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Agenda 12/01/2009 Item #16K 5 Agenda Item No. 16K5 December 1, 2009 Page 1 of 3 .."-- EXECUTIVE SUMMARY Recommendation to authorize the County Attorney to settle a lawsuit filed against the Board Of County Commissiouers by Brian Anderman, an East Naples firefighter, in Collier County Circuit Court, for the sum of $20,000.00 and authorize the Chairman to execute the Settlement Agreement. OBJECTIVE: For the Board of County Commissioners to authorize the County Attorney to settle the lawsuit filed against the Board of County Commissioners by Brian Anderman, an East Naples firefighter, in Collier County Circuit Court, for the sum of $20,000 and authorize the Chairman to execute the Settlement Agreement. CONSIDERATIONS: Mr. Anderman's complaint, dated October 30, 2006, alleges that he injured his back while operating a Collier County EMS stretcher on July 18, 2004. Mr. Anderman was working as an East Naples firefighter when both Collier County EMS and East Naples Fire District arrived to an emergency calL Mr. Andennan voluntarily removed the stretcher from the back of the ambulance without any assistance. Mr. Andennan admits that he was properly trained to use two people to remove the stretcher from the ambulance. Mr. Anderman alleges that the stretcher failed in that the stretcher legs failed to "lock" into place, causing Mr. Andelman to collapse with the stretcher causing injury to his back. There were no witnesses to this alleged event, and accordingly Collier County denies that the injury occurred as - alleged. The parties have completed extensive discovery including depositions and two mediations, Mr. Anderman also named the stretcher manufacturer and maintenance companies as defendants in his lawsuit. These parties have reached a confidential settlement agreement. One weakness in the case for both parties is the inability to specifically identify the stretcher in question. This is due in part to Mr. Anderman failing to report the injury to Collier County EMS and failing to make the County aware that there was a potential problem with the stretcher. In fact, the emergency call was completed and the patient was transferred on the same stretcher successfully. Mr. Anderman suffered extensive injuries which he alleges are based on the incident at issue, Mr. Anderman had two lumbar surgeries and extensive physical therapy. His workers' compensation lien is over $850,000. However, Mr. Anderman also had a significant history of playing sports including a documented injury to his spine while playing soccer in high school (1992), Due to the extensive mcdical damages and a complicated medical history, this case would require at least one medical expert witness whose cost could exceed $12,000 including a compulsory medical exam of the plaintiff and testimony at triaL This case would also require an economist to explain the damages to the jury and the past and future lost wages that Mr. Andennan is claiming, This could potentially cost another five to ten thousand dollars. -- . .",,~~."'~ , , . ,- .... , r.......' .. ,......."......_w_..y.-,...-..,.,~,.w .. Agenda Item No, 16K5 December 1, 2009 Page 2 of 3 As discussed, there is significant expense associated with trying this case, Collier County would face at least $20,000 (twenty thousand dollars) in expert witness fees, There is also potential for the jury to find for the Plaintiff due to his significant injuries and loss of career as a firefighter.. FISCAL IMPACT: Funds are budgeted and available in the Risk Management Property & Casualty Fund, and the impact will be $20,000,00, GROWTH MANAGEMENT IMPACT: There is no growth management impact associated with this item, LEGAL CONSIDERATIONS: The County Attorney's Office has reviewed this case with the Risk Management Department and recommends that the Board of County Commissioners approve this Settlement Agreement. There is a significant risk of exposure and costs associated with trying this case, This item is legally sufficient for Board action, - CMG RECOMMENDATION: For the Board of County Commissioners to authorize the County Attorney to settle the lawsuit filed against the Board of County Commissioners by Brian Andennan, an East Naples firefighter, in Collier County Circuit Court, for the sum of $20,000 and authorize the Chairn1an to execute the Settlement Agreement. PREPARED BY: Colleen M, Greene, Assistant County Attomey ",<~., ,,"~. --""-'- t---.. '. ,.,- Agenda Item No. 16K5 December 1, 2009 Page 3 of3 ..-, COLLIER COUNTY BOARD OF COUNTY COMMISSIONERS Item Number: Item Summary: 16K5 Recommendation to authorize the County Attorney to settle a lawsuit filed against the Board Of County Commissioners by Brian Anderman, an East Naples firefighter, in Coilier County Circuit Court, for the sum of $20,000.00 and authorize the Chairman to execute the Settlement Agreement. 12/1 120099:00:00 AM Meeting Date: Prepared By Colleen Greene Assistant County Attorney Date County Attorney County Attorney 11117120099:38:50 AM Approved By Colleen Greene Assistant County Attorney Date County Attorney County Attorney 11/17120099:43 AM Approved By Jeffrey A. Walker, CPCU, ARM Director ~ Risk Management Date Administrative Services _..v_ Division Risk Management 111171200911:20 AM Approved By Jeff Klatzkow County Attorney Date 11117120093:01 PM Approved By OMS Coordinator Date County Attorney County Attorney 11/18120099:45 AM Approved By John A. Yonkosky Director w Management and Budget Date Office of Management & Office of Management & Budget 11/18120094:21 PM Budget - --,,'-- ,-'"" ..._---.~~.., " ~ ~ '------"T"---