CAP-01-210
IN THE CIRCUIT COURT OF THE SIXTEENTH JUDICIAL CIRCUIT
IN AND FOR MONROE COUNTY, FLORIDA
JOHN MOORE,
Plaintiff,
v.
CASE NO. CAP-01-21O
MONROE COUNTY, a political
subdivision of the State of Florida,
Defendant.
/
STIPULA TED SETTLEMENT AGREEMENT
The parties hereby stipulate and agree to the following settlement stipulation, as follows:
1. The parties agree that the structure located on the subject property has not been
"substantially damaged" as that term is defined in Monroe County's floodplain regulations, and
that Plaintiff has the right to make improvements to the subj ect structure, provided the proposed
improvements do not exceed $115,000.00, which the parties agree is less than the threshold for
"substantial improvement."
2. Plaintiff shall demolish (with appropriate permits) and/or shall obtain after-the-
fact permits for all improvements made pursuant to or related to the improvements made in
connection with a movie production on the property. Said demolition costs shall be included in
the $115,000.00 set fort in Paragraph 1 herein.
4. Plaintiffs proposed development shall remain within the footprint of the existing
improvements and shall comply with all applicable requirements of Monroe County Code
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5. The Agreement is not intended and shall not be construed to authorize any
specific development, and Plaintiff shall comply with all Code provisions and requirements for
development as required by the Code.
6. This Agreement is contingent on final approval by Resolution of the Monroe
County Board of County Commissioners. Following said final approval, this Settlement
Stipulation shall be incorporated into an agreed final judgment, and the Court shall retain
jurisdiction for one year to enforce the terms and conditions of this Stipulation, as needed.
Thereafter, the Clerk is directed to close the file.
WHEREFORE, the Parties hereby agree to the foregoing in settlement of all matters at
issue in this action.
AND~'
~
Florida Bar No. 136964
MORGAN & HENDRICK
Attorneys for Monroe County
317 Whitehead Street
Key West, Florida 33040
305-296-5676
305-296-4331 (fax)
KCabanas@morganandhendrick.com
Florida Bar No. 184825
Attorney for Plaintiff
P.O. Box 620
Taverneir, FL 33070
305-852-3388
tobinlaw@terranova.net
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