2the applicable comprehensive plan and land development regulations, and longstanding uses of adjacent properties, including a prison, a future county jail site and a landfill, andnotwithstanding that the property has had the necessary entitlements to use the property as acorrectional facility since its purchase.2.
CCA and CCA-LLC have at all times reasonably relied upon the City’sstatements and conduct expressing its intent to provide water and wastewater service to theproperty. Now, at the eleventh hour, as a result of the City’s complete reversal, CCA stands tolose its business relationship with ICE or be forced to obtain water and wastewater servicealternative sources, thereby risking the viability of the ICE project.
PARTIES, JURISDICTION AND VENUE
Plaintiff CCA is a company that designs, builds, manages and operatescorrectional facilities and detention centers. CCA is a Maryland Corporation, with its corporateheadquarters and principal place of business located at 10 Burton Hills Boulevard, Nashville,Tennessee 37215.4.
Plaintiff, CCA-LLC is a wholly owned subsidiary of CCA. CCA-LLC ownsproperty in Broward County, Florida comprised of three parcels designated as Folio Nos.513902040490, 513902040500 and 513902040510 (the “
” ), as well as other locationsthroughout the United States. CCA-LLC’s principal place of business is located at 10 BurtonHills Boulevard, Nashville, Tennessee 37215.5.
Defendant, City is a Florida municipal corporation. The City is located inBroward County, Florida. The City is governed by a body politic known as the CityCommission.
Case 0:12-cv-60427-XXXX Document 1 Entered on FLSD Docket 03/07/2012 Page 2 of 36