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4800 ASBURY ROAD DUBUQUE IA LLC and HYVEE INC. vs. City of Dubuque Board of Review Stipulation of SettlementCity of Dubuque City Council Meeting Consent Items # 05. Copyrighted September 6, 2022 ITEM TITLE: 4800 ASBURY ROAD DUBUQUE IA LLC and HYVEE INC. vs. City of Dubuque Board of Review Stipulation of Settlement SUMMARY: Senior Counsel providing a copy of the Stipulation of Settlement regarding a tax assessment appeal filed by the Board of Review with the Iowa District Court for Dubuque County regarding 4800 ASBURY ROAD DUBUQUE IA LLC and HYVEE INC. vs. City of Dubuque Board of Review. SUGGESTED Suggested Disposition: Receive and File DISPOSITION: ATTACHMENTS: Description Agenda Letter Notice of Voluntary Settlement Stipulation of Settlement Affidavit of Service Type Supporting Documentation Supporting Documentation Supporting Documentation Supporting Documentation Barry A. Lindahl, Esq. Senior Counsel Suite 330, Harbor View Place 300 Main Street Dubuque, Iowa 52001-6944 (563) 583-4113 office (563)583-1040 fax balesq u,cityofdubuque�rg Office Hours: 8:00 AM — 5:00 PM, T-W-Th 8:00 AM — 12:00 PM, F Mayor and Members of the City Council of the City of Dubuque City Hall 50 West 13th Street Dubuque, IA 52001 Chairperson of the Dubuque County Board of Supervisors Dubuque County Courthouse 720 Central Avenue Dubuque, IA 52001 Chairperson of the School Board Dubuque Community School District Central Administration Offices 2300 Chaney Road Dubuque, IA 52001 Chairperson of the Conference Board of the City of Dubuque City Hall 50 West 13th Street Dubuque, IA 52001 THE CDubuque JURaerica City DUj!B9TE a II Masterpiece on the Mississippi 2007.2012 2013.2017 August 9, 2022 President of the Board of Directors Northeast Iowa Community College P.O. Box 400 Calmar, IA 52132 Chairperson of the Board of Trustees Dubuque County Hospital Sunnycrest Manor 2375 Roosevelt Street Dubuque, IA 52001 Chairperson of the Council of the Dubuque County Agricultural Extension Service 14858 West Ridge Lane, Suite 2 Dubuque, IA 52003 RE: 4800 ASBURY ROAD DUBUQUE IA LLC and HY-VEE INC. vs. City of Dubuque Board of Review Case Nos. EQCV109274, 112186 and 113527 Enclosed is a copy of the Stipulation of Settlement regarding a tax assessment appeal filed by the Board of Review with the Iowa District Court for Dubuque County. Iowa Code Sec. 441.44 requires that the Stipulation of Settlement be served upon each of you. There is one property that is the subject of these appeals. The appeal is for the January 1, 2019, 2020, 2021 and 2022 assessed value. Proposed Settlement The parties have reached a proposed settlement agreement. The tentative settlement is for an assessed value for January 1, 2019, 2020, 2021 and 2022 of $5,100,000. Pursuant to the Stipulation of Settlement the appeals will be dismissed and the assessed value will be adjusted to $5,100,000 for January 1, 2019, 2020, 2021 and 2022. The value will be apportioned as follows: Land Value: $1,656,900 Building Value: $3,443 100 Total Value: $5,100,000 The proposed settlement will be presented to the Iowa District Court after fourteen (14) days from the date indicated on the attached Notice of Voluntary Settlement. If there are any objections to the settlement they should be made known to the Iowa District Court prior to that time. If you have any questions about the proposed settlement, please contact City Assessor Troy Patzner at (563) 589-7800. Very rely, arry A. Lindahl, Esq. Senior Counsel Enclosure cc: Michael C. Van Milligen, City Manager Adrienne N. Breitfelder, City Clerk Troy Patzner, City Assessor 2 IN THE IOWA DISTRICT COURT FOR DUBUQUE COUNTY 4800 ASBURY ROAD DUBUQUE IA ) LLC and HY-VEE INC., ) Plaintiffs -Appellants, ) vs. ) Case Nos. EQCV109274, 112186 and 113527 CITY OF DUBUQUE BOARD OF ) REVIEW, ) Defendant -Appellee. ) NOTICE OF VOLUNTARY SETTLEMENT TO: City of Dubuque, Iowa County of Dubuque, Iowa Dubuque Community School District Northeast Iowa Community College Dubuque County Hospital Dubuque County Agricultural Extension Service Conference Board of the City of Dubuque YOU ARE HEREBY NOTIFIED, pursuant to Iowa Code Section 441.44 that the above -named Plaintiffs and the Dubuque City Board of Review, Defendant, have entered into a voluntary settlement of these property assessment appeals. A copy of the proposed Stipulation of Settlement is attached hereto. This Stipulation of Settlement will be presented to the above -named Court for approval after fourteen (14) daysfromthe date of this Notice. r- Dated this q k- day of UCW<'- T` , 2022. City of Dubuque Board of Review, Defendant By I " B ry A. Lindahl, Esq. S nior Counsel Suite 330, Harbor View Place 300 Main Street Dubuque, IA 52001-6944 (563) 583-4113 IN THE IOWA DISTRICT COURT FOR DUBUQUE COUNTY 4800 ASBURY ROAD DUBUQUE IA ) LLC and HY-VEE INC., ) Plaintiffs -Appellants, ) ) vs. ) Case Nos. EQCV109274, 112186 and 113527 ) CITY OF DUBUQUE BOARD OF ) REVIEW, ) Defendant -Appellee. ) STIPULATION OF SETTLEMENT Plaintiffs and Defendant state to the Court that the regard to the tax assessment for the following -described 1, 2019, 2020, 2021, and 2022: (Parcel No. 1017476005) has been settled and agreed upon as follows: Valuation: Land Value: $1,656,900 Building Value: $3,443 100 Total Value: $5,100,000 pending litigation with property as of January It is further agreed that the Valuation of $5,100,000 shall be effective for January 1, 2019, 2020, 2021, and 2022. It is further agreed that upon entry of a Court Order confirming the above settlement, the above pending litigation shall be dismissed with prejudice and the costs shall be paid by Plaintiffs. Dated this 2'7f"O'day of 2022. 4800 ASBURY ROAD DUBUQUE IA LLC and HY-VEE INC. By: �) rm e -4 t Marshall, Esq. LANE & WATERiIMAN LLP 220 N. Main Street Suite 600 Davenport IA 52801 (563) 324-3246 CITY OF DUBUQUE BOARD OF REVIEW - 0 lwk B 7 A. Lindahl, Esq. SU4te 330, Harbor View Place 300 Main Street Dubuque, IA 52001-6944 (563) 583-4113 Attorney for Plaintiffs Counsel for the City of Dubuque Board of Review 2 IN THE IOWA DISTRICT COURT FOR DUBUQUE COUNTY 4800 ASBURY ROAD DUBUQUE IA ) Case Nos. EQCV109274 LLC and HY-VEE INC., ) EQCV112186 EQCV113527 Plaintiffs -Appellants, ) vs. ) CITY OF DUBUQUE BOARD OF ) REVIEW, ) ) Defendant -Appellee. ) AFFIDAVIT OF SERVICE State of Iowa, Dubuque County. The undersigned, after being duly sworn upon oath, states that a true and accurate copy of the attached Notice of Voluntary Settlement and Stipulation of Settlement was mailed to the following people and at the following addresses by ordinary mail on the 9th day of Au ust, 2022: Mayor of the City of Dubuque City Hall 13th & Central Avenue Dubuque, IA 52001 Chairperson of the Dubuque County Board of Supervisors Dubuque County Courthouse 720 Central Avenue Dubuque, IA 52001 Chairperson of the School Board Dubuque Community School District Central Administration Offices 2300 Chaney Road Dubuque, IA 52001 Chairperson of the Conference Board of the City of Dubuque City Hall 13th & Central Dubuque, IA 52001 President of the Board of Directors Northeast Iowa Community College P.O. Box 400 Calmar, IA 52132 Chairperson of the Board of Trustees Dubuque County Hospital Sunnycrest Manor 2375 Roosevelt Street Dubuque, IA 52001 Chairperson of the Council of the Dubuque County Agricultural Extension Service 14742 Hwy. 20 West, Suite 2 Dubuque, IA 52003 Barry �. Lindahl, Esq. Senior.Counsel Suite 330, Harbor View Place 300 Main Street Dubuque, IA 52001-6944 (563) 583-4113 Subscribed and sworn to before me this _�_ day of &OWV 2022. .31 F,.: Ndta Public State of Iowa -�s� JENNIFER M. MESSERICH rY , . Commiss on Num er 7 3874 My Comm. Exp. �,