CONSENT DECREE OF THE
BOARD OF COMMISSIONERS
OF THE CITY OF COVINGTON, KENTUCKY

Pursuant to Covington Code of Ordinances 10.21, a hearing was held on

October 23, 2014 before the Board of Commissioners of the City of Covington, Kentucky upon
charges ?led by the City Manager against Jason R. Mardis (d/b/a Colonial Motel) (1515
Madison Avenue, Covington, Kentucky) related to his/its Business Regulatory License. The City
of Covington, by and through its City Manager and counsel, and Colonial Motel, by and through
its owner Jason R. Mardis and counsel, reported to the Board that they are prepared to enter into
the following Consent Degree, which the Board hereby adopts:

1.

Colonial Motel, by and through its owner, Jason Mardis, hereby enters into this Consent
Decree with the City of Covington, whereby it agrees that there existed on its premises
certain conduct that constituted a public nuisance in violation of Covington Code of
Ordinances The Consent Decree is a ?nal, non-appealable order.

Jason Mardis, owner of Colonial Motel, will immediately list the premises for sale to the
public at or below $350,000.00. Sale will include the condition that the premises not be
used as a hotel, motel, bed and breakfast, or temporary or extended stay facility (similar
use to its past, most recent use).

. On November 30, 2015, if the Colonial Motel has not been sold pursuant to this

Agreement, the Business Regulatory License issued to Jason R. Mardis (d/b/a Colonial
Motel) shall be immediately revoked without further hearing. The revocation shall be a
?nal, non-appealable order. If said license is revoked for any reason, the City shall not
implement the Abandoned Urban Property Tax rate as a result of the property being
vacant as long as it is actively listed for sale. Further, the Colonial Motel shall not be
leased, subleased, or otherwise assigned to any other party or allowed to operate after
November 30, 2015 as a hotel, motel, bed and breakfast, or temporary or extended stay
facility.

Any ?nal determination of a violation of Covington Code of Ordinances 92.10
(Criminal Activity as a Public Nuisance) related to the owner?s use, operation, or
management of the Colonial Motel will result in revocation of the Colonial Motel?s
Business Regulatory License. This provision shall not apply if the owner has abated the
nuisance by timely removing the offending party from the premises.

The City shall have a right of ?rst refusal on any sale of the Colonial Motel made with a
good faith offer, said right of ?rst refusal to be exercised no less than 7 days after

presentation of offer to the City and shall only exist for the ?rst purchase contract offered
to owner.

6. Colonial Motel shall comply with all City of Covington ordinances, including the
Covington Nuisance Code.

7. Colonial Motel shall waive any and all known claims against the City, and the City
waives any and all known past and present claims against the Jason R. Mardis (dfbfa
Colonial Motel).

8. Any violation occurring before the date of this Consent Decree shall not form the basis of
any ?lture administrative charge or proceeding against the Colonial Motel by the City of
Covington.

9. The parties hereto understand and agree that the statements made herein and the
execution of the Agreement shall NOT be construed as an admission of wrongdoing or
liability of any other nature on the part of Jason Mardis and/or the Colonial Motel, or any
of their respective of?cers, agents, servants, shareholders or employees, by whom all
such alleged wrongdoing is expressly denied.

SO ORDERED this 23rd day of October, 2014.

 

7/ 

Commissioner Chuc Eilerman

 

Commissionner Steve Frank

 

Commissioner Mildre Rai 5

e/JM/x .

Commissionner Michelle Williams

Hav seen and agree:

 

ity Manager



Bryce C. Rhoades, Esq.
Asst. Cit licitor

 

 

Ed Lante 
Attorney for Jason Mardis and Colonial Motel