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T. County Attorney BOARD OF COUNTY COMMISSIONERS AGENDA ITEM SUMMARY Meeting Date: November 15.2006 Division: County Attorney Bulk Item: Yes l No Department: County Attornev Staff Contact Person: Jerry SanderslMark Rosch AGENDA ITEM WORDING: Approval of a resolution authorizing acceptance of real property located at 936 Crane Boulevard on Sugarloaf Key from the Monroe County Comprehensive Plan Land Authority for affordable housing. ITEM BACKGROUND: The Land Authority is in the process of purchasing the subject property for affordable housing and conveying same to the BOCC (see the Land Authority portion of this meeting agenda for further information). The proposed resolution will add the property to the DOCC's bank of affordable housing sites. The property is currently developed with a single family home that could be rented out as affordable housing until the property is redeveloped. Habitat for Humanity of Key West and the Lower Florida Keys has expressed an interest in being the affordable housing developer of this property. PREVIOUS RELEVANT BOCC ACTION: On September 28, 2005 the Board indicated its desire to have affordable housing land bank sites titled in the BOCC. CONTRACt/AGREEMENT CHANGES: None STAFF RECOMMENDATIONS: Approval TOTAL COST: NtA BUDGETED: Yes No COST TO COUNTY: Nt A SOURCE OF FUNDS: REVENUE PRODUCING: Yes No AMOUNT PER MONTH_ Year APPROVED BY: County Atty -1L OMBlPurchasing _ Risk Management_ DOCUMENTATION: Included X Not Required_ DISPosmON: AGENDA ITEM # Revised 8/06 RESOLUTION NO. A RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA. AUTHORIZING THE ACCEPTANCE OF REAL PROPERTY LOCATED AT 936 CRANE BOULEVARD ON SUGARLOAF KEY FROM THE MONROE COUNTY COMPREHENSIVE PLAN LAND AUTHORITY FOR AFFORDABLE HOUSING. WHEREAS, sections 125.01(1)j and 125.01055, Florida Statutes (FS) empower the Board of County Commissionel"$ of Monroe County, Florida (hereinafter aBOCC") to take measures necessary to increase the supply of affordable housing; and WHEREAS, section 125.35, FS empowel"$ the BOCC to sell or lease real property to the highest and best bidder for the particular use the BOCC deems to be the highest and best or to adopt by ordinance alternative standards and procedures to sell or lease real property; and WHEREAS, sections 125.379 and 125.38, FS empower the BOCC to donate real property to government and nonprofit housing organizations for affordable housing; and WHEREAS, based on the above enabling legislation, the BOCC desires to controt and oversee the development of affordable housing sites acquired by the Monroe County Comprehensive Plan Land Authority; now, therefore, BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA, that: 1. The BOCC hereby agrees to accept title from the Monroe County Comprehensive Plan Land Authority for the real property located at 936 Crane Boulevard on Sugarloaf Key, more particularly described as Block 1, lot 3, North Sugarloaf Acres, Section One (OR 407-695) and having the tax identification number of RE #00117510-000200. 2. The BOCC hereby acknowledges that use of the property will be restricted to affordable housing as defined in the Florida Statutes and the deed(s) into the BOCC will contain the specific deed restrictions shown in Exhibit A. PASSED AND ADOPTED by the Board of County Commissioners of Monroe County, Florida, at a meeting of said Board held on the day of 2006. Mayor McCoy Mayor Pro Tem Spehar Commissioner Di Gennaro Commissioner Murphy Commissioner Neugent (SEAL) Attest: DANNY L. KOLHAGE, Clerk BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA By: By; Deputy c~ ~rrlChairm.n Charles .Sonny" McCoy EXHIBIT A AFFOROABILlTY COVENANTS 1. Term. These affordability covenants are perpetual, run with the land in favor of the Monroe County Comprehensive Plan Land Authority, and are binding on all present and subsequent owners and mortgagees. 2. Prooerty Use. Use of the property shall be restricted to the provision of affordable housing as defined in section 380.0666(3), Florida Statutes, as said statute may be amended from time to time. 3. MonitorinQ. Grantee is responsible for ensuring compliance with the affordability covenants contained herein and expressly agrees to furnish, upon Grantor's request, written certification thereof. BOARD OF COUNTY COMMISSIONERS AGENDA ITEM SUMMARY Meeting Date: 10/18/2006 Division: County Attorney Bulk Item: Y es ~ No Staff Contact Person: Bob Shillinger x3474 AGENDA ITEM WORDING: Authorization to retain the services of the Aronovitz firm to file suit against Hotels.com and similar entities to recoup unpaid bed taxes. ITEM BACKGROUND: Tod Aronovitz, Esq. has already filed suit on behalf of Leon County against internet hotel booking agents seeking to recoup unpaid bed taxes in the U. S. District Court for the Southern District of Florida. Mr. Aronovitz is seeking to represent other counties, including Monroe, and their respective tax collectors in either a class action or consolidated actions against the defendants. Mr. Aronovitz would represent the County on a contingency basis. In litigation of this type, the Court will often establish an award of attorney's fees. If the Court does not, Aronovitz proposes setting his fee at 1/3 of the monies collected; his fee would rise to 38% if this matter was appealed. He also proposes to advance the costs of the litigation which would be ultimately paid by the defendants. The County would only become liable for costs should the defendants prevail and the Courts make an award of costs. This litigation will likely extend over 2-3 years. PREVIOUS RELEVANT BOCC ACTION: On September 20, 2006, the BOCC deferred taking any action on this request until further information could be gathered on the potential cost to the County. CONTRACT/AGREEMENT CHANGES: No~. STAFF RECOMMENDATIONS: Approval. TOTAL COST: TBA if any BUDGETED: Yes ~ No COST TO COUNTY: TEA if any SOURCE OF FUNDS: Ad valorem REVENUE PRODUCING: Yes xx No AMOUNT TBA APPROVED BY: County Atty ~ DIVISION DIRECTOR APPROVAL: DOCUMENTA TION: Included xxx Not Required_ DISPOSITION: AGENDA ITEM # LEGAL SERVICES AGREEMENT This Agreement is entered into by and between Monroe County ("Client") and Aronovitz Trial Lawvers and Freed & Weiss. LLC ("Attorneys") (hereinafter collectively referred to as "the Parties") on this _ day of October, 2006. 1. Authorized Representative of Client. Client designates Bob Shillineer. ESQ.. Assistant County Attornev for Monroe County, as the authorized representative to direct Attorneys and to be the primary individual to communicate with Attorneys regarding the subject matter 0 f Attorney's representation of Client under this Agreement. This designation is intended to establish a clear line of authority and to minimize potential uncertainty, but not to preclude communication between Attorneys and other representatives of Client. 2. Legal Services to be Provided. Attorneys shall represent the Client in litigation (possibly join existing litigation or lead class action litigation) against internet travel companies who do not pay the proper amount of hotel/motel taxes under the applicable law. If Client wishes to retain Attorneys to provide any legal services not provided under this Agreement, then the Parties must execute a separate written agreement for those services. 3. Responsibilities of Parties. Attorneys will perform the legal services called for under this Agreement, keep Client informed of progress and developments, and respond to Client's inquiries and communications. Client will cooperate with Attorneys and kept Attorneys reasonably informed of any developments. Client will also make all necessary persons under its control available for consultation, depositions, hearing, and trial at no cost to Attorneys, Client will likewise make all documents, records, or other evidence under its control available to Attorneys for this case at no cost to Attorneys. 4. Suit as an Individual Case or a Class ActIon Case. Client may bring an action as an individual action or as a class action on behalf of itself and all other similarly situated governmental entities within the State of Florida (the "Class"). If this case proceeds as a class action, then Client bears the responsibilities associated with being a class representative in a class action lawsuit. Thos responsibilities include, without limitation, that Client have a general understanding of the case, vigorously prosecute the litigation, and generally protect the rights and interests of absent class members. 5. Attorney's Fees. Attorneys will receive Attorney's fees for the legal services they provide under this Agreement on a contingent fee basis. A class action case requires the court to analyze and approve fees upon any successful recovery. The term "recovery" shall include, without limitation, the then present value of any monetary payments awarded by the court or agreed to by the adverse parties in this Action or their insurance carrieres). Absent either (a) a court order awarding Client attorney's fees in addition to the Class recovery, or (b) a settlement agreement whereby defendants agree to pay Attorney's fees, Client agrees to pay Attorney's fees of thirty-three percent (33%) of Client's gross recovery or, in the event that any party initiates an appeal, thirty-eight percent (38%) of the gross recovery. If either a court awards attorney's fees in addition to the Class award of attorney's fees are part of a settlement negotiated by the Parties, then Client understands that Attorneys' fees may be in excess of the Legal Services Agreement Page 2 percentages specified above. In no event, however, will Client pay more than the percentages specified above out of its recovery. If payment or all or any part of the amount to bereceived will be deferred (such as in the case of an alUluity, a structured settlement, or periodic payments), the gross recovery, for purposes of calculating Attorneys' fees, will be the initial lump-sum payment plus the present value as of the time of the settlement, the final arbitration or judgment, of the payments to be received thereafter. Attorneys' fees will be paid out of the initial lump-sum payment. If the payment is insufficient to pay the Attorneys' fees in full out of the initial lump sum, then the balance will be paid from subsequent payments on the recovery before any distribution to Client. Client understands that this fee agreement is not set by law but rather is negotiable between Attorneys and Client, determined by a court order, or negotiated as part of a settlement by the parties to the litigation. 6. Costs. Regardless of whether Client brings an individual or class action case, Attorneys will advance all reasonable costs of the Action. Costs include, but are not limited to, expert fees and expenses, investigation costs, deposition expenses, court costs, travel and lodging expenses, and Class notification expenses. In the event of any recovery by Client, Client agrees to reimburse Attorneys for all costs advanced by Attorneys. Absent a court order or settlement agreement to the contrary, Client agrees that costs will be deducted from the recovery after the contingent fee is deducted. 7. Division of Attorneys' Fees. Attorneys may divide the Attorneys' fees received for the legal services provided under this Agreement with additional attorney(s) or law firm(s) retained as associated counsel. Client must approve in writing of any associated counsel before associated counsel performs any work on behalf of Client. Attorneys shall disclose to Client in writing the terms of the attorneys' fee division and the responsibility for advancement of costs. Associated counsel shall have the rights and responsibilities of Attorneys under this Agreement. 8. Representation of Adverse Interests. Client understands that the Rules of Professional Conduct of The Florida Bar require Client's informed written consent before Attorneys may begin or continue to represent Client when the Attorneys have or had a relationship with another party adversely interested in the subject matter of the Attorneys' proposed representation of Client. Attorneys are not aware of any relationship with any other party adversely interested in the subject matter of Attorneys' services for Client under this Agreement. Attorneys shall have the right to represent individuals, other municipalities, governmental agencies, or governmental subdivisions in other similar litigation without the consent of Client, subject to the Rules of Professional Conduct relating to conflicts of interest. 9. Settlement Authority. Attorneys will not settle Client's claim without the approval of Client, who will have the absolute right to accept or reject any individual settlement offer. If this matter proceeds as a class action, then part of Client's responsibilities as a class Legal Services Agreement Page 3 representative is to participate in the analysis of any settlement offer. Ultimately, the court approves any class settlement. 10. Attorneys' Lien. Attorneys will have a lien for Attorneys' fees and costs advanced on all claims and causes of action that are the subject of their representation of Client under the Agreement and on all proceeds of any recovery obtained (whether by settlement, arbitration award, or court judgment). 11. Notices. All written notice and communications to Client relating to this Agreement shall be mailed to or personally delivered to Bob ShiIlin2er. Esq.. Assistant County Attorney for Monroe County, 502 Whitehead Street. 3rd Floor Rear. Key West. FL 33040, and written notices and communications to Attorneys relating hereto shall be mailed to or personally delivered to Tod Aronovitz. Aronovitz Trial Lawyers. 150 W. Fla!!ler Street. Suite 2700. Miami. FL 33130. 12. Termination. In the event that this representation proceeds as a class action, Client cannot terminate Attorneys. Attorneys shall have the right to seek Class Counsel status from the court, and Client shall not interfere with that determination. If Client wishes to cease being a class representative and/or opt-out of the class and retain other counsel, then Client shall notify Attorneys and provide Attorneys with a reasonable opportunity to locate another suitable class representative. 13. Entire Agreement. This Agreement contains the entire agreement of the parties. No other agreement, statement, or promise made on or before the effective date of this Agreement will be binding on the parties. 14. Severability in Event of Partial In Validity. If any provision of this Agreement is held in whole or in part to be unenforceable for any reason, then the remainder of that provision and of the entire Agreement will be severable and remain in effect. 15. Modification by Subsequent Agreement. This Agreement may be modified by subsequent agreement of the Parties only by an instrument in writing signed by both of them or an oral agreement to the extent that the Parties carry it out. 16. Monroe County's performance and obligation to pay under this contract IS contingent upon an annual appropriation by the BOCC Legal Services Agreement Page 4 16. The foregoing is agreed by: ATTESTED BY: , Clerk of the Court By: , Clerk APPROVED AS TO FORM: County Attorney's Office By: , County Attorney Date: 7/~/-~ / Date: L7r~ Client: MONROE COUNTY By: Date: Attorneys: ARONOVITZ TRIAL LA WYERS Museum Tower, Suite 2700 150 West Flagler Street Miami, Florida 33130 (305) 372-2772 Telephone (305) 375-0243 Facsimile FREED WEISS LLC III West Washington Street, Suite 1331 Chicago, Illinois 60602 (312) 220-0000 Telephone (312) 220-7777 F~ . By: -f:~ -A/ Paul Weiss MONROE COUNTY ATTORNEY APPROVED AS T~RM:t7 ~~b__ ~ a~_iJ NATILEENE w. CASSEL ASSISTANT COUNTY ATTORNEY Date /p - It. - n(. STATEMENT OF CLIENT'S RIGHTS Re: Monroe County vs. Hotels.Com. et aI. Before you, the prospective client, arrange a contingency fee agreement with a lawyer, you should understand this Statement of your rights as a client. This Statement is not a part of the actual contract between you and your lawyer, but as a prospective client, you should be aware of these rights: I. There is no legal requirement that a lawyer charge a client a set fee or a percentage of money recovered in a case. You, the client, have the right to talk with your lawyer about the proposed fee and to bargain about the rate of percentage as in any other contract. If you do not reach an agreement with one lawyer you may talk with other lawyers. 2. Any contingency fee contract must be in writing and you have three (3) business days to reconsider the contract. You may cancel the contract without any reason if you notify your lawyer in writing within three (3) business days of signing the contract. If you withdraw from the contract within the first three (3) business day, you do not owe the lawyer a fee although you may be responsible for the lawyer's actual costs during that time. If your lawyer begins to represent you, your lawyer may not withdraw from the case without giving you notice, delivering necessary papers to you, and allowing you time to employ another lawyer. Often, your lawyer must obtain court approval before withdrawing from a case. If you discharge your lawyer without good cause after the three day period, you may have to pay a fee for work the lawyer has done. 3. Before hiring a lawyer, you, the client, have the right to know about the lawyer's education, training and experience. If you ask, the lawyer should tell you specifically about his or her actual experience dealing with cases similar to yours. If you ask, the lawyer should provide information about special training or knowledge and give" you this information in writing if you request it. 4. Before signing a contingency fee contract with you, a lawyer must advise you whether he or she intends to handle your case alone or whether other lawyers will be helping with the case. If your lawyer intends to refer the case to other lawyers he or she should tell you what kind of fee sharing arrangement will be made with the other lawyers. If lawyers from different law firms will represent you, at least one lawyer from each law firm must sign the contingency fee contract. 5. If your lawyer intends to refer your case to another lawyer or counsel with other lawyers, your lawyers should tell you about that at the beginning. If your lawyer takes the case and later decides to refer it to another lawyer or to associate with other lawyers, you should sign a new contract which includes the new lawyers. You, the client, also have the right to consult with each lawyer working on your case and each lawyer is legally responsible to represent your interests and is legally responsible for the acts of the other lawyers involved in the case. 6. You, the client, have the right to know in advance how you will need to pay the expenses and the legal fees at the end of the case. If you pay a deposit in advance for costs, you may ask reasonable questions about how the money will be or has been spent and how much of it remains unspent. Your lawyer should give a reasonable estimate about future necessary costs. If your lawyer agrees to lend or advance you money to prepare or research the case, you have the right to know periodically how much money your lawyer has spent on your behalf. You also have the right to decide, after consulting with your lawyer, how much money is to be spent to prepare a case. If you pay the expenses, you have the right to decide how much to spend. Your lawyer should also inform you whether the fee will be based on the gross amount recovered on or on the amount recovered minus the costs. 7. You, the client have the right to be told by your lawyer about possible adverse consequences if you lose the case. Those adverse consequences might include money which you might have to pay to your lawyer for costs, and liability you might have for attorney's fees to the other side. 8. You, the client, have the right to receive and approve a closing statement at the end of the case before you pay any money. The statement must list all of the financial details of the entire case, including the amount recovered, all expenses, and a precise statement of your lawyer's fee. Until you approve the closing statement you need not pay any money to anyone, including your lawyer. You also have the right to have every lawyer or law firm working on your case sign this closing statement. 9. You, the client, have the right to ask your lawyer at reasonable intervals how the case is progressing and to have these questions answered to the best of your lawyer's ability. 10. You, the client, have the right to make the final decision regarding settlement of a case. Your lawyer must notify you of all offers of settlement before and after the trial. Offers during the trial must be immediately communicated and you should consult with your lawyer regarding whether to accept a settlement. II. If at any time, you, the client, believe that your lawyer has charged an excessive or illegal fee, you, the client, have a right to report the matter to The Florida Bar, the agency that oversees the practice and behavior of all lawyers in Florida. For information on how to reach The Florida Bar, call 800-342-8060, or contact the local bar association. Any disagreement between you and your lawyer about a fee can be taken to court and you may wish to hire another lawyer to help you resolve this disagreement. Usually fee disputes must be handled in a separate lawsuit. 2 Client's Signature: MONROE COUNTY: By: Date: Attorneys' Signatures: ARONOVITZ TRIAL LA WYERS 150 W. Flagler Street Suite 2700, Museum Tower Miami, Florida 33130 (305) 372-2772 Telephone (305) 375-0243 Facsimile FREED & WEISS LLC 111 West Washington Street, Suite 1331 Chicago, Illinois 60602 (312) 220-0000 Telephone (312) 220-7777 Facsimile By: -;Pa-l ~ paulW~ Date: /0 /010 f I / MONROE COUNTY ATTORNEY .A~~ROVED AS TO FO~ /J ".Z6~17J (~ (NATILEENE W CASSEL ASSISTANT COUNTY ATTORNEY Date /D~ II; . a. 3 UNITED STATES DISTRICT COURT SOUTHER.~ DISTRICT OF FLORIDA LEON COUNTY and DORIS MALOY, ) LEON COUNTY TAX COLLECTOR, ) individually and on behalf of all other ) similarly situated counties in the State of Florida, ) ) Plaintiffs, ) v. ) ) HOTELS.COM, L.P., ) a Texas Limited Partnership; ) HOTWIRE, INC., ) a Delaware Corporation; ) CHEAP TICKETS, INC., ) a Delaware Corporation; ) CENDANT TRAVEL OlSTRIBlJTION ) SERVICES GROlJP, INC., a division of ) CENDANT CORPORATION, ) a Delaware Corporation; ) EXPEDlA, INC., ) a Washington Corporation; ) IN TERNETWORK PUBLISHlNG CORP. ) d/b/a LODGING.COM, ) a Florida Corporation; ) LOWESTFARE.COM, TNC., ) a Delaware Corporation; ) MAUPINTOUR, LLC, ) a Delaware Corporation; ) ORBITZ. INC., ) a Delaware Corporation; ) ORBItZ LLC, ) a Delaw'arc Corporation; ) PRICELINE.COM, INC., ) a Delaware Corporation; ) TRA VELOCITY.CO~l, INC., ) a Delaware Corporation; and ) TRAVELOClTY.CO!vL LP. , a Delaware Corporation. ) Defendants. ~Hf n vzW ~ ~~i 'r Case No. .~\R & 1"'1 Y<.<f...,...,y ~ 4' _'_<", i 1~'\ TT: JiTIT'lf"o,:;; ~, '.., -..,'1' .:.:!-!-l;' JOR Y TRIAL DEMANDED ,~ .':0::; ) -) CLASS ACTiON CO~IPLAI2\T Plaimiffs sue Defendants for unpaid Tourist lkvdopment Taxes. and they alkge as follows: :\r~:,;{H<tz -1~~;.J! I..";'.....~.'~r~ \hj~(,.~;n'l l~;vli\.r_, ~ui:c }.?i:)(L i :.::0 \\"C"f Fbglc.'r Str<,ct, .\1iarr~i. i~l(}r~d~ 35130 T _;r:S.>;2~':7;2 ~ 305. }75Jj~..O PARTIES 1. Plaintiff Leon County is a body corporate and a political subdivision established by and authorized to bring suit under F.S. S 125.15, Article I, S 1. I of the Leon County Florida Charter, and ~ 11-46 of the Code of Laws of Leon County. 2. Plaintiff Doris Maloy is the Leon County Tax Collector, an elected public official and constitutional officer and empow'ered b)' S 11-46 of the Leon County Code of Laws to collect and enforce payment of current and delinquent tourist development taxes. 3. Defendant HOTELS.COM, L.P. is a Texas limited partnership with its principal place of business in Dallas, Texas. 4. Defendant HOTWIRE, INC. is a Delaware corporation \\ith its principal place of business in San Francisco, California. 5. Defendant CHEAP TICKETS, INC. is a Delaware corporation with its principal place of business in New York. New York. 6. Defendant CENDA.'l\lT TRAVEL DlSTRffilrTION SERVICES GROUP, INC. is division of CENDANT CORPORATION, a Delaware corporation, \\ith its principal place of business in Parsippany, New Jersey. 7. Defendant EXPEDIA, INC. is a Washington corporation with its principal place of business in Belle\'ue. Washington. 8, Defendant INTER:"'iETWORK PUBLISHING CORP. d.b/a LODGING.COM is a Florida corporation with its principal place of business in Boca Raton. Florida. 9. Defendant LOWESTFARE.COM, INC. is a Delaware corporation with its principal place of business in Non\.'alk, Connt.'Cticut. '"l .\,on..):. itz T~j~ii L~i",-'VI:rs :-.luh'lID1 '[~'1\*)e7, ~"lite 27no> 15() \-Vt.!st r:tdglcf Stre~~::~ \-hall1j~ flortd~l ~~31.:.() T 305..;;1.277': f 5n5375.i':~.43 10. Defendant, I\'1ACpr~TOLR, LLC is a Dela\varc corporation with its principai place of business in Las Vegas. Nevada. Defendant ivtACPINfTOUR, LLC is wholly owned by Defendant MAlJPINTOUR HOLDING, LLC. 11. Defendant ORBITZ. INC. is a Delaware corporation with its principal place of business in Chicago. Illinois. 12. Defendant ORBITZ LLC is a Delaware corporation with its principal place of business in Chicago, Illinois. ] 3. Defendant PRICELlNE.COM, INC. is a Delaware corporation with its principal place of business in Norn'alk, Connecticut. 14. Defendant TRA VELOCITY.COM, INC. is a Delaware corporation with its principal place of business in Southlake, Texas. 15. Defendant TRA VELOCITY. COM, LP is a Delaware partnership \\ith its principal place of business in Southlake, Texas. JURISDICTION A.~D VENUE 20. This Court has subject matter jurisdiction of the claims asserted herein pursuant to 28 V.S.C. ~~ 1331 and 1 332(d){2)(A) in that the amount in controversy exceeds the sum or value of $5,000,000, exclusive of interest and costs, and is a class action in which members of the putative plaintitf class are citizens of States different from Defendants. 21. Venue is proper in this District pursuant to 28 U .S.c. S 1391 (a) in that a substantial part of the events or omissions giving rise to the claims alleged herein occurred, andor it is the judicial district in which at least one of the dcfcndants are subject to personal jurisdiction. 3 \r(\ni.;1':,!Z "fri.it 1....l\,1{'~...~!~ \iLl~;~urn 'l~)wer~ )4ite 27~){}, ~ Sf} \\~t'~il Fl.1gkr StrCr:r~ l\liarnL EoridJ. 3J i,.;~O f 505.5:-2,2771 F 3{j5.3;5.t)2..~3 COMMON ALLEGATIONS A. The Tourist Development Tax 22. Plaintiff Doris Maloy as the Leon County Tax Collector, is empowered to collect the Tourist Development Taxes as set forth in ~ 11-46, et. seq. of the Leon County Code of Laws pursuant to F.S. ~ 125.0104. 23. "'Tourist' means a person who participates in trade or recreation activities outside the county of his or her penn anent residence or who rents or leases transient accommodations as described in paragraph (3)(a)." F.S. ~ 125.0104(2)(b). 24. Florida Statute ~ 125.0104{3)(a) declares the following: It is declared to be the intent of the Legislature that every person who rents, leases, or lets for consideration any living quarters or accommodations in any hotel, apartment hotel, motel, resort motel, apartment, apartment motel, roominghouse, mobile home park, recreational vehicle park, or condominium for a term of 6 months or less is exercising a privilege which is subject to taxation under this section, unless such person rents, leases, or lets for consideration any living quarters or accommodations which are exempt according to the provisions ofchapter2t2. F.S. ~ 125.0104(3)(a) 25. Florida Statute 125.0104 penn its the governing board ofa county to levy, impose, and set a tourist development tax at the rate of up to 4%. F.S. S 125.0 1 04(3)(c) and (d). 26. The tourist development tax shall be charged by the person receiving the consideration for the lease or rental, and it shall be collected from the lessee, tenant, or customer at the time of payment of the consideration for such lease or rental. F.S. ~ 125.0104(3)(0, 27. The person receiving the consideration for such rental or lease shall recehe, account for, and remit the tax to the Florida Department of Revenue, who then on a monthly basis, pays and fl;;tums that tax re'venue to the coumy that imposed the tax. F.S. S i 25.0 104(3)l g). 4 .~..t~Ji:C\ i;;.i-i'j,il k...\'~c:r~ \h;)~'~:n i~~w~(:. S~jite ':70i.Jl t~~~) "oYcst r~aglcr Stc('et. .\lialui. ,HoridJ 33 i :;(} T 3oS.j7':~2i7':: f ~;05.J7;;.0243 28, Leon County Code of Laws S 11~46 (hcrcinatlcr "* 1 1-46" or "Section 11-46") imposes 411;0 Tourist Development Tax. 29. Section I] -46 provides that ..the wurist development tax shall be charged by the person receiving the consideration for the lease or rental and it shalf be collected from the lessee, tenant or customer at the time of payment of the consideration for such lease or rental." ~ 11- 46( c). 30. Plaintiffs and the Class bring one cause of action against each Defendants for Defendants' failure to remit to Plaintiffs and the Class (through the Florida Department of Revenue) the Tourist Development Taxes owed in violation of ~ 11-46 and other substantially similar ordinances of other counties in the State of Florida enacted pursuant to F.S. * 125,0104. B. Defendants' Unlawful Business Practices 31, At all relevant times, Defendants are/were travel agents engaged in the business of renting, leasing, or letting living quarters or accommodations (as described within F.S. ~ 125.0104(3)(a) and ~ 11-46} situated within Leon County and other counties in the State of Florida with substantially similar ordinances enacted pursuant to F.S. ~ 125.0104. 32. Defendants negotiate ""ith living quarters/accommodations a discounted rate for the purchase of room nights, and then Defendants rent, lease, or let them to their customers (generally on-line and over-the-phone) at a marked-up price. 33. Upon intonnation and belief. Defendants fail(ed) to remit 10 Plaintifts and the Class all taxes due pursuant 10 S 1146 and other substantially similar ordinances of other coumics in the State of Florida enacted pursuant to F.S. ~ 125.0104. 34. Instead, Defendants only remit to Plaintiffs and the Class taxes on the room rales they negotiated separatcl)' with the Ji\ing quarters,accommodations at lower pric~s than those paid by the users ofrhe living quartcrsiaccommodations. 5 .lnini)\'jrl. Tfi.ll Ln'.\~r~ Shht.:um ';l.h\'Crc Suite 27"01), 1SC; \-Ve~{ Fbgh!;" ~1n,.et~ \Jklmi1 FlnridJ 33 L30 T j()S.j~2.':;7:-.; ~.; .7(}~..3;.5.n2L:t3 35. When Ddendants charge(d) cuslomers for renting, leasing. or letting these living quarters or accommodations, Defendants identify/identitied to customers the room rate charges. the specified living quarters/accommodations. and the applicable taxes to the customers. 36. Cpon completion of the electronic transaction, customers pay/paid Defendants for the room rates. taxes, and other charges indicated by Defendants. CLASS ACTION ALLEGATIONS 37. Pursuant to Rule 23 of the Federal Rules of Civil Procedure, Plaintiffs bring this action individually and on behalf of the following class (the "Class"): All counties within the State of Florida that (1) are empowered to receive or collect Tourist Development Taxes as set forth in a county ordinance enacted pursuant to F.S. ~ 125.0104 and (2) are not receiving or collecting the full amount due from Defendants' renting, leasing, or letting of accommodations in any hotel or motel. 38. Numerosity. The members of the Class are so numerous that separate joinder of each member is impracticable. On information and belief. the number of potential class member counties is at least fifty. 39. Common Questions of Law and Fact. Plaintiffs' claim raises questions of law or fact common to the questions of law or fact raised by the claim of each member of the class, including inler alia: la) Whether the substantially similar ordinances require Defendants to remit taxes based on the amount of money paid to Defendants by the customers for their rooms; (b) Whether Defendants collected the sufficient amount of TourJ$t Development Taxes from customers; and (c) Whether Defendants remitted a sufficient amount of Tourist Development Taxes to the Plaintiffs and the Class. rh~sc .:ommon questions predominate over any individual questions or issues. 6 '\r<;r:u'.-1G' Tria! I .J~,,'-.('p; ;\!tkt"t.i.fO T<:t"l\,"f- Suit(,~ 2700.15<; \-Vesl Hagh:r Street. ~liami._ ff<)rida 331.30 T 3n5.~;;72.2.;'7:: F 3(5.37~.{j:43 40. Typicality. Plaintiffs' claims are typical of the claims of each member of the Class in that the central subject matter to claims of the Plaintiffs and the Class is that Defendants failed to comply ",,'jtb Ordinances requiring remittance of Tourist Development Taxes. 41. Adequacy of Representation. Plaintiffs can fairly and adequately protect and represent the interests of each member of the class, which are the following: (a) Plaintiffs' claims are substantially similar (if not identical to) those of absent Class members; (b) there are questions oflaw or fact that are common to the Class and that overwhelmingly predominate over any individual issues. such that by prevailing on its oVvn claims, Plaintiffs necessarily will establish Defendants' liability as to all Class members; (C) without the Class representation provided by Plaintiffs, virtually no Class members will receive legal representation or redress for their injuries; (d) Plaintiffs and their counsel have the necessary financial resources to adequately and vigorously litigate this class action; and (e) Plaintiffs and Class counsel are aware of their fiduciary responsibilities to the class members and are determined to diligently discharge those duties by vigorously seeking the maximum possible recovery for the Class. 42. Claim is Maintainable. The claims are maintainable as a class action because Defendants' failure to remit the proper amount of Tourist Development Taxes to the appropriate governmental entity!entities as describe, supra, is generally applicable to all the members of the Class, which thereby makes the final injunctive relief or declaratory relief concerning the class as a v,,'hole appropriate. 7 .\r(':nf.::t,-~tl ':'n~i L~~;,...-;"l.:'i".$ \h.l~~'la1i T)...,'lrer, 'liiI..' }";'~-j(" j:5U \\'eM Fi.1glrr ~i'reet.;\,it:..:.n1L i:'{nriJa .:.:,:; 13{) '"f .~05.j7:::.2-:",; 2 F .j!)5..:::,7~:'.0143 43. Risks of Prosecuting Separate Actions. The pros~cution of separate adions by individual members of the class would create risk of. (a) inconsistent ur varying adjudications with respect to individual members of the class that would establish incompatible standards of conduct for Defendants; and/or (b) adjudications with respect to individual members of the class that would. as a practical matter, be dispositive of the interests of the other members not parties to the adjudications or substantially impair or impede their ability to protect their interests. COUNT I VlOLA TION OF TOURIST DEVELOPMENT T AX ORDINA.~CES 44. Plaintiffs incorporate the allegations in paragraphs I through 43 by reference as if fully set forth herein. 45. Cpon information and belief, from 1986 to present, Defendants charge(d) customers for renting. leasing, or letting living quarters and/or accommodations (as described within F .S. ~ 125.01 04(3)(a) and ~ 11-46) \\ithin the Leon County and other counties in the State of Florida with substantially similar ordinances enacted pursuant to F.S. g 125.0104. 46. Defendants charge(d) customers for renting, leasing, or letting these living quarters andlor accommodations, and it did not remit to the Florida Department of Revenue, on behalf of Plaintiffs and the Class, the Tourist Deyelopment Tax Defendants as set torth in county ordinances enacted pursuant to F.S. ~ 125.0104. 47. Detendants' failure to pa)' the Tourist Development Taxes to Plaintiffs and the Class is deemed a debt uwed by Defendants to Plaintitfs pursuant to ~ 11-46 and other counties in lh~ Slate of Florida"" ith substantially similar ordinances enacted pursuant to F.S. S 125.0104. 8 ,-" ~on-:,'.,ill Tr:~11 r l\" ",~:r~- .\-L4."(.-;.)n'i '1~vt...t:r, ~;l,rrc 27:i.:), i:~O \\'c-~t FL.\~h:r Srri;~t, ~\liunL f!(~(i-da 3-';-130 'TO ...~05.3;2.2.;j2 r ,~o5.,:7;J}2..13 48. The exact amount of Tourist Development Taxes due trom Defendants to Plaintiffs is unknown without an accounting from Defendants. 49. As a direct and proximate result of Defendants' conduct described supra, Plaintiffs and the Class suffered and v.ill continue to suffer damages in the form of \\1thheld Tourist Development Taxes in an amount to be determined at trial. WHEREFORE, Plaintiffs and the Class pray for a judgment in their favor and against Defendants as follows: (a) The Court enters a damage award in favor of Plaintiffs and against Defendants for such sum as is just and reasonable for the damages sustained; (b) The Court awards Plaintiffs and the Class penalties and interest; (C) The Court requires Defendants to allow Plaintiffs to audit the books, records, and other documents of Defendants in order to determine Dettmdants' compliance with tourist development tax ordinances; (d) The Court awards Plaintiffs their attorneys' fees and costs; and (e) The Court awards such other and further relief as the Court may deem just and appropriate under the premises. Plaintiffs demand Ii trial by jury on all issues so triable. 9 ~'\:'(Hl"~'''':~;; Tri~d LH""~'r~ :.,lu~-:~n\ TC~'\~~L S~ll:t." ,"7(10. ~;:\o \.\4!:st flagl~rSt:"("et. ~1i~rni, Fi(;rid~ 33L~d~ r .31'>5.372-.2;~..:2: f _1.fj,j.3-7:).024:j DATED: July 21_, 2006 Respectfully submitted. LEON COLNTY AND DORIS MALOY, LEON COUNTY TAX COLLECTOR B}" Scott Ma ox Florida B No. 65498 MADDOX HORi\"E, P.L.L.C. P.O. Box 10768 Tallahassee. Florida 32302 (850) 222-6020 Telephone (850) 222-] 249 Facsimile T od Aronovitz Florida Bar No. 186430 Steven Jaffe Florida Bar No. 0390770 ARONOVITZ TRIAL LAWYERS Museum Tower, Suite 2700 150 West Flagler Street Miami, Florida 33130 (305) 372-2772 Telephone (305) 375-0243 Facsimile Of Counsel: Robert W. Schmieder II Richard J. Burke Dennis J. Barton III THE LAKIN LAW FIRLv1. P.C, 300 Evans A,..cnue, P.O. Box 229 Wood River, Illinois 62095 (618) 254-1127 Telephone (618) 254-0193 facsimile Paul M. Weiss Will iam M. S \\'cctnam FREED & \.VEISS L1.C III \Vest \Vashington St.re~t, Suttc 1331 Chicago, Illinois 60602 (3 i 2) 220-0000 T dephonc (3 j 2) 220-7777 Facsimile Pro hac vice \lolions fonhcoming. 10 \r'l.f1c.I\'~:l. rfi~i ,.i"'~..~'~.~: :.J;~;.~(.:':_;nl T;-lW("LS\~H\: .:,:-;~-{;~ -~,:'ti \Vt."~l H';l.gJ~r S.tr~~L ;\.~i~U~'1L HnriJ...i Y)i3~j r .~,')5~j; 2.':'7-::' r 5.jS3::'S.t)~~43 Page 1 of 1 Shillinger-Bob From: James T. Hendrick, Esq. Oth@morganandhendrick.com] Sent: Tuesday, September 19, 200611:46 AM To: Shillinger-Bob Subject: Class Action Lawsuit Bob, Attached is a copy of the Complaint filed in the Southern District on behalf of Leon County, et al. as a class action. Tod Aronovitz and his co-counsel, Paul Weiss, are seeking Monroe County's joinder in the suit as a Plaintiff, seeking to recover unpaid hotel tax from Hotels.Com and the other defendants. Can with any questions (296-5676 or 304-7374). Jim 9/19/2006 Page 1 of 1 Shillinger-Bob From: James T. Hendrick, Esq. Uth@morganandhendrick.com] Sent: Tuesday, September 19, 2006 1 :48 PM To: Shillinger-Bob Subject: Class Action suit, Tourist tax Bob, What Tod Aronovitz proposes is to file a separate case against the same Defendants, solely on behalf of MoCo, and to have it consolidated with the Leon County case now pending before Judge Huck. This will give the County undiluted decision-making over terms of any settlement. He estimates the total discovery cost (of all the consolidated cases) to be in the $1-2 million range, all of which will be advanced by Plaintiffs' counsel. At the conclusion of the case, whether by settlement or Judgment, Plaintiffs' atty fees and cost reimbursement will be set by the court and paid from the proceeds ofthe action. Accordingly, Monroe County will have not have to budget or pay those costs and fees. Too is requesting that the BOCC authorize, by letter addressed to him, the filing of the lawsuit by his firm, and his association of co-counsel to assist in the prosecution of the case, with all costs and fees of the action to be advanced by counsel and paid from proceeds of the action. Jim 9/19/2006 BOARD OF COUNTY COMMISSIONERS AGENDA ITEM SUMMARY Meeting Date: 11/15/06 - KL Division: County Attorney Bulk Item: Yes No ~ Staff Contact Person: Bob Shillinger/Jerry Sanders AGENDA ITEM WORDING: Request from John and Ruth Discher to release the affordable housing deed restriction on their property located at Lot 32, Block 10, Cudjoe Ocean Shores Section 2. ITEM BACKGROUND: Mr. and Mrs. Discher desire to sell their property (RE: 001886840-000000) unencumbered by the affordable housing deed restriction, which was imposed when they obtained their ROGO allocation in 1997. The deed restriction runs until 2019. The Dischers contend that at the time they applied for the affordable housing allocation, they were misled into believing that they would only have to pay the impact fees in order to be released from the deed restriction. Staff has been unable to find justification to support their request. PREVIOUS RELEVANT BOCC ACTION: n/a CONTRACTIAGREEMENTCHANGES: n/a STAFF RECOMMENDATIONS: Reject request. TOTAL COST: BUDGETED: Yes No COST TO COUNTY: SOURCE OF FUNDS: REVENUE PRODUCING: Yes No AMOUNTPERMONTH_ Year APPROVED BY: County Arty _ DIVISION DIRECTOR APPROVAL: OMB1~~=~t- SUZANNEA.H ,C UNTYATTORNEY DOCUMENTATION: Included X Not Required_ DISPOsmON: AGENDA ITEM # Revised 8/06 MEMORANDUM TO: Commissioner Spehar District 1 Jerry SlInden ~ Assistllnt County Att~ ~ FROM: SUBJECT: Johll .IId RllIh Discher Affordable Houslll6 Deed Restrictioll RemoVIII Request for Lot Oil Cudjoe Key DATE: FebrulIry 2', 2(J(J6 1. Mr. and Mrs. Discher have been attempting to have the Affordable Housing Deed Restriction removed from the lot upon which their home is located for a considerable period of time. 2. The original restriction was signed by Mr. And Mrs. Discher on July 2. 1997, and recorded in the official record book 1427 page 1328. I attach a copy for easy reference. The Deed Restriction for Mr. and Mrs. Discher is "for twenty (20) years but shall not commence running until a certificate of occupancy has been issued". 3. As you know, the dedication of a dwelling to the affordable housing pool gives development benefits not otherwise available, specifically points in the ROGO permit allocation system. Mr. and Mrs. Discher received those benefits when they applied and obtained preference to receive their building permit in 1997. Mr. and Mrs. Discher received their Certificate of Occupancy on June 30, 1999. A copy is attached. Therefore, the Discher's Affordable Housing Deed Restriction runs from June 1999 through June 2019. 4. The Comprehensive Plan requirement for the long term availability of affordable housing permitted under the ROGO system is implemented in Sec. 9.5-266(f) of the Monroe County Code. This section defines the requirements in the restrictive covenant to insure compliance with the provisions of 1he affordable housing section of the Land Development Regulations. [attache.d a copy for your easy reference. 5. Mr. and Mrs. Discher have been in contact with the Growth Management Division on nwnerous occasions over the past year. Attached is a copy of the letter from K. Marlene Conaway, former Director of Planning and Environmental Resources to Mr. and ~frs. Discher dated April 27. 2005, explaining the affordable housing deed restriction requirements. Also, attached is a copy of a memorandum from Tiffany Stankiewicz. Sr. Planning Technician, to Beth LaFleur, former Director of the Lower Keys Island Planning Team dated August 11,2005, regarding the contacts Mr. and Mrs. Discher have had with that office. 6. No provision exits in the Monroe County Code for '"after-the-fact" rescission of an Affordable Housing Deed Restriction. It appears that Mr. and Mrs. Discher are desirous of removing this restriction solely because it is now economically advantageous for them to do so. It is precisely for this reason that these deed restrictions were initially implemented by the Monroe County Board of County Commissioners in order that affordable housing would remain available. 7. Please do not hesitate to contact me if I can provide additional information or clarification. IS/mt Enclosures ree ,. U. U41&_P .J.UtN'I ""II ICU. H IIUi.-Ift;;R 305-745-8187 JOHN AHDIltnH DISCHElt 22916 BLUEGILL LANE aJDJOE BY. PL31042 1.305-191-6"1'19 1.30S-197..'12.S3 IJJJJ lull 'f) ." (}t\ jDlJ( ft1Jl- Y' f1LE ---- F.~.. 11.... 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M__..tD*............~ T-tw__..__......... ..... ........IIIIIf.. .................. ,.,..-............ .JJII( ..~ .. ................ ........MIll.ll 11.___......___ ."Jlb. 1_. '111.......... 111 1111.......................__ ~~ . - .~.............tD.........,.....ROGlO................. .... J ....._...... ..1IIIr...... WIuIIt .........._... .......a..... _1.......... "ll IW.. ........_ ... ......................,.. I I TlI4.. If...,..., ..,...._.. II,.RI" ...... --c...rr.... .....,..........,....... - I" dIIIII AIIlt.JU..... ......... ,n .,............ -_.._~~\.. p.a -- ! , E I I ! I i [ i I I I I I ! i i i j ; , County of Monroe Plaamlq De,putDaf 2798 Overseas Highway Suire 410 Marathon, Florida 33050 Voice: (305) 289 2500 F 10C: (305) 289 2536 Bfud .r C01llllV c..........'""'-II Mayor Murray Nelson, DiIt. S Mayor Pro Tern David Rke, Dist. 4 Commissioner Sonny McCoy. DiJL I Commissioner Georse Neugent, Oist 2 Commissioner Shirley F~, Dist. 3 April 27, 2005 John & Ruth Discher 22916 Bluegill Lane Cudjoe Key, FL 33042 RE: Affordable Housing Deed Restriction Removal request for Lot 32, Block 10, Cudjoe Ocean Shores Section 2. Cudjoe Key (RE: 001886840.o00ooo) Dear Mr. & Ms. Discher. On April 14, 2005 you submitted a request for the removal of the Affordable Housing Deed Restriction for Lot 32, Block 10, Cudjoe Ocean Shores Section 2. Cudjoe Key. There is no provision in the Conty Code which would pennit the removal of the affordable housing deed restriction. Policy 601.1.7 of the 2010 Comprehensive Plan states: All afforable housing projects which receive development benefits from Monroe County. including but not limited to affoTable housing points in the Permit Allocation System and donations of land, shall be required to maintain the proiect as affordable on a IonS! term basis oursuant todeed restrictions or other mechanisms specified in the Land Development Regualations. and administred by Monroe County or the Monroe County Housing Authority. The Comprehensive Plan requirement for the long term affordablity of affordable housing permitted under the ROGO system is implemented in Sec. 9.5-266(t) Administration and Compliance of the Code. This section defines the requirements in the restrictive covenant to ensure compliance with the provisions of the Afforable houisng Section of the Land Development Regulations. Applicants who previously qualified and then subsuqently received a homestead exemption received a waiver of qualification provided they maintain a homestead exemption. Before new occupants whether owner occupied or teonal occupant the prosepctive occupant(s) must meet the qualifications for affordable housing. There is no provision in the Code or the Comprehensive Plan to remove the restricte covenat before the end of the effective period. Disc;her L32 B I 0 c~oc Ocean Shores See: 2 The County is committed to maintaining the affordablitiy of units that have been permitted as affordable. If individuals were permitted to remove the deed restrictions at will. the complete program would be undermined. I am sorry but I am unable to help you with your request. Sincerely, {~~?- Director of Planning & Environmental Resources cc: Tiffany SbIlJciewicz. Sr. Planning Tcchnic:iln 2 i Page 1 of 1 Stankiewicz-Tiffany From: Stankiewicz~ Tiffany Sent: Thursday. August 11. 2005 11:38 AM To: Lafleur-Beth Subject: AFH Discher On Aug. gll the Discher's came in to discuss th.-e affordable housing application (00188684.005000). They want there deec:I restriction removed since they claim the house can not be sold with the restriction. We explained Marlene Conaway already responded to a previous letter indicating the restriction could not be removed. If they wanted they couk! submit another request. The Di8chers said they refuse to sign any more paperwork for Affordable housing and would be talking to there Attorney. Mr. Discher inalC8ted his home would be worth more if it burned down. They left the office. On Aug. g", 2005, I returned a caD to Tammy G. regarding quesllons on Affordable Housing. I initially request a location of the property and whether the property ts deveJoped or vacant to detennlne which atfordeble housi'1g criteria needs to be explained. She indcated to me the property was vacant so I explained the current guidelines regarding family size, max. seUing price limitation, Iq. footage. et ceteria. A1J we c:onUnued discussing afford8ble housing. I was finally able to determine she was trying to help SOJMOne regarding affordable housing issues. I asked again if the property W8S devek)ped and this time if It was the DIscher property. She s1ated the Discher property of concem. I advised Tammy G. the guidelines I just explained were not applioable to this property. The Discher applied for Affordable Housing In 1997 and where therefore under the old guidelines which are not subject to a selling priCe or a square footage limitation. Someone who earned under 120% of the median income could potentially qualify (58.450 x 120% = $70,140.-). I also expleined the purchaser does not have to live in residence but could rent the dwelling unit within the quidefines {rent charged could not exceed {$70, 140.-x 30%112 = 1,753.50' per month. Later the same day (Aug. glh) lee Rohe. Attorney called me regarding general questions on Affordable Housing. I asked Mr. Rohe if the property location and if it was developed or vacant. He would not give me any information. I explained the affordable housing guideline are specific to the property. 8/11/2005 q'l- 1- OC}OLP tr.) CI tz; :;"'foO ~, -:_' zw :;)0;; o <.' ....l 4: IllI ~~ QU a:; .... zlil. C1 .... ::EO ~-.. ....x. D'" IaI8ftlZCU.. {"'1~1.1 Dwel1Ln9 Vn!t(.)) STAn 01' noRIDA CDUIftY 01' IIODlOa 1'0. ALL WIIOII IT IIU 00IIC&lUr m N all'll \Li...t rtl:'; Sn. N SN ....." ..' 'iI' lIIoU.~ 1. hereby gb..u t. That. ~c+\U~'sCAu.. ~/I(}. the UDde:nivned i.t:;;;) the aol. owner of cuta1n ~.l pr:ope&1:y, altuate, lying and ba"t:; in Kocaroe COUm:y, ft.t:. of FlorWa, de8CIribecl aa fOllowe. oo.-i ...:;1- ...... "" Llrl II. u. toOl~L..'XlJa)~.:~:,A 'fwp. _ Raftge_ Lot:(a>>.:1~ 81ock(e) I I1l. 8ubdlYi.aion.t\14ibt. ~ by. (\~..\ '-t., Vq V' Res ~ , Plat !look I h PI9I' 7.6 '1'bat WIder tbe proYL.~ Mt forth 1ft Cba~ 9.5 of tbal MoIlroe ~y Laad De'ftllos--t Jblval.tione ....IJ: Shan ~ 1'..... ahall be paid by mIY ~-, iacrludJ.D,g anr ~1:a1 ~, prior to race1ving a baildiJ19 pmaJ.t for any new land ....los-ene ~ivUy. III. 'l'hat under eM affordable bouaiDv pcovbJ.on. Nt f~h ~r 9.5 of &aid LaneS o...lopMDt: ltegUlat:lon., the owner or . f the abo9'e--ilellCr!bed ~.1 ~y bava ...." exe.pt:ed froe pa,..eat of their "rail' Sban ~ ..... tal: a {(aback OM) )(' aLogl. taaily,_lIIUlti-f..Uy, ftIObU. ~) dwellJ..nq lO'b". cone~ on II&J.d ~1 propart:r. % ~ .... "'" .... l%; .. ~ m...: t~ ':-.,! r-- 1><1 (J' <;:J 0'1 4: ...~ .or -I I.-~ --J C-J ..c; IV. 'that: t:he _1., tru.f.r, iDheritance. ..e~ en: rantal of any Mfordabl. aoua1Dg Ollie aM.11 only be to pe&'.... who qualify I.UldeZ' . the Coum:y' e cu~ Affordab1.e Roua1ng eU9Utllity r1l9l1r.-nU .. eat:abU.hed ADd ueDCled froa ~~ to tiae. All o~ tM ll'..t:.dccJ.on. beJ:'ein. aball be bJ.ndJ.ft9 upon any tranafereee, 1......, bein or ...igaee.. '" ...;; :" ocr. ~...... v. '1'h&~ tbe CO'nDant. Ithall be effect:J.ve for twenty (20) ,.are but: .ball not c~ ll'UIUl.ln9 until a certificate of 0CCI'lIJl8.ftCY h.. beeft i..ued by the bu11dLn9 official for the dwelling unit: eo whicb the covenant or covenant. apply. Vt. That tbe3pp1J.C&At:(~ua" tbe aUordel. houei.Ag' progr.. to gain a4dltlona po1nt:. 1n tM pa&'lDit: al1oeation ayat:_ P'U'.uane to the ow.llJ.ng Unie Allocatlon T.~ a.endaeDt:. ~1nanc. 016-1992. 0;2; t.. <eI: ~o 'AI'8OU8.0"./'r1D.PH ! i I I ! 1 i ! I ! I I I , ! f . ! i I i , i I f f 0\ N tD(TJ I.On m"" .e Sn. N Si\l .r- H . 'it ~r--! ..."I..,. '-'00: a...:c ( == ~ ... .:;_::;: ;:- -. ~._1?Q~ & _ L_ .~!Ii.1:Lag the .Jr" ,..-..::t.l. ---. ~Q:i'JH. IWGh. : c-f Ad4rH.. ~t?/ ..ID .r~fFf/~/7' U~~ ~j5.~~~ AiSU.... ~~:I St? R,ofiFvelr d/vtl /J? II q ~r-r F;t JJOY() in .... "1tM.~".' , (.1cm.at:~ _ Pr1At/. "I , =~~~~:~ ~~~:1~ Fl 336U; ftJ.at:J'1'Jpe _. __~ Acldr...s ~'1 'L>~l~ AuI!:I&.nGIV~ .331&9 STAB OW ~.1 QOUII'fr or 7'h -.._ CL.- 1IOftU~ WIONG.~ carr-::.... -- ..... . ,.,~co.lC BUOU - tu. day per__Uy appH.I:lId ...Jbh.... 1) I ~ ct... V,.. ~uH, 1> '~f"#7i ' who, !Malft9 duly WDrD, depo... and aay/..y. that: ~"''''f. 18 u. ~ ~ t:1t:l. bal.s.r(.) of Ute ~lICr.l.bed. r..l I*~y .1t:uat:.s 111 ~ CouAty, Plorlda. TM lad1.1..1(_) 1e/u. peracmal1y IcnawD to _ or bu/baye p~c_ .. lc1aae1flcat:1oft. Swan to ...s iIU1Mcdbld befoN - thi. ,J"Jda,. of _1J..ol , A.D. 1~ ~ IO'rAIll' PUBLIC. JQ__ C.f1J-- Prs.. .$1t'~AI r....DfI",,,... -L/./ staU of _ 1.... -; ~'J ..k4t:' t/~I Ify ea.l..1on hplre.. ?A?tP/&./! .J V /7 J~Ah ;;J;.5'c.(7'F ~>/ / ..-n."~' 'AftlOOS.04-<.'1TrUII :;>/ ,. ,rt1.# Jf.-;/~~ P-6't/) f"- /~l.O.rt"u(/r plvt1{ / . .n..:; tvesr -r;Z. A',PZ /,tPY,9'=: .3Jt?jt.t!J MONROI COUNt V 0" r CI AL RRCOROS ! i ~ i I I I I I i I r I I ! ! I ! f --, ~'V101l.rOC COUllt '" j gUll~en' CBK'J.'.tI'IOATB OJ" OCCUPANCY OWNSR: DISCHER JOHN " RUTH PERMIT NUMBER: 97~10000906 000 000 , . THIS IS TO CERTIFY THAT THB BUILDING LOCATED AT: L32 B 10 CUDJOB OCBAN SHORBS RE NUMBER: 28-66-28-018868-40050-00 FOR WHICH PERMIT HAS HERETOFORE BBEN ISSUED. HAS BEEN COMPLBTBD ACCORDING TO PLANS AND SPECIFICATIONS FILED IN THE OFFICE OF THE MONROE COUNTY BUII..OING INSPSCTOR, AND THAT THE PROPOSED USE OF THE aUILDING, TO WIT, AS A SINGLE FAMILY HOME COMPLIES WITH ALL THE BUILDING AND HEALTH LAWS AND ORDINANCES OF MONROE COUNTY AND IS APPROVED FOR THIS USE. BK 10 LT 32 AMENDBD PLAT Ct.T THE FOLLOWING INSPECTIONS HAVE BEEN MADE AND APPROVED: FINAL BIOLOGICAL FINAL ROOF COLUMNS/TIE BEAM FRAMIl-lG AUGERS GROUND SLAB FINAL BUILDING FINAL SEPTr c ROUGH ELECTRIC - TOTAL FINAL ELECTRlC Ale DUCTWORK FINAL AIC ROUGH PL.UMBING - TOTAL FINAL PLUMBING SPECIAL NOTES: THE FOLLOWING ROGa POINTS HAVE BEEN MET: I.QUALIFIED FOR AFFORDABLE HOUSING 2.ULTRA LOW VOL. PLBG. FIXTURES 3.BEER 12 4. BPI 69.44 5 . SOLAR HWl-t 6.130 MFH WINO LOAD 7.155 MPH WIND LOAD 8.CERT. OF ELEV. IN PILE SHOWING SPR AT 15.7' TO ROOFING (IN PROCESS) SLAB/WOOD FLOOR ROOF TRUSSES/SHEATHING INSULATION/DRYWALL BNCLOSURE - FINAL Il-lSULATION - ONLY CERTIFICATE OF ELEVATION TEMPORARY POLE ELECTRICAL SERVICE ROUGH A/e FREON LINES GROUh,) ROUGH PI.l1MBING SEWER CONN8CTION FF !,~; ~ 1 DATED THIS 30 DAY OF JUNE 1999 F'RMIZ HARD1N; , : (<.' BUILDING INSPECTOR CERTIFICATE NL~BER 99-1000051 PHILIP STANDISH/:.. ~.:.. , PLUMBING INSPECTOR WALTER JENKINSI e fib .lol" , ELECTRICAL INSPECTOR f 9.5-266 MONROE COUNTY CODE b) Financial aid to bomebuyers as mortgage assistance, inclusive of loans for down payment assistance; c) Financial incentive for the conversion of transient units to affordable residential units; d) Direct investment in or leverage to housing a1fordability through site acquisition, housing development and hous- ing conservation; or e) Other affordable housing purposes may be established by resolution of the board of county COInmiRSionerB, which shall act as trustees for the fund. The board of county commissioners may enter into agreements with the Mon- roe County Housing Authority; a quaHfied eommunity housing development organization created by the board of county commissioners, or a municipality within Monroe County. (e) Community housing development organization. The board of county commissioners may establish a nonprofit community housing development organization (CHDO), pursuant to federal regulations governing such organizations, to serve as developer of affordable housing units on county-owned property, including or located in the municipalities oftbe county, upon interIocal agre&- ment. In such event, the county may delegate to the community housing development organization all or partial administration of the a1fordable housing trust fund. (0 Administration and compliance: (l) Before any building permit may be issued for any &true- ~ portion or phase of a project to this section, restric- tive covenants(s) shall be filed in the Official Records of Monroe County to ensure compliance with the provisions of this section rtlJlning in favor of Monroe County and enforceable by the county and, if applicable, a participat- ing municipality. The covenants for any affordable hous- ing units partly or wholly financed by a public entity shall be effective for a period of at least fifty (50) years. The covenants for any a1fordable housing units relying wholly upon private non-public fuu~neing shall be e1fective for at least thirty (30) years. The covenants shall not coml1)ence Supp. No. 88 800.160.2 I ( LAND DEVELOPMENT BEGULATlONS I 9.6-266 rnnning until a certificate of OCC11pancy has been issued by the buDding official for the dwelling unit or dwelling units to which the covenant or covenants app~ (2) Restrictive covenants for housing subject to the provi- sions of this section shall be filed. that require compliance with the following: 8. Restricting affordable housing dwelling UDits to hous&- holds meeting the income requirements of section 9.5-266(a)(6)a. b. Restricting employee housing dweIliDg units to h0use- holds meeting the income and employment require- ments of section 9.5-266<aX6)b. c. Restricting market rate housing dwelling units to households meeting the employment requirements of section 9.5-266(a)(8)a. d. Restricting affordable and employee housing dwell- ing units to no more than thirteen hundred (1,300) square feet of habitable space. e. Prohibiting tourist housing use or vacation rental use of any housing developed under the provisions of this section. (3) Tbe eligibility of a potential owner-occupier or renter of an affordable, employee or market rate housing dwelling unit, developed as part of an employee or affordable housing project, shall be determined by the plAnning department upon submittal of an affidavit of q1JaJifi~tion to the pJAI):Qjng department. The form of the aflidavit shall be in a form prescribed by the plAnning department. This eligibility shall be determined by the p)~nning department as follows: a. At the time the potential owner either applies for affordable housing ROGO allocation, or applies to purchase a unit that utilized affordable housing ROGO allocation; or b. At the time the potential renter applies to occupy a residential unit that utilized an affordable ROGO allocation. Supp. No. 89 800.160.3 f 9.5.266 MONROE COUNTY CODE (4) Except as provided in paragraph (5) below, the property owner of each affordable employee or market rate ~ dwelling unit, developed as part of an af1brdab1e or employee housing project, shall be required to aanuaIly submit an affidavit at qUAlification to the plAnn;". de-- partment verifying that the applicable employment and income requirements at paragraph (2) above are met. The annual aftidavit of qualification shall. be in a form pre- scribed by the p)~nning director and shall be filed by the property owner upon receiving written notification by certified mail from the p)fl"ning department. (5) The owner-occupant of an affordable, employee, or JD8J'- ket rate housing dwelling unit, developed _ pert of an affordable or employee housing prqject, who has received a homestead exemption as provided for under the PJ.o:rida Statutes, is not required to submit an annual aflidavit of qualification 88 required above in paragraph (4) if that owner-occupant W8S qualified previously by the plAnning deparbnent. Prior to any chAl'\ge in ownership (inducting, but not limited to: sale, assignment, devise, or othenrise)~ the owner-occupant shall be required to provide documen- tation to the p1Al'ning department in a form prescribed by the planning director proving that the potential OCC11py~ ing household is eligible to occupy that unit prior to a change in ownership of the property. (6) Failure to submit the required annual verification as required in paragraph (4) above or failure to provide documentation prior to change in ownership required in paragraph (5) above shall constitute a violation at the restrictive covenant, the conditions of the certificate of occupancy and this chapter. (7) The restrictive covenants for affordable and employee housing required under this section shall be approved by the growth management director and county attorney prior to the recording of the covenant and issuance of any building permit. (g) [Reserved.] Supp. No. 89 800.160.4 LAND DEVELOPMENT REGULATIONS f 9.5-267 (h) I~rlocal affordable rate of growth allocatUm a.greementB. The Monroe County Board of County CnmmilUrioners may autho- rize interlocal agreements between the county and the cities of Marathon, and Key West, and Islam.~ Villap of glands for the purpose of sharing residential rate of growth aftOrdable housing allocations. The interlocal agreements may be based upon a specific project proposal within ODe or more jurisdictions or may be for a spec:i.tic allocation of units on an annual basis. from the county to a municipality or from a municipality to the county. All allocations made available to a jurisdiction must meet the applicable affordable housing requirements of the receiving jurisdiction's land development regulations and aft'ordable hOWl- ing (JI'fUn8llCe8. (Ord. No. 33-1986. f 9-306; Ord. No. 40-1987. If 6. 73, 74; Ont. No. 6-2001. f 2; Ord. No. 003-2002. 11; Ord. No. 013-2002. If 1. 2; Ord. No. 030-2003. H 5-8; om. No. 047-2008. f 1; Ord. No. 036-2004. f 2; Ord. No. 035-2004. f 4) See. 9.1-..,. H-mmum hotel-motel, recreational vehicle and butitntiODal residential densitiea. Jla. NflI AllocGRd ~ Lt:md u. ~ (roDI'IUlbuJld4bN IMtrit:I and U. (romu/~ tu:rd a.SA. · Urban Commereial: Hotel 10.0- 19.0 0.2 ID8t. Rea. 16.0 24.0 0.2 Bee. Rental 15.0' 16.0" 0.2 Urbul Remda..t.:.l. last. BeiI. 10.0 20.0 0.2 Urba Be8ideotial JI.oblIe Home: Bee. ..tal I 5.0 I 1.0 0.2 Urban ~ Mobile Home-Limited: Bee. Reot8l 6.0 7.0 0.2 Bot.el 10.0 U1i.0 0.0 Jut. Res. 5.0- 20.0 0.0 Bee. Beat8l 10.0-' 10.0* 0.0 Sub Urban Residential: 1nBt. Rea. 3.0 6.0 0.6 Hotel 6.0 litO 0.5 Bee. Rental 6.~ 10.0- 0.5 Demlletion Reeort: Supp. No. 90 800.161 BOARD OF COUNTY COMMISSIONERS AGENDA ITEM SUMMARY Meeting Date: 11/15/06 - K.L Division: Coun~ Attorney Bulk Item: Yes No~ Staff Contact Person: Jerry D. Sanders AGENDA ITEM WORDING: Discussion of proposed settlement of Florida Kevs Citizens Coalition and Last Stand v. Department of Community AUairs and Monroe County. FL. Case No. DOAH 06-2449GM. ITEM BACKGROUND: Two environmental groups, Florida Keys Citizens Coalition and Last Stand, have challenged the Department of Community Affair's approval of five (5) Monroe County Ordinances implementing the Tier System. On November I, 2006, the Board rejected a proposed settlement agreement that would have resolved the challenge and directed staff to negotiate a revised settlement agreement. This item is being placed on the agenda at this time in the event that a revised agreement is negotiated between now and the November 15th BOCC meeting. PREVIOUS RELEVANT BOCC ACTION: On 3/15/2006, BOCC approved Ordinances 008-2006,009-2006,010-2006,011-2006 and 013-2006. On 7/19/06, BOCC directed staff to defend the Challenge. On 9/25/06, the Board authorized staff to continue the final hearing because a tentative settlement agreement was close to being reached. On 11/1/2006 the BOCC held a Closed Session to discuss settlement options and in open session rejected the settlement proposal of September 26, 2006. CONTRACVAGREEMENTCHANGES:N/A STAFF RECOMMENDATIONS: Discussion of the proposed Settlement. TOTAL COST: BUDGETED: Yes No COST TO COUNTY: SOURCE OF FUNDS: REVENUE PRODUCING: Yes No X AMOUNTPERMONTH_ Year APPROVED BY: County Atty ~ DIVISION DIRECTOR APPROVAL: DOCUMENTATION: * Included Not Required _ *Not available at this time. DISPOSITION: Revised 2/05 AGENDA ITEM # BOARD OF COUNTY COMMISSIONERS AGENDA ITEM SUMMARY Meeting Date: 11/15/06 - KL Division: County Attorney Bulk Item: Yes ~ No Staff Contact Person: Suzanne A. Hutton AGENDA ITEM WORDING: Approval of a resolution amending Resolution No. 386-2006 to correct a scrivener's error which omitted the fee for the three-year County license alternative for cats that are not spayed/neutered, specifically 2.E.(2)(b) ITEM BACKGROUND: On September 20, 2006, the Board approved Resolution No. 386 -2006 to provide the alternative three- year license in conjunction with the three-year rabies vaccines administered to some pets. Animal control contractors report a significant number of people selecting the three-year vaccine making the alternative three-year license desirable. PREVIOUS RELEVANT BOCC ACTION: On June 21, 2006 the Board approved Ordinance No. 006-2006 and correlating Resolution 240-2006. On September 20, 2006, the Board approved Resolution No. 386-2006. CONTRACT/AGREEMENT CHANGES: N/A STAFF RECOMMENDATIONS: Approval. TOTAL COST: BUDGETED: Yes No COST TO COUNTY: SOURCE OF FUNDS: REVENUE PRODUCING: Yes....x.... No AMOUNTPERMONTH_ Year APPROVED BY: County Atty ~ OMBlPurchasing _ Risk ~ement ~ -- ~ ~N' COUNTY ATTORNEY DIVISION DIRECTOR APPROVAL: DOCUMENTATION: Included X Not Required DIsPosmON: AGENDA ITEM # Revised 2/05 RESOLUTION NO. - 2006 A RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA, AMENDING RESOLUTION NO. 386-2006 TO PROVIDE A THREE-YEAR COUNTY LICENSE FEE FOR CATS THAT ARE NOT SPA YEDINEUTERED. WHEREAS, Resolution 386-2006 was passed by the Board of County Commissioners on September 20, 2006 providing for one-year and three-year County licenses, fees for dogs, cats and ferrets and replacement license; and WHEREAS, a scrivener's error resulted in the omission of the 3-year County license fee for cats that are "not spayed/neutered and 6 months of age or older", 2.E. (2)(b); and WHEREAS, the animal control contractors report that there are a sufficient number of people selecting the three-year vaccine for their pets to make the alternative three-year license also desirable; NOW, THEREFORE, BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, that: I. Section 2.E. of Resolution No. 386-2006 is hereby amended to read: 2. E. County License: (1) Dogs: (a) Animal is spayed/neutered or under 6months of age (b) Animal is not spayed/neutered and 6 months of age or older ONE YEAR TIJREE YEAR $10 $20 $35 $75 $10 $20 $35 $75 $6 $10 $2 (2) Cats: (a) Animal is spayed/neutered or under 6months of age (b) Animal is not spayed/neutered and 6 months of age or older (3) Ferrets: (4) Replacement (per replacement, regardless of years covered) (5) Dogs and cats with microchips or other means of permanent identification and with registration to the County or a national identification service current to the owner, shall receive a $5 discount from the annual license fee. _ PASSED AND ADOPTED by the Board of County Commissioners of Monroe County, Florida, at a meeting of the Board held on the 15th day of November ,2006. Mayor McCoy Mayor Spehar Commissioner Neugent Commissioner Murphy Commissioner DiGennaro (Seal) Attest: DANNY L. KOLHAGE, Clerk BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA By: Deputy Clerk Date JESOLUTlON NO. _.~ A RI'SOLUTION 011' THE BOARD 011' COUNTY COMMISSIONERS 011' MONROE COUNTY, :n.o1UDA, AMENDING RI'SOLunON NO. -.20D6 1'0 PROVIDE A THREE-YEAR ALTERNADVE IN 1'IIE DOG, CAT . nRRET LICENSE JI'EI'S. WIIEREAS, RaoIutioD No. 240-2006... ....... by dIG lbrd ofC'AJullty c-i..... (BOCC) to mriIe the fees to be cbuged fOr various animal COIIIJOl services ; aDd WIIEREAS, RaolutioR No. 240-2006 ..Jilfti~ tbc alllrallive ...,.,1iceaIe &Y8iJabIe ill coajuDcIion with the tbree-year tabies vaccine which are wImi"ittered to some pets; aDd WIIEREAS, tbc.wnal coaIn)J ~4lCtOB n:poIt duIt tbcrc are a tufIicietIt JJUmbcr ofpeople ~ the tbn:e-year vacciDe for tbeir pets to make the aItemative tbree--year Iic;easc also cIcsirable; NOW, THERUORE, BE rr RESOLVED BY1HE BOARD OF COUN'IY COMMISSIONERS OF MONROE COUNlY, that: 1. Scdioa 2.B. of RcIoJutioa No. 240-2006 is hereby ~ to..: 2. E. Coualy UceaIe: (I) Dogs: (2) Call: (a) ADimaI is IpIIYCIdIacutcr 01' U8der 6IDOIdhI of.. (b) Animal is DOt spayedfneutcJrcd and 6 months of.. or older <a) ADimal Is spayClCllneutered or under 6mon1bs of.. (b) AaiaaI _DOt ~aad 6111011th1 of. OI'oIdec QNJ YEAR. nnum YEAR. $10 120 S3S $7S S10 S20 $35 $6 $10 S2 (3) Femes: (4) a.:p~ (per ~...... ofyclll covcrecI) (5) Dop and cats with microchips or other IDC8III of iM=IiIIIIluCdt identifUWtW. aad widl reptndion to the County or a ft8tioDal idadification SClI'Viee c:urreot to the OWD<<. sbaII receive a S$ <Nc:ount tiom the anauallK:ense fee. PASSED AND ADOPTED by the BoenI ofCouaty ~~ ofMaaroc Couaty. Florida. at a meetiDa of the Boeni held OIl the 20Ch day ofSeptembcr . 2006., _ _ . -MONROE'COUNTY ATTORNEY APPROVED AS ~ - . ~ ~A~N~. CASSat: ..... - ASSISTANT COUNTY ATTo!!,e€ Date /0-/7- 01 ~(' jiIf R 0,..:.... -t rYt;x-< ("'). r - BOARD OP COUNTY COMMl~~_ OP MONROEI:UNTY' n.o~~~<. ! . . 'r- Q ..., (;) .. I m r By: ~ ~ Mayor. fiI fiI :r. 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