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HomeMy WebLinkAbout2021 03 01 Schrimsher Letter to Shawn Boyle City Manager 4 dl J i, PROPERTIES February 26, 2021 VIA- CERTIFIED MAIL- RETURN RECEIPT UQUESTED Mr. Shawn Boyle Mr. Anthony A. Garganese City Manager City Attorney of Winter Springs City of Winter Springs Garganese, Weiss, D'Agresta & Salzman, P. A. 1126 East State Road 434 111 North Orange Ave., Suite 2000 Winter Springs, Fl, 32708 Orlando, FL 32801 RE: Agreement dated June 26, 2000, by and among Schrimsher Land Fund 1986-11, Ltd., Schrimsher Land Fund V, Ltd., and Schrimsher Land Fund VI, Ltd. ("Schrimsher") and the City of Winter Springs ("City") Dear Mr. Boyle & Mr. Garganese: This letter is thirty(30) days written notice that the City of Winter Springs is in default of the above referenced agreement, a short form memorandum of which was recorded on January 8, 2001, in Official Records Book 3988, Page 1063, Public Records of Seminole County, Florida. The City has failed to perform its obligations under this Agreement which entitles Schrimsher to pursue whatever remedies are available under Florida law or equity. Prior to filing an action to seek specific performance and/or injunction relief,this written notice will provide the City an opportunity to cure the default to our reasonable satisfaction. The prevailing party in any litigation shall be entitled to recover its reasonable attorney's fees and costs. Article IV(e) states that except for the conveyances from Schrimsher to the City so described in this Article IV . . . Schrimsher shall have no,further obligation to convey to the City any property for park, open space or gre�n space purposes. However, the obligation for Schrimsher to pay the City for removing trees imposed by the City's tree ordinance renders wooded lots in the Town Center undevelopable and constitutes an administrative taking of private property to function as open space or green space,or even a park for those who trespass. The City obligations in Article V which the City agreed to do but failed to perform include,but are not limited to, the following: a) Within eighteen (18) months . . . extend and connect (i.e., "stub in") City water distribution and sewer collection facilities to the boundaries of Schrimsher Property in sufficient capacity to reasonably accommodate and guarantee the level of service capacity 600 EAST COLONIAL(DRIVE SUITE 100 ORLANDO, FLORIDA 321303 , FAX C407)64R-9230 OFFICE 1407)423-7600 Mr. Boyle & Mr. Garganese February 26, 2021 Page 2 ire art Town Center and SchrimsherProperty. Except as provided in Article V(c) and V(d)below relating to Spine Road and Main Street Improvements, the City shall not be required to extend either sewer or water facilities into the interior portion of the Schrimsher Property unless agreed upon in future written developer agreements. The City also guarantees sufficient capacity within the sewer and water treatment plants to reasonably accommodate andguarantee the level ofservice require the Town Center and Schrimsher Property. The City also agrees that no special City water or sewer connection charge or assessment will be applied to Schrimsher Property for purposes of reimbursing the City for the expense of extending and connecting the City's water distribution and sewer collection facilities to Schrimsher's property as described above Note:Article V(a)does not specify but Article XV concerning the Traffic Signal refers to "construction of the Spine Road north or south of State Road 434". Comments made by City staff and elected officials calls into question whether the City intends to honor these commitments. (b) Promptly commence and within six (6) months . . . submit an application to acquire a Master Star water Management Permit from the St. John's Water Management District forte Town Center and expedite tote ' st extentpossible completion of the master stormwater permitting within the Town Center and Schrimsher Property, *This has NEYER occurred. (c) . . . if Schrimsher desires to construct Spine Road in accordance with the Town Center District Code, prior to City's schedule for said construction provided herein, Schrimsher may design, engineer, permit, survey, and construct Spine Road at Schrimsher's expense.. .Schrimsher shall then be eligible for and receive in connection with the development of the Schrimsher Property transportation impact fee credits in an amount equal to Schrimsher's reasonable costs . . .which costs shall be deemed for "non-site-relate improvements." Accrued credits shall be applied to the development of Schrimsher Property. Regardless of which party constructs Spine Road,the City, at its expense and concurrently with the construction of Spine Road, agrees to design,permit and construct water and sewer utilities for Spine Road required for the Town Center and Schrimsher Property (the "Spine Road Utilities"). Schrimsher shall convey the right of way for Spine Road to the City at such time as the City has obtained all necessary permits forte City to construct Spine Road or at such time that Schrimsher has completed construction of Spine Road, whichever occurs first. Mr. Boyle & Mr. Garganese February 26, 2021 Page 3 Note: Schrimsher and Hawthorn split the costs to construct Spine Road south of State Road 434 making them eligible to receive the impact fee credits and they constructed the Spine Road Utilities south of State Road 434 and should be reimbursed for those sewer and water utilities which were supposed to be designed, permitted and constructed at the City's expense. According to Articles VI and VII,Schrimsher consented to inclusion of the Schrimsher Property in the Town Center District and consented to adoption of the Town Center District Code and its applicability to the Schrimsher Property"subject to the terms and conditions hereof." Article XVI states that the City agrees to cooperate with Schrimsher to allow Schrimsher to design, permit, and construct a road along the existing right-of-way behind the "Mobil Service Station" currently on the corner of State Road 434 and Tuskawilla Road,which may or may not be designed to connect Tuskawilla Road with a frontage road south of State Road 434. Note: The City should bear this in mind when reviewing proposed development of the two properties adjacent to Mobil. Article XVII states that both parties agree that there are no minimum green space or open space requirements within the Town Center District. Article XIX states that this Agreement shall be subject to periodic review by the parties. Periodically, City and Schrimsher agree to cooperate and meet in good faith to discuss the progress made under this Agreement in furtherance of each others mutual interests. Additionally,during said review,the parties may discuss proposing amendments to the Town Center District Code which may be needed to promote the public's interest in creating an economically viable Town Center. Note: Periodic review as described above has NEVER occurred but the City has amended the Town Center District Code without meeting in good faith with Schrimsher or even providing notice to Schrimsher that amendments were being considered. This does not reflect cooperation by the City with Schrimsher to further our mutual interests. Article XX states that Schrimsher and the City shall cooperate fully with each other to effectuate the terms, conditions and intentions of this Agreement. Mr. Boyle & Mr. Garganese February 26, 2021 Page 4 Article XXVI states that this Agreement shall not be modified or amended except by written agreement duly executed by both parties hereto, and Article XXVII states that this Agreement supersedes any other agreement, oral or written, and contains the entire agreement between the City and Schrimsher as to the subject matter hererof. Article XLI states that to the extent there are any conflicts between the provisions of the Town Center District Code and this Agreement,the provision of this Agreement shall control as if approved by the City Commission as a special exception pursuant to the Town Center District Code. Article XLIII states that the City acknowledges Schrimsher's right to impact the wetlands . . . on the north side of State Road 434 and . . . on the south side of State Road 434 in the southeastern portion of Town Center, provided Schrimsher complies with all applicable governmental requirements. Furthermore, the City acknowledges that Schrimsher shall have the right to utilize other wetlands located within Town Center for the purpose of satisfying"wetland mitigation"requirements related to one or more developments located outside of Town Center. The Town Center Plan dated March 23, 1998, was attached as Exhibit "C" and fully incorporated into the Agreement. Although conceptual in nature,it does describe how the plan was developed and its key concepts and guiding principles. The Town Center District Code dated June 12,2000,was attached as Exhibit"E"and fully incorporated into the Agreement. Page 18 states that Main Street is the most important street in the town center. It is lined with mixed-use shopfront buildings that are positioned at the front of each lot. It features angled parking or parallel parking and wide sidewalks. Trees in the right-of-way are optional. The southern portion between Market Square and Magnolia Square is of primary importance for implementation,but it is understood that over time Main Street may grow into the area of Tuskawilla Road north of Magnolia Square. Note: The City was given Magnolia Square plus land north and south of Magnolia Square plus 11 feet of additional right-of-way, all along the east side of Main Street (Tuskawilla Road)but 20 years later there are no mixed-use shopfront buildings along that side of the "most important street in the town center." Mr. Boyle & Mr. Garganese February 26, 2021 Page 5 Also, in the Town Center District Code on page 9, paragraph K. Single vs. Double Loaded Roads states that segments of single loaded Edge Drive are designated for portions of the masterplan in order to provide public access to significant natural areas . . . and Page 22 states the Edge Drive provides public access along the natural boundaries of the town center. Note: Michael Blake Boulevard,which is a single loaded Edge Drive around Wetland Park, does not have a sidewalk along that natural boundary nor is there any other way to provide public access to that "significant natural area" 20 years later. I look forward to your prompt response and comprehensive action plan to address our concerns, and cure the City's default under the terms of our Agreement. Sincerely, SCHRIMSHER LAND FUND 1986-II, V & VI, LTD. SCHRIMSHER PROPERTIES � .... Michael A. Schrimsher cc: Mr. Michael J. Grindstaff, Esquire Mrs. Karen Wankelman, Esquire Shutts & Bowen 300 S. Orange Ave., Ste 1600 Orlando, FL 32801 Mr. Boyle & Mr. Garganese February 26, 2021 Page 5 Also, in the Town Center District Code on page 9, paragraph K. Single vs. Double Loaded Roads states that segments of single loaded Edge Drive are designated for portions of the masterplan in order to provide public access to significant natural areas . . . and Page 22 states the Edge Drive provides public access along the natural boundaries of the town center. Note: Michael Blake Boulevard,which is a single loaded Edge Drive around Wetland Park, does not have a sidewalk along that natural boundary nor is there any other way to provide public access to that "significant natural area" 20 years later. I look forward to your prompt response and comprehensive action plan to address our concerns. Sincerely, SCHRIMSHER LAND FUND 1986-II, V & VI, LTD. SCHRIMSHER PROPERTIES Michael A. Schrimsher cc: Mr. Michael J. Grindstaff, Esquire Mrs. Karen Wankelman, Esquire Shutts & Bowen 300 S. Orange Ave., Ste 1600 Orlando, FL 32801