Agenda 02/12/2008 Item #16K 2
Agenda Item No, 16K2
February 12, 2008
Page 1 of 36
EXECUTIVE SUMMARY
ReeommeDdatioD to approve seveD settlemeDts for road right-of-way parcels aequired
through eODdemDatioD for the on WeD Road Project (On WeD Road Project # 60044).
(Fiscal Impact 541,920.25)
OBJECTIVE: That the Board of County Commissioners approve the proposed Stipulated
Final Judgments for payment of full compensation, expert fees and costs, for the taking of Parcel
174RDUE in CC v. Hittinger, Case No, 07-3898-CA. Parcel 192RDUE in CC v, Munoz. Case
No,07-2823-CA, Parcel205RDUE in CC v, Sardinas, Case No, 07-2824-CA, Parcels 182RDUE
and 196RDUE in CC v, Yzaguirre, Case No, 07-2746-CA. Parcel 197RDUE and 189RDUE in
CC v, Noel. Case No, 07 -3200-CA
CONSIDERA nONS: These parcels are all similarly situated and were negotiated as a
group, In an effort to facilitate this Board's review and consideration, they have been
consolidated into one agenda item. The owners' engineer, hired to evaluate the County's
construction plans, had concerns about drainage in the after condition along Everglades and
opined that the roadway as designed would act much like a dam and result in flooding on the
properties. On the basis of this engineering report, the owners filed a counterclaim against the
County, alleging a separate taking and damages as a result of the purported flooding. Although
the County disputed the owners' engineer's contentions, it revised the project plans to eliminate
any such claim by the owners. As a result of the County's action in revising the plans, the
owners' attorney claimed a fee pursuant to Section 73.092(2), Fla. Stat., based on a non-
monetary benefit.
The chart below identifies the original offers, the deposits made in January, the settlement
amounts, and the additional cost to the County should the Board accepts staffs recommendation.
Each settlement includes $770 for expert fees, primarily engineering fees, and $750 for
attorney's fees. Although the County's appraiser opined that land values were $75,000 per acre
in early 2007, staff made incentive offers based on $loo,ooo/acre, Due to the declining market
through 2007, the County's appraisal expert, at the time of January's Order of Taking hearings,
estimated land values at $35,000/acre, thereby resulting in a significant difference between the
original offers and the good faith deposits, Should litigation continue at this point, the County
can, at the very least, expect each owner to obtain an appraisal report to substantiate their value
and court-ordered mediation. These costs are borne by the County and alone can range from
$6500 to $11,000 per parcel.
Parcel Offer Deposit Settlement Add'l Cost (ihpproved)
174RDUE $12,100 $4,200 $10,504.25 $ 6,30425
182RDUE $12,100 $4,200 $10,504.25 $ 6,30425
196RDUE $10,300 $3,600 $ 9,167,75 $ 5,567,75
192RDUE $ 5,200 $1,800 $ 5,38\.00 $ 3,58\.00
189RDUE $ 5,200 $1,800 $ 5,38\.00 $ 3,581.00
197RDUE $10,300 $3,600 $ 9,167,75 $ 5,567,75
205RDUE 524.100 $8.400 $19.414,25 $ 1 \.014.25
Total 579,300 $27,(iOO 569,510.25 5 41,920.25
,.-'"
Aaenda Item No. 16K2
v February 12, 2008
Page 2 of 36
Staff thinks the proposed settlements are fair and reasonable both to the property owners and the
taxpayers of Collier County. The foregoing settlements are memorialized in the attached
Stipulated Final Judgments.
FISCAL IMPACT: Funds in the amount of $41,920.25 are available in Impact Fees and/or
Gas Taxes.
GROWTH MANAGEMENT IMPACT: None.
RECOMMENDA nON: That the Board of County Commissioners:
I. Approve the proposed Stipulated Final Judgments as to Parcels 174RDUE,
182RDUE, 189RDUE, 192RDUE, 196RDUE, 197RDUE and 205RDUE;
2. Approve the expenditure of funds as stated.
PREPARED BY: Ellen T. Chadwell, Assistant County Attorney
07-3200.cN193S
2
Page] of2
Agenda Item No. 16K2
February 12. 2008
Page 3 of 36
COLLIER COUNTY
BOARD OF COUNTY COMMISSIONERS
Item Number:
Item Summary:
16K2
Meeting Date:
Recommendation to approve seven settlements for road right~of~way parcels acquired
through condemnation for the Oil Well Road Project (Oil Well Road Project # 60044). (Fiscal
Impact $41.920.25)
2/12/2008 9:00:00 AM
Prepared By
Ellen T. Chadwell
Assistant County Attorney
Date
County Attorney
County Attorney Office
11301200810:11:35 AM
Approved By
Najeh Ahmad
Director
Date
Transportation Services
Transportation Engineering &
Construction Management
11301200810:46 AM
A pproved By
Lisa Taylor
ManagementJBudget Analyst
Date
Transportation Services
Transportation Administration
11301200811:09 AM
Approved By
Kevin Hendricks
Right Of Way Acquisition Manager
Date
Transportation Services
TEeM-ROW
1/301200811:47 AM
Approved By
Sharon Newman
Accounting Supervisor
Date
Transportation Services
Transportation Services Admin
1130/2008 1: 1 8 PM
Approved By
Ellen T. Chadwell
Assistant County Attorney
Date
County Attorney
County Attorney Office
1/30120081:49 PM
Approved By
Norm E. Feder, AICP
Transportation Division Administrator
Date
Transportation Services
Transportation Services Admin.
113012008 3:08 PM
Approved By
David C. Weigel
County Attorney
Date
County Attorney
County Attorney Office
1130120083:52 PM
Approved By
OMS Coordinator
Applications Analyst
Date
Administrative Services
Information Technology
1131120088:38 AM
file://C:\AgendaTest\Export\ 1 00-February%20 12, %202008\] 6.%20CONSENT%20AGEND... 2/6/2008
Page 2 of 2
Agenda Item No. 16,(2
February 12, 20GB
Page 4 of 36
Approved By
Susan Usher
Senior Management/Budget Analyst
Date
County Manager's Office
Office of Management 8. Budget
211120086:06 PM
Approved By
James V. Mudd
Board of County
Commissioners
County Manager
Date
County Manager's Office
213/200810:10 PM
file://C:\AgendaTest\Export\ 1 00-February%20 12, %202008\ 16.%20CONSENT%20AGEND... 2/6/2008
Agenda Item No. 16K2
February 12, 2008
Page 5 of 36
IN THE CIRCUIT COURT OF THE TWENTlEm JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL ACTION
COLLIER COUNTY, FLORIDA, a political
subdivision of the State of Florida,
Petitioner,
v,
Case No. 07-3898-CA
HELMUT HITTlNGER, et al.,
Parcel: 174RDUE
Respondent.
/
STIPULATED FINAL JUDGMENT
TH1S CAUSE having come before the Court upon Joint Motion made by Petitioner,
COLLIER COUNTY, FLORIDA, and Respondents, FRANK ALFIERI and DONNA ALFIERI, by
and through their undersigned counsel, for entry of a Stipulated Final Judgment as to Parcel
I 74RDUE, and it appearing to the Court that the parties are authorized to make such Motion, the
Court finding that the compensation to be paid by Petitioner is the full compensation due the
Respondents, FRANK and DONNA ALFIERI, and the Court being otherwise fully advised in the
premises, it is thereupon
ORDERED AND ADJUDGED that:
1. Respondents, FRANK and DONNA ALFIERI, shall recover from Petitioner,
COLLIER COUNTY, FLORIDA, the swn of Ten Thousand Five Hundred Four and 25/100
DoUan ($10,504.25) for Parcell 74RDUE, 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
Aoenda Item No 16K2
- February 1 z'. 2008
Page 6 of 36
damages in connection with said parcel, and all attorney's fees and defense costs. No other costs
and attorney's fees, including supplemental attorney's fees, shall be awarded in this cause,
2. Petitioner will be entitled to a credit in the amount of $4,200.00 for the good faith
deposit made in accordance with the Order of Taking,
3, Title to Parcell 74RDUE in perpetual, non-exclusive Road Right-of-Way, Drainage
and Utility Easement, being fully described in Exhibit "A" attached hereto and incorporated herein,
which vested in Petitioner pursuant to the Order of Taking dated January 9, 2008, and the deposit of
money heretofore made, is approved, ratified, and confirmed,
4. The Notice of Lis Pendens filed in the above-styled cause and recorded in Official
Record Book 4295, Page 2102 of the Public Records of Collier County, Florida be dismissed as to
Parcel No, 1 74RDUE,
5, Within thirty (30) days from receipt of this order, Petitioner shall pay the sum of Six
Thousand Three Hundred and Four and 25/100 Dollars ($ 6,304.25) to Bella y, Patel, P.A.
Trust Account, c/o Bella y, Patel, Esq., 13026 Waterford Run Drive, Riverview, FL, 33569, for the
benefit of Frank and Donna Alfieri.
6, Upon entry of this order, the Clerk shall immediately disburse the total amount of
Four Thousand Two Hundred and No/lOO Dollars ($4,200.00), made payable to Bella Y. Patel,
P.A. Trust Account, c/o Bella y, Patel, Esq., 13026 Waterford Run Drive, Riverview, FL, 33569,
for disbursement of compensation, attorney's fees and costs,
7. Pursuant to Section 74.051(3), F.S" the Clerk of Courts shall disburse the interest
earned on the funds on deposit in the amount of
, via wire transfer from the Clerk of Courts
to the Board of County Commissioners, Account #
Agenda Item No. 16K2
February 12, 2008
Page 7 of 36
8. This Stipulated Final Judgment resolves all issues and claims asserted in this cause
and arising out of or relating in any way to the acquisition of Parcel 174RDUE and shall be
recorded in the Official Records of Collier County, Florida
9, This Court retains jurisdiction to enforce the terms of this Stipulated Final
Judgment.
DONE AND ORDERED in Naples, Florida, this _ day of
conformed copies to:
Ellen T, Chadwell, Esquire
Bella Y. Patel, Esquire
Kevin Hendricks, Acquisition Mgr.rrransp.
Accounting
,2008,
HUGH D. HAYES
CIRCUIT COURT JUDGE
JOINT MOTION FOR STIPULATED FINAL JUDGMENT
The Parties hereby stipulate and respectfully request this Court to enter the foregoing
Stipulated Final Judgment as to Parcel l74RDUE,
Date:
BELLA y, PATEL, ESQ.
Florida Bar No, 896489
LAW OFFICE OF BELLA Y. PATEL, PA
13026 Waterford Run Drive
Riverview, FL 33569
(813) 643-2762 - Telephone
(813) 643-2612 - Facsimile
A TIORNEY FOR RESPONDENTS,
FRANK & DONNA ALFlERI
Date:
ELLEN T. CHADWEL@
Florida Bar No. 983860
OFFICE OF THE COUNTY ATIORNEY
Harmon Turner Building, 8th Floor
3301 East Tamiami Trail
Naples, Florida 34112
(239) 774-8400 - Telephone
(239) 252-6300 - Facsimile
A TIORNEY FOR PETITIONER
Aqenda Item No. 16K2
- February 12, 2008
Page 8 of 36
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Joint Motion on
Stipulated Final Judgment has been furnished by U.S. Mail to all parties listed below on this _
day of
,2008.
ELLEN T, CHADWELL, ESQUIRE
PARCEL 174RDUE
Frank Alfieri
Donna Alfieri
c/o Bella Y. Patel, Esq.
Law Office of Bella Y. Patel. PA
13026 Waterford Run Drive
Riverview, FL 33569
Owners
PROJECT NO, 60044
PROJECT PARCEL NO. 174RDUE
PERPETUAL, NON-EXCLUSIVE ROAD RIGHT-OF-WAY, DRAINAGE AND UTILITY EASEMENT
1 f~_ _~'
v.
Agenda Item No. 16K2
February 12, 2008
Page 9 of 36
LEGAL DESCRIPTION & SKETCH
(NOT A SURVEY)
~IBlr.Ll,
THE EAST 70 FEET OF THE WEST 120 FEET OF THE NORTH 75
FEET OF THE SOUTH 150 FEET OF TRACT 16, GOLDEN GATE
ESTATES UNIT NO. 68, AS RECORDED IN PLAT BOOK 5, PAGE 90
OF THE PUBLIC RECORDS OF COLLIER COUNTY, FLORIDA.
CONTAINING 0,121 ACRES, MORE OR LESS.
THE NORTH 75 FEET OF THE
SOUTH 150 FEET OF TRACT 16
,
E11JAI.. NON-EXCWS/VE
RIGHT-oF-WAY, DRAINAGE
AND UTlUTY EASEMENT
PRCPOSEDADDnlONAL RIGHT..QFJNAY (70 FEET)
EAST HAlF OS'
EXJSTING 100 FOOTWIOE EVERGlADES BOULEVARD RIGHT-oFJNAY
(:~7---U_U_.'
-.--..-..-..--.-..-..-..-.---.-..-..-..-..-..-..-..-.,-..-..-.--..-..-..-..-.---.-..-..-..-.,-..
NORTH
NOT TO SCALE
rCDllltyTfII~partlIIiDnEng~&COl\llrvC6onMlflll9ORllll1.OllpamIInf
OJl2OO7 4~45 PM
I
Agenda IIem No. 16K2
February 12, 2008
Page 10 of 36
IN THE CmCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL ACTION
COLLIER COUNTY, FLORIDA, a
political subdivision of the State of Florida,
Petitioner,
v.
Case No. 07-2823-CA
JOSE MUNOZ, et al.,
Parcel: 192RDUE
Respondent.
/
STIPULATED FINAL JUDGMENT
TIllS CAUSE having come before the Court upon Joint Motion made by Petitioner,
COLLIER COUNTY, FLORIDA, and Respondents, GREGORIO NUNEZ and MIRELLA
NUNEZ, by and through their undersigned counsel, for entry of a Stipulated Final Judgment as to
Parcel I 92RDUE, and it appearing to the Court that the parties are authorized to make such Motion,
the Court finding that the compensation to be paid by Petitioner is the full compensation due the
Respondents, GREGORIO and MIRELLA NUNEZ, and the Court being otherwise fully advised in
the premises, it is thereupon ORDERED AND ADJUDGED that:
1. Respondents, GREGORIO and MIRELLA NUNEZ, shall recover from Petitioner,
COLLIER COUNTY, FLORIDA, the sum of Five Thousand Three Hundred Eighty-One and
No/tOO Dollars ($5,381.00) for Parcel 192RDUE, 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 parcel, and all attorney's fees and defense costs. No other
costs and attorney's fees', including supplemental attorney's fees, shall be awarded in this cause.
Agenda Item No. 16K2
February 12, 2008
Page 11 of36
2. Petitioner will be entitled to a credit in the amount of $1,800.00 for the good faith
deposit made in accordance with the Order of Taking.
3, Title to Parcel 192RDUE in perpetual, non-exclusive Road Right-of-Way, Drainage
and Utility Easement, being fully described in Exhibit "An attached hereto and incorporated herein,
which vested in Petitioner pursuant to the Order of Taking dated January 4, 2008, and the deposit of
money heretofore made, is approved, ratified, and confirmed,
4. The Notice of Lis Pendens filed in the above-styled cause and recorded in Official
Record Book 4272, Page 3598, et seq, of the Public Records of Collier County, Florida is dismissed
as to Parcel No. 192RDUE.
5. Within thirty (30) days from receipt of this order, Petitioner shall pay the swn of
Three Thousand Five Hundred Eighty-One and No/lOO Dollars ($3,581.00), made payable to
Bella Y. Patel, P.A. Trust Account, c/o Bella Y. Patel, Esq., 13026 Waterford Run Drive,
Riverview, FL, 33569, for the benefit of Gregorio and Mirella Nunez.
6. Within thirty (30) days hereof, the Clerk shall disburse the total amount of One
Thousand Eight Hundred and No/I00 Dollars ($1,800.00), made payable to Bella Y. Patel, P.A.
Trust Account, C/D Bella Y. Patel, Esq., 13026 Waterford Run Drive, Riverview, FL, 33569, for
disbursement of compensation, attorney's fees and costs.
7. Pursuant to Section 74.051(3), F.S., the Clerk of Courts shall disburse the interest
earned on the funds on deposit in the amount of
, via wire transfer from the Clerk of Courts
to the Board of County Commissioners, Account #
8. This Stipulated Final Judgment resolves all issues and claims asserted in this
proceeding and arising out of or relating in any way to the acquisition of Parcel 192RDUE and shall
be recorded in the Official Records of Collier County, Florida
I\genda Item No. 16K2
February 12, 2008
Page 12 of 36
9, This Court retains jurisdiction to enforce the terms of this Stipulated Final
Judgment.
DONE AND ORDERED in Naples, Florida, this _ day of
,2008,
CYNTHIA A. ELLIS
CIRCUIT COURT JUDGE
conformed copies to:
Ellen T, Chadwell, Esquire
Bella Y. Patel, Esquire
Kevin Hendricks, Acquisition Mgr.rrransp.
Accounting
JOINT MOTION FOR STIPULATED FINAL JUDGMENT
The Parties hereby stipulate and respectfully request this Court to enter the foregoing
Stipulated Final Judgment as to Parcel 192RDUE.
Date:
Date:
BELLA Y. PATEL, ESQ.
Florida Bar No. 896489
LAW OFFICE OF BELLA Y. PATEL, P.A
13026 Waterford Run Drive
Riverview, FL 33569
(813) 643-2762 - Telephone
(813) 643-2612 - Facsimile
ATTORNEY FOR RESPONDENTS,
GREGORIO & MIRELLA NUNEZ
ELLEN T. CHADWEL&
Florida Bar No, 983860 .
OFFICE OF THE COUNTY ATTORNEY
Harmon Turner Building, 8th Floor
3301 East Tamiami Trail
Naples, Florida 34112
(239) 774-8400 - Telephone
(239) 252-6300 - Facsimile
ATTORNEY FOR PETITIONER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Joint Motion on
Stipulated Final Judgment has been furnished by U.S. Mail to Bella y, Patel, Esq., 13026
Waterford Run Drive, Riverview, FL, 33569 on this _ day of ,2008.
ELLEN T. CHADWELL, ESQUIRE
10 G
'ROJECT NO, 60044
'ROJECT PARCEL NO. 192RDUE
'ERPETUAL, NON-EXCLUSIVE ROAD RIGHT-OF-WAY, DRAINAGE AND UTILITY EASEMENT
LEGAL DESCRIPTION & SKETCH
(NOT A SURVEY)
EXHr~IT -..6
THE WEST 30 FEET OF THE EAST 80 FEET OF THE NORTH 75 FEET
OF THE SOUTH 180 OF TRACT 119, GOLDEN GATE ESTATES UNIT
NO. 64, AS RECORDED IN PLAT BOOK 7, PAGE 64 OF THE PUBLIC
RECORDS OF COLLIER COUNTY, FLORIDA.
CONTAINING 0.052 ACRES, MORE OR LESS
-..-..-.--..-..--.--.-..-..-..-..-..-..-..-.---.-..-..--,-.-------..--.-."-..-..-..-'.-..-..-.
I
_ '"_' .~_~~:.~~. ~~~~~ ~~.~~:~_~~~~!.~~~~~~.~~.T~~~.Y_. !.50_~~.~ _.. _ ._____.
_.. _?fi~EP.AQ!!I1~RK?I!T.:2E..IoY~Y~r:EflL.. _
PERPETUAL, NClN-EXCLUSIVE
ROAD RIGHT -oF_Y, DRAINAGE
AND unUTY EASEMENT
UH PROPERTY LINE
SOUTH PROPERTY UNE
.
.
THE NORTH 75 FEET OF THE
SOUTH 180 FEET OF TRACT 119
z
------ -
~
NOT TO SCALE
. ColInIy T I'IlnsportatiOll Enplneerirg & Gonslr'ud:ion Manfl98lllfll\f Department
03l3007!l:06AM
'-"CZ:'f::;r:;
Agenda Item No. 16K2
February 12, 2008
Page 14 of 36
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLffiR COUNTY, FLORIDA
CIVIL ACTION
COLLIER COUNTY, FLORIDA, a
political subdivision of the State of Florida,
Petitioner,
v.
Case No, 07-2824-CA
PABLO M, SARDINAS, et aI.,
Parcel: 205RDUE
Respondent.
I
STIPULATED FINAL JUDGMENT
THIS CAUSE having come before the Court upon Joint Motion made by Petitioner,
COLLIER COUNTY, FLORIDA, and Respondent, V & A AMERICAN CORP., by and through
their undersigned counsel, for entry of a Stipulated Final Judgment as to Parcel 205RDUE, and it
appearing to the Court that the parties are authorized to make such Motion, the Court finding that
the compensation to be paid by Petitioner is the full compensation due the Respondent, V & A
AMERICAN CORP., and the Court being otherwise fully advised in the premises, it is thereupon
ORDERED AND ADJUDGED that:
1. Respondent, V & A AMERICAN CORP., shall recover from Petitioner, COLLIER
COUNTY, FLORIDA, the sum of Nineteen Thousand Four Hundred Fourteen and 25/100
Dollars ($19,414.25) for Parcel 205RDUE, 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 parcel, and all attorney's fees and defense costs. No other costs
and attorney's fees, including supplemental attorney's fees, shall be awarded in this cause.
Agenda Item No. 16K2
February 12, 2008
Page 15 of 36
2, Petitioner will be entitled to a credit in the amount of $8,400.00 for the good faith
deposit made in accordance with the Order of Taking,
3. Title to Parcel 205RDUE in perpetual, non-exclusive Road Right-of-Way, Drainage
and Utility Easement, being fully described in Exhibit "A" attached hereto and incorporated herein,
which vested in Petitioner pursuant to the Order of Taking dated January 4, 2008, and the deposit of
money heretofore made, is approved, ratified, and confirmed,
4, The Notice of Lis Pendens filed in the above-styled cause and recorded in Official
Record Book 4272, Page 3616, et seq., of the Public Records of Collier County, Florida be
dismissed as to Parcel No. 205RDUE,
5. Within thirty (30) days of receipt of this order, Petitioner shall pay the sum of
Eleven Thousand Fourteen and 25/100 Dollars ($11,014.25) made payable to Bella Y. Patel,
P.A. Trust Account, c/o Bella Y. Patel, Esq., 13026 Waterford Run Drive, Riverview, FL, 33569,
for the benefit of V & A American Corp,
6. Within thirty (30) days hereof, the Clerk shall disburse the total amount of Eight
Thousand Four Hundred and No/I00 Dollars ($8,400.00), made payable to Bella Y. Patel, P.A.
Trust Account, c/o Bella Y. Patel, Esq" 13026 Waterford Run Drive, Riverview, FL, 33569, for
disbursement of compensation, attorney's fees and costs.
7, Pursuant to Section 74,051(3), F.S., the Clerk of Courts shall disburse the interest
earned on the funds on deposit in the amount of
, via wire transfer from the Clerk of Courts
to the Board of County Commissioners, Account #
8. This Stipulated Final Judgment resolves all issues and claims asserted in this cause
and arising out of or relating in any way to the acquisition of Parcel 205RDUE and shall be
recorded in the Official Records of Collier County, Florida.
Agenda item No. 16V.2
February 12, 2008
Page 16 of 36
9. This Court retains jurisdiction to enforce the terms of this Stipulated Final
Judgment; it is therefore,
DONE AND ORDERED in Naples, Florida, this _ day of
conformed copies to:
Ellen T. Chadwell, Esquire
Bella y, Patel, Esquire
Kevin Hendricks, Acquisition Mgr,rrransp,
Accounting
,2008.
CYNTHIA A. ELLIS
CIRCUIT COURT JUDGE
JOINT MOTION FOR STIPULATED FINAL JUDGMENT
The Parties hereby stipulate and respectfully request this Court to enter the foregoing
Stipulated Final Judgment as to Parce1205RDUE.
Date:
BELLA Y. PATEL, ESQ.
Florida Bar No, 896489
LAW OFFICE OF BELLA Y.PATEL,P.A.
13026 Waterford Run Drive
Riverview, FL 33569
(813) 643-2762 - Telephone
(813) 643-2612 - Facsimile
ATTORNEY FOR RESPONDENT,
V & AAMERlCAN CORP.
Date:
ELLEN T. CHADWEL~
Florida Bar No. 983860
OFFICE OF THE COUNTY ATTORNEY
Harmon Turner Building, 8th Floor
3301 East Tamiami Trail
Naples, Florida 341 12
(239) 774-8400 - Telephone
(239) 252-6300 - Facsimile
ATTORNEY FOR PETITIONER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Joint Motion on
Stipulated Final Judgment has been furnished by U.S. Mail to made payable to Bella Y. Patel, P.A.
Trust Account, c/o Bella Y. Patel, Esq., 13026 Waterford Run Drive, Riverview, FL, 33569, on this
_ day of ,2008,
ELLEN T. CHADWELL, ESQUIRE
'ROJECT NO. 60044
'ROJECT PARCEL NO. 205RDUE
'ERPETUAL, NON-EXCLUSIVE ROAD RIGHT-OF-WAY, DRAINAGE AND UTILITY EASEMENT
LEGAL DESCRIPTION & SKETCH EXHIEJ.'T d. ,
(NOT A SURVEY) .:-Ll"...
THE EAST 70 FEET OF THE WEST 120 FEET OF THE SOUTH 150
FEET OF TRACT 6, GOLDEN GATE ESTATES UNIT NO, 65, AS
RECORDED IN PLAT BOOK 5, PAGE 88 OF THE PUBLIC RECORDS
OF COLLIER COUNTY, FLORIDA.
CONTAINING 0.241 ACRES, MORE OR LESS.
THE SOUTH 150 FEET OF TRACT 6
{H PROPERTY UNE
SOUT'H PROPERTY UNE
PERPfTIJIo.L. NON-EXCLUSIVE
ROAD RIGHT-OF-wAY, DfWNAGE
AND UTIUTY EASEMENT
~ ..-..-..-.. -"-"-"-"-
PROPOSED ADDITIONAl RIGHT.QF~WAY (70 FEET)
-..-..-..-..--. ,,-,,-,,-,,-,,-,,-,,-,,-,,-,,-"-"-"-"-"-"'-'-"-'.-..-..-..-..-..-..-
/' EASTHA1.FCF EXISTlNG 100 FOOT wtDE EVERGLADES BOULEVARDRIGHT.QF..wAY (50FEET) ~
1. ,~=
NORTH
NOT TO SCALE
",,,,,,,,,,T___&,,,,,,,",,",,__,
03f30Il)79:f6AM
Agenda Item No. 16K2
February 12, 2008
Page 17 of 36
Agenda Item No. 16K2
February 12, 2008
Page 18 of 36
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL ACTION
COLLIER COUNTY, FLORIDA, a
political subdivision of the State of Florida,
Petitioner,
v.
Case No. 07-2746-CA
ARMANDO B. YZAGUIRRE, et al.,
Parcel: 1 82RDUE
Respondent.
/
STIPULATED FINAL JUDGMENT
THIS CAUSE having come before the Court upon Joint Motion made by Petitioner,
COLLIER COUNTY, FLORIDA, and Respondents, JORGE ECHEZARRAGA and LUZ
ECHEZARRAGA, by and through their undersigned counsel for entry of a Stipulated final
Judgment as to Parcel l82RDUE, and it appearing to the Court that the parties are authorized to
make such Motion, the Court finding that the compensation to be paid by Petitioner is the full
compensation due the Respondents, JORGE and LUZ ECHEZARRAGA, and the Court being
otherwise fully advised in the premises, it is thereupon
ORDERED AND ADmDGED that:
1. Respondent, JORGE & LUZ ECHEZARRAGA, shall recover from Petitioner,
COLLIER COUNTY, fLORIDA, the swn of Ten Thousand Five Hundred Four and 25/100
Dollars ($10,504.25) for Parcel 182RDUE, 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
,
A
]
Agenda Item No. 161">2
February 12, 2008
Page 19 of 35
damages in connection with said parcel, and all attorney's fees and defense costs. No other costs
and attorney's fees, including supplemental attorney's fees, shall be awarded in this cause.
2. Petitioner will be entitled to a credit in the amount of $4,200,00 for the good faith
deposit made in accordance with the Order of Taking.
3. Title to Parcel 1 82RDUE in perpetual, non-exclusive Road Right-of-Way, Drainage
and Utility Easement, being fully described in Exhibit "A" attached hereto and incorporated herein,
which vested in Petitioner pursuant to the Order of Taking dated January 9, 2008, and the deposit of
money heretofore made, is approved, ratified, and confirmed.
4. The Notice of Lis Pendens filed in the above-styled cause and recorded in Official
Record Book 4271, Page 1339 of the Public Records of Collier County, Florida is dismissed as to
Parcel No. 182RDUE,
5. Within thirty (30) days from receipt of this order, Petitioner shall pay the sum of Six
Thousand Three Hundred and Four and 25/100 Dollars ($6,304.25) to Bella Y. Patel, P.A.
Trust Account, c/o Bella Y. Patel, Esq., 13026 Waterford Run Drive, Riverview, FL, 33569, for the
benefit of Jorge & Luz Echezarraga.
6. Within thirty (30) days hereof, the Clerk shall disburse the total amount of Four
Thousand Two Hundred and No/loo Dollars ($4,200.00), made payable to Bella Y. Patel, P.A.
Trust Account, c/o Bella Y. Patel, Esq., 13026 Waterford Run Drive, Riverview, FL, 33569, for
disbursement of compensation, attorney's fees and costs.
7. The compensation amount awarded herein to Respondents, Jorge and Luz
Echezarraga, is subject to the apportiorunent claim, if any, of the mortgagee identified in this
proceeding.
Agenda Item No. 16K2
February 12, 2008
Page 20 of 36
8, Pursuant to Section 74.051(3), F.S., the Clerk of Courts shall disburse the interest
earned on the funds on deposit in the amount of
, via wire transfer from the Clerk of Courts
to the Board of County Commissioners, Account #
9. This Stipulated Final Judgment resolves all issues and claims asserted in this
proceeding or arising out of or relating in any way to the acquisition of Parcel 182RDUE and shall
be recorded in the Official Records of Collier County, Florida.
10. This Court retains jurisdiction to enforce the terms of this Stipulated Final Judgment
and conduct apportionment proceedings, if needed.
DONE AND ORDERED in Naples, Florida, this _ day of
,2008,
HUGH D. HAYES
CIRCUIT COURT JUDGE
Conformed copies to:
Ellen T, Chadwell, Esquire
Bella y, Patel, Esquire
MERS
Kevin Hendricks, Acquisition Mgr.rrransp,
Accounting
Agenda Item No. 16K2
February 12, 2008
Page 21 of 36
JOINT MOTION FOR STIPULATED FINAL JUDGMENT
The Parties hereby stipulate and respectfully request this Court to enter the foregoing
Stipulated Final Judgment as to Parcel 182RDUE.
Date:
BELLA y, PATEL, ESQ.
Florida Bar No. 896489
LAW OFFICE OF BELLA Y. PATEL, P.A.
13026 Waterford Run Drive
Riverview, FL 33569
(813) 643-2762 - Telephone
(813) 643-2612 - Facsimile
ATTORNEY FOR RESPONDENTS,
JORGE & LUZ ECHEZARRAGA
Date:
ELLEN T. CHADWEL~
Florida Bar No. 983860
OFFICE OF THE COUNTY ATTORNEY
Harmon Turner Building, 8th Floor
3301 East Tamiami Trail
Naples, Florida 341 12
(239) 774-8400 - Telephone
(239) 252-6300 - Facsnmle
ATTORNEY FOR PETITIONER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Joint Motion on
Stipulated Final Judgment has been furnished by U.S. Mail to all parties listed below on this _
day of , 2008.
Bella Y. Patel, Esq.
Law Office of Bella Y. Patel. P.A.
13026 Waterford Run Drive
Riverview, FL 33569
Mortgage Electronic Registration
Systems, Inc. as nominee for
America's Wholesale Lender Corporation
clo CT Corporation System, its R.A.
1200 South Pine Island Road
Plantation, FL 33324
ELLEN T. CHADWELL, ESQUIRE
PROJECT NO. 60044
PROJECT PARCEL NO. 182RDUE
PERPETUAL, NON-EXCLUSIVE ROAD RIGHT-OF-WAY, DRAJNAGE AND UTILITY EASEMENT
LEGAL DESCRIPTION & SKETCH
(NOT A SURVEY)
EXHI~!TA
THE EAST 70 FEET OF THE WEST 120 FEET OF THE SOUTH 75
FEET OF THE NORTH 180 FEET OF TRACT 2, GOLDEN GATE
ESTATES UNIT NO. 65, AS RECORDED IN PLAT BOOK 5. PAGE 88
OF THE PUBLIC RECORDS OF COLLIER COUNTY, FLORIDA.
CONTAINING 0.121 ACRES, MORE OR LESS.
THE SOUTH 75 FEET OF THE
NORTH 180 FEET OF TRACT 2
. .-.. -" -" -.. -.. -" -..
PERPETUAL, NON-EXClUSlVE
ROAD RIGHT-OF-WAY, DRAINAGE
AND unUTY EASEMENT
PROI'OSEO ADOmONAl RIGHT ..QFJNA Y (70 FEET)
-..-..-..-..-..-..-..-..-..-..-..-..-..-..-..-..-..-.------.--.-.
./
(SO FEET)
/ EAST HALF CF EXISTING 1OQFOOT WIDE EVERGlADES BOULEVARD RIGHT -OF.wAY
T
-..-..-..-..-..-..-..-..-..-..-..-..-..-'.-..----..-..-.--.-.--.--..-..-..-..-.,-..-..-..-..-.
NORTH
NOT TO SCALE
'''''''''T__'~__
03l3OlD78J40AM
Agenaa Item No. 16K2
February 12, 2008
Page 22 of 36
I
I
I
!
,
Agenda Item No. 16;(2
February 12, 2008
Page 23 of 36
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL ACTION
COLLIER COUNTY, FLORIDA, a
political subdivision of the State of Florida,
Petitioner,
v,
Case No. 07-2746-CA
ARMANDO B. YZAGUIRRE, et al.,
Parcel: 1 96RDUE
Respondent.
/
STIPULATED FINAL JUDGMENT
lHIS CAUSE having come before the Court upon Joint Motion made by Petitioner,
COLLIER COUNTY, FLORIDA, and Respondents, OTHONIEL CASTRO and NOEIDA B.
CASTRO, by and through their undersigned counsel, for entry of a Stipulated Final Judgment as to
Parcel I 96RDUE, and it appearing to the Court that the parties are authorized to make such Motion,
the Court finding that the compensation to be paid by Petitioner is the full compensation due the
Respondents, OTHONIEL CASTRO and NOEIDA B. CASTRO, and the Court being otherwise
fully advised in the premises, it is thereupon
ORDERED AND ADJUDGED that:
1. Respondents, OTHONIEL CASTROand NOEIDA B. CASTRO, shall recover from
Petitioner, COLLIER COUNTY, FLORIDA, the swn of Nine Thousand One Hundred Sixty-
Seven and 75/100 Dollars ($9,167.75) for Parcel 196RDUE, as full payment for the property
interests taken and for damages resulting to the remainder, ifless than the entire property was taken,
and for all other damages in connection with said parcel, and all attorney's fees and defense costs,
Agenda Item No. 16K2
February 12, 2008
Page 24 of 36
No other costs and attorney's fees, including supplemental attorney's fees, shall be awarded in this
cause,
2. Petitioner will be entitled to a credit in the amount of $3,600.00 for the good faith
deposit made in accordance with the Order of Taking.
3. Title to Parcel 196RDUE in perpetual, non-exclusive road right-of-way, drainage
and utility easement, being fully described in Exhibit "A" attached hereto and incorpomted herein,
which vested in Petitioner pursuant to the Order of Taking dated January 9, 2008, and the deposit of
money heretofore made, is approved, mtified, and confirmed,
4, The Notice of Lis Pendens filed in the above-styled cause and recorded in Official
Record Book 4271, Page 1339 of the Public Records of Collier County, Florida is dismissed as to
Parcel No. 196RDUE.
5, Within thirty (30) days from the date of this order, Petitioner shall pay the sum of
Five Thousand Five Hundred Sixty-Seven and 75/100 Dollars ($5,567.75) to Bella Y. Patel,
P.A. Trust Account, c/o Bella y, Patel, Esq" 13026 Waterford Run Drive, Riverview, FL, 33569,
for the benefit of Othoniel Castro and Noeida B. Castro,
6. Within thirty (30) days hereof, the Clerk shall disburse the total amount of Three
Thousand Six Hundred and No/tOO Dollars ($3,600.00), made payable to Bella Y. Patel, P.A.
Trust Account, c/o Bella Y. Patel, Esq., 13026 Waterford Run Drive, Riverview, FL, 33569, for
disbursement of compensation, attorney's fees, expert fees and costs.
6, Pursuant to Section 74.051(3), F,S., the Clerk of Courts shall disburse the interest
earned on the funds on deposit in the amount of
, via wire transfer from the Clerk of Courts
to the Board of County Commissioners, Account #
Agenda Item No. 16K2
February 12, 2008
Page 25 of 36
7. This Stipulated Final Judgment resolves all issues and claims arising out of or
relating in any way to the acquisition of Parcel 196RDUE and shall be recorded in the Official
Records of Collier County, Florida.
8. This Court retains jDrisdiction to enforce the terms of this Stipulated Final
Judgment.
DONE AND ORDERED in Naples, Florida, this _ day of
,2008,
HUGH D. HAYES
CIRCUIT COURT JUDGE
conformed copies to:
Ellen T. Chadwell, Esquire
Bella y, Patel, Esquire
Kevin Hendricks, Acquisition Mgr.rrransp.
Accounting
JOINT MOTION FOR STIPULATED FINAL JUDGMENT
The Parties hereby stipulate and respectfully request this Court to enter the foregoing
Stipulated Final Judgment as to Parcel 196RDUE.
Date:
Date:
ELLEN T. CHADWEL@
Florida Bar No, 983860
OFFICE OF THE COUNTY ATTORNEY
Hannon Turner Building, 8th Floor
3301 East Tamiarni Trail
Naples, Florida 34112
(239) 774-8400 - Telephone
(239) 252-6300 - Facsimile
ATTORNEY FOR PETITIONER
BELLA Y. PATEL, ESQ.
Florida Bar No. 896489
LAW OFFICE OF BELLA Y. PATEL, P.A.
13026 Waterford Run Drive
Riverview, FL 33569
(813) 643-2762 - Telephone
(813) 643-2612 - Facsimile
ATTORNEY FOR RESPONDENTS,
OTHONIEL & NOEIDA B. CASTRO
Agenda Item No. 16K2
February 12, 2008
Page 26 of 36
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Joint Motion on
Stipulated Final Judgment has been furnished by U.S. Mail to all parties listed below on this _
day of
,2008,
ELLEN T, CHADWELL, ESQUIRE
PARCEL 196RDUE
Othoniel Castro
Noeida B, Castro
clo Bella Y. Patel, Esq,
Law Office of Bella Y. Patel. P.A.
13026 Waterford Run Drive
Riverview, FL 33569
'-
n
l,
'ROJECT NO, 60044
'ROJECT PARCEL NO. 196RDUE
'ERPETUAL, NON-EXCLUSIVE ROAD RIGHT-Of-WAY, DRAINAGE AND UTILITY EASEMENT
LEGAL DESCRIPTION & SKETCH EXHIBIT A
(NOT A SURVEY)
THE WEST 30 FEET OF THE EAST 80 FEET OF THE SOUTH 150
FEET OF TRACT 122, GOLDEN GATE ESTATES UNIT NO, 64, AS
RECORDED IN PLAT BOOK 7, PAGE 64 OF THE PUBLIC RECORDS
OF COLLIER COUNTY, FLORIDA.
CONTAINING 0,103 ACRES, MORE OR LESS,
EAST PROPERTY UNE
l
/' WEST HALF OF EXlSTTNG 100 FOOT WIDE EVERGLADES BOUUNARO RIGHT-oF-WAY (SO FEET)
_..~--._.._.._.._._.._.._.._.._.._.._.-_.._.._.._.._..-,,-,--,--,,-,-,,-.--,'-"-"-"-"-"
.. _~.~.AEe!T!O!l!..R1~t'T"g~~YJ!~..
PERPETUAL.. NON-EXCLUSlVE
ROAD RIGHT -oF-wAV, DRAINAGE
AND UnUTY EASEMENT
...RTH PROPERTY UNE
SO\JTH PROPERTY UNE
THE SOUTH 150 fEET Of TRACT 122
NORTH
NOT TO SCALE
CcurtyTransponati;ln E/l9i1llltrtng & ConftUC::IIOnMll1lll8'nlllltOeparlment
1l3.'3Ml78:58AM
~. -!
Agenda Item No. 16K2
February 12, 2008
Page 27 of 36
Agenda Item No. 16K2
February i 2, 2008
Page 28 of 36
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL ACTION
COLLIER COUNTY, FLORIDA, a
political subdivision of the State of Florida,
Petitioner,
v,
Case No, 07-3200-CA
JOSEPH NOEL, et al.,
Parcel: 1 97RDUE
Respondent.
I
STIPULATED FINAL JUDGMENT
TIllS CAUSE having come before the Court upon Joint Motion made by Petitioner,
COLLIER COUNTY, FLORIDA, and Respondents, MAHAMMED S. SHEIKH and SHAMIM
SHEIKH, by and through their undersigned counsel, or entry of a Stipulated Final Judgment as to
Parcel 197RDUE, and it appearing to the Court that the parties are authorized to make such Motion,
the Court fmding that the compensation to be paid by Petitioner is the full compensation due the
Respondents, MAHAMMED S, SHEIKH and SHAMIM SHEIKH, and the Court being otherwise
fully advised in the premises, it is thereupon
ORDERED AND ADJUDGED that:
I, Respondents, MAHAMMED S. SHEIKH and SHAMIM SHEIKH, shall recover
from Petitioner, COLLIER COUNTY, FLORIDA, the swn of Nine Thousand One Hundred
Sixty-Seven and 75/100 Dollars ($9,167.75) for Parcel 197RDUE, 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 parcel, and all attorney's fees and defense costs,
Agenda Item No. 16K2
February 12, 2005
Page 29 of 36
No other costs and attorney's fees, including supplemental attorney's fees, shall be awarded in this
cause,
2. Petitioner will be entitled to a credit in the amount of $3,600.00 for the good faith
deposit made in accordance with the Order of Taking.
3. Title to Parcel 197RDUE in perpetual, non-exclusive Road Right-of-Way, Drainage
and Utility Easement, being fully described in Exhibit "A" attached hereto and incorporated herein,
which vested in Petitioner pursuant to the Order of Taking dated January 4,2008, and the deposit of
money heretofore made, is approved, ratified, and confirmed.
4. The Notice of Lis Pendens filed in the above-styled cause and recorded in Official
Record Book 4281, Page 4054 of the Public Records of Collier County, Florida be dismissed as to
Parcel No. 197RDUE.
5. Within thirty (30) days from receipt of this order, Petitioner shall pay the sum of
Five Thouand Five Hundred Sixty-Seven and 75/100 Donars ($ 5,567.75) to Bella y, Patel,
P.A. Trust Account, c/o Bella Y. Patel, Esq., 13026 Waterford Run Drive, Riverview, FL, 33569,
for the benefit of Mahammed S. Sheikh and Sharnim Sheikh.
6, Upon entry of this order, the Clerk shall forthwith disburse the total amount of
Three Thousand Six Hundred and No/IOO Dollars ($3,600.00), made payable to Bella Y. Patel,
P.A. Trust Account, c/o Bella Y. Patel, Esq., 13026 Waterford Run Drive, Riverview, FL, 33569,
for disbursement of compensation, attorney's fees and costs,
7. Pursuant to Section 74.051(3), F.S., the Clerk of Courts shall disburse the interest
earned on the funds on deposit in the amount of
, via wire transfer from the Clerk of Courts
to the Board of County Commissioners, Account #
Agenda item No. 16K2
February 12, 2008
Page 30 of 36
8. This Stipulated Final Judgment resolves all issues and claims asserted in this cause
and arising out of or relating in any way to the acquisition of Parcel 197RDUE and shall be
recorded in the Official Records of Collier County, Florida.
9. This Court retains jurisdiction to enforce the terms of this Stipulated Final
Judgment.
DONE AND ORDERED in Naples, Florida, this _ day of
conformed copies to:
Ellen T. Chadwell, Esquire
Bella y, Patel, Esquire
Kevin Hendricks, Acquisition Mgr.fTransp.
Accounting
,2008.
CYNTHIA A. ELLIS
CIRCUIT COURT JUDGE
JOINT MOTION FOR STIPULATED FINAL JUDGMENT
The Parties hereby stipulate and respectfully request this Court to enter the foregoing
Stipulated Final Judgment as to Parcel 197RDUE.
Date:
BELLA y, PATEL, ESQ.
Florida Bar No. 896489
LAW OFFICE OF BELLA Y. PATEL, PA
13026 Waterford Run Drive
Riverview. FL 33569
(813) 643-2762 - Telephone
(813) 643-2612 - Facsimile
ATTORNEY FOR RESPONDENTS,
MAHAMMED S. SHEIKH & SHAMIM SHEIKH
Date:
ELLEN T. CHADWEL :.&-:;
Florida Bar No. 9838
OFFICE OF THE COUNTY ATTORNEY
Harmon Turner Building, 8th Floor
3301 East Tamiami Trail
Naples, Florida 34112
(239) 774-8400 - Telephone
(239) 252-6300 - Facsimile
ATTORNEY FOR PETITIONER
Agenda Item No. 16K2
February 12, 2008
Page 31 of 36
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Joint Motion on
Stipulated Final Judgment has been furnished by U.S. Mail to all parties listed below on this _
day of
,2008.
ELLEN T. CHADWELL, ESQUIRE
PARCEL I97RDUE
Mahammed S. Sheikh
ShanUm Sheikh
c/o Bella Y. Patel, Esq.
Law Office of Bella Y. Patel. P.A.
13026 Waterford Run Drive
Riverview, FL 33569
Lit..
'ROJECT NO. 60044
'ROJECT PARCEL NO. 197RDUE
"ERPETUAL, NON-EXCLUSIVE ROAD RIGHT -DF-WAY. DRAINAGE AND UTILITY EASEMENT
LEGAL DESCRIPTION & SKETCH EXHIBIT{' 11"
(NOT A SURVEY) --LJ."..
THE WEST 30 FEET OF THE EAST 80 FEET OF THE SOUTH 150
FEET OF THE NORTH 180 FEET OF TRACT 122, GOLDEN GATE
ESTATES UNIT NO. 64, AS RECORDED IN PLAT BOOK 7, PAGE 64
OF THE PUBLIC RECORDS OF COLLIER COUNTY, FLORIDA.
CONTAINING 0.103 ACRES, MORE OR LESS.
-"-"-"-'---'-"-"-"-"-"-"-"-"-"-"-"-"-"-,,-,,-,,-,,-,,-,'-"-"-"-"-'--"--'-'
EAST PROPERTY UNE
I
_L~'s:.~OF
i
I
I
i
EXISTING 100 FOOT WIDE EVERGLADES BOULEVARD R1GKT .QFJNAY (50 FEET)
r"-"-"-"-"-"-"-'-"-"---"-"-"-"- .-..-..-..-.-..-..-..--.
: PROPOSa>AODmONAl RIGHT-oF-WAY (30 FEET)
~.. -. .-..-.. - .._.. - .'-.
I
I
I
PERPETUAL. NON-EXCLUSIVE
ROAD RIGHT.{)F-WAY, DRAINAGE
AND UTIUTY EASEMENT
NORTH PROPERTf UNEI III
SOUTH PROPERTY LINE
THE SOUTH 150 FEET OF THE
NORTH 180 FEET OF TRACT 122
30 FEET:
!4.
I
NORTH
NOT TO.SCALE
eo..""7....-'........&C___
OJ.l3lM}78:59AM
j.o,
Agenda Item No. 161(2
February 12, 2003
Page 32 of 36
Agenda Item No. 16K2
February 12, 2008
Page 33 of 36
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CmCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL ACTION
COLLIER COUNTY, FLORIDA, a
political subdivision of the State of Florida,
Petitioner,
v.
Case No. 07-3200-CA
JOSEPH NOEL, et al.,
Parcel: 189RDUE
Respondents.
/
STIPULATED FINAL JUDGMENT
TIllS CAUSE having come before the Court upon Joint Motion made by Petitioner,
COLLIER COUNTY, FLORIDA, and Respondent, LADONNA K. SCHMIDT, by and through
their undersigned counsel, for entry of a Stipulated Final Judgment as to Parcel l89RDUE, and it
appearing to the Court that the parties are authorized to make such Motion, the Court finding that
the compensation to be paid by Petitioner is the full compensation due the Respondent, LADONNA
K. SCHMIDT, and the Court being otherwise fully advised in the premises, it is thereupon
ORDERED AND ADJUDGED that:
1. Respondent, LADONNA K. SCHMIDT, shall recover from Petitioner, COLLIER
COUNTY, FLORIDA, the sum of Five Thousand Three Hundred Eighty-One and No/IOO
Dollars ($5,381.00) for Parcel l89RDUE, 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 parcel, and all attorney's fees and defense costs. No other costs
and attorney's fees, including supplemental attorney's fees, shall be awarded in this cause.
Agenda Item No. 16K2
February 12, 2008
Page 34 of 36
2. Petitioner will be entitled to a credit in the amount of $1,800.00 for the good faith
deposit made in accordance with the Order of Taking,
3, Title to Parcel l89RDUE in perpetual, non-exclusive Road Right-of-Way, Drainage
and Utility Easement, being fully described in Exhibit "A" attached hereto and incorporated herein,
which vested in Petitioner pursuant to the Order of Taking dated January 4,2008, and the deposit of
money heretofore made, is approved, ratified, and confirmed,
4. The Notice of Lis Pendens filed in the above-styled cause and recorded in Official
Record Book 4281, Page 4054 of the Public Records of Collier County, Florida be dismissed as to
Parcel No. 189RDUE.
5. Within thirty (30) days from receipt of this order, Petitioner shall pay the sum of
Three Thousand Five Hundred Eighty-One and No/I00 Dollars ($3581.00) made payable to
Bella Y. Patel, P.A. Trust Account, c/o Bella y, Patel, Esq" 13026 Waterford Run Drive,
Riverview, FL, 33569, for the benefit ofLaDonna K. Schmidt.
6. Upon entry of this order, the Clerk shall immediately disburse the total amount of
One Thousand Eight Hundred and No/I00 Dollars ($1,800.00), made payable to Bella Y. Patel,
P.A. Trust Account, c/o Bella y, Patel, Esq" 13026 Waterford Run Drive, Riverview, FL, 33569,
for the benefit of LaDonna K. Schmidt and for disbursement of compensation, attomey's fees and
costs.
7, Pursuant to Section 74.051(3), F.S., the Clerk of Courts shall disburse the interest
earned on the funds on deposit in the amount of
, via wire transfer from the Clerk of Courts
to the Board of County Commissioners, Account #
Aaenda Item No. 16K2
- February 12, 2008
Page 35 of 36
9, This Court retains jurisdiction to enforce the terms of this Stipulated Final
Judgment.
,2008.
DONE AND ORDERED in Naples, Florida, this _ day of
conformed copies to:
Ellen T, Chadwell, Esquire
Bella Y. Patel, Esquire
Kevin Hendricks, Acquisition Mgr./Iransp,
Accounting
CYNTHIA A. ELLIS
CIRCUIT COURT JUDGE
JOINT MOTION FOR STIPULATED FINAL JUDGMENT
The Parties hereby stipulate and respectfully request this Court to enter the foregoing
Stipulated Final Judgment as to Parcel I 89RDUE.
Date:
BELLA Y. PATEL, ESQ.
Florida Bar No. 896489
LAW OFFICE OF BELLA Y.PATEL,P.A.
13026 Waterford Run Drive
Riverview, FL 33569
(813) 643-2762 - Telephone
(813) 643-2612 - Facsimile
ATTORNEY FOR RESPONDENT,
LADONNA K. SCHMIDT
Date:
ELLEN T. CHADWELLW
Florida Bar No. 983860
OFFICE OF THE COUNTY ATTORNEY
Harmon Turner Building, 8111 Floor
3301 East Tamiami Trail
Naples, Florida 34112
(239) 774-8400 - Telephone
(239) 252-6300 - Facsimile
ATTORNEY FOR PETITIONER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Joint Motion on
Stipulated Final Judgment has been furnished by U.S. Mail to Bella Y. Patel, Esq., 13026
Waterford Run Drive, Riverview, FL, 33569, on this _ day of , 2008.
Aqenda Item No. 16K2
- February 12. 2008
Page 36 of 36
PROJECT NO, 60044
PROJECT PARCEL NO. 189RDUE
PERPETUAL. NON-EXCLUSIVE ROAD RIGHT-OF-WAY, DRAINAGE AND UTILITY EASEMENT
LEGAL DESCRIPTION & SKETCH
(NOT A SURVEY)
EXHIBITA
..... . ",.
THE WEST 30 FEET OF THE EAST 80 FEET OF THE NORTH 75 FEET
OFTHE SOUTH 150 FEET OF TRACT 118, GOLDEN GATE ESTATES
UNIT NO. 64, AS RECORDED IN PLAT BOOK 7, PAGE 64 OF THE
PUBLIC RECORDS OF COLLIER COUNTY, FLORIDA.
CONTAINING .052 ACRES, MORE OR LESS
--.-..-..-..-.-.--..-..-..-.--..-..-.------.-..-..-..-..-..-..-.---.-..-..-..-..-..-.,-..-..-..
_.._..~~~.~.~.,
EXISTING 100 FOOTWlOEEVERGLADESBOIA.EVARD RIGHT.IJf-WAY (SOfEET)/
".-..- '" PR~'AD6iTlriW.'RiGHr~-WAY(iO FiEri" -., -' -..-.,-..-..-.. -.'-' ._..
.. - .._. ._0. _.._ .._". _0.
PERPE11JAL NON-EXCLUSIVE
ROAD RIGHT -oF-vw\Y, DRAINAGE
AND UTIUlY EASEMENT
NORTH PROPERTY UNE .
SCl/ffi PROPERTY lINE
THE NORTH 75 FEET OF THE
SOUTH 150 FEET OF TRACT 118
z
------- ~
V'"
NOT TO SCALE
IierCOUIY!y Transporllltion Engineemg & ConslnldiIn ~DepaI1menI
03l3OO78:56AM