Agenda 05/24/2022 Item #16K 8 (Settlement Agreement for Case #21-CA-952 - Juarez)05/24/2022
EXECUTIVE SUMMARY
Recommendation to approve and authorize the Chair to execute a Settlement Agreement in the
lawsuit styled S.J. a minor, by and through her natural parents and guardians, Amy Juarez and Jose
Juarez v. Collier County Board of Commissioners, (Case No. 21-CA-952), now pending in the Circuit
Court of the Twentieth Judicial Circuit in and for Collier County, Florida, for the sum of $150,000.
_____________________________________________________________________________________
OBJECTIVE: Recommendation to approve the settlement in the lawsuit filed by S.J. a minor, by and
through her natural parents and guardians, Amy Juarez and Jose Juarez for the sum of $150,000 and
authorize the Chair to execute the Settlement Agreement.
CONSIDERATIONS: This lawsuit arises out of an accident that occurred on June 18, 2018, at the
Eagle Lakes Community Park summer camp program. The Plaintiff alleged the camp counselors at the
park negligently supervised the campers causing the Plaintiff’s injury. As a res ult of the accident, the
Plaintiff sustained multiple fractures of her leg due to a larger camper colliding with her inside the bounce
house. She has undergone one surgical procedure to date with at least one future procedure confirmed to
be needed in relation to the injury.
The Plaintiff’s past medical expenses totaled $41,578.74. 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 $150,000.
The County Attorney and the Risk Management Director recommend that the Board approve this
settlement as reasonable.
FISCAL IMPACT: Funds are budgeted and available in Fund 516, Property & Casualty Insurance Fund
and the total impact will be $150,000.
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 $150,000 in the lawsuit styled S.J. a
minor, by and through her natural parents and guardians, Amy Juarez and Jose Juarez v. Collier County
Board of Commissioners, (Case No. 21-CA-952), 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-Juarez_Redacted (PDF)
16.K.8
Packet Pg. 1498
05/24/2022
COLLIER COUNTY
Board of County Commissioners
Item Number: 16.K.8
Doc ID: 22277
Item Summary: Recommendation to approve and authorize the Chair to execute a Settlement
Agreement in the lawsuit styled S.J. a minor, by and through her natural parents and guardians, Amy
Juarez and Jose Juarez v. Collier County Board of Commissioners, (Case No. 21-CA-952), now pending
in the Circuit Court of the Twentieth Judicial Circuit in and for Collier County, Florida, for the sum of
$150,000.
Meeting Date: 05/24/2022
Prepared by:
Title: Legal Assistant – County Attorney's Office
Name: Rosa Villarreal
05/16/2022 1:25 PM
Submitted by:
Title: County Attorney – County Attorney's Office
Name: Jeffrey A. Klatzkow
05/16/2022 1:25 PM
Approved By:
Review:
Risk Management Jeff Walker Additional Reviewer Completed 05/16/2022 2:10 PM
County Attorney's Office Colleen Kerins Level 2 Attorney Review Completed 05/16/2022 2:41 PM
Office of Management and Budget Debra Windsor Level 3 OMB Gatekeeper Review Completed 05/16/2022 2:45 PM
Office of Management and Budget Laura Wells Additional Reviewer Completed 05/16/2022 2:52 PM
County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 05/16/2022 3:40 PM
County Manager's Office Dan Rodriguez Level 4 County Manager Review Completed 05/17/2022 9:49 AM
Board of County Commissioners Geoffrey Willig Meeting Pending 05/24/2022 9:00 AM
16.K.8
Packet Pg. 1499
16.K.8.a
Packet Pg. 1500 Attachment: Executed settlement agreement-Juarez_Redacted (22277 : Approve settlement agreement in S.J. a minor through her natural
16.K.8.a
Packet Pg. 1501 Attachment: Executed settlement agreement-Juarez_Redacted (22277 : Approve settlement agreement in S.J. a minor through her natural
16.K.8.a
Packet Pg. 1502 Attachment: Executed settlement agreement-Juarez_Redacted (22277 : Approve settlement agreement in S.J. a minor through her natural
16.K.8.a
Packet Pg. 1503 Attachment: Executed settlement agreement-Juarez_Redacted (22277 : Approve settlement agreement in S.J. a minor through her natural
16.K.8.a
Packet Pg. 1504 Attachment: Executed settlement agreement-Juarez_Redacted (22277 : Approve settlement agreement in S.J. a minor through her natural
16.K.8.a
Packet Pg. 1505 Attachment: Executed settlement agreement-Juarez_Redacted (22277 : Approve settlement agreement in S.J. a minor through her natural