Agenda 02/12/2013 Item #16K22/12/2013 16.K.2.
EXECUTIVE SUMMARY
Recommendation to approve and authorize the Chairwoman to execute a mediated
Settlement Agreement and Release prior to trial in the lawsuit entitled Miguel Rojas and
Luz Escudero v Collier County, and Collier County, filed in the Twentieth Judicial Circuit
in and for Collier County, Florida (Case No. 11- 2901 -CA) for the sum of $25,000.
OBJECTIVE: Recommendation to approve the mediation settlement in the lawsuit filed by
Miguel Rojas and Luz Escudero, against the Board of County Commissioners, for the sum of
$25,000.00 and authorize the Chairwoman to execute the Settlement Agreement and Release.
CONSIDERATIONS: On May 8, 2010, a Collier County vehicle struck the plaintiffs vehicle
at the intersection of Weber Boulevard and Golden Gate Boulevard. Plaintiffs were transported
to the hospital. Plaintiff, Miguel Rojas ultimately underwent physical therapy and received a 6%
whole person impairment based on or cervical/thoracic /lumbar strains and injuries to the
shoulders, right wrist, and ankle. His medical bills total $1.6,409.40. The second Plaintiff, Luz
Escudero, also underwent physical therapy and was given a 6% whole person impairment based
on cervical/thoracic/lumbar sprain/strain and injuries to her elbow, hand and knee. Her medical
bills total $14,725.42
Liability for the accident is clear against the County and the central issue for the jury
determination would be the amount of damages. Through trial, the County would need to retain
a medical expert, conduct additional discovery depositions, order transcripts, and depose the
Plaintiffs' treating physicians. Estimated cost would be approximately $15,000.00. At trial,
Plaintiffs' attorney would blackboard a total of approximately $31,000.00 in medical bills to the
jury. The County, through the Risk Management Department and County Attorney's Office,
agreed to settle this case at mediation for a total sum of $25,000.00, contingent on the Board of
County Commissioners approval of the same.
FISCAL IMPACT: Funds are budgeted and available in Fund 516, Property & Casualty
Insurance Fund and the total impact will be $25,000.00.
GROWTH MANAGEMENT IMPACT• There is no Growth Management Impact associated
with this Executive Summary.
LEGAL CONSIDERATIONS: The County Attorney's Office has reviewed this settlement
with the Risk Management Department and recommends that the Board of County
Commissioners approve this Settlement Agreement. This settlement is based on the exposure to
the County and the costs associated with taking this case to trial. This item is legally sufficient
for Board action and requires a majority vote for approval. — KLN
RECOMMENDATION: For the Board of County Commissioners to accept the mediation
settlement in the lawsuit filed against the Board of County Commissioners by Miguel Rojas and
Luz Escudero in the Twentieth Judicial Circuit Court for the total sum of $25,000.00 and
authorize the Chairwoman to execute the Settlement Agreement and Release.
Prepared by: Kevin L. Noell, Assistant County Attorney
11- 2901- ca/145
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2/12/2013 16.K.2.
COLLIER COUNTY
Board of County Commissioners
Item Number: 16.16.K.16.K.2.
Item Summary: Recommendation to approve and authorize the Chairwoman to execute a
mediated Settlement Agreement and Release prior to trial in the lawsuit entitled Miguel Rojas
and Luz Escudero v. Collier County, and Collier County, filed in the Twentieth Judicial Circuit in
and for Collier County, Florida (Case No. 11- 2901 -CA) for the sum of $25,000.
Meeting Date: 2/12/2013
Prepared By
Name: CrotteauKathynell
Title: Legal Secretary,County Attorney
1/31/2013 10:55:22 AM
Approved By
Name: WalkerJeff
Title: Director - Risk Management,Risk Management
Date: 1/31/2013 11:04:18 AM
Name: NoellKevin
Date: 1/31/2013 11:30:14 AM
Name: GreenwaldRandy
Title: Management/Budget Analyst,Office of Management & B
Date: 1/31/2013 3:50:54 PM
Name: KlatzkowJeff
Title: County Attorney
Date: 2/1/2013 10:27:09 AM
Name: OchsLeo
Title: County Manager
Date: 2/3/2013 12:14:46 PM
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SETTLEMENT AGREEMENT AND MUTUAL RELEASE
THIS SETTLEMENT AGREEMENT AND MUTUAL RELEASE (hereinafter
referred to as the "Agreement and Release ") is entered into and made on this
day of February, 2013 by and between Luz Escudero, (hereinafter referred to as
"Plaintiff ") and Board of County Commissioners for Collier County (hereinafter referred
to as the "County ").
WITNESSETH:
WHEREAS, Plaintiff filed a lawsuit against the County in the Circuit Court for
the Twentieth Judicial Circuit in and for Collier County, Florida, styled Miguel Rojas and
Luz Escu+dero v. Collier County Board of Commissioners, a political subdivision of the
State of Florida, Case No. 11- 2901 -CA (hereinafter referred to as the "Lawsuit"); and
WHEREAS, Plaintiff and the County, without either party admitting any liability
or fault, desire to settle the Lawsuit and any and all disputes that arise from, relate or
refer in any way, whether directly or indirectly, known or unknown, to the incidents
described or allegations made in the Complaint filed in the Lawsuit; and,
WHEREAS, Plaintiff and the County desire to reduce their settlement to a
writing so that it shall be binding upon them as well as their respective owners,
principals, elected officials, officers, employees, ex- employees, agents, attorneys,
representatives, insurers, spouses, successors, assigns, heirs and affiliates.
WHEREAS, Plaintiff and Plaintiff's attorney agree and covenant to fully comply
with all applicable Medicare laws, liens, and Set- Asides, specifically including Section
42 USC § 1395y.
I
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NOW, THEREFORE, in consideration of the mutual covenants, promises and
consideration set forth in this Agreement and Release, and with the intent to be legally
bound, Plaintiff and the County agree as follows:
1. Plaintiff and the County adopt and incorporate the foregoing recitals,
sometimes referred to as 'Whereas Clauses", by reference into this Agreement and
Release.
2. In consideration of the resolution of all disputes or claims arising from or
referring or relating in any way, whether directly or indirectly, to the Lawsuit, and for and
in consideration of the sum of Twelve Thousand Five Hundred Dollars and 00/100
($12,500.00) and other valuable consideration, the receipt and adequacy of which is
hereby acknowledged by Plaintiff, Plaintiff agrees to dismiss the Lawsuit with prejudice.
3. In consideration of the resolution of the Lawsuit, and for other good and
valuable consideration, the receipt and adequacy of which is hereby acknowledged,
Plaintiff, on behalf of herself, her attorneys, agents, representatives, insurers, heirs,
successors and assigns, hereby expressly releases and forever discharges the County,
as well as its elected officials, officers, employees, ex-employees, agents, attorneys,
representatives, successors, assigns, insurers and affiliates from any and all claims,
demands, causes of actions, damages, costs, attorney's fees, expenses and obligations
of any kind or nature whatsoever that she has asserted or could have asserted in the
Lawsuit or that arise from or relate or refer in any way, whether directly or indirectly, to
the Lawsuit or any incident, event or allegation referred to or made in the Complaint in
the Lawsuit.
2
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4. Notwithstanding anything that may be to the contrary in Paragraph 3 of
this Agreement and Release, Plaintiff and the County agree that either of them (as well
as any other persons or entities intended to be bound) shall, in the event of any breach,
retain the right to enforce the terms and conditions of this Agreement and Release.
5. Plaintiff and Plaintiffs attorney agree and covenant to fully comply with all
applicable Medicare laws, liens, and Set-Asides, specifically including Section 42 USC
§ 1395y.
6. Plaintiff and the County acknowledge and agree that this Agreement and
Release is intended to and shall be binding upon their respective owners, principals,
officials, officers, employees, ex-employees, agents, attorneys, representatives,
insurers, successors, assigns, spouses, heirs, and affiliates.
7. Plaintiff and the County recognize and acknowledge that this Agreement
and Release memorializes and states.a settlement of disputed claims and nothing in
this Agreement and Release shall be construed to be an admission of any kind, whether
of fault, liability, or of a particular policy or procedure, on the part of either Plaintiff or the
County.
8. Plaintiff and the County acknowledge and agree that this Agreement and
Release is the product of mutual negotiation and no doubtful or ambiguous language or
provision in this Agreement and Release is to be construed against any party based
upon a claim that the party drafted the ambiguous provision or language or that the
party was intended to be benefited by the ambiguous provision or language.
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9. This Agreement and Release may be amended only by a written
instrument specifically referring to this Agreement and Release and executed with the
same formalities as this Agreement and Release.
10. In the event of an alleged breach of this Agreement and Release, Plaintiff
and the County agree that all underlying causes of action or claims of Plaintiff have
been extinguished by this Agreement and Release and that the sole remedy for breach
of this Agreement and Release shall be for specific performance of its terms and
conditions or any damages arising from the breach. In this regard, Plaintiff and the
County further agree that the sole venue for any such action shall be in the Twentieth
Judicial Circuit in and for Collier County, Florida in Naples, Florida.
11. This Agreement and Release shall be governed by the laws of the State of
__`1 Florida.
12. Plaintiff and Plaintiffs attorney shall be solely responsible for any
Medicare lien, other liens, or Medicare Set-Asides.
[Signature page to follow.]
4
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IN WITNESS WHEREOF, Plaintiff, and the County have signed and sealed
this Agreement and Release as set forth below.
Date:
ATTEST:
DWIGHT E. BROCK, Clerk
Deputy Clerk
Approved as to form and
legal sufficiency:
Kevin L. oell
,A
Assistant County Attorney
STATE OF
COUNTY OF
BOARD OF COUNTY COMMISSIONERS
OF COLLIER COUNTY, FLORIDA
la
-0
Georgia A. Hiller, Esq., Chairwoman
LUZ ESCUDERO, Plaintiff
Jason R. Leonard, Esq.
Attorney for Plaintiff
THIS SETTLEMENT AGREEMENT AND RELEASE BETWEEN PLAINTIFF AND
COLLIER COUNTY, FLORIDA WAS SWORN TO and subscribed by LUZ ESCUDERO,
before me on this - day of 2013.
Signature of Notary Public
Commissioned Name of Notary Public
(Please print, type or stamp)
My Commission expires:
12-2901-CA1147
Personally Known
or
Produced Identification
Type of Identification Produced
5
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ADDENDUM TO SETTLEMENT
AGREEMENT AND GENERAL RELEASE
Representations With Regard to Medicare's Interests
Releasor hereby warrants and represents that I presently am not, nor have ever been enrolled in
Medicare Part A or Part B. Further, I have no claim for Social Security Disability benefits nor am I
appealing or re-filing for Social Security Disability benefits.
Medicare's Interests
In reaching agreement on the terms of this Release, the parties acknowledge Releasor's possible
entitlement to Social Security disability benefits pursuant to 42 U.S.C. § 423, and receipt of Medicare
or Medicaid benefits under 42 U.S.0 § 1395y, as well as the entitlement of the Centers for Medicare
and Medicaid Services ("CMS") to subrogation and intervention, pursuant to 42 U.S.C. § 1395y(b) (2)
to recover any overpayment made by CMS. The parties to this Release agree that this Release is not
intended to shift to CMS the responsibility for payment of medical expenses for the treatment of
injury related conditions. The parties agree that this settlement is intended to provide Releasor a
lump sum and/or future periodic payment which will foreclose Releasee's responsibility for future
payment of all injury related medical expenses.
Non-reimbursable Expenses (where there is an MSA or other future medical expense
consideration)
The parties to this Release understand that many common medical expenses are not payable or
reimbursable under the Medicare program. These medical expenses, not covered by Medicare but
necessary in the ongoing treatment of the Releasor's injury, and without an admission of liability on
the part of the Releosee, have been taken into consideration in the calculation and settlement of
Releasor's future medical expenses. Funds for these non-Medicare covered medical expenses have
been included in the lump sum settlement amount and shall not be paid from any Medicare
allocation amount.
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Senefit Eligibility
Releasor acknowledges that any decision regarding entitlement to Social Security benefits or
Medicare or Medicaid benefits, including the amount and duration of payments and offset
reimbursement for prior payments is exclusively within the jurisdiction of the Social Security
Administration, the United States Government, and the U.S. Federal Courts, and is determined by
Federal law and regulations. As such, the United States Government is not bound by any of the
terms of this Release.
Future Benefits
Releasor has been apprised of his /her right to seek assistance from legal counsel of his /her choosing
or directly from the Social Security Administration or other government agencies regarding the
impact this Release may have on Releasors current or future entitlement to Social Security or other
governmental benefits. Releasor acknowledges that acceptance of these settlement funds may
affect Releasor's rights to other governmental benefits, insurance benefits, disability benefits, or
pension benefits. Notwithstanding this possibility, Releasor desires to enter into this Release
agreement to settle his/her injury claim according to the terms set forth in this Release.
Medicare Recovery Action
Releasor agrees to hold harmless, indemnify and defend Releasee from any cause of action,
including, but not limited to, an action by CMS to recover or recoup Medicare benefits or loss of
Medicare benefits, if CMS determines that the money set-aside has been spent inappropriately or
for any recovery sought by Medicare, including past, present, and future and/or conditional
payments. Releasor agrees not to use designated Medicare allocation funds to pay claims for
conditional payments that may have been made by Medicare.
380652.1
1)
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Complete Understanding
Releasor hereby declares that the terms of this Release have been completely read and are fully
understood and voluntarily accepted for the purpose of making a full and final settlement of any
and all claims, disputed or otherwise, on account of injuries and/or damages related to the Claims
set forth herein, and for the express purpose of precluding forever any further additional claims
against the Release arising out of the aforesaid incident, accident or occurrence.
As to the releaser only:
Releasor Name
Luz Escudero
Releasor Address
STATE OF
COUNTY OF
r.T
THIS ADDENDUM TO SETTLEMENT AGREEMENT AND MUTUAL RELEASE BETWEEN PLAINTIFF AND COLLIER
COUNTY, FLORIDA WAS SWORN TO and subscribed by LUZ ESCUDERO, before me on this - day
of 2013.
Signature of Notary Public
Commissioned Name of Notary Public
(Please print, type or stamp)
My Commission expires:
380652.1
Personally Known
or
Produced Identification
Type of identification Produced
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As to the releasee only:
BOARD OF COUNTY COMMISSIONERS
OF COLLIER COUNTY, FLORIDA
Releasee Date
Georgia A. Hiller, Esq., Chairwoman
Releasee Address
ATTEST:
DWIGHT E. BROCK, Clerk
Deputy Clerk
Approved as to form and
legal sufficiency:
KEVIN L. NOELL
Assistant County Attorney
12-0924-CA
380652.1
4
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2/12/2013 16.K.2.
SETTLEMENT AGREEMENT AND MUTUAL RELEASE
THIS SETTLEMENT AGREEMENT AND MUTUAL RELEASE (hereinafter
referred to as the "Agreement and Release") is entered into and made on this
day of February, 2013 by and between Miguel Rojas, (hereinafter referred to as
"Plaintiff") and Board of County Commissioners for Collier County (hereinafter referred
to as the "County").
W I T N E S S E T H:
WHEREAS, Plaintiff filed a lawsuit against the County in the Circuit Court for
the Twentieth Judicial Circuit in and for Collier County, Florida, styled Miguel Rojas and
Luz Escudero v. Collier County Board of Commissioners, a political subdivision of the
State of Florida, Case No. 11- 290'1 -CA (hereinafter referred to as the "Lawsuit"); and
WHEREAS, Plaintiff and the County, without either party admitting any liability
or fault, desire to settle the Lawsuit and any and all disputes that arise from, relate or
refer in any way, whether directly or indirectly, known or unknown, to the incidents
described or allegations made in the Complaint filed in the Lawsuit; and,
WHEREAS, Plaintiff and the County desire to reduce their settlement to a
writing so that it shall be binding upon them as well as their respective owners,
principals, elected officials, officers, employees, ex-employees, agents, attorneys,
representatives, insurers, spouses, successors, assigns, heirs and affiliates,
WHEREAS, Plaintiff and Plaintiffs attorney agree and covenant to fully comply
with all applicable Medicare laws, liens, and Set-Asides, specifically including Section
42 USC § 1395y.
I -
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2/12/2013 16.K.2.
NOW, THEREFORE, in consideration of the mutual covenants, promises and
consideration set forth in this Agreement and Release, and with the intent to be legally
bound, Plaintiff and the County agree as follows:
1. Plaintiff and the County adapt and incorporate the foregoing recitals,
sometimes referred to as 'Whereas Clauses ", by reference into this Agreement and
Release.
2. In consideration of the resolution of all disputes or claims arising from or
referring or relating in any way, whether directly or indirectly, to the Lawsuit, and for and
in consideration of the sum of Twelve Thousand Five Hundred Dollars and 00/100
($12,500.00) and other valuable consideration, the receipt and adequacy of which is
hereby acknowledged by Plaintiff, Plaintiff agrees to dismiss the Lawsuit with prejudice.
3. In consideration of the resolution of the Lawsuit, and for other good and
valuable consideration, the receipt and adequacy of which is hereby acknowledged,
Plaintiff, on behalf of himself, his attorneys, agents, representatives, insurers, heirs,
successors and assigns, hereby expressly releases and forever discharges the County,
as well as its elected officials, officers, employees, ex- employees, agents, attorneys,
representatives, successors, assigns, insurers and affiliates from any and all claims,
demands, causes of actions, damages, costs, attorney's fees, expenses and obligations
of any kind or nature whatsoever that he has asserted or could have asserted in the
Lawsuit or that arise from or relate or refer in any way, whether directly or indirectly, to
the Lawsuit or any incident, event or allegation referred to or made in the Complaint in
the Lawsuit.
2
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101-1.1 4. Notwithstanding anything that may be to the contrary in Paragraph 3 of
this Agreement and Release, Plaintiff and the County agree that either of them (as well
as any other persons or entities intended to be bound) shall, in the event of any breach,
retain the right to enforce the terms and conditions of this Agreement and Release.
5. Plaintiff and Plaintiffs attorney agree and covenant to fully comply with all
applicable Medicare laws, liens, and Set-Asides, specifically including Section 42 USC
§ 1395y.
6. Plaintiff and the County acknowledge and agree that this Agreement and
Release is intended to and shall be binding upon their respective owners, principals,
officials, officers, employees, ex-employees, agents, attorneys, representatives,
insurers, successors, assigns, spouses, heirs, and affiliates.
7. Plaintiff and the County recognize and acknowledge that this Agreement
and Release memorializes and states a settlement of disputed claims and nothing in
this Agreement and Release shall be construed to be an admission of any kind, whether
of fault, liability, or of a particular policy or procedure, on the part of either Plaintiff or the
County.
8. Plaintiff and the County acknowledge and agree that this Agreement and
Release is the product of mutual negotiation and no doubtful or ambiguous language or
provision in this Agreement and Release is to be construed against any party based
upon a claim that the party drafted the ambiguous provision or language or that the
party was intended to be benefited by the ambiguous provision or language.
3
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9. This Agreement and Release may be amended only by a written
instrument specifically referring to this Agreement and Release and executed with the
same formalities as this Agreement and Release.
10. In the event of an alleged breach of this Agreement and Release, Plaintiff
and the County agree that all underlying causes of action or claims of Plaintiff have
been extinguished by this Agreement and Release and that the sole remedy for breach
of this Agreement and Release shall be for specific performance of its terms and
conditions or any damages arising from the breach. In this regard, Plaintiff and the
County further agree that the sole venue for any such action shall be in the Twentieth
Judicial Circuit in and for Collier County, Florida in Naples, Florida.
11. This Agreement and Release shall be governed by the laws of the State of
Florida. 110—.1
12. Plaintiff and Plaintiff's attorney shall be solely responsible for any
Medicare lien, other liens, or Medicare Set- Asides.
[Signature page to follow.]
4
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IN WITNESS WHEREOF, Plaintiff, and the County have signed and sealed
this Agreement and Release as set forth below.
Date:
ATTEST:
DWIGHT E. BROCK, Clerk
Deputy Clerk
Approved as to form and
legal sufficiency:
/4'
—
4 ° X
Kevin L. Noell
Assistant County Attorney
STATE OF
BOARD OF COUNTY COMMISSIONERS
OF COLLIER COUNTY, FLORIDA
0
0
M
Georgia A. Hiller, Esq., Chairwoman
MIGUEL ROJAS, Plaintiff
Jason R. Leonard, Esq.
Attorney for Plaintiff
COUNTY OF
THIS SETTLEMENT AGREEMENT AND RELEASE BETWEEN PLAINTIFF AND
COLLIER COUNTY, FLORIDA WAS SWORN TO and subscribed by MIGUEL ROJAS,
before me on this - day of 2013.
Signature of Notary Public
Commissioned Name of Notary Public
(Please print, type or stamp)
My Commission expires:
12-2901-CA/146
Personally Known
or
Produced Identification
Type of Identification Produced
5
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ADDENDUM TO SETTLEMENT
AGREEMENT AND GENERAL RELEASE
Representations With Regard to Medicare's interests
Releosor hereby warrants and represents that I presently am not, nor have ever been enrolled in
Medicare Part A or Part B. Further, I have no claim for Social Security Disability benefits nor am I
appealing or re-filing for Social Security Disability benefits.
Medicare's Interests
in reaching agreement on the terms of this Release, the parties acknowledge Releasor's possible
entitlement to Social Security disability benefits pursuant to 42 U.S.C. § 423, and receipt of Medicare
or Medicaid benefits under 42 U.S.0 § 1395y, as well as the entitlement of the Centers for Medicare
and Medicaid Services ("CMS") to subrogation and intervention, pursuant to 42 U.S.C, § 1395y(b) (2)
to recover any overpayment mode by CMS. The parties to this Release agree that this Release is not
intended to shift to CMS the responsibility for payment of medical expenses for the treatment of
injury related conditions. The parties agree that this settlement is intended to provide Releasor a
lump sum and/or future periodic payment which will foreclose Releosee's responsibility for future
payment of all injury related medical expenses.
Non - reimbursable Expenses (where there is on MSA or other future medical expense
consideration)
The parties to this Release understand that many common medical expenses are not payable or
reimbursable under the Medicare program. These medical expenses, not covered by Medicare but
necessary in the ongoing treatment of the Releasor's injury, and Without an admission of liability on
the part of the Releasee, have been taken into consideration in the calculation and settlement of
Releasor's future medical expenses. Funds forthese non-Medicare covered medical expenses have
been included in the lump sum settlement amount and shall not be paid from any Medicare
allocation amount.
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Benefit Eligibility
Releasor acknowledges that any decision regarding entitlement to Social Security benefits or
Medicare or Medicaid benefits, including the amount and duration of payments and offset
reimbursement for prior payments is exclusively within the jurisdiction of the Social Security
Administration, the United States Government, and the U.S. Federal Courts, and is determined by
Federal low and regulations. As such, the United States Government is not bound by any of the
terms of this Release,
Future Benefits
Releasor has been apprised of his /her right to seek assistance from legal counsel of his /her choosing
or directly from the Social Security Administration or other government agencies regarding the
impact this Release may have on Releaser's current or future entitlement to Social Security or other
governmental benefits. Releasor acknowledges that acceptance of these settlement funds may
affect Releasor's rights to other governmental benefits, insurance benefits, disability benefits, or
pension benefits. Notwithstanding this possibility, Releasor desires to enter into this Release
agreement to settle his/her injury claim according to the terms set forth in this Release.
Medicare Recovery Action
Releasor agrees to hold harmless, indemnity and defend Releasee from any cause of action,
including, but not limited to, an action by CMS to recover or recoup Medicare benefits or loss of
Medicare benefits, if CMS determines that the money set-aside has been spent inappropriately or
for any recovery sought by Medicare, including post, present, and future and/or conditional
payments. Releasor agrees not to use designated Medicare allocation funds to pay claims for
conditional payments that may have been made by Medicare,
2
380652.1
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Complete Understanding
Releasor hereby declares that the terms of this Release have been completely read and are fully
understood and voluntarily accepted for the purpose of making a full and final settlement of any
and all claims, disputed or otherwise, on account of injuries and/or damages related to the Claims
set forth herein, and for the express purpose of precluding forever any further additional claims
against the Release arising out of the aforesaid incident, accident or occurrence.
As to the releaser only:
Releasor Name Date
Miguel Rojas
Releasor Address
STATE OF
COUNTY OF
THIS ADDENDUM TO SETTLEMENT AGREEMENT AND MUTUAL RELEASE BETWEEN PLAINTIFF AND COLLIER
COUNTY, FLORIDA WAS SWORN TO and subscribed by MIGUEL ROJAS, before me on this day
of 2013.
Signature of Notary Public
Commissioned Name of Notary Public
(Please print, type or stamp)
My Commission expires:
Personally Known
or
Produced Identification
Type of Identification Produced
380652.1
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As to the releasee only:
BOARD OF COUNTY COMMISSIONERS
OF COLLIER COUNTY, FLORIDA
2/12/2013 16.K.2.
Releasee Date
Georgia A. Hiller, Esq., Chairwoman
Releasee Address
ATTEST:
DWIGHT E. BROCK, Clerk
Deputy Clerk
Approved as to form and
legal sufficiency:
KEVIN L. NOELL
Assistant County Attorney
12-0924-CA
4
380652.1
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