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Agenda 07/13/2021 Item #16K11 (Stipukated Final Judgement - Parcel 194FEE)07/13/2021 EXECUTIVE SUMMARY Recommendation to approve a Stipulated Final Judgment in the amount of $120,000, plus $22,085 in statutory attorneys’ fees and expert fees, for the taking of Parcel 194FEE, required for the Vanderbilt Beach Road Extension Project, Project No., 60168. _____________________________________________________________________________________ OBJECTIVE: To settle full compensation for the taking of Parcel 194FEE required for the construction of Vanderbilt Beach Road, Project 60168. CONSIDERATIONS: On September 22, 2020, the Board authorized, via Resolution No. 2020-175, the condemnation of Parcel 194FEE for the construction of roadway, drainage and utility improvements required for the expansion and extension of Vanderbilt Beach Road from Collier Blvd. to east of 16th Street NE, and Massey Street from Vanderbilt Beach Road to south of Mockingbird Dr. The fee simple acquisition area consists of a strip taking along the rear, northerly boundary of the property and is approximately 19,759 square feet (0.45 acres) in size. The parent tract is owned by Steve Stuart Carder and Yvonne Tinnirello, and contains 2.73 acres of gross land area, which will be reduced to 2.28 acres after the acquisition. An aerial photograph of the subject property is attached to this item for reference. The property owners’ appraiser valued the parcel at $195,400. The County’s appraiser estimated full compensation at $82,800 including severance damages. This amount was adjusted to $90,000 to account for the increase in property values between the date of the appraisal and the date of the deposit of funds following the order of taking. The parties participated in Mediation on June 14, 2021. The attached Stipulated Final Judgment reflects a negotiated compensation amount of $120,000, plus $15,543 in statutory attorneys’ fees and costs and $6,542 in expert fees and costs, for a total of $142,085. The Transportation Engineering Division recommends approval of this Stipulated Final Judgment since a better result is not anticipated at trial. Upon approval, the County Attorney’s Office will file the Joint Motion and Stipulated Final Judgment with the Circuit Court. FISCAL IMPACT: The County is entitled to a credit of $82,800 based on its deposit of the good faith estimate of value. Funds for the balance of $59,455, which includes the Clerk’s $170.00 deposit fee, are available in the Vanderbilt Beach Road Expansion Project Capital Fund, Project 60168. The primary funding source for the acquisition is impact fees. Should impact fees not be sufficient within the project, the secondary funding source will be gas taxes. GROWTH MANAGEMENT IMPACT: None. LEGAL CONSIDERATIONS: This item is approved as to form and legality and requires a majority vote for Board approval. - SAA RECOMMENDATION: To approve the attached Joint Motion and Stipulated Final Judgment and authorize the payment of funds as stated herein. PREPARED BY: Robert Bosch, Manager, ROW Acquisition, Transportation Engineering Division, Growth Management Department ATTACHMENT(S) 1. EXECUTED 194FEE SFJ; Tinnerillo 063021(1) (002) (DOCX) 2. Aerial Depiction 194FEE (PDF) 16.K.11 Packet Pg. 2594 07/13/2021 COLLIER COUNTY Board of County Commissioners Item Number: 16.K.11 Doc ID: 17417 Item Summary: Recommendation to approve a Stipulated Final Judgment in the amount of $120,000, plus $22,085 in statutory attorneys’ fees and expert fees, for the taking of Parcel 194FEE, required for the Vanderbilt Beach Road Extension Project, Project No., 60168. Meeting Date: 07/13/2021 Prepared by: Title: Legal Assistant – County Attorney's Office Name: Jessica Hayes 06/30/2021 4:35 PM Submitted by: Title: County Attorney – County Attorney's Office Name: Jeffrey A. Klatzkow 06/30/2021 4:35 PM Approved By: Review: Transportation Engineering Robert Bosch Additional Reviewer Completed 07/01/2021 7:13 AM Transportation Engineering Jay Ahmad Additional Reviewer Completed 07/01/2021 7:22 AM Growth Management Department Trinity Scott Additional Reviewer Completed 07/01/2021 10:07 AM County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 07/01/2021 11:28 AM Office of Management and Budget Debra Windsor Level 3 OMB Gatekeeper Review Completed 07/02/2021 8:39 AM County Attorney's Office Sally Ashkar Level 2 Attorney Review Completed 07/02/2021 2:31 PM Office of Management and Budget Susan Usher Additional Reviewer Completed 07/02/2021 3:19 PM County Manager's Office Amy Patterson Level 4 County Manager Review Completed 07/04/2021 4:40 PM Board of County Commissioners Geoffrey Willig Meeting Pending 07/13/2021 9:00 AM 16.K.11 Packet Pg. 2595 [20-CA-4081/1647227/1] 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, Case No.: 20-CA-4081 v. Parcel 194FEE JOHN E. WENSLEY; ELSY M. WENSLEY; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC; JUAN HUERTA; EVA HUERTA; JUAN HUERTA LAWN MAINTENANCE, INC; SUNCOAST CREDIT UNION; STEVE STUART CARDER; YVONNE TINNIRELLO; ANTHONY MICHAEL LITKA; KIMBERLY ANN VOGELBACH; JEFFREY ENGLISH; PUBLIX EMPLOYEES FEDERAL CREDIT UNION Respondents. ______________________________________________/ JOINT MOTION FOR ENTRY OF A STIPULATED FINAL JUDGMENT AS TO PARCEL 194FEE Petitioner, COLLIER COUNTY, FLORIDA, together with Respondents, STEVE STUART CARDER AND YVONNE TINNIRELLO, by and through undersigned counsel, hereby respectfully move this Court for the entry of the foregoing Stipulated Final Judgment as to Parcel 194FEE attached hereto as Exhibit “1”. ___________________________ SALLY A. ASHKAR, ESQ. Florida Bar No. 1007665 Collier County Attorney’s Office 3299 E. Tamiami Tr., Suite 800 Naples, FL 34112 Telephone: (239) 252-8400 COUNSEL FOR PETITIONER Sally.Ashkar@colliercountyfl.gov Sheri.Malcolm@colliercountyfl.gov _/s/ JOHN M. LEROUX________ JOHN M. LEROUX, ESQ. Florida Bar No. 773166 3090 Charles Ave., Suite 200 Clearwater, FL 33761 Telephone: (727) 712-1137 COUNSEL FOR RESPONDENT(S) john@jmleroux.com pleadings@jmleroux.com 16.K.11.a Packet Pg. 2596 Attachment: EXECUTED 194FEE SFJ; Tinnerillo 063021(1) (002) (17417 : Stipulated Final Judgment in the amount of $120,000) [20-CA-4081/1647227/1] CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the Joint Motion for Entry of a Stipulated Final Judgment was filed with the FL Courts E-Filing Portal on this ___ day of July 2021. By:________________________ SALLY A. ASHKAR, ESQ. 16.K.11.a Packet Pg. 2597 Attachment: EXECUTED 194FEE SFJ; Tinnerillo 063021(1) (002) (17417 : Stipulated Final Judgment in the amount of $120,000) [20-CA-4081/1647227/1] 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, Case No.: 20-CA-4081 v. Parcel 194FEE JOHN E. WENSLEY; ELSY M. WENSLEY; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC; JUAN HUERTA; EVA HUERTA; JUAN HUERTA LAWN MAINTENANCE, INC; SUNCOAST CREDIT UNION; STEVE STUART CARDER; YVONNE TINNIRELLO; ANTHONY MICHAEL LITKA; KIMBERLY ANN VOGELBACH; JEFFREY ENGLISH; PUBLIX EMPLOYEES FEDERAL CREDIT UNION Respondents. ______________________________________________/ STIPULATED FINAL JUDGMENT AS TO PARCEL 194FEE THIS CAUSE, having come before this Court upon the Joint Motion made by Petitioner, COLLIER COUNTY, FLORIDA, and Respondents, STEVE STUART CARDER AND YVONNE TINNIRELLO, by and through counsel, for the entry of a Stipulated Final Judgment as to Parcel 194FEE for Project 60168, and it appearing to this Court that proper notice was given to the parties having any equity, lien, title, or other interest in or to the real property described therein, and the Court being otherwise fully advised in the premises thereof, it is ORDERED AND ADJUDGED that: 1. Respondents, STEVE STUART CARDER AND YVONNE TINNIRELLO, shall recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of One Hundred Twenty Thousand and No/100 Dollars ($120,000.00) for Parcel 194FEE, as full payment for the property interest taken, in connection with said parcel. 2. Respondent, STEVE STUART CARDER AND YVONNE TINNIRELLO, shall recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Fifteen Thousand Five Hundred Forty-Three and No/100 Dollars ($15,543.00), for all attorney fees and costs 16.K.11.a Packet Pg. 2598 Attachment: EXECUTED 194FEE SFJ; Tinnerillo 063021(1) (002) (17417 : Stipulated Final Judgment in the amount of $120,000) [20-CA-4081/1647227/1] associated with the acquisition of Parcel 194FEE, and no other attorney’s fees or costs will be paid in connection with this Parcel. 3. Respondent, STEVE STUART CARDER AND YVONNE TINNIRELLO, shall recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Six Thousand Five Hundred Forty-Two Dollars and No/100 Dollars ($6,542.00), for all expert fees and costs associated with the acquisition of Parcel 194FEE, and no other expert fees or costs shall be paid in this matter. 4. Petitioner, COLLIER COUNTY, FLORIDA, is entitled to a credit for the good faith estimate of value previously deposited in the amount of Eighty-Two Thousand Eight Hundred and No/100 Dollars ($82,800.00), as payment for the acquisition of Parcel 194FEE, at which time title to said parcel as described in Exhibit “A” vested in the name of Petitioner COLLIER COUNTY, FLORIDA. 5. Within thirty (30) days from the entry of this Order, Petitioner, COLLIER COUNTY, FLORIDA, shall issue a check made payable to the Law Offices of John M. LeRoux, P.A. Trust Account in the total sum of Fifty-Nine Thousand Two Hundred Eighty-Five and No/100 Dollars ($59,285.00), and deliver said check to the Law Offices of John M. LeRoux, P.A., 3090 Charles Avenue, Suite 200, Clearwater, Florida 33761. 6. This Order disposes of all claims arising out of the taking of Parcel 194FEE that have or could have been asserted in this cause. 7. A fee simple taking, being fully described in Exhibit “A” attached hereto and incorporated herein, which vested in Petitioner pursuant to the Stipulated Order of Taking dated May 10, 2021, and the deposit of money heretofore made, is approved, ratified, and confirmed. 8. Petitioner will construct the project in substantial conformance with the ninety percent (90%) construction plans for the project, which plans are incorporated herein by reference. Respondent understands and agrees that this Stipulated Final Judgment contemplates the future 6- 16.K.11.a Packet Pg. 2599 Attachment: EXECUTED 194FEE SFJ; Tinnerillo 063021(1) (002) (17417 : Stipulated Final Judgment in the amount of $120,000) [20-CA-4081/1647227/1] laning of Vanderbilt Beach Road (VBR). No additional compensation shall be due to Respondent for the widening of VBR up to 6-lanes. 9. The Notice of Lis Pendens filed in this cause and recorded in Official Record Book 5868, Page 1418 of the Public Records of Collier County, Florida is hereby dismissed as to Parcel 194FEE. 10. This Court reserves jurisdiction to enforce the terms of this Stipulated Final Judgment. 11. This Stipulated Final Judgment is to be recorded in the Official Records of Collier County, Florida. DONE AND ORDERED in Chambers, Naples, Collier County, Florida, on this ____ day of ____________, 2021. _____________________________________ THE HONORABLE LAUREN L. BRODIE Circuit Court Judge Exhibit “A” 16.K.11.a Packet Pg. 2600 Attachment: EXECUTED 194FEE SFJ; Tinnerillo 063021(1) (002) (17417 : Stipulated Final Judgment in the amount of $120,000) AERIAL – PARCEL 194FEE VANDERBILT BEACH RD EXT PROJECT 60168 PARCEL 194FEE /  16.K.11.b Packet Pg. 2601 Attachment: Aerial Depiction 194FEE (17417 : Stipulated Final Judgment in the amount of $120,000)