Agenda 03/08/2022 Item #16K 9 (Selltement Agreement - Amodeo)03/08/2022
EXECUTIVE SUMMARY
Recommendation to approve and authorize the Chair to execute a Settlement Agreement in the
lawsuit styled Agnes M. Amodeo v. Collier County, (Case No. 21-CA-0649), now pending in the
Circuit Court of the Twentieth Judicial Circuit in and for Collier County, Florida, for the sum of
$7,500.
_____________________________________________________________________________________
OBJECTIVE: Recommendation to approve the settlement in the lawsuit filed by Agnes M. Amodeo for
the sum of $7,500 and authorize the Chair to execute the Settlement Agreement.
CONSIDERATIONS: This lawsuit arises out of an accident that occurred on January 11, 2019, at the
intersection of County Barn Road and Davis Boulevard. The Plaintiff was rear-ended by a County
employee in a County vehicle. The Plaintiff had incurred a total of $22,298.77 in medical expenses
related to the accident.
The Plaintiff’s pre-suit settlement demand was $200,000. The parties commenced discovery and
depositions were taken. After extensive settlement negotiations a tentative settlement, contingent upon
Board approval, was reached to resolve the lawsuit for $7,500.
The County Attorney and the Risk Management Director recommend that the Board approve this
settlement as reasonable. Should the case proceed with additional depositions, mediation and trial, the
costs incurred alone are expected to exceed the tentative settlement amount.
FISCAL IMPACT: Funds are budgeted and available in Fund 516, Property & Casualty Insurance Fund
and the total impact will be $7,500.
GROWTH MANAGEMENT IMPACT: None.
LEGAL CONSIDERATIONS: This item is approved as to form and legality and requires a majority
vote for approval. - CAK
RECOMMENDATION: For the Board of County Commissioners to approve and authorize the
Chairman to execute the Settlement Agreement for the total sum of $7,500 in the lawsuit styled Agnes M.
Amodeo v. Collier County, (Case No. 21-CA-0649), now pending in the Circuit Court of the Twentieth
Judicial Circuit in and for Collier County, Florida.
PREPARED BY: Colleen A. Kerins, Assistant County Attorney
ATTACHMENT(S)
1. Settlement Agreement -Amodeo_Redacted (PDF)
16.K.9
Packet Pg. 1203
03/08/2022
COLLIER COUNTY
Board of County Commissioners
Item Number: 16.K.9
Doc ID: 21514
Item Summary: Recommendation to approve and authorize the Chair to execute a Settlement
Agreement in the lawsuit styled Agnes M. Amodeo v. Collier County, (Case No. 21-CA-0649), now
pending in the Circuit Court of the Twentieth Judicial Circuit in and for Collier County, Florida, for the
sum of $7,500.
Meeting Date: 03/08/2022
Prepared by:
Title: Legal Assistant – County Attorney's Office
Name: Rosa Villarreal
03/02/2022 8:45 AM
Submitted by:
Title: County Attorney – County Attorney's Office
Name: Jeffrey A. Klatzkow
03/02/2022 8:45 AM
Approved By:
Review:
Risk Management Jeff Walker Additional Reviewer Completed 03/02/2022 8:51 AM
County Attorney's Office Colleen Kerins Level 2 Attorney Review Completed 03/02/2022 9:02 AM
Office of Management and Budget Debra Windsor Level 3 OMB Gatekeeper Review Completed 03/02/2022 9:11 AM
Office of Management and Budget Susan Usher Additional Reviewer Completed 03/02/2022 10:11 AM
County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 03/02/2022 1:27 PM
County Manager's Office Dan Rodriguez Level 4 County Manager Review Completed 03/02/2022 1:39 PM
Board of County Commissioners Geoffrey Willig Meeting Pending 03/08/2022 9:00 AM
16.K.9
Packet Pg. 1204
16.K.9.aPacket Pg. 1205Attachment: Settlement Agreement -Amodeo_Redacted (21514 : Approve settlement in Amodeo v. Collier County 21-CA-0649)
16.K.9.aPacket Pg. 1206Attachment: Settlement Agreement -Amodeo_Redacted (21514 : Approve settlement in Amodeo v. Collier County 21-CA-0649)
16.K.9.aPacket Pg. 1207Attachment: Settlement Agreement -Amodeo_Redacted (21514 : Approve settlement in Amodeo v. Collier County 21-CA-0649)
16.K.9.aPacket Pg. 1208Attachment: Settlement Agreement -Amodeo_Redacted (21514 : Approve settlement in Amodeo v. Collier County 21-CA-0649)
16.K.9.aPacket Pg. 1209Attachment: Settlement Agreement -Amodeo_Redacted (21514 : Approve settlement in Amodeo v. Collier County 21-CA-0649)
16.K.9.aPacket Pg. 1210Attachment: Settlement Agreement -Amodeo_Redacted (21514 : Approve settlement in Amodeo v. Collier County 21-CA-0649)