Agenda 04/26/2022 Item #16K 7 (Settlement Agreement in lawsuit - Husseini)04/26/2022
EXECUTIVE SUMMARY
Recommendation to approve and authorize the Chair to execute a Settlement Agreement in the
lawsuit styled Farris Husseini v. Collier County Board of Commissioners (Case No. 20-CA-2596),
now pending in the Circuit Court of the Twentieth Judicial Circuit in and for Collier County,
Florida, for the sum of $35,000.
_____________________________________________________________________________________
OBJECTIVE: Recommendation to approve the settlement in the lawsuit filed by Farris Husseini for the
sum of $35,000 and authorize the Chair to execute the Settlement Agreement.
CONSIDERATIONS: This lawsuit arises out of a slip and fall accident that occurred on September 17,
2016, at the Collier County Museum located at 3331 Tamiami Trail East, Naples. The Plaintiff alleges
that while walking towards an exhibit on the museum grounds, he slipped on accumulated green
mildew/mold/moss that was on the walking path and he suffered injuries to his neck, lower back, and
ankle.
The Plaintiff alleged total medical costs of $67,282.37, in addition to his claim for future medical
treatment. The Plaintiff’s pre-suit settlement demand was $200,000. The parties commenced discovery.
After extensive settlement negotiations a tentative settlement, contingent upon Board approval, was
reached to resolve the lawsuit for $35,000.
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 $35,000.
GROWTH MANAGEMENT IMPACT: None.
LEGAL CONSIDERATIONS: This item is approved as to form and legality and requires a majority
vote for approval.
RECOMMENDATION: For the Board of County Commissioners to approve and authorize the
Chairman to execute the Settlement Agreement for the total sum of $35,000 in the lawsuit styled Farris
Husseini v. Collier County Board of Commissioners (Case No. 20-CA-2596), 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. executed settlement agreement_Redacted (PDF)
16.K.7
Packet Pg. 1606
04/26/2022
COLLIER COUNTY
Board of County Commissioners
Item Number: 16.K.7
Doc ID: 21923
Item Summary: Recommendation to approve and authorize the Chair to execute a Settlement
Agreement in the lawsuit styled Farris Husseini v. Collier County Board of Commissioners (Case No. 20-
CA-2596), now pending in the Circuit Court of the Twentieth Judicial Circuit in and for Collier County,
Florida, for the sum of $35,000.
Meeting Date: 04/26/2022
Prepared by:
Title: Legal Assistant – County Attorney's Office
Name: Rosa Villarreal
04/11/2022 3:26 PM
Submitted by:
Title: County Attorney – County Attorney's Office
Name: Jeffrey A. Klatzkow
04/11/2022 3:26 PM
Approved By:
Review:
Risk Management Jeff Walker Additional Reviewer Completed 04/11/2022 3:30 PM
County Attorney's Office Colleen Kerins Level 2 Attorney Review Completed 04/11/2022 4:23 PM
Office of Management and Budget Debra Windsor Level 3 OMB Gatekeeper Review Completed 04/12/2022 8:29 AM
County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 04/13/2022 11:57 AM
Office of Management and Budget Susan Usher Additional Reviewer Completed 04/15/2022 11:13 AM
County Manager's Office Amy Patterson Level 4 County Manager Review Completed 04/15/2022 1:53 PM
Board of County Commissioners Geoffrey Willig Meeting Pending 04/26/2022 9:00 AM
16.K.7
Packet Pg. 1607
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Packet Pg. 1608 Attachment: executed settlement agreement_Redacted (21923 : Approval of settlement agreement in Farris Husseini v. Collier County 20-CA-
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Packet Pg. 1609 Attachment: executed settlement agreement_Redacted (21923 : Approval of settlement agreement in Farris Husseini v. Collier County 20-CA-
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Packet Pg. 1610 Attachment: executed settlement agreement_Redacted (21923 : Approval of settlement agreement in Farris Husseini v. Collier County 20-CA-
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Packet Pg. 1611 Attachment: executed settlement agreement_Redacted (21923 : Approval of settlement agreement in Farris Husseini v. Collier County 20-CA-
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Packet Pg. 1612 Attachment: executed settlement agreement_Redacted (21923 : Approval of settlement agreement in Farris Husseini v. Collier County 20-CA-
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Packet Pg. 1613 Attachment: executed settlement agreement_Redacted (21923 : Approval of settlement agreement in Farris Husseini v. Collier County 20-CA-