Agenda 06/10/2008 Item #16K 1
Agenda Item No. i6K 1
June 10. 2008
Page 1 of 8
EXECUTIVE SUMMARY
Recommendation to approve a Stipulated Final Judgment for Parcels 140 and 140B in the
lawsuit styled Collier County v. Edward Stanley Sanditen, et al., Case No. 02-5165-
CA(Immokalee Road Project No. 6(018). (Fiscal Impact $ 19,991)
OBJECTIVE: That the Board of County Commissioners approve the Stipulated Final
Judgment for payment of full compensation, expert fees and eosts, in settlement for the taking of
Parcels ]40A and 140B in the lawsuit styled Collier County v. Edward Stantey Sandilen, el at.,
Case No. 02-5165-CA (Immokalee Road Project No. 60018).
CONSIDERA TIONS: Prior to suit, staff offered the Respondent, Roy David Hilberg,
$49,300 which was rejected. The County acquired the subject property by entry of an Order of
Taking and by depositing the sum of $52,200. Due to a change in grade, the Respondent claimed
damages. After engineering evaluation, the County and Respondent have negotiated a settlement
of $62,000 as full compensation for the taking of these two parcels. In addition, this proposed
settlement provides for payment of statutory attorney's fees and all expert fees and eosts in this
case.
If approved, the County will pay the following costs:
. Additional Compensation:
. Expert Witness Fees:
. Statutory Attorney's Fees*:
. TOTAL
$ 9.800
$ 6,000
$ 4.19]
$ 19,991
* Attorney's Fees are mandated by S 73.092, F.5., and are based on 33% of the difference
between any settlement amount and the initial offer, i.e., 0.33 x ($62,000- $49,300).
Attached is the proposed Stipulated Final Judgment.
FISCAL IMPACT: Funds in the amount of $19,991 are available in the FY 2008 adopted
budget. Source of funds are Impact Fees and/or Gas Taxes.
GROWTH MANAGEMENT IMPACT: None.
RECOMMENDATION: That the Board of County Commissioners:
1. Approve the proposed Stipulated Final Judgment as to Parcels 140A and ]40B;
2. Approve the expenditure of funds as stated.
PREPARED BY: Ellen T. Chadwell, Assistant County Attorney
02.5165CA/780
Page I of2
,A,gellda Item f\jo. 16K1
June 10 2008
Page 2 of 8
COLLIER COUNTY
BOARD OF COUNTY COMMISSIONERS
Item Number:
16K1
Item Summary:
Recommendation to approve a Stipulated Final Judgment for Parcels 140 and 1408 in the
lawsuit styled Collier County v. Edward Stanley Sanditen, et aI., Case No. 02-5165-CA
(lmmokalee Road Project No 60018) (Fiscal Impact $19,991)
6/10/20089.0000 AM
Meeting Date:
Prepared By
Ellen T. Chadwell
Assistant County Attorney
Date
County Attorney
County Attorney Office
5/23/200811:53:36 AM
Approved By
Najeh Ahmad
Director
Date
TransportaUon Services
Transportation Engineering &
Construction Management
5/27/200811:35 AM
Approved By
Usa Taylor
Management/Budget Analyst
Date
Transportation Services
Transportation Administration
5127/20082:29 PM
Approved By
Enen T. Chadwell
Assistant County Attorney
Date
County Attorney
County I';ttorney Office
5/28/200810:56 AM
Approved By
Sharon Newman
A.:counting Supervisor
Date
Transportation Services
Transportation Services Admin
5128/2008 2:58 PM
Approved By
Jeff ~<Iatzkow
Assistant County Attorney
Date
County Attorney
Count~' Attame)' Office
5/29/20088:34 AM
Approved By
Kevin Hendricks
Right Of Way Acquisition Manager
Date
Transportation Services
TECM-ROW
5/29/2008 1 :54 PM
Approved By
OMS Coordinator
OMS Coordinator
D<.:te
County Manager's Omee
Office of Management & Budget
5/30/2008 9:27 AM
Approved By
Susan Usher
Senior Management/Budget Anaiyst
Date
County Manager's Office
Office of Management & Budget
6!4!2008 S:32 AM
fiJe://C:\AeendaTest\ExDort\ 1 09-June%20 1 O. %202008\] 6.%20CONSENT%20AGENDA \ 16... 6/4/200&
Approved By
James V. r-JIudd
County fVianager
Date
Board of ::':ounty
Commissjoners
County Manager's Office
6/4/2008 9:56 AM
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Agenda Item r,o. i6K 1
June 10.2008
Page 4 of 8
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY, FLORIDA CIVIL ACTION
COLLIER COUNTY, a political subdivision
of the State of Florida,
Petitioner,
v.
Case No. 02-5165-CA
Parcel No. 140A, 140B
EDWARD STANLEY SANDlTEN, et a!.,
Respondents.
/
STIPULATED FINAL JUDGMENT
THIS CAUSE, having come before the Court upon Joint Motion made by Petitioner,
COLLIER COUNTY, FLORIDA, and Respondent, ROY DAVID HILBERG, by and through
their undersigned counsel, for entry of a Stipulated Final Judgment as to Parcels 140A and 140B,
the Court finding that the compensation to be paid by Petitioner, COLLIER COUNTY,
FLORIDA, is the full compensation due Respondent, ROY DAVID HILBERG, and the Court
being otherwise fully advised in the premises thereof, it is thereupon
ORDERED AND ADJUDGED that:
1. Respondent, ROY DAVID HILBERG, receive from Petitioner, COLLIER
COUNTY, FLORIDA, the sum of Sixty Two Thousand and No/tOO Dollars ($62,000.00), as
full payment for the property interests taken and for damages resulting to the remainder, if less
than the entire property was taken, and for all other damages in connection with said parcels.
::em i'~o. "1 'Sr(1
,Llii8 10. ~)C;~'3
5813
2. Petitioner will be entitled to a credit for the good faith estimate of value
previously deposited in the amount of$52,200.00.
3. Respondent shall receive, pursuant to Florida Statutes 973.092(1), as a reasonable
attorney's fee, the sum of Four Thousand One Hundred Ninety-One and No/lOO Dollars
($4,191.00), based on a benefit to the property owner of $12,700.00, and that no other attorney's
fees shall be awarded in this cause.
4. Respondent shall receive as full settlement of any and all claims for expert fees
and costs the sum of Six Thousand and No/lOO Dollars ($6,000.00).
5. Within thirty (30) days of entry of this Order, Petitioner shall pay the sum of
Nineteen Thousand Nine Hundred Ninety-One and No/100 Dollars ($19,991.00) made
payable to Roetzel & Andress TRUST ACCOUNT, c/o Kenneth A. Jones, Esquire, 2320 First
Street, Suite 1000, Ft. Myers, FL 33901 for proper disbursement in accordance with this Order.
6. Title to Parcels 140A and 140B, fee simple interests, being fully described in
Exhibit "A" attached hereto and incorporated herein, which vested in Petitioner, COLLIER
COUNTY, FLORIDA, pursuant to the Order of Taking dated May 22, 2003, and the deposit of
money heretofore made, is approved, ratified, and confirmed.
7. The Notice of Lis Pendens filed in the above-styled cause and recorded in Official
Record Book 3178, Page 2184 of the Public Records of Collier County, Florida, be dismissed as
to Parcels 140A and 140B.
8. This Stipulated Final Judgment is to be recorded in the Official Records of Collier
County, Florida.
9. This Court retains jurisdiction to enforce the terms of this Stipulated Final
Judgment.
Agenda Item r"o. 16K 1
.Jcne 10. 20G8
Page 6 of 8
DONE AND ORDERED III Naples, Collier County, Florida, this
day of
,2008.
HUGHD.HAYES
Circuit Court Judge
Conformed copies to:
Ellen T. Chadwell, Esquire
Kenneth A. Jones, Esquire
Kevin Hendricks, Transportation Dept.
Accounting
JOINT MOTION
The Parties hereby stipulate and respectfully request this Court to enter the foregoing
Stipulated Final Judgment as to Parcels 140A and 140B.
Dated:
Dated:
Kenneth A. Jones, Esquire
Florida Bar No.: 0200158
Roetzel & Andress
2320 First Street, Suite 1000
Fort Myers, FL 33901
(239) 337-3850- Phone
(239) 337-0970- Facsimile
ATTORNEY FOR RESPONDENT:
ROY DAVID HILBERG
Ellen T. Chadwell
Assistant County R y
Florida Bar No.: 983860
Collier County Attorney's Office
3301 East Tamiami Trail, 8th Floor
Naples, Florida 34112
(239) 252-8400 - Phone
(239) 252-6300 - Facsimile
ATTORNEY FOR PETITIONER
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NORTH UNE or 15E.CTION 29
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NOTES:
1. THIS IS NOT A SURVEY.
2. BASIS OF BEARING 15 N/A.
3. SUBJtCT TO EASEMENTS, RESERVATIONS AND
RESTRICTIONS OF RECORD. '"
NOT TO SCALE:
DESCRIP TION:
THE NORTHERLY \79.\6 fEET OF THE WEST 30'. FEET OF
THE NORTH ONE HALF OF THE NORTH WEST QUARTER
OF THE NORTHEAST QUARTER, LESS THE NORTH 100.00
FEETPRE~OUSL Y DEDlCA TED FOR STATE HIGHWAY 1646.
SECTION 29, TOWNSHIP 4B SOUTH, RANGE 27 EAST,
COLLIER COUNTY, FLORIDA. CON T AINING 0.055 ACRES
MORE OR LESS.
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J\aenda item ~~o. 16K1
. . June 10, 2008
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1. ThIs hs not 0 survey.
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3. Sub-jec:t to easements, reservatlons and
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SCALE
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NOT VALlD..,T UT tHE SIGNATURE: ,\ND
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