2001-24400 RESO
/
RESOLUTION NO. 2001-24400
A RESOLUTION OF THE MAYOR AND CITY COMMISSION
OF THE CITY OF MIAMI BEACH, FLORIDA APPROVING
A SETTLEMENT BETWEEN THE CITY OF MIAMI BEACH
AND AMERICAN RIVIERA REAL ESTATE COMPANY, AND
PALM COURT AT 23RD STREET, LTD., (PALM COURT,
INC., GENERAL PARTNER), AUTHORIZING THE
EXECUTION OF ANY AND ALL NECESSARY
DOCUMENTS.
WHEREAS, the City of Miami Beach filed an eminent domain case against American
Riviera Real Estate Company, and Palm Court at 23rd Street, Ltd. (Palm Court, Inc., general partner)
for the acquisition of the following legally described property:
Lots 4 and 6, Block 2, MIAMI BEACH IMPROVEMENT
COMPANY SUBDNlSlON, as recorded in Plat Book 5, Page 7, of
the Public Records of Miami-Dade County, Florida, also known as
Lots 4 and 6, Block 2, AMENDED PLAT OF THE OCEAN FRONT
PROPERTY OF THE MIAMI BEACH IMPROVEMENT
COMPANY, according to the plat thereof, as recorded in Plat Book
5, Page 7, ofthe Public Records of Miami-Dade County, Florida
in City of Miami Beach vs. American Riviera Real Estate Company. et al. Eleventh Judicial
Circuit Court Case No. 99-2418 CA 06, General Jurisdiction; and
WHEREAS, all parties in the above-referenced case ("Parties") desire to settle the case to
avoid further costs and risks ofJitigation, with the understanding and agreement ofthe Defendants
that the settlement or this Resolution shall in no event be construed or deemed to be evidence, or an
admission on the part of the City to the contrary and without conceding any infirmity in its claims;
and
WHEREAS, the Parties consider it desirable that the action be disposed of oil the terms and
conditions set forth in the proposed Stipulated Order of Taking and Final .f.!!ggment attached hereto
as Exhibit "A", in order to avoid further expense and to dispose of protracted litigation; and
WHEREAS, the City Attorney and Special Counsel, Tom Goldstein, recommend that it is
in the best interest of the City to resolve this case; and
WHEREAS, the Parties have agreed to the terms and conditions as set forth in the proposed
Stipulated Order of Taking and Final Judgment attached hereto as Exhibit "A".
NOW, THEREFORE, BE IT DULY RESOLVED BY THE MAYOR AND CITY
COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA:
Section 1:
That the City Commission approves the proposed Stipulated Order of Taking
and Final Judgment attached hereto as Exhibit "A".
Section 2:
That the City Commission hereby authorizes all necessary City personnel and
special counsel to sign the Joint Motion requesting the Court to enter the
Stipulated Order of Taking and Pinal Judgment.
PASSED and ADOPTED this 30th day of
May
,2001.
ATTEST:
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FORM&LANGUAGI
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IN THE CIRCUIT COURT OF THE ELEVENTH
JUDICIAL CIRCUIT OF FLORIDA IN AND FOR
DADE COUNTY
GENERAL JURISDICTION DIVISION
NO. 99-2418 (CA 06)
CITY OF MIAMI BEACH, a Florida
municipal corporation,
Petitioner,
vs.
AMERICAN RIVIERA REAL ESTATE
COMPANY, a FloridaR<f,orporation, and
PALM COURT AT 23 STREET, LTD.,
a Florida limited partnership,
et aI.,
Defendants.
/
STIPULATED ORDER OF TAKING AND FINAL JUDGMENT
THIS CAUSE coming on upon the joint motion for the entry of an Order of Taking
and Final Judgment made by the Petitioner, CITY OF MIAMI BEACH, and the
Defendants, AMERICAN RIVIERA REAL ESTATE COMPANY, a Florida corporation,
and PALM COURT AT 23RD STREET, LTD., a Florida limited partnership, as to
property located at 211 22"d Street, Miami Beach, Florida, legally described as:
Lots 4 and 6, Block 2, MIAMI BEACH IMPROVEMENT
COMPANY SUBDIVISION, as recorded in Plat Book 5,
Page 7, Public Records of Miami-Dade County, Florida,
also known as Lots 4 and 6, Block 2, AMENDED PLAT
OF THE OCEAN FRONT PROPERTY OF THE MIAMI
BEACH IMPROVEMENT COMPANY, according to the
Plat thereof, as recorded in Plat Book 5, Page 7, Public
Records of Miami-Dade County, Florida;
and it appearing that the parties were authorized to enter into such motion, and the
Miami Beach vs. American Riviera Real Estate Co., et al.
Case No. 99-2418 (CA 06)
Page No.2
Court finding that the compensation to be paid by the Petitioner is full, just and
reasonable for all parties concerned, and the Court being otherwise fully advised in the
premises, it is now, therefore
ORDERED and ADJUDGED as follows:
1. That this Court has jurisdiction of the subject matter of and the parties to
this cause.
2. That the pleadings in this cause are sufficient and the Petitioner is
properly exercising its delegated authority.
3. That upon recordation of this Stipulated Order of Taking and Final
Judgment and payment of the amount hereinafter specified into the
Registry of the Court, fee simple title to the Property, as described in the
legal description herein, shall vest in the Petitioner, City of Miami Beach.
4. That the Defendants do have and recover of and from the Petitioner the
sum of One Million Five Hundred Thousand ($1,500,000) Dollars, in full
payment for the property taken, inclusive of severance damages and any
other claims, excluding attorney's fees and reasonable costs.
5. That the Defendant, Palm Court at 23'd Street, Ltd., will receive from the
Petitioner, City of Miami Beach, the following:
a. Eighteen (18) parking decals will be
provided for 28 months, without charge,
(representing a value of $30,000). Nine (9) of the
Miami Beach vs. American Riviera Real Estate Co., et aJ.
Case No. 99-2418 (CA 06)
Page No.3
eighteen (18) parking decals shall be for the
Collins Avenue parking lot located at 22nd Street
and the remaining nine (9) parking decals shall be
for on-Street parking adjacent to the Palm Court
Building. After the 28 months, Palm Court would
be responsible to acquire the decals at whatever
the City's then current monthly rate for its parking
decals. Palm Court would be responsible for the
renewal process and the payment of required fees;
however, the City acknowledges that the decals will
be available for a period of not less than twelve (12)
years.
b. Two (2) ramping spaces consisting of 20
feet each for a total of 40 feet to be located
at the Northeast corner of Liberty Avenue and
23'd Street directly in front of the Palm Court
building will be provided for a period
of 2,700 days, without charge, (representing
a value of $54,000). Said space is presently
available at $10 per day or approximately
$300 per month ($300 x 2 = $600 x 12 = $7200 x
Miami Beach vs. American Riviera Real Estate Co., et at
Case No. 99-2418 (CA 06)
Page No.4
7.5 = $54,000). Palm Court would be responsible to
acquire the ramp space after the 2,700 days at whatever
the then current City rate for ramp space; however,
the City acknowledges that the ramp spaces will be
available for a period of not less than twelve years.
6. That Petitioner shall pay the total sum of Two Hundred Forty-Five
Thousand ($245,000) Dollars as payment for all attorney's fees incurred
by both Defendants in the defense of this cause, and upon the deposit of
funds hereinafter provided for, the Clerk of this Court shall issue a check
for said amount to Brigham Moore, LLP Trust Account
7. That the Petitioner shall pay the total sum of Two Hundred Twenty-Five
($225,000) Dollars as payment for all reasonable costs incurred by both
Defendants in the defense of this cause, and upon the deposit of funds
hereinafter provided for, the Clerk of this Court shall issue a check for said
amount to Brigham Moore, LLP Trust Account
8. That the Petitioner shall deposit the sum of One Million Nine Hundred
Seventy Thousand ($1,970,000) Dollars in the Registry of this Court within
ten (10) days from the date of entry of this Order of Taking and Final
Judgment
9. That the Clerk of this Court shall forthwith pay from the funds deposited
Miami Beach vs. American Riviera Real Estate Co.. et aL
Case No. 99-2418 (CA 06)
Page No, 5
into the Registry of the Court, to the Tax Collector of Miami-Dade County
the 1999 and 2000 delinquent and the 2001 prorated real estate taxes
through the date of this Order on the Property (Folio No. 02-3226-001-
0470), which are due and owing in the sum of $25,960.25. If all or part of
these taxes are paid prior to said disbursement, the Clerk's disbursement
for taxes shall be reduced or eliminated accordingly.
10. That upon the deposit as set forth above in paragraph 8 and without
further notice or Order of this Court, the Petitioner shall be entitled to
immediate possession of the Property.
11. That this Court shall retain jurisdiction in this cause to determine the rights
of the said Defendant owner and lessee, and mortgagees, judgment
creditors, lienholders and other claimants with respect to the amount to be
paid pursuant to Paragraph 4 above and to enforce the terms of this
Stipulated Order of Taking and Final Judgment.
12. Petitioner and Defendants do hereby agree to voluntarily dismiss with
prejudice American Riviera and Palm Court vs. City of Miami Beach, Case
No. 00-01322 (CA 05), and American Riviera vs. City of Miami Beach,
Special Master Appeal No. 1108. Defendants, their successors and
assigns, and Ron Bloomberg, individually and as an officer of American
Riviera Real Estate Company and Palm Court, Inc., general partner of
Palm Court at 23rd Street Ltd., release, acquit and forever discharge the
Miami Beach VS. American Riviera Real Estate Co., et at
Case No. 99-2418 (CA 06)
Page No.6
City of Miami Beach and the City of Miami Beach Redevelopment Agency,
their past, present and future agents, servants, successors, heirs,
administrators and all other persons, firms, corporations, associations or
partnerships of and from any and all claims, actions, causes of actions,
demands, rights, damages, costs, expenses and compensation
whatsoever, which they now have or which they may hereafter accrue on
account of or in any way growing out of the use of the Property as a
regional library, including but not limited to any and all applications for or
granting of governmental approvals and construction of the regional
library, or any and all zoning, comprehensive development plan, parking
or any other issue that would impede, delay or prevent the design,
construction or operation of the regional library.
DONE and ORDERED in Chambers at Miami, Miami-Dade County, Florida, this
_day of May, 2001.
CIRCUIT COURT JUDGE
Copies furnished to:
Thomas Goldstein, Esquire
Mark Tobin, Esquire
Brad Gould, Esquire
Robert Dixon, Esquire
James Kracht, Esquire
CITY OF MIAMI BEACH vs. AMERICAN RIVIERA
Case No. 99-02418 (CA 06)
Stipulated Order of Taking and Final Iudgment
Page 7 of 7
JOINT MOTION
The parties, by and through their undersigned counsel, who are authorized to settle this
cause, and hereby do settle this cause as set forth in the above final judgment, respectfully move
for the entry of the foregoing Stipulated Order of Taking and Final Judgment this ~O ff day
'-'
of May, 2001.
Thomas Goldstein, Esquire
Special Counsel for Petitioner
Florida Bar No. 180724
2810 Stephen P. Clark Center
111 N.W. First Street
Miami, Florida 33128-1993
(305) 375-5151/5303
~
e . Schuster, E
Florida Bar No. 19466
Brigham Moore, LLP
Attorneys for American Riviera
203 S.W. 13 Street
Miami, Florida 33130
(305) 858-2400
~e~~~~ ~
Florida Bar No. 966150
Shutts & Bowen
Attorneys for Palm Court at 23'd Street, Ltd.
First Union Center, Suite 2000
200 East Broward Boulevard
Fort Lauderdale, Florida 33301
(954) 524-5505
~~~~
-
Officer and Representative of American
Riviera Real Estate Company
F TUESOAY, MAY 29, 2001 The Herald 58 J
'CITY OF MIAMI BEACH """
NOTICE OF A SPECIAL f....W
CITY COMMISSION MEETING ~
NonCE I.S HEREBY given that the City Commission of the City of Miami Beach,. :
Florida. WIll hold a Special City Commission Meetin!jl in tt1e Commission Chalnben, .
3rd noor, City Hall, 1700 ConventiOn Center Drrve. Miami Beach, Aorida, on
Wednesday, May 30, 2001. commencing at 10:00 8.m.. to discuss settlement or
City of MiJ'lml BA:lch V!: American Rivi9l'l!l Real EstatA Cnmn:'lnv At al.. eleventh
Judicial Circuit Court Case Number 99-2418 CAD6. This case is an eminent domain -
proceeding concerning property located at 211 22nd Street, Miami Beach, Rorida. '
Inquiries concerning this meeting should be directed to the City Manager's office at
(30S) 673-7010. This meeting may be opened and continued and, under such
circumstances, additlonallegal notice would not be provided. .
ALL PEflSONS are in\lited to attend this meeting or be represented by an agent, or. .
to express their views in writing to the City Commission. cia the City Clerk, 1700. .
Convention Center' Olive. 1st floor, Miami Beach, Florida 33139{ .
Robert e. parcher, City Clerk _ ..
City of Miami Beach
Pursuant to Section 286.0105, Fla. Stat, the City hereby advises the public that if a. .
person decides to appeal any decision made by the City Commission with respect to -
any matter consiclered at its meeting or its hearing, such person must ensure that a '.
verbatim record of the proceedings is made, whiCh record Includes ttle testimony and . .
evidence upon which the appeai is to be based. This notice does not constitute .
consent by the City for the intrOduction or admission of otherwise inadmissible or. ...
irrelevant evidence, nor does it authori%e challenges or appeals not otherwise aIlowed.~
bylaw.
IN ACCORDANCe WITH THE AMERICANS WITH OlSA81UT1ES ACT OF 1990.
PERSONS NEEDING SPECIAL ACCOMMOOATION TO PARTICIPATE IN THIS .
PROCEEOING SHOULD CONTACT THE CIlY CLERK'S OFFICE NO LATER THAN' ,
FOUR DAYS PRIOR TO THE PROCEEDING. TELEPHONE (305) 673.7411 FOR ..
ASSISTANCE; IF HEARING iMPAIRED, TELEPHONE THE FLORIDA RELAY SERVICE. .
NUMBERS, (SOO) 955.8771 (TOO) OR (800) 955.8770 (VOICE), FOR ASSISTANCE. .
~d NO. 0026
CITY OF MIAMI BEACH
CITY HALL 1700 CONVENTION CENTER DRIVE MIAMI BEACH, FLORIDA 33139
hllp:\\ci.miami-beach.ft.us
~.
L.T.C. No.-/.flltL.dm I
LETTER TO COMMISSION
May 25, 2001
TO:
Mayor Neisen O. Kasdin and
Members of the City Commission
FROM:
Jorge M. Gonzalez A~
City Manager U I
SUBJECT:
NOTICE OF A SPECIAL COMMISSION MEETING
A Special City Commission Meeting will be held on Wednesday May 30, 2001, commencing at
10:00 a.m., in the City Commission Chambers. The purpose of this meeting is to discuss settlement
of City of Miami Beach vs. American Riviera Real Estate Company, et al., Eleventh Judicial Circuit
Court Case Number 99-2418 CA06. This case is an eminent domain proceeding concerning property
located at 211 22nd Street, Miami Beach, Florida.
Please let me know if you have any questions.
JMG:ptw
c: Murray H. Dubbin, City Attorney
Christina M. Cuervo, Assistant City Manager
Mayra Diaz Buttacavoli, Assistant City Manager
Bob C. Middaugh, Assistant City Manager
Tim Hemstreet, Special Assistant to the City Manager
Mary Greenwood, Executive Assistant to the City Manager
Ronnie Singer, Executive Assistant to the City Manager
Bob Parcher, City Clerk
Ramiro Inquanzo, Chief of Staff
Department Directors
f:/cmgr/$all/cmgr/ltc-O 1 /reviera.mtg
OFFICE OF THE CITY ATTORNEY
ce~ o!J/fiomi 11-
F
L
o
R
o
A
MURRAY H. DUBBIN
City Attorney
Telephone:
Telecopy:
(305) 673-7470
(305) 673-7002
COMMISSION MEMORANDUM NO. 839-01
TO:
Mayor Neisen O. Kasdin and
Members of the City Commission
DATE: May 30, 2001
FROM: Murray H. Dubbin ofi/-..-
City Attorney
SUBJECT: Discuss Settlement of City of Miami Beach vs. American Riviera Real Estate
Company. Eleventh Judicial Circuit Court Case No. 99-2418 CA06, General
Jurisdiction.
Please add the above captioned matter to the Commission Agenda.
1700 Convention Center Drive -- Fourth Floor -- Miami Beac
Agenda Item --.m 0 g
Date 5-30- 01
200/- 2.YVOo
CITY OF MIAMI BEACH
~
Interoffice Memorandum
To:
Robert Parcher
City Clerk
Date: June 5, 2001
From:
Robert Dixon
Deputy City Attorney
Subject: City of Miami Beach v. American Riviera Real Estate Company et al.
Case No. 99-2418 CA 06
Accompanying please find a certified copy of the Stipulated Order of Taking and Final Judgment
entered in the above-referenced case on May 30, 2001.
RD/ag
~.
IN THE CIRCUIT COURT OF THE ELEVENTH
JUDICIAL CIRCUIT OF FLORIDA IN AND FOR
DADE COUNTY
GENERAL JURISDICTION DIVISION
NO. 99-2418 (CA 06)
,
CITY OF MIAMI BEACH, a Florida
municipal corporation,
Petitioner,
.
~.
vs.
AMERICAN RIVIERA REAL ESTATE
COMPANY, a Florida lfPrporation, and
PALM COURT AT 23R STREET, LTD.,
a Florida limited partnership,
et aI.,
Defendants.
/
STIPULATED ORDER OF TAKING AND FINAL JUDGMENT
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THIS CAUSE coming on upon the joint motion for the entry of an Order of Taking
and Final,Judgment made by the Petitioner, CITY OF MIAMI BEACH, and the
Defendants, AMERICAN RIVIERA REAL ESTATE COMPANY, a Florida corporation,
\' .
and PALM COURT AT 23RD STREET, LTD., a Florida limited partnership, as to
property located at 211 22nd Street, Miami Beach, Florida, legally described as:
Lots 4 and 6, Block 2, MIAMI BEACH IMPROVEMENT
COMPAN'f'SUBDIVISION, as recorded in Plat Book 5,
Page 7, Public Records of Miami-Dade County, Florida,
also known as Lots 4 and 6, Block 2, AMENDED PLAT
OF THE OCEAN FRONT PROPERTY OF THE MIAMI
BEACH IMPROVEMENT COMPANY, according to the
Plat thereof, as recorded in Plat Book 5, Page 7, Public
Records of Miami-Dade County, Florida;
and it appearing that the parties were authorized to enter into such motion, and the
A TRUE COpy
CERTIFICATION ON :AST f>AGI
HARm RUVIN, Cl1nKi
Miami Beach vs. American Riviera Real Estate Co., et at.
Case No. 99-2418 (CA 06)
Page No.2
,
Court finding that the compensation to be paid by the Petitioner is full, just and
reasonable for all parties concerned, and the Court beQng otherwise fully advised in the
premises, it is now, therefore
ORDERED and ADJUDGED as follows:
1. That this Court has jurisdiction of the subject matter of and the parties to
this cause.
2. That the pleadings in this cause are sufficient and the Petitioner is
properly exercising its delegated authority.
3. That upon recordation of this Stipulated Order of Taking and Final
Judgment and payment of the amount hereinafter specified into the
Registry of the Court, fee simple title to the Property, as described in the
legal description herein, shall vest in the Petitioner, City of Miami Beach.
4. That the Defendants do have and recover of and from the Petitioner the
\i
sum of One Million Five Hundred Thousand ($1,500,000) Dollars, in full
payment for the property taken, inclusive of severance damages and any
other claims, excluding attorney's fees and reasonable costs.
.
5. That the Defendant, Palm Court at 23rd Street, Ltd., will receive from the
Petitioner, City of Miami Beach, the following:
a. Eighteen (18) parking decals will be
provided for 28 months, without charge,
(representing a value of $30,000). Nine (9) ofthe
A TH.UE COP.,. .
CERTIFICATION ON LAST PA~
HARVlY RUVIN. CLERKt.,.
,
\'
Miami Beach vs. American Riviera Real Estate Co., et al.
Case No. 99-2418 (CA 06)
Page No.3
eighteen (18) parking decals shall be for the
Collins Avenue parking lot located at 22nd Street
and the remaining nine (9) parking decals shall be
for on-Street parking adjacent to the Palm Court
Building. After the 28 months, Palm Court would
be responsible to acquire the decals at whatever
the City's then current monthly rate for its parking
decals. Palm Court would be responsible for the
renewal process and the payment of required fees;
however, the City acknowledges that the decals will
be available for a period of not less than twelve (12)
years.
b.
Two (2) ramping spaces consisting of 20
feet each for a total of 40 feet to be located
at the Northeast corner of Liberty Avenue and
23M Street directly in front of the Palm Court
building will be provided for a period
of 2,700 days, without charge, (representing
a value of $54.000). Said space is presently
available at $10 per day or approximately
$300 per month ($300 x 2 = $600 x 12 = $7200 x
A THUE COPY
CERTIFICATION ON LAST P^~
HARVEY RUVIN, CLERK';
':'
Miami Beach vs. American Riviera Real Estate Co., et al.
Case No. 99-2418 (CA 06)
Page No.4
,
7.5 = $54,000). Palm Court would be responsible to
acquire the ramp space atier the 2,700 days at whatever
the then current City rate for ramp space; however,
the City acknowledges that the ramp spaces will be
available for a period of not less than twelve years.
6. That Petitioner shall pay the total sum of Two Hundred Forty-Five
Thousand ($245,000) Dollars as payment for all attorney's fees incurred
by both Defendants in the defense of this cause, and upon the deposit of
funds hereinafter provided for, the Clerk of this Court shall issue a check
for said amount to Brigham Moore, LLP Trust Account.
7.
That the Petitioner shall pay the total sum of Two Hundred Twenty-Five
\'
($225,000) Dollars as payment for all reasonable costs incurred by both
Defendants in the defense of this cause, and upon the deposit of funds
hereinafter provided for, the Clerk of this Court shall issue a check for said
amount to Brigham Moore, LLP Trust Account.
.'
8. That the Petitioner shall deposit the sum of One Million Nine Hundred
Seventy Thousand ($1,970,000) Dollars in the Registry of this Court within
ten (10) days from the date of entry of this Order of Taking and Final
Judgment.
9. That the Clerk of this Court shall forthwith pay from the funds deposited
11 TRUE COpy
CERTIFICATION ON lAST-~
HARVEY fiUVIN. CtElIll
..
Miami Beach vs. American Riviera Real Estate Co., et al.
Case No. 99-2418 (CA 06)
Page No.5
,
into the Registry of the Court, to the Tax Collector of Miami-Dade County
the 1999 and 2000 delinquent and the 2001 prorated real estate taxes
through the date of this Order on the Property (Folio No. 02-3226-001-
0470), which are due and owing in the sum of $25,960.25. If all or part of
these taxes are paid prior to said disbursement, the Clerk's disbursement
for taxes shall be reduced or eliminated accordingly.
10. That upon the deposit as set forth above in paragraph 8 and without
further notice or Order of this Court, the Petitioner shall be entitled to
immediate possession of the Property.
11. That this Court shall retain jurisdiction in this cause to determine the rights
of the said Defendant owner and lessee, and mortgagees, judgment
creditors, lienholders and other claimants with respect to the amount to be
\'
paid pursuant to Paragraph 4 above and to enforce the terms of this
Stipulated Order of Taking and Final Judgment.
12. Petitioner and Defendants do hereby agree to voluntarily dismiss with
prejudice American Riviera and Palm Court vs. City of Miami Beach, Case
.'
No. 00-01322 (CA 05), and American Riviera vs. City of Miami Beach,
Special Master Appeal No. 1108. Defendants, their successors and
assigns, and Ron Bloomberg, individually and as an officer of American
Riviera Real Estate Company and Palm Court, Inc., general partner of
Palm Court at 23rd Street Ltd., release, acquit and forever discharge the
'A TRUE COPY- ,.
CERTifiCATION ON lAST PAt;."
HARV\:Y RUVIN. ClEtlK
Miami Beach vs. American Riviera Real Estate Co., et al.
Case No. 99-2418 (CA 06)
Page No.6
,
City of Miami Beach and the City of Miami Beach Redevelopment Agency,
,
their past, present and future agents, seivants, successors, heirs,
administrators and all other persons, firms, corporations, associations or
partnerships of and from any and all claims, actions, causes of actions,
demands, rights, damages, costs, expenses and compensation
whatsoever, which they now have or which they may hereafter accrue on
account of or in any way growing out of the use of the Property as a
regional library, including but not limited to any and all applications for or
granting of governmental approvals and construction of the regional
library, or any and all zoning, comprehensive development plan, parking
or any other issue that would impede, delay or prevent the design,
construction or operation of the regional library.
DONE and ORDERED in Chambers at Miami, Miami-Dade County, Florida, this
~day of May, 2001.
."
~1i,~
CUlT URT JUDGE
Nf( N. bEAN
ClftCUtT JUDGE
Copies furnished to:
Thomas Goldstein, Esquire
Mark Tobin, Esquire
Brad Gould, Esquire
Robert Dixon, Esquire
James Kracht, Esquire STATE OF FLORIDA, COUNTY OF DADE
I HEREBY CERTIFY that the for.eioJ~ Is,f ....e""Mrect copy of tile
orl,inJlonfi1einthlsoff1ce.~D
HARVEY RUVIN Clerk, of Circu' a C nty Courts
<Deputy Clerk
, .
CITY OF MIAMI BEACH vs. AMERICAN RIVIERA
Case No. 99-02418 (CA 06)
Stipulated Order of Taking and Final Judgment
Page 7 of 7
JOINT MOTION
,
The parties, by and through their undersigned counsel, who are authorized to settle this
cause, and hereby do settle this cause as set forth in the above final judgment, respectfully move
for the entry of the foregoing Stipulated Order of Taking and Final Judgment this~ ~~ay
of May, 2001.
~
=M ""ldm"" ",q"""
Special Counsel for Petitioner
Florida Bar No. 180724
2810 Stephen P. Clark Center
11 I N.W. First Street
Miami, Florida 33128-1993
(305) 375-5151/5303
.'
~G-2'
FloridalBar No. 966150
Shutts & Bowen
Attorneys for Palm Court at 23rd Street, Ltd.
First Union Center, Suite 2000
200 East Broward Boulevard
Fort Lauderdale, Florida 33301
(954) 524-5505 .
dre H. Sc stet, s
Florida Bar No. 194660
Brigham Moore, LLP
Attorneys for American Riviera
203 SW. 13 Street
Miami, Florida 33130
(305) 858-2400
'--/
m erg, Individually and as
Officer and Representative of American
Riviera Real Estate Company