Backup Documents 07/13/2021 Item #16K 3 ORIGINAL DOCUMENTS CHECKLIST & ROUTING SLIP
TO ACCOMPANY ALL ORIGINAL DOCUMENTS SENT TO 1 6 K 3
THE BOARD OF COUNTY COMMISSIONERS OFFICE FOR SIGNATURE
Print on pink paper. .'ttach to original document. I he completed routing slip and original documents are to be torssarded to the(ount) Attorney Office
at the time the item is placed on the agenda. All completed routing slips and original documents must be received in the County Attorney Office no later
than Monday preceding the Board meeting.
**NEW** ROUTING SLIP
Complete routing lines#1 through#2 as appropriate for additional signatures,dates,and/or information needed. If the document is already complete with the
exception of the Chairman's signature,draw a line through routing_lines#1 through#2,complete the checklist,and forward to the County Attorney Office.
Route to Addressee(s)(List in routing order) Office Initials Date
1.
2. Risk Management Risk Management
3. County Attorney Office County Attorney Office CAK 7-13-21
4. BCC Office Board of County PT by 7-13-21
Commissioners JMH/s/
5. Minutes and Records Clerk of Court's Office (S
P-I l ��
PRIMARY CONTACT INFORMATION
Normally the primary contact is the person who created/prepared the Executive Summary. Primary contact information is needed in the event one of the
addressees above,may need to contact staff for additional or missing information.
Name of Primary Staff Rosa Villareal/County Attorney's Office Phone 239-252-8400
Contact/ Department
Agenda Date Item was July 13,2021 Agenda Item Number 16K3
Approved by the BCC
Type of Document Settlement Agreement and Mutual Release in the Number of Original 1
Attached lawsuit styled Annette Riddle v.Collier County Documents Attached
Board of County Commissioners(Case No. 19-
CA-0743)
PO number or account
number if document is
to be recorded
INSTRUCTIONS & CHECKLIST
Initial the Yes column or mark"N/A"in the Not Applicable column,whichever is Yes N/A(Not
appropriate. (Initial) Applicable)
1. Does the document require the chairman's original signature? N/A
2. Does the document need to be sent to another agency for additional signatures? If yes, N/A
provide the Contact Information(Name;Agency;Address;Phone)on an attached sheet.
3. Original document has been signed/initialed for legal sufficiency. (All documents to be RV
signed by the Chairman,with the exception of most letters,must be reviewed and signed
by the Office of the County Attorney.
4. All handwritten strike-through and revisions have been initialed by the County Attorney's N/A
Office and all other parties except the BCC Chairman and the Clerk to the Board
5. The Chairman's signature line date has been entered as the date of BCC approval of the RV
document or the final negotiated contract date whichever is applicable.
6. "Sign here"tabs are placed on the appropriate pages indicating where the Chairman's RV
signature and initials are required.
7. In most cases(some contracts are an exception),the original document and this routing slip N/A
should be provided to the County Attorney Office at the time the item is input into SIRE.
Some documents are time sensitive and require forwarding to Tallahassee within a certain
time frame or the BCC's actions are nullified. Be aware of your deadlines!
8. The document was approved by the BCC on July 13,2021 and all changes made RV N/A is not
during the meeting have been incorporated in the attached document. The County an option for
Attorney's Office has reviewed the changes,if applicable. this line.
9. Initials of attorney verifying that the attached document is the version approved by the /A is not
BCC,all changes directed by the BCC have been made,and the document is ready for the option for
Chairman's signature. this line.
16K3
MEMORANDUM
Date: July 15, 2021
To: Rosa Villarreal, Paralegal/ Legal Assistant
County Attorney's Office
From: Teresa Cannon, Sr. Deputy Clerk
Minutes & Records Department
Re: Settlement Agreement w/Riddle
Attached for your records is a scanned copy of the document referenced above, (Item
#16K3) adopted by the Board of County Commissioners on Tuesday, July 13, 2021.
If you have any questions, please call me at 252-8411.
Thank you.
Attachment
16K3
SETTLEMENT AGREEMENT
THIS SETTLEMENT AGREEMENT (hereinafter referred to as the "Agreement") is
entered into and made on this 1344 day of ,ItA lu , 2021, by and between
ANNETTE RIDDLE, hereinafter referred to as "Plaintiff," and COLLIER COUNTY BOARD
OF COUNTY COMMISSIONERS, hereinafter referred to as "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, in the case styled Annette Riddle v.
Collier County Board of Commissioners, Case No. 19-CA-0743 (hereinafter referred to as the
"Lawsuit"); and
WHEREAS, Plaintiff and the County, without either party admitting any liability or
fault, desires 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, accrued or unaccrued, to the incidents
described or allegations made in the complaint filed in the Lawsuit; and,
WHEREAS, Plaintiff and the County desire to reduce the settlement to a writing so that
it shall be binding upon both parties' respective owners, principals, elected officials, officers,
employees, ex-employees, agents, attorneys, representatives, insurers, successors, assigns, heirs,
departments, agencies and affiliates.
NOW, THEREFORE, in consideration of the mutual covenants, promises and
consideration set forth in this Agreement, and with the intent to be legally bound, Plaintiff and
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.
[19-CA-743/1646956/1] 1
16K3
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 ten thousand dollars and 00/100 ($10,000.00) 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 owners, principals, elected
officials, officers, employees, ex-employees, agents, attorneys, contractors, representatives,
successors, assigns, insurers, heirs, departments, agencies and affiliates, from any and all claims,
demands, causes of actions, damages, costs, liens, attorney's fees, expenses, medical bills 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, accrued or
unaccrued, known or unknown, to the Lawsuit or any incident, event or allegation referred to in
the complaint in the Lawsuit.
4. Notwithstanding anything that may be to the contrary in Paragraph 3 of this
Agreement, 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.
5. Plaintiff and the County acknowledge and agree that this Agreement is intended
to and shall be binding upon their respective owners, principals, elected officials, officers,
employees, ex-employees, agents, attorneys, representatives, insurers, successors, assigns, heirs,
and affiliates.
[19-CA-743/1646956/1] 2
16K3
6. Plaintiff and the County recognize and acknowledge that this Agreement
memorializes and states a settlement of disputed claims and nothing in this Agreement 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.
7. Plaintiff and the County acknowledge and agree that this Agreement is the
product of mutual negotiation and no doubtful or ambiguous language or provision in this
Agreement 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.
8. This Agreement may be amended only by a written instrument specifically
referring to this Agreement and executed with the same formalities as this Agreement.
9. In the event of an alleged breach of this Agreement, Plaintiff and the County
agree that all underlying causes of action or claims of Plaintiff have been extinguished by this
Agreement and that the sole remedy for breach of this Agreement shall be for specific
performance of the terms and conditions of this Agreement. 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.
10. This Agreement shall be governed by the laws of the State of Florida.
11. Plaintiff agrees to use the proceeds of the settlement funds for the payment and
satisfaction of all liens, medical bills, attorney fees, and all other expenses, costs, debts, or losses
whatsoever, arising out of or in any way connected to the incident described in the Lawsuit,
which Plaintiff brought or could have brought in the subject Lawsuit. Plaintiff agrees to be
solely responsible for complete payment of these obligations out of the settlement proceeds.
[19-CA-743/1646956/1] 3
Jun 30 21, 02:08p Annette M Riddle 2392130395 p.2
1 6 K 3
IN WITNESS WHEREOF; Plaintiff and the County have signed and sealed this
Agreement and Release as set forth below.
By: ' '
Annette Riddle, Plaintiff
STATE OF FLORIDA
COUNTY OF COLLIER
The foregoing instrument was acknowledged before me by means of 1— physical
presence or online notarization,this3, day of ,2021, by Annette Riddle.
Nik; : ,, TAMMYD.RANDOLPH of Notar blic- to o Florida
.. .�. L MY�EXPIRES:
NH 088097 y(/ { p Ij
t ._" EXPIRES:Peb uory 2, l lL rnm ' �- —ROM l IN+, ?`�"Bonded 7rm,Mossy Public Undennera
,�� (Print, Type, or Stamp Commissioners
Name of Notary Public)
Personally Known OR Produced Identification
Type of Identification Produced:
AS TO COUNTY:
ATTEST:
CRYSTAL K. KINZEL, Clerk BOARD F COUNTY COMMISSIONERS
OF CO I OUNTY, FL DA
By:
Attest,as o Cha iian's envy Tayl , Chairperson
` •
srq *ture qt
Date Date: 31,k\ 13 ' QC) \
Approved"4g18 f and legality
Colleen A. Kerins
Assistant County Attorney
'L19-CA-743/1646956?] 4