RESOLUTION 91-20233 RESOLUTION NO. 91-20233
A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF
MIAMI BEACH APPROVING A SETTLEMENT WITH AT&T
COMMUNICATIONS OF THE SOUTHERN STATES, INC. AND
AUTHORIZING THE MAYOR AND CITY CLERK TO EXECUTE A
SETTLEMENT AGREEMENT, SETTLING AT&T COMMUNICATIONS
OF THE SOUTHERN STATES, INC. V. CITY OF MIAMI
BEACH, CASE NO. 90-55849, IN THE ELEVENTH JUDICIAL
CIRCUIT COURT.
WHEREAS, in AT&T Communications of the Southern States, Inc.
v. City of Miami Beach, case No. 90-55849 in the Eleventh Judicial
Circuit Court, AT&T made a claim against the City in the amount of
$128, 417 . 44 for overpaid Public Utility Tax during the period of
December 1987 through May 1988 ; and
WHEREAS, the City has negotiated a Settlement Agreement with
AT&T to settle the claim for 62 . 4% of the $128, 417 . 44 , or
$80, 132 . 48, plus interest at 8 1/2% per annum from February 1 to
October 15, 1991, with the entire principal settlement amount plus
accrued interest, for a total of $84, 958. 00, payable on or before
October 15, 1991; and
WHEREAS, the City Attorney and the City Manager have
recommended the settlement.
NOW, THEREFORE, BE IT DULY RESOLVED BY THE CITY COMMISSION OF
THE CITY OF MIAMI BEACH, FLORIDA, that the Settlement with AT&T is
hereby approved and the Mayor and City Clerk are hereby authorized
to execute the Settlement Agreement, a copy of which is attached
hereto.
PASSED and ADOPTED this 23rd day of January , 1991.
ATTEST:
City Clerk yor
PNB: lm
FORM APPROVED
LEGAL DEPT.
By
Date -4/2-
SETTLEMENT AGREEMENT
AGREEMENT, dated this 25th day of February,
1991, by and between AT&T Communications of the Southern
States, Inc. (hereinafter referred to as "AT&T") and the City
of Miami Beach ("Miami Beach") , as follows:
WHEREAS, the parties to this Settlement Agreement are
parties in a civil action styled AT&T Communications of the
Southern States, Inc. v. City of Miami Beach, Case No. 90-
55849 currently pending before the Florida Circuit Court of
the Eleventh Judicial Circuit (the "Civil Action") ; and
WHEREAS, the parties hereto wish and are mutually willing
to enter into this Settlement Agreement for the purpose of
settling the differences between them in the Civil Action and
all claims therein, in order to avoid the further risk,
inconvenience and expense associated with their respective
prosecution and defense of the Civil Action;
NOW, THEREFORE, in consideration of the premises and
other good and valuable consideration, the receipt and
sufficiency of which is hereby acknowledged, the parties
hereto agree as follows:
1. payment by Miami Beach. In total satisfaction of
all claims asserted or that could be asserted by AT&T in the
Civil Action, Miami Beach hereby agrees to pay the sum of
$84, 958 . 00 to AT&T, such payment to be made by wire transfer
on or before October 15, 1991.
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2 . Most Favored Nation Status. In the event that AT&T
should agree, after the date of this Settlement Agreement, to
accept payment from any other Florida municipality of an
amount which is a smaller percentage than the percentage of
its claim in the Civil Action accepted from Miami Beach, then
AT&T agrees to refund to Miami Beach, at the time of its
acceptance of such smaller percentage payment, the amount of
money necessary to render the two percentages to be the same.
"Percentage" for the purposes of this paragraph shall be a
fraction, the numerator of which shall be the amount of the
payment accepted by AT&T and the denominator of which shall be
the total amount of the overpayment claim (excluding interest,
costs, or fees) asserted by AT&T on grounds similar or
related to those asserted in the Civil Action. In the case of
a subsequent payment or payments to be made over a period of
time, the applicable percentages shall be determined at
present value, employing a discount rate of eight and one-half
percent (8 1/2%) . The adjustment provided for by this
paragraph shall not apply to any amounts awarded by judgment
or in the event of any final determination of entitlement or
lack of entitlement on the part of AT&T in any judicial
proceeding.
3. Audit. Miami Beach reserves the right, within the
time permitted by law and at its own expense, to audit AT&T' s
public service tax returns and supporting documentation for
the period covered by the Civil Action and assess any amounts
determined to be due as a result of such audit.
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4. Dismissal of the Civil Action. Upon execution of
this Settlement Agreement and payment by Miami Beach, the
parties will cause to be filed with the Circuit Court a
Stipulation of Dismissal of the Civil Action, on the merits
and with prejudice.
5. Costs. Each party shall bear its own costs and
attorneys ' fees.
6. Entire Agreement. This Settlement Agreement
constitutes the entire agreement of the parties. This
Settlement Agreement may not be modified or amended or any
term or provision hereof waived or discharged except in
writing signed by the party against whom such amendment,
modification, waiver or discharge is sought to be enforced.
7. Assignability. Neither of the parties hereto may
transfer, assign or otherwise alienate any of its obligations
under this Settlement Agreement except upon the express
written consent of the other party. Neither of the parties to
this Settlement Agreement may transfer, assign or otherwise
alienate the rights conferred upon it by virtue of this
Settlement Agreement.
8. Full Power and Authority. Each of the parties to
this Settlement Agreement hereby warrants and covenants that
it has full right and authority to dispose of all claims
asserted in the Civil Action, and that it has not previously
transferred, assigned or otherwise alienated any of such
rights. Each of the parties hereby warrants and covenants
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that the person or persons executing this Settlement Agreement
on its behalf is duly authorized and empowered to do so.
9. Counterparts. This Settlement Agreement may be
executed in several counterparts, each of which shall be
deemed an original, but all of which together shall constitute
one and the same instrument.
10. Governing Law. This Settlement Agreement shall be
interpreted and enforced in accordance with the law of the
State of Florida.
CITY OF/M/ EA• ' LOR
BY: L ./
MAYOR
ATTEST:
Try-
, CITY CLERK
SEAL APPROVED AS TO FORM AND LEGALITY
FOR THE USE AND RELIANCE OF THE
CITY OF MIAMI BEACH, FLORIDA
ONLY.
-7zY z , 19 9/.
taer
CITY ATTORNEY
MIAMI BEACH, FLORIDA
AT&T COMMUNICATIONS OF THE
SOUTHERN STA ES, INC.
BY: - 44gEe--C
TITLE: / Tax Director
(CORPORATE SEAL)
ORIGINAL
RESOLUTION NO. 91-20233
Approving a settlement with AT&T
Communications of the Southern States,
Inc. and authorizing the Mayor and City
Clerk to execute a settlement agreement,
settling AT&T Communications of the
Southern States, Inc. V. City of Miami
Beach, Case No. 90-55849, in the Eleventh
Judicial Circuit Court.