BCC Minutes 06/24/2008 Closed Session (#12A-Lucky, M.K., Inc.) MINUTES
Lucky, M . K. Inc .
June 24 , 2008
tee.-1%44140.e..ft. ireloy
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY.FLORIDA CIVIL ACTION,
LUCKY M.K.,INC.,a Florida Corporation,
Petitioner,
vs. Case No.07-0958CA
COLLIER COUNTY,a Political Subdivision of `"m� II
the State of Florida,and JIM COLETTA,in His ti,
Capacity of Chairman of Collier County Board r.
Of County Commissioners, s
Respondents.
/ ca
r ,
ORDER GRANTING MOTION TO DISMISS,
THIS CAUSE comes before the Court on Petitioner's"Notice of Voluntary Dismissal
with Prejudice,"filed August 28,2008. Accordingly,it is hereby,
ORDERED AND ADJUDGED that the Petition for Writ of Certiorari is DISMISSED
with prejudice.
DO AND ORDERED in Chambers at Naples,Collier County,Florida,this /10
day of
I. ,2008.
• thia A.Ellis
ircuit Judge
certificate of Service
I HEREBY CERTIFY that a true and correct copy of the foregoing order has been
furnished to Mark A. Slack,Esquire,Attorney for Petitioner,Paulich,Slack&Wolff,P.A.,5147
Castello Drive,Naples,FL 34103; Jacqueline W.Hubbard,Esquire,Office of the County
Attorney,Harmon Turner Building,3301 East Tamiarai Trail,Naples,FL 34112; Court
Administration(X),3301 E.Tamiami Trail,Naples,Florida 34112; this day of
,2008,
Dwight E.Brock
Clerk of Court
By;
Deputy Clerk
June 24, 2008
TRANSCRIPT OF THE MEETING OF THE
BOARD OF COUNTY COMMISSIONERS
Naples, Florida, June 24, 2008
CLOSED SESSION
Item #12A - Lucky M.K., Inc.
LET IT BE REMEMBERED, that the Board of County
Commissioners, in and for the County of Collier, and also acting as
the Board of Zoning Appeals and as the governing board(s) of such
special district as has been created according to law and having
conducted business herein, met on this date at 12:00 p.m., in CLOSED
SESSION in Building "F" of the Government Complex, East Naples,
Florida, with the following members present:
CHAIRMAN: Tom Henning
Donna Fiala
Jim Coletta
Fred Coyle
Frank Halas
ALSO PRESENT:
Jim Mudd, County Manager
Jeffrey A. Klatzkow, County Attorney
Jacqueline Hubbard, Assistant County Attorney
Page 1 — Item #12A (Lucky, M.K. Inc.)
June 24, 2008
CHAIRMAN HENNING: We're going to go to item 12A and
12B, and I think Jacqueline is going to lead us off.
Item #12A
THE BOARD IN EXECUTIVE SESSION WILL DISCUSS:
SETTLEMENT NEGOTIATIONS AND STRATEGY RELATED
TO LITIGATION EXPENDITURES IN THE PENDING
LITIGATION CASES OF LUCKY, M.K., INC. V. COLLIER
COUNTY, ET AL., CASE NO. 07-0958-CA, NOW PENDING IN
THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER
COUNTY, FLORIDA — CLOSED SESSION
MS. HUBBARD: Okay. For the record, Jacqueline Hubbard,
Assistant County Attorney, and present is Jeff Klatzkow, County
Attorney, and all five commissioners, and County Manager Jim Mudd.
We're here to talk about a settlement offer that has been made in
the Green Heron lawsuit of$150,000 in cash. In exchange their
lawsuit would be dismissed. And, essentially, that will be the end of
this matter.
We have a lawsuit in which a developer came to the board --
came to the county to receive a Certificate of Occupancy on what
turned out to be about the last 18 units of a fairly substantial
development.
Someone on county staff was quick enough to notice that the
development had not complied with all of the development order. The
development order, however, was quite old, and quite a few CO's have
been issued through the years.
This was a subsequent developer, so there was some equities in
his favor. Nonetheless, he filed a motion -- he filed a complaint
asking for damages, asking that the Court issue a Writ of Mandamus
to compel the county to turn over those CO's because the county
Page 2 — Item #12A (Lucky, M.K. Inc.)
June 24, 2008
refused to do so when it discovered that these developer commitments
had not been completed.
I filed a motion to dismiss the writ mainly because it's not the
kind of case where a writ should issue. And after that was filed with
the Memorandum of Law, the developer contacted us, and we sat
down to try to settle the matter.
We were unable really to reach a settlement; however, we
reached what I would call a tentative settlement in which the clock
was running. And so we agreed that if they posted a letter of credit,
we would continue to engage in settlement discussions for a period of
24 months, which we've done, and we haven't really been able to
reach anything until very recently, which prompted the closed session
here today.
And essentially we have alleged that through the years our -- the
developer owes us about $695,000 in improvements that we feel the
developer was committed to make.
I'd like to bear in mind that at the time these commitments were
made, the cost of these improvements has increased substantially. We
relied upon the methodology that was used by the developer's
engineer, and we haven't really proved up these issues to my
satisfaction.
MR. KLATZKOW: Yeah, but there's another issue that they've
been paying us impact fees over the years.
MS. HUBBARD: Yes. They've paid over a million.
MR. KLATZKOW: This developer's pre-impact fee fee era. We
got into an agreement way back when to -- they would do
improvements to Santa Barbara and Davis Boulevard, but over the
years, they've been paying impact fees, you know, some of which
money's been going to these roads anyway. So the development does
have some equities involved here.
MS. HUBBARD: Right. On the second page you see where the
calculations regarding the impact fees are located.
Page 3 — Item #12A (Lucky, M.K. Inc.)
June 24, 2008
In any event -- in any event, the developer has made an argument
basically that, you know, we should have caught this sooner. You let
all these other units close. We gave COs to over 500 units prior to
these remaining ones. And now he's the last developer in the chain of
developers and you want to hold him responsible for everything that
wasn't done in the prior years.
We thought that the developer does have some equities there.
We did not hold the prior developer's feet to the fire, and we are
getting to the end of the development.
In any event, the settlement is, they will pay to the county
$150,000 in cash to terminate the whole dispute. We've discussed this
at length with the transportation staff. They believe that that's a
reasonable settlement. I think they were of the opinion that they were
not expecting really to recover --
MR. KLATZKOW: Anything.
MS. HUBBARD: -- any cash at all. So this was a found money
for them.
So if you approve the settlement, what you are doing is accepting
the $150,000 which would go into the transportation division, and we
will not have to litigate a case that, although ultimately I think tilts in
the county's favor in terms of prevailing, I think it would be an
extremely complex matter to litigate and would probably take up a lot
of our time and take a lot of time to complete.
MR. KLATZKOW: Well, you've got a collection issue, too.
Even if we prevailed in this case, two, three years from now, I don't
know that we can collect on the money since the development's all
closed out and gone. This is cash in hand.
MS. HUBBARD: So that's why our recommendation is to accept
the settlement.
MR. MUDD: And I can confirm Jackie's statement that
transportation staff says $150,000 is probably better than we'll ever do
in a court of law. Well, I can't say about the court of law. But it's --
Page 4 — Item #12A (Lucky, M.K. Inc.)
June 24, 2008
because it's so old and had multiple owners, that the $150,000 offer
seems to be reasonable.
CHAIRMAN HENNING: Is there any questions? Commissioner
Coyle?
COMMISSIONER COYLE: Did we fail in any way to collect
things, to hold people accountable?
MR. KLATZKOW: No. The problem was, we weren't really
doing the road widenings all those years. So you've got a
development that committed to help us with the road widening
projects. The road widenings never happened, so I don't think this
was a failure of our staff. The problem was a timing problem.
COMMISSIONER COYLE: So had we insisted that it be been
done back then, it would have been done at a lot cheaper cost and the
developer wouldn't have had to pay?
MR. KLATZKOW: But it was a proportional share cost though.
We would have had to -- we didn't need the road then, so there was no
point to widen the road and spend the monies then.
MR. MUDD: I will tell you, Commissioner, that there's an
ongoing staff effort -- and I mean, our PUD system that we have --
and we've also got Nick involved with Lauren Beir (phonetic), and
we're basically in the process of automating all the commitments on
every PUD so that we don't lose any visual on any commitment that
we have, because there are 300-plus PUDs, all have commitments.
Some of them are multiples.
So not only are we putting it so that we've got it in a spreadsheet,
but we also have the background. So it's GIS map and it's -- and we've
got the intersection -- plus you have DCAs that have nothing to do
with the PUD that all have -- we've integrated all that stuff so we don't
lose sight of it.
MR. KLATZKOW: You're got DRIs up there.
MR. MUDD: Absolutely.
CHAIRMAN HENNING: Okay. Well, this is a -- this is a DRI.
Page 5 — Item #12A (Lucky, M.K. Inc.)
June 24, 2008
There was multiple developers who developed it out, and this is the
last parcel that's going to be developed, which is developed. Okay.
MS. HUBBARD: Yes.
COMMISSIONER FIALA: What's the name of the
development?
MS. HUBBARD: Green Heron.
COMMISSIONER HALAS: Green Heron. Remember we had
many times in the PUD monitoring, this particular development was
always coming before us because they didn't meet their commitments
with the residents; remember that?
COMMISSIONER FIALA: Yeah.
COMMISSIONER HALAS: And that's when we really got after
setting up some kind of a monitoring system for all the PUDs and
DRIs in the county.
COMMISSIONER FIALA: Oh, yeah.
COMMISSIONER HALAS: Okay.
COMMISSIONER FIALA: I remember that, yes.
CHAIRMAN HENNING: Okay. Well, if there's no further
questions, we're going to close the shade session and then we're going
to be out at one o'clock and continue this item in the public's -- public
eye.
MS. HUBBARD: Thank you very much.
MR. KLATZKOW: So it's the will of the board to take the
settlement?
MS. HUBBARD: No, no. We do that in open court.
CHAIRMAN HENNING: We're going to do that in the open.
MS. HUBBARD: We're going to do that in open court. Can't
vote in here.
(The closed session concluded at 12:18 p.m.)
*****
TRANSCRIPT PREPARED ON BEHALF OF GREGORY
COURT REPORTING SERVICES, INC., BY TERRI LEWIS.
Page 6 — Item #12A (Lucky, M.K. Inc.)