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Agenda 12/10/2024 Item #16K 3 (Approve a Stipulated Final Judgment in the amount of $44,300 plus $8,217 in statutory attorney fees and costs for the taking of Parcel 1236FEE required for the Vanderbilt Beach Road Extension Project No. 60168.)12/10/2024 Item # 16.K.3 ID# 2024-2007 Executive Summary Recommendation to approve a Stipulated Final Judgment in the amount of $44,300 plus $8,217 in statutory attorney fees and costs for the taking of Parcel 1236FEE required for the Vanderbilt Beach Road Extension Project No. 60168. OBJECTIVE: To settle full compensation for the taking of Parcel 1236FEE required for the construction of the Vanderbilt Beach Road Extension Project No. 60168. CONSIDERATIONS: On September 22, 2020, the Board authorized, via Resolution No. 2020-175, the condemnation of Parcel 1236FEE for the construction of roadway, drainage and utility improvements required for the expansion and extension of Vanderbilt Beach Road from Collier Boulevard to east of 16th Street NE and Massey Street from Vanderbilt Beach Road to south of Mockingbird Drive. The fee simple acquisition area consists of a strip taking along the rear, northerly boundary of the property and is approximately 0.17 acres in extent. The parent tract is a vacant lot owned by Sognare, LLC, and contains 1.14 acres of gross land area, which has been reduced to 0.97 acres after the acquisition. An aerial photograph of the subject property is attached. The County’s appraiser estimated full compensation at $23,000 including severance damages, which was adjusted to $31,400 by the Transportation Engineering Division’s Review Appraiser to account for increases in property prices since the date of the appraisal. The property owner’s initial demand was $57,340 plus attorney’s fees and costs. The parties participated in informal negotiations and reached an agreement. The attached Stipulated Final Judgment reflects a negotiated compensation amount of $44,300 plus $8,217 in statutory attorney’s fees and costs, for a total of $52,517. 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 $23,000 for its deposit of the good faith estimate of value. Funds for the balance of $29,687, which includes the Clerk’s $170.00 deposit fee, are available in the Vanderbilt Beach Road / CR951 to 8th Project (60168). The primary funding source for the acquisition of right of way is through Road Impact Fee District Funds (3090, 3091, 3092, 3093, 3094, 3095). Should impact fees not be sufficient, the secondary funding source will be Road Construction Gas Tax Fund (3083). GROWTH MANAGEMENT IMPACT: None. LEGAL CONSIDERATIONS: This item is approved as to form and legality and requires a majority vote for Board approval. -SAA RECOMMENDATIONS: 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 ATTACHMENTS: 1. Aerial - Parcel 1236FEE 2. P1236FEE Joint Motion for Stipulated Final Judgment Page 9782 of 10663 AERIAL – PARCEL 1236FEE (Vanderbilt Beach Road Ext Phase 1- Project No. 60168) PARCEL 1236FEE / Page 9783 of 10663 [21-CA-499/1899778/1] 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.: 21-CA-499 v. Parcel 1236FEE 180 12TH AVE NE, LLC; CONSTANCE ANN BRUGGEMAN, AS TRUSTEE UNDER THAT CERTAIN GARY FAMILY LAND TRUST DATED MARCH 18, 2020; CHRISTOPHER E. O’ROURKE; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. GREGORY J. BUHLER; SARAH A. BUHLER; SUNCOAST CREDIT UNION; SOGNARE LLC; WEST COAST FUND, LLC; ILEN ESTRADA; ILEN ESTRADA REALTY, INC., A DISSOLVED FLORIDA CORPORATION Respondents. ______________________________________________/ JOINT MOTION FOR ENTRY OF A STIPULATED FINAL JUDGMENT AS TO PARCEL 1236FEE Petitioner, COLLIER COUNTY, FLORIDA, together with Respondent, SOGNARE LLC, by and through undersigned counsel, hereby respectfully move this Court for the entry of the foregoing Stipulated Final Judgment as to Parcel 1236FEE attached hereto as Exhibit “1”. ___________________________ COLLEEN M. GREENE, ESQ. Florida Bar No. 502650 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 Colleen.Greene@colliercountyfl.gov Sally.Ashkar@colliercountyfl.gov Sheri.Malcolm@colliercountyfl.gov /s/ SUMMER E. DEGEL __ SUMMER E. DEGEL, ESQ. Florida Bar No. 0106536 Gray Robinson, P.A. PO Box 3068 Orlando, FL 32802 Telephone: (407) 843-8880 COUNSEL FOR RESPONDENT Summer.DeGel@gray-robinson.com Page 9784 of 10663 [21-CA-499/1899778/1] 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 ____________ 2024. By: __________________________ SALLY A. ASHKAR, ESQ. Page 9785 of 10663 [21-CA-499/1899778/1] 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.: 21-CA-499 v. Parcel 1236FEE 180 12TH AVE NE, LLC; CONSTANCE ANN BRUGGEMAN, AS TRUSTEE UNDER THAT CERTAIN GARY FAMILY LAND TRUST DATED MARCH 18, 2020; CHRISTOPHER E. O’ROURKE; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. GREGORY J. BUHLER; SARAH A. BUHLER; SUNCOAST CREDIT UNION; SOGNARE LLC; WEST COAST FUND, LLC; ILEN ESTRADA; ILEN ESTRADA REALTY, INC., A DISSOLVED FLORIDA CORPORATION Respondents. ______________________________________________/ STIPULATED FINAL JUDGMENT AS TO PARCEL 1236FEE (with disbursement instructions to the Clerk) THIS CAUSE, having come before this Court upon the Joint Motion made by Petitioner, COLLIER COUNTY, FLORIDA, and Respondent, SOGNARE LLC, by and through counsel, for the entry of a Stipulated Final Judgment as to Parcel 1236FEE 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, SOGNARE LLC, shall recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Forty-Four Thousand Three Hundred Dollars and No/100 ($44,300.00) for Parcel 1236FEE, as full payment for the property interest taken, including any and all business damages, in connection with said parcel. 2. Respondent, SOGNARE LLC, shall recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Eight Thousand Two Hundred Seventeen Dollars and No/100 Page 9786 of 10663 [21-CA-499/1899778/1] ($8,217.00) for all attorney’s fees, expert fees, and costs, and no other attorney’s fees, expert fees, or costs will be paid in this matter. 3. Petitioner, COLLIER COUNTY, FLORIDA, is entitled to a credit for the good faith estimate of value previously deposited in the amount of Twenty-Three Thousand and No/100 Dollars ($23,000.00), as payment for the acquisition of Parcel 1236FEE, at which time title to said parcel as described in Exhibit “A” vested in the name of Petitioner COLLIER COUNTY, FLORIDA. 4. Within thirty (30) days from the entry of this Order, Petitioner, COLLIER COUNTY, FLORIDA, shall pay the total sum of Twenty-Nine Thousand Five Hundred Seventeen Dollars and No/100 ($29,517.00), by issuing a check issuing a check payable to Gray Robinson PA Trust Account, and mailing the check to Gray Robinson, PA, c/o Summer DeGel, Esq., 301 E. Pine Street, Suite 1400, Orlando, FL 32801. 5. Within thirty (30) days from the entry of this Order, the CLERK OF COURTS shall disburse from the Court’s registry the total amount of Twenty-Three Thousand and No/100 Dollars ($23,000.00), by issuing a check issuing a check payable to Gray Robinson PA Trust Account, and mailing the check to Gray Robinson, PA, c/o Summer DeGel, Esq., 301 E. Pine Street, Suite 1400, Orlando, FL 32801. 6. This Order disposes of all claims arising out of the taking of Parcel 1236FEE 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 Order of Taking dated June 23, 2021, and the deposit of money heretofore made, is approved, ratified, and confirmed. 8. Petitioner will construct the project in substantial conformance with the one hundred percent (100%) 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 Page 9787 of 10663 [21-CA-499/1899778/1] Respondent for the widening of VBR up to 6-lanes. Accordingly, if the project is not constructed in substantial conformance with the one hundred percent (100%) construction plans for the project, Respondent shall have the same remedies as would have been afforded to them had the case been resolved by jury verdict with said plans and specifications having been made a part of the record at trial. Central & Southern Florida Flood Control District v. Wye River Farms, Inc., 297 So.2d 323 (Fla. 4th DCA 1974); cert. denied 310 So.2d 745 (Fla. 1975). 9. The Notice of Lis Pendens filed in this cause and recorded in Official Record Book 5897, Page 2775 of the Public Records of Collier County, Florida be dismissed as to Parcel 1236FEE. 10. This Court reserves jurisdiction to enforce the terms of this Stipulated Final Judgment. 11. This Stipulated Final Judgment is to be recorded in the Official Records of Collier County, Florida. Exhibit “A” Page 9788 of 10663