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Reso 2015-2445
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Reso 2015-2445
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Last modified
7/26/2016 1:00:08 AM
Creation date
8/6/2015 4:13:49 PM
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CityClerk-Resolutions
Resolution Type
Resolution
Resolution Number
2015-2445
Date (mm/dd/yyyy)
07/16/2015
Description
Ratify Agmt to Retain Srvs of Holland & Knight Law Firm
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Legal
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Reso Delivered on 7/26/2016 1:00 AM to Legal Dept.
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involving "the retrofitting of some of the storm water discharges . . . coming. into the canal." <br /> Trial T. 593-94. On cross-examination, however, Mr. Carney admitted that he was unaware <br /> whether Respondent had any discussions with the owner of Oleta River State Park regarding the <br /> ability to engage in offsite mitigation there, Trial T. 612, and that he had not spoken with the <br /> City of Sunny Isles Beach regarding the viability of a mitigation plan that included a retrofitting <br /> of stormwater-draining infrastructure within the City. Trial T. 614. <br /> Again, Respondent's witnesses' assumptions, provided exclusively in the form of pure <br /> opinion evidence, that Respondent would have been able to secure a location for off-site <br /> environmental mitigation amounted to improper speculation, which has been expressly forbidden • <br /> by the Florida Supreme Court in Yoder. See Yoder, 81 So. 2d at 221 ("To permit such evidence <br /> [on what could be done to the land or what might be done to it to make it more valuable] would <br /> open a flood-gate of speculation and conjecture that would convert an eminent domain <br /> proceeding into a guessing contest."). This speculative evidence contaminated the trial in that it <br /> enabled the jury to conclude the award property could have been developed into a private <br /> docking facility. As such, a new trial should be granted. <br /> D. Respondent's witnesses presented speculative testimony regarding Respondent's <br /> access to upland property. <br /> As of the date of trial, the parties had agreed that the Parent Tract included only <br /> submerged lands and not any upland property. See 5/22/15 Hr'g Tr. 5:20-6:11. It was also <br /> undisputed that any development of the submerged lands into a private docking facility would <br /> require the use of some upland property. Trial T. 688-89 (testimony from Mr. Checca that <br /> permit application to DERM would have to identify some upland property). <br /> At trial, Mr. Checca testified that it was feasible to develop the property as a private <br /> docking facility because there were uplands adjacent to it. Trial T. 676-77. On cross- <br /> 8 <br />
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