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Agenda 07/13/2021 Item #16K12 (Stipulated Final Judgement - Parcel 225FEE)07/13/2021 EXECUTIVE SUMMARY Recommendation to approve a Stipulated Final Judgment in the amount of $69,000, plus $15,106 in statutory attorneys’ fees and costs and expert fees and costs, for the taking of Parcel 225FEE, required for the Vanderbilt Beach Road Extension Project, Project No., 60168. _____________________________________________________________________________________ OBJECTIVE: To settle full compensation for the taking of Parcel 225FEE required for the construction of Vanderbilt Beach Road, Project 60168. CONSIDERATIONS: On September 22, 2020, the Board authorized, via Resolution No. 2020-175, the condemnation of Parcel 225FEE for the construction of roadway, drainage and utility improvements required for the expansion and extension of Vanderbilt Beach Road from Collier Blvd. to east of 16th Street NE, and Massey Street from Vanderbilt Beach Road to south of Mockingbird Dr. The fee simple acquisition area consists of a strip taking along the rear, southerly boundary of the property and is approximately 19,895 square feet (0.46 acres) in size. The parent tract is owned by Logan J. Roe and David S. Roe, and contains 2.73 acres of gross land area, which will be reduced to 2.27 acres after the acquisition. An aerial photograph of the subject property is attached to this item for reference. The property owners’ appraiser valued the parcel at $92,300. The County’s appraiser estimated full compensation at $50,200 including severance damages. This amount was adjusted to $53,500 to account for the increase in property values between the date of the appraisal and the date of the deposit of funds following the order of taking. The parties participated in informal negotiations and reached an agreement. The attached Stipulated Final Judgment reflects a negotiated compensation amount of $69,000, plus $8,481 in statutory attorneys’ fees and costs and $6,625 in expert fees and costs, for a total of $84,106. The Transportation Engineering Division recommends approval of this Stipulated Final Judgment since a better result is not anticipated at trial. Upon approval, the County Attorney’s Office will file the Joint Motion and Stipulated Final Judgment with the Circuit Court. FISCAL IMPACT: The County is entitled to a credit of $50,200 based on its deposit of the good faith estimate of value. Funds for the balance of $34,076, which includes the Clerk’s $170.00 deposit fee, are available in the Vanderbilt Beach Road Expansion Project Capital Fund, Project 60168. The primary funding source for the acquisition is impact fees. Should impact fees not be sufficient within the project, the secondary funding source will be gas taxes. GROWTH MANAGEMENT IMPACT: None. LEGAL CONSIDERATIONS: This item is approved as to form and legality and requires a majority vote for Board approval. - SAA RECOMMENDATION: To approve the attached Joint Motion and Stipulated Final Judgment and authorize the payment of funds as stated herein. PREPARED BY: Robert Bosch, Manager, ROW Acquisition, Transportation Engineering Division, Growth Management Department ATTACHMENT(S) 1. EXECUTED - 225FEE SFJ; Roe (DOCX) 2. Aerial 225FEE (PDF) 16.K.12 Packet Pg. 2602 07/13/2021 COLLIER COUNTY Board of County Commissioners Item Number: 16.K.12 Doc ID: 17418 Item Summary: Recommendation to approve a Stipulated Final Judgment in the amount of $69,000, plus $15,106 in statutory attorneys’ fees and costs and expert fees and costs, for the taking of Parcel 225FEE, required for the Vanderbilt Beach Road Extension Project, Project No., 60168. Meeting Date: 07/13/2021 Prepared by: Title: Legal Assistant – County Attorney's Office Name: Jessica Hayes 06/30/2021 4:48 PM Submitted by: Title: County Attorney – County Attorney's Office Name: Jeffrey A. Klatzkow 06/30/2021 4:48 PM Approved By: Review: Transportation Engineering Robert Bosch Additional Reviewer Completed 07/01/2021 7:03 AM Transportation Engineering Jay Ahmad Additional Reviewer Completed 07/01/2021 7:23 AM Growth Management Operations Support Christopher Johnson Additional Reviewer Completed 07/01/2021 7:59 AM Growth Management Department Trinity Scott Additional Reviewer Completed 07/01/2021 10:11 AM County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 07/01/2021 11:29 AM Office of Management and Budget Debra Windsor Level 3 OMB Gatekeeper Review Completed 07/02/2021 8:38 AM County Attorney's Office Sally Ashkar Level 2 Attorney Review Completed 07/02/2021 2:56 PM Office of Management and Budget Susan Usher Additional Reviewer Completed 07/02/2021 4:10 PM County Manager's Office Amy Patterson Level 4 County Manager Review Completed 07/04/2021 4:40 PM Board of County Commissioners Geoffrey Willig Meeting Pending 07/13/2021 9:00 AM 16.K.12 Packet Pg. 2603 [20-CA-3566/1647232/1] 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.: 20-CA-3566 v. Parcel 225FEE GHANSHYAMBHAI M. PATEL; ALPHA PATEL; STATE OF FLORIDA DEPARTMENT OF REVENUE; PATRICK R. LEON; LOGAN J. ROE; DAVID S. ROE; ARIEL CHAVEZ Respondents. ______________________________________________/ JOINT MOTION FOR ENTRY OF A STIPULATED FINAL JUDGMENT AS TO PARCEL 225FEE Petitioner, COLLIER COUNTY, FLORIDA, together with Respondent(s), LOGAN J. ROE AND DAVID S. ROE, by and through undersigned counsel, hereby respectfully move this Court for the entry of the foregoing Stipulated Final Judgment as to Parcel 225FEE attached hereto as Exhibit “1”. ___________________________ SALLY A. ASHKAR, ESQ. Florida Bar No. 1007665 Collier County Attorney’s Office 3299 E. Tamiami Tr., Suite 800 Naples, FL 34112 Telephone: (239) 252-8400 COUNSEL FOR PETITIONER Sally.Ashkar@colliercountyfl.gov Sheri.malcolm@colliercountyfl.gov /s/ JOHN M. LEROUX_____________ JOHN M. LEROUX, ESQ. Florida Bar No. 773166 3090 Charles Ave., Suite 200 Clearwater, FL 33761 Telephone: (727) 712-1137 COUNSEL FOR RESPONDENT(S) john@jmleroux.com pleadings@jmleroux.com 16.K.12.a Packet Pg. 2604 Attachment: EXECUTED - 225FEE SFJ; Roe (17418 : Stipulated Final Judgment in the amount of $69,000) [20-CA-3566/1647232/1] CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the Joint Motion for Entry of a Stipulated Final Judgment was filed with the FL Courts E-Filing Portal on this ___ day of ______ 2021. By:________________________ SALLY A. ASHKAR, ESQ. 16.K.12.a Packet Pg. 2605 Attachment: EXECUTED - 225FEE SFJ; Roe (17418 : Stipulated Final Judgment in the amount of $69,000) [20-CA-3566/1647232/1] 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.: 20-CA-3566 v. Parcel 225FEE GHANSHYAMBHAI M. PATEL; ALPHA PATEL; STATE OF FLORIDA DEPARTMENT OF REVENUE; PATRICK R. LEON; LOGAN J. ROE; DAVID S. ROE; ARIEL CHAVEZ Respondents. ______________________________________________/ STIPULATED FINAL JUDGMENT AS TO PARCEL 225FEE THIS CAUSE, having come before this Court upon the Joint Motion made by Petitioner, COLLIER COUNTY, FLORIDA, and Respondent(s), LOGAN J. ROE AND DAVID S. ROE, by and through counsel, for the entry of a Stipulated Final Judgment as to Parcel 225FEE for Project 60168, and it appearing to this Court that proper notice was given to the parties having any equity, lien, title, or other interest in or to the real property described therein, and the Court being otherwise fully advised in the premises thereof, it is ORDERED AND ADJUDGED that: 1. Respondent(s), LOGAN J. ROE AND DAVID S. ROE, shall recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Sixty-Nine Thousand and No/100 Dollars ($69,000.00) for Parcel 225FEE, as full payment for the property interest taken, including damages and statutory interests, in connection with said parcel. 2. Respondent(s), LOGAN J. ROE AND DAVID S. ROE, shall recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Eight Thousand Four Hundred Eighty-One and No/100 Dollars ($8,481.00), for all attorney fees and costs associated with Parcel 225FEE and no other attorney fees or costs shall be paid in this matter. 3. Respondent(s), LOGAN J. ROE AND DAVID S. ROE, shall recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Six Thousand Six Hundred Twenty-Five Dollars and 16.K.12.a Packet Pg. 2606 Attachment: EXECUTED - 225FEE SFJ; Roe (17418 : Stipulated Final Judgment in the amount of $69,000) [20-CA-3566/1647232/1] No/100 Dollars ($6,625.00), for all expert fees and costs associated with Parcel 225FEE and no other expert fees or costs shall be paid in this matter. 4. Petitioner, COLLIER COUNTY, FLORIDA, is entitled to a credit for the good faith estimate of value previously deposited in the amount of Fifty Thousand Two Hundred and No/100 Dollars ($50,200.00), as payment for acquisition of Parcel 225FEE, at which time title to said parcel as described in Exhibit “A” vested in the name of Petitioner COLLIER COUNTY, FLORIDA. 5. Within thirty (30) days from the entry of this Order, Petitioner, COLLIER COUNTY, FLORIDA, shall issue a check made payable to the Law Offices of John M. LeRoux, P.A. Trust Account in the total sum of Thirty-Three Thousand Nine Hundred Six and No/100 Dollars ($33,906.00), as payment for acquisition of Parcel 225FEE, and deliver said check to the Law Offices of John M. LeRoux, P.A., 3090 Charles Avenue, Suite 200, Clearwater, Florida 33761. 6. This Order disposes of all claims arising out of the taking of Parcel 225FEE that have or could have been asserted in this cause. 7. A fee simple taking, being fully described in Exhibit “A” attached hereto and incorporated herein, which vested in Petitioner pursuant to the Stipulated Order of Taking dated March 24, 2021, and the deposit of money heretofore made, is approved, ratified, and confirmed. 8. Petitioner will construct the project in substantial conformance with the ninety percent (90%) construction plans for the project, which plans are incorporated herein by reference. Respondent understands and agrees that this Stipulated Final Judgment contemplates the future 6-laning of Vanderbilt Beach Road (VBR). No additional compensation shall be due to Respondent for the widening of VBR up to 6-lanes. 9. The Notice of Lis Pendens filed in this cause and recorded in Official Record Book 5844, Page 3791 of the Public Records of Collier County, Florida is hereby dismissed as to Parcel 225FEE. 10. This Court reserves jurisdiction to enforce the terms of this Stipulated Final Judgment. 16.K.12.a Packet Pg. 2607 Attachment: EXECUTED - 225FEE SFJ; Roe (17418 : Stipulated Final Judgment in the amount of $69,000) [20-CA-3566/1647232/1] 11. This Stipulated Final Judgment is to be recorded in the Official Records of Collier County, Florida. DONE AND ORDERED in Chambers, Naples, Collier County, Florida, on this ____ day of ____________, 2021. _____________________________________ THE HONORABLE LAUREN BRODIE Circuit Court Judge Exhibit “A” 16.K.12.a Packet Pg. 2608 Attachment: EXECUTED - 225FEE SFJ; Roe (17418 : Stipulated Final Judgment in the amount of $69,000) VANDERBILT BEACH ROAD EXTENSION PROJECT 60168 – PARCEL 225FEE / PARCEL 225FEE 16.K.12.b Packet Pg. 2609 Attachment: Aerial 225FEE (17418 : Stipulated Final Judgment in the amount of $69,000)