORIDA, shall pay
an additional Seven Thousand Nine Hnndred Fifty and NollOO Dollars ($7,950.00) to Respondent;
it is further
ORDERED AND ADJUDGED that Petitioner shall pay Respondent's attorney's fees and
costs in the amonnt of One Thousand Five Hnndred Eighteen and Noll 00 Dollars ($1,518.00), and
there shall be no additional attorney's fees and costs awarded in this case pursuant to Section.
73.092(1), Florida Statutes; it is further
ORDERED AND AJUDGED that this Court reserves jurisdiction to consider and award
attorney's fees pursuant to Section 73.092(2), Florida Statutes, should the case should be reopened
for apportionment or other supplemental proceedings; it is further
ORDERED AND ADJUDGED that Petitioner shall pay Respondent's expert fees and costs
in the amonnt of Five Thousand and Noll 00 Dollars ($5,000.00), and there shall be no additional
expert fees and costs awarded in this case; it is further
ORDERED AND ADJUDGED that within thirty (30) days hereof, Petitioner shall pay the
total sum of Fourteen Thousand Four Hnndred Sixty-Eight and Noll 00 Dollars ($14,468.00), to the
Trust Acconnt of Blucher Law Group, LLC, 7300 Delainey Court, Sarasota, Florida 34240, for
proper disbursement of compensation to Respondent, attomey's fees, expert fees and costs in
accordance with this order; it is further
ORDERED AND ADJUDGED that Parcel 152RDUE, being a road right-of-way drainage
and utility easement, being fully described in Exhibit "A" attached hereto and incorporated herein,
which vested in Petitioner pursuant to the Order of Taking dated January 4,2008, and the deposit of
2
Agenda Item No. 16K7
December 1, 2009
Page 6 of 8
money heretofore made, is approved, ratified, and confirmed, and this judgment is based upon the
right-of-way maps and plans provided to Defendant with the initial offer; it is further
ORDERED AND ADJUDGED that the Notice of Lis Pendens filed in the above-styled
cause and recorded in Official Record Book 4272, Page 3641 of the Public Records of Collier
County, Florida be dismissed as to Parce1152RDUE; it is further
ORDERED AND ADJUDGED that this Stipulated Final Judgment is to be recorded in the
Official Records of Collier County, Florida; it is further
ORDERED AND ADJUDGED that this Order disposes of all claims arising out of the
taking of Parcel I 52RDUE and that have or could have been asserted in this cause, it is therefore
DONE AND ORDERED in Chambers at Naples, Collier County, Florida, this
day of
,2009.
,",..
HONORABLE CYNTHIA A. PIV ACEK
CIRCUIT COURT JUDGE
conformed copies to:
Robert N. Zachary, Esquire
Paul A. Blucher, Esquire
Kevin Hendricks, Acquisition Mgr.rrransp.
,..-
3
'---.-'-'-'
-"""~"""'.--'--'----
_ n._,~~ ,. ,. '''.n ._
I'
Agenda Item No. 16K7
December 1, 2009
Page 7 of 8
JOINT MOTION FOR STIPULATED FINAL JUDGMENT
Petitioner, COLLIER COUNTY, FLORIDA, together with Respondent, PATRICIA K.
CARLYLE, hereby respectfully move for entry of the foregoing Stipulated Final Judgment as to
Parcel I 52RDUE.
111/,/0 Cj
Dated:
Dated:
If
~ROBERT N. ZACHARY
Florida Bar No. 816604
ASSISTANT COUNTY A TIORNEY
Hannon Turner Building, 8th Floor
330 I East Tamiami Trail
Naples, Florida 34] 12
(239) 774-8400 - Telephone
(239) 252-6300 - Facsimile
A TIORNEY FOR PETITIONER
PAUL A. BLUCHER, ESQUIRE
Florida Bar No. 860409
BLUCHER LAW GROUP, LLC
7300 Delainey Court
Sarasota, FL 34240
(941) 361-1 145 - Telephone
(941) 361-1146 - Facsimile
A TIORNEY FOR RESPONDENT,
PATRICIA K. CARLYLE
CP:07-2829;200
4
,
I
.
Agenda Item No. 16KY
December 1. 2009
Page 8 of 8
.
.
PROJECTEO. 6llO44
PROJECT ARea NO. 152RDUE
PERPE11J , NON-EXClUSIVE ROAD RIGHT-OF-WAY. DRAINAGE AND UTIUTY EASEMENT
LEGAL DESCRlPTlOt:! & SKETCH
(NOT A SURVEY)
EXHIBIT
~~ I of
Tf1E WEST 30 FEET OF THE EAST 80 FEET OF THE NORTH 75 FEET
OF~E SOUTH 105 FEET OF TRACT 121, GOLDEN GATE ESTATES
UN T NO. 69, AS RECORDED IN PLAT BOOK 7, PAGE 65 OF THE
PU UC RECORDS OF COLLIER COUNTY, FLORIDA,
CONTAINING 0.052 ACRES, MORE OR LESS.
-.--..-1.._.._.._ "_"_h..._.._.._.._.._.._._ _.._.._ '__"_"_"_"_'__" _.._.._u_.._.._..__._..
"-" .
r:,.tlTflRClPElln'tl/lf
I
Wl!STMW'OF D8lJG1001'OO'l''JIIIbI:8EltQLAOII''lou.tvNtOI'lOHT..:Jf.WAY lSOFEETl/
'_"_"_.._.._.._.__.,_ n_,,_"_"_h_.'_,,_ "-'
P~ADOmOHoILRn'tT.a=.wAYlllFEE1) ,
--..-..-..-..-.. -..-..-..-..-.._..-t
r"-"-"-"-"-"-"-
"-"-"-"
~~USlIIE
RCloIll --OF_v. ClRAIN.\GE
AlCJunUTYEI'DeI.~
I
.~ ! :lOfW
I '"I
I
,
,
THE NORTH 75 FEET OF TIiE
SOUTK 105 FEET OF TRACT 127
.
I
I
I
j
I
I
iSOlJTHPROI'ER1Yt.>>Il!
I
I
,
N
------- ~
.........
NOT TO SCALE
.,,~.
--...---.--...._..0.'...',...,...--
. .,-.~-"-,---.,., '
r"