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HomeMy WebLinkAboutcoa.lu.ec.Kuehlman 415 W. Francis 198535v�-$S Kuehlman 9115 W. Francis 1985 Lot Line Adjustment / 0 7 EI C q&OAD SUKMA.RY SHEET - City of. .- DATE RECEIVED*f CASE NO. DATE RECEIVs •MPLETE- STAFF: ..ES 1 z�Representative A..-In�iIIl.WM!n�l�Ll�flrl/ Type of Application: I. GMP/SUBDIV IS ION/PUD (4 step) Conceptual Submission ($2,730.00) Preliminary Plat ($1,640.00) Final Plat ($- 820.00) II. SUBDIV IS ION/PUD (4 step) Conceptual Submission ($1,900.00) Preliminary Plat ($1,220.00) Final Plat ($ 820.00) III. EXCEPT ION/EXEMPTION/REZON ING (2 step) ($1,490.00 ) IV. SPECIAL REVIEW (1 step) ($ 680.00) Special Review Use Determination Conditi a ✓ Other l^ P&Z CC MEETING DATE: �`\ of PUBLIC HEARING: YES HATE REFERRED: 2 INITIALS: -------------------- ------------- REFERRALS: City Atty Aspen Consol. S.D. School District City Engineer Mtn. Bell Rocky Mtn. Nat. Gas Housing Dir. Parks Dept. State Hwy Dept (Glenwd) Aspen water Holy Cross Electric State Hwy Dept (Gr.Jtn) City Electric Fire Marshall Bldg: Zoning/Inspectn Envir. Hlth. Fire Chief Other: --------------------------------- FINAL ROUTING: DATE ROUTED • i," i INITIAL: City Atty City Engineer Building Dept. Other: Other: FILE STATUS AND LOCATION: Reviewed b XyeFsm.4`• Lot SI,t�` Y= Aspen Pu City Counc' JJ ✓� 0'4 / i fllr CDr1s+Fury �i) Ord .�v�'S�J. 1. The lot line between Lots F and G, where parallel to the existing Kueh man structure, shall be moved 3-1/2 feet to the east, and �r^rother segments of the lot line shall be change so as to retain ()Vlf i lots 3,000 s.f. each. A new plat shall be submitted for CJy„il ,IrP 6 P1 ni g and Encineering Office approvals. 2. Both parties shall acree to join any special improvement dis- tricts formeO in the future. 3. The plat shall contain all information requested in: the Engineer- ing Office memorandum of October 11, 1985 and shall meet the criteria of Section 20-15 of the I'ur.iciral Code in Final Plat subr:ittal. 4. Any removal of trees shall be subject to Section 13-76 of the Municipal Code. 6. A Statement of Subcivi_ion E.;cefticn shall be filed for approval of the City Attorney. -ev i euc . t.sren PL' City Council 0 suox 554 PAGE486 DECLARATION OF COVENANTS, RESTRICTIONS AND CONDITIONS John Thomas Kuehlman and Helen Jane Kuehlman, and George A. Wester ("Covenantors"), for themselves, their successors and assigns, in consideration of the granting of a lot line adjustment application by the City Council of the City of Aspen, and as an inducement to the granting thereof, hereby covenant with the City of Aspen, Pitkin County, Colorado, to restrict such property, and hereby do restrict such property as follows: 1. Covenantors are the owners of the following described property (the "Property") together with the improvements thereon situated in the City of Aspen, Pitkin County, State of Colorado: Lots E and F (the "Kueh-1mann Lots") and Lots G, H, and I (the "Wester Lots") Block 4, City and Townsite of Aspen, Pitkin County, Colorado. 2. In the event of any municipal improvement or improvements of the kind contemplated in Section 20-16 of the Municipal Code of the City of Aspen, as amended, become, in the sole judgment or discretion of the City Council of the City of Aspen, necessary or desirable to the area of the subject property, Covenantors will make no objection to any special assessment or special tax or proceeding therefor on the basis that the property is adequately served by existing improvements and/or on the basis that the premises will not be served or benefited by the improvement or improvements proposed. Covenantors further agree to join, upon the City's demand therefor, any improvement district formed for con- struction of such improvements (including, without limita- tion, drainage, underground utilities, paving, curbs, gutters, sidewalks, street lights, etc.) in the area of the property or to reimburse the City of Aspen directly upon demand therefor if the City should choose to construct these improvements without the formation of such a district. 3. Covenantors warrant that they are the title owners of the subject property with full authority to restrict the property as aforesaid and that there are no persons or entities who have an interest in the subject property who have not agreed and consented to the aforesaid restrictions. 4. None of the covenants contained herein shall be released or waived in any respect without the prior consent of the City of Aspen, reflected by resolution of the City Council of the City of Aspen. 'L� 7 C" 2 < - -1 a < R1 � AA 'W • fA Cn a s � 0 0 pzox 554 PAGE487 IN WITNESS 44•WHEREOF, this declaration has been duly executed this / —day of �dP� 1987. GEORGE( STER (Owner of Lots G, H and I, Block 4, City and Townsite of Aspen) JOHN THOMAS KUEHLMAN WiLi jlx_ __" HE EN JANE KUEHLMAN (Owners of Lots E and F, Block 4, City and Townsite of Aspen) STATE OF COLORADO ) ) ss. COUNTY OF PITKIN ) S� The fore oing instrument was acknowledged before me this / day of , 1987 by George A. Wester. WITNESS my hand and official seal. 10 '' ........ 'J iy 'commission expires: �'�7A • _JJ - r ti' COLORADO ) COUNTY OF PITKIN ) C� L -L1 Notary Public yank of Monaco S. Monaco St. kwy. Denver, Colorado 80224 The forego ng instrument was acknowledged before me this day off 1987 by Helen Jane Kuehlman. WITNESS my hand and official seal. My commission expires: /a '6 f- D Notary Pub 7� \' -2- Qo. �GA':.. d�cra 0 STATE OF COLORADO ) 80N 5011 ss. COUNTY OF PITKIN ) The foregyng,instrument was acknowledged before me this day of 1987 by John Thomas Kuehlman. WITNESS my hand and official seal. My commission expires: No ary Publ i!' :.o APPROVED AS TO FORM: Paul T,�dune, Ci y Attorney JDS4D/01 -3- v:- • • Aspen City Council Regular Meetina November 11; 1L8 .j Mayor Stirling said one of the reasons for this condition was that Council did not want to have entertain a oject.changinathe Stirling said he would be willing to number of units that have to be sold. Mayor Stirling toed to Councdilect as thestaff gas possible; secondednby ge and get back Councilwoman Fallin. All in favor, motion carried. SUBDIVISION EXCEPTION - Saurel Mayor Stirling left the meeting due to a conflict" of interest. Steve Burstein, planning office, said this is a request to condominiumize a duplex located on the corner of Monarch and Sleeker. Burstein told Council when the building inspector did an inspection, he found 3 dwelling units as defined in the Code, there are some electrical corrections to be made, and some encroachments to be addressed. Burstein told Council the applicant has requested this duplex be exempted from the 6 month rental restriction based on the history of the use. Burstein told Council since the building was built, " t has been rented short term. It is felt that it is not reasonable in the change of form of ownership to make the rental restrictions a condition i of approval. Burstein said staff feels this a unique situation, and Council can exempt this frotr� the 6 month rental restriction. Bob Hughes, representing the applicant, told Council none of the conditions are unacceptable, and they ale in the process of working them out. Hughes said they will take care of the third unit. Hughes said they plan on straightening the fence out rather than asking for an encroachment. City Attorney Taddune said staff feels that the requirements of going through the full subdivision process would be redundant and would serve no public purpose, and is unnecessary to the land use policies of the city. Councilwoman Fallin moved to approve a subdivision exception for the purpose of condominiumization of the Saurel duplex subject to the conditions 1 through 6 of the planning office memorandum city November 5, 1985, including the language as outlined by attorney; seconded by Councilman Isaac. All in favor, motion carried. KU-EHLMAN LOT LINE- ADJUSTMENT Steve Burstein, planning office, this is a request to move the lot line 3 feet from the existing house. Councilman Isaac asked if this would resolve the litigation. Jon Seigle said it would; this has been in litigation for 5 years. Burstein said staff 14 i .y Aspen City Council Regular Meeting_ Novembe 11, 1985 would rather see the lot line moved 6-1/2 feet so that it will not create a non -conforming structure. Seigle told Council the Kuehlman's encroach on Wester's land, and this is the only solution they have come up with. Wester will -not agree to the additional 3-1/2 feet. Councilwoman Walls moved approval of the lot line adjustment subject to conditions 2 through 6 in the planning office memorandum November 4, 1985; seconded by Councilman Isaac. All in favor, motion carried. REQUEST TO L-EASE-CITE' STABLES City Clerk Koch told Council 2-1/2 stalls at the stables are presently being leased to Terry Harp; this is a request to lease 2 additional stalls by Morrison. There are a total of 6 stalls at the city stables. City Attorney Taddune told Council this lease should be rewritten by his office. Morrison told Council he has a surrey he would like to do tours of town with, as well as a horse drawn ski shuttle. Mayor Stirling moved to instruct the city attorney to negotiate and drawn up a lease with Mr. Morrison and return to the next Council meeting; seconded by Councilwoman Fallin. Mayor Stirling said the lease payments seem quite low. Cindy Shafer, finance director, told Council the city pays the water bills on this property and they are close to what the city receives in rent. All in favor, motion carried. RESOLUTION #29, -1985 - Commercial GMP Carry Over Steve Burstein, planning office, prepared two versions of this resolution. One carries over quota in the SCI and Commercial/lodge category. Two weeks ago, two Councilmembers felt that nothing should be carried over. Staff is willing to support not carrying any quota over. Councilwoman Walls noted Council has voted in the past to not carry any quotas over. Councilman Isaac moved to adopt Resolution #29, Series of 1985, carrying over quota in the NC/SCI zone; motion DIES for lack of a second. Mayor Stirling moved to adopt Resolution #29, Series of 1985, carrying no commercial space forward; seconded by Councilwoman Walls. 15 0 • 0 • MEMORANDUM TO: Aspen City Council THR3 : Hal Schilling, City Manag FROM: Steve Burstein, Planning Office RE: Kuehlman Lot Line Adjustment DATE: November 4, 1985 SUMMARY: The Planning Office recommends approval of the lot line adjustment subject to the conditions listed below. LOCATION: 915 W. Francis, Lot F and G, Block 4, City and Townsite of Aspen. Lots E and F, owned by Mr. Keuhlman, presently contain a single-family house, while Lots G, H and I; owned by Mr. Wester, are presently undeveloped. ZONING: R-6 APPLICANT'S REQUEST: Mr. and Mrs. John Kuehlman, owners of Lots E and F, and Mr. George H. Wester, owner of Lots G, H and I of Block 4, request a subdivision exception for the purpose of a lot line adjust- ment between Lots F and G. PREVIOUS COUNCIL ACT ION: None. BACKGROUND: A corner of the Kuehlmans' house, 915 W. Francis, encroaches on Lot G, owned by Mr. Wester. Civil Action No. 80CV99 was brought against the Kuehlmans by Mr. Wester regarding this matter. Both parties agreed that a lot line adjustment would be the most appropriate resolution of the encroachment, after which a request would be made to the Court to stipulate to a Consent Decree approving the adjustment. APPLICABLE SECTION OF CODE: Stated in Section 20-19(a)(4) of the flunicipal Code, are the conditions by which a lot line adjustment may be granted: (i) The applicant demonstrates that the purpose of the request is to correct an engineering or survey error in a recorded plat, to permit a boundary change between consenting adjacent landowners or to address specific hardship, provided that the corrected plat meets the standards of the Code at the time of the request; and (ii) The adjustment will not directly or indirectly affect the development rights or permitted density on the property by providing the opportunity to create a new lot or parcel for • • •• development or resale purposes. It may be considered sufficient proof that the application will not affect the development rights or permitted density of the property if the applicant documents that the lands in question are fully developed under existing zoning and will not change in developments status due to the adjustment; or if the applicant agrees to compete under the GMP for any development rights beyond the existing level of develop- ment on the newly created lots or parcels; and (iii) Subsequent to the adjustment, the parcels or lots will continue to conform to the underlying area and bulk requirements of the zone district. In cases of an existing non -conforming lot, the adjustment shall not increase the non -conformity of the resulting lots or parcels; and ( iv) The applicant otherwise complies with all applicable zoning and subdivision regulations of the City of Aspen. PROBLEM DISCUSSION: Referral Comments: In a memorandum from the Engineering Office, dated October 11, 1985, the following comments were made: 1. The lot line adjustment would create a non -conforming situation in which the existing house would encroach in the eastern five (5) foot side yard setback. 2. The applicants should be required to join any Improvement Districts formed in the future. 3. The plat should note the square footage of the area affected by the lot line adjustment, existing utility sources, and meter locations. PLANNING OFFICE COMMENTS: The lot line adjustment meets the criteria by which it is to be considered in Section 20-19 (a) (4) . It is a boundary change between consenting adjacent landowners for the purpose of rectifying an encroachment problem. Both Lots F and G would remain at 3,000 s.f. after the requested lot line adjustment. Development rights and permitted density on the properties would not be affected. As noted by the Engineering Office, the lot line adjustment would not accomplish making the existing house in complete conformity with required setbacks. Sufficient side yard setbacks considering the three foot (31) roof overhang, would require that the property line be six feet, six inches (616") from the Kuehlman residence. The proposal is for a property line three feet (3') away from the house. The Planning Office believes that it would be more desireable if the lot line adjustment were to bring the structure into conformity. If a structure were built on Wester Is property, sited as close to the setbacks as allowed, then the two structures would be eight feet (81) 2 • • 00 apart and roof projections would be 3-1/2 feet apart. Furthermore, the Kuehlman residence will be subject to the non -conforming structure regulations in Section 24-13.3 of the Code. Under the circumstances that the two parties cannot agree to a rectified lot line adjustment, we feel that the proposal is still beneficial in reducing non -confor- mities and merits Council approval. RECOMMENDATION: The Planning Off ice recommends approval of the Kuehlman Lot Line Adjustment subject to the conditions listed below: 1. The lot line between Lots F and G, where parallel to the existing Kuehlman structure, shall be moved 3-1/2 feet to the ea st , and other segments of the lot line shall be change so as to retain lots of 3,000 s. f . each. A new plat shall be submitted f or Planning and Engineering Office approvals. 2. Both parties shall agree to join any special improvement dis- tricts formed in the future. 3. The plat shall contain all information requested in the Engineer- ing Office memorandum of October 11, 1985 and shall meet the criteria of Section 20-15 of the Municipal Code in Final Plat submittal. 4. Any removal of trees shall be subject to Section 13-76 of the Municipal Code. 6. A Statement of Subdivision Exception shall be filed for approval of the City Attorney. SB.221 C. }- r v C 3 • • . • KLEIN, SEIGLE & KRABACHER PROFESBIONAL CORPORATION HERBERT B. KLEIN JON DAVID SE10LE 0.JOBEPH KRABACHER THOMAS C. HILL Alan Richmond Planning Department City of Aspen Aspen City Hall 130 South Galena Aspen, Colorado 81611 ATTORNEY@ AT LAW 201 NORTH MILL STREET ABPEN, COLORADO 81E11 September 12, 1985 TELEPHONE 13031 925.9700 Re: Lots F and G, Block 4, City and Townsite of Aspen Dear Alan: This firm represents John and Helen Kuehlman, who are the owners of Lots E and F, BLock 4, City and Townsite of Aspen. I have had previous communication with Paul Taddune, City Attorney, regarding a certain quiet title action brought by Mr. George Wester, who is owner of Lots G, H, and I, Block 4, City and Townsite of Aspen, against my clients regarding a lot line encroachment on the common boundary of Lots F and G. On behalf of my clients, I am requesting a lot line adjust- ment pursuant to Sections 20-19 (a) (4) and 20-19 (b) (c). The lot line adjustment sought is for purposes of solving the enroachment problem. It is my understanding, based upon my discussions with Mr. Taddune and yourself, that this matter may be taken directly to City Council for approval as an exception from the application of the provisions of Section 20 of the Aspen Municipal Code because compliance with those provisions, in connection with this application, would serve no public purpose and would be redundant and unnecessary in relation to the land use policies of the City of Aspen. Please find enclosed four copies of the amended plat and four copies of this application letter, along with a check in the amount of $680.00 to cover the application fee. It is my understanding that the application fee is in reality a retainer and that the unused portion will be returned to the applicants upon completion of this matter. It is my hope, in light of the Alan Richmond September 12, 1985 Page Two very simple request contained herein and the costs involved to date by my clients and Mr. Wester, that your office can keep its fees to a minimum. Sincerely yours, KLEIN, SEIGLE & KRABACHER, P.C. By I J n avid Seigle JDS/jgc Enclosures cc: Robert Hughes, Esquire Mr. and Mrs. Kuehlman * 0 • MEMORANDUM To: Steve Burstein, Planning Office From: Elyse Elliott, Engineering Office Date: October 11, 1985 Re: Kuehlman Lot Line Adjustment After reviewing the above application and making a site inspection, the Engineering Department has the following comments: - The lot line adjustment will create a non -conforming lot because the existing house on Lots E & F will not have a 5' side yard setback. As long as we're adjusting the lot line to rectify an existing problem, we should solve all complications. - The applicants should be required to join an Improvement District. - The plat should note the square footage of the area affected by the lot line adjustment. It should also show the existing utility sources and meter locations. *0 • • TO: FROM: RE: DATE: PENDRANDUM City Attorney City Engineer Steve Burstein, Planning Office Kuehlman Lot Line Adjustment City Case No. 0,35-85 September 18, 1985 Attached is an application submitted by Jon Seigle on behalf of John and Helen Kuehlman, requesting subdivision exemption approval for the purpose of a lot line adjustment. Mr. and Mrs. Kuehlman own Lots E and F, Block 4, City and Townsite of Aspen. They propose to purchase I.ot G, Block 4, City and Townsite of Aspen from the current Mr. Wester (represented by Bob Hughes) . Please review this application and return your referral comments to the Planning Office no later than October 16, 1985, in order for this office to have adequate time to prepare for its presentation before the City Council on October 28th. Thank you. ft go KLEIN, SEIGLE & KRABACHER PROFESSIONAL CORPORATION HERBERT S. KLEIN JON DAVID SEIGLE B.JOSEPH KRABACHER THOMAS C. HILL Allan Richmond City of Aspen Planning Office 130 South Galena Aspen, Colorado 81611 ATTORNEYS AT LAW 201 NORTH MILL STREET ASPEN, COLORADO 81611 September 20, 1985 Re: Application for Lot Line Adjustment/Lots F and G, Block 4, Aspen, Colorado. Dear Alan: TELEPHONE (303) 925-8700 Following our telephone conversation please be advised, that based upon my review of all title documents, that John Thomas Kuehlman and Helen Jane Kuehlman are the record owners of Lots E and F, Block 4, City and Townsite of Aspen, Pitkin County, Colorado. Mr. George Wester, who owns Lot G, Block 4, is represented by Robert Hughes, and he will be sending you a letter which evidences Mr. Wester's consent to lot line adjustment as well as setting forth Mr. Wester's ownership of Lot G. It is my understanding that this matter will be scheduled to go before City Council sometime in the month of October and I would appreciate that as soon as you have definitively scheduled this matter to please let me know. Sincerely yours, KLEIN, SEIGLE & KRABACHER, P.C. I1 A�n David Seigle JDS/ jgc `-- cc: John Kuehlman Bob Hughes • LAW OFFICES OATES, HUGHES & KNEZEVI PROFESSIONAL CORPORATION THIRD FLOOR. ASPEN PLAZA BUILDING 533 EAST HOPKINS AVENUE LEONARD M. OATES ASPEN. COLORADO 81611 ROBERT W. HUGHES RICHARD A. KNEZEVICH DEBORAH QUINN September 19, 1985 Mr. Alan Richman Planning Director Aspen/Pitkin Planning Office 130 S. Galena Street Aspen, CO 81611 i SEP 2 3 Wr, 4 AREA CODE 303 1 TELEPHONE 920-1700 TELECOPIER 920-1121 Re: Lots F and G, Block 4, City and Townsite of Aspen Dear Alan: We represent George A. Wester, who is the owner of Lot G, Block 4, City and Townsite of Aspen. We have been asked by Jon Seigle to confirm for you as accurate that Mr. Wester had commenced an action in trespass as a result of an encroachment upon his property by the single-family residence constructed on Lot F and owned by John Thomas and Helen Jane Kuehlman. In connection with that matter, the parties have agreed to settle the dispute by effecting a lot line adjustment in the manner that was proposed to you in Jon Seigle's letter to you dated Septem- ber 12, 1985. Should you require any further confirmation in order to complete staff review of the lot line adjustment appli- cation, please let me know. Incidentally, the matter has been unresolved for quite some time and, if there is anything that you can do to expedite the process, I would certainly appreciate that. Sincerely, OATES, HUGHES. & KNEZEVICH, P.C. By Robert W. Hughes RWH/caa cc: Jon D. Seigle, Esq. rwh3.21 ft of KLEIN, SEIGLE & KRABACIIER PROFESSIONAL CORPORATION ATTORNEYS AT LAW HERBERT S. KLEIN 201 NORTH MILL STREET JON DAVID SEIGLE ASPEN. COLORADO 51811 S. JOSEPH KRABACHER THOMAS C. HILL September 12, 1985 Alan Richmond Planning Department City of Aspen Aspen City Hall 130 South Galena Aspen, Colorado 81611 TELEPHONE 13031 925-9700 Re: Lots F and G, Block 4, City and Townsite of Aspen Dear Alan: This firm represents John and Helen Kuehlman, who are the owners of Lots E and F, Block 4, City and Townsite of Aspen. I have had previous communication with Paul Taddune, City Attorney, regarding a certain quiet title action brought by Mr. George Wester, who is owner of Lots G, H, and I, Block 4, City and Townsite of Aspen, against my clients regarding a lot line encroachment on the common boundary of Lots F and G. On behalf of my clients, I am requesting a lot line adjust- ment pursuant to Sections 20-19 (a) (4) and 20-19 (b) (c). The lot line adjustment sought is for purposes of solving the enroachment problem. It is my understanding, based upon my discussions with Mr. Taddune and yourself, that this matter may be taken directly to City Council for approval as an exception from the application of the provisions of Section 20 of the Aspen Municipal Code because compliance with those provisions, in connection with this application, would serve no public purpose and would be redundant and unnecessary in relation to the land use policies of the City of Aspen. Please find enclosed four copies of the amended plat and four copies of this application letter, along with a check in the amount of $680.00 to cover the application fee. It is my understanding that the application fee is in reality a retainer and that the unused portion will be returned to the applicants upon completion of this matter. It is my hope, in light of the Alan Richmond September 12, 1985 Page Two very simple request contained herein and the costs involved to date by my clients and Mr. Wester, that your office can keep its fees to a minimum. Sincerely yours, KLEIN, SEIGLE & KRABACHER, P.C. By J n avid Seigle JDS/jgc Enclosures cc: Robert Hughes, Esquire Mr. and Mrs. Kuehlman MRMORANDUM TO: Paul Taddune, City Attorney FROM: Alan Richman, Acting Director RE: Wester vs Kuehlman DATE: January 10, 1984 I have read the materials you sent me regarding the referenced law case. It is quite clear to me that this matter falls within the bounds of Section 20-19(a)(4), lot line adjustment provisions. These matters have been routinely handled by my office as an expedited subdivision exception, one step to Council. I strongly recommend against processing this request as a subdivision exemption because there should certainly be a plat filed along with the proposal to protect future buyers. Please refer the applicant to my office. CITY OF-ASPEN 130 qalena street aspe%� !gn,7corado 81611 303-925 -2020 MEMORANDUM DATE: January 9, 1985 TO: Planning Director FROM: City Attorney RE: Wester v. Kuehlman p IE@IEnd[EIn Annexed please find a letter from Jon Seigle dated January 2, 1985, and related materials involving a boundary adjustment with regard to Lot G, Block 4, City and Townsite of Aspen. Please review the proposed plat and lot line adjustment. Unless there are major problems, it might be appropriate to refer this matter to the City Council as a subdivision exemption under the provi- sions of Section 20-3(4) as amended. PJ T/mc Attachment cc: Jon David Seigle, Esq. Robert W. Hughes, Esq. ft N KLEIN, SEIGLE, DELMAN & KRABACHER `^ A, PROFESSIONAL CORPORATION V�1IV ATTORNEYS AT LAW 201 NORTH MILL STREET HERBERT S. KLEIN ASPEN. COLORADO 8 161 1 JON DAVID SEIGLE JAMES H. DELMAN B. JOSEPH KRABACHER January 2, 1985 THOMAS C. HILL Paul Taddune, City Attorney City of Aspen 130 South Galena Street Aspen, CO 81611 Re: Wester v. Kuehlman Civil Action No. 80 CV 99 Dear Paul: REM TELEPHONE (303) 925-8700 This firm represents the defendants John Thomas Kuehlman and Helen Jane Kuehlman, and Bob Hughes, of Oates, Hughes & Knezevich, represents the plaintiff George A. Wester in the above -referenced action filed in the District Court of Pitkin County. As you will recall, Bob and I met with you to discuss this case in the spring of 1984. Essentially, the case revolves around the fact that the Kuehlman's house, which they purchased in 1963, encroaches slightly on the property owned by Mr. Wester (being Lot G, Block 4, City and Townsite of Aspen). The parties to the litigation have agreed that the most appropriate resolution of the encroachment is to do a lot line adjustment and then request the Court to stipulate to a Consent Decree approving the adjustment. I am enclosing for your review the following documents: 1. Stipulation for Entry of Consent Decree; 2. Affidavit; 3. Proposed Form of Order; 4. Plat and Title Lot Line Adjustment. We would appreciate the City's consent to the Stipulation. Given the posture of the litigation and the simplicity of the solution, I do not see that the City of Aspen would have any objection to consenting to the Stipulation. Although it is not entirely clear from reading the City Code whether this matter requires a hearing before Planning and Zoning Commission, it is my understanding based upon my meeting with you, that you should be able to resolve this matter at council level. • Paul Taddune January 2, 1984 Page Two I would appreciate your review of the enclosed documentation and upon your review, communicating with me regarding any questions you might have and also a timetable for obtaining the City's consent. Sincerely yours, KLEIN, SEIGLE, DELMAN & KRABACHER, P.C. By 4o—David Seigle JDS/dg Enclosures cc: Mr. & Mrs. Kuehlman Robert Hughes DISTRICT COURT, COUNTY OF PITKIN, STATE OF C OLPAD0 Civil Action No. 80 CV 99 AFFIDAVIT GEORGE A. WESTER, Plaintiff, v.and JANE , ASSOCIATION, aH JOHN THOMAS KUEHLtColorado corporation, �1 'Ate ASPEN SAVINGS AND LOAN Defendants. The undersigned being duly sworn states as follows • Block 4, StateCity and 1, That they are the owners , of tof Colorado (hereinafter referred Townsite of Aspen, County of to as "Real Property") • tember 15 , 1963. 2, That they purchased the Real Property on Sep ert 3. That at the time of their purchase of the property, the pro P y was improved with a single-family residence. 4, That the undersigned have continued uisitioside in the residence located on the real property since the date of acq encroach or located on the real property 5. That the improvements County of Pitkin, State of Block 4, City and Townsite of Aspen, the plat attached hereto as Ex Colorado as inhibit B . Lot G, dicated on had no knowledge of the encroachment until 6. That the undersigned 1974. FURTHER the affiant sayeth not. 10 n omas ue man e en ane ue man *0 • • / IIDISTRICT COURT, COUNTY OF PITKIN, STATE OF COLORADO Civil Action No. BOCV99 STIPULATION FOR ENTRY OF CONSENT DECREE GEORGE A. WESTER, Plaintiff, V. JOHN THOMAS KUEHLMAN, HELEN JANE KUEHLM.AN, and ASPEN SAVINGS AND LOAN ASSOCIATION, a Colorado corporation, Defendants. COME NOW the Plaintiff by and through his attorneys GOLDSMITH and LUBY, a Professional Corporation, and Defendants John Thomas Kuehlman, Helen Jane Kuehlman and Aspen Savings and Loan Association, by and through their attorneys, SACHS, KLEIN & SEIGLE, P.C., and hereby stipulate as follows: 1. Plaintiff's complaint alleges that the certain improvements located on Defendants Kuehlmans' real property described as Lot F, Block 4, City and Townsite of Aspen, Pitkin County, Colorado (hereinafter referred to as "Lot F") encroaches on Plaintiff's real property, which is described as Lot G, Block 4, City and Townsite of Aspen, Pitkin County, Colorado (herein- after referred to as "Lot G"). 2. Defendants Kuehlmans admit that the improvements encroach as alleged in the complaint. 3. The parties desire to dispose off the claim set forth in the complaint by requesting the Court to enter a Consent Decree which would provide that the common lot line between Lot F and Lot G be adjusted as set forth on the replat of Lot F and Lot G which is attached hereto as Exhibit "A" and incorporated herein by reference. 4. Each party shall pay his or her own costs, including attorneys' fees, incurred in the prosecution of this matter except that Defendants Kuehlmans agree to reimburse Plaintiff the sum of $1,500.00 for attorneys' fees incurred in these proceedings and further provided that Defendants Kuehlmans shall pay all surveying costs and filing fees incurred in • • • connection with the preparation and filing of the replat of Lots F and G, and all attorneys' fees incurred by Plaintiff from date hereof in connection with review of this documentation and obtaining approval of the City of Aspen to this Consent Decree, provided, however-, that in the event a Consent Decree is not granted by the Court for any reason, Defendants Kuehlmans shall no longer have responsibility for reimbursement to Plaintiff for future fees incurred, except as the Court might otherwise order and allow. 5. The replat of Lots F and G is for purposes of equitably resolving the problems created by the encroachment of the improvements on Lot G and not for the purposes of evading the subdivision regulations of the City of Aspen. 6. The City of Aspen has been informed of these proceedings and the request for the Entry of a Consent Decree, has no objection thereto, and by its signature below confirms that, as adjusted, Lots G, H and I taken together meet the area and bulk requirements of thCdateehereoff for thethe yof Asen constructionnofla pal Code in effect one duplex thereon. WHEREFORE, the parties request that the Court enter a Consent Decree which orders a replat of Lot F and Lot G as set forth in Exhibit "A" and orders the parties to bear their own costs, including attorneys' fees, subject to the provisions of paragraph 4 above, and for such other and further relief as the Court deems proper. GOLDSMITH and LUBY, SACHS, KLEIN & SEIGLE, Professional Corporation Professional Corporation By Paul F. Goldsmith,1016 Attorney for Plaintiff George A. Wester 1151 Bannock Street Denver, CO 80204 (303)893-0234 APPROVED: ATTEST: Kathryn Koch, City Clerk By Jon David Seigle, #6620 Attorney for Defendants John Thomas Kuehlman, Helen Jane Kuehlman, and Aspen Savings & Loan Assoc. 201 N. Mill St., Suite 201 Aspen, CO 81611 (303)925-8700 CITY OF ASPEN Paul Taddune, City Attorney -2- /, DISTRICT COURT, COUNTY OF PITKIN, STATE OF COLORADO Civil Action No. 80 CV 99 GEORGE A. WESTER, Plaintiff, V. JOHN THOMAS KUEHLMAN, HELEN JANE KUEHLMAN, and ASPEN SAVINGS AND LOAN ASSOCIATION, a Colorado corporation, Defendants. This matter comes on for consideration of the Stipulation for Entry of Consent Decree and the Court being fully advised in the premises finds as follows: 1. That Plaintiff is the owner of Lot G, Block 4, City and Townsite of Aspen, Pitkin County, Colorado (hereinafter referred to as "Lot G") . 2. That Defendants John Thomas Kuehlman and Helen Jane Kuehlman ("Kuehlmans") are the record owners of the property described as Lot F, Block 4, City and Townsite of Aspen, Pitkin County, Colorado (hereinafter referred to as "Lot F") and have been so since 1963. 3. That at the time of the Kuehlmans' acquisition of the property, it was improved with a single-family residence which remains intact as of the date of this Order. 4. Th7,.t the improvements located on Lot F encroaches on Lot G. 5. That the parties have stipulated to a replat of the common property line between Lot F and Lot G for purposes of resolving the encroachment and such replat is not done for purposes inconsistent with the subdivision regulations of the City of Aspen. 6. That the City of Aspen by and through its counsel, Paul Taddune, has consented to the entry of this Order. THE COURT HEREBY ORDERS: 1. That the common lot line between Lot F and Lot G be hereby replatted as set forth in Exhibit A attached hereto which is titled replat of Lots F and G, City and Townsite of Aspen; 'a a FRANCIS STREET W� `,,C \%-#- ALLEY R_" i E 4'. t "v FNGTNFERS AnnROVAL .This Plat'was approved by the. Citv Fnaineer, City of Aspen, this day of 19 City Fngineer ASPEN CIT`.' COUNCIL APPROVP- This Plat was approved by the Aspen Cite Council this day of 19—and sianeed this c?av of , 19 yor ATTEST: C�-tv Clerk RECORDING CERTIFICATE I hereby certifv that: this Plat was accepted for filing in my off4ce at o'clock_.M. on the day of �__ and was duly filed. in Plat Rook _^ at Paae PITKIN COT.?NT' CLERK & RECORDER Clerk John Thomas xuelhman and Helen Jane Kuelh_m.,an beina the owners of Lots F and F Block 4 and George A. Wester heina the owner of Lots G, H, and I Block 4 Aspen, Colorado have by these present laid out and replatted the same into Lots F and F-1 and into Lots G-1, H and I as shown on this Plat. Join Thomas Kuelhman Helen Jane Kuel man George A. Wester STATE OF COLORADO) ) s s COUNT" OF PITKIN) The foreaoina certificate was acknowledged before me this day of 19 by John Thomas Kue�iman and Helen Jane Kuelhman. My Commission expires Witness my hand and official seal: Notar7y--pul5lic The foreaoina certificate was acknowledged before me this day of , 19�1 by Georae A. Wester. My Commission expires: Witness my hand and ofT1_(5_1­a1 seams Notary Public SURVEYOR'S CERTIFICATE I, HAROLD Ta, JOHNSON, registered surveyor do hereby certify that this Plat was prepared under my supervision and the the out- side boundaries, lots, roads and other features are correctly shown hereon, that the same are based on actual field surveys Performed on the described property under my direct control and supervision all in accordance with generally accepted survevina or.actices and Section 38-51, C.R.S. (1973). IN WITNESS T,TPFREOF, I have set my hand and seal on this day of sf.... fir 19 P� Harold W. Joh on - L.S. 9018 LOT LINE ADJUSTMENT LOTS F & G. BLOCK 4 ASPEN, COLORADO HAROLD W. JOHNSON REGISTERED LAND SURVEYOR BOX 249 WOODY CREEK, COLORADO 81656 TEL. (303) 923-3496