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Agenda 05/10/2016 Item #16K 35/10/201616.K.3. EXECUTIVE SUMMARY Recommendation to approve a Joint Motion and Final Judgment in the amount of $1,715,000 for the taking of Parcels 251DAME, 255DAME, 257DAME, 258DAME, 258TCE1 and 258TCE2, as full compensation, including all attorney's fees, expert fees and costs, in the lawsuit style Collier County v S.D. Corporation of Naples, InG, et al., Case No. 15 -CA -1580, required for the Wing South / Sandy Lane Interconnect portion of the Lely Area Stormwater Improvement Project, Project No. 51101, and authorize any necessary budget amendments. (Fiscal Impact: $976,330) OBJECTIVE: To settle full compensation owed for the taking of Parcels 251DAME, 255DAME, 257DAME, 258DAME, 258TCE1 and 258TCE2 required for the Wingsouth/Sandy Lane Interconnect portion of the Lely Area Stormwater Improvement Project, Project No. 51101, hereinafter referred to as LASIP. CONSIDERATIONS: This item is a follow-up to an Item brought to the Board April I P. To refresh the Board's recollection, on June 11, 2013 and June 9, 2015, the Board authorized the condemnation of Parcels 251DAME, 255DAME, 257DAME, 258DAME, 258TCE1 and 258TCE2 in order to construct stormwater improvements to the Wing South / Sandy Lane Interconnect segment of LASIP. On October 29, 2015, the Court entered an Order of Taking for the required property and the County subsequently deposited a good faith estimate of value in the amount of $738,500.00 into the Court Registry. The four perpetual, non-exclusive drainage, access and maintenance easements and two temporary construction easements, totaling around 10.09 acres, were taken from property owned by S.D. Corporation of Naples, Inc., and Cypress Landings II of Naples, LLC. Attached are aerials of the subject property and a location map for your reference. At mediation, the owners, through their representatives and counsel, presented a claim for full compensation in the amount of $5,794,420.00, which included both the compensation for the value of the land taken, a cost to cure for lost access, and severance damages based on the claim that LASIP will negatively impact the drainage of the remainder property, causing increased developmental costs and loss of development potential. Collier County staff and the engineer of record strongly disputed the claim that the parent tract will be damaged at all by LASIP and the County's appraiser found that no severance damages are to be awarded. In fact, the County's experts contend that the parent tract will drain better after the construction of LASIP than it did before. The best final offer that the County received at mediation is an all-inclusive amount of $2,100,000.00 for value of the land taken, any cost to cure, all severance damages, all experts' fees and attorney's fees. Staff recommended rejection of the settlement, which recommendation was approved. The Board then approved the recommendation to make an Offer of Judgment in the amount of $1,200,001.00 as full compensation. The offer did not include attorneys fees and expert costs. If the Offer had been accepted, with attorney fees and expert costs the total cost to the County at the end of the day was estimated to be $1,680,351.25. Packet Page -1334- 401VU1rst-1MI � Through negotiation, the parties have arrived at a proposed Global Settlement (which includes all attorney and expert fees) of $1,715,000, which is approximately $35,000 above the Offer of Judgment. It also is a $385,000 reduction from the Mediated Settlement Agreement that the Board rejected. The County Attorney's Office, special litigation counsel and staff are recommending approval of this settlement, which will eliminate the risk of a negative jury verdict and will reduce the amount of expert fees which both parties will be required to expend to conduct a jury trial. If approved, the County Attorney's Office will file the attached Joint Motion and Final Judgment with the Circuit Court. GROWTH MANAGEMENT IMPACT: None. FISCAL IMPACT: A budget amendment in the amount of $976,330.00 is needed. Source of funds is transfers from the General Fund (00 1) and Unincorporated Area General Fund (111). LEGAL CONSIDERATIONS: This item has been reviewed as to form and legality and requires a majority vote for Board approval. — JAK RECOMMENDATION: Recommendation to approve a Joint Motion and Final Judgment in the amount of $1,715,000.00 for the taking of Parcels 251DAME, 255DAME, 257DAME, 258DAME, 258TCE1 and 258TCE2, as full compensation, including all attorney's fees, expert fees and costs, in the lawsuit style Collier County v. S.D. Corporation of Naples, Inc., et al., Case No. 15 -CA -1580, required for the Wing South / Sandy Lane Interconnect portion of the Lely Area Stormwater Improvement Project, Project No. 51101, and authorize any necessary budget amendments. Prepared by: Jeffrey A. Klatzkow, County Attorney Attachments: (1) Joint Motion and Final Judgment and (2) Aerials of Subject Property Packet Page -1335- 5/10/2016 16.K.3. COLLIER COUNTY Board of County Commissioners Item Number: 16.16.K.16.K.3. Item Summary: Recommendation to approve a Joint Motion and Final Judgment in the amount of $1,715,000 for the taking of Parcels 251DAME, 255DAME, 257DAME, 258DAME, 258TCE1 and 258TCE2, as full compensation, including all attorney's fees, expert fees and costs, in the lawsuit style Collier County v. S.D. Corporation of Naples, Inc., et al., Case No. 15 -CA - 1580, required for the Wing South / Sandy Lane Interconnect portion of the Lely Area Stormwater Improvement Project, Project No. 51101, and authorize any necessary budget amendments. (Fiscal Impact: $976,330) Meeting Date: 5/10/2016 Prepared By Name: BrockMaryJo Title: Executive Secretary to County Manager, County Managers Office 5/4/2016 5:09:17 PM Submitted by Title: Executive Secretary to County Manager, County Managers Office Name: BrockMaryJo 5/4/2016 5:09:18 PM Approved By Name: KlatzkowJeff Title: County Attorney, Date: 5/4/2016 5:12:03 PM Name: OchsLeo Title: County Manager, County Managers Office Date: 5/4/2016 5:16:52 PM Packet Page -1336- 5/10/2016 16.K.3. 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, V. Case No.: 15 -CA -1580 S.D. CORPORATION OF NAPLES, INC.; PARCELS: 251 DAME; CYPRESS LANDINGS II OF NAPLES, LLC, 255DAME; a Florida limited liability company; and 257DAME; WING SOUTH, INC., formerly known as Wing 258DAME; South Airpark Private Villas, Inc., 258TCE1; and 258TCE2 Respondents. PETITIONER COLLIER COUNTY AND RESPONDENTS S.D. CORPORATION OF NAPLES, INC. AND CYPRESS LANDINGS II OF NAPLES, LLC, JOINT MOTION FOR STIPULATED FINAL JUDGMENT COMES NOW, Petitioner, COLLIER COUNTY, FLORIDA, together with Respondents, S.D. CORPORATION OF NAPLES, INC., and CYPRESS LANDINGS II OF NAPLES, LLC, by and through their undersigned counsel, and hereby proposed Stipulated Final Judgment as to Parcels 251 258DAME, 258TCE1, and 258TCE2, attached hereto as EMILY R. PEPIN, ESQUIRE Florida Bar No. 92956 Collier County Attorney's Office 3299 East Tamiami Trail, Suite 800 Naples, FL 34112 Telephone: (239) 252-8400 Facsimile: (239) 774-0225 CO -COUNSEL FOR PETITIONER emitypepin _,colliergov.net ,jenniferbelpedio,�@collier og v.net nancvbradleygcollier off; v.net move for entry of the 255DA,4IE, 257DAME, A". BELLA Y. PATEL, ESQ. Florida Bar No. 961670 13026 Waterford Run Drive Riverview, FL 33569 Telephone: (813) 643-2762 Facsimile: (813) 643-2612 CO -COUNSEL FOR RESPONDENTS S D. CORPORATION OF NAPLES, INC.; and CYPRESS LANDINGS II OF NAPLES, LLC bellapatelganaol.com Packet Page -1337- 5/10/2016 16.K.3. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the Joint Motion for Stipulated Final Judgment was electronically filed with the Florida Courts E -Filing Portal which will send a notice of electronic filing to parties appearing via electronically, and by U.S. mail to parties as indicated on the Service List below on this day of , 2016. EMILY R. PEPIN, ESQUIRE SERVICE LIST PARCEL 251DAME S.D. CORPORATION OF NAPLES, INC. Craig B. Willis, Esq. c/o Bella Y. Patel, Esq. Fixel & Willis Bellapatelpa F4ol.com cwillis e,fixelwillis.com; Brian A. Bolves, Esq. ccrossley(nfixelwillis.com Manson, Bolves & Donaldson, P.A. Co -Counsel for Petitioner bbolves@mansonbolves.com PARCEL 255DAME CYPRESS LANDINGS II OF NAPLES, LLC, a Craig B. Willis, Esq. Florida limited liability company Fixel & Willis c/o Bella Y. Patel, Esq. cwillis fixelwillis.com; Bellapatelpa(a7aol.com ccrossleyajiixelwillis.com Brian A. Bolves, Esq. Co -Counsel for Petitioner Manson, Bolves & Donaldson, P.A. bbolvesa,mansonbolves.com PARCEL 257DAME S.D. CORPORATION OF NAPLES, INC. Craig B. Willis, Esq. c/o Bella Y. Patel, Esq. Fixel & Willis Bel lapatelpa zaol.com cwillis(gb-fixelwillis.com; Brian A. Bolves, Esq. cerossley@,fixetwillis.com Manson, Bolves & Donaldson, P.A. Co -Counsel for Petitioner bbolves cl)mansonbolves.com PARfF.T,R 25RDAMFt 2.59TCE1: and 258TCE2 S.D. CORPORATION OF NAPLES, INC. WING SOUTH, INC., formerly known as Wing c/o Bella Y. Patel, Esq. South Airpark Private Villas, Inc. Bel lapatelpa@aol.com_ Brian A. Bolves, Esq. c/o Stephen P. Hart 4985 Tamiami Trail East Manson, Bolves & Donaldson, P,A. Naples, FL 34113 bbolvesC@,mansonbolves.com dcantwe l l(@mansonbolves.com Craig B. Willis, Esq. Fixel & Willis cwillis &fixelwillis.com; ccrossIa(&fixelwillis.com Co -Counsel or Petitioner Packet Page -1338- IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA COLLIER COUNTY, FLORIDA, a political subdivision of the State of Florida, Petitioner, V. Case No.: S.D. CORPORATION OF NAPLES, INC.; PARCELS: CYPRESS LANDINGS II OF NAPLES, LLC, a Florida limited liability company; and WING SOUTH, INC., formerly known as Wing South Airpark Private Villas, Inc., Respondents. STIPULATED FINAL JUDGMENT 5/10/2016 16.K.3. 15 -CA -1580 251DAME; 255DAME; 257DAME; 258DAME; 258TCE1; and 258TCE2 THIS CAUSE having come before the Court upon the Joint Motion made by Petitioner, COLLIER COUNTY, FLORIDA, and Respondents, S.D. CORPORATION OF NAPLES, INC., and CYPRESS LANDINGS II OF NAPLES, LLC, by and through their undersigned counsel, for entry of a Stipulated Final Judgment as to Parcels 251 DAME, 255DAME, 257DAME, 258DAME, 258TCE1, and 258TCE2 for Project No. 51101, and it appearing to the Court that the parties are Exhibit "1" to Joint Motion for Stipulated Final Judgment Packet Page -1339- 5/10/2016 16.K.3. authorized to make such Motion, the Court finding that the compensation to be paid by Petitioner is the full compensation due the Respondents, S.D. CORPORATION OF NAPLES, INC., and CYPRESS LANDINGS II OF NAPLES, LLC, and the Court being otherwise fully advised in the premises thereof, it is thereupon ORDERED AND ADJUDGED that Respondents, S.D. CORPORATION OF NAPLES, INC., and CYPRESS LANDINGS II OF NAPLES, LLC, have and recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of One Million Seven Hundred Fifteen Thousand and No/100 Dollars ($1,715,000.00) for Parcels 251 DAME, 255DAME, 257DAME, 258DAME, 258TCE1, and 258TCE2, as full compensation and 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, statutory interest, attorney's fees, expert fees and costs in connection with said parcels; it is further ORDERED that of the sums awarded herein, One Million Two Hundred Thousand One and No/100 Dollars ($1,200,001.00) be awarded for the value of the property taken, any and all improvements within the take, all severance damages, costs to cure and any and all other damages to the remainder as a result of the property taken; it is further ORDERED that of the sums awarded herein, Five Hundred Fourteen Thousand Nine Hundred Ninety -Nine and No/100 Dollars ($514,999.00) be awarded for all attorney's fees, expert fees and costs incurred by Respondents; it is further; ORDERED that Petitioner, COLLIER COUNTY, FLORIDA, is entitled to a credit for the good faith estimate of value previously deposited into the Court Registry in the amount of Seven Hundred Thirty Eight Thousand Six Hundred Seventy and No/100 Dollars ($738,670.00), as payment for acquisition of Parcels 251 DAME, 255DAME, 257DAME, 258DAME, 258TCE1, and Exhibit "1" to Joint Motion for Stipulated Final Judgment Packet Page -1340- 5/10/2016 16.K.3. 258TCE2, at which time title to said parcel as described in Exhibit "A" vested in the name of the Petitioner, such sum already having been disbursed to Respondents; it is further ORDERED that within thirty (30) days hereof, Petitioner shall pay the total sum of Nine Hundred Seventy Six Thousand Three Hundred Thirty and No/100 Dollars (S976,330.00) to Bella Patel, Esq., 13026 Waterford Run Drive, Riverview, FL 33569; it is further ORDERED that this Stipulated Final Judgment Order disposes of all claims arising out of the taking of Parcels 251DAME, 255DAME, 257DAME, 258DAME, 258TCE1, and 258TCE2, and that have or could have been asserted in this cause; it is further ORDERED that the Notice of Lis Pendens filed in the above -styled cause and recorded in Official Record Book 5188, Page 3548 of the Public Records of Collier County, Florida be dismissed as to Parcels 251DAME, 255DAME, 257DAME, 258DAME, 258TCE1, and 258TCE2; it is further ORDERED that the Court reserves jurisdiction to enforce the terms of this Stipulated Final Judgment; it is further ORDERED that this Stipulated Final Judgment is to be recorded in the Official Records of Collier County, Florida; it is further DONE AND ORDERED in Chambers at Naples, Collier County, Florida, this day of 32016. HONORABLE JAMES R. SHENKO CIRCUIT COURT JUDGE conformed copies to: Emily R. Pepin, Esq., Co -Counsel for Petitioner, emilypepinna.collier oov..net Bella Y. Patel, Esq., Co -Counsel for Respondents S.D. Corporation and Cypress Landings, Bellai)atelpa@aol.com aol.com Kevin Hendricks, Transportation ROW Acquisition Manager, kevinhendricks ,collier og_ v.net Clerk's Office, Accounting 15 -CA -15801734 Exhibit 111" to Joint Motion for Stipulated Final Judgment Packet Page -1341- 5/10/2016 16.K.3. EXHIBIT "A" Page 27 of 30 LEGAL DESCRIPTION PERPETUAL, NON-EXCLUSIVE DRAINAGE, ACCESS AND MAINTENANCE EASEMENT PARCEL NO.251DAMiE LYING IN THE NORTHEAST QUARTER (NE 1/4) OF SECTION 16, TOWNSHIP 50 SOUTH, RANGE 26 EAST COLLIER COUNTY, FLORIDA A tractor parcel of land lying in the Northeast Quarter (NE 1/4) of Section 16, Township 50 South, Range 26 East, Collier County, Florida, which tract or parcel Is more particularly described as follows: Commencing at the northwest corner of the Northeast Quarter (NE 1/4) of said Section 16; thence South 89'24'26" East on the north line of said fraction for 30.00 feet to the Point of Beginning. From said Point of Beginning; thence continue South 89'24'26" East on the north line of said fraction for 2324.69 feet to an intersection with the west line of a Tract "C" as recorded in Official Records Book 1240, page 1808, public records of Collier County, Florida; thence South 00'17'52" East on said west line for 71.01 feet to an intersection with a line 71 feet south of (as measured on a perpendicular) and parallel with the north line of the Northeast Quarter (NE 1/4) of said Section 16; thence North 89'24'26" West on said parallel line for 369.98 feet to an intersection with the west line of Exhibit 'B" as recorded in Official Records Book 2282, page 1903, said public records; thence North 00'18'45" West on said west line for 1.00 foot to an intersection with a line 70 feet south of (as measured on a perpendicular) and parallel with the north line of the Northeast Quarter (NE 1/4) of said Section 16; thence North 89'24'26" West on said parallel line for 677.37 feet to an intersection with the west line of the Northeast Quarter (NE 1/4) of the Northeast Quarter (NE 1/4) of said Section 16; thence North 00'16'49" West on said west line for 6.00 feet to an intersection with a line 64 feet south of (as measured on a perpendicular) and parallel with the north line of the Northeast Quarter (NE 1/4) of said Section 16; thence North 89'24'26" West on said parallel line for 1,277 36 feet to an Intersection with a line 30 feet east of (as measured on a perpendicular) and parallel with the west line of said fraction; thence North 00'16'35" West on said parallel line for 64.01 feet to the Point of Beginning Parcel contains 155,435 square feet (3,57 acres), more or less. Bearings hereinabove mentioned are based on State Plane Coordinates, Florida Zone East, North American Datum of 83 (NSRS 2007) wherein the north line of the Northeast Quarter (NE 1/4) of said Section 16 bears South 89'24'26" East. 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