HomeMy WebLinkAboutR-2002-034 Approving the Settlement of the lawsuit existing between the City of Dania Beach, Florida, ET Al, and the Florida Power and Light Company RESOLUTION NO. 2002-034
A RESOLUTION OF THE CITY OF DANIA BEACH, FLORIDA
APPROVING THE SETTLEMENT OF THE LAWSUIT
EXISTING BETWEEN THE CITY OF DANIA BEACH,
FLORIDA, ET AL, AND THE FLORIDA POWER AND LIGHT
COMPANY; AUTHORIZING THE PROPER CITY OFFICIALS
TO EXECUTE DOCUMENTS IN CONNECTION WITH SUCH
SETTLEMENT, INCLUDING NOTICE OF A DISMISSAL WITH
PREJUDICE, A RELEASE AND WAIVER OF ALL CLAIMS
AND A PROMISSORY NOTE; FURTHER, PROVIDING FOR
AN EFFECTIVE DATE.
WHEREAS, the City of Dania Beach and several other municipalities located in
Broward County, Florida filed a lawsuit in the Seventeenth Judicial Circuit Court for
Broward County, Florida, known as City of Dania Beach, et al. v Florida Power and
Light Company, Case No. 01-008883; and
WHEREAS, the City of Dania Beach and FP&L are willing to settle their
differences as identified in the lawsuit, which settlement includes entry by the parties
into a new franchise agreement (embodied in a City ordinance), repayment of
$443,156.00 for funds overpaid by FP&L to the City and execution of associated
settlement documents pertaining to dismissal of the litigation, including a Promissory
Note for the subject repayment;
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COMMISSION OF THE
CITY OF DANIA BEACH, FLORIDA:
Section 1. That the proper City officials are authorized to execute settlement
documents in connection with the above-referenced litigation, including a Promissory
Note (a copy of the form of which is attached, marked as Exhibit "A" and incorporated
by this reference) for the repayment of the funds identified above, subject to the
approval as to form of such documents by the City Attorney.
1 RESOLUTION NO. 2002-034
Section 2. That this resolution shall be in force and take effect immediately upon
its passage and adoption.
PASSED and ADOPTED this 26th day of MARCH, 2002.
S
V D:
MA R-COMMISSIONER
A TEST: ROLL CALL:
Dm� COMMISSIONER BERTINO-YES
CHARLENE JriLJNSON COMMISSIONER MCELYEA-ABSENT
CITY CLERK COMMISSIONER MIKES-YES
VICE MAYOR FLURY-YES
MAYOR CHUNN-YES
APPROVED AS TO FORM AND CORRECTNESS:
tHdMAS J. N RO
CITY ATTORNEY
2 RESOLUTION NO. 2002-034
PROMISSORY NOTE
$443,156.00 Dated: Marche', 2002
For value received, CITY OF DANIA BEACH, FLORIDA, a municipality duly chartered
and incorporated under the laws of the State of Florida (the "Borrower"), promises to pay to the
order of FLORIDA POWER & LIGHT COMPANY, a corporation organized and existing under
` the laws of the State of Florida (the "Lender"), on the Maturity Date (as hereinafter defined), at
the office of the Lender at 9250 West Flagler Street, Miami, Florida 33174, Attention: Bruce R.
Wuenker (or at such other office or location as the Lender shall specify to the Borrower in
writing from time to time), the principal sum of FOUR HUNDRED FORTY THREE THOUSAND
ONE HUNDRED FIFTY SIX AND NO/100 DOLLARS ($443,156.00) (the "Loan"), in lawful
money of the United States of America in immediately available funds.
The principal amount of this Note shall be payable in full on the date (the "Maturity
Date") which is the earlier of (a) one (1) Business Day following the date upon which the Lender
makes the first franchise payment to the Borrower pursuant to the provisions of a new Franchise
Agreement to be entered into between Borrower and Lender effective no later than March 29,
2002, in the form of a Franchise Ordinance to be adopted by the Borrower prior to March 29,
2002, to the extent that the same are accepted by the Lender pursuant to a written Acceptance
of such Franchise Ordinance filed by the Lender on or before March 29, 2002 (the "New
Franchise Agreement'), and (b) July 1, 2002.
The Borrower shall have the right, at any time or from time to time, to prepay the loan
evidenced by this Note in whole or in part, without premium or penalty.
• All payments by the Borrower under this Note shall be made without setoff or
counterclaim and in such amounts as may be necessary in order that all payments, after
deduction or withholding for or on account of any present or future taxes, levies, imposts, duties
or other charges of whatsoever nature imposed by any government or any political subdivision
or taxing authority thereof, shall not be less than the amounts otherwise specified to be paid
under this Note. The Borrower shall further pay any present or future stamp or documentary
taxes or any other excise or property taxes, charges or similar levies which arise from any
payment made hereunder or.from the execution, delivery or registration of, or otherwise with
respect to, this Note or any of the other documents evidencing and/or securing the loan
evidenced by this Note. Without prejudice to the survival of any other agreement of the
Borrower hereunder, the obligations of the Borrower under this paragraph shall survive the
termination of this Note and the repayment of the loan evidenced hereby.
For the purposes hereof, the following term shall have the following meanings:
"Business Day" shall mean a day on which commercial banks are
open for business in Miami, Florida.
Upon the happening of any of the following events, each of which shall constitute a
default hereunder (herein referred to as an "Event of Default'), all liabilities of the Borrower to
the Lender, whether or not evidenced by this Note, shall thereupon or thereafter, at the option of
the Lender, without notice or demand, become due and payable: (a) failure of the Borrower to
perform any agreement hereunder or under any other instrument or agreement evidencing,
• MIA2001/88921-1
1
securing and/or guaranteeing the obligations and indebtedness of the Borrower to the Lender
evidenced by this Note, including, without limitation, the New Franchise Agreement, or (b)
failure of the Borrower to pay in full, when due, any liability whatsoever or any principal
installment of this Note.
The Borrower agrees to pay all costs incurred by any holder hereof, including
reasonable attorneys' fees (including those for appellate proceedings), incurred in connection
with any Event of Default or in connection with the collection or attempted collection or
enforcement hereof, whether or not legal proceedings may have been instituted.
All parties to this Note, including the Borrower and any sureties, endorsers or
guarantors, hereby waive presentment for payment, demand, protest, notice of dishonor, notice
of acceleration of maturity, and all defenses on the ground of extension of time for payment
hereof, and agree to continue and remain bound for the payment of principal, interest and all
other sums payable hereunder, notwithstanding any change or changes by way of release,
surrender, exchange or substitution of any security for this Note or by way of any extension or
extensions of time for payment of principal or interest; and all such parties waive all and every
kind of notice of such change or changes and agree that the same may be made without notice
to or consent of any of them.
Rights and remedies of the holder as provided herein shall be cumulative and concurrent
and may be pursued singularly, successively or together at the sole discretion of the holder, and
may be exercised as often as occasion therefor shall occur, and the failure to exercise any such
right or remedy shall in no event be construed as a waiver or release of the same.
• The Lender is hereby authorized at any time and from time to time, without notice to the
Borrower (any such notice being expressly waived by the Borrower), to set off and apply any
and all payments which may at any time be due and owing by the Lender to the Borrower
pursuant to the New Franchise Agreement against any and all of the obligations of the Borrower
now or hereafter existing under this Note or any other instrument executed in connection with
this Note, regardless whether the Lender shall have made demand under this Note or any such
other instrument. Nothing herein, however, shall in any manner be deemed or construed to
affect, impair or diminish the obligation of the Borrower to pay this Note in full as and when the
same shall become due and payable, which obligation is absolute and unconditional, whether or
not any payments are made or to be made by the Lender pursuant to the New Franchise
Agreement or are sufficient therefor and whether or not the New Franchise Agreement ever
becomes effective. The Lender agrees promptly to notify the Borrower after any such setoff and
application, provided that the failure to give such notice shall not affect the validity of such setoff
and application. The rights of the Lender under this paragraph are in addition to any and all
other rights (including, without limitation, other rights of setoff) which the Lender may otherwise
have.
No failure on the part of Lender to exercise any right or remedy hereunder, whether
before or after the happening of a default shall constitute a waiver thereof, and no waiver of any
past default shall constitute a waiver of any future default or of any other default. No failure to
accelerate the debt evidenced hereby by reason of default hereunder, or acceptance of a past
due installment, or indulgence granted from time to time shall be construed to be a waiver of the
right to insist upon prompt payment thereafter, or shall be deemed to be a novation of this Note
or as a reinstatement of the debt evidenced hereby or as a waiver of such right or acceleration
• MIA2001/88921-1
2
or any other right, or be construed so as to preclude the exercise of any right that Lender may
have, whether by the laws of the State of Florida, by agreement, or otherwise; and Borrower
and each endorser or guarantor hereby expressly waives the benefit of any statute or rule of law
or equity that would produce a result contrary to or in conflict with the foregoing. This Note may
not be changed orally, but only by an agreement in writing signed by the party against whom
such agreement is sought to be enforced.
THE BORROWER HEREBY, AND THE LENDER BY ITS ACCEPTANCE OF THIS
NOTE, KNOWINGLY, VOLUNTARILY AND INTENTIONALLY WAIVE THE RIGHT EITHER
MAY HAVE TO A TRIAL BY JURY IN RESPECT OF ANY LITIGATION BASED HEREON, OR
ARISING OUT OF, UNDER OR IN CONNECTION WITH THIS NOTE AND ANY AGREEMENT
CONTEMPLATED TO BE EXECUTED IN CONJUNCTION HEREWITH, OR ANY COURSE OF
CONDUCT, COURSE OF DEALING, STATEMENTS (WHETHER VERBAL OR WRITTEN) OR
ACTIONS OF EITHER PARTY. THIS PROVISION IS A MATERIAL INDUCEMENT FOR THE
LENDER MAKING THE LOAN EVIDENCED BY THIS NOTE.
This Note shall be governed by and construed in accordance with the laws of the State
of Florida, without regard to the principles of conflicts of laws thereunder.
IN WITNESS WHEREOF, the Borrower has caused this Note to be duly executed and
delivered as of the date first above written.
CITY OF DANIA BEACH, FLORIDA
i
By: 4Robert
Its: Mayor H. Chug Jr.
BY:
_ Ian Pa i . W nager
Attest:
By: �
Charlene Johnso ' ity Clerk
Approved as to form and correctness:
By:
Th niia's Mns , 'City Attorney
• MIA2001/88921-1
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ACKNOWLEDGEMENT CERTIFICATE
STATE OF FLORIDA)
COUNTY OF BROWARD)
On following persons, Ivan Pato, City Manager and Robert H. Chunn, Jr., Mayor
of the City of Dania Beach, Florida, did appear before me this 271h day of March, 2002.
Linda G. Fry ,
sF Cmmbsbn#CC 767980 -
&*a A1l6..16,2002 i atuxe of Nq,ary
Of Fl A 60°dMG M,INC. —n
Personally know ( 11 or produced identification
Type of Identification produced
• MIA2001/88921-1
4
ORDINANCE NO. 173
AN ORDINANCE OF THE CITY OF DANIA, FLORIDA,
GRANTING TO FLORIDA POWER & LIGHT COMPANY,
ITS SUCCESSORS AND ASSIGNS AN ELECTRIC
FRANCHISE FOR A PERIOD OF THIRTY (30) YEARS,
IMPOSING PROVISIONS AND CONDITIONS RELATING
THERETO, AND PROVIDING FOR MONTHLY PAYMENTS
TO THE CITY, AND PROVIDING THAT ALL ORDINANCES
OR PARTS OF ORDINANCES AND ALL RESOLUTIONS OR
PARTS OF RESOLUTIONS IN CONFLICT HEREWITH BE
REPEALED TO THE EXTENT OF SUCH CONFLICT; AND
PROVIDING FOR AN EFFECTIVE DATE.
BE IT ORDAINED BY THE CITY COMMISSION OF THE CITY OF DANIA,
FLORIDA:
Section 1. That there is hereby granted to Florida Power & Light
Company (herein called the "Grantee") , its successors and assigns,
"leg or franchise to construct, maintain
the non-exclusive right, privi
and operate in, under, upon, over and across the present and future
streets, alleys, bridges, easements and other public places in the
City of Dania, Florida (herein.called the "Grantor") and its successors,
in accordance with established practice with respect to electrical
construction and maintenance, for the period of thirty (30) years from
he date of acceptance hereof, electric light and power facilities
0
(including copduits, poles, wires and transmission lines, and, for its
own use, telephone and telegraph lines) for the purpose of supplying
electricity to Grantor, and its successors, and inhabitants thereof,
and persons and corporations beyond the limits thereof.
Section 2. As a condition precedent to the taking effect of this
grant, Grantee shall have filed its acceptance hereof with the Grantor's
Clerk within thirty (30) days hereof.
Section 3. That the facilities shall be so located or relocated
and so erected as to interfere as little as possible with traffic over
said streets, alleys, bridges and public places, and with reasonable
egress from and ingress to abutting property. The location or relocation
of all facilities shall be made under the supervision and with the
approval of such representatives as the governing body of Grantor may
designate for the purpose, but not so as unreasonably to interfere with
the proper operation of Grantee's facilities and service. That when
any portion of a street is excavated by Grantee in the location or
r-location of any of its facilities, the portion bf the street so
avated shall, within a reasonable time and as early as practicable
aor such excavation, be replaced by the Grantee at its expense and
in as good condition as it was at the time of such excavation.
Section 4. That Grantor shall in no way be liable or respon-
.6ible for any accident or damage that may occur in the construction,
operation or maintenance by Grantee of its facilities hereunder, and
the. acceptance of this ordinance shall be deemed an agreement on the
part of the Grantee, to indemnify Grantor and hold it harmless against
any and all liability; loss, cost, damage or expense, which may accrue
to Grantor by reason of the neglect, default or misconduct of Grantee
in the construction, operation br maintenance of its facilities here-
under.
Section 5. That all rates and rules and regulations established
by Grantee from time to time shall at all times. be reasonable and
Grantee's rates for electricity shall at all times be subject to such
regulation as may be provided by law.
• Section 6_ That no later than sixty (60) days after the first
anniversary date of this grant and no later than sixty (60) days after
each succeeding anniversary date of this grant, the Grantee, its
successors and assigns, shall have paid to the Grantor and its
successors an amount which added to the amount of all taxes as assessed,
levied, or imposed (without regard to any discount for early payment
or any interest or penalty for late payment) , licenses, and other
impositions levied or imposed by the Grantor upon the Grantee's elec-
tric property, business or operations, and those of Grantee's electric
subsidiaries for the preceding tax year, will equal six per cent (6%)
of Grantee' s revenues from the sale of electrical energy to residential,
commercial and industrial customers within the corporate limits of
the Grantor for twelve (12) fiscal months preceding the applicable
anniversary date.
-2-
Section 7. Payment of the amount to be paid to Grantor by
*antee under the terms of Section 6 hereof shall be made in ad-
ice by estimated monthly installments commencing ninety (90) days
Otterthe effective date of this grant. Each estimated monthly
installment shall be calculated on the basis of ninety per cent (90%)
of Grantee's revenues (as defined in Section 6) for the monthly
billing period ending sixty (60) days prior to each scheduled monthly
payment. The final installment for each fiscal year of this grant
shall be adjusted to reflect any underpayment or overpayment resulting
from estimated monthly installments made for said fiscal year. .
Section 8— As a further consideration of this franchise, said
Grantor agrees not to engage in the business of distributing and
selling electricity during the life of this franchise or any extension
thereof in competition with the Grantee, its successors and assigns.
Section 9. That failure on the part of Grantee to comply in any
substantial respect with any of the provisions of this ordinance,
shall be grounds for a forfeiture of this grant, but no such forfeiture
;hall take effect if the reasonableness or propriety thereof is
tested by Grantee until a court of competent jurisdiction (with
right of appeal in either party) shall have found that Grantee has
failed to comply in a substantial respect with any of the provisions
of this franchise, and the Grantee shall have six (6) months after
the final determination of the question, to make good the default
before a forfeiture shall result with the right in Grantor at its
discretion to grant such additional time to Grantee for compliance as
necessities in the case require.
Section 10. This franchise as provided by this ordinance shall
take effect on the date upon which Grantee files its acceptance with
Grantor.
Section 11. Should any section or provision of this ordinance or
any portion hereof be declared by a court of competent jurisdiction to
be invalid, such decision shall not affect the validity of the re-
mainder hereof as a whole or any part hereof, other than the part
declared to be invalid.
-3-
Section 12. That if for any reason this ordinance shall be
0 found to be invalid, then, in such event, it is the declared intent
of the City Commission that this ordinance shall be inoperative and
void as of the time when it was first introduced and that Ordinance
No. 308, effective on October 23, 1953, shall be and remain in full
force and effect as though this ordinance had not been enacted.
Section 13. That all ordinances or parts of ordinances and
all resolutions or parts of resolutions in conflict herewith be and
the same are hereby repealed to the extent of such conflict.
Section 14: That this ordinance shall be in force and take effect
immediately upon its passage and adoption.
PASSED and ADOPTED on First Reading on the 23rd day of May
1978.
PASSED and ADOPTED on Second and Final Reading on the 13th
day of June 1978.
o /
® - CO R .
ATTEST:
CITY CLERK'- AUDITOR
APPROVED FOR FORM AND CORRECTIVENESS
BY
FRANK C. ADLER, City Attorney
City of Dania, Florida
-4-
ORDINANCE No 308
AN ORDINANCE GRANTING TO FLORIDA POWER & LIGHT COMPANY, ITS SUCCESSORS AND ASSIGNS. AN ELEC,
TKIC FRANCHISE, AND 1\1POSENG PROVISIONS AND CONDITIONS RELATING THERETO:
sE IT__0-�a�-�BY THE CITY CONuLSSION OF TIC C�7 OF DANIA� �— --_--_••__.--rLORIDA:—
si-tction I. Tltat there is hereby granted to Florida Power&Lipht Company (herein called the "Grantee-). iti successors end as-
he non<xclusive ri;;:u,Privilege or franchise to construct,maintain and operate in,under,upon,over and across the present and fu-
ture streets,alleys,bridges,casements and other public places of o rid a, (herein called the
"Grantor-) and its successors, in accordance with established practice with respect to electrical construction and maintenance, for the
period of thirty years from the date of acceptance hereof,electric light and power facilities (including conduits, poles, wires and trans-
mission lines, end, for its own nse, telephone and telegraph lines) for the purpose of supplying electricity to Grantor,and its successors,
the inhabitants thereof, and persons and corporations beyond the limits thereof.
Section II. That Grantor hereby reserves the right at and after the expiration of ibis grant to purchase the property of Grantee
used under this grant,as provided by the Laws of Florida, in effect at the tirue of Grantee's acceptance hereof, including Section 16722
of the Florida Statutes of IM,and as a condition precedent to the taking effect of this grant.Grantee shall give and grant to the Grantor
the right to purchase so reserved. Grantee shall be deemed to have given and granted such right of purchase by its acceptance hereof,
which shall be filed with the Grantor's clerk within thirty (30) days after this ordinance takes effect.
Section M. That the facilities shall be so located or relocated and so erected as to interfere as little as possible with traffic over
said streets,alleys,bridges and public places,and with reasonable egress from and ingress to abutting property. The location or relocation
of all facilities shall be made under the supervision and with the approval of such representatives as the governing body of Grantor may
designate for the purpose,but not so as unreasonably to interfere with the proper operation of Grantee's facilities and service.That when
any portion of a street is excavated by Grantee in the location or relocation of any of iu facilities.the portion of the street so excavated
shall,within a reasonable time and as early as practicable after such excavation,be replaced by the Grantee at iu expense and in as good
condition as it was at the time of such excavation,
Section IV. That Grantor shall in no way be liable or responsible for any accident or damage that may occur in the construction,
operation or maintenance by Grantee of its facilities hereunder, and the acceptance of this ordinance shall be deemed an agreement on the
part of Grantee,to indemnify Grantor and hold it harmless against any and all liability, loss, cost, damage or experue, .which may accrue
to Grantor by reason of the neglect,default.or misconduct of Grantee in the construction, operation or maintenance of its facilities
hereunder.
Section V. That all rates and rules and regulations established by Grantee from time to time shall at all times be reasonable and
Grantee's rates for electricity shall at ail times he subject to such regulation as may be provided by law.
Section VI. That within thirty days after the first anniversary date of this grant and within thirty days after each succeeding no-
iversary date of this grant,the Grantee,its successors and assigns,shall pay to the Grantor and its successors an a rgir addod to
oomoun, of all taxes, licensee, an nth. iosiiione levied or imposed by the Grantor upon the Grau '�prop_rty, business, or
ns, and those of Grsntee'4ubn canes for the preceding tax year, will equal 6% of Grantees revenues from the sale of
eal energy to residential and commercial customers within the corporate limiu of the Grantor for the twelve fiscal months preced•
ing the applicable anniversary date.
Section VII_ As a further consideration of this francbise, said Grantor agrees not to engage in the business of distributing and
selling electricity during the life of this franchise or any extension thereof in competition with the Grantee,its successors and assigns
Section VIII. That failure on the part of Grantee to comply in any substantial respect with any of the provisions of this ordinance,
shu11 be grounds for a forfeiture of ibis grant,but no such forfeiture shall take effect if the reasonableness or propriety thereof is pro-
tested by Grantee until a court of competent jurisdiction (with right of appeal in either party) shall have found that Grantee has failed
to comply in a substantial respect with any of the provisions of this franchise, and the Grantee shall have six (6) months after the final
determination of the question,to make good the default before a forfeiture shall result with the ri:lat in Grantor at its discretion to grant
rucb additional time to Grantee for compliance as necessities in the case require.
Section IX. This ordinance shall take effect in accordance with the provisions of the Charter of
the City of Dania, Florida (Chapter 25768, Laws of Florida, Acts of 1949, as amended).
Section X. That all ordinances end parts of ordinances in conflict herewith be and the same are hereby repealed
21 September 53
PASSED AND ADOPTED this........... -....._duv oL_.._.._._ ..._.._.---.__..—..-------------..--- T9.-•---
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Title_Corc:dssioners
ACCEPTANCE OF ELECTRIC FRANCHISE
ORDINANCE NO. 173
BY FLORIDA POWER & LIGHT COMPANY
City of Dania June 28, 1978
Dania, Florida
Florida Power & Light Company does hereby accept the
electric franchise in the City of Dania, Florida, granted by
Ordinance No. 173, being:
"AN ORDINANCE OF THE CITY OF DANIA, FLORIDA,
GRANTING TO FLORIDA POWER & LIGHT COMPANY, ITS
SUCCESSORS AND .ASSIGNS AN ELECTRIC FRANCHISE
FOR A PERIOD OF THIRTY (30) YEARS, IMPOSING
PROVISIONS AND CONDITIONS RELATING THERETO, AND
PROVIDING FOR MONTHLY PAYMENTS TO THE CITY, AND
PROVIDING THAT ALL ORDINANCES OR PARTS OF
ORDINANCES AND ALL RESOLUTIONS OR PARTS OF
RESOLUTIONS IN CONFLICT HEREWITH BE REPEALED
TO THE EXTENT OF SUCH CONFLICT; AND PROVIDING
FOR AN EFFECTIVE DATE."
which was passed and adopted on June 13, 1978.
This instrument is filed with the City Clerk of the
City of Dania, Florida, in accordance with the provisions of
Section 2 of said ordinance.
FLORIDA POWER & LIGHT COMPANY
1 /
ny� �
Vir
ce President
ATTEST:
Secre ry
I HEREBY ACKNOWLEDGE receipt of the above Acceptance of
Electric Franchise Ordinance No. 173 by Florida Power & Light
Company, and certify that I have filed the same for record in the
permanent files and records of the City of Dania, Florida on this
28th day of June, 1978.
City Clerk of the City of
Dania, Florida
•
STATE OF FLORIDA )
COUNTY OF BROWARD )
CITY OF DANIA )
I, Mary Thornhill, duly appointed and acting
City Clerk of the City of Dania, DO HEREBY CERTIFY that
the foregoing is a true and correct copy of Ordinance
No. 308, of the ordinances of the City of Dania, Florida,
passed and adopted by the City Commission of the City of
Dania, Florida, on September 21, 1953•
Dated this 24th day of September, 1953•
r
rj City Clerk
City of Dania, Florida
SEAL.
VISIONS AND CONDITIONS RELATING THERETO,"
and certify files
that I have and recordsfofethehCitymoffor record in Dania, Floridal,ethis
manent fileles
_day of October, 1953•
�ty Clerk
1 �
ACCEPTANCE OF CITY OF DANIA O$
ELECTRIC FRANCHISE ORDINANCE N0.
October 21, 1953
i
city of Dania
Dania, Florida
The Florida Power & Light Company does hereby
accept Ordinance No. 30$, it being:
"AN ORDINANA�G TSING TO SUCCESSORSIANDPASSIGNS,
LIGHT COMP AIM IDpOSING PRO-
AN TAND ING THERETO.
CONDITIONS RELAT
VISIONS 't
th the City Clerk of
This instrument is filed wi
the City of Dania, Florida, in accordance with the provi-
sions of Section II of said Ordinance.
FLORIDA. POWER & LIGHT COtIPANY
By Vice President
R. C. Fullerton,
ATTEST: v�
MI. B. PdcDona d, Secretary
I hereby acknowledge receipt of the above Acceptance
by the Florida Power & Light Company of Ordinance No. 30$, it
being:
"AN LIGHTDINANCE COMPANY, ITSISUCCESSORS FLORIDA
AND1ASSIGNS,
LIGHT AND 71�1POSING PRO-
AN ELECTRIC FRANCHISE,
VISIONS AND CONDITIONS RELATING THERETO,"
of Dania, Florida, this
have cordsofa hheCit}�e for record in the per-
and certify thand at I mandayent filesof filed
October, 1953-
P /
,r l��Clerk
City
'RDIN.ANCE NO. 77- .,50 EXPIRES : 6-27-2007-
CITY OF POMPANO BEAC:
Broward County, Florida
AN ORDINANCE GRANTING TO FLORIDA POIrr-P. & LIGri1'
CafP?NY, ITS SUCCESSORS AND ASSIQNS, AN ELECTRIC
FRANCHISE, IMPOSING PROVISIONS ,AN CONDITIONS
RELATING THERETO; PROVIDING FOR N1ON`7riLY PAYbftM'S
TO T7-iE CITY; PROVIDING A SAVINGS CLAUSE; PROVIDING
A REPEALING CLAUSE; PROVIDING AN E':--ECTIVE DATE.
WfiiREA.S, there is currently in effect Ordinance No. 438 of the
City of Pompano Beach, Florida, passed and adopted August 24, 1948, whereby
the City of Pompano Beach did grant to Florida Power $ Light Company, its
successors and assigns, a thirty (30) year electric utility franchise; and
*ERLAS, in consideration of the granting by the City of Pompano
Beach of a new thirty (30) year franchise prior to expiration of the franch;se
granted by said Ordinance No. 438, Florida Power & Light Company has offe ed
to include industrial revenues in the franchise fee calculation, and to -emit
franchise fee payments to the City in est:Lnated monthly installments rather
than on an annual basis as provided in said Ordinance No. 438, thereby
providing substantially increased benefits to the City; and
• NHER..AS, the City Commission of the City of Pompano Beach therefor`
deems it wise and expedient and in the best interest of the City to enter
a new franchise agreement with Florida Power u Light Company prior to
expiration of the franchise granted by said Ordinance No. 438; and
*a-0ZkS, pursuant to law, seven (7) days, notice has been given
by publication in a paper of general circulation in the City, notifying the
public of this proposed ordinance and of a public hearing in the Commission
Aieet_ng Room of the City of Pompano Beac'rl, Florida; and
IN=AS, a public hearing before the City Commission was held,
pursuant to the published notice described above at which hearing the
parties in interest and all other citizens so desiring had an opportunit}-
to be and were in fact heard; now, therefore
BE IT aAGTED BY TES' CITY OF r?LD.ANO BEACH, FLORIIIA:
SECTION 1: That there is hereby granted to Florida Power V Light
Company (herein called the "Grantee") , its successors and assigns, the
•
EXHIBIT
A -
non-exclusive right, privilege franchise to construct, maintain anc
operate in, under, upon, over and across the present and future streo__
alleys, bridges, easements and other public places of the City of parr---
Beach, Florida (herein called the "Grantor") and its successors, in
accordance with established practice with respect to electrical core t—
and maintenance, for the period of thirty years from the date of acre:-_
hereof, electric light and power facilities (including conduits, poles,
wires and transmission lines, and, for its own use, .telephone and tele5-
lines) for the purpose of supplying electricity to Grantor, and its
successors, and inhabitants thereof, and persons and corporations beyon_
the limits thereof.
SECTION 2: As a condition precedent to the taking effect of
grant, Grantee shall. have filed its acceptance hereof with the Grantor,
clerk within thirty (30) days hereof.
SECTION 3: That the facilities shall be so located or relocate.
and so erected as to interfere as little as possible with traffic over
said streets, alleys, bridges and public places, and with reasonable eg-=_
from and ingress to abutting property. The location or relocation of all
facilities shall be made under the supervision and with the approval of
such representatives as the governing body of Grantor may designate for
—o
the purpose, but not so as unreasonably to interfere with the proper ope--
of Grantee's facilities and service. That when any portion of a street i=
excavated by Grantee in the location or relocation of any of its facilitie
the portion of the street so excavated shall, within a reasonable time an_`
as early as practicable after such excavation, be replaced by the Grantee
its expense and in as good condition as it was at the time of such excavat:
SECTION 4: That Grantor shall in no way be liable or responsib7=
for any accident or damage that may occur in the construction, operation cT
maintenance by Grantee of its facilities hereunder, and the acceptance of
ordinance shall be deemed an agreement on the part of the Grantee, to inde-
Grantor and hold it harmless against any and all liability, loss, cost, d`7
or expense, which may accrue to Grantor by reason of the neglect, default
misconduct of Grantee in the construction, operation or maintenance of its
facilities hereunder.
2
SECTION S: That all rates ,d rules and regulations
established by Grantee from time to time shall at all times be reasonable
and Grantee's rates for electricity shall at all times be subject to such
regulation as may be provided by law.
SEO'rION 6: That no later than sixty days after the first arrive-;`
date of this grant and no later than sixty days after each succeeding arJJ,ivo_
date of this grant, the Grantee, its successors and assigns, shall have paid
to—the Grantor and its successors, in consideration hereof, an amount which
added to the amount of all taxes as assessed, levied, or imposed (without reZ,
to any discount for early payment or any interest or penalty for late payment
licenses, and other impositions levied or imposed by the Grantor upon the
Grantee's electric property, business, or operations, and those of Grantee`s
electric subsidiaries for the preceding tax year, will equal 6% of Grantee's
revenues from the sale of electrical energy to residential, commercial and
industrial customers within the corporate limits of the Grantor for the twelve
fiscal months preceding the applicable anniversary date. Payments made by
the Grantee to the Grantor pursuant to this Section shall not be cons idered
in any manner to be .in the nature of a tax.
SECTION 7: Payment of the amount to be paid to Grantor by Grantee
® under the terms of Section 6 hereof shall be made in advance by estimated
monthly installments commencing ninety days after the effective date of this
grant. Each estimated monthly installment shall be calculated on the basis
of ninety percent (90%) of Grantee's revenues (as defined in Section 6) for
the monthly billing period ending sixty days prior to each scheduled mcnthiti
payment. The final installment for each fiscal year of this grant shall be
adjusted to reflect any underpayment or overpayment resulting from estimated
monthly installments made for said fiscal year.
SECTION B: As a further consideration of this franchise,
Grantor agrees not to engage in the business of distributing and srllln1,
electricity during the life of this franchise or any extension tharmr
in ccaipetitim with the Grantee, its successors and assigm.
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•
SECTIOI 9: That failure a ne part of Grantee to comply in
any substantial respect with any of the provisions of this ordinance, shall
be grounds for a forfeiture of this grant, but no such forfeiture shall
take effect if the reasonableness or propriety thereof is protested by
Grantee until a court of competent jurisdiction (with right of appeal in
either party) shall have found that Grantee has failed to comply in a
substantial respect with any of the provisions of this franchise, and the
Grantee shall have six (6) months after the final determination of the ques.__
to make good the default before a forfeiture shall result with the right
in Grantor at its discretion to grant such additional time to Grantee for
compliance as necessities in the case require.
SECTION 10: If any section or provision of this ordinance shall
be held invalid, such holding shall not affect or invalidate any other
section or provision which is not of itself invalid.
SECTION 11: That Ordinance No. 438 and all other ordinances and
parts of ordinances in conflict herewith be and the same are hereby repealed.
SECTION 12: This Ordinance shall take effect on the date upon i:hic,:
Grantee files its acceptance pursuant to Section 2 hereof, upon receipt of
which the City Clerk is hereby directed to attach said acceptance to this
Ordinance, said acceptance to be thereafter incorporated herein by reference aE
if set forth in full.
PASSED FIRST READING this 14th day of June 1977.
PASSED SECOND READING this 21st day of Jane 1977.
MAX1WRYDER, hia.yo:
ATi
E LLJNZ; Eiry Clerk
DCR/lc
5/20/i
#215
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IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
® FOR BROWARD COUNTY,
FLORIDA
CASE NO.: _y
CITY OF POMPANO BEACH, FLORIDA.
CITY OF COCONUT CREEK, FLORIDA,
CITY OF DANI.A BEACH, FLORIDA,
CITY OF MARGATE, FLORIDA, and
CITY OF TAMARAC, FLORIDA,
Plaintiffs,
V. cl..
FLORIDA POWER & LIGHT COMPANY,
A Florida corporation 3
Defendant.
COMPLArN7
T
�rr
Plaintiffs. CITY OF POMPANO BEACH, FLORIDA, CITY OF COCONUT
CREEK, FLORIDA, CITY OF DANIA BEACH, FLORIDA, CITY OF MARGATE,
FLORIDA. and CITY OF TAMARAC. FLORIDA, by undersigned counsel, complain
against defendant. FLORIDA POWER & LIGHT COMPANY, a Florida corporation. as
follows:
Jurisdiction. Parties and Venue
1. This is an action for declaratory judgment and unjust enrichment, over
which this Court has exclusive subject matter jurisdiction.
?. Plaintiffs. CITY OF POMPANO BEACH, FLORIDA ("Pompano
Beach"), CITY OF COCONUT CREEK. FLORIDA ("Coconut Creek"), CITY OF
DANIA BEACH. FLORIDA, formerly known as Dania. Florida ("Dania Beach"), CITY
EXHIBIT
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WEISS SER 9 GUEDES. P.A.
i.,_I NG CA, IJ; .�... =0 R T _ �c_. (954) 763-4242 • FAX (9S4) 764 `.
OF MARGATE, FLORIDA ("Margate"), and CITY OF TAMARAC, FLORIDA
® ("Tamarac"), are municipalities duly chartered and incorporated under Florida law, and
situated in Broward County, Florida. Plaintiffs will collectively be referred to as the
"Cities."
3. Defendant FLORIDA POWER & LIGHT COMPANY ("FPL") is a
Florida corporation, that does substantial business in, owns real property located in, and
maintains corporate offices in Broward County, Florida.
4. FPL supplies electricity throughout' each of the Cities pursuant to
franchises granted to FPL by the Cities, as more particularly set forth below.
5. FPL, as the owner of real and personal property in each of the Cities, is
legally obligated under the Florida Constitution and Florida law to pay each of the Cities
those real and personal property taxes levied on FPL by the Cities each year.
® 6. This cause of action occurred and continues to occur in each of the Cities
in Broward County, Florida.
7. Venue is proper in Broward County, Florida, pursuant to Chapter 47,
Florida Statutes.
Conditions Precedent and Authority for Suit
8. The Qoverning bodies of each of the Cities authorized the filing of this
action.
9. All applicable conditions precedent to.the bringing of this action have
either been satisfied, performed or waived.
i
WEISS SEROTA HELFMAN PASTORIZA & GUEDES, P.A.
3107 STIRLING WOAD, SUITE 300, FORT LAUDERDAL=, FLORIDA 33312 • TEL. (954)763-4242 • FAX(954)764-7770
COUNT I: DECLARATORI' JUDGMENT
• 10. The Cities repeat and reallege paragraphs 1 through 9 as if set forth at
length herein.
11. This is an action for a declaratory judgment pursuant to Chapter 86,
Florida Statutes, and for such further relief that the Court deems just and proper.
The LejZal Controversy
12. A significant legal controversy has arisen between the Cities and FPL
relating to each of the Cities' electric franchise ordinances (the "Franchise Ordinances").
13. The Franchise Ordinances each grant to FPL thirty (30) year electric
service franchises in each of the Cities, and also purportedly grant to FPL indirect real
and personal property tax exemptions.
14. The Cities believe that such indirect property tax exemptions are
impermissible under the Florida Constitution and applicable state lain, and are
consequently ultra wires. invalid and void. FPL disagrees.
1�. As a direct result of the foregoing, and as more particularly set forth
below. the Cities are in doubt as to their rights under the Franchise Ordinances.
Specifically. the Cities are in doubt as to the validity and enforceability of the purported
property tax exemptions contained in Section 6 of each of the Franchise Ordinances, the
present effect of which is to allow FPL to offset hundreds of thousands of dollars per year
in propem, taxes against the six percent (6%) franchise fees, therebS, adversely impacting
the financial position of the Cities and consequently, all of their taxpayers.
WEISS SEROTA HELFMAN PASTORIZA & GUEDES. P.A.
. �. �..�. D. S'..._= 300. 'OR- L..�i.7_�Z)AL-, _._ORID4 3—31_ • ic.�. .o5.1 '63-4242 • 'AX (Q�4) 7b4-i i-
The Franchise Ordinances
. 16. On June 21, 1977, the Pompano Beach City Commission enacted
Ordinance No. 77-50 that granted to FPL an electric franchise for a thirty (30) year term,
to deliver electricity throughout Pompano Beach's boundaries on the terms and
conditions stated therein. A true copy of the Pompano Beach Franchise Ordinance is
attached hereto as Exhibit "A." Shortly thereafter, FPL consented to the terms of the
Pompano Beach Franchise Ordinance.
17. On June 23, 1977, the Coconut Creek City Commission enacted
Ordinance No. 300.03 that granted to FPL an electric franchise for a thirty (30) year term,
to deliver electricity throughout Coconut Creek's boundaries on the terms and conditions
stated therein. The Coconut Creek Franchise Ordinance is in all material aspects the
same as the Pompano Beach Franchise Ordinance, attached hereto as Exhibit "A."
Shortly thereafter, FPL consented to the terms of the Coconut Creek Franchise Ordinance.
18. On June 13, 1978, the Dania City Commission enacted Ordinance No. 173
that granted to FPL an electric franchise for a thirty (30) year term, to deliver electricity
throughout Dania's boundaries on the terms and conditions stated therein. The Dania
Franchise Ordinance is in all material aspects the same as the Pompano Beach Franchise
Ordinance, attached hereto as Exhibit "A." Shortly thereafter, FPL consented to the terms
of the Dania Franchise Ordinance.
19. On August 2, 1978, the Margate City Commission enacted Ordinance No.
78-23 that granted to FPL an electric franchise for a thirty (30) year term, to deliver
electricity throughout Margate's boundaries on the terms and conditions stated therein.
• 4
WEISS SEROTA HELFMAN PASTORIZA & GUEDES, P.A.
107 S?iRLING ROAD. SUITE 300, FORT LAUDERDALE, FLORIDA 33312 • TEL. (9S4)763-4242 • FAX (954) 764_7770
The Margate Franchise Ordinance is in all material aspects the same as the Pompano
Beach Franchise Ordinance, attached hereto as Exhibit "A.'' Shortly thereafter. FPL
consented to the terms of the Margate Franchise Ordinance.
20. On January 12, 1977, the Tamarac City Commission enacted Ordinance
No. 76-57 that granted to FPL an electric franchise for a thirty (30) year term, to deliver
electricity throughout Tamarac's boundaries on the terms and conditions stated therein.
The Tamarac Franchise Ordinance is in all material aspects the same as the Pompano
Beach Franchise Ordinance, attached hereto as Exhibit "A." Shortly thereafter. FPL
consented to the terms of the Tamarac Franchise Ordinance.
The Franchise Fee and the Improper Indirect Tax Exemption
21. As consideration for the right to use the Cities' streets and public rights-of-
way and as consideration for the thirty-year franchises, Section 6 of each of the Franchise
Ordinances provides, inter alia, that FPL shall pay to each of the Cities an annual
franchise fee of six percent (60 o) of FPL's revenues from the sale of electrical energy to
residential. commercial. and industrial customers within the corporate limits of each of
the Cities. However. Section 6 of each of the Franchise Ordinances also purportedly
allows FPL to offset against this franchise fee an amount equal to all taxes assessed or
levied on FPL's electric property.. business or operations in the respective city.
22. Section 6 provides, in totals
No later than sixty (60) days after the first
anniversary date of this grant. and no longer than
sixty (60) days after each succeeding anniversary
The `Grantee" in the Franchise Ordinances is FPL and the "Grantor" is each of the
respective Cities.
WEISS SEROTA HELFMAN PASTORIZA & GUEDES, P.A.
31:�7 S-IRL!N� r=:... SU!TE 300. FORT LAUDERDAL=, FLORIDA 333i2 TEL. (954' 763-4242 • FAX 195e; ?oc_----D
date of this grant, Grantee, its successors and
assigns, shall have paid to the Grantor and its
successors an amount which added to the amount of
all taxes as assessed, levied or imposed (without
reaard to anv discount for early payment or any
interest or penalty for late payment), licenses. and
other impositions levied or imposed by the Grantor
upon Grantee's electric property, business, or
` operations and those of Grantee's electric
subsidiaries for the preceding tax year, will equal
six percent of Grantee's revenues from the sale of
electrical energy to residential, commercial and
industrial customers within the corporate limits of
the Grantor for the twelve (12) fiscal months
preceding the applicable anniversary date.
(Emphasis added).
The underlined language, which creates the improper indirect tax exemption, will
hereafter be referred to as the "Tax Exemption Language."
FPL's Use of the Improper Indirect Tax Exemption
• 23. Relying upon the Tax Exemption Language, FPL claims, and has claimed;
that it has the absolute legal right to "offset" annually all ad valorem real property taxes
and personal property taxes levied on FPL by each of the Cities from the six percent (6%)
franchise fee.
24. In fact, acting pursuant to its purported "legal rights" under the Franchise
Ordinances, each and every year since each of the Franchise Ordinances was adopted,
FPL has offset property taxes levied on FPL by each of the Cities from its annual 6%
franchise fee. No other taxpayer in any of the Cities enjoys such an indirect, dollar for
dollar property tax exemption.
6
WEISS SEROTA HELFMAN PASTORIZA 8c GUEDES, P.A.
31C7 S7 R'_!NG ROAD, SUITE 300, FORT LAUDERDALE, FLORIDA 33312 • TEL. (954)763-4242 • FAX (9S4) 764-7770
25. Moreover; each and every year since each of the Franchise Ordinances was
® adopted. FPL has also taken advantage of the discounts for early payment of assessed ad
valorem taxes as provided by Section 197.162, Florida Statutes. Accordingly, FPL
offsets the entire amount of taxes actually levied on it by each of the Cities, rather than
the actual amount of taxes paid by FPL, from the six percent (6%) franchise fee owed by
FPL to each City.under the Franchise Ordinances.
26. FPL is recovering every dollar, and more, of the property taxes it pays to
each of the Cities each and every year, the result of which is an inequitable, disparate,
onerous and unconscionable annual loss of the revenues to the Cities, which, in turn, must
be absorbed by all of the other property taxpayers in the Cities.
The Indirect Tax Exemption is Ultra Vires and Void
27. At the time the Cities approved the Franchise Ordinances, and at all other
times material hereto; the Cities were not authorized by the Florida Constitution or any
other law to provide a tax exemption to FPL. Article VII, Section 2 of the Florida
Constitution provides in relevant part, that "all ad valorem taxation shall be at a uniform
rate within each taxing unit..." Article VII, Section 3, provides for certain limited
property tax exemptions, none of which apply here. Article VII, Section 9, authorizes
cities and other governmental entities to levy ad valorem taxes but does not authorize any
property tax exemptions.
28. In addition, Section 196.001, Florida, Statutes.. provides in relevant part
that:
Unless expressly exempted from taxation, the
following property shall be subject to taxation in the
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WEISS SEROTA HELFMAN PASTORIZA & GUEDES, P.A.
-i - 57..,_:r,G RO.=.D. SU17�- 300. FOR- '_AUD=RD.=.LE. FLORIDA 33312 • kDS4) 763-d242 =AX (954) "o --"ice
manner provided by law: (1) All real and personal
property in this state and all personal property
. belonging to persons residing in this state...
Chapter 196 contains numerous exemptions, none of which apply to FPL's real and
personal property. This was true under Florida law at the time the Franchise Ordinances
were adopted and it continues to be true today.
29. The subject portion of Section 6 of the Franchise Ordinances provides FPL
with a set-off against its franchise fee equal to all taxes paid by FPL. Florida law is well-
settled that such a set-off constitutes an indirect tax exeption, and is not permitted unless
authorized by the Florida Constitution. Thus, the Tax Exemption Language contained in
Section 6 is ultra vires and void.
The Severance Provision
30. The Franchise Ordinances contain general severance provisions. For
example. Section 10 of the Pompano Beach Franchise Ordinance provides:
If any section or provision of this ordinance shall be
held invalid, such holding shall not affect or
invalidate any other section or provision which is
not of itself invalid.
31. Thus, the parties agreed and intended that, if this type of problem arose
and one section were declared invalid, all remaining portions of the ordinance would
remain in effect. Thus, the best way to match the parties' intent is to enforce the
severability provision, reforming the Franchise Ordinances to require the payment of a
franchise fee of 6% with no improper offset.
•
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WEISS SEROTA HELFMAN PASTORIZA& GUEDES, P.A.
3107 STIRLiNG .RCAD. SUITE 300, FORT LAUDERDALE, FLORIDA 33312 • TEL. (9S4)763-4242 • FAX (9S4) 764-7770
32. As a result of this provision, if the Court declares the Tax Exemption
Language to be ultra wires and invalid; it should also provide that the remaining portions
of Section 6 and the remaining sections of the Franchise Ordinances remain in full force
and effect. This is what the parties agreed would happen if any words or phrases were
declared invalid.
FPL's Continued Insistence to Tale
Advantage of the Improper Tax Exemption
33. Some of the Cities have attempted, in good faith. to obtain FPL's consent
to cease use of the improper tax exemption and to amend the Franchise Ordinances. FPL
has refused.
34. Accordingly, unless the Court grants the declaratory relief sought by this
action. FPL will continue to be the only taxpayer in each of the Cities to enjoy what the
Cities believe to be an illegal, ultra wires, and void indirect real and personal property tax
exemption.
WHEREFORE, the Cities respectfully demand judgment under Chapter 86,
Florida Statutes, declaring that:
(a) the Tax Exemption Language contained in Section 6 of the Franchise
Ordinances constitutes an indirect tax exemption;
(b) each of the Cities lacked and lacks the legal power to contract away;
directly or indirectly, their ad valorem taxing power;
9
WEISS SEROTA HELF MAN PASTORIZA & GUEDES. P.A.
i3- .v ROAD. SUITE 300. FORT LAUDERDA'�E. =!ORID.� 33312 TEL. (954)763-4242 • FAX (954i 764-7770
(c) the Tax Exemption Language contained in Section 6 of each of the
Franchise Ordinances is therefore void, ultra vires and unenforceable under the Florida
Constitution and applicable Florida law;
(d) because of the severability provision, the remaining portions of Section 6
(other than the Tax Exemption Language) and all other Sections of the Franchise
Ordinances remain in full force and effect, and
(e) further granting to the Cities costs and any other relief the Court deems to
be just and proper under the circumstances.
COUNT II: UNJUST ENRICHMENT/RESTITUTION
35. The Cities repeat and reallege paragraphs 1 through 9, 12 through 14 and
16 through 34, as if set forth at length herein.
36. This is an action for unjust enrichment/restitution to recover all sums
improperly withheld by FPL from the Cities under the ultra vires and void Tax
Exemption Language, and for such further relief that the Court deems just and proper.
.37. FPL, and all other owners of real and personal property in each of the
Cities, is legally obligated to pay to the Cities all real and personal property taxes levied
by each of the Cities each year.
38. Each year, FPL has improperly offset a portion of the real and personal
property taxes that it owed to each of the Cities, relying on the Tax Exemption Language
contained in Section 6 of the Franchise Ordinances.
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WEISS SEROTA HELFMAN PASTORIZA & GUEDES, P.A.
31C? S71RLING ROAD. SUITE 300. FORT LAUDERDALE, FLORIDA 33312 • TEL. (954)763-4242 FAX(954) 764-777C
39. FPL has been unjustly enriched at the expense of each of the Cities an
amount equal to the full amount it has offset in taxes as a result of the Tax Exemption
Language. FPL's enrichment has been at the direct expense of each of the Cities.
WHEREFORE, the Cities respectfully demand judgment against defendant FPL
in an amount to be determined at trial, and further granting to each of the Cities its costs
incurred in this action and any other relief the Court deems to be just and proper under the
circumstances.
DATED: May 15, 2001
Respectfully submitted,
WEISS SEROTA HELFMAN
PASTORIZA & GUEDES, P.A.
Counsel for Plaintiffs
3107 Stirling Road, Suite 300
Fort Lauderdale, FL 33312
Telephone: (954) 763-4242
Telecopier: (954) 764-7770
Bv:
J ie Alan Cole
Florida Bar No.: 767573
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WEISS SEROTA HELFMAN PASTORIZA & GUEDES, P.A.
3'0' STiP_;>�G ROAD, SUITE 300. FORT LAUDERDALE. FLORIDA 33312 .E... (9S4) 763--4242 • =AX(95-: 75a.7-70
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY,FLORIDA
CASENO. 01-008883 (03)
CITY OF POMPANO BEACH,FLORJDA,
et al.,
Plaintiffs,
V.
FLORIDA POWER&LIGHT COMPANY,
a Florida corporation,
Defendant.
PLAINTM'l CITY OF DANIA BEACH'S
NOTICE OF VOLUNTARY DISMSSAL WrM PREAM'CE
Plaintiff, City of Dania Beach, Florida,pursuant to Florida Rule of Civil Procedure
• 1.420(a)(1),hereby voluntarily dismisses with prejudice the entirety of its action and all claims it
has asserted herein against Defendant;Florida Power&Light Company.]
Dated-this day of March, 2002. -
WEISS SEROTA B=FMAN
PASTORIZA & GUEDES,P.A.
Attorneys for Plaintiff, City of Dania Beach
3107 Stirling Road, Suite 300
Fort Lauderdale,Florida 33312
Telephone: (954) 763-4242
Telecopier: (954) 764-7770
By:
Jamie Alan Cole
Florida Bar No. 767573
' This notice voluntarily dismisses with
prejudice the acii� ns and claims filed herein by the
filed
herein by the City of Dania Beach,but does not affect
other plaintiffs in this case.
EXHIBIT
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RELEASE AND WAIVER OF ALL CLAIMS
KNI OW ALL PERSONS BY THESE PRESENTS:
That for value received and other good and valuable considerations, the receipt and
` sufficiency of which are hereby acknowledged, the CITY OF DANIA BEACH ("CITY"), a
Florida municipal corporation, does hereby, for itself and its agencies, subdivisions, departments,
divisions, representatives, successors; assigns, officers, officials, agents and employees, their
heirs, executors, administrators, personal representatives, successors and assigns, and any person
or entity claiming by, through or for or succeeding to the right of any of the foregoing
(hereinafter sometimes referred to as the "Releasor"), release, remise, acquit, satisfy, waive and
forever discharge FLORIDA POWER &.LIGHT COMPANY ("FPL"), a Florida corporation, its
parents, subsidiaries, affiliates, directors; employees, officers, stockholders, agents, insurers,
reinsurers, sureties. attorneys. successors and assigns, the heirs; executors. administrators.
personal representatives, successors and assigns of any of the foregoing. and any person or entity
acting for, by or through any of the foregoing (hereinafter referred to collectively as "Releasees")
of and from any and all manner of actions, causes of action, suits. debts, costs, attorney's fees,
sums of money, accounts,reckonings, bonds. bills, specialties, covenants. controversies, loss of
services. obligations, liabilities. agreements, promises, variances, disputes, torts, trespasses,
damages, property damage, losses, liens,judgments, executions, complaints. claims.
counterclaims. cross-claims, injunctive relief and all demands whatsoever, in law or in equity,
whether known or un1mown, whether liquidated, fixed or contingent, whether mature or not,
whether disputed or undisputed, whether foreseen or unforeseen, whether foreseeable or not, and
whether discoverable or not (hereinafter referred to collectively as "All Claims"), which Releasor
EXHIBIT
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ever had, now has or hereafter can, may or shall have, or might in the future have or claim to
have, directly or indirectly, against Releasees:
(1) on account of, in connection with or in any way arising out of or relating to
that certain franchise agreement between FPL and the CITY, the terms of which are set forth in
City of Dania Ordinance No. 173, passed and adopted June 13, 1978, and FPL's written
acceptance thereof dated.June 28, 1978 ("Current Franchise Agreement"), a true copy of which is
attached hereto as Exhibit "A" and incorporated herein by reference, including but not limited to
All Claims relating in any way to the amount of franchise fees payable by FPL to the CITY under
the Current Franchise Agreement, including without limitation All Claims relating to the
amounts and revenues used to calculate and pay such franchise fees, including but not limited to
All Claims that were or could have been asserted in that certain cause styled City of Pompano
Beach. et al. v. Florida Power & Light Company, In the 17th Judicial Circuit in and for Broward
County, Florida. Case No. 01-008883 (03) (such cause being hereinafter referred to as the
"Lawsuit"), provided, however, that the claims released and waived under this subsection (1) do
not include any claim CITY may have against FPL under Section 4 of the Current Franchise
Agreement that accrued on or before the date of this Release And Waiver Of All Claims; and
(2) All Claims relating in any way to the method of calculating the franchise fees
payable by FPL to the CITY under the terms of the new franchise agreement agreed to by and
between FPL and the CITY in consideration of the settlement of the Lawsuit, a copy of which is
attached hereto as Exhibit"B" ("New Franchise Agreement"), including but not limited to All
Claims relating to which revenues are used to calculate the franchise fee under Section 5 of the
New Franchise Agreement, provided, however, that the claims released and waived under this
subsection (2) do not include any claim that could not possibly have accrued until after the New
Franchise Agreement goes into effect, such as a claim that the agreed upon method for
calculating the franchise fee has not been followed or that the amount of the franchise fee has
been calculated incorrectly under the agreed upon method.
The undersigned represents and warrants that no claim which the Releasor has or might
have had against Releasees has been assigned or transferred to any other person or entity, and, to
the maximum extent permitted by law, agrees to indemnify Releasees and hold Releasees
harmless from any and all liability or expense resulting from the assigmnent or transfer of any
such claims.
The Releasor acknowledges and agrees that this release is given for the compromise of
doubtful and disputed claims, that the payment made is not to be construed as an admission
against interest or admission of liability on the part of Releasees as to any claim, demand,
controversy, dispute, defense. cause of action, counterclaim. matter or thing alleged in the
Lawsuit or mentioned herein and compromised and settled hereby, and that Releasees deny
liability therefor and intend merely to avoid the costs of litigation.
The Releasor acknowledges that it has read this Release And Waiver of All Claims and
laiows its contents, that it has had the advice of counsel as to its meaning and intent, that it is
executing this Release And Waiver of All Claims freely and voluntarily for the purposes
expressed herein, that-no promise, inducement or agreement not expressed herein has been made
to it, and that the teams of this Release And Waiver of All Cla
ims are contractual and not a mere
recital.
If any provision of this Release And Waiver of All Claims or the application thereof to
any circumstance is void, invalid or unenforceable for any reason, the remainder hereof, or the
application of such provision to circumstances other than those to which it is held void, invalid or
unenforceable, shall not be affected thereby but shall remain in full force and effect, and each
provision hereof shall be valid and enforced to the fullest and broadest extent permitted by law.
IN WITNESS WHEREOF, the CITY OF DANIA BEACH has caused this Release And
Waiver Of All Claims to be executed in its name and its seal to be affixed, by its proper and fully
authorized representative, this day of March, 2002.
• ATTEST: CITY OF DANIA BEACH, a Florida
municipal corporation
By:
CitN,Clerk , City Manager
(SEAL)
APPROVED AS TO FOIUM
AND LEGALITY:
,City Attorney
-4-
STATE OF FLORIDA
SS:
COUNTY OF BROWARD
I HEREBY CERTIFY that on this date, before me, an officer duly authorized in this
State and County to take acknowledgements, personally appeared , City
Manager of the City of Dania Beach, a Florida municipal corporation, named in the foregoing
Release And Waiver Of All Claims, who is personally known to me or who produced the
following as identification , and that he acknowledged
executing the foregoing Release And Waiver Of All Claims freely and voluntarily in the presence
of the City Clerk and City Attorney under authority duly vested in him by the City of Dania
Beach and that the seal affixed is the true seal of the City of Dania Beach.
• WITNESS my hand and official seal in the County and State last aforementioned
this day of March, 2002.
(signature)
Commission No.
(print name)
My Commission Expires:
Notary Public
. 19 State of Florida
•
-5-
SUN-SENTINEL
PUBLISHED DAILY NOTICE OF
FORT LAUDERDALE, BROWARD COUNTY, FLORIDA BEFORE PUBLIC
RING
CITY ACOMMIS-
BOCA RATON, PALM BEACH COUNTY, FLORIDA CITTYN OF DANIA BEACH,
MIAMI, MIAMI DADE COUNTY, FLORIDA ADOPITTION DA OF THERFING
OL-
LOWING PROPOSED ORDI-
NANCES
NOTICE IS HEREBY GIVEN
STATE OF FLORIDA that the City commission
of the City of Dania Beach,
COUNTY OF BROWARD/PALM BEACH/MIAMI DADE (Florida. on March 26
BEFORE THE UNDERSIGNED AUTHORITY, PERSONALLY APPEARED soon' Uie�eafter as the
matter may pbe heard,will.
conduct a ublic hearingi
WHO, ON OATH,SAYS THAT in the City Commission
HE/SHE IS A DULY AUTHORIZED REPRESENTATIVE OF THE CLASSIFIED BeachbCity Mall,the
e00 west
DEPARTMENT OF THE SUN-SENTINEL, DAILY NEWSPAPER PUBLISHED Dania Beach Boulevard,
Dania Beach, Florida to IN BROWARD/PALM BEACH/MIAMI DADE COUNTY, FLORIDA, AND THAT THE consider the proposed
ATTACHED COPY OF ADVERTISEMENT, BEING A: o�dlntencesf entitled:owing
AN ORDINANCE OF THE
ADMINISTRATION CITY of DANIA BEACH,
FLORIDA. PERTAINING TD
CHAPTER 2 OF THE CITY
IN THE MATTER OF: CODE of ORDINANCES,
WHICH CHAPTER IS ENTI-
TLED 'ADMINISTRATION'.
AMENDING THE CODE OF
Administrabon ORDINANCES,BY AMEND.
ING SECTION 2-12. ENTI-
TLED -ISSUANCE OF
IN THE CIRCUIT COURT, WAS PUBLISHED IN SAID NEWSPAPER IN THE PROMISSORY OBLIGA-
TIONS,' BY INCREASING
ISSUES OF: GTHE ENERAL SOLID AMOUNT SOL D PR NCI-
PAL OBLIGATIONS OUT.
STANDING AT ANY ONE
3/15 10813490 TIME FROM S3,000,000.00
TO S6,000,000.00: PRO.
VIDING FOR CONFLICTS
AFFIANT FURTHER SAYS THAT THE SAID SUN-SENTINEL IS A NEWSPAPER ANCE; FURTH RR PROVED-
PUBLISHED IN SAID BROWARD/PALM BEACH/MIAMI DADE COUNTY, FLORIDA, ING FOR AN EFFECTIVE
AND THAT THE SAID NEWSPAPER HAS HERETOFORE BEEN CONTINUOUSLY ANT ORDINANCE of THE
CITY OF IA
PUBLISHED IN SAID BROWARD/PALM BEACH/MIAMI DADE COUNTY, FLORIDA, FLORIDA GRANTS GC To
® EACH DAY,AND HAS BEEN ENTERED AS SECOND CLASS MATTER AT THE FLORIDA POWER AND
POST OFFICE IN FORT LAUDERDALE, IN SAID BROWARD COUNTY, FLORIDA, LIGHT COMPANY,ITS SUC-
CESSORS AND ASSIGNS,
FOR A PERIOD OF ONE YEAR NEXT PRECEDING THE FIRST PUBLICATION OF IMPOSING PROVISIONS
ATTACHED COPY OF ADVERTISEMENT;AND AFFIANT FURTHER SAYS THAT AND CONDITIONS RELAT-
HE/SHE HAS NEITHER PAID, NOR PROMISED,ANY PERSON, FIRM, OR ING TO SUCH FRANCHISE:
PROVIDING FOR MONTHLY
CORPORATION,ANY DISCOUNT, REBATE, COMMISSION, OR REFUND, FOR THE PAYMENTS TO B ACHE CITY
PURPOSE OF SECURING THIS ADVERTISEMENT FOR PUBLICATION IN SAID VIDING FOR CONFLICTS:
N PER. PROVIDING FOR SEVER-
///��� ANCE: FURTHER, PROVID-
ING FOR AN EFFECTIVE
J DATE.
�1/V A Copy of these proposed
(SIGNATURE O><,a(FFIANT) theinances Off Off,
are o( theh c in
lry
Clerk, City Hall, 100 west
Dania Beach Boulevard,
SWORN TO AND SUBSCRIBED BEFORE ME Dania Beach,Florida,and
may be inspected by the
ON: 15-March-2002 , A.D. public during normal
working hours.
Interested parties may ap-
pear at the aforesaid
meeting and be heard
with respect to the pro-
(SR3WATUREf OF NOTARY PUBLIC) posed. Any person who
decides to appeal any de-
,,`� � Barbara Strickland cision made by the City
��"' Commission 9 CC 9440 i 4 Commission with respect
to any matter considered
_�. FX#M -�; JAY 2004 _ at this hearing will need al!
4; 1 record of the proceedings
Bonded 7r--
�� � Atleu`c Bobdi^g Co.,Inc. and for such purpose may
,,, ,�� need to ensure that a ver-
batim record of the pro-
(NAME OF NOTARY,TYPED, PRINTED, 0 STAMPED) re ord i made, which
ecrtl nclutles the testi-
mony and evidence upon
which the appeal is to be
PERSONALLY KNOWN OR based.
In accordance with the
American with Disabilities
PRODUCED IDENTIFICATION Act, persons needing as-
sistance to participate in
any of the proceedingsi
should contact Charlene,
Johnson, City Clerk, 1001
West Dania Beach Boule-i
vard,Dania Beach,Florida)
33004. (954) 924-3622 at,
least 48 hours prior to the
meeting.
/s/Charlene Johnson
City Clerk
March 15,2002
A
a
CITY OF DANIA BEACH
MEMORANDUM
TO: Mayor and Commissioners
cc: Ivan Pato, City Manager
FROM: Tom Ansbro, City Attorney
DATE: March 21, 2002
RE: Ordinance Adopting Proposed New Florida Power and Light Franchise
Agreement; Comparison of Proposed and Current Agreements
• The proposed new FP&L Franchise Agreement has been a endaed for City
ry
Commission adoption by ordinance (second reading) for the March 26, 2002 meeting. Two
modifications have been made to the ordinance since its first reading. The "severability"
provision has been revised to expressly state that if any provision in the Agreement is found to
be invalid, illegal, void or of no effect (by a court), then the entire ordinance shall be
considered null, void and of no further force or effect. It is the position of FP&L that the new
Agreement provisions are so "interdependent" that, if a court were to effectively remove one
or more provisions because of invalidity or illegality, it would affect the entire ordinance and
Franchise Agreement. The other change is merely a minor typographical revision (change "In"
to "in" in one sentence as requested by FP&L attorneys).
The current thirty (30) year Franchise Agreement was adopted by ordinance on June
13, 1978 (Ordinance No. 173) and is set to expire in 2008. The new Agreement also provides
for a term of thirty (30) years, expiring in 2032. Both Agreements give FP&L a "non-
exclusive" right to supply electricity, and each contains an agreement by the City that it will
not compete with the Company by engaging in the business of distribution or sale of
electricity.
In the proposed new Agreement, a number of recitations are made about the factual
background of the proposed settlement of the pending litigation between the Company and the
City (in the first three (3) pages of the Agreement, which contain the recitals or "WHEREAS"
clauses); the Agreement currently in effect does not, of course have corresponding provisions.
March 21, 2002
Page 2
In nearly all other respects, the proposed Agreement is substantially similar to the 1978
-', Agreement. The most significant change in the Agreement is the provision specifying that the
current franchise fee paid to the City of 6% of the company's revenues will be altered to a
figure of 5.9%, but no "offset" for ad valorem taxes (real estate or property taxes) will be
applied against that franchise fee payment. That provision is included as a direct result of the
` claims by the City in the pending lawsuit, and will result in substantial additional revenue to
the City.
The new Agreement also contains new provisions which recognize that if a competitor
of FP&L seeks to sell electric power to the City, the City will afford FP&L an opportunity to
"meet or beat" the competitor's offer. If FP&L does not do so, the City is free to purchase
power from the competitor, and the Agreement still remains in effect. Another new provision
specifies that if the City gives a competitor a franchise that FP&L finds to contain terms more
favorable than those in the new proposed Agreement, then FP&L may terminate its franchise
with the City. A similar provision is also included within the new Agreement, allowing for
termination by the Company if the United States government, State of Florida or any of their
respective:agencies allow a competitor to provide service in the City which puts the Company
at a "competitive disadvantage". In that event, unless terms are negotiated with such
competitor within ninety (90) days from the date FP&L expresses its intent to terminate
because of the anticipated competition and disadvantage, and matters cannot be rectified to
address this type of "competitive disadvantage", then the Company could terminate the
Agreement. The new Agreement also provides the City with the right to audit the Company's
records; the current Agreement does not contain such a provision.
Lastly, the current franchise contains the standard "severance" or "severability" clause
which allows for the franchise Agreement to remain intact even if a court decides that a portion
of the Agreement is illegal or invalid. As mentioned above, the new Agreement has a provision
which would render the entire Agreement void if a part of it were declared to be illegal,
invalid or of no effect. As mentioned above, other provisions, such as indemnification of the
City for the Company's actions and restoration of a work site after excavation, are
substantially the same in both Agreements.
This is now ready for Commission consideration and adoption at the March 26, 2002
City Commission meeting.
TJA:slw
Attachment