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44-2005-CA-266-KDANNY L. KOLHAGE CLERK OF THE CIRCUIT COURT DATE: May 24, 2006 TO: Suzanne Hutton County Attorney ATTN. Kathy Peters Executive Assistant FROM. Pamela G. Han oc Deputy Clerk At the May 16, 2006, Board of County Commissioner's meeting the Board granted approval and authorized execution of a Settlement Agreement in Walgreen's Company and Gadinsky Real Estate, LLC vs. Monroe County vs. Florida Keys Citizens Coalition (Intervenor), Case No. 44- 2005 -CA- 266 -K. Enclosed is the original Settlement Agreement for your handling. Should you have any questions please do not hesitate to contact this office. cc: Finance File ✓ IN THE CIRCUIT COURT OF THE SIXTEENTH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR MONROE COUNTY, FLORIDA WALGREEN'S COMPANY and GADINSKY REAL ESTATE, LLC, Petitioners, VS. MONROE COUNTY, Respondent, and FLORIDA KEYS CITIZENS COALITION, Intervenor. CASE NO.44- 2005 -CA -266 -K JUDGE RICHARD G. PAYNE SETTLEMENT AGREEMENT THIS AGREEMENT has been entered into between Petitioners, Walgreen's Company and Gadinsky Real Estate, LLC, and Respondent, County of Monroe, a governmental entity. WHEREAS, the parties desire to amicably resolve all issues between them relating to this litigation, and WHEREAS, the parties further agree that it is in their best interest to terminate the litigation so as to avoid further expense and delay by entering into this Agreement. NOW THEREFORE, in consideration of the mutual promises and undertakings contained herein, the receipt and sufficiency of which are hereby acknowledged, the parties agree as follows: 1. The Monroe County Growth Management Department shall issue to Walgreen's Company a Conditional Use Development Order approving the Major Conditional Use Application filed by Scotty's, Inc., to demolish an existing Scotty's hardware store on Big Pine Key and construct in its place a 16,510 square foot Walgreen's pharmacy with drive- through pharmacy window, with the following conditions: A. Prior to the issuance of the Certificate of Occupancy, signs shall be posted on the access driveways from Key Deer Boulevard and US Highway 1 that limit the access of delivery vehicles only through the Key Deer Boulevard driveway. B. Prior to issuance of a building permit, the transplantation plan must be revised to delete the removal of two threatened Paurotis Palms. C. Prior to issuance of a building permit, the surface water management plan shall be approved by the South Florida Water Management District. D. Prior to issuance of a building permit, the Florida Department of Health or Florida Department of Environmental Protection, as appropriate, shall approve the Wastewater Treatment System. E. Prior to issuance of a building permit, a Fire Protection Plan shall be approved by the Monroe County Fire Marshal. F. The Keys Energy Services (KEYS) shall determine load requirement based on the review of a complete set of plans and approval shall be received prior to the issuance of a building permit. G. The architectural standards adopted for Big Pine Key shall be incorporated into the building design in collaboration with and subject to the approval of the Monroe County Director of Planning. H. The onsite traffic patterns, including the addition of a perimeter road and integrated bike path, shall be reconfigured as depicted on the site plan attached hereto and made a part hereof. To the extent Monroe County deems it appropriate to do so, all or part of the perimeter road and /or integrated bike path may be eliminated in order to accommodate placement of the waste water treatment facility referred to in subparagraph M below. I. The property owner shall be prohibited from applying for an alcoholic beverage permit for a period of two (2) years commencing from the date of issuance of the Conditional Use Development Order. J. The freestanding sign shall be reduced in size so as to be no larger than the CVS pharmacy freestanding sign. K. Only native vegetation, as approved by the County Biologist, shall be utilized in the landscape buffers. L. Only cutoff lighting shall be utilized and located so as to prevent spillover on to neighboring residential uses. M. If desired by Monroe County, the area to the rear of the pharmacy between the designated employee parking and Northerly property line may be utilized by Monroe County or its designee to construct a sewage treatment facility, the construction, operation and maintenance of which shall be at no cost to Walgreen's. In the event Monroe County does not elect to construct a sewage treatment facility on this site, Walgreen's shall plant a buffer, 30- foot deep, of native vegetation between the Northerly boundary and the designated employee parking. 2. Upon issuance of the Conditional Use approval, Walgreen's Company shall be permitted to apply for all necessary building permits for construction of the Walgreen's pharmacy, consistent with the terms of the Conditional Use approval. Monroe County Growth Management Department shall process the application[s] in the normal course and issue the requisite building permits upon a determination that the application[s] are consistent with the Conditional Use approval. 3. Upon issuance of the Conditional Use approval, Walgreen's Company shall file with the Court a Notice of Voluntary Dismissal of this action with prejudice. 4. The parties shall exchange mutual General Releases in the form customarily utilized by attorneys in connection with litigation in this County. 5. Each party shall bear its own attorneys fees and costs in connection with this litigation. In the event it becomes necessary for either party to commence legal proceedings to enforce the terms of this Agreement, the prevailing party shall be entitled to reasonable attorneys fees and costs in connection with such action. By entering into this Agreement, the parties are not acknowledging the merits or lack of merits of these proceedings. Rather, the parties are entering into this Agreement for the purpose of avoiding further expense and delay inherent in litigation of this nature. IN WITNESS WHEREOF, the parties hereto have executed this Agreement the J ' day of May 2oo6. WALGREEN'S COMPANY COUNTY OF MONROE, a political subdivision of tlw5tate of Florida By: B Keith Miller, Agea4 Atak J sffflo- 144'arr GADINSKY REAL ESTATE, LLC, a Florida limited liability company am Seth Gadinsky, Managing Member ONROE rn. >, - APp ,. e R. rANEY 4 =---- Charles "Sbil'ny "McCoy, Mayor WALGREENS CO. Fax:8473154078 May 15 2006 10:43 PAS this litigstim In the event it becomes necessary for after party to commence legal proceedings to enforce the terms of this Agreement, the prevailing party shall be entided to reasonable attorneys bees and costs to connection with such action. By entering into this Agreement, the parties are not actmo oiedging the merits or lack of merits of these proceedings. Rather, the parties are entering into this Agreement for the purpose of avoiding further expense and delay inherent m litigation of this nature. IN SNT1NEW WHEREOF, the parties hereto have exemftd this Agreement the / of May 2o06. WALGREEN'S COMPANY alley By Keith M Rest If+tmc ~yet• GADDMa REAL WrAM LLC, a Florida limited liability company t - 111 Charles `Sonny" McCoy, Mayor 4 MONROE CO NTYATTO"" �Y APPRO R ERT S. S EF ASSISlt T �otlr �OF Date 7{