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Agenda 02/28/2023 Item #16K 3 (County Attorney to file a lawsuit on behalf of the BCC against Elizabeth McGuire to recover damages incurred for the repair of a Collier County vehicle involved in a vehicle accident)16. K.3 02/28/2023 EXECUTIVE SUMMARY Recommendation to authorize the County Attorney to file a lawsuit on behalf of the Collier County Board of County Commissioners against Elizabeth McGuire in the County Court of the Twentieth Judicial Circuit in and for Collier County, Florida, to recover damages incurred by the County for the repair a Collier County truck involved in a motor vehicle accident with Elizabeth McGuire totaling $1,860.79, plus costs of litigation. OBJECTIVE: For the Board of County Commissioners to authorize the County Attorney to file a lawsuit on behalf of the Collier County Board of County Commissioners, against Elizabeth McGuire to recover damages in the amount of $1,860.79, plus costs of litigation. CONSIDERATIONS: On February 23, 2022, Jonathan Perez, a Utility Specialist with the Water Division was driving a Collier County Ford truck when the vehicle was struck by a 2020 Lincoln driven by Elizabeth McGuire. The accident was witnessed by Detective Brenden Fahey of the Collier County Sheriff's Office who subsequently responded to the accident and found Elizabeth McGuire at fault for the accident. The County incurred damages in the amount of $1,860.79. Despite repeated demands, Elizabeth McGuire's insurance carrier, Allstate Fire & Casualty Insurance Company, has refused and continues to refuse to reimburse the County for the necessary repairs. The County has no other recourse for recovery of the costs than to proceed with litigation. FISCAL IMPACT: Filing fees, service and process fees total approximately $185.00. Funds are budgeted and available in the Risk Management Property & Casualty Fund (516). GROWTH MANAGEMENT IMPACT: There is no growth management impact associated with this item. LEGAL CONSIDERATIONS: The County Attorney has reviewed and approved this item. This item is legally sufficient for Board action and requires majority vote for approval. - CAK RECOMMENDATION: That the Board of County Commissioners authorize the County Attorney to file a lawsuit on behalf of the Collier County Board of County Commissioners, against Elizabeth McGuire, in the County Court of the Twentieth Judicial Circuit in and for Collier County, Florida, to recover damages incurred by the County for the repair of the Ford F150 in the amount of $1,860.79, plus costs of litigation. PREPARED BY: Colleen A. Kerins, Assistant County Attorney Michael K. Quigley, Risk Management Division Director ATTACHMENT(S) 1. McGuire COMPLAINT (PDF) 2. McGuire Pre -suit demand letter to allstate (PDF) Packet Pg. 1395 16. K.3 02/28/2023 COLLIER COUNTY Board of County Commissioners Item Number: 16.K.3 Doc ID: 24673 Item Summary: Recommendation to authorize the County Attorney to file a lawsuit on behalf of the Collier County Board of County Commissioners against Elizabeth McGuire in the County Court of the Twentieth Judicial Circuit in and for Collier County, Florida, to recover damages incurred by the County for the repair a Collier County truck involved in a motor vehicle accident with Elizabeth McGuire totaling $1,860.79, plus costs of litigation. Meeting Date: 02/28/2023 Prepared by: Title: Legal Assistant — County Attorney's Office Name: Rosa Villarreal 02/13/2023 3:36 PM Submitted by: Title: County Attorney — County Attorney's Office Name: Jeffrey A. Klatzkow 02/13/2023 3:36 PM Approved By: Review: Risk Management County Attorney's Office Office of Management and Budget County Attorney's Office Office of Management and Budget County Manager's Office Board of County Commissioners Michael Quigley Additional Reviewer Colleen Kerins Level 2 Attorney Review Debra Windsor Level 3 OMB Gatekeeper Review Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Christopher Johnson Additional Reviewer Amy Patterson Level 4 County Manager Review Geoffrey Willig Meeting Pending Completed 02/13/2023 4:05 PM Completed 02/15/2023 10:41 AM Completed 02/15/2023 10:55 AM Completed 02/15/2023 4:12 PM Completed 02/16/2023 11:57 AM Completed 02/21/2023 12:31 PM 02/28/2023 9:00 AM Packet Pg. 1396 16. K.3.a IN THE COUNTY COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA SMALL CLAIMS DIVISION COLLIER COUNTY BOARD OF COUNTY COMMISSIONERS, Plaintiff, V. ELIZABETH MCGUIRE, Defendant. COMPLAINT FOR DAMAGES Case No. COMES NOW, the Plaintiff, COLLIER COUNTY BOARD OF COUNTY COMMISSIONERS (hereinafter "the County"), by and through undersigned counsel, hereby sets forth its Complaint against ELIZABETH MCGUIRE for damages and negligence and states to the Court in support as follows: 1. This is an action for damages that exceeds $500.00 but does not exceed $2,500.00. 2. All events and occurrences set forth occurred and took place in Collier County, Florida. 3. Collier County is a political subdivision of the State of Florida. 4. At all times material, the Defendant, Elizabeth McGuire, was sui juris and a resident of Collier County, Florida. 5. This Court has jurisdiction over all parties and venue is proper in Collier County, Florida. 6. On February 23, 2022, Elizabeth McGuire was operating a motor vehicle at or about 3:08 p.m. at the intersection of Golden Gate Parkway and Livingston Road in Naples, Florida. F- z a J IL 2 O 0 as c as E M Q [ 22-R M G-00719/ 1740427/1] Packet Pg. 1397 16. K.3.a 7. Elizabeth McGuire was traveling east bound in the right lane of Golden Gate Parkway and was turning south onto Livingston Road when she began to make the right turn and turned into the Plaintiff's vehicle. Jonathan Perez, in the course and scope of his employment, was driving a 2017 Ford truck owned by the Plaintiff, Collier County Board of County Commissioners. 8. Elizabeth McGuire failed to use due care and caused property damage to the vehicle owned by the Plaintiff. 9. Elizabeth McGuire had a duty to operate her vehicle in a reasonable, responsible and safe manner towards the public, in general, and towards any and all vehicles and property surrounding the area in which she was operating her vehicle. 10. Elizabeth McGuire breached her duty and was negligent in failing to use due care when she struck the Plaintiff's vehicle traveling on Livingston Road. 11. As a result of the negligence of Elizabeth McGuire, the County suffered property damage in the amount of $1,860.79 to repair the County owned and maintained vehicle, plus statutorily accruing interest. 12. Although requested to pay these damages, Elizabeth McGuire has refused and continues to refuse to pay the damages, which necessitated the filing of this action. WHEREFORE, Plaintiff, COLLIER COUNTY BOARD OF COUNTY COMMISSIONERS, demands judgment against the Defendant, Elizabeth McGuire, for all aforementioned damages, legal interest, and interest from the entry of judgment until paid, plus cost of litigation, and any further relief this Court deems just and proper. CERTIFICATE OF SERVICE ON NEXT PAGE [ 22-R M G-00719/ 1740427/1] Packet Pg. 1398 16. K.3.a CERTIFICATE OF SERVICE The undersigned attorney hereby certifies that a true and correct copy of the above and foregoing has been filed with the Florida Courts E-Filing Portal, which will send an electronic notification to Elizabeth McGuire, 8288 Lucello Terrace N, Naples, FL, 34114, on this day of 2023. COLLIER COUNTY, FLORIDA By: COLLEEN A. KERINS, ESQ. Florida Bar No. 91752 Collier County Attorney's Office 3299 East Tamiami Trail, Suite 800 Naples, Florida 34112-5746 Telephone: (239) 252-8400 Facsimile: (239) 252-6300 Counsel for Plaintiff COLLIER COUNTY colleen. kerinskcolliercountyfl. gov rosa.villarrealncolliercountyfl. gov marian.rh nekcolliercount�fl.gov [ 22-R M G-00719/ 1740427/1] Packet Pg. 1399 Office of the County Attorney Jeffrey A. Klatzkow Deputy County Attorney • Scott R. Teach Managing Assistant County Attorneys • Colleen M. Greene • Heidi F. Ashton-Cicko* *Board Certified City, County and Local Government Law Assistant County Attorneys • Sally A. Ashkar • Colleen A. Kerins • Derek D. Perry • Ronald Tomasko August 24, 2022 VIA EMAIL TO CLAIMS@CLAIMS.ALLSTATE.COM Claims Department Allstate Fire & Casualty Insurance Company 2775 Sanders Road Northbrook, IL 60062 RE: Claim Number 0660217472 Date of Loss: February 23, 2022 Your Insured: Elizabeth McGuire PRE -SUIT DEMAND LETTER ON BEHALF OF COLLIER COUNTY BOARD OF COUNTY COMMISSIONERS To Whom It May Concern: Please be advised that this matter has been forwarded to the County Attorney's Office for future handling on behalf of the Collier County Board of County Commissioners. As you are aware, on February 23, 2022, a vehicle owned and driven by your insured, Elizabeth McGuire, caused an accident in which a truck owned and maintained by Collier County was struck and damaged, causing $1,860.79 in damage. At the time of the accident, Jonathan Perez, an employee of the Collier County Board of County Commissioners, was driving a 2017 Ford truck, under the ownership and control of the Collier County Board of County Commissioners, southbound on Livingston Road in Naples, Florida. Your insured, Ms. Elizabeth McGuire was traveling eastbound on Golden Gate Parkway attempting to make a right turn onto Livingston Road when she hit the County's vehicle. As repeatedly pointed out to your adjuster, not only did CSD Branden Fahey (Badge Number 4428) from the Collier County Sheriff s Office respond to the accident, but he also personally witnessed the accident and assigned fault to your insured. Despite the personal observations of the responding officer, Allstate has continued to deny the County's property damage claim. As you can see from the documents attached, fault for the vehicle accident in question clearly falls upon your insured. Please review the enclosures, which includes the draft Complaint that will be filed should Allstate not reverse its denial of the claim. The incident report, pictures of the vehicle damage, and proof of costs incurred by the County are also attached for your review and consideration. 3299 East Tamiami Trail, Suite 800 • Naples Florida 34112-5749 • (239) 252-8400 • FAX: (239) 252-6300 Packet Pg. 1400 16. K.3.b The County is hopeful that after a further review, you will accept responsibility and reimburse Collier County the $1,860.79, incurred. Therefore, please send your payment, made out to the "Collier County Board of County Commissioners" and mail it to: Collier County Attorney's Office Attn: Colleen Kerins, Esquire 3299 East Tamiami Trail -Suite 800 Naples, FL 34112 Failure to remit payment within 10 days will result in the County Attorney's Office seeking Board of County Commissioner approval to file suit against your insured, Elizabeth McGuire, for the full amount of damages, plus any costs of litigation and statutory interest. Please kindly respond to this letter within 10 days from the date of receipt. Sincerely, Colleen A. Kerins Assistant County Attorney Enclosures cc: Elizabeth McGuire, 8288 Lucello Ter. N, Naples, FL 34114 [22-RMG-00719/1740434/113299 East Tamiami Trail, Suite 800 • Naples Florida 34112-4902 • (239) 252-8400 • FAX: (239) 252-6300 Packet Pg. 1401 IN THE COUNTY COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL ACTION COLLIER COUNTY BOARD OF COUNTY COMMISSIONERS, Plaintiff, V. ELIZABETH MCGUIRE, Defendant. COMPLAINT FOR DAMAGES Case No. COMES NOW, the Plaintiff, COLLIER COUNTY BOARD OF COUNTY COMMISSIONERS (hereinafter "the County"), by and through undersigned counsel, hereby sets forth its Complaint against ELIZABETH MCGUIRE for damages and negligence and states to the Court in support as follows: 1. This is an action for damages that exceeds $500.00 but does not exceed $2,500.00. 2. All events and occurrences set forth occurred and took place in Collier County, Florida. 3. Collier County is a political subdivision of the State of Florida. 4. At all times material, the Defendant, Elizabeth McGuire, was sui juris and a resident of Collier County, Florida. 5. This Court has jurisdiction over all parties and venue is proper in Collier County, Florida. 6. On February 23, 2022, Elizabeth McGuire was operating a motor vehicle at or about 3:08 p.m. at the intersection of Golden Gate Parkway and Livingston Road in Naples, Florida. [ 2 2- R M G-00719/ 17404 27 / 1 Packet Pg. 1402 7. Elizabeth McGuire was traveling east bound in the right lane of Golden Gate Parkway and was turning south onto Livingston Road when she began to make the right turn and turned into the Plaintiff's vehicle. Jonathan Perez, in the course and scope of his employment, was driving a 2017 Ford truck owned by the Plaintiff, Collier County Board of County Commissioners. 8. Elizabeth McGuire failed to use due care and caused property damage to the vehicle owned by the Plaintiff. 9. Elizabeth McGuire had a duty to operate her vehicle in a reasonable, responsible and safe manner towards the public, in general, and towards any and all vehicles and property surrounding the area in which she was operating her vehicle. 10. Elizabeth McGuire breached her duty and was negligent in failing to use due care when she struck the Plaintiff's vehicle traveling on Livingston Road. 11. As a result of the negligence of Elizabeth McGuire, the County suffered property damage in the amount of $1,860.79 to repair the County owned and maintained vehicle, plus statutorily accruing interest. 12. Although requested to pay these damages, Elizabeth McGuire has refused and continues to refuse to pay the damages, which necessitated the filing of this action. WHEREFORE, Plaintiff, COLLIER COUNTY BOARD OF COUNTY COMMISSIONERS, demands judgment against the Defendant, Elizabeth McGuire, for all aforementioned damages, legal interest, and interest from the entry of judgment until paid, plus cost of litigation, and any further relief this Court deems just and proper. CERTIFICATE OF SERVICE ON NEXT PAGE [ 22- R M G-00719/ 17404 27/ 1] Packet Pg. 1403 CERTIFICATE OF SERVICE The undersigned attorney hereby certifies that a true and correct copy of the above and foregoing has been filed with the Florida Courts E-Filing Portal, which will send an electronic notification to Elizabeth McGuire, 8288 Lucello Terrace N, Naples, FL, 34114, on this day of 2022. COLLIER COUNTY, FLORIDA COLLEEN A. KERINS, ESQ. Florida Bar No. 91752 Collier County Attorney's Office 3299 East Tamiami Trail, Suite 800 Naples, Florida 34112-5746 Telephone: (239) 252-8400 Facsimile: (239) 252-6300 Counsel for Plaintiff COLLIER COUNTY colleen.kerinsncolliercountyfl.gov rosa.villarrealga,colliercountyfl.gov marian.rhynegcolliercountyfl.gov [ 22- R M G-007 19/17404 27/ 11 Packet Pg. 1404 44 ® GMC � BUICK BUBARU 1411 Solana Rd Naples, FL 34103 Phone: (239) 649-1400 2901 COUNTY BARN RD PO 4500215011 NAPLES, FL 34112-2302 SERVICE DEPARTMENT HOURS 7:30 a.m. to 6:00 p.m. Monday - Friday 8:00 a.m. to 3:00 p.m. Saturday 239-252-4118 239-252-2277 02/24/22 8005110/-' 03/25/22 Pre-Invoic 68151 1 68151 BONNIE HAMM/B5053 1FTMF1C80HKC37207 12017 1 FORD I F-150 I XL 2WD REG CAB 811 CC2-1456 : 239-537-6402 AR#: #1 - 61BUZ: BODY SHOP REPAIRS REPAIR AS PER ESTIMATE Tech: LEONARDO ESPERANZA (716) Sub Total: 1293.60 ------------------------------------------------------------------- #2 - 63BUZ: REFINISH BODY SHOP REFINISH AS PER ESTIMATE Tech: FRANCISCO MARTINEZ (625) Sub Total: 260.40 ------------------------------------------------------------------- Paint & Materials SERVICE: ALL ORIGINAL EQUIPMENT REPLACEMENT PARTS HAVE A 2 YEAR OR LABOR 24,000 MILE WARRANTY (LABOR MAY APPLY) BODY SHOP: ALL REPLACEMENT PARTS ARE GUARANTEED AS SPECIFIED BY PARTS DEDUCTIBLE INDIVIDUAL MANUFACTURER'S WARRANTY. COLLISION LABOR AND PAINT ARE GUARANTEED FOR AS LONG AS YOU OWN THIS VEHICLE. SUBLET DISCLAIMER OF WARRANTY The only warranties applying to this part(s) are those which may be offered by the manufacturer. Manufacturer's parts and related labor are guaranteed for 12 months or 12,000 miles, whichever comes first. The selling dealer hereby expressly disclaims all warranties, either expressed or implied, including any Implied warranties of merchantibility SHOP SUPPLIES HAZARDOUS MATERIALS SALES TAX OR TAX I.D. XXXXXXXXXX52C or fitness for a particular purpose, and neither assumes nor authorizes any other person to assume for it any liability in connection with the sale of this part(s) and/or service. Buyer shall not be entitled to recover from the selling dealer any consequential damages, damages to property, damages for loss of use, loss of time, loss of profits or income, or any other incidental damages. SPECIAL ORDER DEPOSIT DISCOUNTS TOTAL DUE 1293.6 260.4 148.8 1 1 1 1 1 1 1 K1 Packet Pg. 1405 1 WO Company:00I COLLIER COUNTY WO Department: 253212 WATER SERVICE DISTRIBUTION 408 WO Shop:01 Work Order Shop 01 COUNTY BARN FLEET SHOP Equipment: CC2-1456 License: TF2655 Color: White Engine: 3.5 V6 Year: 2017 GVW: 6100 Make: FORD Serial: 1 FTMF 1 C80HKC37207 Model: F 150 Misc. Field: A23 Location: Department: 253212:WATER SERVICE DISTRIBUTION 408 16. K.3.b CUSTOMER COPY *0000183930* WO#: 0000183930 N Date In: 02/24/2022 07:56 Date Out: 03/11/2022 07:00 f° WO Total Cost: 157.99 N 3 WO Status: C Last WO#:0000183930 f° Bill Code: 7 Last WO Date: 02/24/20. a Operator: 290 0 Class: 2DA:1/2 & 3/4 TON 2WD PICKUP TRUCK Company: 001 COLLIER COUNTY v Monitor Group: r Site: WSD:WATER SERVICE DISTRIBUTION 408 N •L METERS 0 WO Meter Reading Override? Eq Meter Actual LTD M 68151 Y M 68616 68616 0 PM SERVICE Due Type Type Description Due Type Type Description E 68137 A A: PM - OIL CHANGE, LUBE, 72137 C C PM FILTER 11 / 16/2022 C C PM A: PM - OIL CHANGE LUBE 05/ 16/2022 A FILTER N N REPAIRS PERFORMED r R n MID Date Labor OT SH RTY RTY Description Lab Hrs Cc a� 299 03/10/2022 0.21306 N 3 A002DP3165BN A Accident I Cab & Sheet Mtl Door 18., a� Entrance I Repair 299 03/10/2022 0.43694 N 3 A002DP3165BN A Accident I Cab & Sheet Mtl Door 37.1 E Entrance I Repair 211 02/24/2022 1.00000 N 3 A00200002OBN A Accident Cab & Sheet Mtl System 86.' n Inspect 2 a as L SUBLET REPAIRS Vendor Date Back RTY RTY Description c a� E U PARTS ISSUED a Strm Part Number Part Description RTY RTY Description QTY Unit Tot., Cost Cost Packet Pg. 1406 Strm Part Number Part Description 1 DECAL/LOGO LOGONEHICLE COLLIER COUNTY 1 SHOPSUPPLIES SHOP SUPPLIES Code Code Description RTY Date Description Parts:14.83 Labor:143.16 PARTS ISSUED RTY RTY Description C002139015513S C Capitalization Repair I Cab & Sheet Mtl I Decals Install A0021390100BN A Accident Cab & Sheet Mtl I Decals Replace MISCELLANEOUS COSTS RTY Description CREDITS Work Order Total: 157.99 Sublet: 0.00 Misc Cost: 0.00 QTY Unit Tot Cost Cc N c 1 4.10 4. 5 2.15 10.' Misc. Cc ? Credit Amou s Credit: 0.00 Packet Pg. 1407 FLORIDA TRAFFIC CRASH REPORT LONG FORM F7 SHORT FORM ff] UPDATE ❑ (Electronic Version) Date of Crash Time of Crash Date of Report Invest 23/Feb/2022 03:08 PM 23/Feb/2022 03:08 PM 23/Feb/2022 12:00 AM CRASH IDENTIFIERS County Code City Code County of Crash Place or 64 52 COLLIER Time on Scene Time Cleared Scene Completed �R.ason(iflnvesfigationNOTT_Cor 23/Feb/2022 23/Feb/2022 03:43 Yes 03:08 PM PM ROADWAY INFORMATION HIGHWAY SAFETY & MOTOR VEHICLES, TRAFFIC CRASH RECORDS NEIL KIRKMAN BUILDING, TALLAHASSEE, FL 32399-0537 Report Number HSMV Crash Report Number 22-74328 25096150 ;rash Within City Limits Time Reported Time Dispatched NAPLES Yes 231Feb/2022 23/Feb/2022 03:08 PM 03:08 PM Notified By Law Enlorcement i Crash Occured On Street, Road, Highway 0 At Street Address# © At Lattitude and Longitude LIVINGSTON RD 26.173803-81.751209 At Feet Or Miles Direction ()From Intersection With Street, Road, Highway 0 Or From Milepost # 39 South GOLDEN GATE PKWY Road System Identifier Type Of Shoulder Type Of Intersection 4 County 1 Paved 1 Not at Intersection CRASH INFORMATION (Check if Pictures Taken) light Condition Weather Condition Roadway Surface Condition School Bus Related Manner Of Collision 1 Daylight 1 Clear 1 Dry 1 No 3 Angle First Harmful Event Type First Harmful Event First Harmful Event Location Within Interchange First Harmful Event Relation to Junction 14 1 On Roadway No 3 Intersection. Related Contributing Circumstances: Road Contributing Circumstances: Road Contributing Circumstances: Road 1 None Contributing Circumstances: Environment Contributing Circumstances: Environment Contributing Circumstances: Environment 1 None Work Zone Related Crash In Work Zone Type Of Work Zone. Workers In Work Zone Law Enforcement In Work Zone 1 No I VEHICLE (Check if Commercial) Vehicle Motor Vehicle Type Hit and Run Veh License Number State Reg. Expires Permanent Reg. VIN 1 1 Vehicle In Transport 1 No WFL161 FL 25/Dec/2022 5LMCJ2C98LUL28241 Year Make Model Style Color Extent of Damage, Est. Damage Towed Due To Damage Vehicle Removed By Rotation 2020 LINC UT BGE Minor 2000 No ELIZABETH MC GUIRE Driver Insurance Company nsurance Policy Number ALLSTATE FIRE AND CASUA 9419239060828 Name of Vehicle Owner (Check Box If Business) Current Address (Number and Street) City and State Zip Code ELIZABETH A MC GUIRE 8288 LUCELLO TER N NAPLES FL 34114 Trailer License Number State Reg. Expires Permanent Reg. VIN Year Make Length Axles One: Trailer License Number State Reg. Expires Permanent Reg. VIN Year Make Length Axles Two: Vehicle Direction On Street, Road, Highway ,, At Est. Speed Posted Speed Total Lanes Traveling: East GOLDEN GATE PKWY 45 6 CMV Configuration Cargo Body Type Area of Initial Impact Most Damaged Area s a s e t Is. Uhderc°mtW t ° ° ° ° 1e. Vndcc niW Comm GVWR/GCWR Trailer Type (trailer one) Trailer Type (trailer two) = 4Not Applicable i rs rs v ° 19.Overmm i is is :� ° is. over= 20. Windshield ra n rd 9 21.TYdlm 20. Windshield u 3 rz 11 ro a 21.7Yefier Haz. Mat. Release Haz Mat. Placard Number Class u Motor Carrier Name US DOT Number Motor Carrier Address City and State Zip Code Phone Number Comm/Non-Commercial Vehicle Body Type Vehicle Defects (one) Vehicle Defects (two) Emergency Vehicle Use Specival Function of MV 16 (Sport) Utility Vehicle 1 None 1 No 1 No Special Function Vehicle Maneuver Action Trafficway Roadway Grade Roadway Alignment Most Harmful Event Most Harmful Event Detail 5 Turning Right 4 Two -Way Divided, Positive Median Barrier 1 Level 1 Straight 2 Collision with Non -Fixed 14 Motor Vehicle In Transport Object Traffic Control Device For This Vehicle First (1) Sequence of Events Second (2) Sequence of Events Third (3) Sequence of Events Fourth (4) Sequence of Events 5 Traffic Control Signal 2 Collision with Non -Fixed Object 14 Motor Vehicle In Transport VEHICLE (Check if Commercial) U Vehicle Motor Vehicle Type Hit and Run Veh License Number State Reg. Expires Permanent Reg. VIN 2 1 Vehicle In Transport 1 No TF2655 FL 1FTMFIC80HKC37207 Year Make Model I Style Color I Extent of Damage Est. Damage Towed Due To Damage Vehicle Removed By Rotation 2017 FORD PK WHI Minor No JONATHAN PEREZ Driver Insurance Company Insurance Policy Number FLEET INSURANCE 64A3EX000001518 HSMV 90010 S Page 1 of 4 Packet Pg. 1408 Date of Crash Date of Report Invest. Agency Report Number HSMV Crash Report Number 16.K.3.b 23/Feb/2022 03:08 PM 23/Feb/2022 03:08 PM 22-74328 25096150 Name of Vehicle Owner (Check Box If Business) Current Address (Number and Street) City and State Zip Code COLLIER COUNTY BOARD OF COUNTY 3299 TAMIAMI TRL E STE 700 NAPLES FL 34112 COMISSIONERS Trailer License Number State Reg. Expires Permanent Reg. VIN Year Make Length Axles One: to W C Trailer License Number State Reg. Expires Permanent Reg. VIN Year Make Length Axles Two: Vehicle Direction On Street, Road, Highway At Est. Speed Posted Speed Total Lanes ca rave ing: South LIVINGSTON RD 45 6 r •� CMV Configuration Cargo Body Type Area of Initial Impact Most Damaged Area 3 a a 1 40 a 16 7 ls. vnaKmsaii a a s 4 a a AUndmurdW O 1e rr a 19.Ovatum Comm GVWR/GCWR 4 Not Applicable Trailer Type (trailer one) Trailer Type (trailer two) 20.4Vi:tdehield a rs u tr rs a 21.Tnila 20 Windshield a to u » rs s 21.1Ya6et Haz. Mat. Release Haz Mat. Placard Number Class O Motor Carrier Name US DOT Number d C Motor Carrier Address City and State Zip Code Phone Number L O r Comm/Non-Commercial Vehicle Body Type Vehicle Defects (one) Vehicle Defects (two) Emergency Vehicle Use Specival Function of MV Q 3 Pickup 1 None 1 No i No Special Function Vehicle Maneuver Action Trafficway Roadway Grade Roadway Alignment Most Harmful Event Most Harmful Event Detail O 13 Stopped in Traffic 4 Two -Way Divided, Positive Median Barrier 1 Level 1 Straight 2 Collision with Non -Fixed 14 Motor Vehicle in Transport O Object V Traffic Control Device For This Vehicle First (1) Sequence of Events Second (2) Sequence of Events Third (3) Sequence of Events Fourth (4) Sequence of Events 1 No Controls 2 Collision with Non -Fixed Object d 14 Motor Vehicle In Transport N 'L PERSON RECORD Person# Description Vehicle # Name Date of Birth Sex one Number Re -Exam 1 1 Driver 1 ELIZABETH A MC GUIRE 25/Dec/1945 2 Female 2393513695 No Address City State Zip Code 8288 LUCELLO TERN NAPLES FL 34114 Driver License Number State Expires DLType Req. End. Injury Severity Ejection M-260.221.45.965.0 FL 25/Dec/2029 5 E/Operator 3 No Req 1 None 1 Not Ejected Endorsement Restraint System Air Bag Deployed Helmet Use Eye Protection Seating Location Seat Seating Location Row Seating Location Other 3 Shoulder and Lap Belt 2 Not Deployed 1 Left 1 Front Used Drivers Actions at Time of Crash (first) Drivers Actions at Time of Crash (second) Driver Distracted By Vision Obstruction 2 Operated MV in Careless or Negligent Manner 1 Not Distracted 1 Vision Not Obscured Drivers Actions at Time of Crash (third) Drivers Actions at Time of Crash (fourth) Drivers Condition at Time of Crash 1 Apparently Normal Suspected Alcohol Use Alcohol Tested Alcohol Test Type Alcohol Test Result BAC Suspected Drug Use Drug Tested Drug Test Type Drug Test Result 1 No 1 No I Source of Transport to Medical Facility EMS Agency Name or ID EMS Run Number Medical Facility Transported To 1 Not Transported PERSON RECORD Person# Description Vehicle'# Name Date of Birth Sex Phone Number Re -Exam 2 1 Driver 2 JONATHAN PEREZ 08/Jul/1965 1 Mele 7087742635 No Address City State Zip Code 4065 14TH AVE SE NAPLES FL 34117 Driver License Number State Expires DLType Req. End. Injury Severity Ejection P-620-420.65.248-0 FL 08/Ju112029 1 A 3 No Req 1 None 1 Not Ejected Endorsement Restraint System Air Bag Deployed Helmet Use Eye Protection Seating Location Seat Seating Location Row Seating Location Other 3 Shoulder and Lap Belt 2 Not Deployed 1 Left 1 Front Used Drivers Actions at Time of Crash (first) Drivers Actions at Time of Crash (second) Driver Distracted By Vision Obstruction 1 No Contributing Action 1 Not Distracted 1 Vision Not Obscured Drivers Actions at Time of Crash (third) Drivers Actions at Time of Crash (fourth) Drivers Condition at Time of Crash 1 Apparently Normal Suspected Alcohol Use Alcohol Tested Alcohol Test Type Alcohol Test Result BAC Suspected Drug Use Drug Tested Drug Test Type Drug Test Result 1 No 1 No I Source of Transport to Medical Facility EMS Agency Name or ID EMS Run Number Medical Facility Transported To 1 Not Transported NARRATIVE Page 2 of 4 Packet Pg. 1409 )ate of Crash Date of Report Invest. Agency Report Number HSMV Crash Report Number 16.K.3.b 23/Febi2022 03:08 PM 23/Feb/2022 03:08 PM 22-74328 25096150 :rash occurred in the middle south bound lane of Livingston Rd just south of Golden Gate Parkway. CSD Fahey (ID 4428) witnessed the incident. '2 was stopped in traffic In the middle lane just south of Golden Gate Parkway. V1 was traveling east bound in the right turn lane of Golden Gate Parkway to go South on Ivingston Rd. V1 began making the right turn and immediately turned Into the middle lane. V1 struck V2's front right door with her front left door and fender area. S loth vehicles were removed from scene by the Drivers. to hazards present on scene. • to Injuries observed or reported on scene by all Involved. 1 found at fault for failure to use due care. REPORTING OFFICER ID/Badge # Rank and Name Department Type of Department 4428 CSD BRENDEN FAHEY COLLIER COUNTY SHERIFFS OFFICE SO i Page 3 of 4 Packet Pg. 1410 Date of Crash Date of Report Invest. Agency Report Number HSMV Crash Report Number 16.K.3.b 23/Feb/2022 03:08 PM 23/Feb/2022 03:08 PM 1 22.74328 1 25096150 Page 4 of 4 Packet Pg. 1411