Item Q2
BOARD OF COUNTY COMMISSIONERS
AGENDA ITEM SUMMARY
Meeting Date: March 16,2005
Bulk Item: Yes XX No
Division: County Attorney
Staff Contact Person: Pedro Mercado
AGENDA ITEM WORDING: Authority to institute litigation against Sum Air Sevices and/or
Paradise Aviation.
ITEM BACKGROUND: Carol CoUins purchased Sum Air Senrices which operates one of the
F.B.O.'s in Marathon from Ed Steigerwald. Ms. Collins then turned around and leased a portion
of the F.B.O. bKk to Mr. Steigerwald now d/b/a Paradise Aviation. The problem is tbat Deither
party used an attorney in the transaction aDd Steigerwald claims to still be the F.B.O. lease
holder however CoUins is tbe person that until recently has aduaDy been paying the Rnt. For
some reason neitber party has flied a declaratory adion to clarify who is the actual leaseholder
and for the past several months DO payments have been made DB the lease. Marathon airport has
been caught in the middle aDd tbe lease payments are curreDtIy over $16,500 iD arrean therefore
we are seeking to terminate the lease aDd recover the arreages.
PREVIOUS RELEVANT DOCC ACTION:
NONE
CONTRACT/AGREEMENT CHANGES:
N/A
STAFF RECOMMENDATIONS:
Approval
TOTAL COST:
BUDGETED: Yes
No
COST TO COUNTY:
SOURCE OF FUNDS:
REVENUE PRODUCING: Yes
No
AMOUNT PER MONTB_ Year
APPROVED BY: County Au4J? OMBlPurchasing _ Risk Management _
DMSION DIRECTOR APPROVAL: (\ ~-v1L&)li' vbl, K/o<(
1 (TYPE NAME HERE)
DOCUMENTA nON:
Included
Not Required_
DIsPOsmON:
AGENDA ITEM #
OK~~r; S~O?O~3~E
(305) 294-4641
PUBLIC SAFETY
FLORlDA KEYS MARATHON AI
James R. "Reggie" Paras, Director/Manager ~"ll
9400 Overseas Highway, Suite 200 ::.. 2l
Marathon, F1. 33050
Telephone: (305) 289-6002/289-6060
FAX: (305) 289-6071
r~
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
#7002 2410 0000 9944 9708
February 15, 2005
Paradise Aviation, Inc.
9850 Overseas Highway
Marathon, FL 33050
BOARD OF COUNTY COMMISSIONERS
Mayor Dixie M. Spehar, District 1
Mayor Pro Tern Charles "Sonny" McCoy, District 3
George Neugent, District 2
David P Rice, District 4
Murray E. Nelson, District 5
RECEIVED
FEB 1 6 znn~
MONAOE COUNTY ATTORNEY
RE: Notice of Default, FBO failure to pay monthly rent for the premises
To Whom It May Concern:
In accordance with Paragraph 19(a) of the Marathon Fixed Based Operator (FBG)
Agreement made and entered by Monroe County, Florida and Paradise Aviation, Inc.,
effective on April 6, 1998, as amended, this is notice that Paradise Aviation, Inc. is in
default of that Agreement for failure to timely submit the payments required of it under
Paragraph 3. In this case, the monthly payments for the following months are in arrears:
I) October 2004: FBO facility - $8.443.06; 2) December 2004: FBG facility and
aprons, in the total amount of $9.142.07; 3) January 2005: FBG facility and aprons, in
the total amount 0[$9.160.94 plus fuel flow.
Paradise Aviation, Inc.
Page Two
February 15, 2005
If the default is not cured within 15 days of the receipt of this notice, then the
County will terminate the Agreement.
Sincerel},
I
//
'. ,
"-,
James R. "Reggie" Paros, Director
Public Safety Division
Florida Keys Marathon Airport Manager
JRPlsd
cc: Tom Willi, County Administrator
Peter Horton, Director of Airports
./John R. Collins, County Attorney
Pedro Mercado, Assistant County Attorney
OK~~ ~2.~~E
(305 ~ 29<1-M>41
Charles 'SOllilY' McCoy
County Commissioner
530 Whitehead Street
Key iN est, Florida 33040
305-292-3430
FAX; 305-292-3577
E-Mail;BOCCDIS3ra~monrecountv-fl.com
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BOARD OF COUNTY COMMISSIONERS
MAYOR Dixie Spehar, District 1
Mayor Pro-Tem Charles McCoy, District 3
Commissioner George Neugent, District 2
Commissioner David Rice, District 4
Commissioner Murray Nelson. District 5
February 14, 2005
Ms. Carol J. Collins, President/Owner
Sum Air Services, Inc.
9850 Overseas Highway
Marathon, FL 33050
Dear Ms. Collins:
Congresswoman neana Ros~Lehtinen has forwarded your request for her assistance
regarding difficulties you are experiencing related to your purchase of a fixed base operation
at the Marathon Airport Based on your correspondence, there appears to be, or has been,
civil litigation on this matter and you further indicate that you are pursuing criminal charges
for fraud and embezzlement against the previous owner. You also indicate that County staff
has been involved; namely, the County Attorney, Director of Airports and the Airport Manager.
Most of the issues that appear to have created the situation are legal matters which
must be entrusted to the expertise of our County Attorney. I am concerned, however, that
you feel you are being discriminated against and not afforded the same opportunities as others.
Therefore, I am copying your correspondence to our present County Administrator, Tom Willi,
Requesting he research your concerns and respond to you directly with his findings and any
recommended action that may provide some relief.
Sincerely,
'-~/J;#~
D~Z M. Spehar
DMS:kmp
RECEIVED
cc:
Congresswoman neana Ros~Lehtinen
Monroe County Commission
Tom Willi, County Administrator;
John R. Collins, County Attorney
Peter Horton, Director of Airports
Reggie Parros, Airport Manager
FEB 1 6 2005
MONROE COUNTY ATTORNEY
COMMITTEES:
PLEASE RESPOND TO:
2160 RAYBURN HOUSE OfFICE 81)" DIN'C
o WASHINGTON, DC 20515-0918
(202) 225~3931
FAX: 12021 225~5620
INTERNATIONAL RELATIONS
GOVERNMENT REFORM
CHAIR:
SUBCOMMITTEE ON
MIDDLE EAST
AND CENTRAL ASIA
([:ongre~~ of tbe Wniteb ~tate~
~OU5C of l\cprcscntatibcs
ILEANA ROS-LEHTINEN
18TH DISTRICT, FLORIDA
o
DISTRICT OFFICE:
9210 SUNSET DRIVE
Sum: 100
MIAMI, FL 33173
(305} 275-1800
FAX: (3051 275-1801
VICE CHAIR:
SUBCOMMITTEE ON
WESTERN HEMISPHERE
SUBCOMMITTEE ON
WElLNESS AND
HUMAN RIGHTS
January 26, 2005
FfB 1 : 200s
Mayor Dixie Spehar
Monroe County
500 Whitehead St., Suite 102
Key West, FL 33040
Dear Mayor Spehar:
I would like to take this opportunity to bring to your attention the case of a
constituent.
Ms. Carol J. Collins, President/Owner Sum Air Services has contacted me
regarding an outstanding case she has with Monroe County regarding the rent owed by
her business to Marathon Airport. Ms. Collins has also informed me that she is currently
in litigation with the former owners.
I am enclosing Ms. Collins letter and information for your review. Consistent with
all applicable rules and regulations, Mr. Collins would be grateful for your serious
consideration of her case.
Thank you for your attention to this matter.
Sincerel~,
r 11/~ ..
, ..'J!. ,/J n .
Ileana" s- e~n
Member of Congress
IRL :rp
Enclosed
cc: Ms. Carol J. Collins
President/Owner
Sum Air Services, Inc.
9850 Overseas Hwy.
Marathon, FL 33050
PRINTED ON RECYCLED PAPER
Sum Air Services, Inc.
Carol J. Collins
9850 Overseas Highway
Marathon FL 33050
305 743-5201
Congresswoman Ileana Ros- Lehtinen
2160 Rayburn House Office Building
Washington DC 20515
202 225-3931
Dear Ms. Ros-Lehtinen,
December 14,2004
I would like your help addressing numerous difficulties I have had operating a
business at the Florida Keys Marathon Airport in Marathon, Monroe County, FL.
Although the problems have been ongoing since I acquired the business in March of
2003, I had delayed pursuing the issue because there were signs that the county was ready
to address the situation. It has now been quite some time and nothing has happened to
relieve the problems.
Federal law requires that all business located on airports that receive federal
funding have like rent and operating requirements so that they may compete on a level
playing field. I believe that I am being discriminated against due to both the business
practices of Monroe County and the "good old boy" network of the Florida Keys. If the
people of the .'in" group are happy with the status quo, no amount of reasoning or
evidence presented will provide enough incentive to change.
The following is a brief history ofthe situation and, of course, more details are
available as needed.
In March of 2003 I completed .'negotiations" with John Edgar Steigerwald III for
the purchase of a fixed based operation at the Marathon airport. This operation had been
operated as Paradise Aviation since 1998. In January of 2003 Mr. Steigerwald merged
Paradise with the charter service he also operated, Sum Air Services, Inc., and began
operating the FBO as Sum Air Services, Inc. d/b/a Paradise Jet Support. This was done,
according to Steigerwald, for accounting purPoses add so that the name would include the
word "Jet" to be more competitive with the other FBO on the field. That FBO is Grant
Air d/b/a Marathon Jet Center. Mr. Steigerwald's wife, Ute, it turned out, was the
registered owner of the corporation. I wrote a check to Ute Steigerwald for $275,000.00
on March 14th, 2003 for the purchase of Sum Air Ser.vices, Inc. and the FBO lease with
Monroe County. Mr. Steigerwald gave a copy of the Paradise Aviation lease to me and
said, "This is your lease. Put it in a safe place."
Ute Steigerwald had fired Reta Seaver, the bookkeeper, in January of 2003 and
had taken over the position herself. Prior to that, Ute was only at the FBO to fill the
vending machines, and, as far as I knew, never did anything else for the business except
the payroll. Ute stayed on as bookkeeper to train Jeanette Abella who was to take over
the position for me. She left that position on April 8th, 2003.
I will not go into any details of the problems I began to encounter with the
Steigerwalds and the FBO. These problems are related, but are best saved for another
time as I am pursuing fraud and embezzlement charges against the Steigerwalds.
On May 5th, 2003 the County sent a certified letter of default to Mr. Steigerwald
I also received a copy of the letter and tried to speak to Mr. Steigerwald about it. He told
me just to ignore it because the County. as he had told me during our "negotiations". still
owed me for overpayment of rent. This set off alarms in my mind and I immediately
called the Airport Manager. Mr. "Reggie" Paros and asked that he set up a meeting with
the Director of Airports and the County Attorney. My purpose for this meeting was to
introduce myself as the new owner of the FBO and to speak to them regarding the rent
structure. as the rents do not currently allow both FBOs to compete on a level playing
field. I had been led to believe, by Mr. Steigerwald that the work that he and Brad Neat,
the former manager of Paradise had done toward resolving the rent inequities had been
successful. The books that were turned over to me by the Steigerwalds showed a large
credit balance due from the County and he had also assured me verbally that this was so.
I was completely unprepared for the hostile greeting I received from the Director
of Airports. Jim Roberts and the County Attorney James Collins. Peter Horton was also
there, and he and the airport manager remained relatively neutral during the discussions.
Rather than repeat myself, I have attached a copy of a letter I drafted following that
meeting. I intended sending the letter to the county commissioners, but my own attorney
advised against it on the grounds that it was "too strongly worded" At the time I agreed
with him that it would be better to show my own good faith to the County. pay the
outstanding rent as the new owner and establish good relations with the county so that
more favorable operating terms might be negotiated
As of December of2004, it is now two years since the SteigerwaIds have paid any
money to the county. The County refuses to recognize my status as the legal leaseholder
because the SteigerwaIds will not give me a formal assignment of the lease. This is in
spite of the fact that he has admitted, in a hearing before Judge Mark Jones, that I have
paid for said lease. The Steigerwalds have been occupying space in the hangar for which
I pay the county rent. The County gives the SteigerwaIds all the rights of the leaseholder
and does it in a way to handicap my ability to conduct business.
The County also persists in the inequitable rent structure between FBOs that
allows my competitor to use predatory pricing tactics with impunity to lure customers
away from my facility due to their considerably lower overhead (see attachments). They
have also been granted a waiver from the County required insurance coverage of
$5,000,000.00 liability insurance to which I am being held and other waivers and changes
made to the Airport Minimum Standards to accommodate their business practices.
I hope you will see fit to investigate this situation further. I have too much
invested in this business, financially, physically and emotionally to give in to the pressure
that is being placed on me to "go away." I would appreciate the opportunity to meet with
you or your representative to discuss this matter.
R~ctfu1!y' ,.
i~QcdtkU
Carol J/Collins,
President/Owner
BOCC
June 19, 2003
Dear Commissioners,
I am writing as the new owner/operator of Paradise Aviation at the Rorida
Keys Marathon Airport, now renamed Paradise Jet Support.
On May 20th, 20031 met with Mr. Paras, the airport manager, James
Roberts as director of airports, Peter Horton of the Key West airport and Richard Collins,
the County attorney. The purpose of this meeting was to introduce myself to them and to
discuss with them some of the ongoing issues this FBO has had with the operations of the
airport and the difficulties of doing business which are a direct result of actions taken by
county administrators.
All my issues were repeatedly counteracted with the comment that the leases
were awarded on a compettive bid and that any attempts to change the terms of my lease
would result in the lease going out to bid once again and I was told in a most unpleasant and
demeaning tone by Mr. Collins that "You, young lady, would stand to lose it all.H
The fact is the lease at the West end FBO has been changed repeatedly
through the use of waivers and changes in the minimum standards for the sole purpose of
accommodating their goals which has resulting in the West end operation having more
favorable terms and a much lower operating cost.
Federal regulation prohibits an airport which receives Federal Funds from
discriminating against one operator over another. Federal Technical Order 5190.6A 4-
148.(2) states that "Each FBO at any airport shall be subject to the same rates, fees,
rentals, and other charges as are uniformly applicable to all other FBO's making the same or
similar uses of such airport utilizing the same or similar facilities. H
Even this was greeted with the competitive bid argument. All this is
completely ignoring the fact that at the time the leases were bid and awarded the two FBOs
were not in direct competition with one another. Mr. Roberts himself stated at the BOCC
meeting where the permits for a jet fuel facility at the West end were approved "It's about
time we made the two FBOs equal. H "
There is no equality when the rent is so much higher for one facility than
another and we are offering the same product for sale at an overhead which has become
prohibitive. The unequal rent structure allows one business to undercut the other with
impunity in a blatant effort to drive out the competition.
This is not an area of growth as you would have in a large metropolitan region.
The only result of having two facilities offering the same services is a dilution of the business
and the County does not make any more income it only shifts the source.
"
pg.2
When I told Mr. Roberts and Mr. Collins that the County has continuously
raised the rent on the anniversary date, but at the same time systematically chopped away
pieces of our business by giving, first Mosquito Control, then the West end FBO, and now
the Sheriff's department the rights to jet fuel, I was told by Mr. Collins, "then I guess you
picked the wrong business."
I said to him that the County has certain obligations to their lease holders. Mr.
Collins responded with "Obligationst What obligations?" I said "Legal, moral, ethical, take
your pick." He then leaned back in his chair and said, with all the smug scarasm he could
muster, "No, no and no!"
Is this the way the County Commissioners want their representatives to deal
with tenants?
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