Agenda 05/10/2022 Item #16K 5 (Compensation for Taking of Parcels for Vanderbilt Rd Extension Project No. 60168 )16. K.5
05/10/2022
EXECUTIVE SUMMARY
Recommendation to approve a Stipulated Final Judgment in the total amount of $1,500,000 plus
$246,075 in statutory attorney and experts' fees and costs, for the taking of Parcels 113POND,
113TDRE, 129FEE1, 129FEE2 and 327FEE, required for the Vanderbilt Beach Road Extension
Project No. 60168.
OBJECTIVE: To settle full compensation for the taking of Parcels 113POND, 113TDRE, 129FEE1,
129FEE2 and 327FEE required for the construction of the Vanderbilt Beach Road Extension Project No.
60168.
CONSIDERATIONS: On September 22, 2020, the Board authorized, via Resolution No. 2020-175, the
condemnation of Parcels 113POND, 113TDRE, 129FEE1, 129FEE2 and 327FEE for the construction of
roadway, drainage and utility improvements required for the expansion and extension of Vanderbilt Beach
Road from Collier Boulevard to east of 16' Street NE and Massey Street from Vanderbilt Beach Road to
south of Mockingbird Drive. The parent tract is owned by Gerald W. McCollum and Syble W. McCollum
and consists of three contiguous parcels of land containing a total area of 56.36 acres, which will be
reduced to 50.33 acres after the acquisition. The fee simple acquisition areas (Parcels 113POND,
129FEE1, 129FEE2 and 327FEE) consist of takings along the southerly and westerly boundaries of the
property and total approximately 6.04 acres in extent. The temporary driveway restoration easement
(Parcel 113TDRE) is located on the westerly side of the property and is approximately 0.05 acres in
extent. An aerial photograph of the subject property depicting the approximate location of the parcels
taken is attached.
The County's appraiser estimated full compensation at $1,272,600. The property owner's initial demand
was $2,072,800 plus attorney's fees and expert fees and costs. The parties participated in mediation and
reached an agreement. The attached Stipulated Final Judgment reflects a negotiated compensation amount
of $1,500,000, plus $198,075 in statutory attorney's fees and $48,000 in expert fees and costs, for a total
of $1,746,075.
The reason for these appraisal and settlement figures is three -fold:
(1) The size and location of the property. The property is very large, consisting of 50.33 acres
after the acquisition, and has a favorable location close to Collier Blvd. (SR 951) with frontage on
both Vanderbilt Beach Rd and Massey St. It is the last property of its size on Vanderbilt Beach
Rd., west of Everglades Blvd.;
(2) The potential for the property. Appraisers are required by Florida law to estimate full
compensation based upon the highest and best use of the property. The County's appraiser agreed
that the highest and best use of this property is a residential or commercial development; and
(3) Executed offer to purchase the property. The property owners presented the County with a
duly executed letter of intent with a national developer, who has operated in Collier County for
many years, proposing to develop a residential community of at least 130 single-family homes on
the property. The agreement far exceeded the price -per -acre of the County's appraisal and would
be admissible at trial.
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 $799,600 for its deposit of the good faith
estimate of value. Funds for the balance of $946,645, which includes the Clerk's $170.00 deposit fee, are
available in the Vanderbilt Beach Road Extension Project Capital Fund, Project 60168. The primary
Packet Pg. 995
16. K.5
05/10/2022
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.
Cei:Z1111AM:1uElleff i11uIDiem rlUIW.TomI ern i -
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
ATTACHMENT(S)
1. Aerial Maps - McCollum Parcels - 113POND, etc. (PDF)
2.20-CA-3586 (DOCX)
3.21-ca-658 and 21-ca-314 (DOCX)
Packet Pg. 996
16. K.5
05/10/2022
COLLIER COUNTY
Board of County Commissioners
Item Number: 16.K.5
Doe ID: 22108
Item Summary: Recommendation to approve a Stipulated Final Judgment in the total amount of
$1,500,000 plus $246,075 in statutory attorney and experts' fees and costs, for the taking of Parcels
113POND, 113TDRE, 129FEE1, 129FEE2 and 327FEE, required for the Vanderbilt Beach Road
Extension Project No. 60168.
Meeting Date: 05/10/2022
Prepared by:
Title: — County Attorney's Office
Name: Madison Bird
05/02/2022 11:44 AM
Submitted by:
Title: County Attorney — County Attorney's Office
Name: Jeffrey A. Klatzkow
05/02/2022 11:44 AM
Approved By:
Review:
Transportation Engineering
Robert Bosch
Additional Reviewer
Transportation Engineering
Jay Ahmad
Additional Reviewer
Growth Management Department
Lisa Taylor
Additional Reviewer
Growth Management Operations Support
Tara Castillo
Growth Management Department
Trinity Scott
Transportation
County Attorney's Office
Sally Ashkar
Level 2 Attorney Review
Office of Management and Budget
Debra Windsor
Level 3 OMB Gatekeeper Review
Office of Management and Budget
Susan Usher
Additional Reviewer
County Attorney's Office
Jeffrey A. Klatzkow Level 3 County Attorney's Office Review
County Manager's Office
Dan Rodriguez
Level 4 County Manager Review
Board of County Commissioners
Geoffrey Willig
Meeting Pending
Completed
05/02/2022 12:10 PM
Completed
05/02/2022 12:31 PM
Completed
05/02/2022 1:29 PM
Additional Reviewer
Completed
Completed
05/02/2022 2:18 PM
Completed
05/02/2022 4:52 PM
Completed
05/03/2022 8:16 AM
Completed
05/03/2022 10:44 AM
Completed
05/03/2022 11:18 AM
Completed
05/03/2022 4:48 PM
05/10/2022 9:00 AM
Packet Pg. 997
leuid pe4eindi4g a anojddV : 80LZZ) 'owaNOdM - slaoaed wnlioOoW - sdeW jep9v :;uawLjae;;y
LLI
w
LL.
r
N
M
ad
N
w
w
LL co
rn m
N �
� O
O
W O
LWL Z
H
°1 U
LLI
n
o a
M O
t--w`A-
iBs shop ��� _ — -� a •r s
.tr •� .:. :� _
� I 0. �• � s N �f � L
9 r • �'• 04
N
' �� t � ►�.�a`� t,� art .� � _ E • d
V� {.rM- • 40
asj.' s ('w R N 0
LU
LLI
O h
LLI ~ • J ty LLI
L) y
M 'rLLI CL
ALk IL
ONES-
� �� W �~ •K•4:i f� 1
ui 4 r • �
u..
eagle WAY- - ilm'.
_
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-3586
V. Parcels 129FEE1 and 129FEE2
GERALD W. MCCOLLUM; SYBLE W. MCCOLLUM;
PATRICK PLUNKETT; GRAYSEN P. JOHNSON, II
PERSEPHONE JOHNSON, MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, INC, WELLS FARGO
BANK, NA, SUCCESSOR IN INTEREST TO WACHOVIA
BANK, NA; MOHAN SITLANI, TRUSTEE, SITLANI TRUST
DATED NOVEMBER 7, 2006, AS AMENDED AND RESTATED
Respondents.
JOINT MOTION FOR ENTRY OF A STIPULATED FINAL JUDGMENT AS TO
PARCELS 129FEE1 and 129FEE2 *
Petitioner, COLLIER COUNTY, FLORIDA, together with Respondents, GERALD W.
MCCOLLUM AND SYBLE W. MCCOLLUM, by and through undersigned counsel, hereby
respectfully move this Court for the entry of the foregoing Stipulated Final Judgment as to
Parcels 129FEE1 and 129FEE2 attached hereto as Exhibit 1.
COLLEEN M. GREENE, ESQ.
Florida Bar No. 502650
Collier County Attorney's Office
3299 E. Tamiami Tr., Suite 800
Naples, FL 34112
Telephone: (239) 252-8400
COUNSEL FOR PETITIONER
Colleen. Greenekcolliercountyfl. gov
Sheri.Malcolm(kcolliercountfl.gov
Al CHARLES R. FORMAN
C14ARLES R. FORMAN, ESQ.
Florida Bar No. 229253
1301 NE 14a' Street
Ocala, Florida 34470
Tele. (352) 732-3915
COUNSEL FOR RESPONDENTS
crforman(a-,hotmail. com
SHarriskformanthomaslaw.com
* This joint motion is the result of a settlement agreement for cases 20-CA-3586 (Parcels 129FEE1 and 129FEE2); 21-CA-314 (Parcel 327FEE);
and 21-CA-658 (Parcel 113POND/TDRE). The total compensation for these parcels is $1,500,000.00 to Respondents McCollum; $198,075.00 in
attorney's fees; and $48,000.00 in expert fees. For filing purposes only, the amounts were divided per case.
M
N
W
W
a_
CD
N
T-
W
W
a_
CD
N
T
ui
0
F-
M
T
T
Packet Pg. 999
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
2022.
II
COLLEEN M. GREENE, ESQ
* This joint motion is the result of a settlement agreement for cases 20-CA-3586 (Parcels 129FEE1 and 129FEE2); 21-CA-314 (Parcel 327FEE);
and 21-CA-658 (Parcel 113POND/TDRE). The total compensation for these parcels is $1,500,000.00 to Respondents McCollum; $198,075.00 in
attorney's fees; and $48,000.00 in expert fees. For filing purposes only, the amounts were divided per case.
M
N
LU
LU
LL
CD
N
T-
LU
LU
LL
CD
N
T
LLI
o:
0
F-
M
T
T
Packet Pg. 1000
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-3586
V. Parcels 129FEE1 and 129FEE2
GERALD W. MCCOLLUM; SYBLE W. MCCOLLUM;
PATRICK PLUNKETT; GRAYSEN P. JOHNSON, II
PERSEPHONE JOHNSON, MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, INC, WELLS FARGO
BANK, NA, SUCCESSOR IN INTEREST TO WACHOVIA
BANK, NA; MOHAN SITLANI, TRUSTEE, SITLANI TRUST
DATED NOVEMBER 7, 2006, AS AMENDED AND RESTATED
Respondents.
STIPULATED FINAL JUDGMENT AS TO PARCELS 129FEE1 and 129FEE2*
THIS CAUSE, having come before this Court upon the Joint Motion made by Petitioner,
COLLIER COUNTY, FLORIDA, and Respondents, GERALD W. MCCOLLUM AND SYBLE
W. MCCOLLUM, by and through counsel, for the entry of a Stipulated Final Judgment as to
Parcels 129FEE1 and 129FEE2 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:
Respondents, GERALD W. MCCOLLUM AND SYBLE W. MCCOLLUM, shall
00
LO
recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Five Hundred T
Thousand and No/100 Dollars ($500,000.00) for Parcels 129FEE 1 and 129FEE2, as full N
c
payment for the property interest taken, including any and all business damages, in connection z
with said parcel. a
* This joint motion is the result of a settlement agreement for cases 20-CA-3586 (Parcels 129FEE1 and 129FEE2); 21-CA-314 (Parcel 327FEE);
and 21-CA-658 (Parcel 113POND/TDRE). The total compensation for these parcels is $1,500,000.00 to Respondents McCollum; $198,075.00 in
attorney's fees; and $48,000.00 in expert fees. For filing purposes only, the amounts were divided per case.
Packet Pg. 1001
2. Respondents, GERALD W. MCCOLLUM AND SYBLE W. MCCOLLUM, shall
recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Sixty -Six Thousand
Twenty -Five and No/100 Dollars ($66,025.00), for all attorney fees and costs associated with the
acquisition of Parcels 129FEE 1 and 129FEE2. No other attorney's fees or costs will be paid in
this matter.
3. Respondents, GERALD W. MCCOLLUM AND SYBLE W. MCCOLLUM, shall
recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Sixteen Thousand
Dollars and No/100 Dollars ($16,000.00), for all expert fees and costs associated with the
acquisition of Parcels 129FEE 1 and 129FEE2, 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 Seventy -Two Thousand Six
Hundred Dollars and No/100 ($72,600.00), as payment for the acquisition of Parcels 129FEE1
and 129FEE2, 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 pay the total sum of Five Hundred Nine Thousand Four Hundred
Twenty -Five Dollars and No/100 ($509,425.00), as payment for acquisition of Parcels 129FEE1
and 129FEE2, attorney's fees, costs, and expert fees, by issuing a check payable Forman &
Thomas Trust Account, and mailing it to Charles R. Forman, Esq., 1301 NE 14t' Street, Ocala, FL
34470.
6. Petitioner will construct the project in substantial conformance with the one
hundred percent (100%) construction plans for the project, which plans are incorporated herein by
* This joint motion is the result of a settlement agreement for cases 20-CA-3586 (Parcels 129FEE1 and 129FEE2); 21-CA-314 (Parcel 327FEE);
and 21-CA-658 (Parcel 113POND/TDRE). The total compensation for these parcels is $1,500,000.00 to Respondents McCollum; $198,075.00 in
attorney's fees; and $48,000.00 in expert fees. For filing purposes only, the amounts were divided per case.
co
00
LO
Cl?
Q
0
N
r
c
d
E
z
a
Packet Pg. 1002
reference.
7. This Order disposes of all claims arising out of the taking of Parcels 129FEE1 and
129FEE2, that have or could have been asserted in this cause.
8. 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
June 11, 2021, and the deposit of money heretofore made, is approved, ratified, and confirmed.
9. The Notice of Lis Pendens filed in this cause and recorded in Official Record Book
5847, Page 3545 of the Public Records of Collier County, Florida be dismissed as to Parcels
129FEE 1 and 129FEE2.
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.
Exhibit "A"
LEGAL DESCRIPTION (PARCEL 129 FEE1)
A PORTION OF THE SOUTH HALF OF THE SOUTHEAST QUARTER OF THE SOUTHWEST QUARTER OF SECTION 38. TOWNSHIP 48
SOUTH, RANGE 28 EAST, COLDER COUNTY, FLORIDA, BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS:
COMMENCING AT THE SOUTHEAST CORNER OF THE SOUTHWEST QUARTER Of SAID SECTION 36;
THENCE S.8754'51'W., ALONG THE SOUTH LINE OF SAID SECTION 35, FOR 814.91 FEET;
THENCE N.0706"I S'K, FOR 59.91 FEET TO A POINT ON A LINE LYING 50 FEET NORTH OF AND PARALLEL TO THE SOUTH LINE
OF SAID SECTION 36 AND THE POINT OF BEGINNING OF THE HEREIN DESCRIBED PARCEL;
THENCE S.69'54'28'W.. ALONG SAID PARALLEL LINE. FOR 510.79 FEET TO A POINT ON THE WEST LINE OF THE SOUTHEAST
QUARTER OF THE SOUTHWEST QUARTER OF SAID SECTON M: p
THENCE N_0224'19'W., ALONG SAID WEST LINE. FOR 21.90 FEET TO A POINT ON A CURVE; T—
THENCE EASTERLY 91,44 FEET ALONG THE ARC OF A W)N—TANGENTIAL CURVE TO THE RIGHT HAVING A RADUS OF 6,035.00 N
FEET THROUGH A CENTRAL ANGLE OF 00'52'05' AND BEING SUBTENDED BY A CHORD WHICH BEARS 5.86'29'09"E. FOR 91.44
FEET TO A POINT OF REVERSE CURVATURE; co
THENCE EASTERLY 420.76 FEET ALONG THE ARC OF A REVERSE CURVE TO THE LEFT HAVING A RADIUS OF 5.965.00 FEET 00
THROUGH A CENTRAL ANGLE OF 04'02'29' AND BEING SUBTENDED BY A CHORD WHICH BEARS S.88'04'21'E. FOR 420.67 FEET; M
THENCE S.00'28'32E., FOR 1.31 FEET;
THENCE N.90C10'40E., FOR D.DO FEET TO THE POINT OF BEGINNING Of THE PARCEL DESCRIBED HEREIN; V
CONTAINING 4,416 SQUARE FEET MORE OR LESS. N
BEARINGS ARE BASED ON STATE PLANE COORDINATES, FLORIDA EAST ZONE. ` tie, ,
d
E
t
t�
c0
a
* This joint motion is the result of a settlement agreement for cases 20-CA-3586 (Parcels 129FEE1 and 129FEE2); 21-CA-314 (Parcel 327FEE);
and 21-CA-658 (Parcel 113POND/TDRE). The total compensation for these parcels is $1,500,000.00 to Respondents McCollum; $198,075.00 in
attorney's fees; and $48,000.00 in expert fees. For filing purposes only, the amounts were divided per case.
Packet Pg. 1003
LEGAL DESCRIPTION (PARCEL 129 FEE2)
A PORTION SOUTHWEST QUARTER OF SECTION 36, TOWNSHIP 48 SOUTH, RANGE 26 EAST, COLLIER COUNTY, FLORIDA.
BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS:
COMMENCING AT THE SOUTHEAST CORNER OF THE SOUTHWEST QUARTER OF SAJO SECTION 36;
THENCE N,02'31'16"W_. ALONG THE EAS7 LINE OF SAID SOUTHWEST QUARTER, FOR 60.05 FEET TO A POINT ON A
LINE LYING 60 FEET NORTHERLY OF AND PARALLEL TO THE SOUTH LINE OF SAID SECTION 36, AND THE POT y OF
BEGINNING OF THE PARCEL HEREIN DESCRIBED,
THENCE S.8754'28"W., ALONG SAID PARALLEL LINE, FOR 51.09 FEET;
THENCE N.00'02'54W., FOR 124.02 FEET;
THENCE N.89'58'35*E„ FOR 45.74 FEET TO A POINT ON SAID EAST LINE; 0
THENCE S,02'31'16"E., ALONG SAID EAST LINE, FOR 124.08 FEET TO THE POINT OF BEGI3yN�Q$.
DESCRIBED HEREIN -
CONTAINING
`•
CONTAINING 6,003 SQUARE FEET, MORE OR LESS. •�, �itSflC�f6)
BEARINGS ARE BASED ON STATE PLANE COORDINATES, FLORIDA EAST ZONE.
co
00
LO
Cl?
a
O
N
C
d
E
t
C�
c0
a
* This joint motion is the result of a settlement agreement for cases 20-CA-3586 (Parcels 129FEE1 and 129FEE2); 21-CA-314 (Parcel 327FEE);
and 21-CA-658 (Parcel 113POND/TDRE). The total compensation for these parcels is $1,500,000.00 to Respondents McCollum; $198,075.00 in
attorney's fees; and $48,000.00 in expert fees. For filing purposes only, the amounts were divided per case.
Packet Pg. 1004
16. K.5.c
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.: 21-CA-658
Parcel 113POND/TDRE
DORIS L. BENDER, TRUSTEE OF THE GEORGE BENDER
REVOCABLE TRUST AGREEMENT DATED OCTOBER 23, 1997;
GERALD W. MCCOLLUM; SYBLE W. MCCOLLUM; RICHARD
L. VANDERHORST; LESLIE K. VANDERHORST; DANIEL
D. GOTTWALD; PATSY L. GOTTWALD; NEW RESIDENTIAL
MORTGAGE, LLC; ROBERT J. GREENLING, JR; SUNCOAST
SCHOOLS FEDERAL CREDIT UNION; DISCOVER BANK
Respondents.
COLLIER COUNTY, FLORIDA, a political subdivision of
the State of Florida,
Petitioner,
V.
Case No.: 21-CA-314
Parcel 327FEE
WAYNE MCCOLLUM; SYBLE MCCOLLUM; BENJAMIN GARCIA
RAQUEL GARCIA; MARIA GARCIA; JOSE GARCIA; WELLS
FARGO BANK SUCCESSOR IN INTEREST TO WACHOVIA
BANK, SUCCESSOR IN INTEREST TO WORLD SAVINGS BANK, FSB;
GRANT C. BONSER; MARY C. BONSER; CALIBER HOME LOANS;
ALPHA FOUNDATION SPECIALISTS, INC; MATTHEW SHANLEY;
CNR AIR CONDITIONING, INC; MARIANNE R. ZEITLER; US BANK
NATIONAL TRUST ASSOCIATION, NOT IN ITS OFFICIAL CAPACITY
BUT SOLELY AS OWNER TRUSTEE FOR LEGACY MORTGAGE
ASSET TRUST 2018-RPL2; MFC INVESTMENTS, LLC
Respondents.
JOINT MOTION FOR ENTRY OF A STIPULATED FINAL JUDGMENT AS TO
PARCELS 113POND/TDRE AND 327FEE *
Petitioner, COLLIER COUNTY, FLORIDA, together with Respondents, GERALD W.
* This joint motion is the result of a settlement agreement for cases 20-CA-3586 (Parcels 129FEE1 and 129FEE2); 21-CA-314 (Parcel
327FEE); and 21-CA-658 (Parcel 113POND/TDRE). The total compensation for these parcels is $1,500,000.00 to Respondents
McCollum; $198,075.00 in attorney's fees; and $48,000.00 in expert fees. For filing purposes only, the amounts were divided per
case.
c
M
N
W
W
LL
CD
N
r
r
W
W
LL
CD
N
r
L
0
M
r
r
Packet Pg. 1005
16. K.5.c
MCCOLLUM AKA WAYNE MCCOLLUM; AND SYBLE W. MCCOLLUM AKA SYBLE
MCCOLLUM, by and through undersigned counsel, hereby respectfully move this Court for the
entry of the foregoing Stipulated Final Judgment as to Parcels I I3POND/TDRE in case 21-CA-
658, and Parcel 327FEE in case 21-CA-314attached hereto as Exhibit 1.
COLLEEN M. GREENE, ESQ.
Florida Bar No. 502650
Collier County Attorney's Office
3299 E. Tamiami Tr., Suite 800
Naples, FL 34112
Telephone: (239) 252-8400
COUNSEL FOR PETITIONER
Colleen. Greenekcolliercountyfl. gov
Sheri.Malcohnkcolliercountfl.gov
Al CHARLES R. FORMAN
CHARLES R. FORMAN, ESQ.
Florida Bar No. 229253
1301 NE 14th Street
Ocala, Florida 34470
Tele. (352) 732-3915
COUNSEL FOR RESPONDENTS
crformankhotmail. com
sharriskformanthomaslaw. com
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
2022.
M.
COLLEEN M. GREENE, ESQ
* This joint motion is the result of a settlement agreement for cases 20-CA-3586 (Parcels 129FEE1 and 129FEE2); 21-CA-314 (Parcel
327FEE); and 21-CA-658 (Parcel 113POND/TDRE). The total compensation for these parcels is $1,500,000.00 to Respondents
McCollum; $198,075.00 in attorney's fees; and $48,000.00 in expert fees. For filing purposes only, the amounts were divided per
case.
c
M
N
W
W
LL
CD
N
T
W
W
LL
CD
N
T
W
0
M
T
Packet Pg. 1006
16. K.5.c
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.: 21-CA-658
Parcel 113POND/TDRE
DORIS L. BENDER, TRUSTEE OF THE GEORGE BENDER
REVOCABLE TRUST AGREEMENT DATED OCTOBER 23, 1997;
GERALD W. MCCOLLUM; SYBLE W. MCCOLLUM; RICHARD
L. VANDERHORST; LESLIE K. VANDERHORST; DANIEL
D. GOTTWALD; PATSY L. GOTTWALD; NEW RESIDENTIAL
MORTGAGE, LLC; ROBERT J. GREENLING, JR; SUNCOAST
SCHOOLS FEDERAL CREDIT UNION; DISCOVER BANK
Respondents.
COLLIER COUNTY, FLORIDA, a political subdivision of
the State of Florida,
Petitioner,
V.
Case No.: 21-CA-314
Parcel 327FEE
WAYNE MCCOLLUM; SYBLE MCCOLLUM; BENJAMIN GARCIA
RAQUEL GARCIA; MARIA GARCIA; JOSE GARCIA; WELLS
FARGO BANK SUCCESSOR IN INTEREST TO WACHOVIA
BANK, SUCCESSOR IN INTEREST TO WORLD SAVINGS BANK, FSB;
GRANT C. BONSER; MARY C. BONSER; CALIBER HOME LOANS;
ALPHA FOUNDATION SPECIALISTS, INC; MATTHEW SHANLEY;
CNR AIR CONDITIONING, INC; MARIANNE R. ZEITLER; US BANK
NATIONAL TRUST ASSOCIATION, NOT IN ITS OFFICIAL CAPACITY
BUT SOLELY AS OWNER TRUSTEE FOR LEGACY MORTGAGE
ASSET TRUST 2018-RPL2; MFC INVESTMENTS, LLC
Respondents.
* This joint motion is the result of a settlement agreement for cases 20-CA-3586 (Parcels 129FEE1 and 129FEE2); 21-CA-314 (Parcel
327FEE); and 21-CA-658 (Parcel 113POND/TDRE). The total compensation for these parcels is $1,500,000.00 to Respondents
McCollum; $198,075.00 in attorney's fees; and $48,000.00 in expert fees. For filing purposes only, the amounts were divided per
case.
c
M
N
LLI
LLI
LL
CD
N
r
r
Lu
Lu
LL
CD
N
r
LLI
0
M
r
r
Packet Pg. 1007
16. K.5.c
STIPULATED FINAL JUDGMENT AS TO PARCELS 113POND/TDRE AND 327FEE*
THIS CAUSE, having come before this Court upon the Joint Motion made by Petitioner,
COLLIER COUNTY, FLORIDA, and Respondents, GERALD W. MCCOLLUM AKA WAYNE
MCCOLLUM; AND SYBLE W. MCCOLLUM AKA SYBLE MCCOLLUM, by and through
counsel, for the entry of a Stipulated Final Judgment as to Parcels 113POND/TDRE in case 21-
CA-658, and Parcel 327FEE in case 21-CA-314, 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, GERALD W. MCCOLLUM AKA WAYNE MCCOLLUM; AND
SYBLE W. MCCOLLUM AKA SYBLE MCCOLLUM, shall recover from Petitioner, COLLIER
COUNTY, FLORIDA, the total sum of Five Hundred Thousand and No/100 Dollars
($500,000.00) for Parcel 113POND/TDRE, as full payment for the property interest taken,
including any and all business damages, in connection with said parcel.
2. Respondents, GERALD W. MCCOLLUM AND SYBLE W. MCCOLLUM, shall
recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Sixty -Six Thousand
Twenty -Five and No/100 Dollars ($66,025.00), for all attorney fees and costs associated with the
acquisition of Parcel I I3POND/TDRE. No other attorney's fees or costs will be paid in this matter
3. Respondents, GERALD W. MCCOLLUM AND SYBLE W. MCCOLLUM, shall
recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Sixteen Thousand
Dollars and No/100 Dollars ($16,000.00), for all expert fees and costs associated with the
* This joint motion is the result of a settlement agreement for cases 20-CA-3586 (Parcels 129FEE1 and 129FEE2); 21-CA-314 (Parcel
327FEE); and 21-CA-658 (Parcel 113POND/TDRE). The total compensation for these parcels is $1,500,000.00 to Respondents
McCollum; $198,075.00 in attorney's fees; and $48,000.00 in expert fees. For filing purposes only, the amounts were divided per
case.
Packet Pg. 1008
16. K.5.c
acquisition of Parcel 113POND/TDRE, 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 Six Hundred Sixty -Four Thousand
Two Hundred Dollars and No/100 ($664,200.00), as payment for the acquisition of Parcel
I I3POND/TDRE, at which time title to said parcel as described in Exhibit "A" vested in the name
of Petitioner COLLIER COUNTY, FLORIDA.
5. At the time of construction of the Vanderbilt Beach Road expansion project, the
County shall construct a single-family home residential driveway substantially similar to and in
the approximate location of the existing driveway at the southeast corner of Tract C of the
Respondents' property (Parcel I I3POND/TDRE). Respondents hereby provide the County with a
temporary license and right of entry to access, construct, and complete the driveway.
6. Respondents, GERALD W. MCCOLLUM AKA WAYNE MCCOLLUM; AND
SYBLE W. MCCOLLUM AKA SYBLE MCCOLLUM, shall recover from Petitioner, COLLIER
COUNTY, FLORIDA, the total sum of Five Hundred Thousand and No/100 Dollars
($500,000.00) for Parcel 327FEE, as full payment for the property interest taken, including any
and all business damages, in connection with said parcel.
7. Respondents, GERALD W. MCCOLLUM AND SYBLE W. MCCOLLUM, shall
recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Sixty -Six Thousand
Twenty -Five and No/100 Dollars ($66,025.00), for all attorney fees and costs associated with the
acquisition of Parcel 327FEE. No other attorney's fees or costs will be paid in this matter.
8. Respondents, GERALD W. MCCOLLUM AND SYBLE W. MCCOLLUM, shall
* This joint motion is the result of a settlement agreement for cases 20-CA-3586 (Parcels 129FEE1 and 129FEE2); 21-CA-314 (Parcel
327FEE); and 21-CA-658 (Parcel 113POND/TDRE). The total compensation for these parcels is $1,500,000.00 to Respondents
McCollum; $198,075.00 in attorney's fees; and $48,000.00 in expert fees. For filing purposes only, the amounts were divided per
case.
Packet Pg. 1009
16. K.5.c
recover from Petitioner, COLLIER COUNTY, FLORIDA, the total sum of Sixteen Thousand r_
N
W
Dollars and No/100 Dollars ($16,000.00), for all expert fees and costs associated with the �
0
N
acquisition of Parcel 327FEE, and no other expert fees or costs shall be paid in this matter. r
w
w
9. Petitioner, COLLIER COUNTY, FLORIDA, is entitled to a credit for the good a
N
T
faith estimate of value previously deposited in the amount of Sixty -Two Thousand Eight ui
0
Hundred Dollars and No/100 ($62,800.00), as payment for the acquisition of Parcel 327FEE, at
T
which time title to said parcel as described in Exhibit "A" vested in the name of Petitioner z
COLLIER COUNTY, FLORIDA.
10. Within thirty (30) days from the entry of this Order, Petitioner, COLLIER
COUNTY, FLORIDA, shall pay the total sum of Four Hundred Thirty -Seven Thousand Fifty
Dollars and No/100 ($437,050.00), as payment for acquisition of Parcels 113POND/TDRE and
327FEE, attorney's fees, costs, and expert fees, by issuing a check payable to Forman & Thomas
Trust Account, and mailing it to Charles R. Forman, Esq., 1301 NE 14th Street, Ocala, FL 34470.
11. Petitioner will construct the project in substantial conformance with the one
hundred percent (100%) construction plans for the project, which plans are incorporated herein by
reference.
12. This Order disposes of all claims arising out of the taking of Parcels
I I3POND/TDRE and 327FEE that have or could have been asserted in this cause.
13. As to Parcel 113POND/TDRE, a fee simple taking, being fully described in
* This joint motion is the result of a settlement agreement for cases 20-CA-3586 (Parcels 129FEE1 and 129FEE2); 21-CA-314 (Parcel
327FEE); and 21-CA-658 (Parcel 113POND/TDRE). The total compensation for these parcels is $1,500,000.00 to Respondents
McCollum; $198,075.00 in attorney's fees; and $48,000.00 in expert fees. For filing purposes only, the amounts were divided per
case.
Packet Pg. 1010
16. K.5.c
Composite Exhibit "A" attached hereto and incorporated herein, which vested in Petitioner
pursuant to the Stipulated Order of Taking dated June 10, 2021, and the deposit of money
heretofore made, is approved, ratified, and confirmed.
14. The Notice of Lis Pendens filed in this cause and recorded in Official Record Book
5904, Page 2854 of the Public Records of Collier County, Florida be dismissed as to Parcel
113POND/TDRE.
15. As to Parcel 327FEE, a fee simple taking, being fully described in Exhibit "B"
attached hereto and incorporated herein, which vested in Petitioner pursuant to the Stipulated
Order of Taking dated June 10, 2021, and the deposit of money heretofore made, is approved,
ratified, and confirmed.
16. The Notice of Lis Pendens filed in this cause and recorded in Official Record Book
5890, Page 1044 of the Public Records of Collier County, Florida be dismissed as to Parcel
327FEE.
17. This Court reserves jurisdiction to enforce the terms of this Stipulated Final
Judgment.
18. 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
2022.
THE HONORABLE ELIZABETH V. KRIER
Circuit Court Judge
* This joint motion is the result of a settlement agreement for cases 20-CA-3586 (Parcels 129FEE1 and 129FEE2); 21-CA-314 (Parcel
327FEE); and 21-CA-658 (Parcel 113POND/TDRE). The total compensation for these parcels is $1,500,000.00 to Respondents
McCollum; $198,075.00 in attorney's fees; and $48,000.00 in expert fees. For filing purposes only, the amounts were divided per
case.
Packet Pg. 1011
16. K.5.c
Composite Exhibit "A"
LEGAL DESCRIPTION (PARCEL 113 POND)
A PORTION OF THE SOUTH HALF OF THE SOUTHWEST QUARTER OF THE SOUTHWEST QUARTER OF SECTION 36. TOWNSHIP 48
SOUTH, RANGE 26 EAST, COLLIER COUNTY, FLORIDA, BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS:
COMMENCING AT THE SOUTHWEST CORNER OF SECTION 36;
THENCE N.0217'20W., ALONG THE WEST LINE OF SAID SECTION 36, FOR 60.04 FEET TO THE POINT OF BEGINNING OF THE
HEREIN DESCRIBEO PARCEL;
THENCE CONTINUE N.02'17'24'W„ ALCNG THE WEST LINE OF SAID SECTION 36, FOR BOB.97 FEET;
THENCE N.89'58'00'E„ FOR 33.43 FEET;
THENCE S.02 38'24" E.. FOR 33.14 FEET TO A POINT OF CURVATURE:
THENCE SOUTHERLY 82.58 FEET ALONG THE ARC OF A TANGENTIAL CURVE TO THE LEFT HAVING A RADIUS OF 1.931.97 FEET
THROUGH A CENTRAL ANGLE OF 02'28'57' AND BEING SUBTENDED BY A CHORD WHICH BEARS $.OY51'52'E. FOR 82.58 FEET;
THENCE S.O5'03'4O"E., FOR 93.34 FEET TO A POINT ON A CURVE;
THENCE SOUTHEASTERLY 32.63 FEET ALONG THE ARC Of A NON-TANGENTAL CURVE TO THE LEFT HAVNG A RADIUS OF 21.99
FEET THROUGH A CENTRAL ANGLE OF 65'00'57" AND BEING SUBTENDED BY A CHORD WHICH BEARS S.4732'28'E. FOR 29.71
FEET TO A POINT OF REVERSE CURVATURE;
THENCE EASTERLY 481.42 FEET ALONG THE ARC OF A REVERSE CURVE TO THE RIGHT HAVING A RADIUS OF 684.09 FEET
THROUGH A CENTRAL ANGLE OF 4719'16" AND BEING SUBTENDED 8Y A CHORD WHICH BEARS S.69'53'19'E. FOR 471.55 FEET
TO A POINT OF REVERSE CURVATURE;
THENCE EASTERLY 549.72 FEET ALONG THE ARC OF A REVERSE CURVE TO THE LEFF HAVING A RADIUS OF 780,96 FEET
THROUGH A CENTRAL ANGLE OF 40'19'50" AND BEING SUBTENDED BY A CHORD WHICH BEARS S.69'53'35'E. FOR 538.44 FEET
TO A POINT OF REVERSE CURVATURE;
THENCE EASTERLY 327.64 FEET ALONG THE ARC OF A REVERSE CURVE TO THE RIGHT 14AANG A RADIUS OF 5,951,58 FEET
THROUGH A CENTRAL ANGLE OF OY09'15" AND BEING SUBTENDED BY A CHORD WHICH BEARS 5.5B'28'53*E. FOR 327.60 FEET;
THENCE S.OZ'24'19'E., FOR 21,94 FEET;
THENCE S.8W54'28'W., ALONG THE NORTH LINE OF THE SOUTH 60 FEET OF SAID SECTION 35. FOR 1,323.17 Ft ET TO THE
POINT OF BEGINNING OF THE PARCEL DESCRIBED HEREIN:
CONTAINING 228.953 SQUARE FEET OR 5.26 ACRES. MORE OR LESS. . ► ► ► f ' +' f r
BEARINGS ARE BASED ON STATE PLANE COORDINATES, FLORIDA EAST ZONE.
LEGAL DESCRIPTION (PARCEL 113 TORE)
A PORTION OF THE SOUTH HALF OF THE SOUTHWEST QUARTER OF THE SOUTHWEST QUARTER OF 5ECTION 36.
TOWNSHIP 48 SOUTH, RANGE 25 EAST, COLLIER COUNTY, FLORIDA, BEING MORE PARTICULARLY DESCRIBED AS
FOLLOWS:
COMMENCING AT THE SOUTHWEST CORNER OF SECTION 36;
THENCE N.02'17'24"W.. ALONG THE WEST LINE OF SAID SECTION 36, FOR 669.01 FEET;
THENCE N.8W58'O0'E„ FOR 33.43 FEET TO THE POINT OF BEGINNING OF THE HEREIN DESCRIBED PARCEL;
THENCE N.89'59'55"E., FOR 35.04 FEET;
THENCE S.02'38'24'E., FOR 31.53 FEET TO A POINT OF CURVATURE;
THENCE SOUTHERLY 26.04 FEET ALONG THE ARC OF A TANGENTIAL CURVE TO THE LEFT
1,008.31 FEET THROUGH A CENTRAL ANCLE OF 00'49'31' AND BEING SUBTENDED BY A
S.03'03'09'E. FOR 26.04 FEET:
THENCE S.86'33'4B'W.. FOR 35.00 FEET TO A POINT ON A CURVE,,
THENCE NORTHERLY 26.53 FEET ALONG THE ARC OF A NON -TANGENTIAL CURVE TO THE
1,977.UO FEET THROUGH A CENTRAL ANGLE OF 00"46'08" AND BEING SUBTENDED BY A
N.03-03'08iV. FOR 26.53 FEET;
THENCE N.02'38'24'W., FOR 33.14 FEET TO T14F POINT OF BEGINNING OF THE PARCEL
CONTAINING 2,052 SQUARE FEET, MORE OR LESS.
HAVING A RADIUS OF
CHORD WHICH REARS
RIGHT HAVING A RADIUS OF
CHORD WHICH BEARS
DESCRIBED HEREJN,; k i r i ,
*This joint motion is the result of a settlement agreement for cases 20-CA-3586 (Parcels 129FEE1 and 129FEE2); 21-CA-314 (Parcel
327FEE); and 21-CA-658 (Parcel 113POND/TDRE). The total compensation for these parcels is $1,500,000.00 to Respondents
McCollum; $198,075.00 in attorney's fees; and $48,000.00 in expert fees. For filing purposes only, the amounts were divided per
case.
c
�a
N
W
LU
LL
0)
N
LU
LU
LL
M
N
T-
LU
H
Cl)
Packet Pg. 1012
16. K.5.c
Exhibit "B"
LEGAL DESCRIPTION (PARCEL 327 FEE)
UARTER OF SECTION
TOWNSHIPN48FSOUTH,THE QRTH HALF RANGE 25 OF THE EAST, COWERWEST QUARTER OF THE COUNTYFLORIDA. BEING MORSOUTHWEST
�QCULARLY DESCRIBED AS
FOLLOWS:
THE WEST 35 FEET OF THE NORTH HALF OF THE SOUTHWESi QUARTER OF THE SOUTHWEST QUARTER OF SECTION 36,
TOWNSHIP 48 SOUTH, RANGE 26 EAST. COWER COUNTY, FLORIDA,
CONTAINING 23,415 SQUARE FEET. MORE OR LESS. .�•`_y �`��I18E� , ' �'�
BEARINGS ARE BASED ON STATE PLANE COORDINATES, FLORIDA EAST ZONE ,� ti";.••• G',
ectlfi�af. •..�
* This joint motion is the result of a settlement agreement for cases 20-CA-3586 (Parcels 129FEE1 and 129FEE2); 21-CA-314 (Parcel
327FEE); and 21-CA-658 (Parcel 113POND/TDRE). The total compensation for these parcels is $1,500,000.00 to Respondents
McCollum; $198,075.00 in attorney's fees; and $48,000.00 in expert fees. For filing purposes only, the amounts were divided per
case.
Packet Pg. 1013